If you are a California resident (as defined below) and your personal information (as defined by the CCPA) is subject to the California Consumer Privacy Act (with any implementing regulations and as may be amended from time to time, “CCPA”), please also review the below section, “Additional Information for California Residents” for additional disclosures, our Notice at Collection, and a description of your rights with regard to your personal information (as defined by the CCPA) and other information related to the CCPA.
1. The Types of Information We Collect and How We Collect It
Personal Data You Provide to Us. Depending on how you interact with us and the Services, FirstEnroll may collect the following categories of personal data from or about you, including:
Identifiers and similar information such as a name, address, phone number, date of birth, email address, Social Security number, or other similar identifiers.
Additional information protected under certain federal or state laws, like a signature, insurance policy number, credit card, bank account, or other financial information.
Characteristics of protected classifications under certain federal or state laws, including gender, age, and marital status.
Internet or other electronic network activity information, including interactions with our Website or use of certain online tools.
Please note that some of this information may be considered sensitive personal data or sensitive personal information under applicable law.
Information We Collect from Other Sources. We may also collect personal data from other sources including our third-party partners and business customers. For example, we may receive personal data including your name, email address, and Social Security number from our agents when you enroll in our Services.
2. How We Use the Personal Data We Collect
How we use your personal data may vary depending on how you interact with us and our Services. Generally, we use data we collect about you primarily to provide our Services to you in accordance with any contract with you, communicate with you, and manage and improve our Services for you and our customers, as permitted by applicable law.
FirstEnroll may collect, use, and process your personal data for various business or commercial purposes, including to:
Provide you with our Services, including managing and administering our Services;
Process transactions as necessary to meet our contractual obligations to you;
Perform our contractual obligations to a customer;
Comply with our legal or regulatory obligations;
Improve the Website and learn how visitors use the Website;
Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including preventing fraud; and
Other purposes disclosed at the time you provide your information or otherwise with your consent.
We may use information for any purpose if the information does not identify you and cannot be combined with other information accessible to us to identify you.
3. How We Share the Personal Data We Collect
Depending on how you interact with us and our Services, FirstEnroll may share your personal data in the following circumstances with the following entities:
Your Insurance Company. We may share or otherwise provide your personal data to your insurance company in order to provide our Services.
Service Providers. We may share your personal data with vendors and service providers that perform services on our behalf in association with the operation of our Website and provision of our Services. For example, we may hire other companies to handle payment processing, provide data storage, help us operate the Services or our business, provide technical support, provide call center services, and assist in marketing.
Consent. We may share your personal data with your consent or at your direction.
Sale or Transfer of Business or Assets. We may disclose and transfer information we have collected about you in connection with a merger, consolidation, restructuring, the sale or transfer of some or all of our interests and/or assets, or other corporate changes, including in connection with any due diligence process.
Legal Matters. We may disclose your information where required to comply with law (including applicable regulations), or to respond to subpoenas, judicial processes, or government requests and investigations, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.
Safety and Security. We may disclose your information where we believe the disclosure is necessary or appropriate to prevent physical harm or financial loss. We may also disclose your information to protect the security of the Services, servers, networks systems, and business or as necessary to protect other business or legal interests.
Other. We reserve the right to share your personal data if required or permitted to do so by law.
We may disclose your information to third-parties for the purposes described above in How We Use the Personal Data We Collect.
Please note that we may also disclose data about you that does not identify you (and cannot be combined with other information accessible to us to identify you) for any purpose.
We require third-party service providers to protect the confidentiality of personal data and to use such personal data only for the purposes for which it was disclosed to them. FirstEnroll restricts access to personal data it collects about you to its employees and agents who have been advised as to the proper handling of such personal data and who need to know that personal data in order to provide our Services.
Please note that for purposes of this section (“How We Share the Personal Data We Collect”) “sharing” does not mean “sharing” as defined under the CCPA. For additional disclosures and information on our CCPA practices, please review Additional Information for California Residents below.
4. The Security Measures We Take to Safeguard Information
FirstEnroll has implemented commercially reasonable technical, administrative, and physical security measures to protect the information that we collect or receive. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.
5. Children’s Privacy
Our Website is intended for use by those over the age of 18, and minors under the age of 13 may not use the Website. We do not knowingly solicit or collect personal data on the Website from children under the age of 13. If we learn that, despite these measures, a child under the age of 13 has submitted personal data to us through the Website, we will take reasonable measures to delete such information from our records and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required by law). If you believe we might have information about your child, please contact us atMSinger@FirstEnroll.com.
6. Retention of Personal Data
FirstEnroll will retain your personal data for as long as we require it to perform our contractual rights and obligations or for our legitimate interests, or for such longer period as required by our legal or regulatory obligations. In general, we will retain your personal data throughout your relationship with us and for a reasonable period after our relationship with you has ended. To determine the appropriate retention period for your personal information, we will consider the amount, nature, and sensitivity of the personal information, the potential risk from unauthorized use or disclosure, the purposes for which we process it and whether we can achieve those purposes through other means, and applicable legal requirements.
7. Links to External Websites
9. Do Not Track
Your browser and other mechanisms may permit you to send do-not-track signals or other similar signals to express your preferences regarding online tracking. We do not currently respond to such signals.
Third-parties, such as our analytics providers, may collect data that relates to you on the Website, across time, and over other websites. We cannot control third-parties’ responses to do-not-track signals or other such mechanisms. Third-parties’ use of data relating to you and responsiveness to do-not-track signals is governed by their respective privacy policies
10. Your Choices and Rights and How to Exercise Them
If you no longer wish to receive marketing materials from us, you can let us know by contacting us at CS@FirstEnroll.com or using other unsubscribe features that we provide in our marketing communications.
Subject to local law, you may have certain additional rights regarding your personal data. These may include the following rights to: (i) access your personal data; (ii) correct inaccuracies in the data we hold about you; (iii) delete personal data we have collected from or about you; (iv) receive your personal data in a usable electronic format and transmit it to a third-party; and (v) opt out of the processing of your data for purposes of (a) targeted advertising, (b) the sale of personal data, or (c) profiling in furtherance of decisions that produce legal or similarly significant effects.
If you are a California resident, please review Additional Information for California Residents below for a description of your California-specific rights regarding your personal information.
How to Exercise Your Rights. If you would like to exercise the rights you may have with regard to your personal data, contact us at CS@FirstEnroll.com or call us at (732) 440-8600.
11. Additional Information for California Residents
The CCPA imposes certain obligations on FirstEnroll and grants certain rights to California residents (“California Resident,” “you,” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about our privacy practices, including how and why we collect, use and disclose your personal information, our Notice at Collection, and your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions under the CCPA and other limitations under applicable law, and are only available to California Residents.
Terms used in this California-specific section have the meaning ascribed to them in the CCPA. FirstEnroll is a “business.”
Notice at Collection and Use of Personal Information
Information We Collect
Depending on how you interact with us, we may collect the categories of personal information listed above in The Types of Information We Collect and How We Collect It.
Purpose for Collection and Use of Information
We may collect and use your personal information for the purposes listed above in How We Use the Personal Data We Collect.
Sale or Sharing of Personal Information
We do not sell or share your personal information (as such terms are defined under the CCPA).
How Long We Keep Information
We retain your personal information as described above in Retention of Personal Data.
Our Collection, Use, and Disclosure, of Personal Information and Sensitive Personal Information
Information We Have Collected and Our Purpose for Collecting It
In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information from the categories of sources listed above in The Types of Information We Collect and How We Collect It. We may collect all or a few of the categories of personal information for the business or commercial purposes identified in How We Use the Personal Data We Collect.
Our Disclosure of Personal Information
FirstEnroll does not sell or share your personal information (as those terms are defined under the CCPA). We do not knowingly sell or share personal information of California Residents under 16 years old.
In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as describe in the below chart:
Category of Personal Information
Category of Third Party
Identifiers (for example, your name, address, phone number, date of birth, email address, and Social Security number)
Third parties as needed to complete a transaction, including financial institutions and entities that assist with fraud prevention, Providers or partners that support our business operations (such as payment services providers, etc.), Businesses that we are evaluating in connection with a potential investment or business opportunity.
Additional information subject to Cal. Civ. Code § 1798.80(e) (for example, a signature, insurance policy n umber, financial information, or bank account information)
Third parties as needed to complete a transaction, including financial institutions and entities that assist with fraud prevention; Providers or partners that support our business operations (such as payment services providers, etc.); Businesses that we are evaluating in connection with a potential investment or business opportunity.
Characteristics of protected classifications under certain federal or state laws (for example, gender, age, national origin, citizenship, or marital status)
Third parties as needed to complete a transaction, including financial institutions and entities that assist with fraud prevention; Businesses that we are evaluating in connection with a potential investment or business opportunity.
Internet or other electronic network activity information, (for example, interactions with our Website or use of certain online tools)
Third parties as needed to complete a transaction, including financial institutions and entities that assist with fraud prevention; Providers or partners that support our business operations (such as payment services providers, etc.; Businesses that we are evaluating in connection with a potential investment or business opportunity.
In addition, in the preceding 12 months, we may have disclosed all of the categories of personal information identified above in The Types of Information We Collect and How We Collect It to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, or opposing counsel and parties to litigation; and (ii) other third parties as may otherwise be permitted by law. We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the business or commercial purposes identified above in How We Use the Personal Data We Collect.
FirstEnroll may also disclose or make available your personal information with our service providers, including our client relationship management, human resources, and information technology providers, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in or as otherwise permitted by the CCPA.
Use and Disclosure of Sensitive Personal Information
As noted above in The Types of Information We Collect and How We Collect It, under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with a right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights with regard to such personal information, including the right to:
(1) Be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which the categories of personal information shall be used.
(2) Request that FirstEnroll delete any personal information about you that we collected, subject to certain exceptions (“Request to Delete”).
(3) Correct inaccurate personal information (“Request to Correct”).
(4) Request that FirstEnroll, as a business that collects personal information about you and that discloses your personal information for a business purpose, disclose to you (“Request to Know”).
(5) Not be discriminated against because you exercised any of your rights under the CCPA.
(6) Opt-out of the “sale” (as that term is defined in the CCPA) of your personal information if a business sells your personal information (we do not).
(7) Opt-out of the “sharing” (as that term is defined in the CCPA) of your personal information if a business shares your personal information with third parties (we do not).
(8) Limit the use and disclosure of sensitive personal information where required by the CCPA (“Right to Limit”) (please note that we are not using your sensitive personal information for purposes that would require that we provide you with a Right to Limit).
The CCPA does not restrict FirstEnroll’s ability to do certain things like comply with other laws or comply with regulatory investigations. FirstEnroll also reserves the right to retain, and not to delete, certain personal information after receipt of a Request to Delete where permitted by the CCPA.
How to Submit a Request under the CCPA
If your personal information is subject to the CCPA, you may submit Requests to Know, Requests to Correct and Requests to Delete (“Consumer Rights Request”) through the following methods: on FirstEnroll’s website at https://www.firstenroll.com/contact, by emailing us at CS@FirstEnroll.com with “Consumer Rights Request” in the subject line, or by calling us at (732) 440-8600.
FirstEnroll is only required to respond to verifiable Consumer Rights Requests made by a California Resident or their legally authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit written proof that they are authorized to act on your behalf or have a power of attorney. We may deny requests from authorized agents who do not submit proof that they have been authorized by you to act on your behalf. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
Keep in mind that FirstEnroll is not required to provide information in response to Requests to Know more than twice in a 12-month period. Any response to a Request to Know will only cover the 12-month period preceding the verifiable request.
12. Notification of Changes
13. Contact Information