Notice of Privacy Practices

Your privacy is important to us. At Assertus we look forward to maintaining appropriate security standards that enable you to trust your personal information or data handled through our multiple services. These standards help us build our business relationship. At Assertus we value your trust.

This Notice of Privacy Practice (“Notice”) applies to the Services provided by ASSERTUS HOLDINGS, LLC, and/or any of its affiliates and/or subsidiaries, hereinafter, collectively referred to as ASSERTUS; as well as to our products, applications, websites, mobile applications or other platforms (collectively, the “Services”).

This Notice explains which information is collected from customers of our Services, including information that can be used to personally identify you (“Personal Information”) and how we use it. Personal information is data that identifies you or makes you identifiable. We recommend reading the details listed below.

This Notice will be in force when ASSERTUS performs actions not related to a covered entity as defined in 45 CFR 160.103. Likewise, it applies to any client or visitor of our Services. We reserve the right to amend this Notice at any time. ASSERTUS will notify you of any changes to this Notice by sending a communication to the primary email address specified in your account or by posting a public announcement on our website. The changes and/or amendments considered as significant will enter into force within thirty (30) days after notification and/or publication on our website. Non-substantial changes or clarifications will take effect immediately.

By using our Services after been notified or after a publication of changes to this Notice, it will be understood that you have authorized and accepted the terms and conditions applicable to the collection, use, and exchange of your Personal Information, which will be subject to the terms and conditions of the updated Notice. The Client and/or user acknowledges and accepts that, by accessing, using, creating an account, browsing our website, it will be considered as the Client’s consent and acceptance of all the terms and agreements of our website. Accessing or executing the action of “clicking” on the I ACCEPT icon represents your informed willingness to approve all the terms and conditions for the use of our Services and our Notice of Privacy Practices.

We encourage our Clients and/or users to consult this Notice periodically to be aware of and understand our current privacy practices.

If you have any questions regarding this Notice, please contact us:

By email:         compliance@assertus.com
By Phone:       787-622-2200
By mail:           PMB 238 #1353 Rd. 19, Guaynabo PR 00966

 

THIS PRIVACY NOTICE EXPLAINS:

WHY DO WE COLLECT AND USE YOUR INFORMATION?

At ASSERTUS, when we collect and/or use our personal information and/or the data of clients, potential clients, and/or persons with an interest in our Services, we are governed by our corporate principles, applicable security frameworks, and procedures for the management of information-gathering.

ASSERTUS only collects the information that you voluntarily provide us when visiting our website, when you create an account, contact us, access, or use our Services. These apply to any information that you voluntarily submit to us and information about how you handle the Services or information provided by cookies.

A cookie allows your browser to remember the websites you have visited before and to improve your experience when you review that website again because it recalls your preferences. When accessing some restricted use areas at our website, your browser sends the session number to our servers. This information is collected to identify the communication session. If you want to disable “cookies”, most browsers will tell you how you can do it in the “help” section. However, if you disable cookies, you may not be able to access certain areas or functionalities of our Services.

Including, but not limited to, we may use the information we collect for the following purposes:

1.    QUALITY  ASSURANCE OF PRODUCTS AND SERVICES –

Including, but not limited to: managing the details of administration, changes of conditions, updates and/or renewals of terms and conditions, policies; notifications or any communication related to our Services, providing interactive features on our Services, completing, complying with, administering and communicating with you regarding our Services. Establish service and/or support from your account and/or online profile in one of our Services; provide customer service and alert you to product or service information.

2.    MARKETING, RESEARCH, AND ADVERTISING MANAGEMENT –

Including, but not limited to: managing the details of administration, changes of conditions, updates and/or renewals of terms and conditions, policies; notify any other communication related to our Services; provide interactive features on our Services; identify product performance, incident resolutions and/or the effectiveness of our departments. Send you information about our products, services, and/or events, promotions, or offering of additional products or Services that may be of interest to you. Administration of contests, promotions, surveys, focus groups; other marketing and/or research activities.

3.    INTERNAL OPERATIONS –

Including, but not limited to: improving the effectiveness of our Services and departments; conduct research and analysis related to our operations, execute other activities related to logistics and operations, as necessary and or required.

4.    FRAUD SECURITY AND COMPLIANCE –

Including, but not limited to: protecting our assets and preventing fraudulent transactions, validating credentials and authenticating clients, customers, business partners, and/or any other entity and/or individual that may have access to all of our Services; protect the security and integrity of our Services, data and assist agencies with sufficient and/or delegated authority to investigate and respond to legal/regulatory investigations.

 

TYPE OF INFORMATION WE COLLECT

ASSERTUS may collect certain information that it can use in each and every one of the scenarios mentioned above. The information that could be collected may include aspects and/or any details related, but not limited to:

1.    IDENTIFICATION INFORMATION –

Can consist of actions such as creating a profile, an account, create a record, assign support and/or sales action, start and/or continue a Service, “chat”, call or communicating online, and/or in person. For example, name, address (billing as applicable), zip code, email address, phone number (s), mobile phone number (s), account number, account details, and/or questions and/or security responses.

2.    INFORMATION THAT YOU POST –

We collect information when you post at a public space or website. For example: on our social media profiles, ratings, and reviews.

3.    EVENT INFORMATION –

We collect this type of information when you register to participate in our events, such as contact information and postal address.

4. DEMOGRAPHIC INFORMATION –

We collect this information when you participate in a contest, promotion, and/or survey. For example, your age, gender, and zip code.

5. DRIVING LICENSE INFORMATION –

We collect your driver’s license information to the extent permitted by law. For example, to meet identity validation requirements.

 

6. DEVICE INFORMATION –

We collect this information when you visit our website and/or Services. For example, the type of device you use to access any of our platforms, your device identification number, IP address, or mobile operating system.

7. LOCATION INFORMATION –

We collect this information about your location when your device is configured to provide location information. For more information, see the section “Our Use of Information Technology” detailed below.

8. COMMERCIAL INFORMATION –

We collect this information to administer, provide access based on your account or profile related to the Services agreed with ASSERTUS.

9. INTERNET OR OTHER INFORMATION ON NETWORK ACTIVITY –

We may collect this information when you visit our website, use our mobile applications, and/or interact with our Services and other technologies; this information is collected automatically once you initiate it. For example, your browsing history, search history, and additional information about your interactions with our Services, Platforms, or advertisements.

10. OTHER INFORMATION –

If you use our website and/or services, we may collect information about the browser you are using. We can see which websites you have visited or which sites you visit when you leave us or see how often you use our Services and/or if data and/or what type of information was downloaded. If you participate in our events, we may capture images, video material and/or record sessions, among other detection and/or validation programs. When you visit our offices, we may capture images, video images and/or use facial recognition applications for security reasons. When calling our customer service and/or sales and implementation department, we log calls for quality assurance and operational optimization purposes.

HOW DO WE COLLECT INFORMATION?

1. INFORMATION THAT YOU PROVIDE US –

We may collect a variety of information when you create a profile, account, place an order,      request a quote, call, sign an agreement, register for an event, or take advantage of other programs and/or Online Services and/or in person. The information that we may collect includes your name, address, zip code, email addresses, telephone number(s), credit card number(s), among others.

2. INFORMATION WE COLLECT THROUGH DATA COLLECTION TECHNOLOGIES

We may collect information through various platforms. For example, we may collect your Personal Information when you visit our websites, use our applications, or interact with our Services or other technologies and/or Platforms. This information is collected automatically or initiated by the customer. For more information, see the next section “Our Use of Information Technology”.

3. INFORMATION ON OTHER SOURCES AND TRANSPORTATION LINES –

We may collect or use information that is made available to us through third-party platforms, online databases, and directories or other means. You should consider that this information may be governed by the privacy statement of the third party. It is possible to share information or match customer data with a third party. However, when this type of information is shared, ASSERTUS de-identifies or shares the data anonymously.

We may receive various types of information, including identification information, contact information, and transactional information from our affiliates, service providers, suppliers, Business Associates, among other entities.

Some features or functionalities of the Services they use include or provide connectivity to the services and/or interfaces of third parties, business partners, suppliers, databases, educational material, industry associations, among others. The connectivity and/or interfaces of the Services with these third parties may include direct or indirect interaction with another application, information, data, or other services. These third parties may require that the Client and/or the Users or Clients, who use and/or access such elements or functionalities of any and all ASSERTUS Services, consent, accept, comply with and remain bound to additional terms and conditions related to the terms and conditions of the third parties. The use and/or access by the Client of the characteristics or functionalities of such third parties constitutes their acceptance and recognition of being bound by any and all terms and conditions of third parties.

The use of said products or services of Third Parties and/or New Technology Companies will constitute the agreement of the Client and / or users to be bound by the terms of said Third Parties and/or New Technology Companies. The Client and/or the Users acknowledge that access to the Services will be provided through various facilities and communication lines, and the information will be transmitted through local exchange transport lines and the Internet and through routers, “switches” and other devices (collectively, “transportation lines”) owned, maintained, and serviced by Third Party carriers, utilities, and Internet service providers, all of which are outside the control of ASSERTUS.

ASSERTUS assumes no responsibility for or related to, the integrity, privacy, security, confidentiality or use of any Customer Information while it is transmitted on the carrier’s lines, or any delay, failure, interruption, interception, loss, transmission, or corruption of said Customer Information attributable to transmission on the carrier’s lines. The use of the transport lines is exclusively at the risk of the Client and is subject to all applicable local, state, national and international laws. ASSERTUS will fully comply with all transmission protocols established by industry standards.

HOW DO WE SHARE YOUR INFORMATION?

We may share your information, including, but not limited to, the following ways:

1. INTERNALLY –

We may share your information within our affiliates, service providers, vendors, Business Associates, among other entities.

2. ON OUR PLATFORMS –

For example, we may display the information you post on our Services for referrals, success stories, and/or reviews. We can also display the information that you choose to share in our profiles and/or Marketing accounts, including social networks, emails and/or reproduction of communications, reposts, and/or comments.

3. OUR SERVICE PROVIDERS –

Your information may be shared with third parties who facilitate our operations and perform services on our behalf. For example, this may include advertising and marketing providers, or any other fulfillment service provider, among others.

4. WITH OUR BUSINESS PARTNERS –

This may include third parties that provide products and services related to our business that enhance our portfolio of offerings, services, and/or product lines to help us better serve you.

5. WITH THIRD PARTIES FOR MARKETING PURPOSES –

This may include, but is not limited to, campaigns, events, social media accounts, and/or promotions with third parties. These third parties may also share your information with others. These third parties may use your information for their own promotional purposes, or for the promotional purposes of others, including the delivery of Internet-based advertising.

6. ANY SUCCESSOR TO ALL OR PART OF OUR BUSINESS –

For example, if ASSERTUS merges with, acquires or is acquired by another business entity. This may include an asset sale, corporate reorganization, or other change of control. Please note that if ASSERTUS or any of its affiliates and/or subsidiaries are sold or otherwise acquired by a third party, all data assets will become the property of the acquiring party. Said part will be subject to any consent, exclusion, or other conditions of the clients on the data. A change in data ownership may or may not include a notice on ASSERTUS primary online sites or affected affiliates and / or subsidiaries.

7. IN COMPLIANCE WITH THE LAW OR TO PROTECT US –

This could include, but is not limited to, responding to a court order or subpoena. It could also include the exchange of information if a government agency or investigative body requests. We may share information when we are investigating possible fraud. This could include fraud that we believe has occurred during any promotion.

OUR USE OF INFORMATION TECHNOLOGIES

The following section describes various types of technologies that we may use when you are interacting, supporting and / or contacting our employees, suppliers, customers, prospects, business partners and / or any person and / or entity with an interest in products and / or services. by ASSERTUS. Interactions could occur under the use, access and / or contact with any and all of our Services, online profiles, marketing channels and / or activities (including social networks) and / or interactions in person.

“COOKIES” –

For more information on this, see the section called “Assertus Statement on ‘Cookies’”.

OPTIMIZATION SERVICES –

ASSERTUS may share and/or use third-party and/or own products to analyze, interpret, understand, and optimize each and every one of the services and/or improvements. These tools may run in the background of our Services analyzing usage, collecting logs, and/or information, and then returning reports. However, credential or password data is not collected for these aspects of analysis.

SOCIAL MEDIA AND NEW TECHNOLOGY COMPANIES –

ASSERTUS has profiles on various social networks and new technology companies. These companies may have specific interest-based ad programs that match people who have shown interest in ASSERTUS through our website or other Services with their profiles (such as Facebook) and platforms (such as Facebook and Google properties). We may use this match to serve relevant interest-based ads on those companies’ networks.

MOBILE APPS –

ASSERTUS may offer mobile applications that you can download from the “application store” of your phone or smart device, as well as applications that you can download from your Internet-connected devices (for example, a smart TV).

The ASSERTUS mobile applications, with your permission, may use your device’s camera, microphone, or location information to enable functions or services.

The ASSERTUS mobile application preferences can be managed through the ASSERTUS mobile application and in the settings of your device.

MANAGING YOUR PREFERENCES

This section details how you can express your preferences, including choosing to opt-out of some data collections or uses.

1. ACCESS TO ACCOUNTS, ONLINE PROFILES AND ORDERS –

If you are a registered user of our Services, you can update your information in your profile and / or in the My Account section.

If you have any additional questions, please call our Customer Service Department at 787-622-2202.

2. DATA EXCHANGE PREFERENCES –

If you prefer that we not share your information with third parties for marketing purposes, you can contact us. See below for contact information.

If you decide to write to us, please include your name, address, and phone number and “DO NOT SHARE TO THIRD PARTIES” in your request.

Processing your application can take up to 10 business days.

3. COMMUNICATIONS BY EMAIL –

  1. Marketing or promotional emails:

 

To opt out of receiving marketing or promotional emails from ASSERTUS at a specific email address, you can:

Use the unsubscribe link in the footer of any email sent by ASSERTUS (if it exists and/or is available).

For some Services, you may be able to unsubscribe by logging into your account and/or profile and indicating your opt-out preference.

Contact us by mail, by phone or by email. See below for contact information. Include in your communication “OP-OUT PREFERENCE” and include your name, address, email and phone number.

Processing your application can take up to 10 business days.

  1. Survey emails:

We may send separate surveys, by email, to our customers in order to collect opinions and comments on their experiences of the Services.

To opt out of receiving survey emails from ASSERTUS, you can use the options mentioned above and/or you could use the unsubscribe link which may include survey emails.

Operational emails (e.g., maintenance window) do not provide an opt-out option.

Contact us by mail, by phone or by email. See below for contact information. Include in your communication “OP-OUT PREFERENCE” and include your name, address, email, and telephone number.

Processing your application can take up to 10 business days.

  1. Direct Mail or Telemarketing

To opt out of receiving direct calls by mail or telemarketing, you can contact us by mail, by phone or by email. See below for contact information. Include in your communication “NO MAIL COMMUNICATIONS” and include your name, address, email and telephone number.

Processing your application can take up to 10 business days.

  1. Exception to the voluntary exclusion of direct mail:

In order to be more effective in our communication and marketing efforts, direct mails are constantly prepared well in advance, this can mean weeks or months in advance in certain cases.

For this reason, it is possible that, for a period of time, you will continue to receive some physical mail and/or email after sending us your request. However, the foregoing does not mean that ASSERTUS has not responded to your request. We request your understanding and cooperation in this regard.

OWNERSHIP RIGHTS ON CUSTOMER INFORMATION

If ASSERTUS or any of its subsidiaries are sold or otherwise acquired by a third party, all ASSERTUS data assets will become the property of the acquiring party. Said part will be subject to any consent, exclusion, or other conditions of the clients on the data. A change in data ownership may or may not include a notice on ASSERTUS primary online sites or affected affiliate sites and/or Services.

SAFEGUARD INFORMATION –

ASSERTUS has put in place various procedural, technical and administrative measures to safeguard the information we collect and use. We design our technology-enabled Services to accept, initiate and allow communication through a Secure Transaction Layer (TSL). TSL is an encryption standard that provides a layer of security while information is transmitted over the Internet. A matter of policy, we do not disclose details regarding our security measures as this could be beneficial information for criminals and other tough players. Please note that no standard or security guarantee is guaranteed to provide 100% security. You should always use appropriate self-protection measures and practice safe browsing on all websites and / or services. The National Cybersecurity Alliance provides comprehensive information to stay safe online. In addition, sometimes illegal attempts are made to use our brand to create false representations of our services, including sending false emails and / or carrying out other illegal activities with the aim of committing fraud or attempting to violate customers and / or user safety. We actively monitor these fraudulent actions and hoaxes. If you receive any communication with the alleged ASSERTUS brand and / or related to any of our Services that seems suspicious, please contact us as soon as possible to compliance@assertus.com and/or call our Customer Service Department at 787.622.2202.

ASSERTUS STATEMENT ON ‘COOKIES’ –

This Statement may apply to some and/or all of our Services, including online services that may be owned, managed and/or operated by ASSERTUS. By continuing to use some and/or all of our Services, you agree to the use of cookies. We use cookies, web beacons, pixels, and other tracking technologies to deliver, monitor, and improve our websites, mobile-enabled web, and display content. This Statement describes the information we collect through cookies and other tracking technologies. Approved third parties may also place cookies on your web or mobile browser when you use our online services. Additional information about our use of your Personal Information can be found in this Notice of Privacy Practice.

HOW AND WHY, WE USE COOKIES –

We use cookies to improve our services and provide you with the best possible experience. We can use cookies to identify you; provide relevant and interest-based advertising; remember your preferences; ensure your access; know when content has been shown to you; provide aggregate auditing, research, and reporting to advertisers; understand and improve our online services; and detect and defend against fraud and other risks. When we send you an email, we may use cookies to understand whether you have accessed the information provided in the email. We may combine the information collected through cookies with your personal information in order to provide you with a personalized experience, including advertising about products and services that you may find of interest. The information we collect from cookies may also allow us to identify you on all devices, such as smartphones, tablets, computers, or related browsers.

We may allow certain approved third parties to place their cookies on our websites or within our advertisements. Your web browser may request advertisements directly from the servers of third-party ad networks that do not have a business relationship with us. These ads may place cookies that you can view, edit, or set third-party cookies, just as if you had requested a web page from the third-party site. We are not responsible for the practices, including the use of cookies, employed by third-party websites, mobile-enabled web or online services linked to or from ASSERTUS or for the content therein.

Third-party websites, the mobile-enabled website and / or online services accessible on the Internet are outside the control or limits of ASSERTUS.

MANAGE YOUR COOKIE PREFERENCES –

To optimize your online experience, we use different types of cookies. Managing cookie preferences differs from browser to browser, allowing you to consult your browser for more information. If you want to disable cookies and web beacons, please use the help function of your web browser to restrict cookies from our websites. However, if you block ASSERTUS cookies, you may find some errors and/or limitations in some and/or all of our Services.

WEBSITE OPTIMIZATION SERVICES –

If you wish to opt out of any search engine analysis by browser, please refer to the opt-out policies of the browser you are using.

Interest-based ads: If you want to opt out of interest-based advertising, click here. Please note that you will be excluded from all interest-based advertising from all the Network Advertising Initiative (NAI) business members for that specific browser on that particular device. If you choose not to participate, from some NAI members, you may continue to see or receive online advertising from ASSERTUS.

To opt out of interest-based advertising in mobile apps, you can disable mobile ad tracking or reset the ad identifier in your device settings.

SOCIAL MEDIA AND NEW TECHNOLOGICAL ADVERTISING –

You can manage your preferences for many of these advertising programs through the links provided below:

If you block ASSERTUS cookies, you may find some errors and/ or limitations in some and/or all of our Services.

ADDITIONAL DISCLOSURES

1. HEALTH INFORMATION –

Some of the ASSERTUS Services may be covered by federal and/or state regulations, including HIPAA.

Some of the ASSERTUS Services may include the collection of personal health information (PHI), for example: name, address, email address, social security number, health plan details, etc.

2. CHILDREN’S ONLINE PRIVACY PROTECTION ACT –

The Children’s Online Privacy Protection Act imposes requirements on websites that collect personal information about children under the age of 13 (for example, name, address, email address, social security number, etc.). Our current website, marketing and/or sales procedure does not include the collection of personal information on anyone under the age of 13 online. For this reason, our online promotions are restricted to participants who are at least 13 years old.

If this policy changes, we will revise this part of our Notice of Privacy Practices and comply with the requirements of the Children’s Online Privacy Protection Act.

3. CLICK ON ‘I ACCEPT’ –

ASSERTUS reserves the right to use “Click – I Accept” through the terms and conditions for the access of the Client or users in its Services, Marketing, Sales, Operations and/or Administration Processes. Whenever the Client or a User is required to “click” or accept or be bound by any online terms and conditions in accessing or using the Services, these terms and conditions are binding.

4. COMMENTS AND IDEAS –

Comments and Ideas (as defined below) that Clients, Prospects, Persons with an interest in ASSERTUS Services, current and/or future Users or Business Associates will restrict ASSERTUS’ legal right to use, benefit from, disclose, publish , keep secret or otherwise exploit Comments and Ideas, without compensating or crediting Clients, Prospects, People with an interest in the ASSERTUS Services, current and/or future Users or Business Associates in question. (“Comments and Ideas” means any suggestion, request, recommendation, or idea to improve or otherwise modify the Company’s Application Software, Product, System, or Service.)

5. INTELLECTUAL PROPERTY –

ASSERTUS retains all rights, titles, and interests over and for each and every one of its Services, including, among others, each and every one of the graphics, documentation, user interfaces, logos and trademarks reproduced through the Services. Clients, Prospects, Persons with an interest in the ASSERTUS Services, Current and/or future Users or Business Associates acknowledge that copyright and other laws protect the Software and the Application Services and their components.

6. SERVICES “AS IS” AND “AS AVAILABLE.” –

EXCEPT TO THE EXTENT STATED OTHERWISE IN THIS NOTICE, THE CUSTOMER ACCEPTS THE SERVICES “AS IS” AND “AS AVAILABLE.” NEITHER ASSERTUS, ITS AFFILIATES, SUBSIDIARIES, EMPLOYEES, OFFICES, OR TRUSTEES, NOR ANY OF ITS AGENTS, REPRESENTATIVES, SUPPLIERS, ADVERTISERS, PROMOTIONAL PARTNERS, OR LICENSORS MAKE ANY REPRESENTATION, OR LIMITED WARRANTY OF ANY TYPE, EXPRESSED, OR IMPLIED, INCLUDING ANY IMPLIED LIMITED WARRANTIES OF MERCHANTABILITY, COURSE OF PERFORMANCE OR USE OF COMMERCE.

7. CROSSED FUNCTIONALITY AND CONTINUOUS IMPROVEMENT. –

ASSERTUS, at its sole option, and from time to time, may make modifications, updates, changes, tests, and quality assurance processes to improve this Notice and/or any of its Services. The availability of the Services for multiple devices does not guarantee that the same capabilities, features or appearance would be available on all devices or for all types of Clients and/or users.

8. CHOICE OF LAW AND JURISDICTION –

This Notice and all claims arising out of or related to this Notice, including, but not limited to, tort claims shall be governed solely by the applicable federal laws of the United States of America and the state laws of the Commonwealth of Puerto Rico. .

9.   AMENDMENT, CHANGES, REMOVAL, EXPANSION, UPDATES, AND CONSENT

ASSERTUS may modify this Notice from time to time by posting a modified version on its website or by sending a written notice from the Client. Said modification will be considered accepted and will take effect ten (10) days after said notification. Continued use by the Customer of the Services after the effective date of a modification will confirm the Customer’s consent to them.

The access of the Client and/or user, click, use, make improper use, of any and all the Services and/or Platforms of ASSERTUS is constituted as content of the terms and conditions of this Notice, in addition to the terms and conditions of any other Third Party and/or of a current and effective agreement.

ASSERTUS

CONTACT US

If you have any questions about this Notice, you can contact us as follows:

By email, write to:                                          compliance@assertus.com
By phone, call:                                              787-622-2202
By postal mail, write to:                                 ATTN: Departamento de Cumplimiento PMB 238 #1353 Rd. 19 Guaynabo PR 00966