SAG-AFTRA Health Plan Online Privacy Policy

We respect and are committed to protecting your privacy. This Privacy Policy lets you know how and for what purposes we are collecting, processing and using your Personal Information (as defined herein). We pledge that we will take reasonable steps to ensure that your Personal Information and Usage Information (as defined herein) will only be used in ways that are in compliance with this Privacy Policy.

This Privacy Policy is in effect for any web pages, mobile applications, third party social media sites (with respect to our use of your Personal Information), email lists, generic information and Personal Information collected by, owned by and/or made available on behalf of the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan (“our” or “we”), no matter the method of collection (e.g. mail, fax, sign-up/sign-in page, survey), including collection through this website, located at http://www.sagaftraplans.org and any online features, services and/or programs offered by or on behalf of the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan (collectively, the “Web Properties”).

Notwithstanding the foregoing, this Privacy Policy is not applicable to any other web pages, mobile applications, third party social media sites, email lists, generic information and Personal Information collected by, owned by and/or made available on behalf of any entity other than the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan. Users of the foregoing resources should refer to the privacy policy in effect for the applicable owner.

Your use of the Web Properties is also governed by the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan Terms and Conditions, located at http://www.sagaftraplans.org/health/tos and http://www.sagaftraplans.org/sag-pension/tos.     

Please read this Privacy Policy carefully, which includes important information about your legal rights, remedies, and obligations with respect to your Personal Information and Usage Information. By accessing or using the Web Properties, you are entering into a legal contract with the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan regarding your Personal Information and Usage Information. By accessing or using the Web Properties, you agree to be bound by the Privacy Policy and all additional terms incorporated by reference. If you do not agree to any portion of this Privacy Policy, you should not access or otherwise use the Web Properties.

We will make an effort to update this web page with any changes to this Privacy Policy and you are encouraged to review this Privacy Policy frequently.

Types of Personal Information the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan Collects or Receives

The SAG-AFTRA Health Plan and the SAG-Producers Pension Plan store and use the information that we collect or receive through the Web Properties in strict compliance with applicable state and federal law. The types of Personal Information we, and any third party we engage for the purposes of administering, operating, hosting, configuring, designing, maintaining and providing internal support for our Web Properties, collect may include, among other things (collectively, “Personal Information”): (1) contact information (e.g. name, address, home and mobile telephone numbers, email address); (2) biographical information such as household data, preferences, and demographic information (e.g. date of birth, gender, marital status); (3) mother's maiden name (parent's name prior to marriage); (4) bank account and credit/debit card numbers; (5) racial or ethnic origin; (6) social security number; (7) any of the above information about your spouse and dependents; and (8) your health care ID number.

How Information is Collected

The SAG-AFTRA Health Plan and the SAG-Producers Pension Plan may collect or receive your Personal Information and/or Usage Information when you: (1) request information about our products or services through the Web Properties; (2) access the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan’s social media platform; (3) sign up for email notifications, electronic newsletters, mobile messages (including SMS), or social media notifications from, or on behalf of the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan; (4) respond to one of our surveys; (5) provide the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan with comments, suggestions or other input through the Web Properties; (6) create or access your user account for use in connection with the Web Properties (your “User Account”); and (7) participate in any online discussion, providing comments, direct messages, correspondence between members or third parties, forum or similar exchange, publicly or privately, through the Web Properties, if applicable. We may also receive information from third parties that provide us with such information, including as part of any investigation or inquiry that we may undertake.

Website Collected Information

The SAG-AFTRA Health Plan and the SAG-Producers Pension Plan may also collect or receive three types of information when you visit or use the Web Properties: contact information, provided information and usage information.

Contact Information

Contact information refers to the information that you intentionally provide to us when you submit a request to be contacted. This information may include Personal Information such as your name, address, phone number, and email address, as well as any other information that you may voluntarily provide through the Web Properties. We collect this information only for purposes of responding to requests for more information about the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan and our offerings. When you submit contact information, you accept that this information will be shared with our staff, and agents acting on our behalf, that may be able to assist you.

Provided Information

You may be asked to submit or you may voluntarily submit information through the Web Properties, including Personal Information. Whether you submit any Personal Information to the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan through the Web Properties is entirely up to you. You are under no obligation to provide Personal Information this way. However, this information is essential for the provision and quality of some of the services we offer to you, so we cannot provide you with certain services if you choose to withhold requested information. Your submission of any Personal Information, and our and our agents' use of your Personal Information that they receive from us, shall at all times be in compliance with this Privacy Policy.

Usage Information

The SAG-AFTRA Health Plan and the SAG-Producers Pension Plan may obtain generic information about you when you visit the Web Properties (collectively, “Usage Information”). The types of Usage Information we, and any third party we engage for the purposes of administering, operating, hosting, configuring, designing, maintaining and providing internal support for our Web Properties, collect may include, among other things, the following categories of information: (1) Internet Protocol (or IP) address, protocol and sequence information; (2) browser language and type; (3) domain name system requests; (4) operating system and platform, device type and device identifiers; (5) browsing history (including time spent at a domain, time and date of your visit) and number of clicks; (6) hypertext transfer protocol headers, application client and server banners, and operating system fingerprinting data; (7) MAC address, device ID/UDID, or similar device-specific code; and (8) aggregated information.

Browser Log Files: Our servers automatically log each visitor to the Web Properties and collect and record certain information about each visitor. This information includes or may include your IP address, browser language, browser type, operating system, domain names, browsing history (including time spent at a domain, time and date of your visit), referring/exit web pages and URLs, and number of clicks. The domain name and IP address reveal nothing personal about the visitor other than the IP address from which the visitor has accessed the Web Properties.

Cookies: From time to time, the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan may send a cookie to your computer. By continuing to use the Web Properties, you are agreeing to our use of cookies. A cookie is a small piece of data that is sent to your Internet browser from a web server and stored on your computer's hard drive and that can be re-sent to the serving website on subsequent visits. A cookie, by itself, cannot read other data from your hard disk or read other cookie files already on your computer. A cookie, by itself, does not damage your system. We may use cookies to identify and keep track of, among other things, those areas of the Web Properties that you have visited in the past in order to enhance your next visit to the Web Properties, and to improve the Web Properties’ performance and usefulness. You can choose whether or not to accept cookies by changing the settings of your Internet browser, but some functionality of the Web Properties may be impaired or not function as intended if you choose not to accept cookies. Each browser is a little different, so look at your Help menu to learn the correct way to modify your cookies. For more information about cookies, including how to set your browser to reject cookies, visit www.allaboutcookies.org.

Web Beacons: Some of our web pages and electronic communications may contain electronic images, which may or may not be visible to you, known as Web Beacons (sometimes referred to as clear gifs). Web Beacons collect only limited information that includes a cookie number; time and date of a page view; and a description of the page on which the Web Beacon resides. These Web Beacons do not carry any Personal Information and are only used to track usage of the Web Properties and activities associated with the Web Properties.

Unique Identifier: We may assign you a unique internal identifier to help keep track of your future visits. We use this information to gather aggregate demographic information about our visitors, and we use it to personalize the information that you see on the Web Properties and some of the electronic communications you receive from us. We keep this information for our internal use.

Use of Personal Information

The Personal Information that we collect is used to:

1. Enable the features of the Web Properties, including, but not limited to: (a) providing services to you, such as providing you information about the applicable pension and health plans; and (b) setting up and managing your online account, including but not limited to our processing your requests for information, and/or providing support, products or services to you.

2. Improve the Web Properties by determining which of our products, features and services are most popular. We may analyze your information and usage information to enable us and our affiliates to provide services to you and develop new features, functionality and services and otherwise for our internal business purposes.

3. Personalize your experience on the Web Properties.

4. Communicate with you and to inform you about our services. When requested by you, we and/or any of our third party service providers may send you and keep you updated with information about existing and new products, services or features by email, telephone (including, but not limited to, SMS), mail or by means of any other contact details you provide to us, our affiliates or to such third party service providers.

Protected Health Information

The SAG-AFTRA Health Plan does not share your Protected Health Information (“PHI”) that we obtain through the Web Properties or by other means with third parties, except authorized parties as permitted under the Health Insurance Portability and Accountability Act (“HIPAA”). To learn more about our treatment of medical information and how the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan protect your PHI, please review our Notice of Privacy Practices, located at http://www.sagaftraplans.org/sites/default/files/inline-files/SAG-AFTRA_Health_Plan_Notice_of_Privacy_Practices_10_2016.pdf, which is incorporated herein by reference.

When Information is Disclosed by the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan

In addition to the times or occasions permitted under HIPAA when we might disclose Personal Information about you, we might also disclose Personal Information when required by law or in the good-faith belief that such disclosure is necessary to: (1) comply with a legal process and applicable laws; (2) enforce this Privacy Policy; (3) respond to claims that any materials, documents, images, graphics, logos, designs, audio, video and any other information provided to, from or on the Web Properties by you violates the rights of third parties; (4) assist government enforcement agencies; (5) investigate and/or protect our rights, property or safety or the rights, property or personal safety of our agents, employees, contractors, visitors and the public; (6) investigate potential unauthorized access or misuse of the Web Properties; or (7) otherwise enforce or apply our Terms and Conditions and other agreements.

We may now or in the future share non-personally identifiable information (such as anonymous user usage data, referring/exit pages and URLs, platform types, number of clicks, etc.) with third parties to demonstrate the usage patterns for the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan content, functionality and/or services on the Web Properties and/or on third party websites, or as we otherwise see fit, consistent with applicable law. Non-personally identifiable information, in an aggregated, anonymized form, such that you are not individually identified, may be provided to other parties for marketing, advertising or other uses, as we see fit.

We also reserve the right to disclose Personal Information and/or non-personally-identifiable information in connection with the enforcement of our Terms and Conditions, to take precautions against liability, to investigate and defend against any third-party claims or allegations, to assist government enforcement agencies, to protect the security or integrity of the Web Properties, and to protect our rights, property, or personal safety of  the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan, and that of our users or others.

We reserve the right to transfer your Personal Information, as well as any other information about or obtained from you, in connection with the merger, sale or other disposition of all or part of the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan business and/or assets. You expressly agree and consent to the use and/or transfer of your Personal Information or other information in connection with a sale or transfer of some or all of our assets in any of the above described proceedings. Furthermore, we cannot and will not be responsible for any breach of security by any third parties or for any actions of any third parties that receive any of the information that is disclosed to us.

The Web Properties may also link to a wide variety of other websites and may contain advertisements of third parties. We are not and cannot be responsible for the privacy policies of those websites of third parties or for how they treat information (including, but not limited to personally identifiable information) about their users.

We may disclose your Personal Information and/or Usage Information for any purpose disclosed by us when you provide the information. We may also disclose your Personal Information and/or Usage Information with your permission or as directed by you.

User Account, Password, and Security

For certain features available through the Web Properties, we may require the use of encryption technologies provided for your protection and/or User Account. We use reasonable precautions to protect the privacy of your username, password and User Account information and to ensure that information collected through the Web Properties is not lost, misused or altered inappropriately by administering security measures.

You are ultimately responsible for protecting your username, password and User Account information from disclosure to third parties, and you are not permitted to circumvent the use of required encryption technologies. You agree to: (a) immediately notify the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan of any unauthorized use of your username, password and/or User Account, and/or any other breach of security; and (b) ensure that you log out from your User Account at the end of each session. While we may provide certain encryption technologies and use other reasonable precautions to protect your confidential information and provide suitable security, we do not and cannot guarantee or warrant that any information transmitted through the Internet is secure, or that such transmissions are free from delay, interruption, interception or error.

We maintain reasonable safeguards to keep your Personal Information secure. When we provide Personal Information to our affiliates or third party service providers as discussed in this Privacy Policy, we require that these parties agree to process such information in compliance with our Privacy Policy or in a manner that complies with applicable privacy laws. The use of your information by a trusted business partner may be subject to that party’s own privacy policy.

Employment Opportunity Information Collection

For individuals interested in job opportunities with the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan, the Web Properties currently or may in the future allow you to submit a request for additional job opportunity information and/or submit a resume or similar information. The Web Properties may be used to collect Personal Information from prospective employees for human resources recruitment purposes. The information may then be shared with the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan human resources department and others within the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan who are involved in the recruitment process. By submitting any of this information you consent to our use of the information. This permission also applies to job application inquiries that you may send to us other than through the Web Properties.

Information from Children

We do not collect Personal Information from any person that we know to be under the age of 13 for purposes of the Web Properties. Specifically, the Web Properties are not intended or designed to attract children under the age of 13. You affirm that you are either more than 18 years of age (or such greater age of consent in your state of residence), or are an emancipated minor, or possess legal parental or guardian consent, and are fully able and competent to enter into the terms, conditions, obligations, affirmations, representations, and warranties set forth in this Privacy Policy, and to abide by and comply with this Privacy Policy. THE WEB PROPERTIES ARE NOT INTENDED FOR CHILDREN UNDER 13 WHO ARE  UNSUPERVISED  BY THEIR PARENT(S) OR LEGAL GUARDIAN(S).

Parents and legal guardians should be aware that this Privacy Policy will govern our use of Personal Information, but also that information that is voluntarily given by children – or others – in email exchanges, forums, discussion areas, comments, bulletin boards or the like may be used by other parties to generate unsolicited communications.  The SAG-AFTRA Health Plan and the SAG-Producers Pension Plan encourages all parents and legal guardians to instruct their children in the safe and responsible use of their Personal Information while using the Internet.

The SAG-AFTRA Health Plan and the SAG-Producers Pension Plan do collect Personal Information about children in connection with administering and operating the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan pension and health plans, and nothing herein shall limit or otherwise restrict the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan ability or practices with respect to such collection about children. We do not engage in any marketing activities to your child through the Web Properties. To be clear, we treat privacy as a top priority, especially any information about your child.

Privacy Outside the Web Properties

The Web Properties may now or in the future contain various links to other websites, including, but not limited to, links to websites of various third party service providers. SAG-AFTRA Health and SAG-Producers Pension Plan are not and cannot be responsible for the privacy practices or the content of any of those other websites. Other than under agreements with certain reputable organizations and companies that are Business Associates under HIPAA, we do not share any of the Personal Information that you provide to us with any of the websites to which the Web Properties link, although we may share aggregate, non-personally identifiable information, such that you are not individually identified, with those other third parties. Please check with those websites in order to determine their privacy policies and your rights under them.

European Union Users

The Web Properties and our products and services are hosted in the United States and are governed by United States law. As some of the SAG-AFTRA Health and SAG-Producers Pension Plan participants are located in countries subject to the General Data Protection Regulations (GDPR) which took effect on May 25, 2018, we are providing this GDPR Notice.  The purpose of this Notice is to make clear that while our operations are not necessarily subject to GDPR compliance, the Plans are nonetheless issuing this GDPR Notice to explain the handling of the personal data of those who reside in one of the countries subject to the GDPR.  If you are using the Web Properties or our products or services from outside the United States, please be aware that your Personal Information and/or Usage Information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Web Properties or our products and services, you consent to your Personal Information and Usage Information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.

Choices Regarding Your Personal Information

Whether you submit any Personal Information to the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan through the Web Properties is entirely up to you. You are under no obligation to provide Personal Information to us. However, this information is essential for the provision and quality of some of the services that we offer to you, so we cannot provide you with certain services or provide you with access to certain features if you choose to withhold requested information.

You may choose to prevent the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan from disclosing or using your Personal Information under certain circumstances (“opt out”). You may opt out of any disclosure or use of your Personal Information for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization by notifying us by one of the methods at the end of this Privacy Policy, or by following the procedures set forth in an electronic communication from us, if applicable. There are some uses of Personal Information from which you cannot opt out, such as pursuant to HIPAA, a valid law enforcement investigation or civil proceeding, or a transfer to a third party in accordance with this Privacy Policy.

You also may not opt out of the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan collection and use of your Personal Information in connection with the routine business operations and data collection in connection with administering and operating the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan pension and health plans. Nothing herein shall limit or otherwise restrict the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan ability or practices with respect to such collection and use of your Personal Information as set forth in the preceding sentence.

Please note that opting out of the disclosure and use of your Personal Information as a prospective employee may prevent you from being hired as an employee by the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan to the extent you are using this Web Properties to apply for an open position.

If the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan collect Personal Information from you, such information will not be disclosed or used by the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan for purposes that are incompatible with the purpose(s) for which it was originally collected or for which you subsequently gave authorization unless you affirmatively consent to such disclosure and use.

Your California Privacy Rights

Under California’s “Shine the Light” law otherwise known as the California Consumer Privacy Act (CCPA), California residents who provide certain personally identifiable information in connection with obtaining products or services for personal, family, or household use are entitled to request and obtain from us (once per calendar year) information about the customer information that we shared (if any) with other businesses for their own direct marketing uses.  The purpose of this notice is to make clear that while our operations are not necessarily subject to the CCPA compliance, the Plans are nonetheless issuing this CCPA Notice to explain the handling of this information.  If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2018 will receive information regarding 2017 information sharing activities, if any).

To obtain this information, please send an email message to complianceofficer@sagaftraplans.org with “Request for California Privacy Information” in the subject line and in the body of your message.  We will provide the requested information to you at your email address in response.  Please be aware that not all information sharing is covered by the “Shine the Light” requirements, and only information on covered sharing will be included in our response.

Under California Civil Code Section 1789.3, California users are entitled to the following consumer rights notice: If you have a question or complaint regarding the services or products provided through the Web Properties, please send an email complianceofficer@sagaftraplans.org. You may also contact us by writing to 3601 West Olive Avenue, Suite 200, Burbank, California 91505 or by calling us at (818) 973-4472. Currently there is no charge to access the Web Properties, other than to purchase any services or products through the Web Properties, and any applicable taxes and other charges associated with those purchases. Unless otherwise stated, these charges appear for each purchase on the order confirmation pages relating to each purchase. California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by mail at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (916) 445-1254 or (800) 952-5210.

“Do Not Track” Signals

Note that your browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services that you visit.  Like many websites and online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.  To find out more about “Do Not Track,” you may wish to visit www.allaboutdnt.com.

Access and Correction

To access your Personal Information in the possession of the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan and correct inaccuracies of that information in our records, please contact us in the manner specified at the end of this Privacy Policy. We ask you to identify yourself and the information requested to be accessed and amended before processing such requests, and we may decline to process requests in limited circumstances as permitted by our then current business practices and/or applicable laws, rules and regulations.

Your Consent to this Privacy Policy

By accessing and using the Web Properties, you consent to the collection and use of your information (including Personal Information) by us as specified above or as we otherwise see fit, in compliance with this Privacy Policy, unless you inform us otherwise by means of the procedure identified below. If we decide to change this Privacy Policy or some part of it, we will make an effort to post those changes on this web page so that you will always be able to understand what information we collect, how we use that information and under what circumstances we may disclose that information to others. Your use of the Web Properties following our publication of any amendment of this Privacy Policy will signify your assent to and acceptance of its revised terms for all previously collected information and information collected from you in the future. We may use comments, ideas, information, feedback or suggestions that you may submit in any manner that we may choose without notice or compensation to you.

If you have questions or comments of any kind, or if you see anything on the Web Properties that you think is inappropriate or incorrect, or you would like to send the SAG-AFTRA Health Plan and the SAG-Producers Pension Plan notification pursuant to the terms of this Privacy Policy, please contact us by email or by sending your comments, notifications or requests to:

SAG-AFTRA Health Plan and SAG-Producers Pension Plan

3601 West Olive Avenue, Suite 200

Burbank, California 91505

Attn: Compliance Officer

Phone:  (818) 973-4472

complianceofficer@sagaftraplans.org

Copyright © 2019. SAG-AFTRA Health Plan and SAG-Producers Pension Plan. All Rights Reserved.

EFFECTIVE AS OF: October 3, 2014

LAST UPDATED: November 4, 2019