Privacy Policy

Effective date as last modified: May 15, 2020

INTRODUCTION

Covenant HealthShare, Inc. ( “Covenant HealthShare”,“we”, “us” or“our”) respects your privacy and is committed to protecting it through our compliance with this Privacy Policy (“Privacy Policy”).

This Privacy Policy describes the types of information we may collect from you or that you may provide when you visit the website www.covenantshare.org (our “Website“) and our practices for collecting, using, disclosing, maintaining, and protecting that information.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy applies to information we collect:

• On or through this Website.
• In email, text, and other electronic messages between you and this Website or Covenant HealthShare.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Privacy Policy.

This Privacy Policy does not apply to information collected by:

• Covenant HealthShare offline or through any other means, including on any other website operated by Covenant HealthShare or any third party; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to the terms set forth in this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy, below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Your use of the Website and our Services is at all times subject to our Terms of Use, available here (the “Terms”), which incorporates this Privacy Policy. Any capitalized terms we use in this Privacy Policy without defining them have the definitions given to them in the Terms.

CHILDREN UNDER THE AGE OF 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@covenantshare.org.

INFORMATION WE COLLECT

Our Website collects information that identifies, relates to, describes, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer (“personal information”). Personal Information does not include your Personal Information that has been de-identified, pseudonymized, anonymized, aggregated, and/or otherwise processed so as to be unidentifiable in such a way that the data can no longer be attributed to a specific individual (by reasonable means) without the use of additional information, and where such additional information is kept separate and under adequate security to prevent unauthorized re-identification of a specific individual such that one could not, using reasonable efforts, link such information back to a specific individual (collectively, all of the foregoing in this sentence being referred to as “De-Identified Personal Information”).

Covenant HealthShare’s Website and business operations have collected the following categories of personal information from its website visitors and users within the last twelve (12) months:

The information we collect on or through our Website also may include:

• Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, posting materials, or requesting further services. We may also ask you for information when you enter a promotion sponsored by us, and when you report a problem with our Website. For example, if you register on our Website, we collect your name, e-mail address and password. If you place an order with us, we collect the personal information that you provide to us, such as your billing and payment information. You may also have the option to store credit card or other payment information to make it easier to purchase products or service from the Website in the future. If you contact our member services agents, you may also provide us with personal information that we collect. When you purchase a product or service, we collect all of your order information, such as the type of product you purchased and the costs of each product. We may provide you with the opportunity to review our products or participate in public forums associated with the Website. Any reviews, posts or comments will be public, so you should use care before posing information about yourself online.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Information about your health or medical history that you provide in a health insurance application.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on the Website.
• Information you provide on a member portal or provided on your behalf on an agent or broker portal.

Personal information does not include:

• Publicly available information from government records.
• De-Identified personal information.

SOURCES OF DATA COLLECTION

Covenant HealthShare obtains the categories of personal information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete, and products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies.
• From our third party business partners, such as insurance agents and brokers, medical providers and service providers.

Information We Collect Through Automatic Data Collection Technologies:

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Please visit https://allaboutdnt.com/ for information on how you can opt out of behavioral tracking on this Website and other mechanisms that enable consumers to exercise choice about behavioral tracking.

The information we collect automatically is statistical data and may include personal information that we may maintain or associate with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our Website.
• Use cookies.

The technologies we use for automatic data collection may include:

Browser Cookies. A browser cookie is a small file placed on the hard drive of your computer. By using our Website, you consent to our placement of cookies on your computer. You may occasionally get cookies from our business partners or other third parties. We have no access to or control over these cookies. You may refuse to accept browser cookies by activating the appropriate setting on your browser. Please consult your browser’s “help” section for instructions. If you choose to decline cookies then you may not be able to fully experience the features of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Local Stored Objects. Certain features of our Website may use local stored objects to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for local stored objects, see Choices About How We Use and Disclose Your Information below.

We use Google Analytics, a web analysis service provided by Google LLC (“Google”). Google Analytics uses Cookies that are stored on your computer and allow for an analysis of your website use. The information generated by the Cookies about your use of our Website is forwarded to Google and stored on servers located in the USA.

You may opt out from the use of Cookies by changing your browser settings. You may also deactivate the service by downloading and installing the browser add-on to deactivate Google Analytics for your current browser, available at: https://tools.google.com/dlpage/gaoptout/. For further information about managing and disabling cookies on your computer please visit: www.allaboutcookies.org/manage-cookies.

Third-Party Use of Cookies:

Some content or applications, including advertisements, on the Website are provided by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the next section below.

Choices About How We Use and Disclose Your Information:

We strive to provide you with choices regarding the personal information you provide to us. The following mechanisms may provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
• Solicitations from Covenant HealthShare. If you do not wish to have your email address/contact information used by Covenant HealthShare to solicit your business with Covenant HealthShare, you can opt-out by sending an email to: privacy@covenantshare.org. If we have sent you a solicitation email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Covenant HealthShare as a result of a product purchase, product service experience, or other transactions.
• Communications from Covenant HealthShare. You will still receive communications from us regarding your insurance quote, application, policy or advanced premium tax credit even if you opt out of receiving our surveys and/or notices of additional products and services.

HOW WE USE YOUR PERSONAL INFORMATION

We may use the personal information we collect for one or more of the following business purposes:

• To present our Website and its contents to you.
• To provide you with information, products, or services you request from us.
• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To provide you with notices about your account, including expiration and renewal notices.
• To notify you about changes to our Website or any products or services we offer or provide through it.
• To help find you, and if you choose to do so, apply for health insurance and other products that may be of interest to you and your family.
• To allow you to participate in any interactive features on our Website.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To evaluate or conduct a potential merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Covenant HealthShare’s assets, whether as a going concern or as part of a similar proceeding, in which personal information held by Covenant HealthShare about our Website users is among the assets transferred.
• To fulfill any other purpose for which you provide it.
• For any other purpose with your consent.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Covenant HealthShare will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Disclosure of Personal Information:

Covenant HealthShare may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We may disclose De-Identified personal information without restriction.

Advertising on Third-Party Websites

By clicking “Get My Free Healthcare Quote”, you consent by electronic signature to be contacted by third party Marketing Partners about you request for information, without limitation, by providing you information, offers, or advertisements by telephone call or text message to the number(s) you have provided on this or any other Covenant HealthShare branded form( including any cellular number), even if that number is on any local, state or national “Do Not Call” list, sent using an automatic telephone dialer, text message or an artificial or prerecorded voice, and by email or live representative. This consent is not required as a condition of making a purchase. Message and Data rate may apply.

We do not sell your personal information.

We may disclose your personal information to the following categories of third parties:

• To our subsidiaries and affiliates.
• To contractors, service providers, data aggregators, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• Medical providers.
• Your chosen insurance company and/or health care sharing ministry (HCSM) and its affiliates.
• Insurance agents, brokers, and business partners.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Covenant HealthShare’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Covenant HealthShare about our Website users is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us your email address as part of completing a form on the Website or calling our sales center, we may use your email address or other personal information provided to contact you.
• For any other purpose disclosed by us when you provide the information.
• Companies to which you give consent for us to disclose.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Terms and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Covenant HealthShare, our customers/members, or affiliates.

Providing you with a quote or processing your application:

We may use your personal information to get in touch with you when necessary to process your application or to provide you with a quote. For example, emails may be sent to you throughout the application process to inform you of the status of your application and to seek additional information that is requested as part of the application. We may also use phone numbers you provide to send you telephone or text messages about your application or account, and such messages may be automatically sent with an autodialer, an artificial or prerecorded voice, or other automation technology. We use the information we collect about you to deliver the services we offer, and to operate and improve our Website. Our services may include a Short Message Service (“SMS”) which may deliver up to 2 messages per day to your wireless device and the display of personalized content and advertising. We may use your information to contact you about Website updates, conduct surveys, or informational and service-related communications, including important security updates. You may remove your information by replying “STOP” to the SMS text message you received. Alternatively, you may submit your request by email to us, including the email address and phone number you registered with us.

Customer satisfaction, referrals and other products:

We or our affiliates may contact you to survey your satisfaction with our service, refer our products and services to other people, and/or to inform you of additional products and services. You may opt-out of receiving these additional communications from us by following the opt-out procedures below or as set out in the emails we send to you, as applicable.

Required Disclosures:

Except as otherwise described in this Privacy Policy, we will not disclose your Personal Information to any third party unless required to do so by law, court order, legal process, or subpoena, including to respond to any government or regulatory request, or if we believe that such action is necessary to: (a) comply with the law, comply with legal process served on us or our affiliates, subsidiaries, contracted vendors, or affinity partners, or investigate, prevent, or take action regarding suspected or actual illegal activities; (b) enforce our Terms or customer agreement (including for billing and collection purposes); (c) take precautions against liability; (d) investigate and defend ourselves against any third-party claims or allegations; (e) assist government enforcement agencies or to meet national security requirements; (f) to protect the security or integrity of our Website, our services, or any software we provide related thereto; or, (g) exercise or protect the rights, property, or personal safety of us, our users or others.

We will attempt to notify you about these requests unless: (i) providing notice is prohibited by the legal process itself, by court order we receive, or by applicable law, or (ii) we believe that providing notice would be futile, ineffective, create a risk of injury or bodily harm to an individual or group, or create or increase a risk of fraud upon us, our users, our Website, or our services. In instances where we comply with legal requests without notice for these reasons, we will attempt to notify that user about the request after the fact if we determine in good faith that we are no longer legally prohibited from doing so and that no risk scenarios described in this paragraph apply.

It is likely that the identity and categories of such third parties will change during the life of your account. We require that our third-party service providers only use your personal information as necessary to provide the requested services to us and each service provider is subject to a set of terms consistent with the applicable portions of this Privacy Policy.

CORRECTING YOUR ACCOUNT INFORMATION

You can review and change the personal information in your account by logging into the Website and visiting your account profile page.

Copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our Terms.

POSTING CONTENT

You also may submit information, such as comments, reviews, testimonials, etc., to be published or displayed (“posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “Content”). Your Content is posted and transmitted to others at your own risk. We cannot control the actions of other users of the Website with whom you may choose to share your Content. Therefore, we cannot and do not guarantee that your Content will not be viewed by unauthorized persons.

By posting any Content you agree to and do hereby grant us and our licensors, affiliates, partners, successors and assigns, a nonexclusive, perpetual, irrevocable, worldwide, sublicensable, transferrable, royalty-free right and license to use, store, display, publish, transmit, transfer, distribute, reproduce, rearrange, edit, modify, aggregate, summarize, create derivative works of and publicly perform the Content that you post or otherwise submit to us for any purpose, in any form, medium, or technology now known or later developed (“Right to Use”). The Right to Use you grant us also extends to any Content that you have posted to our Facebook or other social media account pages, or on other websites, e.g., Google, Yelp, Trip Advisor, Instagram, etc. The term “Use” includes, but is not limited to, use, reproduce, modify, publish, list information regarding, edit, delete, translate, distribute, publicly display, publicly perform, and make derivative works of the content.

If we permit you to post Content, by posting any Content you agree to with the following User Content Posting Guidelines:

To the extent our Website contains areas where you can post or submit to be posted such as comments, product reviews, testimonials, etc., you agree to post Content that is proper and related to the general theme of the Website. Content also includes that which you send to us by email, text, mail, or other means. You agree not to post any Content that:

• Is off-topic, false, inaccurate, misleading, defamatory, libelous, stalking, threatening, obscene, pornographic, indecent, vulgar, offensive, which contains unlawful material or information, or which otherwise violate the legal rights (such as rights of privacy and publicity) of others;
• Harasses, degrades, intimidates, or is hateful toward an individual or group of individuals on the basis of religion, gender, sexual orientation or identity, race, ethnicity, age, or disability;
• Is not your own original creation or that you do not have permission to use or that infringes the copyright, trademark, patent, or other proprietary right of any person or that is used without the permission of the owner;
• Is intended to provide professional advice, including but not limited to, the provision of medical treatment, or legal, financial or investment advice;
• Promotes or provides instructional information about illegal or illicit activities;
• Purports to be from any person or entity, including but not limited to one of our employees, or falsely states or otherwise misrepresents your affiliation with a person or entity;
• Includes personal or identifying information about another person without that person’s explicit consent, or is doxxing;
• Contains software code of any kind, including, but not limited to, code that contain viruses, corrupted files, or any other similar software or programs designed to or that may interrupt, lock up, destroy, damage or limit the operation of another person’s computer or network or telecommunications equipment;
• Disrupts the normal flow of dialogue with an excessive number of messages (flooding attack) to the Website, or that otherwise negatively affects the ability of others to use the Website; or,
• Advertises or offers to sell any goods or services, or engage in surveys, contests, chain letters, or for any commercial purpose.

You may not attempt to gain unauthorized access to our computer systems or those of any our service providers or third parties, or engage in any activity that disrupts, diminishes the quality of, interferes with the performance of, or impairs the functionality of, the Website or our services. We reserve the right, but do not undertake the obligation, to refuse to post or remove any posted Content from our Website for violation of these rules or for any other reason, and to refuse to accept any future postings by you.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We maintain reasonable physical, electronic, and procedural safeguards designed to help us protect your non-public personal information against loss, misuse, disclosure and alteration. When you establish an account at Covenant HealthShare, a password is generated to help protect your account information. Passwords can be updated. A password is only as strong as you make it. You should select a unique password and keep it safe. You may change your password as often as you wish by going to the Member Log In link of the Website.

DATA RETENTION

You can delete your account or request that we delete your account by contacting us.

We retain your information after you request such deletion for longer periods for specific purposes to the extent that we are obliged to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. We may retain De-Identified Personal Information for as long as we deem appropriate. For example, if we process your payments, we will retain this data for longer periods of time as required for tax or accounting purposes. Additional examples of specific reasons we would retain some data for longer periods of time include:

• Our contractual and business relationships with you.
• Security, fraud and abuse prevention –to protect you, other people, and us from fraud, abuse, and unauthorized access.
• Financial record keeping – when you make a payment to us we are often required to retain this information for long period of time for purposes of accounting, dispute investigation and resolution, and compliance with tax, anti-money laundering, and other financial regulations.
• Complying with legal or regulatory requirements – to meet any applicable law, regulation, legal process, or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.
• Direct communications with us – if you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.

Even if you delete your account, keep in mind that the deletion by our service providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. We may retain De-Identified Personal Information for as long as we deem appropriate.

CHANGES TO OUR PRIVACY POLICY

Covenant HealthShare reserves the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on the Website and update the effective date of this Privacy Policy. The date the Privacy Policy was last revised is identified at the top of the page. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

CONTACT INFORMATION

If you have any questions or comments about this Privacy Policy, the ways in which Covenant HealthShare collects and uses your information, your choices and rights regarding such use, or wish to opt out of certain communications, please do not hesitate to contact us at:

Email: privacy@covenantshare.org

Toll Free Phone: 855-539-1552