EB EMPLOYEE SOLUTIONS, LLC 

PRIVACY POLICY

EFFECTIVE DATE: 03/15/2016

EB Employee Solutions, LLC (“EBES”) takes your privacy very seriously. We share a commitment to protect your privacy and the confidentiality of your personal information that you provide on our website www.differencecard.com, and our mobile application (Difference Card Smart Mobile). These protections also apply to our www.wellintune.com website.

The purpose of this Website Privacy Policy is to let you know how we handle the information collected through the use of this website. This policy does not apply to information collected through other means such as by telephone or in person, although that information may be protected by other privacy policies.

This website is intended for a United States audience. Any information you provide, including any personal information, will be transferred to and processed by a computer server located within the United States.

Information Collection and Tracking

In order to use this website, you must first provide us information through offline mechanisms. During this process we collect contact information (such as name and address), as well as sensitive information such as your Social Security number (which acts as your username to login to the site). We use this information to set up your account so that you are able to utilize our service to view transactions and balances within the Participant Portal and to access all forms that you may need to manage your account.  As is true of most websites, we gather certain information automatically and store it in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data. We may use your activity information unless restricted by this policy or by law. We do not link this automatically collected data to other information we collect about you.

Some examples of the ways we use your activity information include:
    •    Customizing your experience on the website including managing and recording your preferences.
    •    Marketing, product development, and research purposes.
    •    Tracking resources and data accessed on the website.
    •    Developing reports regarding website usage, activity, and statistics.
    •    Assisting users experiencing website problems.
    •    Enabling certain functions and tools on this website.
    •    Tracking paths of visitors to this website and within this website.

This website may include web pages that give you the opportunity to provide us with personal information about yourself, such as:
    •    Street address
    •    Email address
    •    Telephone number
    •    Date of birth
    •    Health information

You do not have to provide us with personal information if you do not want to; however, that may limit your ability to use certain functions of this website or to request certain services or information.

Use of Personal Information

We may use personal information for a number of purposes such as:
    •    To respond to an email or particular request from you.
    •    To personalize the website for you.
    •    To process information requested by you.
    •    To administer surveys and promotions.
    •    To provide you with information that we believe may be useful to you, such as   information about health products or services provided by us or other businesses.
    •    To perform analytics and to improve our products, websites, and marketing.
    •    To comply with applicable laws, regulations, and legal process.
    •    To protect someone’s health, safety, or welfare.
    •    To protect our rights or the rights of affiliates or related third parties, or to take appropriate legal action, such as to enforce our Terms of Use.
    •    To keep a record of our transactions and communications.
    •    As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law.

We may share personal information within our company, and we may combine personal information that you provide us through this website with other information we have received from you, whether online or offline, or from other sources such as from our vendors.  This information may include demographics provided by employers.

Third Party Sharing

We will share your personal information with third parties only in ways that are described in this Website Privacy Policy. We do not sell your personal information to third parties.

We may provide your personal information to companies that provide services to help us with our business activities such as processing your payment, processing your healthcare payment requests, or offering customer support. These companies are authorized to use your personal information only as necessary to provide these services to us.

We may disclose your personal information as required by law, such as to comply with a subpoena, or similar legal process.

We may disclose your personal information when we believe in good faith that such disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or prominent notice on our website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information.

Tracking Technologies

Technologies such as: cookies, beacons, tags and scripts are used by EBES and our marketing partners, affiliates, analytics, or online customer support provider. These technologies are used in analyzing trends, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies to remember users’ settings. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.

Links to Other Sites

This Website Privacy Policy applies only to information collected by this website. This website contains links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information.

Social Media Widgets

Our Web site includes Social Media Features, such as the Facebook Like button (and Widgets, such as the Share this button or interactive mini-programs that run on our site). These Features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Site. Your interactions with these Features are governed by the privacy policy of the company providing it.

Access to Personally Identifiable Information

If your personally identifiable information changes, or if you no longer desire our service, you may correct, update, amend, delete/remove, or deactivate it by emailing our Customer Support at privacy@wellintune.com or by contacting us by postal mail at the contact information listed below. We will use best efforts to respond to your request to access within 30 days.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. If you wish that we no longer use your information to provide you services contact us at privacy@wellintune.com. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Security

The security of your personal information is important to us. When you use our site and enter sensitive information (such as Social Security number) on our login page, we encrypt the transmission of that information using secure socket layer technology (SSL). We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Online Communication

We may send electronic newsletters, notification of account status, and other communications, such as marketing communications, on a periodic basis to various individuals and organizations. We may also send email communications regarding topics such as general health benefits, website updates, health conditions, and general health topics. We will offer you appropriate consent mechanisms, such as opt-out, for such marketing communications and certain other communications. You may opt out of these commutations at any time by changing your account settings. Please be aware that you may not have the ability to opt out of certain types of communications, such as account status or website updates.

Information for Children Under 13

We do not intentionally collect any personal information from children under the age of 13 through this website. If you think that we have collected personal information from a child under the age of 13 through this website, please contact us.

Changes in this Privacy Policy

We may update this Website Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

To contact us regarding this policy and our related privacy practices, please email or write to us at:
    Email:         privacy@differencecard.com
    Address:     EB Employee Solutions, LLC
                         PO Box 322
                         Mount Kisco, NY 10549
    Phone:      (914) 220-0903

If you believe we or any company associated with us has misused any of your information please contact us immediately and report such misuse.