Bolton Street Programs – Privacy Policy
Effective Date:
This Privacy Policy is effective as of August 29, 2024 and it was last updated on 08/29/2024.
Scope
Sterling & Sterling LLC DBA Bolton Street Programs (“Bolton Street Programs,” “we,” “our,” or “us”) is committed to respecting your privacy. This Privacy Policy describes how we collect, use, and disclose your information across the websites we operate (“e,g. boltonst.com), mobile applications, and the services we provide (“Services”) including after we no longer provide those Services to you. Our websites and mobile applications are referred to as the “Sites.” “Personal information” is non-public information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to an individual.
This Privacy Policy explains:
- The types of information we collect through our Sites and Services.
- How we use and protect that information.
- The types of information we may share with others and under what circumstances.
- The choices you have regarding our collection, use, and sharing practices.
- Details regarding our use of cookies and other tracking technologies.
This Privacy Policy does not address our use of personal information obtained in the context of our relationship with you as either our employee, director, officer, independent contractor, part-time worker, or as an applicant for one of those positions (collectively, “Employee”). To understand how we treat California Employees’ personal information, please see our Employee Privacy Policy here.
When you use our Services, you agree to our collection, use, and disclosure of personal information about you as described in this Privacy Policy. If you do not provide us with personal information we request, we may not be able to provide you with our Services or your experience when using those Services may be impaired.
This Privacy Policy applies when you interact with us through our Sites and Services. It also applies anywhere it is linked. It does not apply to non-Bolton Street Programs websites that may link to the Sites or Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.
A link to a Portable Document Format (PDF) version of this Privacy Policy can be found here: boltonst.com/bolton-street-website-privacy-policy.
Personal Information We Collect
Below you will find a chart that describes the categories of personal information we, or service providers or contractors on our behalf, have collected, where that personal information came from, and the purpose for the collection of that personal information, all within the past 12 months from the effective date of this notice. Please note that these are categories of personal information as they are set forth under California law and across our various product lines. We did not necessarily collect all of the specific pieces of personal information listed for any given person or product. In addition to personal information, we may also collect, use, and/or disclose anonymous, de-identified, and/or aggregate data that is not linked to a particular individual. Our use or disclosure of such information is outside the scope of this Privacy Policy. We only maintain and use such data in a way that does not reasonably identify a particular individual, and we will not attempt to re-identify it, except to test our de-identification process.
For purposes of this Privacy Policy:
- Personal information collected from you or from others on your behalf means that we receive that information from you, your employer or union (e.g., if we administer your employer’s or union’s employee benefits plan), or from entities you refer us to (e.g., your medical provider)
- Operational functions include things like rating, underwriting, and issuing insurance policies, administering benefits, providing brokerage or consulting services under your or your employer’s insurance contract, auditing our products or services, understanding how our Sites are used, improving our services, security, preventing fraud, and for legal compliance purposes
As reflected above, we process your personal information as necessary for performing our contract or our legitimate interests in informing you about our products and services and providing you with those products and services pursuant to our contract.
We may obtain some of this information from external parties, including external parties that collect this information on our behalf. For example, we use payment processors when you engage in transactions related to our Sites and Services. We also collect the following information about you from other sources:
- Information about your transactions with us from the insurance companies we contact to underwrite your insurance.
- Information we receive from the Department of Motor Vehicles.
- Information we receive from consumer reporting agencies.
- Information contained in medical records or from medical professionals that is related to insurance claims.
Digital Technologies
When you interact with our Sites and Services, certain information about your use may be collected automatically. This includes:
- Details of your visits to and information generated in the course of your use of the Sites (including the timing, frequency, and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our Sites;
- Details regarding the device you use to access our Services, including but not limited to your IP address, operating system, and browser type;
- Information about how you interact with our ads and newsletters, including whether you open or click links in any correspondence; and
- Information that you make available to us on social media platforms, such as by clicking on a social media icon linked from our Sites or Services, including your account ID or username and other information included in your posts.
We rely on partners, such as Google Analytics, to provide many features of our Sites and Services and provide us data about your use. This information may be collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. These tracking technologies may be used for the following purposes:
- Advertising: Allowing us to provide targeted advertisements or marketing communications that we believe may be of interest to you.
- Analytics: Allowing us to understand how our services are being used, track site performance, and make improvements.
- Site Operations: Enabling features that are necessary for providing you the services on our Sites, such as identifying you as being signed in, tracking content views, and remembering your preferences.
- Social Media: Enabling content-sharing on social networking sites (e.g., LinkedIn, Facebook).
If you interact with us through social media, your interaction may allow that social media company to collect digital tracking information about you or your device, including through the use of tracking technologies. Please visit the social media company’s respective privacy policy to better understand its data collection practices and the controls it makes available to you.
If you prefer not to have the benefits of cookies, your internet browser or other third party software on your workstation can be adjusted to treat cookies in different ways. Depending upon the type of browser you are using, you might be able to configure your browser: (i) to prompt you to accept or reject cookies on an individual basis; or (ii) to prevent your browser from accepting any cookies at all. You should refer to the supplier or manufacturer of your web browser for specific details about cookie security. For general information about how to manage cookies, visit www.allaboutcookies.org/manage-cookies/ (please note that this website is not connected to us and we are not responsible for its content). Rejecting cookies might affect your ability to perform certain transactions on our Website and our ability to recognize your browser from one visit to the next.
For more information about your choices with regard to interest-based advertising, you may wish to visit the Digital Advertising Alliance’s Consumer information page: www.aboutads.info/consumers/.
Below is a list of these partners with links to more information about their use of your data and how to exercise your options regarding tracking.
Your browser or device may include “Do Not Track” functionality. At this time, we do not alter our Sites’ data collection and use practices in response to Do Not Track signals.
Please note that opting out of advertising networks does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from other companies that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, you may also delete your opt-out preferences.
If you engage with our Site’s chat feature, please know that we sometimes use chatbots or other service provider or contractor services to provide such features. Your conversations with these chatbots provide such service providers and contractors access to the information you enter into the chat, but we contractually require them to only use that information to provide us with their services.
Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Sites and Services may not be available, work, or work as designed. You may also be able to opt out of or block tracking by interacting directly with the other companies who conduct tracking through our Sites and Services.
Personal Information Disclosed Within the Past 12 Months
Below you will find a chart that generally describes the categories of personal information we have disclosed and the purpose for the disclosure of that information, all within the past 12 months from the effective date of this notice.
In addition to the above, in certain circumstances, as permitted by law, we might disclose some information without an explicit authorization from you. For example, we may disclose your personal information to insurance regulatory authorities, law enforcement, and similar authorities to comply with applicable law or legal process, protect our interests, or prevent or prosecute fraud. Your personal information may also be transferred in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction.
As explained in the Digital Technologies section above, we may share personal information with other parties, including for serving ads on our behalf targeted to your interests and based on your online activities. We do not disclose personal information to third parties for those third parties’ direct marketing purposes or share your personal information for money, but our use and disclosure of your identifiers and contact information, commercial information, Internet or other electronic network activity information, and professional of employment-related information, to marketing partners and analytics providers for marketing purposes within the last 12 months, could fall within certain jurisdictions’ definitions of “selling,” “sharing,” or “targeted advertising.”
Opting-out of Certain Types of Processing
If you are a resident of the U.K. or California, you (or for California residents, your authorized agent) may opt-out of our use and/or disclosure of your personal information across non-Bolton Street Programs businesses, websites, and applications for targeted advertising purposes (“opt-out of selling/sharing”) by calling us at 1-800-767-7837, submitting this webform www.boltonst.com/do-not-sell-my-personal-information/, or using an opt-out preference signal, such as the Global Privacy Control (GPC) on browsers and/or browser extensions that support such a signal. Your decision to opt-out of selling/sharing will not alter the number of advertisements you see, only whether those advertisements are tailored to you. To download and use a browser supporting the GPC browser signal, click here: globalprivacycontrol.org/orgs. If you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
If you do not have a Bolton Street Programs account, or if you are not logged into your Bolton Street Programs account, your request to opt-out of selling/sharing will be linked to your browser identifier only and not linked to any account information, because the connection between your browser and the account is not known to us. This means that you will need to opt-out on each browser or device you use. If you would like us to make the connection between your browser and your account, please ensure that you are logged in to your Bolton Street Programs account when requesting to opt-out of selling/sharing, or submit this form www.boltonst.com/do-not-sell-my-personal-information/. Your browser may save some information in its cookies and cache to maintain your privacy preferences. Clearing these may remove opt-out preferences, requiring you to opt-out again. You may also choose to control targeted ads you receive within apps by using the settings and choices made available to you by your device manufacturer.
We do not use or disclose sensitive personal information for any purposes other than those permitted by law (e.g., as necessary to provide goods or services you have requested, legal compliance, etc.).
Children’s Information
Our Sites and Services are intended for users age sixteen and over. No one under the age of 16 may provide any personal information on the Sites. We do not knowingly collect personal information from children under 16 and therefore, we do not sell or share such personal information. If you are under 16, do not use or provide any information on the Sites. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at the email address below.
How We Secure Your Information
We use a combination of physical, technical, and administrative safeguards to protect the information we collect through our Sites and Services. While we use precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
Your Privacy Rights
You can limit our sharing with our affiliates for their business purposes or our sharing your information with anyone (affiliates and non-affiliates) for marketing purposes by contacting us using the information in the “Contact Us” section below.
Residents of the UK and California, including via an authorized agent, have the following rights:
- The right to know what personal information we have collected about you, including the categories of personal information, categories of sources from which we collected the personal information, the purpose for our collection of your personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you, and receive a copy of the same;
- The right to delete personal information we have collected from you, subject to certain exceptions;
- The right to correct inaccurate personal information that we maintain about you;
- The right to opt-out of the sale or sharing (sometimes called “targeted advertising”) of your personal information; and
- The right to not receive discriminatory treatment for exercising your privacy rights.
If you are a U.K. resident, you also have:
- the right to object to our processing of your personal information; and
- the right to lodge a complaint with the International Commissioner’s Office (“ICO”);
- when we process your personal information based on consent, the right to withdraw your consent at any time via the methods discussed above in the “Opting-out of Certain Types of Processing” section. Your withdrawal does not affect the lawfulness of our processing of your personal information prior to your consent withdrawal.
Certain information we collect may be exempt from these rights, for example, because it is public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm-Leach-Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
Certain states (e.g., Arizona, California, Connecticut, Georgia, Illinois, Kansas, Maine, Massachusetts, Minnesota, Montana, Nevada, New Jersey, North Carolina, Ohio, Oregon, Virginia, and Wisconsin) provide consumers with a right to access or correct personal information collected about them. For additional information regarding our privacy practices or your rights, you may contact us using the information in the “Contact Us” section below.
How to Submit a Request to Know, Access, Correct, Delete, or Object to Processing
If you have the right to submit a request to know, access, correct, delete, or object to processing of your personal information, you or your authorized agent can email your request to Webmaster@BoltonSt.com, call us toll-free at 1-800-767-7837, or submit the webform available at www.boltonst.com/consumer-privacy-request/.
What Happens After You Submit a Request to Know, Access, Correct, Delete, or Object to Processing
Following a request to know, access, correct, delete, or object to processing your personal information, we will take commercially reasonable steps to verify your identity, such as asking you to provide information matching what we have in our files (e.g., contact information). If you are an agent authorized to make a request on another individual’s behalf, please indicate that when submitting your request. Agents must generally provide a signed authorization evidencing their authority to act on behalf of another individual. We will process your request in accordance with applicable law.
Document Retention
We will not retain your personal information for longer than reasonably necessary for the purpose(s) we collected it. How long we retain your personal information depends on a number of criteria, including the nature of our relationship with you, whether you or your employer purchases one of our products, which product, when you last interacted or were insured with us, the type of personal information at issue, and legal considerations.
Users Outside the United States
If you use our Sites and Services outside the United States, you understand that we collect, process, and store your information in the United States. The laws in the United States regarding personal information may be different from the laws of your jurisdiction. When we transfer personal information to the United States, we do so in accordance with applicable law and subject to appropriate safeguards, including, for example, standard data protection clauses. If you would like more information about our international transfers of personal information, please contact us via the contact information provided in the “Contact Us” section below.
Changes to this Privacy Policy
We may update this Privacy Policy at any time. The “Effective Date” at the top of this page indicates when this Privacy Policy was last revised.
Contact Us
If you have any questions, we can be reached either by email at Webmaster@BoltonSt.com, or by toll-free telephone number at 1-800-767-7837.
