Privacy Policy

Last Modified: May 2020

Reform Labs (the “Company,” “we,” or “us”) is committed to protecting and respecting your privacy. This Privacy Policy (“Policy”) describes how we gather and use your information. This Policy applies to the information we collect, or you provide, through any of Reform Labs’ digital resources (for example, via our websites, applications, email correspondence, marketing materials, and other online or downloadable tools) (collectively, “online resources”) that reference or display a link to this Policy. By using websites and other online resources that reference or display a link to this Policy, you are accepting and agreeing to the practices described herein.

How We Collect Information and What Information We Collect

We receive information from you, your employer, or your employer’s broker or carrier. The amount and type of information we collect, and how we collect it, depends on which features of the range of online services we offer (“Services”) are being used. We collect information that you, your employer, or your employer’s insurance broker or carrier give us by filling in forms or data fields through our online resources. If you submit any personal information related to other people in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Policy. We may combine the information collected from you through the Services with information we receive from and about you from others, and use the combined information in accordance with this Policy. Some examples of the personal information we collect include:

• Registration Information: We may collect your email address and password (your login credentials), and other information necessary to register and set up your account for our Services.
• Identity information: Depending on the Services you, your employer, your employee benefits broker, benefits carrier or MEWA, or the MEWA management company engaged by your broker, carrier or MEWA chooses to use, the information we collect may include information necessary to manage and track human resources processes and benefits, including your name, date of birth, Social Security Number or tax identification number, contact information (postal address, email address, phone number), function, and contact preferences.
• Dependent information: Depending on the Services you, your employer, your employee benefits broker, benefits carrier or MEWA, or the MEWA management company engaged by your broker, carrier or MEWA chooses to use, we may collect names and identifiers for members of your family and others (i.e., dependents) that you have chosen to cover with your benefits.
• Payment Information: To the extent necessary to process a payment, you may also give us certain of your financial information, including credit card information, bank details, tax data, or information regarding credit history.
• Insurance information and Protected Health Information (PHI): If you use our Services to manage or obtain insurance (health, dental, vision, life & disability, etc.), we may assist you with enrollment in insurance coverage, and Reform Labs may process information related to your insurance coverage, including eligibility and enrollment information. Reform Labs takes steps to protect PHI consistent with the Health Insurance Portability and Accountability Act (HIPAA), and its attendant regulations. Please see our disclosures Related to Insurance Services in Section 3 (Disclosure of Your Information) below.

We collect information from your computer or electronic devices. We (or a third-party designated by us) receive certain types of information whenever you visit our websites or otherwise use Reform Labs’ online resources.

• Device and IP Information: We collect the Internet Protocol (IP) address used to connect your computer to the internet, information about your browser type and version, time zone settings and geographic location, browser plug-in types and versions, and operating system and platform. If you use a mobile device to access our website or online resources, we may collect information about your device, including your device ID and device type, as well as usage information about your device and your use of our mobile websites and other mobile resources. Reform Labs may log this information and analyze it to determine anomalous behavior, detect threats and generally improve our Services.
• Cookies and Beacons: We collect information provided by tracking technologies, such as cookies, beacons, single-pixel tags, local share objects (Flash), local storage, Etags and scripts.
• Visit and Use Information: We collect information about your visits to our website and use of our online resources, including the full Uniform Resource Locators (URL), clickstream to, through and from our website (including date and time), the products or services you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
• Information from Third-Party Sites and Services: In cases where Reform Labs has integrated with third party providers or services, we may have access to your information on such third-party services

How We Use Your Information

Information we receive from you, your employer, or your employer’s broker or carrier. We use the information we collect from you, your employer, or your employer’s broker or carrier, to carry out our obligations arising from contracts entered in to between Reform Labs and either you, your employer, your employee benefits broker, benefits carrier or MEWA, or the MEWA management company engaged by your employee benefits broker or benefits carrier or MEWA, and to provide you, your employer, your broker, carrier or MEWA, or MEWA management company with the information, goods, and services requested from us. We may also use this information to notify you about changes to our Services, or changes to regulatory requirements that may affect our Services or your use of them; and to provide you with information about Services we believe may interest you.

Information we receive from your computer or electronic devices. We (or a third party designated by us) may use this information to improve our website and ensure that content is presented in the most effective manner for you and your computer or device; to measure or understand the effectiveness of advertising we deliver to you and others, and to deliver relevant advertising to you; and to make suggestions and recommendations to you and other users of our website about goods or services that may interest you or them.

Disclosure of Your Information

Rest assured that Reform Labs will never rent or sell your personal information. We will share your personal information only as described below.

• Reform Labs Personnel: Reform Labs personnel and authorized consultants and/or contractors may have access to user information as necessary in the normal course of our business.
• Third Parties: We may share your personal information with your employer(s), employee benefits brokers and benefits carriers, whom your employer and broker has chosen to receive quotes for benefits or enroll in coverage. In each case, Reform Labs will share what it determines in good faith to be the least amount of information necessary to fulfill the need of such third party. We may use, access, transmit and process PHI for you in our capacity as a Business Associate as defined under HIPAA. A “Business Associate” is a person or entity that performs certain functions that may involve the use or disclosure of PHI for a Covered Entity (like an insurance carrier). The reasons that a Business Associate like Reform Labs may use and disclose PHI is to help carry out benefits-related services in connection with providing the Service, or as otherwise permitted under applicable law.
• Protection of Reform Labs, Others: We may share personal information when we believe in good faith that such release is necessary to comply with any legal obligation; to enforce or apply our Terms of Use and other policies; or to protect the rights, property, or safety of Reform Labs, our employees, our users, or others. This includes the sharing of personal information with public authorities, and other companies and organizations, in the event of a cyber security incident or for fraud protection, for example. We will also disclose your information to third parties in the event we sell or buy any business or assets, in which case we may disclose your information to the prospective seller or buyer of such business or assets, or if Reform Labs or substantially all of its assets are acquired by a third party, in which case information held by us about our users may be one of the transferred assets.
• Service Providers: Reform Labs may share personal information as well as information from tools such as cookies, log files, device identifiers and location data, with third-parties that help Reform Labs provide services to you (“Service Providers”). Our Service Providers will be given access to your information only as is reasonably necessary for Reform Labs to provide the Services. We require Services Providers to protect your data in a manner consistent with this Policy and to limit the use of such information to the performance of services for Reform Labs. Reform Labs may also remove parts of data that can identify you and share only anonymized data with Service Providers, including combining your information with other information in a way that it is no longer associated with you.
• Data Storage: Your encrypted personal information is stored on servers provided by a third-party cloud-based service provider that protects and stores your information in a manner that is consistent with this Policy.
• With Your Consent: Except as noted above, we will contact you when your personal information is shared with third parties or used for a purpose incompatible with the purpose(s) for which it was originally collected, and you will be able to opt out to prevent the sharing of this information.

Communications

We will never provide your email address to a third party without your explicit permission. Reform Labs may send you emails with Reform Labs-related news, products, offers, surveys or promotions. Pursuant to the Services provided by us to you, your employer, broker or carrier, you may also receive email notices from us informing you of actions that either have been performed by us, or are required to be performed by you, via our online resources. If you do not want to receive email from us click the “unsubscribe” instructions contained in each email message.

Please note that if you opt out of receiving email messages from us, you will continue to receive all emails related to our systems (e.g., those regarding forgotten user passwords) and legal notices (e.g., updates to our policies).

Security of Your Information

Reform Labs has implemented industry standard administrative, technical, and physical security safeguards designed to protect the personal information you provide. If you choose, access to your information on our Services is password-protected, and data is protected by SSL encryption when it is exchanged between your web browser and the Service. We support secure https access to the Service websites and regularly monitor our system for possible vulnerabilities and attacks to protect information stored on our servers. While we endeavor to create online resources that are always secure and reliable, we cannot guarantee the confidentiality of communications or materials transmitted to or from us (or to or from any other party), via the Reform Labs website or other online resources. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our administrative, technical, or physical safeguards and we accept no responsibility and are in no way liable for the security of the information transmitted via our website or other online resources.

You are responsible for maintaining the confidentiality of your Services access information and password and for restricting access to your devices, and you agree to accept responsibility for all activities that occur under your password. Please help keep your account safe by using a strong password.

External Websites

Our online resources may, from time to time, contain links to, or otherwise make available, third-party websites, services, or other resources not operated by us or on our behalf (“Third Party Services”). If you access Third Party Services by clicking on a hyperlink consult the privacy policies of those websites before you submit information to them. Reform Labs is not responsible for the privacy practices of third-party websites. These links are provided as a convenience only and do not constitute an affiliation with, endorsement or sponsorship of the Third Party Services.

Agreement for the Collection and Use of Your Information;

By using Reform Labs websites or other online resources, you acknowledge that you have read the terms of this Privacy Policy and you agree with the collection and the use of your information as set out herein.

Changes to Our Privacy Policy

We may amend this Policy from time to time. Changes we make to the Policy in the future will be posted on this page. Please check back frequently to see any updates or changes to the Policy. Your continued use of our websites and online resources following the posting of changes to this Policy will indicate your acceptance of the Policy changes.

Questions

If you have any questions, comments or requests relating to this Privacy Policy, please send an email to us.