Privacy Policy

PRIVACY POLICY

Last updated: September 2026

THIS PRIVACY NOTICE DESCRIBES HOW VOLUNTARY BENEFITS AT WORK, INC., ITS AFFILIATES AND SUBSIDIARIES (“VB@WORK,” “WE,” “US,” “OUR”) COLLECT, USE, DISCLOSE AND PROTECT PERSONAL INFORMATION IN RELATION TO YOUR ACCESS TO OR USE OF THE SERVICES, AND DESCRIBES YOUR PRIVACY RIGHTS AND HOW THE LAW PROTECTS YOU.

This privacy notice applies to all of the services, websites, text messaging programs and apps offered by Voluntary Benefits at Work, Inc. (collectively, the “Services”), but excludes Services that have separate privacy notices that do not incorporate this privacy notice.

VB@Work is committed to safeguarding the privacy of the people we serve. We use personal information to provide and improve the Services. By using the Services, you agree to the collection and use of information in accordance with this privacy notice.

The VB@Work company that provides each Service is primarily responsible for the personal information collected and held in relation to that Service. A description of our Services and our contact details are available here: https://www.vbwork.com/contact.htm

1. PERSONAL INFORMATION WE COLLECT

We collect only the personal information necessary to provide and improve our Services. We may collect personal information about you from a variety of sources, including information we collect from you directly (e.g., when you contact us) and from other sources, described below.

We may be required by law to collect certain personal information about you, or as a consequence of any contractual relationship we may have with you. Failure to provide this information may prevent or delay the fulfillment of these obligations. We will inform you at the time your information is collected if providing certain personal information is required and the consequences of not providing it.

1.1. Information we collect directly from you

Depending on the Service, website or app you are using, the categories of information we may collect directly from you include:

  • personal details (e.g., name, date of birth);
  • contact details (e.g., phone number, email address, postal address or mobile number);
  • government-issued identification details (e.g., Social Security number, passport details);
  • health and medical details (e.g., health certificates);
  • policy details (e.g., policy numbers and types);
  • bank details (e.g., payment details, account numbers and routing numbers);
  • driver’s license details;
  • online log-in information (e.g., username, password, answers to security questions);
  • information relating to any claims;
  • messages you send to us through the Services, including by email or text message;
  • other information we receive from you on applications or required questionnaires (e.g., occupation, current employer); and
  • information we collect automatically from you (e.g., clickstream data and other data collected using cookies and other device-identifying technologies (“Cookies”)). Further information about our use of Cookies is available in Annex A below.

Our websites do not currently respond to “Do Not Track” signals sent by web browsers, and we do not alter our data collection and use practices when we receive such a signal. Third-party analytics providers we use, such as Google Analytics, may collect information about your online activities over time and across different websites.

1.2. Information we collect from other sources

The categories of information we may collect about you from other sources are:

  • personal details (e.g., name, date of birth);
  • contact details (e.g., phone number, email address, postal address or mobile number);
  • bank details (e.g., account numbers and routing numbers);
  • financial information from consumer-reporting agencies for the purpose of ascertaining credit history; and
  • policy details (e.g., policy numbers and types).

We may receive such information from your employer, insurance carriers, consumer-reporting agencies, our affiliated companies, or other third parties in the course of conducting our business.

1.3. Sensitive personal information

We may also collect certain information about you that is considered more sensitive under applicable law, such as:

  • information about your race, ethnic origin, religious views and philosophical beliefs, membership of professional or trade associations, gender identity or sexual orientation for diversity and statutory monitoring purposes where appropriate; and
  • health, biometric or disability information required to administer policies or process claims.

1.4. Children’s privacy (COPPA)

We do not knowingly collect online information from children under the age of 13. Our Services are marketed toward adults. If we are notified that we have collected personal information, as defined by the Children’s Online Privacy Protection Act (“COPPA”), of a child under the age of 13, we will delete the information as expeditiously as possible.

2. HOW WE USE YOUR PERSONAL INFORMATION AND THE BASIS ON WHICH WE USE IT

We may use your personal information to:

  • provide, maintain, protect and personalize our Services, including our insurance products, consulting and brokerage services, and to monitor the usage of our Services;
  • manage your account, including your registration as a user of the Services;
  • perform a contract, including the development, compliance and undertaking of the purchase contract for the products or services you have purchased or any other contract with us through the Services;
  • contact you by email, telephone, SMS/text message, or other equivalent forms of electronic communication regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable for their implementation;
  • contact you with information about products, services and events offered through your employer, or that are similar to those you have already purchased or enquired about (unless you have opted out of marketing, or we are otherwise prevented by law from doing so);
  • respond to your enquiries and manage your requests;
  • cooperate with regulators and law enforcement bodies;
  • resolve complaints and handle requests for data access or correction;
  • protect your, our or others’ rights and interests; and
  • communicate with you regarding your account or changes to our policies, terms and conditions.

Some jurisdictions require a legal basis to use or process your personal information. In most cases the legal basis will be one of the following:

  • to fulfill our contractual obligations to you in connection with your policy or contract with us, for example using your contact details to reply to your requests. Failure to provide this information may prevent or delay the fulfillment of these contractual obligations;
  • to comply with our legal obligations, for example to keep records of the services we provide you as required by applicable law or regulation, or to comply with any governmental, quasi-governmental or court orders or subpoenas;
  • where there is a public interest in the processing, for example where it is necessary to prevent and detect fraud; and
  • to meet our or a third party’s legitimate interests, for example to understand how you use our Services so that we can develop new services, to protect our rights or the rights of third parties, or to resolve any disputes. When we process personal information to meet our legitimate interests, we put in place robust safeguards to help ensure that your privacy is protected and that our legitimate interests are not overridden by your interests or fundamental rights and freedoms.

We may also obtain your consent to collect and use certain types of personal information, including when we are required to do so by law (for example, in jurisdictions where consent is always required to collect personal information, in relation to our direct marketing activities or use of Cookies and tracking technologies, or when we process sensitive personal information about you). If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us using the details at the end of this privacy notice.

3. SMS / TEXT MESSAGING

By contacting us by SMS/text message, or by opting in to receive text messages from us, you agree to receive recurring messages from Voluntary Benefits at Work. Message and data rates may apply. Message frequency depends on your interactions and preferences. You can reply STOP at any time to opt out of future messages, or HELP for more information.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent are excluded from all of the information-sharing categories described in this privacy notice and will not be shared with any third parties.

4. YOUR RIGHTS OVER YOUR PERSONAL INFORMATION

You have the right to access, correct, or delete your personal information, and you may have additional rights depending on applicable law. These include rights in certain circumstances to:

  • access your personal information;
  • request proof of the authorization or previous consent given to us to collect and process your personal information;
  • correct the information we hold about you;
  • erase your personal information;
  • restrict our use or disclosure of your personal information;
  • object to our use or disclosure of your personal information;
  • request information about the use and processing of your personal information by VB@Work;
  • receive your personal information in a usable electronic format and transmit it to a third party (right to data portability);
  • revoke the consent given by you for the processing of your personal information; or
  • lodge a complaint with your local data protection authority.

If you would like to discuss or exercise these rights, please contact us using the details below. We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate. We will contact you if we need additional information from you in order to honor your requests.

5. INFORMATION SHARING

We do not sell or rent your personal information, and we do not share it with third parties for their own marketing or promotional purposes. Your personal information is kept confidential and is disclosed only as described in this privacy notice, as required by law, or with your explicit consent. We may share your personal information in the following limited circumstances:

  • With your consent. We may share your personal information when we have obtained your consent to do so.
  • Insurance carriers, service providers and business partners. We may share your personal information with insurance carriers, service providers and business partners that are bound by confidentiality obligations and that help us provide the specific Services you have requested, such as placing and administering coverage, processing secure payments, fulfilling orders, operating our Services, supporting email and messaging services, and analyzing information. We use servers and services owned by third parties to store information, including messages you send through the Services.
  • Affiliates. We may share your personal information with companies controlled by or under common control with Voluntary Benefits at Work for any purpose allowed by this privacy notice.
  • Law enforcement, courts, regulators and other authorities. We may share your personal information with law enforcement agencies, courts, regulators, government or quasi-governmental authorities or other third parties where we believe it is necessary to comply with a legal or regulatory obligation, respond to subpoenas, court orders or legal process, enforce our Terms of Service or other agreements, establish or exercise our legal rights or the legal rights of others, defend against legal claims, or investigate, prevent or take action regarding illegal activities, suspected fraud, or potential threats to anyone’s physical safety.
  • Business transfers. We may transfer your personal information to the extent reasonably necessary for the consideration, negotiation, or completion of a merger, reorganization, or acquisition of our business, or a sale, liquidation, or transfer of some or all of our assets. Should such a transfer occur, we will use reasonable efforts to ensure that the receiving entity uses your personal information in a manner consistent with this privacy notice.

We may share aggregated, non-identifiable information with others without further notice to you, such as the total number of people who used the Services in a specific month or the total number of messages sent during a particular period.

When required by applicable law, when we share personal information with third parties we will ensure that those third parties maintain a comparable level of protection of the personal information as set out in this privacy notice by contractual or other means. To the fullest extent permitted by applicable law, we exclude all liability arising from the use of your personal information by third parties. When required by applicable law, data transfers will be logged and documented, identifying the recipient, the purpose of the transfer, and the type of data transferred. Where required by law, we can on request confirm the name of each third party to which personal information is, or will be, transferred.

6. INTERNATIONAL DATA TRANSFERS

Your personal information may be transferred to and processed in locations outside of your state, province, country, or other governmental jurisdiction where data protection laws may differ from those in your jurisdiction. We take steps to ensure that your information is handled securely and in line with this privacy notice, regardless of where it is processed.

7. INFORMATION SECURITY AND RETENTION

We implement technical, organizational, administrative and physical measures to help ensure a level of security appropriate to the risk to the personal information we collect, use, disclose and process. These measures are aimed at ensuring the ongoing integrity and confidentiality of personal information. We evaluate these measures on a regular basis to help ensure the security of the processing. Please be aware that, despite our ongoing efforts, no security measures are perfect or impenetrable.

We restrict access to your personal information to those who require access to such information for legitimate, relevant business purposes.

We retain your personal information only as long as necessary to fulfill the purposes outlined in this privacy notice, which generally means for as long as we have a relationship with you. Once our relationship with you has ended, we will retain your personal information for a period of time that enables us to:

  • maintain business records for analysis and/or audit purposes;
  • comply with record retention requirements under the law;
  • resolve disputes, enforce our agreements, and defend or bring any existing or potential legal claims; and
  • deal with any complaints regarding the Services.

We will delete your personal information when it is no longer required for these purposes. If there is any information that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of that information.

7.1. Secure communications

Live chat sessions on our site are encrypted to encode information that you share with our operators. By contrast, email messages sent in clear text over the public internet can be observed by an unintended third party. Non-encrypted internet email communications may be accessed and viewed by other internet users without your knowledge and permission while in transit to us. If you wish to keep your information private, please do not use email to send us information that you consider confidential or proprietary. You may contact us by telephone instead using the number provided in Section 10 (Contact Us).

7.2. Third-party vendors

For certain services on our website, such as live chat or webcasts, we will ask for information about you such as your name, business, and email address. Where we use a third-party vendor to provide online services, the vendor has agreed to keep your information confidential. For example, transcripts of live chat sessions may be archived in a database by our vendor for review by our operators.

8. LINKS TO OTHER SITES

We may provide links to other websites not owned or controlled by us that we think might be useful or of interest to you. We are not responsible for the privacy practices of other website owners or the content or accuracy of those websites. Links to other websites do not constitute or imply our endorsement of those websites, any products or services described on them, or any other material they contain. We advise that you review the privacy policies of any third-party websites you visit.

9. CALIFORNIA PRIVACY RIGHTS

The provisions of this Section 9 (California Privacy Rights) relate solely to residents of the State of California (“consumers” or “you” for purposes of this section). We included this section to comply with the California Consumer Privacy Act of 2018, as amended (the “CCPA”), and any terms defined in the CCPA have the same meaning when used in this section.

9.1. Applicability of the CCPA

9.1.1. VB@Work as a service provider

Our company assists individuals and companies with insurance-related solutions through insurance placement, risk management, and consulting services. In our role as an insurance broker or agent, we act as a service provider on behalf of our clients and insurance carriers. Unless stated otherwise in this section or in a separate disclosure, we process your CCPA Covered Personal Information as a service provider (as defined by the CCPA) on behalf of a customer (and/or its affiliates) or an insurance carrier that is the responsible business (as defined by the CCPA) for your CCPA Covered Personal Information. When acting as a service provider, we will only collect, use, and otherwise process your CCPA Covered Personal Information as directed by our customers and as otherwise permitted by the CCPA and applicable law.

If your data has been submitted to us by you and you wish to exercise your consumer rights under the CCPA, please direct your request to the insurance carrier (business) that placed insurance coverage for you. If your data has been submitted to us on behalf of a commercial customer and you wish to exercise any CCPA consumer rights because you are or were employed by that commercial customer, please direct your request to that commercial customer directly. If you submit your request directly to us, consistent with the CCPA, we will inform you that you should submit the request to the commercial customer or insurance carrier on whose behalf we process the information and, where feasible, provide you with contact information for that business.

We are not responsible for, and have no control over, the privacy and data security practices of our customers, which may differ from those set forth in this privacy notice. For detailed privacy information related to our collection and use of your data on behalf of a customer, please contact that customer directly.

9.1.2. VB@Work as a business

In some limited circumstances and in some of our corporate functions, we may act as a CCPA business rather than as a CCPA service provider. Where we act as a business, we will fulfill your verifiable consumer request as described below.

9.1.3. CCPA exemptions

This Section 9 does not apply to:

  • publicly available information from government records;
  • de-identified or aggregated consumer information; and
  • information or organizations excluded from the CCPA’s scope, including medical information governed by the California Confidentiality of Medical Information Act (CMIA), protected health information collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), or personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including the Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994 (DPPA).

Under the limited circumstances where we are acting as a business, and your personal information is not otherwise excluded as set forth above, the following information applies to how we collect, use, and share your personal information.

9.2. Information we collect when we are acting as a business

As a business, we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or device (“CCPA Covered Personal Information”). In particular, we have collected the following categories of CCPA Covered Personal Information from consumers within the last twelve (12) months:

Category
A. Identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Collected: Yes
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)): A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, medical information, or health insurance information. Some CCPA Covered Personal Information included in this category may overlap with other categories. Collected: Yes
C. Protected classification characteristics under California or federal law: Age (40 years or older), race, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status. Collected: Yes
D. Commercial information: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Collected: Yes
E. Biometric information: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Collected: No
F. Internet or other similar network activity: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Collected: Yes
G. Geolocation data: Physical location or movements. Collected: No
H. Sensory data: Audio, electronic, visual, thermal, olfactory, or similar information. Collected: No
I. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)): Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Collected: No
J. Inferences drawn from other personal information: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Collected: No

9.3. Categories of sources from which we collect personal information where we act as a business

We obtain the CCPA Covered Personal Information listed above from the following categories of sources:

  • For all of the above categories collected, directly from you, as described in Section 1.1 (Information we collect directly from you).
  • For all of the above categories collected, from third parties, as described in Section 1.2 (Information we collect from other sources).
  • For Categories A (identifiers) and F (internet or other similar network activity), indirectly from you, as described in Annex A (Cookies Policy).

9.4. Use of CCPA Covered Personal Information when we are acting as a business

We may use or disclose the CCPA Covered Personal Information we collect for one or more of the following business purposes:

  • We use all of the above categories of CCPA Covered Personal Information collected to:
    • Fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question, we will use that information to respond to your inquiry.
    • Provide, support, personalize, and develop our website, products, and services.
    • Create, maintain, customize, and secure your account with us.
    • Provide you with support and respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
    • Help maintain the safety, security, quality, and integrity of our website, products and services, databases and other technology assets, and business, including to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and prosecute those responsible for that activity, and to debug to identify and repair errors that impair existing intended functionality.
    • Respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
    • Evaluate or conduct 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 bankruptcy, liquidation, or similar proceeding, in which CCPA Covered Personal Information held by us about our website or application users is among the assets transferred.
  • We use Categories A (identifiers), B (categories listed in the California Customer Records statute), and D (commercial information) to process your requests, purchases, transactions, and payments and to prevent transactional fraud.
  • We use Categories A (identifiers) and F (internet or similar network activity) for:
    • Auditing related to a current interaction with you and concurrent transactions, including counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with applicable law.
    • Testing, research, analysis, and product development and demonstration, including to develop and improve our website, products, and services.
  • For all of the above categories of CCPA Covered Personal Information collected, as described to you when collecting your CCPA Covered Personal Information or as otherwise set forth in the CCPA.

We will not collect additional categories of CCPA Covered Personal Information or use the CCPA Covered Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

9.5. Sharing CCPA Covered Personal Information when we are acting as a business

We may disclose your CCPA Covered Personal Information to a third party for a business purpose.

9.5.1. Disclosures of CCPA Covered Personal Information for a business purpose
In the preceding twelve (12) months, we have disclosed all of the above categories of personal information collected for a business purpose.

9.5.2. Sales of CCPA Covered Personal Information
We do not sell consumer personal information. Therefore, in the preceding twelve (12) months, we have not “sold” any categories of CCPA Covered Personal Information.

9.6. Your CCPA consumer rights

The CCPA obligates businesses that collect consumer information (as that term is defined in the CCPA) to fulfill the following rights of California residents who submit a verifiable consumer request. As stated above, where we act as a CCPA service provider and receive a request directly from you, we will direct you to submit your request to the customer or carrier on whose behalf we process your information. Under the limited circumstances where we act as a CCPA business, we will fulfill your request as described below.

9.6.1. Data access

You have the right to request that we disclose certain information to you about our collection and use of your CCPA Covered Personal Information over the past twelve (12) months. Once we receive and verify your request (see below), we will disclose to you:

  • The categories of CCPA Covered Personal Information we collected about you.
  • The categories of sources for the CCPA Covered Personal Information we collected about you.
  • Our business or commercial purpose for collecting that CCPA Covered Personal Information.
  • The categories of third parties with whom we share that CCPA Covered Personal Information.
  • The specific pieces of CCPA Covered Personal Information we collected about you (also called a data portability request). Note that the law prohibits us from disclosing at any time a consumer’s Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers.

9.6.2. Data deletion

You have the right to request that we delete your personal information where we act as a business. This right is subject to several exceptions. Where we act as a CCPA business, we may deny your deletion request if retaining the information is necessary for us or our service providers to:

  • Complete the transaction for which we collected the CCPA Covered Personal Information and take actions reasonably anticipated within the context of our ongoing business relationship with you or our client.
  • Detect bugs or errors in our website or Services, detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information as permitted by law or that are compatible with the context in which we collected it.

9.6.3. Sales opt-out and opt-in

The CCPA gives consumers the right to opt out of and opt in to the sale of their personal information. We do not sell consumer personal information.

9.6.4. Right to non-discrimination

The CCPA prohibits businesses from discriminating against consumers because they exercised any of their CCPA rights. We will not discriminate against you for exercising any of your CCPA consumer rights.

9.7. Exercising access, data portability, and deletion rights

As stated in this Section 9, we generally function as a CCPA service provider with respect to our corporate clients and insurance carriers that function as CCPA businesses. Where we act as a service provider and your data has been submitted to us by or on behalf of our corporate client or insurance carrier, we will not be able to substantively address your request to exercise consumer rights, and we will ask you to submit your request directly to the relevant business.

In the limited circumstances where we are processing your personal information as a CCPA business, we will address your request accordingly. You may exercise the access, data portability, and deletion rights described above by submitting a verifiable consumer request to us by either:

  • Emailing us at info@vbwork.com; or
  • Calling us at (678) 888-0848.

You may only make a verifiable consumer request for access or data portability twice within a twelve (12) month period.

9.8. Verification process

Under the CCPA, where we act as a business, we are only required to fulfill verifiable consumer requests. Only you, or your Authorized Agent (a person or a business entity registered with the California Secretary of State that you authorize to act on your behalf), may make a verifiable consumer request related to your CCPA Covered Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

Where you choose to submit your request through an Authorized Agent, we may require you to provide your Authorized Agent with written permission to do so and to verify your own identity. We may deny any request by an Authorized Agent that does not submit proof that the agent has been authorized by you to act on your behalf.

  • Requests for access to categories of personal information. Where you or your Authorized Agent submit a request for disclosure of categories of personal information we as a business have collected about you, we will verify your request to a “reasonable degree of certainty.” This may include matching at least two data points that you provide with data points we maintain about you and have determined to be reliable for the purposes of verification.
  • Requests for specific pieces of personal information (portability requests). Where you or your Authorized Agent submit a request for disclosure of specific pieces of personal information we as a business have collected about you, we will verify your request to a “reasonably high degree of certainty.” This may include matching at least three data points that you provide with data points we maintain about you and have determined to be reliable for the purposes of verification. We will also require you to submit a signed declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.
  • Requests to delete. Where you or your Authorized Agent submit a request for deletion of personal information we as a business have collected about you, we will verify your request to a “reasonable degree” or a “reasonably high degree of certainty” depending on the sensitivity of the personal information and the risk of harm to the consumer posed by unauthorized deletion.

We will only use CCPA Covered Personal Information provided in a verifiable consumer request to verify your identity or authority to make the request.

9.9. Response timing and format

Where we act as a business, we will endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the twelve (12) month period preceding receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your CCPA Covered Personal Information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

9.10. Other California privacy rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our website who are California residents to request certain information regarding our disclosure of personal information to affiliates and other third parties for their direct marketing purposes. To make such a request, please send an email to info@vbwork.com.

10. CONTACT US

The VB@Work company that provides each Service is primarily responsible for the personal information collected in relation to that Service. If you have any questions or concerns about this privacy notice or your personal information, or would like to exercise your rights, please contact us at:

Voluntary Benefits at Work, Inc.
1090 Hershey Drive SE
Marietta, GA 30062
Phone: (678) 888-0848
Email: info@vbwork.com

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that we have not been able to assist with your complaint or concern, you may have the right to make a complaint to the data protection authority in your jurisdiction.

11. CHANGES TO THIS PRIVACY NOTICE

You may request a copy of this privacy notice from us using the contact details set out above.

We may update this privacy notice from time to time, consistent with applicable law. Where changes will have a fundamental impact on the nature of our processing of your personal information or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise any rights you may have under applicable law (e.g., to object to the processing). Other changes will be posted on this page with an updated “Last updated” date. We encourage you to review this privacy notice periodically. Your continued use of our Services after changes are posted constitutes your acceptance of the updated privacy notice.

ANNEX A – COOKIES POLICY

Our Services may use cookies and similar tracking technologies to enhance your experience. Cookies are small text files placed on your device that collect information about your activity on the Services. They help us improve our site and deliver a better and more personalized service. They enable us to:

  • estimate our audience size and usage pattern;
  • store information about your preferences, and so allow us to customize our site according to your individual interests;
  • speed up your searches; and
  • recognize you when you return to our site.

Cookies and tags used on this site may include, but are not limited to, Google Analytics (“GA”) and Google Tag Manager. We use GA to better understand how visitors use our sites and to help manage their performance and design. Google stores the information collected via these cookies. For more information about GA, please see Google’s Privacy Policy and Help pages.

You can control the use of cookies through your browser settings, including refusing cookies. However, if you disable cookies you may be unable to access certain parts of our site or use certain features of the Services. Unless you have adjusted your browser settings to refuse cookies, our system will issue cookies when you visit our site unless otherwise prohibited by applicable law.

We do not use our own cookies to collect personal information such as your email address, and we do not combine information collected through cookies with your personal information. We do not provide cookie information to other parties for their own marketing use. We make no attempt to look at or examine other cookies or information that may be stored on your computer.

To find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit www.allaboutcookies.org or www.aboutcookies.org.