Senior Planning Services Privacy Policy
Last update: October 2024

PRIVACY IS IMPORTANT TO US. PLEASE READ THIS PRIVACY POLICY BEFORE USING THE SENIOR PLANNING SERVICES (“SPS”) WEBSITE OR SERVICES.

This Privacy Policy describes the types of information collected from our individual users when accessing or using the SPS website located at seniorplanning.comor our client portal (together, the “Website”) or additional services from the SPS team, as applicable (collectively, the “Services”). This Privacy Policy also explains how we may use and disclose such information. 

BY USING THE SERVICES, YOU ARE CONSENTING TO THE TERMS DESCRIBED IN THIS PRIVACY POLICY AND THE SPS TERMS AND CONDITIONS. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR THE TERMS AND CONDITIONS, DO NOT ACCESS OR USE THE SERVICES.We may revise and update this Privacy Policy, or the Terms and Conditions from time to time with or without notice. Your continued use of the Services means you accept those changes.

I. INFORMATION SPS COLLECTS AND HOW WE USE IT

This section describes the types of personal information we may collect about you. Such information is generally collected either (i) directly from your voluntary engagement with the Services (for example, by entering information into data fields on the Website or contact us via email, phone, or chat bot); (ii) automatically from you when you interact with the Services; or (iii) third-party partners.

If you decline to provide certain information while using the Services, you may not be able to use or participate in some or all of the features offered through the Services.

The following categories of personal information we may collect from you includes:

  • Contact and account information. In order to set up an account we may collect your name, signature, phone number, mailing address, and email address.
  • Financial information. To provide anduse our Services, we may collect your credit card information, banking information, including account type, account number, account balance, and transaction history, billing address, shipping address, or other payment information.
  • Health-related information. To provide the Services, we may collect your health information such as medical conditions, care,or health risk status.
  • Social security number or government identification. We may collect identification information such as your social security number or state driver’s license in order to provide the Services.
  • Insurance information. By providing the Services, we may collect your Medicare or Medicaid policy number or other health insurance information.
  • Feedback information. To receive and respond to your customer service requests or comments on your experience with SPS, we may collect your name, phone number, address, email address, images, and any relevant history.
  • Application or Recertification information. We may collect the above information as well as your demographics such as date of birth, gender, occupation, income, and marital status to complete an application or recertification.
  • Browser or Device Information: When you interact with our Website, we may automatically collect information about the computers, phones, and other devices you are using (e.g. IP address, browsing and search history, WiFi information, device attributes, operating system version, etc.).
  • Website Usage: So that we may understand and improve on the user experience and functionality of the Website, we may collect information about how you interact with the Website such as mouse movements, clicks, keystrokes, the date of your visit, the time spent on pages of the Website, or other actions.

Personal information that is automatically collected may be obtained through cookies and similar technologies. Cookies are small files that are stored on your computer or mobile device through a user ID or other preferences. We use cookies to personalize your experience when you use the Services (e.g. auto-populating your log-in credentials or settings). You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features through our Website or take full advantage of all our services. For more information about these technologies, please see our section on COOKIES, WEB BEACONS, AND OTHER WEB TECHNOLOGIES below.

II. INFORMATION SPS COLLECTS FROM THIRD PARTIES

We may supplement information about you from third parties such as healthcare professionals; data brokers; insurance companies; third party administrators; yourlegal advisors for which (a) we may be providing back-office support (as processors and not controllers), or (b) they may be providing you with spend-down or related legal services in connection with your application or recertification,service providers; vendors; banking and other financial institutions; affiliates; business partners; customers, social media platforms; and government agencies or public records, so that we may provide the Services.

III. HOW SPS USES COLLECTED INFORMATION

SPS uses the information it collects for the following purposes:

  • To provide you with the Services
  • To provide you with updates regarding your application or recertification
  • To address your inquiries and requests
  • To contact and manage our relationship with you
  • To manage your SPS account
  • To ensure proper functionality of the Website and the Services
  • To analyze usage trends and enhance or improve the Website and the Services
  • To protect against fraud or other illegal activities
  • To process payments for the Services
  • For other purposes disclosed at the time you provide your information or otherwise with your consent

SPS uses your information only for the purposes for which it was collected and in accordance with this Privacy Policy.

IV. SECURITY AND RETENTION POLICY

SPSwill retain your information for as long as is necessaryfor the processing purpose(s) for which the data was collected, and any other permissible, related purpose but no longer than five(5) years from collection. When we no longer need the personal information we collect, we either deidentify the information or securely destroy the information.

SPS has put in place reasonable and appropriate security measures to protect the information collected via the Website and the Services. However, note that the confidentiality of information transmitted over the Internet cannot be guaranteed. Please exercise caution when transmitting information over the Internet and through the Website. SPS does not and cannot guarantee that unauthorized third parties will not gain access to your information.It is also very important that you do not share your username or password with anyone. You are responsible for all activity that occurs under your account. To the extent SPSstores certain information using its third-party hosting service provider Amazon Web Services and does not make any warranty regarding the privacy or security of any information stored by Amazon Web Services.

V. COOKIES, WEB BEACONS, AND OTHER WEB TECHNOLOGIES

SPS utilizes automatic data collection to enhance the Website and the Services. The web technologies SPS may use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website or the Services. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.
  • Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website.
  • Web Beacons. The Website and SPS emails may contain small electronic files known as web beacons (also known as clear gifs, pixels, tags, and single-pixel gifs) that allow us to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
  • Log Files: Log files are pieces of information that inform how users are accessing the Website. For example, each time you visit the Website, it may create a log file that someone visited the page. Log files can be used to create aggregate reports of Website activity.
  • Do Not Track Mechanisms.Because there is no consensus on how companies should respond to web browser-based do-not track (“DNT”) mechanisms, our system will not recognize or respond to Do Not Track requests or headers at this time.

VI. HOW PERSONALINFORMATION MAY BE DISCLOSED

By using our Services, you consent to SPS’s disclosure of yourpersonalinformation with our affiliate companiesand any applicable MCP/MLTC or HCA on a confidential basis in order to provide the Services and without further consent from you.

In addition, SPS reserves the right to comply with the law and to release your information for the following reasons:

  • Legal Matters.In response to subpoenas, regulatory or judicial processes, governmental requests and investigations, or as otherwise required by law.
  • To Prevent Fraud or Illegal Activity. If we reasonably believe that there has been a violation of the Terms and Conditions or to protect the security of the Website, Services, and any SPS servers, network systems, and databases.

VII. THIRD-PARTY WEBSITES

The Website and Services may suggest links to third-partywebsites that might be useful or of interest to you. SPS does not exercise authority over or endorse such third-party websites. In each instance, you may access third-party websites at your own risk. Although SPS strives to ensure that it refers to reliable third-parties,SPS does not guarantee the accuracy, completeness, or timeliness of the information on these third-party websites, nor isSPS any way responsible for any decision you make or action you take in reliance on such information. SPS offers you links on an “as-is” basis and you will no longer be protected by the SPS privacy policy or security practices. Please read any third-party privacy and security policies closely.

VIII. HILDREN’S PRIVACY

The Services are not intended for use by children under the age of 18. In accordance with the Children’s Online Privacy Protection Act of 1998, SPS does not knowingly request information from anyone under the age of 13 without parental consent.

IX. CHANGES TO THIS PRIVACY POLICY

SPS may change this Privacy Policy from time to time. We encourage you to routinely check this page for any changes thereof. By continuing to access or use the Website or the Services you agree to accept any revised terms.

X. ADDITIONAL RIGHTS FOR CONNECTICUT OR WASHINGTON RESIDENTS

If you are a Connecticut resident, certain rights may be afforded to you under the Connecticut Data Privacy Act (CTDPA). You may exercise your Connecticut privacy rights (listed below) by emailing privacy@seniorplanning.com.We will confirm and generally carry-out your request within forty-five (45) calendar days unless the request is unusually extensive or complex, in which case we will inform you of the expected timeline for handling your particular request. We do not discriminate against any Connecticut residents who exercise any of their rights described in this Privacy Policy.

  • The Right to Access: You may request, free of charge once per 12-month period, that we disclose to you the categories and specific pieces of information that we have collected about you and our sources for such information. Please note that we may charge a reasonable fee to cover administrative costs for requests that are unfounded, excessive, or repetitive.
  • The Right to Obtain: You may request a copy of your personal data that we have in our records in a portable and readily usable format if you need to share your data with a third-party.
  • The Right to Delete: You may request that we delete any personal information that we have collected from or about you.
  • The Right to Correct Inaccurate Personal Information: You may request, that we provide you with the name of the provider that shared your incorrect information with us.
  • Right to Appeal: If we reasonably decline your request, you will be able to appeal our decision by emailing us at privacy@seniorplanning.comand we will inform you in writing within sixty (60) days of any action taken or not taken in response to your appeal.

If you are a Washington resident, certain rights may be afforded to you under the Washington My Health My Data Act (MHMDA). You may exercise your Washington privacy rights (listed below) by emailing privacy@seniorplanning.com.We will confirm and generally carry-out your request within forty-five (45) calendar days unless the request is unusually extensive or complex, in which case we will inform you of the expected timeline for handling your particular request. We do not discriminate against any Washington residents who exercise any of their rights described in this Privacy Policy.

  • The Right to Confirm and Access: You may request, free of charge once per 12-month period, that we disclose to you the categories and specific pieces of healthdata that we have collected about you and our sources for such information. Please note that we may charge a reasonable fee to cover administrative costs for requests that are unfounded, excessive, or repetitive.
  • The Right to Delete: You may request that we delete any health data that we have collected from or about you.
  • The Right to Withdraw:You may withdraw your consent and request that we abstain from collecting or sharing your health data.
  • Right to Appeal: If we reasonably decline your request, you will be able to appeal our decision by emailing us at privacy@seniorplanning.com and we will inform you in writing within forty-five (45) days of any action taken or not taken in response to your appeal.

XI. CONTACT US

If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at privacy@seniorplanning.com.