Memoir, Inc. d/b/a Chapter and its affiliates, including Chapter Medicare LLC d/b/a Chapter Advisory LLC, and Chapter Technologies LLC (collectively “Chapter,” “Company”, “we”, “us”), provide services to educate and advise individuals regarding retirement decisions, including healthcare, financial, and technology matters. We also, through Chapter Advisory LLC (doing business in California as Chapter Insurance Services), provide licensed insurance agency services to help individuals choose additional Medicare coverage and other types of health coverage for their needs. This Privacy Policy is designed to help you understand how we collect, use, and share your personal information and to help you understand and exercise your privacy rights.
This Privacy Policy applies to personal information collected from and about you in connection with your use of our websites, mobile applications, and other online offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other online offerings are collectively called “Services”. In addition to reading this Privacy Policy, please review our Terms of Service, which governs your use of our Services, with the exception of Services provided by Chapter Technologies LLC, which are exclusively governed by the Chapter Technologies Terms of Sevice. If you do not agree to the applicable Terms of Service and the collection, use and sharing of your information as detailed in this Privacy Policy, please do not access or otherwise use our Services or any information or content accessible on our Services.
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
This Privacy Policy covers how Chapter collects, uses, shares, and processes personal and other information and data of users of our Services. To the extent that we provide you with notice through our Services of different or additional privacy policies or practices (e.g., at the point of collection), those additional privacy policies shall govern such data collection and use.
The categories of personal information we collect depend on how you interact with us, our Services and the requirements of applicable laws, regulation, and official guidance. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
We may collect the following personal information that you provide to us.
· Health Coverage Questionnaires. We may collect personal information that you provide through a questionnaire on our website so that we can evaluate your health coverage preferences and identify the types of health plans that make sense for you. The personal information we collect may include name, zip code, current medical providers, prescriptions, current medical plan information, and information regarding your health history. While much of this information is optional, providing as much information as possible allows us to provide recommendations that are better tailored and more useful for you.
· Account Creation. We may collect personal information if you choose to create an account, such as name, email address, and zip code.
· Your Communications with Us. We may collect personal information when you request information about our Services, register for our newsletter or blog updates, request customer or technical support, interact with our online forms and tools, complete an application for insurance coverage, interact with one of our representatives over the phone, apply for a job or otherwise communicate with us.
· Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
· Interactive Features. We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public”, unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
· Sweepstakes or Contests. We may collect personal information you provide for any sweepstakes or contests that we offer, consistent with applicable laws and regulations. In some jurisdictions, we are required to publicly share information of sweepstakes and contest winners.
· Conferences, Trade Shows, and Other Events. We may collect personal information from individuals when we attend conferences, trade shows, and other events.
· Business Development and Strategic Partnerships. We may collect personal information from individuals and third parties to assess and pursue potential business opportunities.
· Job Applications. We may post job openings and opportunities on our Services. If you reply to one of these postings by submitting your application, CV and/or cover letter to us, we will collect and use your information to assess your qualifications.
We may collect personal information automatically when you use our Services:
· Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. In addition, we may collect information that other people provide about you when they use our Services, including information about you when they tag you.
· Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, session replay and other technologies (“Technologies”) to automatically collect information through your use of our Services. Session replay tools may record your interactions with the Services, such as how you move across the Services or interact with our web forms.
· Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
· Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Our uses of these Technologies fall into the following general categories:
· Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;
· Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
· Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests – e.g., as you indicate in our questionnaire –or past items viewed;
· Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
· Analytics. We may use Technologies and other third-party tools to process analytics information on our Services, such as Google Analytics. For more information, please review the Google Privacy Policy. To learn more about how to opt-out of Google Analytics’ use of your information, please click here.
· Google Maps API. We use Goole Maps APIs in some of our Services. For more information about the Google Maps APIs, please review the Google Privacy Policy.
· Social Media Platforms. Our Services may contain social media buttons such as LinkedIn, Twitter, Facebook, and Instagram. These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.
See Section 5 below to understand your choices regarding these Technologies.
We may obtain information about you from other sources, including healthcare providers and third-party organizations and partners who provide health-related services and who authorize such information sharing. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
We use your information to fulfill our contract (the Terms of Service or the Chapter Technologies Terms of Service) with you and provide you with our Services, such as:
· Providing you with recommendations and short-lists regarding health plans;
· Assisting you in preparing coverage applications for submission to insurance carriers;
· Providing information to your designated healthcare provider or the healthcare provider who referred you, if authorized by you;
· Managing your information and accounts;
· Providing access to certain areas, functionalities, and features of our Services;
· Answering requests for customer or technical support;
· Communicating with you about your account, activities on our Services, and policy changes;
· Processing applications if you apply for a job, we post on our Services; and
· Allowing you to register for events, including any virtual events.
We use your information for various administrative purposes, such as:
· Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
· Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
· Measuring interest and engagement in our Services;
· Short-term, transient use, such as contextual customization of ads;
· Improving, upgrading or enhancing our Services;
· Developing new products and Services;
· Ensuring internal quality control and safety;
· Authenticating and verifying individual identities;
· Debugging to identify and repair errors with our Services;
· Auditing relating to interactions, transactions and other compliance activities;
· Enforcing our agreements and policies; and
· Complying with our legal obligations.
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable laws, regulations, and official guidance.
Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalized advertising,” including through cross-device tracking, in compliance with applicable laws and regulations.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth below.
We also use your information for other purposes as requested by you or as permitted by applicable law.
· Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
· De-identified and Aggregated Information. We may use personal information and other information about you to create de-identified and/or aggregated information that does not identify you individually, such as metrics regarding plan selection, de-identified demographic information, de-identified location information, information about the devices from which individuals access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
· Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends or colleagues through our referral services. Our referral services may allow you to forward or share certain content with a friend, colleague, or healthcare provider, such as an email inviting your friend to use our Services.
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
· Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes service providers that provide us with IT support, hosting, payment processing, customer service, and related services.
· Business Partners. We may share your personal information with business partners to provide you with a product or service that you have requested. With your consent, we may also share your personal information to business partners with whom we jointly offer products or services.
· Affiliates. We may share your personal information with our company affiliates with your consent for our administrative purposes, including activities such as IT management, for them to provide services to you such as health brokerage services, or support and supplement the Services we provide.
· Advertising Partners. We may share your personal information with third-party advertising partners where you have provided your consent for us to do so. These third-party advertising partners may set Technologies and other tracking tools on our Services to collect information regarding your activities and your device (e.g., your IP address, cookie identifiers, page(s) visited, location, time of day). These advertising partners may use this information (and similar information collected from other services) for purposes of delivering personalized advertisements to you when you visit digital properties within their networks. This practice is commonly referred to as “interest-based advertising” or “personalized advertising.”
· APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and software development kits (“SDKs”) as part of the functionality of our Services, such as to obtain the latest information on Medicare plans, insurance carriers, healthcare providers, and prescription drugs to consider this information in our recommendations for you. For more information about our use of APIs and SDKs, please contact us as set forth below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
· Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms of Service or this Privacy Policy).
We process requests to be placed on do-not-mail, do-not-phone, and do-not-contact lists as required by applicable law.
· Text Messages. You may opt out of receiving text messages from us by following the instructions in the text message you have received from us or by otherwise contacting us at [email protected]. No mobile information will be shared with third parties/affiliates for their own marketing/promotional purposes. All the above categories exclude text messaging originator opt in data and consent; this information will not be shared with any third parties.
· Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information if you use our mobile application. You may opt out of this collection by changing the settings on your mobile device.
· “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.
· Cookies and Interest-Based Advertising. You may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Digital Advertising Alliance, the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada. Additionally, you can turn off certain third-party targeting/advertising cookies by visiting the Network Advertising Initiative: https://optout.networkadvertising.org/ and by visiting Google: https://tools.google.com/dlpage/gaoptout.
Please note you must separately opt out in each browser and on each device. Your browser may provide you with some options regarding cookies. For more detailed information about how to disable or administer your cookie settings in your web browser, please refer to the applicable page for the browser you are using:
• Safari: http://help.apple.com/safari/mac/8.0/#/sfri11471
• Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Microsoft Edge / Internet Explorer: http://windows.microsoft.com/en-GB/windows-vista/Block-or-allow-cookies
• Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
You can withdraw your consent to allow for cookies, change your browser settings, and delete the cookies already stored on your computer at any time. Please note that if you delete, or choose not to accept, cookies, you may not be able to utilize the features of the services on our website to their fullest potential.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us.
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
If you are from a non-U.S. country, please be aware that the personal information you submit, including information provided through our Services, is being sent to a location in the United States. The data protection laws in the United States are likely different from those of the country in which you are located, and your personal information may be subject to access requests from governments, courts, or law enforcement in the United States according to laws of the United States. By providing such personal information through the Services, you are consenting to (and represent that you have authority to consent to), the transfer of such information to the United States for the uses and purposes described in this Privacy Policy. Without limiting the above, for the avoidance of doubt we do not have an establishment or target people in the EEA or UK.
It is our policy to protect the confidentiality of Social Security numbers (SSNs) from misuse and improper disclosure by maintaining and enforcing physical, electronic, and procedural safeguards. We prohibit unlawful disclosure of SSNs, and limit access to SSNs to our personnel who need access to SSNs in order to perform their job functions. We do not disclose SSNs to third parties except where required or permitted by law.
Residents of California may have certain rights under §1798.83, known as the “Shine The Light” law, to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal 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 clearly in writing to us using the contact information provided below.
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter603A. If you have any questions, please contact us as set forth below.
The Services are not directed to children or individuals under the age of 18, and we do not knowingly collect personal information from children. Protecting children’s privacy online is very important to us. If you are a parent or guardian and wish to review information that you believe we may have unintentionally collected from your child, or have that information modified or deleted, you may contact us as described below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account.
This Privacy Policy was last updated on October 3, 2023.
We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.
If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: