American Benefits Consulting ("ABC") Privacy Statement

TRUSTe

Effective Date: 10/19/2020

Purpose and scope

This Statement describes how American Benefits Consulting, an Alliant Insurance Services Inc. Company (“ABC”), and its affiliate American Benefits & Compensation Systems Inc., with a website located at http://www.abcsys.com and its corporate sites and applications that it maintains and hosts on behalf of its Clients, uses and discloses certain personally identifiable information that it receives on its application platforms within the context of providing Benefits Administration services to its clients. The use of information collected through our service offerings shall be limited to the purpose of providing the benefits administration services for which our clients have engaged us. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

ABC is dedicated to keeping any and all personally identifiable information private and secure. As an industry leading Insurance Benefits Consulting practice, we develop and host a variety of applications for our clients and their employees to facilitate and support the Benefit Administration services that we provide to said clients. This Privacy Policy describes how we collect and maintain personally identifiable information about users of our applications, the types of information we collect, the circumstances under which we may disclose that information, and our practices with regards to safeguarding the information we collect and maintain.

International users

ABC’s applications and Web sites are hosted in the United States. If your country of residence is outside of the United States, for example the European Union, Asia, or any other region with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that through your continued use of our applications and Web site, which are governed by U.S. law and this Privacy Policy, you are transferring your personally identifiable information to the United States and you consent to such transfer.

Data security & integrity

ABC has hosting centers that store and process Personal Data in various locations in the United States and follows the latest information security best practices to protect all Personal Data that passes through its systems and processing framework. ABC also takes significant precautions to keep Personal Data reliable for its intended use.

In order to safeguard your personal data such as your log in credentials, Employee ID, address etc we use custom software and other production infrastructure technologies that are designed to not only prevent unauthorized users from accessing our systems, but also to alert ABC personnel if any unauthorized access or suspicious activity is detected. These practices range from the implementation of encryption software such as HTTPS/SSL for all web traffic, password protected Web sites, specific policies around password strength, implementation of network firewalls to protect data residing within ABC’s network infrastructure, the implementation of sophisticated infrastructure technologies to monitor the production infrastructure that houses personal data, and well documented Information Security Policies and Procedures regarding the use and privacy of client and personal data as a whole.

In general, ABC makes best efforts and leverages industry best practices to safeguard and protect all personal, confidential and sensitive data that it manages on behalf of its clients and their respective employees. No method of transmission over the Internet, or method of electronic storage, is 100% secure however, therefore we cannot guarantee its absolute security. If you have any questions about security on our Web site, you can contact us at privacy@abcsys.com.

Types of data we collect

ABC collects information under the direction of its clients, and it works with its clients to help them provide notice to their constituents concerning the purpose for which personally identifiable information is collected. ABC may use this personal data for a variety of business purposes, including facilitating the delivery or provision of insurance products or services that are offered to the employees of our clients as part of our benefit programs, to establish or maintain client and business relationships, or to conduct other activities in support of providing benefits administration services to its clients and their employees.

Most of the information we collect comes directly from information supplied on applications or forms submitted by or on behalf of our plan participants, or directly from client Human Resource or payroll systems. We also may receive Personal Data from Insurance Carriers and other vendors with whom we partner in order to better serve our clients and plan participants, as well as to provide for a more seamless and customer friendly experience to our end users.

In general, ABC may obtain Personal Data from several different sources, including generic information from website visitors and individual benefit plan participants, policy and premium information from Insurance Carriers, and payment and other related product information from its partners that provide other services as part of ABC’s benefits service offering (for example Legal or Pet Insurance providers). We also obtain various types of Personal Data about plan participants from our clients directly.

Such data may include general contact information, first and last name, home address, phone and fax numbers, email address, and other personally identifiable information. It may also contain information about products and services ordered or provided, financial and payment information with regards to payroll deduction services that we provide, as well as user IDs, passwords, and other transaction or user registration related data.

The types and categories of information we collect on behalf of our clients about end users that use our products and services include:

  • information we receive from end users of our systems on applications for insurance and other forms,
  • information about your employment status and hire date from your employer, and
  • information about your policy related transactions with us; such as your coverage amount and payment history.

There also may be occasions where specific personal data is requested before an individual can enter certain sections of our applications or Web sites, or for participation in a certain benefits program. In all such cases, we will collect only personally identifiable information that is voluntarily provided by the user and in all cases consider such information strictly confidential.

In no way will your personally identifiable information ever be used, sold, or disclosed without your consent, except as set forth herein.

Data changes and opting out

Our clients, their respective employees, or agents of our clients may contact us if they wish to make any changes to their personal data, or if they would like to access and correct personal data that we maintain about them. Users also have the ability to opt-out of having ABC store personally identifiable information if they desire. In any of these cases, such persons can contact ABC by sending an email to privacy@abcsys.com or by following the instructions at the end of this privacy statement.

Also, to the extent that any of these individuals receives marketing communications from ABC and wishes to unsubscribe or otherwise stop receiving such communications, an individual can contact us at privacy@abcsys.com, and ABC will remove that person from all such communications going forward.

However, please contact your HR Administrator directly to update or remove/delete your personally identifiable information if you see that any basic employee information is incorrect (name, address, email address, employee ID #, etc) or if you do not wish to participate in the Voluntary or other Benefits programs that ABC provides since client Human Resources or payroll systems are in almost all cases the source of such Personal Data for ABC, and personal data maintained by ABC is updated and synchronized from these systems on a regular basis.

We will respond to all such requests for Opting Out or Personal Data changes typically within 5 business days, but in no case more than 30 calendar days from the date of the request.

Our clients and services

ABC provides a wide variety of services and solutions to its business clients (“Clients”) that facilitate Benefits Planning and Administration services. These services include, but are not limited to:

  • employee eligibility processing,
  • product enrollment processing,
  • automated payroll deduction services, and
  • online benefits enrollment, administration and support

Those eligible to participate in the Benefits Programs administered by ABC (“End Users”) normally have some direct or indirect employment relationship to our clients. Often Personal Data about the End Users is obtained from the clients’ Human Resources or payroll systems. In other cases, Personal Data is obtained directly from the End Users; for example, during End Users’ enrollment or registration on our Benefits Portals. Data collected may include personally identifiable information such as Social Security number, Employee ID, name and address. Wherever we obtain access to Personal Data about individuals or End Users, we are acting as a data processor on behalf of our clients, and we therefore conduct such activities strictly in accordance with their instructions and pursuant to our contractual arrangements with them.

If you are an End User with an existing direct relationship with one of our clients, you should refer to the client’s (your employer or former employer’s) provided information to understand the privacy practices that apply to personal data that they retain about you. Furthermore, if you would like to access and review your personal data, you should contact your employer with any such requests. If you would like to access and review your personal data maintained at ABC, we will cooperate as appropriate with these requests and will respond to such requests typically within 5 business days but in no case more than 30 calendar days. In such cases ABC can be contacted through regular support and account management channels, or reached directly at privacy@abcsys.com.

Other necessary disclosures

ABC may disclose personal data to business partners and subcontractors as necessary in connection with the performance of its services or solutions, or as otherwise appropriate in connection with a legitimate business need. If you do not want us to share your personal information with these companies, contact us at privacy@abcsys.com. We may for example disclose such information to an email service provider who sends service related emails to you on our or our clients’ behalf, to the owner of your applicable insurance policy (if you are not the owner), or to authorized members of your company’s Human Resources department as necessary. These service providers are authorized to use your personal data only as necessary to provide these services to us and are approved by our clients beforehand. If authorized by you, we will also share your information with your financial and/or legal advisors. Transfers to subsequent third parties are covered by the provisions in this Policy regarding notice and choice and the service agreement with our Clients.

ABC may also disclose personal data as necessary in connection with the sale or transfer of all or part of the business. In these situations, ABC will require the recipient of the data to protect the data in accordance with the relevant principles in the Privacy Shield framework, or otherwise take steps to ensure that the personal data is appropriately protected.

In certain situations, ABC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We also reserve the right to disclose personal data and/or other information about you that we believe, in good faith, is appropriate or necessary to enforce our agreements, to take precautions against liability, to investigate and defend ourselves against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of our applications and Web sites, and to protect the rights, property, or personal safety of us, our users and others associated with our organization.

Tracking technologies

Technologies such as COOKIES, beacons, tags and scripts are used by ABC and some of the companies we partner with in providing Voluntary Benefits offerings to our Clients and end users. These technologies are used in analyzing and auditing user behavior, tracking user sessions and data, and in limited cases to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by some of our partner companies on an individual as well as aggregated basis.

We use cookies to store user preferences and other individual session related information as well as for authentication. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our website, but your ability to use some features or areas of our website may be limited.

As is true of most web sites, we gather certain information automatically and store it in log files. This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you however we may combine this automatically collected log information with other information we collect about you for security, marketing or other business purposes.

A word on links to other sites

We are not responsible for the privacy policies of any business partner or other vendor sites that are linked to any of the web portals or applications developed or maintained by ABC. We have no control over these sites. Please consult the respective privacy policies associated with these sites for more information on their practices, and for instructions on how to opt-out of certain practices if desired. Our privacy policy does not apply to, and we cannot control the activities of, such other Web sites.

In the event of merger, sale or bankruptcy

In the event that we, or a part of our company related to ABC’s applications or Web sites, are acquired by, or merged with a third party entity, you agree that we may transfer or assign the information we have collected from you as part of such merger, acquisition, or other change of control, provided we arrange for the continued protection of your information. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we may not be able to control, due to legal or regulatory requirements, how your personally identifiable information is treated, transferred, or used.

In the event of these events occurring we will provide you with notice 30 days prior.

Changes to this privacy policy

We may change this privacy policy from time to time as Privacy laws and regulations evolve and as our contractual agreements with our Clients evolve from which we gain access to your Personal Data. If we have a significant change to our privacy practices which affects the way we store, manage share or otherwise handle your Personal Data, we will provide you with notice accordingly. All changes to this privacy policy will be published to our home page as well as to our Client Benefit portal applications and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

The latest revision date of the Privacy Policy will always be posted at the top of this document. If there is a change in how we use your personally identifiable information, we will notify you here, by email, or by means of notice on our home page or via links on our applicable web sites and applications prior to the change becoming effective.

Data retention

Subject to our agreement with our clients, ABC will retain personal data we process on behalf of our clients for as long as needed to provide services to our clients and End Users. ABC will retain and use this personally identifiable information as necessary to comply with our legal obligations and our agreements with our clients to manage, store and process your data on your behalf or as directed by End Users in specific situations upon request conformant to the Privacy Policy described herein.

EU-US data privacy framework program and dispute resolution

American Benefits Consulting, an Alliant Insurance Services Inc. Company (as well as its affiliate American Benefits & Compensation Systems, Inc.) (“ABC”) participates in and has certified its compliance with the EU-U.S. Data Privacy Framework Program. ABC is committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Data Privacy Framework, to the Framework’s applicable Principles. To learn more about the Data Privacy Framework, visit the U.S. Department of Commerce’s Data Privacy Framework List at https://www.dataprivacyframework.gov/s/participant-search. ABC is responsible for the processing of personal data it receives, under the Data Privacy Framework, and subsequently transfers to a third party acting as an agent on its behalf. ABC complies with the Data Privacy Framework Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Data Privacy Framework, ABC is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, ABC may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://feedback-form.truste.com/watchdog/request. Under certain conditions, more fully described on the Data Privacy Framework website at https://www.dataprivacyframework.gov/s/, you may invoke binding arbitration when other dispute resolution procedures have been exhausted.

General questions or requests for changes to personal data

If you have any questions about this Privacy Statement, or if you would like to request access to Personal Data that we maintain about you, please contact us as follows:

American Benefits Consulting
101 Park Ave, 14th Floor
New York, NY 10178
(212) 716-3410
privacy@abcsys.com

If your personal data changes, or if you no longer desire our service, you may correct, update, or delete inaccuracies, or have your account removed and/or deactivated from our systems by emailing our Customer Support at support@abcsys.com, or at privacy@abcsys.com. Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. We typically will respond to your request within 5 business days but in no case more than 30 calendar days. We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Thank you,

ABC Privacy Team

Allana Agard

Business Analyst

Allana joined Alliant in June 2022 as a Business Analyst I/Website Quality Assurance Analyst. In her role, she gathers data, analyzes requirements, and documents specifications for new systems processes and enhancements.

 

Allana has worked as a Business Analyst for 5+ years and has extensive experience in the Healthcare/Insurance industry for 10+ years.

Tara Emerich

Account Associate

Tara joined Alliant/ABC in 2021. Her responsibilities include investigating and resolving client and employee issues, preparing client invoices and reporting, and auditing enrollment and payroll files.

She has previously worked in the ABC call center and prior to that has 20+ years’ experience working with a variety of insurance lines.

Tara is licensed in Accident, Health, and Life insurance.

Tai Scott

Account Associate

Tai joined Alliant/ABC as an Account Associate in 2016 and is now an Account Associate II for the Voluntary Benefits Operations Team. Some of her responsibilities include processing and auditing the internal payroll processes and files, processing invoice payments to vendors, and assisting in implementation of new clients. 

Tai has held various roles in the health insurance and benefits industry for 7 years prior to coming to Alliant/ABC including processing COBRA, Coordination of Benefits & FSA statements and billing

Tai has a BA in Human Biology from Temple University and is a licensed broker in Life, Accident and Health.

 

Debbie Amador

Project Manager

Debbie joined Alliant/ABC in 2002. Her responsibilities include coordinating projects, managing project implementation plans as well as ongoing process improvement support for the Voluntary Benefits Operations Team. She has held various roles with her tenure at Alliant/ABC including client management, health and productivity development, and operations.

 

Debbie has a BA in Business Marketing from Western Washington University and is licensed in life and disability.

Brandi Coomes

Account Associate

Brandi joined Alliant/ABC in 2022. Her main responsibilities
include client file management and overall daily support of client
relationship. Brandi’s prior experience includes work as a program coordinator
and licensed insurance agent.

Brandi has a BS from LeTourneau University and is licensed
in Accident & Health and Life.

Arnaldo Desire

Benefit Advocate

Arnaldo joined Alliant/ABC in 2008. His role in the company is a Benefits Representative for the VB team. He provides customer service, professional support and guidance to client HR contacts and employees. In addition, he is responsible for client communications and client file management. With over 16 years of experience at ABC, he also worked on the Employee Benefits team.

Danielle K. Rainone

First Vice President – Consultant

Danielle joined ABC in March of 2014. She has been in the employee benefits field for more than 20 years, starting her career in sales of Retirement and Healthcare products. In 2000, she joined MetLife and held various leadership roles in key areas, including eBusiness, Sales Productivity and an International expat assignment in London. In 2008, Danielle joined CIGNA as leader of the Group Insurance Account Management and Service Operations organization, including Client Management, Implementation, Contracts and Eligibility. Most recently she was the VP of National Accounts Client Management at Prudential, leading a team managing a $3B+ block of Life and Disability business.

Danielle earned her BA in Marketing from Georgetown University.

Daniel Norton

Senior Manager, Executive Benefits

Dan joined ABC in 2007. He manages the team responsible for the implementation and day-to-day administration of our Executive Benefits plans. Dan has a BA in Business Management from the University of Colorado at Boulder and is licensed in life, accident, and health.

Michael R Grippo

Executive Benefits & Administration Systems

Mike has been at ABC since 1990, implementing and administering non-qualified executive benefit plans on behalf of some of America’s largest companies. Prior to joining ABC, he worked for a major life insurance company and a brokerage firm for over 10 years, where he gained expertise in actuarial software development, advanced underwriting, and life insurance product and competitive analysis.

Mike has a BS degree in actuarial science from the College of Insurance.

Jeffrey Jones

Executive Vice President

Jeff Jones is an Executive Vice President and Group Benefits Practice Leader. Jeff has been in the insurance and benefits industry since 1986. His responsibilities at ABC include Group Life and Disability/Leave Management practice lead, business development, client relationship management, and Executive Disability practice lead.

Jeff has a BA in Economics from Ursinus College.

Craig Guiffre

Executive Vice President/Managing Director

Craig has over 40 years’ experience in the Group Benefits industry and joined ABC in 2010 to oversee the consulting practices, administration, technology, and compliance areas. Today, he also leads Alliant’s National Absence, Disability and Life practice. He began his career with MetLife where he served in various sales, marketing, and operational capacities including head of National Accounts, Chief Marketing Officer for Institutional Business, and Senior Vice President and P&L owner for their Group businesses. He held a similar role at Guardian Life where he was responsible for the Group Life, Accident, and Disability lines of business as well as the Marketing organization and key technology initiatives. Most recently, Craig was Senior Vice President at CIGNA where he managed the Group Insurance sales, Account Management, and Product Development organizations.

Craig received his BS from Lehigh University and his MBA from Manhattan College.

Eric Levy

Executive Vice President/Senior Managing Director

Eric joined ABC in 2003 following a career leading Compensation and Benefits functions for several Fortune 500 companies. Eric has more than 30 years’ experience in the HR and Employee Benefits field. Eric has responsibility for overall leadership and growth, as well as shared business development responsibilities for ABC. In addition, he leads the East Region for Alliant Employee Benefits and holds national practice leadership roles for Alliant including voluntary benefits. Eric also maintains active consulting and relationship roles with many of ABC’s key clients. Prior to joining ABC, Eric was the SVP – Compensation & Benefits for Starwood Hotels and Resorts Worldwide. Eric also held senior Compensation and Benefit leadership positions for PepsiCo, Tambrands Inc., and HomeGrocer.com.

Eric has an undergraduate degree in Industrial and Labor Relations from Cornell University and an MBA in Finance from the Stern School of Business at NYU.