Privacy Policy

1. Overview

Comeryx Insurance Services, Inc (“Comeryx”, “we”, “our”, or “us”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes how we collect, process, retain, and disclose personal data about you when providing services to you through our websites located at www.comeryx.com (our “Websites”) and our practices for using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• Through our Websites.
• In communications, including email, text, chat, and other electronic messages that you request through the Website or offline inquiries.
• When you interact with our advertising and applications (including mobile apps) on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Comeryx from or about you offline or through any other means, including on any other website operated by Comeryx or any third party that does not link to this policy; or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we treat it. By interacting with our Websites or providing us with your information, you agree to the collection, use, processing, and sharing of your information as described in this policy.

This policy may change from time to time as further described below. Your continued use of the Websites after we make changes as described here is deemed to be acceptance of those changes, so please check the policy periodically for updates.

2. Children's and Minors' Data

Our Websites are not intended for, and we do not knowingly collect any personal data from, children under the age of 18. If we learn we have collected or received personal data from a child under 18 years old without verification of parental consent, we will delete that information.

3. Information from the European Union and Other Countries Outside of the United States

Our Websites, products, and services are intended primarily for individuals located within the United States.

Comeryx does not intentionally or knowingly market to, target, or solicit individuals who are residents of the European Union, Canada, or any other jurisdiction outside of the United States, nor does it intentionally or knowingly collect personal information from such individuals. The Company makes no representation that this website or its privacy practices comply with the laws of jurisdictions outside the United States, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”), Canadian privacy laws, or the laws of any country or jurisdiction other than the United States.

Individuals outside of the U.S. or subject to jurisdictions other than the U.S. are advised not to submit personal information. If you are accessing this website from outside the United States, you do so at your own initiative and are responsible for compliance with applicable local laws.

4. The Personal Data That We Collect or Process

“Personal data” (or “PII”) is information that identifies, relates to, or describes, directly or indirectly, you as an individual, such as your name, email address, telephone number, home address, location, and other information about you that is nonpublic, and that we obtain so we can provide you with information that you request about our products and services, plus any other identifier we may use to contact you online or offline as further described in this policy.

Information You Provide to Us:

We collect no PII from you when you visit our website or application unless you voluntarily choose to provide it. We do not collect PII from users who visit our Website anonymously, although we may collect website tracking data (more on this subject below).

When filling out a form or registering on our Websites, you may be asked to enter your name, email address, phone number, or other details to help you with your experience and so that we can provide you information that you request.

We may collect the following personal information:

• Your name
• Address
• Email address
• Telephone number
• Content and PII you elect to provide as part of your registration with us or in any inquiries, reviews, or feedback you provide through emails, chats, or other communications sent to us
• Device information, including your IP address, device identifiers, operating system and version, preferred language, hardware identifiers, browser type and settings, and other device information
• Location information based on your IP address
• Other PII that you voluntarily submit

We also collect:

• Statistics or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal data. For example, we may aggregate personal data to calculate the percentage of users accessing a specific webpage or feature within our Websites.
• Technical information. Technical information includes information about your internet connection and usage details about your interactions with the Websites, such as clickstream information to, through, and from our Websites (including date and time), products that you view or search for; page response times, download errors, length of your visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), or methods used to browse away from a page.

If we combine or connect non-personal statistical or technical data with personal data so that it directly or indirectly identifies an individual, we treat the combined information as PII.

5. How We Collect Your Personal and Other Data

You Provide Information to Us

We collect information about you when you interact with our Websites, such as when you fill out a form requesting information from us.

Automatically Through Our Websites

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect information that may include PII. Using automatic collection technologies helps us to improve our Websites and to deliver a better and more personalized experience to you.

The technologies we use for this automatic data collection may include:

• Cookies. A cookie is a small file placed on your device when you interact with the Websites. You may refuse to accept or disable cookies by activating the appropriate setting on your browser or device. However, if you select this setting, you may be unable to access certain features of the Websites.
• Web Beacons. Some parts of the Websites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those parts or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity).

To the extent any of these automated technologies are considered a personal data sale, targeted advertising, or profiling, under applicable laws, depending on where you live, you may opt out from use of these automated technologies for such uses by contacting us as described below. Be aware that some Website features may be unavailable if you opt-out of or limit our options for using your information for such purposes.

6. How We Use Your Information

We use commercially reasonable administrative, physical, and technical measures designed to protect your personal data from accidental loss or destruction and from unauthorized access, use, alteration, and disclosure. However, no website, mobile application, system, electronic storage, or online service is completely secure, and we cannot guarantee the security of your personal data transmitted to, through, using, or in connection with the Websites. In particular, email, texts, and chats sent to or from the Websites may not be secure, and you should carefully decide what information you send to us via such communications channels. Any transmission of personal data is at your own risk.

The safety and security of your information also depends on you. You are responsible for taking steps to protect your personal data against unauthorized use, disclosure, and access.

We use information that we collect about you or that you provide to us, including any personal data, to:

• Provide you with the Websites and any content, features, information, products, or services that we make available through the Websites.
• Fulfill any purpose for which you provide it.
• Improve our Websites, including by analyzing your information and creating aggregated data derived from your information) to develop, maintain, analyze, improve, optimize, measure, and report on our Websites and their traffic.
• Notify you when about updates to our Websites and offerings are available, and about changes to any products or services we offer or provide though them.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

When you visit our Websites, the usage information we collect, whether connected to your personal data or not, helps us improve our Websites and deliver a better and more personalized experience by enabling us to:

• Estimate the volumes and usage patterns of visitors to our Websites and users of our Websites.
• Store information about your preferences, allowing us to customize the Websites according to your individual needs and interests.
• Speed up your searches.
• Recognize you when you return to our Websites.

We may also use your information to contact you about goods and services to respond to your inquiry or respond to your request. If you do not want us to use your information in this way, please contact us as set forth below.

7. Who We Disclose Your Information To

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may also disclose personal data that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our organization and provide our services to you, or otherwise perform any obligations we undertake to you, and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
• 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 Comeryx's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Comeryx is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us an email address for purposes of learning more about our services, we may contact you with information in response to your request.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal data:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our Website Terms of Use.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our organization, our customers, or others.

The categories of personal data we may disclose include:

• Name and contact information.
• Location information as derived from your IP address.
• Device information.
• Content and information you elect to provide to us.

8. Your Rights and Choices About Your Information

This section describes mechanisms you can use to control certain uses and disclosures of your information and rights you may have under state law, depending on where you live.

Advertising, marketing, cookies, and other tracking technologies choices:

• Cookies and Other Tracking Technologies. You can set your browser to refuse all or some browser cookies or other tracking technology files, or to alert you when these files are being sent. You can choose whether or not to allow the Websites to collect information through other tracking technologies by using the opt-out option available on our main webpage, or through the contact option further set forth below. If you disable or refuse cookies or similar tracking files, some features may be inaccessible or not function properly. We respond to “Do Not Track” and general privacy control (GPC) technologies as required by applicable law.
• Promotions by Comeryx. If you do not wish us to use your information to promote our products or services, you can opt out by contacting us as set forth below.
• Location Data. Although we do not use commonly-used location tracking services, we may collect information about your location based on your IP address. If you block the use of cookies through the option on our Website or contact us as set forth below, we will not collect such information.

9. Your Privacy Rights

Depending on your state of residency, you may have certain rights related to your personal data, including:

• Access and Data Portability. You may confirm whether we process your personal data and access a copy of the personal data we process. To the extent feasible and required by state law, depending on your state, data will be provided in a portable format. Depending on your state, you may have the right to receive additional information and it will be included in the response to your access request.
• Correction. You may request that we correct inaccuracies in your personal data that we maintain, taking into account the information's nature and processing purpose.
• Deletion. You may request that we delete personal data about you that we maintain, subject to certain exception under applicable law.
• Opt Out of Using Personal Data for Targeted Advertising, Profiling, and Sales. You may request that we do not use your personal data for these purposes.

Important: The exact scope of these rights vary by state, and you can review more on those rights below. There are also several exceptions where we may not have an obligation to fulfill your request.

To exercise any of these rights, contact us as set forth below.

Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to process your request to opt out from certain types of data processing, including data “sales” as defined under certain laws. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.

10. How We Retain Your Personal Data

We keep the categories of personal data described in this policy for as long as reasonably necessary to fulfill the purposes described or for as otherwise legally permitted or required, such as maintaining the Websites, operating our organization, complying with our legal obligations, resolving disputes, and for safety, security, and fraud prevention. This means that we consider our legal and business obligations, potential risks of harm, and nature of the information when deciding how long to retain personal data. Retention periods may vary depending on the nature of the information and the purpose for which it was collected. At the end of the retention period, personal data will be deleted, destroyed, or deidentified.

11. Changes to Our Privacy Policy

We may update this policy from time to time, and we will provide notice of any such changes to the policy as required by law. The date the privacy policy was last updated is identified at the top of the page. We will notify you of changes to this policy by updating the “last updated” date and posting the updated policy on the Websites. We may email or otherwise communicate reminders about this policy, but you should check our Websites periodically to see the current policy and any changes we have made to it.

12. Contact Information

To exercise your rights or ask questions or comment about this privacy policy or our privacy practices, contact us at: optout@comeryx.com.

Our physical address is:

13. Additional Terms Specific to Certain State Laws

Certain U.S. states may also provide users with additional rights under their privacy laws. To the extent such laws apply to Comeryx, this section provides additional information regarding how we process personal information of such residents, and their privacy rights under applicable law.

Depending on where you live, you may have some or all of the following rights under applicable law and under certain circumstances:

• Know/Access including the following information:
  • Confirm whether we process your personal data.
  • The categories of personal data that we process.
  • The categories of sources from which we collected personal data.
  • The business or commercial purpose for collecting, processing, selling, or sharing personal data.
  • The categories of third parties with whom we disclose personal data.
• Erase, Cancel, or Delete the personal information that we have collected from or about you. Be aware these rights are not absolute and that Comeryx may lawfully deny such request in certain circumstances, such as where we rely on your information to supply a contractual service you have asked for, where the information is still needed for the purpose for which it was collected, or where we are required to retain it to comply with a legal obligation.
• Rectify/Correct inaccurate personal data that we maintain about you or completing incomplete personal data, including by means of providing a supplementary statement.
• Data Portability of data you provided Comeryx in a readily usable format (to the extent technically feasible).
• Limit Use or Disclosure of sensitive personal data to only certain business purposes set forth under applicable law.
• Revoke Consent to Process personal data, including sensitive personal data where we rely on your consent pursuant to applicable law.
• Object to Processing of personal data about you where such data is processed based on Comeryx's legitimate interest.
• Opt-out of “sales” or “sharing/targeted advertising” if we engage in such processing activities under applicable law.
• Nominate an Agent to exercise your privacy rights on your behalf.
• Sensitive personal data is not used or disclosed for purposes other than those permitted by applicable law, including to provide requested services or as otherwise authorized by you.
• Not to be Subject to Solely Automated Decisions Producing Legal Effects without your consent or other legal basis and to access information about the existence of any solely automated decision-making that produces a legal effect, as well as information about the logic involved and the consequences of such processing.
• Appeal our refusal to take action on your request to exercise the rights described above.
• Nondiscrimination for exercising the rights described above.

To exercise your rights under applicable law, or if you are acting as an authorized agent on behalf of a consumer, please follow the instructions provided below. These rights are not absolute, and in certain cases we may not be able to respond to your request, such as when a legal exemption applies or if we are not able to verify your residency or identity or, if an authorized agent, your authority to act on behalf of the individual.

For all other requests to exercise your privacy rights, please contact us as set forth above.

If we decline to take action on your request, where applicable law requires you may appeal such refusal by submitting your request within a reasonable time period after we send you our decision by following the directions provided to you in the Comeryx communication containing our decision, or by stating your election to appeal via the contact information set forth above.

We will comply with required requests as soon as reasonably practicable and in accordance with applicable laws. If your request is clearly unfounded, repetitive, or excessive, we may charge a reasonable fee or decline to comply with your request.

Notice to California Residents (Shine the Light)

We do not sell or share personal information as those terms are defined under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (“CCPA/CPRA”). We do not use or disclose sensitive personal information for purposes other than those permitted by applicable law and for the purposes for which you or a third party has provided your information to us. For California residents, we consider any opt-out of “sale” or “share/targeted advertising” a request pursuant to California's “Shine the Light” law to stop sharing your personal data covered by that law with third parties for their direct marketing purposes.

Notice to Nevada Residents

Nevada Revised Statutes Chapter 603A allows Nevada residents to opt-out of the “sale” of certain types of personal data. Subject to several exceptions, Nevada law defines “sale” to mean the exchange of certain types of personal data for monetary consideration to another person. If you are a Nevada resident who wishes to exercise your “sale” opt-out rights, you may submit a request to us using the contact information listed above and we will comply with your request as required by Nevada law.