Who is Gravie?
Section 1312(e) of the Affordable Care Act and the privacy and security standards set forth in the Affordable Care Act and 45 C.F.R. 155.260, establish the scope of our authority to collect Personal Information for the purposes outlined above. Gravie Agency LLC is also a licensed insurance producer in certain states and has entered into agreements with certain health insurance carriers to market and sell their products on and off the exchange. In accordance with state licensing, appointment, and privacy requirements, Gravie Agency LLC collects Personal Information for purposes of providing services under these agreements.
Available products and services on the Platform include personalized online decision support systems to help you review, compare and select policies of insurance, health savings accounts (HSAs), health reimbursement arrangements (HRAs), group health plans, and other products and services made available by Gravie. We will also help you to arrange for payment of insurance policies.
Our Relentless Commitment to the Security and Privacy of Your Information
Gravie takes very seriously our responsibility to always ensure the security of member information we collect through the course of doing business. While laws and regulations are in place to protect your privacy, we opt to take additional steps to prevent security breaches, like adopting National Institute of Standards and Technology guidance, performing regular risk assessments and simulations, and maintaining an industry-leading information security and privacy training program for our employees. We know you have enough to worry about, and we aim to take concern over the privacy of your information off of the list.
We maintain accounts on third-party websites, such as social media sites, as tools to better interact with the public. The security and privacy policies of third-party websites apply to your activity on those websites. Users of third-party websites often share information with the general public, user community, and/or the third party operating the websites. You should review the privacy policies of all websites before using them and ensure that you understand how your information may be used. You should also adjust privacy settings on your account on any third-party website to match your preferences.
Access to and use of the Platform and/or the Gravie Services is limited exclusively to users located in states within the United States where the Platform and/or the Gravie Services is available. The Platform and/or the Services are not available to users located outside the United States. Accessing the Platform and/or obtaining the Services from jurisdictions where content is illegal, or where we do not offer the Platform and/or the Services, is prohibited.
Collection of Personal Information
Personal information is information from and about you that may be able to personally identify you. We treat any information that may identify you as personal information. We collect most Personal Information directly from you. We collect Personal Information from users of this Platform who voluntarily choose to disclose this information in order to access the Gravie Services available through this Platform.
In order to provide the Gravie Services, we need to collect some of your Personal Information, which may include your name, username, banking and financial information, insurance policy number, social security number, date of birth, address, contact information, marital status, information about your sex, gender, gender identity, sex life, and related medical conditions, and medical information, such as whether you use tobacco. If you are considering family coverage, we will need to collect the same information on family members. If you are enrolling in a group health plan, you may be asked to respond to medical questions on an application for coverage. To arrange for payment of individual insurance policies, you will need to provide us with bank information. To determine your eligibility for government subsidies (such as premium tax credits on a state or federal health care exchange), we will need your social security number and financial information.
We collect Personal Information from you when you:
- register to become a Member;
- use tools on the Platform;
- conduct a transaction (e.g., purchase coverage) through the Gravie Service; and
- choose to provide us with additional information.
The decision to provide your information is voluntary and is not required. However, if you choose not to provide the requested information, Gravie will not be able to make its products and services available to you.
We will also collect information automatically as you navigate through our Platform. We use the following technologies to automatically collect data:
- We use other third party tools, such as Datadog, which allow us to track the performance of our Platform. These tools provide us with information about errors, mobile application and website performance, and other technical details we may use to improve our Platform.
We collect Personal Information from all users of this Platform in order to enhance the user’s experience while visiting the Platform and to improve the design and content of the Platform, including:
- the date and time of your visit to our Platform;
- your location at the time of your visit, down to the city-level;
- the number of visitors to this Platform;
- the websites from which users enter this Platform;
- the pages users visit while on this Platform;
- the actions (e.g., button clicks) users take while on this Platform;
- the length of these visits;
- the names of the users’ Internet providers and internet protocol addresses;
- the users’ browser information;
- the speed of the users’ connections, and
- the search terms used to find this Platform, as applicable.
How We Use Your Personal Information
We may use your Personal Information for the following purposes:
- Operate, maintain, supervise, administer, and enhance our Platform or the Gravie Services, including monitoring and analyzing the effectiveness of content on the Platform, aggregate site usage data, and other usage of the Platform and/or the Gravie Services such as assisting you in completing the registration process.
- Provide our Gravie Services to you, in a custom and user-friendly way.
- Provide you with information Gravie Services that you request from us or that may be of interest to you.
- Promote and market our Platform and/or the Gravie Services to you. For example, we may use your Personal Information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about services or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services on third party websites. You can opt-out of receiving these emails at any time as described below.
- To provide you notices or about your account.
- Contact you in response to a request.
- To notify you about changes to our Platform and/or the Gravie Services we offer or provide through them.
- Fulfill any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
- Anonymize and aggregate information for analytics and reporting.
- To respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations.
- Authenticate use, detect fraudulent use, and otherwise maintain the security of our Platform and the safety of others.
- To provide you information about goods and services that may be of interest to you, including through newsletters.
- Any other purpose with your consent, such as through the Gravie “Release of Information” form.
How We Share Your Personal Information
We may share Personal Information with third parties in certain circumstances or for certain purposes, including:
- Our business purposes: We may share your Personal Information with our affiliates, vendors, service providers, employers, referral partners, and business partners, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security advisors, in order to coordinate payments, provide products and services, and enable administrative functions related to the services you choose. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
- With your consent: We may share your Personal Information if you request or direct us to do so, such as through the Gravie “Release of Information” form.
- Compliance with law: We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
- Business transfer: We may share your Personal Information 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 our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users are among the assets transferred.
- To enforce our rights: We may share your Personal Information to enforce any applicable terms and conditions and Terms of Service , and to ensure the safety and security of our Gravie Services and our users.
- De-identified information: We may also disclose de-identified information, so that it cannot be reasonably used to identify any individual, with third parties for marketing, advertising, research, or similar purposes.
- To market our products and services: We may share your Personal Information with affiliates and third parties to market our products and services. Please note that we will never sell your information for marketing purposes, nor will we share your information with third parties for their direct marketing purposes, and you always have the right to opt-out of receiving communications from us.
- Third party analytics: We use Google Analytics to understand and evaluate how visitors interact with our Platform and/or the Gravie Services. These tools help us improve our Platform and/or the Gravie Services, performance, and your experience.
Each type of web browser provides ways to restrict and delete cookies. Browser manufacturers provide resources to help you with managing cookies. Please see below for more information.
- Google Chrome
- Internet Explorer
- Mozilla Firefox
- Safari (Desktop)
- Safari (Mobile)
- Android Browser
- Opera Mobile
For other browsers, please consult the documentation that your browser manufacturer provides.
If you do not wish to have your email address used by Gravie to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any e-mail or other marketing communications you receive from us or logging onto your Account Preferences page. This opt out does not apply to information provided to Gravie as a result of a product purchase, or your use of our Platform and/or the Gravie Services. You may have other options with respect to marketing and communication preferences through our Platform.
Accessing, Correcting, and Deleting Your Personal Information
In addition to any data access capabilities available through the Platform, you may contact us by phone at 800.501.2920 to inform us of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. You may also have certain deletion rights in accordance with applicable law. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
We retain the data we collect for different periods of time depending on what it is, how we use it and applicable legal requirements. We may retain some data for longer periods of time than other data when necessary for legitimate business or legal purposes, such as legal retention requirements, security, fraud and abuse prevention, or financial record-keeping.
We have taken steps and implemented administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use of Gravie data. Where you have been given or you have chosen a password, you agree to protect the confidentiality of your user ID and password, and not to share or disclose your user ID or password to any third party.
We strive to use best practices and industry standard security measures and tools to protect your data. We protect your transactions involving Personal Information over the Internet using Transport Layer Security (TLS) technology. We restrict access to your Personal Information in our database to our authorized employees, our agents and certain of our authorized partners. We are not responsible for the circumvention of any privacy settings or security measures contained in your operating system or mobile device.
This Platform is not designed for, or intentionally targeted at, users under the age of 18. We will not knowingly collect any Personal Information directly from users under the age of 18 online through this Platform. Parents/legal guardians or personal representatives of children under the age of 18 may register on a child’s behalf in order to purchase a child-only plan. If you believe that we have collected Personal Information from a user under the age of 18, please contact us.
Do Not Track Signals
Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Platform is not currently set up to respond to those signals.
If you are enrolling for individual insurance through Gravie Agency LLC, you may also submit a complaint to the Centers for Medicare and Medicaid Services (CMS) via the Federally Facilitated Marketplace (FFM) Call Center by calling: 800.318.2596, 24 hours per day, 7 days per week, except holidays.
In accordance with California Civil Code Sec. 1789.3, California residents are entitled to know that they may file grievances and complaints with the Complaint Assistance Unit of the Division of Consumer Services of the Department of Consumer Affairs. Grievances and complaints may be submitted in writing to 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916.445.1254 or 800.952.5210; or by email to firstname.lastname@example.org.