Last Updated: November, 2023
This Privacy Policy (“Privacy Policy” or “Policy”) explains how Prodigy Insurance Associates LLC and its subsidiaries, divisions, and affiliates (collectively referred to as "Prodigy," "we," "us," or "our") collects personal information based on your interactions with us when utilizing our services on websites, social media, email exchanges, mobile apps, and other online platforms where this Policy is available (referred to as the "Service"). This Policy applies to our collection and use of personal information and describes rights you may have with respect to your personal information. By using the Service and otherwise interacting with us, you agree to the terms of our Terms of Service, including this Policy.
This Policy does not cover the personal information we collect about employees and independent contractors, or job applicants.
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at optimalhealthplans@outlook.com.
PRODIGY collects the following categories of personal information:
We have collected the same categories of personal information in the 12 months prior to the date of this Privacy Policy.
We retain the categories of personal information we collect for the length of time necessary to provide our Services and to comply with legal obligations or to protect our legal rights.
[Unless stated otherwise in a separate agreement, PRODIGY does not collect sensitive personal information such as social security numbers, driver's license, state identification, or passport numbers; account login, financial account, debit card, or credit card numbers in combination with security or access credentials; racial or ethnic origin, religious or philosophical beliefs, union membership; the contents of your mail, email, or text messages (unless we are the intended recipient); genetic data; biometric information for unique identification; or personal information concerning your sex life or sexual orientation. We kindly request that you refrain from sending or disclosing such sensitive personal information to us].
Information You Provide to Us
PRODIGY collects personal information directly from you when you engage with our Service, get in touch with us, use our Service, or subscribe to receive offers or emails from us. This information can be submitted through online forms, phone calls, or other means of interacting with the Service.
Information We Obtain Indirectly
We may receive personal information about you from our third-party affiliates or partners, including publisher partners to whom you may have provided your information, and from marketing companies as part of their relationship with us. We may purchase this information from third parties, and all collected information will be handled in accordance with this Policy. We may combine this data with information we already have, including contact details (such as email addresses) and automatically collected log information.
Information Collected Automatically
When you use our Service, we automatically collect certain information through cookies and similar technologies. We may combine this automatically collected log information with other information we collect about you. Some of this information may be collected using tracking technologies provided by third parties, subject to those parties' privacy policies and terms of service.
PRODIGY collects your contact and demographic information to assist in finding suitable health insurance plans for you and your family. In furtherance of this purpose, and to provide the requested quotes, products, or services, PRODIGY may share these categories of personal information with insurance agents, carriers, lead aggregators, and other service providers within our network ("Network Partners"). PRODIGY only collects and processes the minimum personal information necessary for the purposes of our information processing activities and retains such information as required to fulfill these purposes. Our information processing activities include conducting our business, delivering products and services, personalizing your website experience, marketing, customer support, user verification, quality management services, Service maintenance, improvements, and compliance with legal requirements. If PRODIGY intends to process your personal information for a purpose other than that for which it was initially collected, we will provide you with relevant information and, if required by law, obtain your consent.
[We also use personal information to monitor or improve our website; for internal business analysis; to prevent fraud, activities that violate our Terms of Service or other contracts, or that are illegal; and to protect our rights and the rights and safety of our users or others.]
[For those who interact with us in a commercial capacity, we use your personal information to engage in business transactions with the entity you represent and market to or engage in diligence with the entities you represent.]
When we engage in digital advertising, we may sell the following categories of personal information (according to the broad definition of “sell” under select state privacy laws), share them for purposes of cross-context behavioral advertising, or use them for targeted advertising: Name, Email Address, Street Address, City, State, Phone Number, Zip Code, IP Address, Household income, Date of Birth, Family Size, Preexisting Conditions, Time Spent on Features, Browser and Device Characteristics, Information On How and When You Use Our Service, Internet Service Provider (ISP) Details, Referring and Exit Pages, Operating System, Clickstream Data and Other Technical Information, Age, Sex/Gender, Ethnicity, Military or Veteran Status.
These categories of personal information are sold to, or shared for cross-context behavioral advertising or targeted advertising with, advertising networks and other companies that facilitate digital advertising. We engage in such sales and sharing to facilitate digital advertising that is able to reach people that are most likely to be interested in the Services we provide. We do so by allowing third parties to place cookies or other tracking technologies on our website that may collect information about your online activities over time and across different websites or applications. For more information about the use of cookies and other tracking technologies, see the section “Our Use of Cookies and Analytics” below.
We also sell the following categories of personal information to our affiliates so they can offer their products and services to you: Name, Email Address, Street Address, City, State, Phone Number, Zip Code, IP Address, Household income, Date of Birth, Family Size, Preexisting Conditions, Time Spent on Features, Browser and Device Characteristics, Information On How and When You Use Our Service, Internet Service Provider (ISP) Details, Referring and Exit Pages, Operating System, Clickstream Data and Other Technical Information, Age, Sex/Gender, Ethnicity, Military or Veteran Status.
To opt out of such sales and sharing of personal information, click here.
We do not sell or share for cross-context behavioral advertising any of the other categories of personal information we collect.
The following chart describes the categories of personal information we disclosed to third parties for a business purpose in the 12 months prior to the date of this Policy:
Personal Identifiers: Including your name, email address, street address, city, state, phone number, zip code, and IP address
Demographic Information: Including household income, date of birth, family size, and preexisting conditions, if any
Internet or other electronic activity information: Including online activity, preferences, time spent on features, browser and device characteristics, information on how and when you use our Service, internet service provider (ISP) details, referring and exit pages, operating system, clickstream data, and other technical information.
Protected class information: age; sex/gender; ethnicity; military or veteran status
PRODIGY’S Service Providers are restricted to using your personal information solely for these tasks and cannot use it for other purposes. They must adhere to confidentiality, security, and legal obligations in line with this Policy and applicable laws.
We may share non-identifying information, such as aggregate statistics or usage data, with third parties to illustrate how PRODIGY is used, detect industry trends, and produce marketing materials. This aggregated information will not contain personally identifiable information and is not limited in use.
We may share your personal information with third parties with your consent. If you agree to share your personal information with a third party, it will be subject to that third party's privacy policy and practices. You can withdraw your consent by contacting us at optimalhealthplans@outlook.com
We may also disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also disclose your personal information to third parties to help detect and protect against fraud or data security vulnerabilities. And we may disclose or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring.
We do not sell or disclose sensitive personal information.
We may use cookies, pixel tags, web beacons and other similar tracking technologies (“tracking technologies”) to automatically collect information through our website. Tracking technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that record certain pieces of information when you visit our website.
We may use cookies to personalize and enhance the information presented to you and to provide our Service. Specifically, PRODIGY uses cookies for the following purposes:
We do not intend to use cookies to retrieve information unrelated to our Service or your interaction with it.
We may use pixel tags, web beacons, and other similar technologies to collect information about your online activities, email interactions, online and mobile advertisements, and to track analytics and statistics that help PRODIGY improve services and deliver more relevant content and advertising via PRODIGY or linked from our services.
[We also allow third parties to use tracking technologies on our website for analytics and advertising. They assist in helping display advertisements, tailor advertisements to your interests and to assist in determining if you require assistance or are having problems navigating on our website. Some of these third parties are our service providers that may use certain technologies to record your interactions with the sites, including without limitation, your keystrokes and mouse clicks, and information about when, how and from where you accessed our sites. This information is used to help us manage our sites and provide a good user experience. The service providers we use in this regard agree not to sell or disclose any of the recorded information to third parties (other than subcontractors who assist in providing this service to us or for legal compliance purposes at our direction). Other third parties use the tracking technologies to collect information about how you interact with other website and advertisements across the Internet to provide advertising that is tailored to your interests and which may appear on our website or on other website or platforms.]
You may set your browser to notify you when you receive a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.
[We use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a Site, what pages they visit when they do so, and what other websites they visited prior to visiting our Site. For information about Google’s privacy practices, please refer to the Google Privacy Policy: https://policies.google.com/privacy?hl=en-US#infocollect.]
The Service is not intended for individuals under the age of eighteen, and we employ mechanisms to prevent registration and usage of the Service by such individuals. PRODIGY will never knowingly request or collect personal information from children. If you are under eighteen years old, please do not provide your information on our Service. If we become aware that a child has submitted personally identifiable information, we will promptly delete it from our records. If you suspect that we have information from a child, please contact us.
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals.
Our Sites may contain links to third party websites, including social media buttons that link to social media platforms. This Policy does not govern how those third parties or social media platforms collect or use personal information and we do not endorse or have control over their practices. The privacy policies and terms of use for those third parties’ websites/apps or social media platforms govern those companies’ privacy practices. We are not responsible for the content or privacy practices of any third-party websites or platforms.
We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to maintaining a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to factors that cannot reasonably be prevented. Accordingly, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.
PRODIGY is a U.S.-based enterprise and may process, transmit, and store information about users of the Service on servers located in multiple countries, including the United States. Consequently, your personal information may be subject to data protection and other laws differing from those in your country of residence. In response to inquiries or requests from government authorities or to fulfill judicial processes in countries where we operate, your personal information may be disclosed. By utilizing the Service or providing us with information, you consent to the collection, processing, maintenance, and transfer of such information to the United States and other applicable territories, which may not have privacy laws as comprehensive or equivalent to those in your country of residence or citizenship.
By supplying your contact information and voluntarily opting in to receive communications from PRODIGY, you consent to receiving communications directly from PRODIGY, our affiliates, Network Partners, and their agents (collectively referred to as "Contacts"). These communications may be delivered through various channels, including the Service, third-party platforms, phone carriers, and other service providers assisting us and our Contacts in delivering emails, calls, and text messages. You expressly authorize us to share your information as described herein, agreeing that our Contacts and we may periodically send you newsletters, promotional emails, and contact you via live operators, automated telephone dialing systems, pre-recorded messages, and text messages to provide the Service. You can stop receiving emails, calls, and text messages from us by following the instructions in these messages or by contacting us at info@phnins.com. To cease communications from any of our Contacts, please notify them directly.
As with all data collected by PRODIGY, we reserve the right to disclose information as necessary to comply with legal requirements, avoid liability, protect our rights or property, or satisfy governmental requests. When you submit information online or provide data in connection with the Program, you are obligated to provide accurate, complete, and truthful information. The use of a false or misleading identity, or one that you are not authorized to use, is strictly prohibited. If, at PRODIGY's sole discretion, we suspect that any information is false, inaccurate, incomplete, or if you have enrolled in the Program for ulterior motives, we may deny access to the Program and pursue appropriate legal remedies.
Certain features of our Service, both presently and in the future, may allow you to submit content, such as written comments, reviews, product images, or interactive responses to content, for publication or display in public areas of the Service (referred to as "User Content"). Exercise caution when sharing information in these public areas, as any data you provide can be accessed by any user of the Service. We lack control over the actions of other Service users with whom you may choose to share your User Content.
If you have provided your contact information to PRODIGY via this website and wish to have your name and contact details removed from our database, kindly send an email to info@phnins.com to request unsubscribing. We will make reasonable efforts to remove your name and contact information where feasible. It is important to note that we may need to retain some of this information to fulfill our business obligations with you or for other Service-related transactions.
We will review and update this Policy from time to time. If changes are made, we will update the Privacy Policy and reflect the date of such modification in the date above. If the changes are material, you will be notified via email or a notice on our website.
If there are any questions regarding this Privacy Policy or to request a copy of this Privacy Policy in another format you may contact us at optimalhealthplans@outlook.com
Laws in certain US states give residents of those states specific rights with respect to the personal information collected about them. See below for more information.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, the California Consumer Privacy Act (“CCPA”) and other laws provide you with the following rights with respect to your personal information:
Your Right To Know About Personal Information We Collect
You can ask us for the following information from us with respect to the personal information we have collected about you since January 1, 2022:
Your Right To Request Deletion of Personal Information We Have Collected From You
Upon your request and subject to exceptions in the law, we will delete the personal information we have collected from you.
Your Right to Request to Correct Personal Information We Hold About You
You have the right to request that we correct personal information we hold that you believe is not accurate. We will take steps to determine the accuracy of the personal information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct to assist us in evaluating the request.
Your Right to Ask Us Not to Sell or Share Personal Information We Have Collected About You
With respect to those categories of personal information that we sell to third parties or share with third parties for the purpose of cross-context behavioral advertising, you have the right to opt out of such sales and sharing.
Opt-out Preference Signals
An opt-out preference signal is sent by a platform, technology, or mechanism on behalf of consumers and communicates a consumer’s choice to opt out of the sale and sharing of personal information for cross-context behavioral advertising with all businesses that recognize the signal, without having to make individualized requests. The signal can be set on certain browsers or through opt-out plug-in tools.
We recognize the Global Privacy Control signal and do so at the browser level and it does not apply to personal information we may collect offline or that we may associate only with your name or email address. This means that if the signal is sent through a specific browser, we will recognize it for that browser only, and only with respect to the identifiers for that browser. If you would like more information about opt-out preference signals, including how to use them, the Global Privacy Control website has such information (https://globalprivacycontrol.org/).
Your Right to Ask Us to Limit the Use of Your Sensitive Personal Information
To the extent we use or disclose your sensitive personal information to infer characteristics about you, you have the right to request that we not do so and limit our use of such information to providing our Services and other business or operational purposes set forth in the CCPA relating to the use of sensitive personal information.
California Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about the personal information (if any) disclosed to third parties for direct marketing purposes in the preceding calendar year. To make a request, please contact us at optimalhealthplans@outlook.com.
Our Commitment to Honoring Your Rights
If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.
Exercising Your Rights and How We Will Respond
To exercise your rights to know, delete or correct your personal information, or to ask a question, contact us at optimalhealthplans@outlook.com. For such requests, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
You can direct us not to sell your personal information or share it for purposes of cross-context behavioral advertising here. For such requests, we will comply no later than 15 business days after receipt of your request.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Verification of Identity – Requests to Know, Delete or Correct
We will ask you for two pieces of personal information and attempt to match those to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
Authorized Agents
You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process:
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
COLORADO PRIVACY RIGHTS
If you are a Colorado resident, the Colorado Privacy Act (“CPA”) grants the rights described below with respect to personal information we collect about you.
Please note that for purposes of this section of this Policy, we consider “personal information” to have the same meaning as “personal data” as defined under the CPA.
Exercising Your Rights and How We Will Respond
To exercise your rights to know, delete or correct, or to ask a question, contact us at optimalhealthplans@outlook.com or click here. We will respond to such requests within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
You can opt out of the sale of your personal information or the use of your personal information for targeted advertising here. We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Our Commitment to Honoring Your Rights
If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than others.
Verification of Identity – Requests to Know, Delete, Correct
We will ask you for two pieces of personal information and attempt to match those to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
When We Do Not Act on a Request – Appeal Process
In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.
Additionally, you have the right to appeal our decision by contacting us at optimalhealthplans@outlook.com within 30 days after your receipt of our decision. Please provide us with [information the company needs (e.g., reference number) to identify denial of request]. We will respond to your appeal within 45 days of our receipt of the request, unless we need additional time to do so (up to 60 additional days), in which case we will notify you.
CONNECTICUT PRIVACY RIGHTS
If you are a Connecticut resident, the Connecticut Data Privacy Act (“CTDPA”) grants the rights described below with respect to personal information we collect about you.
Please note that for purposes of this section, we consider “personal information” to have the same meaning as “personal data” as defined under the CTDPA.
Exercising Your Rights and How We Will Respond
To exercise your rights to know, delete or correct, or to ask a question, contact us at optimalhealthplans@outlook.com or click here. We will respond to such requests within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
You can opt out of the sale of your personal information or the use of your personal information for targeted advertising here.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to provide you with an explanation as to why.
Our Commitment to Honoring Your Rights
If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services or provided a different level or quality of goods or services than others.
Verification of Identity – Requests to Know, Delete, Correct
We will ask you for two pieces of personal information and attempt to match those to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
When We Do Not Act on a Request – Appeal Process
In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.
Additionally, you have the right to appeal our decision by contacting us at optimalhealthplans@outlook.com within 30 days after your receipt of our decision. Please provide us with [information the company needs (e.g., reference number) to identify denial of request]. We will respond to your appeal within 60 days of our receipt of the request.
Authorized Agents
You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process:
NEVADA PRIVACY RIGHTS
Nevada law gives its residents the right to opt out of the sale of their personal information. To exercise your rights in this regard, please contact us at optimalhealthplans@outlook.com.
VIRGINIA PRIVACY RIGHTS
The Virginia Consumer Data Privacy Act (“VCDPA”) grants Virginia residents the following rights with respect to their personal information we collect:
While Virginia law provides the right to opt out of the sale of personal information, we do not sell personal information consistent with the definition of “sale” under Virginia law.
Please note that for purpose of this section of this Policy, we consider “personal information” to have the same meaning as “personal data” as defined under the VCDPA.
Exercising Your Rights and How We Will Respond
Contact us at optimalhealthplans@outlook.com to exercise the right to know, obtain a portable copy of, delete, or correct your personal information or to opt out of the sale of your personal information. We will respond to such requests within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
You can direct us not to process your personal information for purposes of targeted advertising here.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations.
Verification of Identity – Requests to Know, Delete, Correct
We will ask you for two pieces of personal information and attempt to match those to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
When We Do Not Act on a Request – Appeal Process
In some cases, we may not act on your requests (e.g., if we cannot do so under other laws that apply). When this is the case, we will explain our reasons for not providing you with the information or taking the action (e.g., correcting data) you requested.
Additionally, you have the right to appeal our decision by contacting us at optimalhealthplans@outlook.com within 30 days after your receipt of our decision. Please provide us with [information the company needs (e.g., reference number) to identify denial of request]. We will respond to your appeal within 60 days of our receipt of the request.
UTAH PRIVACY RIGHTS
The Utah Consumer Privacy Act grants Utah residents the following rights with respect to their personal information we collect:
Personal information, or "personal data," means information that is linked or reasonably linkable to an identified individual or an identifiable individual. "Personal data" excludes deidentified data, aggregated data, or publicly available information.
If you or an authorized agent wish to make any of the above requests, please contact us at optimalhealthplans@outlook.com or fill out our interactive form. When submitting a request, provide enough information to identify you (e.g., your first and last name, email address, and telephone number) and details about the requested data. We will use this information solely to respond to your request. We may not disclose information if we cannot verify that the requester is the person about whom we collected information or someone authorized to act on their behalf.
To opt out of the sale and sharing of your personal information for all purposes, you can also follow the instructions found here: "Do Not Sell or Share My Personal Information."