Web Privacy Statement
Welcome to The Cotillion Group's website. We appreciate your interest in us.
At The Cotillion Group, we take the issue of privacy very seriously. We want to assure Users of our Website (meaning any individual, including site visitors as well as those individuals who provide personal information via this Website, herein referred to as "User(s)") that their personal information is secure and maintained in confidence, consistent with applicable state and federal laws. By "personal information", we mean data that uniquely identifies an individual, such as a name, address, social security number, telephone number or other individually identifiable information.
I. Information Collected Online
From time to time, we may request personal information from you at our site in order to deliver requested materials to you, respond to your questions, or deliver a product or service. When you visit and navigate our site and when you communicate with us via our site, we will not collect personal information about you, unless you provide us that information voluntarily.
How you use the The Cotillion Group Website will determine whether or not we need to collect information from you and how much information we collect. For many features, we do not require any information on who you are or ask questions about you. For some of our features, we need to either verify your identity through a login process, or collect sufficient information from you to provide the service of that feature.
B. Email, Product Inquiry
The Cotillion Group provides email boxes for comments and questions. We invite Users to use those email boxes to send secure messages to The Cotillion Group regarding Website accounts or The Cotillion Group's products or services. The Cotillion Group retains copies of these secure messages for 1,000 days, but does not disclose secure messages to any non-affiliated third parties.
Access to the information provided through the use of these secure messages and feedback forms will be limited to those The Cotillion Group representatives or other appropriate third parties who need to view this information to respond to the inquiry or to perform their job responsibilities.
The Cotillion Group also invites Users to send emails and access products and services from non-related service providers through links on the The Cotillion Group pages. Users should also review the privacy polices contained on these Websites for information regarding how the service providers use the information.
A cookie is a small piece of information about an Internet session that may be created when an individual accesses a Website. Cookies can contain a variety of information, including the name of the Website that issued them, where on the site the User visited, passwords, and even Users' names that have been supplied via forms. Note that most Web browsers can be modified by the User to prevent cookies from being attached to the User.
II. Use of Information Collected Online
The Cotillion Group does not sell your non-public personal information to anyone. Unlawful disclosure of your personal information, including social security number, is prohibited.
All information submitted by any individual to The Cotillion Group may be retained to provide a record of such communications and to comply with any applicable legal and/or regulatory requirements and may be verified for accuracy. In addition:
The Cotillion Group uses any information submitted by you on the The Cotillion Group sites as well as information submitted by you on sites of non-related service providers that are linked to The Cotillion Group to provide improved customer service, to provide relevant health care related information, to update information we have about you and/or your group, and to monitor the effectiveness of our online services. In some cases, The Cotillion Group may use such information to provide you with access to information on products and services offered by The Cotillion Group or our affiliates.
Your e-mail address information will be used only for The Cotillion Group-related mailings and will not be given, sold or rented to any other party for any other use without your prior approval.
Information may also be "cleansed" by The Cotillion Group (stripped of any information which could identify you personally, such as your name or e-mail address), aggregated with other data, and used for general research, classification purposes, marketing, or other purposes without permission, but only in non-individually identifiable forms.
III. Access to Information Collected Online
Certain The Cotillion Group employees may be provided with information regarding Users in order to respond to the individual's needs and provide requested information regarding specific products or services. Certain employees will also be provided with information regarding Users in order to administer their or their group's benefit programs and to monitor the effectiveness of the online services. The Cotillion Group employees are required, by written confidentiality statements, corporate policies, and state or federal laws or regulations to maintain the confidentiality of personal information and to use strict standards of care in handling the information. Employees who do not conform to these confidentiality requirements are subject to disciplinary sanctions that may include dismissal.
B. The Cotillion Group Affiliates, Business Associates and Service Providers
The Cotillion Group may disclose personal information of its Users collected through its Website as permitted by law to affiliates along with non-related service providers that assist The Cotillion Group in meeting the needs of its customers. Information collected by affiliates and non-related service providers may also be shared with The Cotillion Group as permitted by law. All such information will be disclosed to respond to the individual's needs and to provide information about products or services offered by or through The Cotillion Group, The Cotillion Group's affiliates and the non-related service providers. Personal information is treated with the same standards of confidentiality that The Cotillion Group applies to other confidential information. The Cotillion Group's affiliates are subject to corporate policies regarding privacy and confidentiality and The Cotillion Group's non-related service providers and Business Associates are legally bound by contract to employ at least the same strict standards of confidentiality as employed by The Cotillion Group.
C. Third Parties
Other than as set forth above, The Cotillion Group does not transmit any personal information collected through its Website to any third party without the permission of the individual. Personal information may be transmitted, however, if there is a specific need to complete a transaction requested by the individual. Health plan administrators will have access to online enrollment applications, but not to other personal information collected online by The Cotillion Group.
IV. Compliance Assurance
The Cotillion Group uses commercially reasonable computer security technology selected and implemented to provide adherence to the security and privacy policies described in this online posting. Although we make reasonable efforts to protect your information from unauthorized use or alteration, you should be aware there is always some risk in sending information over the Internet.
B. Account Access
Consistent with the requirements set forth under certain state and federal laws, The Cotillion Group grants access to personal information only to those employees, affiliates and third parties as required to provide healthcare products and services, or as you permit. All such employees, affiliates and third parties are subject to privacy policies, at least as restrictive as the policy described in this online document.
C. Internal Compliance Program
D. Questions and Concerns
V. Changes to This Statement
The Cotillion Group may change this Statement from time to time. This Statement is not intended to and does not create any contractual or other legal rights in or on behalf of any party.