Effective Date: 03/15/2013
Privacy Notice Table Of Contents
Our Commitment To Privacy:
Your privacy is important to us. Renaissance Benefit Advisors, Inc.
is committed to protecting the confidentiality and security
of information you provide us on our websites. To better protect your
privacy, we provide this Privacy and Security Policy to explain our
online information practices and the choices you can make about the
ways your information is collected and used. This Policy can be found
on our homepage and at any place on our websites where personally
identifiable information is requested.
If we decide to change our privacy policy, we will post those changes
to this privacy statement, the home page, and other places we deem
appropriate so that you are aware of what information we collect, how
we use it, and under what circumstances, if any, we disclose it.
We reserve the right to modify this privacy statement at any time, so
please review it frequently. If we make material changes to this
policy, we will notify you here, by email, or by means of a notice on
our home page.
The Scope of This Privacy and Security Policy:
This Privacy and Security Policy only addresses our use and disclosure
of information we collect from you on our websites. The website
dcp.mydeferral.com is our
service platform. The data collected from the "end user" on these sites
is owned by our "Client." On our corporate website, www.mydeferral.com, all
data collected on this site is collected and owned by Renaissance Benefit Advisors, Inc.
Please note that other websites or third parties, referenced on our website, may adhere
to their own customs and policies. We are not affiliated with the
creation or management of the content or privacy policies of such
websites or third parties. We are neither responsible nor liable for
privacy or other information collection issues related to such other
websites or third parties.
Data collected
We only collect the
information that you provide to us or that we are directed to collect
by the Client. Such data may include basic contact information such as
your name, postal address, e-mail address, and phone number, as well as
sensitive personal information such as compensation or payment
information if required. In this regard, we do not control what end
user data we may receive and host, nor what steps the Client, as data
controller, has taken to ensure that the data is reliable for its
intended use, accurate, complete, and current. We also collect Client
Information on our portal and corporate website. Client Information is
personal information about people in our Client's organization, such as
account managers and users, who interact with our portal. Client
Information usually is limited to name, work e-mail address, work phone
number, and job title, and we collect it through the portal or other
means provided to us. We use this information to support your account,
maintain our business relationship with you, respond to your inquiries,
and perform recordkeeping functions.
Notice
We operate under the
assumption that it is generally our Client's obligation as data
controller to notify individuals about the purposes for which we
collect and use information about them, how individuals can contact us
with any inquiries or complaints, the types of third parties to which
they disclose your information, and the choices and means offered for
limiting our use and disclosure. As your data processor, we make
available to you this privacy policy so that you can better understand
our data practices and whether they are consistent with privacy notices
made available to you.
Access
The U.S.-EU Safe Harbor requires that
data subjects must have access to personal information about them that
an organization holds, and that they be able to correct, amend, or
delete that information where it is inaccurate. We operate under the
assumption that it is generally the Client's obligation as data
controller to provide data subjects a means of accessing their data. If
you would like your data deleted, please contact us at the information
below. We will respond to requests within 30 days of receipt.
Choice
The U.S.-EU Safe Harbor requires that members offer end users a choice
to opt out of uses and disclosures of their data that are incompatible
with the purposes for which that data was originally collected or
subsequently authorized. We operate under the assumption that it is
generally our Client's obligation as data controller to obtain from
data subjects the appropriate consent to transfer their data to us and
to process data using our products for defined purposes. As your data
processor, we will not share, sell, rent, or trade with third parties
for their marketing purposes any Client or end user data collected by
us, unless you direct us to do so and have the appropriate
authorization to do so.
The Information We Collect and The Ways We Use It:
This notice applies to all information collected or submitted on our
websites. On some pages, you can log into your account, initiate
account transfers, make changes to account information, and request
additional information. Once you log onto any of our websites, you
provide us with the identity of your current Internet address and the
type of operating system and browser software you are using. While you
are visiting our website, we may ask you for other personal
information. The types of personal information that we may request from
you, upon you visiting our website, are your name, address, e-mail
address, phone number, etc. Please note that providing such information
is optional. However, in order to access the personal information we
collect about you, you may be required to provide identifying
information.
During your visit to our website, we may also keep track
of the sections of our website that you visit the most. We do this so
we can continually provide our users with better visiting experiences.
For instance, we may use such user tracking information to modify the
most frequently visited sections of our website, so that they can be
accessed more efficiently by a broader range of operating systems.
Additionally, we may aggregate your tracking information with that of
our other website users in order to tell our programmers that X number
of users visited a certain area on our website, or that Y number of
users filled out a form. We will not, however, disclose any information
that could be used to identify you or any of the other website users.
Any personal information that you provide us with on our website is
only used on your behalf to complete a transaction or change, or
provide any other assistance, that you request. We do not share this
information with outside parties except to the extent necessary to
complete that transaction, change, or request. We use return email
addresses only to answer the emails we receive. Such addresses are not
used for any other purpose and are not shared with outside parties.
Moreover, we never use or share the personally identifiable information
provided to us online in ways unrelated to the ways described above,
without first providing you with an opportunity to opt-out or otherwise
prohibit such unrelated uses.
Our Commitment To Data Security:
The security of your personal information is important to us. When you
enter sensitive information on our portals, we encrypt 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, while we strive to use
commercially acceptable means to protect your personal information, we
cannot guarantee its absolute security.
"Cookies" are data files sent
by a website to your computer memory. They can be used to track
activity on the website and help protect the security of confidential
data. Your privacy and security are not compromised when you accept a
cookie from our website because no other company can access our cookie
information except us. The visitor information stored in a cookie,
during a session to our website, is only valid for that single session;
it would be useless to anyone who could decipher it once the visitor is
logged out.
Some of our business partners use cookies and other
tracking technologies on our corporate site. We have no access to or
control over these cookies and data is only collected in the aggregate.
Accessing Or Correcting Your Information:
You can access all your personally identifiable information that we
collect online and maintain by visiting the website or contacting the
plan administrator. If there are any factual errors regarding your
personal information located on our website, you can correct the errors
by sending a request to the designated contact of the website that
credibly shows error.
To protect your privacy and security, if the
contact individual is our employee, we will also take reasonable steps
to verify your identity before granting access or making any
corrections.
Minors:
This website does not intend to collect any information from, or market
any products or services to, children. We do not knowingly gather or
solicit data from children under the age of 18 through our website for
marketing purposes.
Additional Rights:
Applicable federal and state laws may give you additional rights that
are not put forth in this online Privacy and Security Policy. We
reserve the right to disclose your personal information as required by
law and when we believe that disclosure is necessary to protect our
rights and/or to comply with a judicial proceeding, court order, or
legal process served on our Website.
How To Contact Us:
Should you have any questions or concerns about this Privacy and
Security Policy, please call us at 1-800-692-8463 (Outside the U.S.
call +1-267-482-6400), contact us online, or at our mailing address
at :
MyDeferral Client Services
2600 Kelly Road, Suite 210
Warrington, PA 18976