Privacy Notice

Welcome to Combined Benefits Group (CBG) Internet website (CBG Site). It is important for users to understand what information CBG collects and maintains about users when visiting the CBG Site.

As part of the day-to-day business operations of CBG, a Texas corporation, we receive and maintain certain information regarding our clients and our clients’ employees. CBG limits the collection of personal information to what is required for benefit administration or for underwriting purposes. Information received from the CBG Sites depends, in part, on what users do when transacting business on the CBG Sites. CBG respects the privacy of every individual who visits the CBG Sites. Therefore, CBG would like to define the types of information received and describe how it is maintained in this privacy policy (“Privacy Policy”). This policy refers only to the information collected and maintained from the CBG Sites.

Using the CBG Sites confirms a user’s consent and agreement to this privacy policy including collection, use, and disclosure of information by CBG to authorized parties, as described herein. A user’s visit to the CBG Sites and communication with CBG via the CBG Sites is subject to this Privacy Policy, as well as our User Agreement or Terms of Service. If a user does not agree with this privacy policy, the user can choose to stop using the CBG Sites.

Disclosure of Non-Public Personal Information:
CBG defines “personal information” as data that is unique to an individual, such as that individual’s name, address, age, Social Security Number (or other identifier, such as driver’s license or state identification number or employee identification number), e-mail address, or telephone number. We may request personal information from users to deliver requested materials to individuals, respond to user questions, or deliver a product or service. Any personal information that users may provide via the CBG Sites will be used solely for the purpose specified by a user’s employer.

CBG restricts access to nonpublic personal information unless it is needed to complete a transaction that is authorized by users or a user’s employer. Certain information may be shared with a user’s employer, providers, and vendors (such as carriers, brokers, and wellness providers) that are authorized by a user’s employer to assist in supplying products and services to users. Information is provided to nonaffiliated third parties as required by federal and state law. CBG maintains physical, electronic, and procedural safeguards that comply with federal regulations to guard users’ nonpublic personal information.

Other Information Collected:
CBG may ask for personal information (such as date of birth, social security number, name, address with zip code, telephone number and e-mail address) to verify appropriate CBG Sites usage. This information is collected from a user’s employer (CBG’s client).

Through use of the website, CBG may collect information about user diagnosis and/or medical conditions, treatment/medical history (including prescription medications), health insurance information, and/or financial or other relevant information, as necessary to submit coverage determination requests. The information CBG collects may include “Protected Health Information,” as defined by HIPAA.

As a normal course of business, CBG records phone conversations regarding a user’s benefit enrollment choices. These voice recordings act as the user’s electronic signature and are subject to quality checking by our internal staff. A transcript of the recording may be requested and provided to a vendor authorized by the employer, or by the employer’s human resources or benefits department to verify a benefit election.

The CBG Sites may write and read “cookies” to a user’s web browser. A cookie is an element of data that is stored temporarily or permanently on the user’s computer and can communicate between the CBG Sites and the user’s browser. A cookie is not a computer program and has no ability to read data residing on a computer or instruct it to perform any function. We do not use cookies to store personal information about users.

We may also use “client-side page tagging” which uses code on each page of the CBG Sites to write certain information about the page and the visitor to a log when a page is rendered to a browser. This technique is commonly used on commercial websites. “Tagging” does result in JavaScript or other client-side code to be run on a user’s computer, but it is limited to providing information about the page from the CBG Sites that a user is requesting, and the configuration of the user’s browser. It will not read any of the data files on a computer or execute other functions. It does not extract any personal information about users. A user can prevent tagging by disabling JavaScript in the browser, but that may prevent the user from utilizing any or all the CBG Sites features.

Children under 13:
The CBG Sites are designed and directed to adults; it is not directed to children under the age of 13. We do not knowingly collect personal information from children, although we use and disclose children’s personal information that we have obtained voluntarily from users, a user employer, or other third parties about the administration of a user’s benefit programs. If users are under the age of 13, they are not permitted to submit information to the CBG Sites.

Users Emails to Us:
Please note that user’s email, like most non-encrypted Internet communications, may be accessed and viewed by others without the user’s knowledge and permission while in transit to us. Therefore, please do not send an e-mail to us with personal information. CBG has no way to secure personal information sent by the user via e-mail. If users send us e-mail to ask a question, we will only use the information provides to answer a user’s request. Personal information will not be provided to a non-affiliated third party without a user’s prior consent, except as permitted by federal and state law.

Retention of Information Collected:
The non-public personal information collected and maintained from the CBG Sites will be retained for seven years from the date of its creation or the date when it was last in effect, whichever is later; or longer, as required by law. Personal information is disposed of in a secure manner when no longer needed for the purpose for which it was obtained and used.

Direct Access to Other Websites:
CBG offers direct links to other separate and individual web sites that offer information, which could be beneficial to client employees. Since these direct links are separate web sites independent of the CBG Sites, they may have different privacy guidelines. If users have questions about those websites, we suggest they contact the appropriate controlling authorities of these sites or review their privacy policy.

Correction/Updating Personal Information:
If the personally identifiable information of a user of our services changes or an employer’s information changes, or if the user or employer no longer desires to use the services on the CBG Sites, CBG will endeavor to provide a way to correct, update or remove that user’s personal data. It is the user’s responsibility to verify that their personal information is accurate. To correct or update personal information, it may be necessary to contact the user’s human resources, benefits department, or third party agent authorized by the employer. Upon request and verification of identity, CBG will provide personal information collected during the benefits enrollment process.

Inquiries, Complaints, or Disputes:
For inquiries, complaints, or to dispute any information on this website, please contact the user’s human resources, benefits department, or third-party agent designated by the employer. Upon request by the human resources, benefits department, or third-party agent designated by the employer, CBG will investigate and document any inquiries, complaints, or dispute of information. A report will be provided to the user’s human resources, benefits department, or third-party agent designated by the employer. Any release of information in the report will be at the discretion of the human resources, benefits department, or third-party agent designated by the employer.

Security:
CBG takes precautions to protect its users’ personal non-public information. We implement various security measures in accordance with industry standards to protect the security of personal information both on the CBG Sites, and off-line.

Technical Security: CBG uses SSL (Secured Socket Layer) encryption to protect sensitive information online. When the registration/login form asks users to enter sensitive information, the information is encrypted and is protected with the encryption software. While on a secure page (such as the login page) using a modern web browser (such as Microsoft Edge or Chrome), the lock icon on the bottom of web browsers or to the left of the web address bar, becomes locked, as opposed to unlocked, or open, when users are just browsing the Internet. Note that browser choices are personal, and a user’s browser may display the security status differently. Please check the browser’s website for more information on secure web pages.

Administrative Security: CBG protects user-information off-line and data at rest. Only CBG employees who need the information to perform their jobs are granted access to personally identifiable information. Furthermore, all CBG employees are kept up to date on CBG security and privacy practices.

Physical Security: The computers and servers that store personally identifiable information are kept in a secure environment.

If users have any questions about security at the CBG Sites, please submit questions in writing to us at:

Security Policy Administrator
Combined Benefits Group
1202 Lakeway Drive, Suite 6
Austin, TX 78734

Notification of Changes to Privacy Policy
CBG reserves the right to change or update this Privacy Policy at any time. If we revise our Privacy Policy, we will post the revised policy on the CBG Sites. As we may make changes at any time without notifying users, we suggest that users periodically consult this Privacy Policy. Please note that our rights to utilize a user’s personal information will be based on the privacy policy in effect at the time the user submits the personal information to us. This Privacy Policy is not intended to and does not create any contractual or other legal right or obligation on behalf of any party.