Code of Ethics & Compliance
BASG is committed to conducting its business in adherence to all legal requirements established by the states and territories in which it provides services and products. BASG takes pride in maintaining the highest ethical standards and industry best practices. To this end, BASG places the best interests of its clients as paramount to any other concerns involved in the placement of insurance services and products. Specifically, BASG:
- Abides by its ethical obligations to deliver honest, competitive, and meaningful service and advice on the placement of any insurance products, services, or coverages, and strives to provide access to an open, fair, and competitive insurance market place;
- Exercises due diligence in making full and complete disclosures of all quotes and declinations from all markets contacted for each specific line of coverage, including the date and time of contact, the name, address, phone number, and to the extent available, email address of the individual contact for each market;
- Makes every good faith effort to avoid even the appearance of a conflict of interest between BASG, its clients, and/or any provider of any insurance products or services, and promptly notifies clients of any real or potential conflict; and
- Takes reasonable steps to ensure that any available commission rates are provided to its clients upon request, including the identification of the appropriate contact sources from which to obtain commission rate information on the insurance policies issued.
Terms & Conditions
Introduction
The following terms and conditions (“Terms and Conditions”) govern use of this website (www.BASG.com) and any BASG supported website and the content therein, including mobile applications (collectively the “BASG Websites”). USE OF BASG WEBSITES CONSTITUTES ACCEPTANCE OF THESE TERMS AND CONDITIONS. IF YOU DO NOT AGREE WITH THESE TERMS AND CONDITIONS, YOU SHOULD IMMEDIATELY CEASE USE OF BASG WEBSITE.
The BASG Websites present information and content that is owned or licensed by BASG Insurance Services, Inc., its parents, subsidiaries, and affiliates (collectively, “BASG”). When used in these Terms and Conditions, “we” and “our” mean BASG and “you” and “your” refers to any individual or entity that accesses or otherwise uses the BASG Website.
Other Agreements
These Terms and Conditions apply only to use of the BASG Websites and do not modify any other agreement or contract that may exist between you and BASG (“Other Agreements”). In the event of any conflict between these Terms and Conditions and such Other Agreements, the Other Agreements govern and control.
DO NOT RELY ON THIS WEBSITE FOR YOUR FINANCIAL OR LEGAL DECISIONS
Content published on BASG Websites is for informational purposes only. Consult your financial and legal advisors, and independently verify all information whenever making any financial decision. Nothing on the BASG Websites should be construed as rendering tax, legal, investment, insurance, or accounting advice, nor should it be construed to bind coverage, unless otherwise expressly stated. Insureds should consult with their insurance advisors with regard to specific coverage issues.
SCOPE OF USE
Use of the BASG Websites to perform or participate in any illegal activity is prohibited.
You further agree that you are solely responsible for (and that BASG has no responsibility to you or to any third party for) any content that you create, transmit, or display while using the BASG Websites or services. You likewise agree that you are responsible for the consequences of your actions (including any loss that BASG may suffer).
PROHIBITED EMAILS; POSTS ON BASG-SUPPORTED FORMS OR BLOGS, ETC.
BASG’s email system is a private email system. Numerous or bulk unsolicited commercial email messages are prohibited. Emails intended to, or appearing to be intended to, harass, embarrass, threaten, defame, or impersonate any person or containing pornographic, offensive, indecent, or discriminatory matter is prohibited.
You agree not to access (or attempt to access) any of the BASG Websites or services by any means other than through the interface that is provided by BASG, unless you have been specifically allowed to do so in a separate written agreement with BASG. You specifically agree not to access (or attempt to access) any of the BASG Websites or services through any automated means (including the use of scripts or web crawlers).
SECURE AREAS; PASSWORDS
Portions of BASG Websites are restricted and require authorization for access. Unauthorized use of or access to such areas is prohibited. If you are an authorized user of any restricted area, you are responsible to maintain the security/confidentiality of your password. DO NOT SHARE YOUR PASSWORD WITH ANYONE.
BASG is entitled to act on instructions received under your password. Change your password immediately if you know or suspect that it has been compromised. If you suspect any unauthorized activity related to your account, you should contact BASG immediately. BASG will not be liable for any unauthorized access to your personal information that is (i) not the direct result of BASG’s intentional or negligent conduct, or (ii) the result of your failure to properly secure your password, or (iii) the result of your sharing your password with anyone else. BASG may block access to secure areas without prior notice if BASG believes that your password is being used by someone other than you, or if any unauthorized access to your personal information has occurred, or may occur, or for other reasons.
OWNERSHIP AND USE OF CONTENT
Except as may be otherwise provided by applicable law or written agreement with BASG, all information and content on the BASG Websites, including, but not limited to, all text, analyses, reports, articles, graphics, software applications, video and audio files, photos, trademarks, service marks and trade dress is owned or licensed by BASG. The content is protected worldwide by applicable intellectual property laws. Unless you have agreed otherwise in writing with BASG, nothing in these Terms and Conditions gives you a right to use any of BASG’s trade names, trademarks, service marks, logos, domain names, and other distinctive brand features. You may, however, make and use printouts of the content for your personal, non-commercial use only, provided that the printouts retain all copyright, trademark, and other proprietary notices. BASG reserves the right to terminate, at any time, your right to make personal copies of content. You may not copy, transmit, distribute, modify, publicly perform, reuse, sell, or display any of the content for any public or commercial purpose except with the prior written consent of BASG or the owners of the materials, which they may issue in their sole discretion. In addition, you may not use the content in any other website or in a network computer environment, including framing the content within another website. Except for the limited use rights expressly provided in this paragraph, all rights in content are reserved.
If you have been given an explicit right to use any of these brand features in a separate written agreement with BASG, then you agree that your use of such features shall be in compliance with that agreement, any applicable provisions of these Terms and Conditions, and any other applicable BASG policies that it may publish from time to time.
LICENSE
BASG gives you a personal, worldwide, royalty-free, non-assignable, and non-exclusive license to use the BASG Websites, and software or services provided thereby. This license is for the sole purpose of enabling you to use and enjoy the benefit of the BASG Websites, software, or services, in the manner permitted by these Terms and Conditions.
You may not (and you may not permit anyone else) to copy, modify, create a derivative work of, reverse engineer, decompile, or otherwise attempt to extract the source code of any software or program, unless expressly permitted or required by applicable law, or unless BASG specifically authorizes such activity in writing.
SUBMISSIONS MADE TO BASG
You may be required to provide information about yourself (such as identification or contact details) as part of the registration process for access to certain portions of the BASG Websites and the services provided. You agree that any registration information you give to BASG will always be accurate, correct, and up-to-date.
By providing information or materials to the BASG Websites (other than personal information subject to BASG’s Privacy Statement, http://www.BASGinsurance.com/Privacy.aspx), you grant to BASG an unrestricted, irrevocable, worldwide, royalty-free license to use, reproduce, display, publicly perform, and transmit such information and materials for any purpose, including without limitation, disclosing any such information and materials as necessary to satisfy any law, regulation, or governmental request. In addition, BASG is free to use any ideas, concepts, know-how, or techniques that you may submit to BASG through the BASG Websites for any purpose, including, but not limited to, improving our services. BASG shall not be subject to any obligations of confidentiality regarding the information or materials that you submit except as specified in BASG’s Privacy Statement, as set forth in Other Agreements, or as otherwise required by law. Although BASG will make reasonable efforts to protect and secure the personal information it receives, you should remember that email submissions over the internet may not be secure and are subject to the risk of interception by third parties. Please consider this fact before emailing or electronically submitting any personal or confidential information. BASG recommends that you encrypt personal or confidential information before submitting it over the internet.
You further acknowledge and agree that while BASG may not currently have set a fixed upper limit on the number of transmissions you may send or receive through the BASG Websites (or services provided thereby) or on the amount of storage space used for the provision of any service, BASG reserves the right to fix upper limits at any time and in its sole discretion.
JURISDICTIONAL STATEMENT; UNITED STATES ONLY
The services and products described and information provided through the BASG Websites are directed to and are intended to be made available only to persons in the United States and are not intended for distribution to, or use by, any person in any other country or any jurisdiction where such distribution or use would be contrary to law or regulation or that would subject BASG to any registration requirement within such jurisdiction or country. Software and other materials from the BASG Websites may be subject to export controls imposed by the United States and may not be downloaded or otherwise exported to any country or anyone prohibited by law. BASG prohibits your downloading or exporting of software or other material from the BASG Websites in violation of U.S. Export Laws and/or the laws of your resident country. By downloading software or other material from the BASG Websites, you represent and warrant that you are able to do so in full compliance with all applicable laws.
WARRANTY DISCLAIMER
We strive to provide accurate and up-to-date material on the BASG Websites. BASG and its licensors make no representations or warranties that the materials are suitable for your needs, are complete, timely, reliable, or are free from errors or inaccuracies. YOUR USE OF THE BASG WEBSITES AND CONTENT IS AT YOUR OWN RISK. BASG assumes no responsibility to keep content current or to correct inaccuracies or errors in content. The content published on the BASG Websites and the operation of these sites are provided “as is” and for informational purposes only, and BASG disclaims all representations or warranties of any kind, either express or implied, including warranties of merchantability, fitness for particular purpose, title, non-infringement, accuracy, completeness, and timeliness. Some jurisdictions may not permit certain disclaimers of warranties. In such case, BASG disclaims warranties to the fullest extent permitted by the applicable law.
YOUR RESPONSIBILITY FOR SECURITY
BASG does not warrant that the BASG Websites will operate error-free or are free from viruses, worms, Trojan horses, or other destructive or harmful code. BASG assumes no liability or responsibility for any damages to you, your computer, or other property due to your access to, use of, or downloading of content from the BASG Websites. If you download or copy content from the BASG Websites, you are responsible for taking all reasonable precautions necessary to ensure the security and integrity of your computer and systems, including employing current virus protection software.
LINKS
Links from the BASG Websites to a non-BASG site may be provided for users’ convenience only. BASG does not control or review these sites nor does the provision of any link imply an endorsement or association of such non-BASG sites. BASG is not responsible for and makes no representation or warranty regarding the contents, completeness or accuracy, or security of any materials on such sites. If you decide to access such non-BASG sites, you do so at your own risk.
LIMITATION OF LIABILITY
In no event shall BASG or any other party involved in creating, producing, or delivering the BASG Websites or content on BASG’s behalf be liable for any direct, incidental, special, consequential, indirect, lost profits, loss of business or data, or punitive damages arising out of your access to, or use of, or inability to access or use, the BASG Websites, or any content, or the performance of any product thereon, even if BASG is expressly advised of the possibility of such damages.
CHANGES
BASG reserves the right to change the content on the BASG Websites and services provided, including these Terms and Conditions, from time to time without prior notice. The changes may include superseding terms and conditions, specific notices, or the discontinuation or disabling of any service, program, website, or mobile application. YOU SHOULD REVIEW THESE TERMS AND CONDITIONS PERIODICALLY TO BE AWARE OF ANY CHANGES THAT ARE MADE. Your continued use of the BASG Websites constitutes your acceptance of any change or update, all of which shall become controlling when posted.
GOVERNING LAW
These Terms and Conditions shall be governed by, and construed in accordance with, the laws of the United States and the State of California, without giving effect to conflict of law principles thereof.
RESERVATION OF RIGHTS
BASG reserves the right to seek all remedies available at law and in equity for violations of these Terms and Conditions, including the right to block access from a particular internet address. BASG does not intend to market any products or services to children and does not knowingly collect personal information from them. By using the BASG Websites, you represent that you are at least 18 years old. If you are under 18 years old, do not use the BASG Websites.
SEVERABILITY
If any provision of these Terms and Conditions is held invalid, void, or unenforceable, then that provision will be considered severable and the remaining provisions shall remain in full force and effect.
Privacy Policies
At BASG Insurance Services, Inc. (“BASG”), one of our top priorities is making sure that the information we have about you is protected and secure. We value our relationship with you and work hard to preserve your privacy and ensure that your preferences are honored.
BASG Privacy Policy
1. Our Pledge to You
At BASG Insurance Services, Inc. (“BASG”), one of our top priorities is making sure that the information we have about you is protected and secure. We value our relationship with you and work hard to preserve your privacy and ensure that your preferences are honored. At the same time, the very nature of our relationship may result in BASG’s collecting or sharing certain types of information about you in order to provide the products and services you expect from us.
This Privacy Policy describes the information collected on our websites (including, but not limited to, www.BASG.com) (the “Site”) and how it is used and protected. This Privacy Policy applies only to the Sites.
By using the Sites or by providing your information to us, you consent to the collection, use, and disclosure of your information in accordance with this Privacy Policy, the Terms and Conditions, BASG’s Privacy Notices (to the extent applicable), and any written agreement(s) executed and in effect in connection with any of our products or services.
2. What Information is Collected by BASG or its Service Providers and When
The information we receive and how we use it depends on what you do when visiting the Sites. The Sites and related services may require registration for access. As part of registration and related services, we ask you to provide us certain information about you. You may provide us and our service providers personal information using the Sites in a number of ways, for example by entering that information into data fields on the Site (e.g., by creating an account) or in communications with us using the contact information at the end of this Privacy Policy or in the Terms and Conditions or Privacy Notices. Personal information includes data that specifically identifies you, such as your name, email address, mailing address, telephone number, and financial information. Public information is that information that you make publicly available through your account or by posting or otherwise communicating via the Site.
We may receive personal information from other sources. For example, if you connect your social media account(s) to your account, the social media site may share information with us about your use of their services, including information about your profile, contacts, and viewed or liked content. We encourage you to read the applicable privacy policies for your social media accounts. We shall have no responsibility for the data collection and use practices of those social media site.
If you use the Site to make a payment, we collect information about the transaction. This includes the date of the transaction, payment information, such as your credit or debit card number and other card information, and other account and authentication information, as well as billing and contact details.
BASG and its service providers also collect certain non-personal information, data that does not identify you as an individual person. This information tells us about how people use the Sites so that we can analyze their effectiveness and provide you with a better web experience. We collect and use this information through a variety of technologies, including “cookies” and analysis applications, as discussed below.
(a) Server Information
Like every website, the BASG servers automatically and temporarily store the following information in the server log files. This information is provided by your browser, unless you have deactivated the function.
- IP address of the inquiring computer
- File query by the client
- The http response code
- The Internet page from which you visited us (referrer URL)
- The time of the server query
- The browser type and version
- The operating system used on the enquiring computer
The server log files are not analyzed with respect to individuals. At no time can this data be attributed to specific individuals.
(b) Site Visit Tracking Technologies
As is standard practice on many websites, the Sites may use “cookies” and other technologies to help BASG understand which parts of the Sites are the most popular and the preferences of the BASG customers. BASG may also use cookies and other technologies to study traffic patterns on the Sites, to improve their functionality and usability as well as to improve the effectiveness of our communications with users. BASG may also use cookies to customize your experience and provide greater convenience to you during your interactions with the Sites.
A cookie is a unique alphanumeric identifier that websites use to help identify the number of unique visitors to a website, whether or not those visitors are repeat visitors, and the source of the visits. Cookies cannot be executed as code or used to deliver a virus and thus pose no threat to you. Servers and sites other than the one placing the cookie on your hard drive cannot read the cookie, and no personal information can be gathered by other servers from the cookie. If you prefer not to enable cookies or to disable them, you may do so through your web browser’s security settings. Please note that certain features of the Sites may not be available once cookies have been disabled.
Like most websites, the Sites gather certain information automatically and stores it in log files. This information includes internet protocol (“IP”) addresses, browser type, operating system, internet service provider (“ISP”), referring/exit pages, date/time stamp of access, and clickstream data, and information about the content you view on the Sites. When you visit the Sites, the servers automatically log your IP address, the time and duration of your visit, and the time and duration spent on the pages of the Sites which you view. If you arrive at the Sites by clicking a paid advertisement or a link in a communication, then the server will capture information that tracks your visit from that link. If you arrive at the Sites by clicking on a non-paid source, such as a search engine result or link on another website, the server may capture information that tracks your visit from that source, to the extent available.
Some of our communications to you may contain a “click-through URL” which links to content on the Sites. When you click one of these URLs, it passes information through the BASG web server before you arrive at the destination web page. BASG tracks this click-through data to help determine interest in particular topics and measure the effectiveness of our communications. If you prefer not to be tracked, simply avoid clicking text or graphic links in emails you receive from BASG.
Certain features of the Sites may use local stored objects (“Flash cookies”) to collect and store information about your preferences and navigation to, from, and on our websites. Flash cookies are not managed by the same browser settings as are used for browser cookies.
BASG additionally may use web beacons or pixel tags, which are tiny invisible graphic images, in the Sites. Web beacons and pixel tags may be used by BASG to count users who have visited its webpages and for related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
(c) Different Devices
If you use different devices (e.g., your smart phone, laptop, and/or home computer) to access the Sites, we may be provided with and collect device-specific information, including your hardware model, operating system version, unique device identifiers, phone number, location, and mobile network information. We may associate your device identifiers or phone number with your account information.
(d) Third-Party Analytics
We may use third-party service providers (e.g., search engines) to collect and analyze information about use of the Sites. These service providers may utilize cookies and related technologies to collect personal information.
3. Use of Information
BASG and its service providers may use your personal information to provide our products and services and to contact you in response to inquiries you submit. BASG and its service providers may retain and use your information for the following purposes:
- to present the Sites and related content to you;
- to provide you with information, products or services that you request from us;
- to provide you with notices about your account;
- to process your applications and transactions;
- in combination with other information for improvement of the Sites, as well as marketing and promotional purposes;
- to provide more consistent and personalized services across the Sites, including to personalize our advertising, marketing, and promotional efforts;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
- to notify you about changes to the Sites or any products or services we offer or provide though it;
- to allow you to participate in interactive features on the Site;
- in any other way we may describe when you provide the information; and
- for any other purpose with your consent.
4. When Your Information is Disclosed
BASG may disclose aggregated information about our customers without restriction. This data cannot be attributed to any specific individual. We may disclose aggregated customer data to our affiliates and to other third parties for lawful purposes.
BASG and its service providers may transfer information between them for business purposes. For example, BASG’s service providers may handle technical support, payment processing, marketing and surveys, or information analysis. We furnish our service providers the information they need to perform these and other services, and we work with our service providers to respect and protect your information. We may also provide your information to our affiliates. The entities with which we share information may be located in the United States or other countrie
In the event that BASG or some of our assets are sold or transferred or used as security, or to the extent we engage in business negotiations with our business partners, the information collected on the Sites may be transferred or shared with third parties as part of that transaction or negotiation. We may also provide information or provide access to information to any of our affiliated businesses or to our business partners.
On rare occasions, we may disclose specific information without your consent and without notice to you as required to comply with laws and regulations, or to comply with court orders, subpoenas, or lawful discovery requests. Information collected from you may also be used to investigate security breaches or otherwise cooperate with authorities. We may also share information with companies assisting in fraud protection or investigation.
We may disclose information about you without your consent and without notice to you as required to enforce or apply the Terms and Conditions or other agreements, including for billing and collection purposes.
5. How Your Information is Protected
We take reasonable steps to protect the privacy of your data by restricting access to our personnel on a need-to-know basis in connection with our providing services to you and by safeguarding it from unauthorized individuals by limiting access to our databases. Although access to your information is restricted by reasonable physical, technical, and organizational safeguards, it should be understood that we cannot guarantee complete security or accuracy of customer information. We ask that you assist our security efforts by maintaining the privacy of all computer passwords that you use to connect with BASG and to encrypt confidential information transmitted to us over the internet. Please also advise us immediately at the address listed below of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
6. Communications
You may receive electronic communications from BASG when you provide your email address. If you do not wish to continue receiving email communications you can opt-out by following the unsubscribe instructions provided in such communications.
7. Third Party Sites
The Sites may contain links to other websites. Please note that when you click on one of these links, you will leave the Sites and will be subject to the policies and privacy practices of the other site, which may differ significantly. You should review the policies of other sites you visit. The Company is not responsible for the content, technology, security, or practices of linked sites operated by others, or for your use of linked sites.
8. GLBA Privacy Notice
For U.S. customers, we will use and share any information that we collect from or about you in accordance with our Gramm-Leach-Bliley Privacy Notice.
9. EU Privacy Notice
For information about how BASG collects and uses EU personal information, please review our EU Privacy Notice.
10. Children’s Privacy
The Sites are not aimed at or intended for children. We do not knowingly collect information from children under the age of thirteen through the Sites. If we obtain actual knowledge that we have inadvertently collected personal information from a child under the age of thirteen, we will delete that information from our records. If you believe we might have any information from a child under the age of thirteen, please contact us here.
11. Applicable Law
We recognize that the Sites may be accessed from anywhere in the world, and that the laws of the jurisdictions in which some users are located may differ substantially from those of the United States and the State of California. Because we cannot practicably prevent users in different jurisdictions from accessing the Sites, you are responsible for knowing and complying with the laws of your jurisdiction. If such laws conflict with your use of the Sites or any of their content or functionality, the Sites are not intended for you, and we ask you not to use them or submit any information through them.
12. California Privacy Rights
California Civil Code Section 1798.83 permits California residents who are users of the Sites to request from us once a year, free of charge, information about the personal information the Company disclosed to third parties for direct marketing purposes in the preceding calendar year (if any). If applicable, this information would include a list of the categories of personal information that was shared and the names and addresses of all third parties with which the Company shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us at the address provided below.
“Do Not Track” is a privacy setting that you may set in your web browsers. If turned on, this setting requests that websites not track information about users. At this time, we do not respond to “Do Not Track” browser settings or signals California residents who are users of the Sites may have additional rights, including the following:
- to request access to your personal information;
- to request deletion of your personal information;
- to request disclosure of the categories of personal information collected about you, the categories of sources of the personal information, the business or commercial purpose for collecting or selling the information, the categories of third parties with whom the Company shares the personal information, and the specific pieces of personal information collected about you.
Please note that these rights may be subject to certain limitations. However, we will not discriminate against you for exercising any of these rights. If you are a California resident and would like to make such a request, please submit your request in writing to us at the address provided below.
13. Review, Modify, or Delete Your Information
To the extent you have established an account with our system, you can review and change your personal information by logging into the Sites and visiting your account. You may also send us an email to correct or delete any personal information that you have provided to us. If you request that your account information be deleted or if you unsubscribe from communications, we may maintain information about your transactions or inquiries for future service and recordkeeping purposes. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide you information, products, or services. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
14. Updates to this Privacy Policy
BASG may update this Privacy Policy and the Sites to reflect material changes in how we collect, use, share, or store your information, to satisfy legal requirements, or for other business purposes. You should review this Privacy Policy when you visit the Sites to understand our current practices. The date at the top of the page shows when this Privacy Policy was last updated.
We encourage you to refer to this Privacy Policy on an ongoing basis so that you understand our current practices. You consent to any changes we make to this Privacy Policy if you continue to use the Site after receiving a notice of the change or upon our posting of the new Privacy Policy on the Site.
15. Interpretation of this Privacy Policy
Any interpretation associated with this Privacy Policy will be made by BASG’s legal counsel. This Privacy Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word 'including' is used, it means “including without limitation.”
This Privacy Policy does not create or confer upon any individual any rights, or impose upon BASG any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable country, state, and other privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and applicable privacy laws, this Privacy Policy shall be interpreted in that case to give effect to, and comply with, such privacy laws.
16. Contact Us
If you have questions or comments about this Privacy Policy or the Sites, please contact us using the information below.
Benefit Advisors Services Group, LLC (“BASG”)
18100 Von Karman Avenue
10th Floor
Irvine, CA 92612
Phone: (619) 238-1828
Send email here.
BASG Privacy Policy for California Residents
This Privacy Policy for California Residents supplements the information contained in BASG Insurance Services, Inc.’s (“BASG”) Privacy Policy and applies solely to all website visitors, users and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this policy.
1. Information We Collect
BASG collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, BASG has collected the following categories of personal information from its consumers and employees within the last twelve (12) months:
Category | | Examples |
---|---|---|
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. |
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, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories. |
C. Protected classification characteristics under California or federal law. | | Age (40 years or older), race, color, ancestry, 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, genetic information (including familial genetic information). |
D. Commercial information. | | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. |
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, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. |
F. Internet or other similar network activity. |
| Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement. |
I. Professional or employment-related information. | | Current or past job history or performance evaluations. |
K. Inferences drawn from other personal information. | | Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. |
Personal information does not include information that is publicly available from government records, de-identified or aggregated consumer information, and information excluded from the scope of CCPA such as health information covered by the Health Insurance Portability and Accountability Act of 1996, and its implementing regulations (collectively, “HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data, nor does it include personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (“FCRA”), the Gramm-Leach Bliley Act (“GLBA”), the California Information Privacy Act (“FIPA”) and the Driver’s Privacy Protection Act of 1994.
BASG obtains the above categories of personal information from the following sources:
- Directly from you. For example, from forms you complete or products you purchase.
- Indirectly from you. For example, from observing your actions on our website.
- From BASG clients, insurance carriers and third party administrators.
- From consumer reporting agencies
2. Use of Personal Information
BASG may use or disclose the personal information it collects for one or more of the following business purposes:
- To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
- To provide, support, personalize, and develop our Website, products, and services.
- To create, maintain, customize, and secure your account with us.
- To process your requests, purchases, transactions, and payments and prevent transactional fraud.
- To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
- To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Website, third-party sites, and via email or text message (with your consent, where required by law).
- To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
- For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
- To respond to regulatory and administrative agency requests, as well as law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To respond to civil litigation matters including subpoenas or other requests required by law.
- For other business and operational purposes, including litigation management.
- As appropriate to protect BASG’s rights or property or to protect the rights or property of you, our customers or others.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of BASG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by BASG about our Website users is among the assets transferred.
BASG will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
3. Sharing Personal Information
BASG may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we take reasonable steps to ensure that the third party who receives the information protects it. As needed, and when required by law, when we disclose personal information for a business purpose, we will enter into a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We may share your personal information for a business purpose with the following categories of third parties:
- Our affiliates
- Third parties to whom we need to disclose your information in connection with products or services we provide you
- Service providers, co-brokers, managing general underwriters and managing general agents
- Insurance carriers
- Governmental agencies for licensing purposes
- Third party claims adjusters
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, BASG has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category I: Professional or employment-related information.
Category K: Inferences drawn from other personal information.
No Sale of Personal Information
In the preceding twelve (12) months, BASG has not sold any personal information.
4. Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how you can exercise them.
Access to Specific Information and Data Portability Rights
You have the right to request that BASG disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability and Deletion Rights), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you.
- The disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that BASG delete any of your personal information that we have collected from you, subject to certain exceptions. Upon receiving and confirming your request (see Exercising Access, Data Portability and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code Section 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with BASG.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability and Deletion Rights
To exercise the access, data portability and deletion rights described above, please submit a verifiable consumer request to us by:
- Calling Us: (855) 608-6990
- Emailing Us
- Visiting Our Website
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time, we will inform you of the reason and extension period in writing.
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 the verifiable consumer request’s receipt. 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 personal information that is readily useable 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.
5. Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
6. Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section 1798.83) permits users of our Website that our California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email.
7. Changes to our Privacy Notice
BASG reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.
8. Contact Information
If you have any questions or comments about this notice, the ways in which BASG collects and uses your information, your choices and rights regarding such use, or you wish to exercise your rights under California law, please contact us at:
Posting Date: 1/16/20
Effective Date: 1/1/20
BASG EU Privacy Notice
1. Our Pledge to You
At BASG Insurance Services, Inc. (“BASG”), one of our top priorities is making sure that the information we have about you is protected and secure. We value our relationship with you and work hard to preserve your privacy and ensure that your preferences are honored. At the same time, the very nature of our relationship may result in BASG’s collecting or sharing certain types of information about you in order to provide the products and services you expect from us.
This EU Privacy Notice (“Notice”) is for persons located in the European Union (“EU”), and it supplements BASG’s Privacy Policy. This Notice describes how BASG uses your personal information in accordance with the EU General Data Protection Regulation (“GDPR”).
2. Scope
This Notice applies to individuals whose personal information is collected by or provided to BASG while the individual is located in the EU. This Notice applies to such personal information whether it was provided to BASG on our websites (including, but not limited to, www.BASG.com), or through any process whereby personal information is collected by, or on behalf of, BASG.
3. Sensitive Personal Information
At times, BASG and its service providers may need to request your sensitive personal information (e.g., information relating to health, genetics, or biometrics). Unless BASG has another legal basis for collecting and processing your sensitive information, BASG will request your affirmative consent before collecting and processing this information.
4. Use of Information
BASG and its service providers may use your information to manage our contractual relationship with you, because we have a legitimate interest to do so, and/or to comply with a legal obligation. These purposes are identified in our Privacy Policy.
On other occasions where we ask you for consent, we will use the information for the purposes which we explain at that time. You have the right to withdraw you
5. Data Retention
We retain personal information for as long as necessary to provide services to you and fulfill the transactions you have requested, or for other necessary purposes such as complying with our legal obligations and enforcing our agreements. Retention periods vary depending on the type of information and how it is used. The criteria we use to determine the appropriate retention periods include:
- How long we have a relationship with you and provide services or products to you.
- Whether there is a legal, contractual or similar obligation that requires us to keep your information for a certain period of time.
- Whether you have consented to retention of your information for a longer period of time.
- Whether the personal information is sensitive.
When we no longer need to use or retain your personal information, we will remove it from our systems or depersonalize it so that it cannot be used to identify you.
6. Rights to Access and Control Your Personal Information
You have choices about the collection, use, and sharing of your personal information, including:
- Access: You can request a copy of your personal information.
- Change or Correct: You have a right to correct personal information that we hold about you that is inaccurate or incomplete. You can review and edit your personal information by logging onto our websites and visiting your account. You may also send us an email to correct any personal information that you have provided to us.
- Deletion: Under certain circumstances, you can request that we erase or delete all or some of your personal information (e.g., it is no longer necessary to provide services to you).
- Object to or Restrict Use: Under certain circumstances, you can request that we stop using and processing your personal information or restrict our use and processing of your personal information.
- Data Portability: You have the right to have your personal information transferred to another organization.
- Automated Individual Decision-Making: You have the right not to be subject to a decision based on automated profiling.
- Marketing: You may opt-out of direct marketing or profiling we carry out for direct marketing by sending us an email.
- Withdrawing Consent: If we have collected or processed your personal information with your consent, you may withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information based on other lawful processing grounds.
For your protection, we may need to verify your identity before fulfilling your request. Please note that we may need to retain certain information for recordkeeping purposes or to complete transactions that occurred prior your request. We will also retain your personal information if reasonably necessary to comply with our legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or enforce the Terms and Conditions.
To learn more about how to make these requests, please contact us here.
7. File a Complaint
You may submit a complaint to an EU supervisory authority if you believe that BASG’s processing of your personal information violates the GDPR. For more information about submitting a complaint, consult the relevant supervisory authority.
8. Cross-Border Transfers
We may transfer your personal information to other countries in compliance with applicable laws. In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those countries may have access to your personal information.
9. Updates to this Notice
BASG may update this Notice to reflect material changes in how we collect, use, share, or store your information, to satisfy legal requirements, or for other business purposes. We encourage you to refer to this Notice on an ongoing basis so that you understand our current practices. The date at the top of the page shows when this Notice was last updated.
10. Interpretation of this Notice
Any interpretation associated with this Notice will be made by BASG’s legal counsel. This Notice includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it means “including without limitation.”
This Notice does not create or confer upon any individual any rights, or impose upon BASG any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable country, state, and other privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Notice and applicable privacy laws, this Notice shall be interpreted in that case to give effect to, and comply with, such privacy laws.
11. Contact Us
If you have questions or comments about this Notice, please contact us using the information below.
Benefit Advisors Services Group, LLC (“BASG”)
18100 Von Karman Avenue
10th Floor
Irvine, CA 92612
Telephone: (619) 238-1828
Send email here.
Gramm-Leach Bliley (GLBA) Policy
1. Our Pledge to You
At Benefit Advisors Services Group, LLC (“BASG”) (“BASG”), one of our top priorities is making sure that the information we have about you is protected and secure. We value our relationship with you and work hard to preserve your privacy and ensure that your preferences are honored. At the same time, the very nature of our relationship may result in BASG’s collecting or sharing certain types of non-public personal information (“NPI”) about you in order to provide the products and services that you expect from us. Please read this Privacy Notice (“Notice”) carefully to understand how we collect, share, and protect our customers’ NPI.
2. Information We Collect
To provide you with insurance products and services, BASG may collect or obtain NPI actively (i.e., through an interaction with you, an affiliate, or a non-affiliated third party) or passively (i.e., automatically from your computer). The types of NPI we collect depend on the product or service you expect from us and may include:
- Information that you submit to BASG in applications or other forms, such as your name, address, telephone number, date of birth, social security number, occupation, assets, income, and health history;
- Information regarding your transactions with BASG, our affiliates, or non-affiliated third parties, such as your transaction history, policy coverage, payment history, and claims history; and
- Information provided to BASG by third parties (such as your employer(s), bank(s), or other insurer(s), as well as credit reporting agencies or government agencies) for the purpose of verifying the accuracy of our records.
3. How We Share Information
We may share some of the NPI we obtain about you as needed to provide the products and services you request.
Our sharing of NPI is primarily limited to companies related to BASG by common ownership or control (“Affiliates”). However, we may also share your NPI with certain non-affiliated third parties that perform business or professional services on our or your behalf. Such non-affiliated third parties, which BASG does not directly or indirectly control or own, may include:
- People who perform insurance, business, and professional services for us, such as helping us pay claims and detect fraud;
- Medical providers for insurance and treatment purposes;
- Financial services providers, such as companies engaged in insurance and securities; • Non-financial organizations, such as companies engaged in the direct marketing and selling of consumer products and services offered by BASG or our Affiliates; and
- People bound by confidentiality obligations, such as lawyers, auditors, and similar professional representatives.
We may also disclose NPI in connection with a proposed or final sale or merger of insurance business or for study purposes, but such disclosure, if any, is made confidentially and the recipient is bound by nondisclosure and use restrictions. We do not share your NPI with non-affiliated third parties for their own marketing purposes.
In addition, the law permits us to share information about our current and former customers with government agencies or authorized third parties under certain circumstances. For example, we may be required to share such information in response to subpoenas or to comply with certain laws.
When other companies help us to conduct business, we expect them to follow applicable privacy laws. We do not authorize them to use or share NPI except when necessary to conduct the work they are performing for us or to meet regulatory or other governmental requirements.
If you are a new customer, please note that we can begin sharing your NPI 45 days from the date we sent this notice. When you are no longer our customer, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
4. How We Protect Non-Public Personal Information
We take reasonable steps to protect the privacy of your NPI by restricting access by our personnel on a need-to-know basis in connection with our providing services to you and by safeguarding it from unauthorized individuals by limiting access to our databases. We give access only to employees who need to know the NPI to provide insurance products or services to you. Although BASG uses administrative, electronic, mechanical, and physical safeguards to protect the confidentiality and security of your NPI, it should be understood that we cannot guarantee complete security or accuracy of all customer information. We ask that you assist our security efforts by maintaining the privacy of all computer passwords that you use to connect with BASG and to encrypt confidential information transmitted to us over the internet.
5. Applicability of Practices
Our practices described above regarding NPI apply to our former, current, and future customers
6. Retention Period for NPI
We maintain NPI about you for as long as we provide products or services to you. We may maintain your NPI for a longer period if necessary for related business activities or as required by law. For our former customers, your NPI is subject to the same security protections, as well as the same use and disclosure restrictions, as is our current customers’ NPI. When NPI is no longer necessary for our business purposes or compliance with applicable law, we will return or destroy the information.
7. Access to Information
You may request access to certain NPI we collect to provide you with insurance products and services. You must make your request in writing and send it to the address provided in Section 11. The letter should include your full name, address, telephone number, and policy number (if applicable). If we validate your request, we will send you a copy of your NPI to the address provided.
Please note that if the NPI includes health information, we may require additional information from you. We may also need to coordinate your access through the provider of the information in accordance with the Health Insurance Portability and Accountability Act of 1996, and its implementing regulations (“HIPAA”) and any business associate agreement with the provider of the information. We may charge a reasonable fee to cover our copying costs.
Please note this section only applies to NPI BASG collects or obtains to provide you with insurance products or services.
8. Correction of Information
If you believe the NPI we have about you is incorrect, please write to us at the address provided in Section 11. Please include in your letter your full name, address, telephone number, policy number (if applicable), the NPI you request that we correct, and an explanation of why you believe your NPI is inaccurate. If we agree with you and are not legally prohibited from making the requested change, we will make the requested corrections to your NPI and notify you of the correction.
If we disagree with you or are not in position to make the requested change, such as because we received the NPI from a medical provider and do not maintain the NPI you requested us to correct, we will tell you why we are not going to make the requested correction. We will also tell you that you may submit a statement to us describing why you believe the NPI is correct. It should also include the reason(s) why you disagree with our decision not to correct the NPI in our files. We will file your statement with the disputed NPI.
9. Right to Opt Out
You have the right under the law to limit:
- Our sharing information about your creditworthiness to our Affiliates’ for their everyday business purposes;
- Our sharing of your personal information to our Affiliates to market to you; and
- Our sharing of your personal information to non-Affiliates to market to you.
If you would like to change or limit the way we share your NPI with our Affiliates or non-Affiliates, please contact us. See Section 11 for our contact information. California residents have additional rights. If you are a California resident, please see Important Privacy Choices for Consumers. Please note that it may take at least four (4) weeks to process your request.
10. Changes to this Privacy Notice
BASG reserves the right to change this Notice at any time. We will provide our customers with the updated Notice when we make substantive revisions. If we make a significant change, we will also note on the main page of our website that we have updated this Notice. In most cases, we will attempt to post notification thirty (30) days before the effective date of the change.
11. Our Commitment to Privacy and Contact Information
For additional information about BASG’s commitment to privacy, please visit the BASG Privacy Policies page.
You may contact us with any questions or to exercise your rights by calling us toll-free at (800) 821-9282 or by writing to:
Privacy Officer
Benefit Advisors Services Group, LLC (“BASG”)
18100 Von Karman Avenue
10th Floor
Irvine, CA 92612
This Notice is effective as of August 28, 2019.