• UniversalBenefitProgram is here to protect and improve the personal and financial health of all consumers.
• When you use, access or interact with our services, you are agreeing to our Terms of Service and also consenting to our information practices disclosed and hyperlinked herein.
• Definitions
• “UniversalBenefitProgram” or “us” or “our” or “we” refers to UniversalBenefitProgram and its affiliates, not to our parent company Genus.
• “Information practices” refers to the collection, use, disclosure, sale, share, and retention of personal information.
• “Privacy Policy” refers to this disclosure and our hyperlinked privacy disclosure incorporated by reference in their entirety.
• “Services” refers to information practices when you:
• visit or interact with us on our websites (“Websites” or “Sites”)
• apply for or obtain a product/service through us
• receive or reply to email or other electronic communications from us or our partners
• use our software applications (“Apps”) on or through computers and mobile devices
• register for online access to your account
• view or click on our ads or other Assurance online content
• ask to receive information about our products or services
• fill out an online survey or provide your feedback
• interact with us on social media or websites and applications maintained by other parties
• apply for employment with us
• provide services to us or on behalf of us as an employee of a service provider, consultant, or other business relationship
• “Website” or “Site” means www.UniversalBenefitProgram.com.
• “You” and “your” means the user of our Websites and Services.

Scope

This Policy covers our information practices and your choices in connection with our Services.

Regulations

Our U.S. Consumer Privacy Notice applies to our information practices in connection with seeking, applying, or obtaining a financial product or service pursuant to Gramm-Leach-Bliley Act (GLBA).

Our California Resident Privacy Disclosure, applies to the information practices subject to California Privacy Rights Act of 2020 (CPRA).

External Parties

This Policy does not cover the privacy practices of third parties or service providers that we do not own or control. Certain Services of affiliates may contain different privacy statements, which supplement this Policy.

We are not responsible for the information practices of third parties, including any third party operating a website or service to which our Services link. The inclusion of a link to a third-party feature does not imply endorsement of the linked website or service by us or by our affiliates. When you leave our Services or interact with a third-party feature, you should also read the applicable party's privacy policies and Terms of Service to make sure you understand their information practices.

In addition, we are not responsible for the information practices of other organizations, such as Facebook, Apple, Google, Microsoft, Bing, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose directly to other organizations or which you enable to be disclosed to other organizations as result of your device or browser preferences through or in connection with your use of the Apps or social media pages.

Geography

Our Services are intended for use by residents of the United States. They are not intended to subject us to the laws or jurisdictions of any state, country or territory other than those of the United States.

Children

Our Services are directed towards individuals able to shop, apply, or enroll in the financial service products we offer. Our Services are not directed at nor intended for unemancipated minors or children under the age of 16. We also do not knowingly collect personal information from minors.

How We Collect Information

Depending on your relationship with us, there are three primary ways we may collect information about you: (1) when you provide it to us, (2) through automated technologies, and (3) by asking others to provide it. We need to collect personal information to provide Services to you. If you do not provide the information requested, we may not be able to provide the Services.

We’ve broken down each of those three categories in further detail.

1. Information You May Provide to Us

You may provide information to us in various ways, such as through online forms, over the phone, or other means offered through our Service. For example, on our Website we may ask you some basic questions in order to generate an insurance quote for you. The types of information you provide us fit into two categories.

Personal Information is information that identifies you personally, such as your name, postal address, email address, telephone number, or other contact information.

Non-Personal Information is information about you or your household that, on its own, doesn’t identify you personally, like gender, income, employment status, or products of interest. This also includes information that has been aggregated in a manner such that it no longer reveals your identity

When we combine Non-Personal Information with Personal Information, we treat it like Personal Information for as long as it is combined.

Unless specifically requested, we ask that you do not send us, and you do not disclose, any additional personal information (e.g., information related to government identifiers, racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, or criminal background) during the use of our Services.

If you disclose, to us or to our service providers, any personal information relating to other people in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

2. Information We May Automatically Collect

We may automatically collect certain information from your device or computer regarding how you access and interact with our Services. We call this Usage Information for purposes of this Privacy Policy. Usage Information is a critical part of how we improve your experience on our Websites and, more importantly, provide you with more personalized insights and recommendations, which is the core of what we aim to do.

In some instances, we may combine Usage Information with Personal Information. If we do, we will treat the combined information as personal information as long as it is combined.

There are four types of Usage Information we may collect:

1. Device Information. We collect information about your device, such as your operating system, hardware model, application or browser type and version, browser configuration, IP Address, and unique identifiers associated with your device.

2. Activity Information. We automatically collect certain information in system logs or similar files about your use of our Services, how you interact with our Services and advertisements, and information about data or files that have been uploaded to our Services. This Information may include things like buttons you click and mouse movements, date and time of access, pages visited, web beacons, and cookie or pixel tag information. 

3. Information Used to Reidentify. We collect information to try to reidentify you across multiple browsing sessions and devices (for instance, connecting your current browsing session with a prior session).

4. Location Information. We may use certain information to estimate your location such as IP Address. We may also request location-enabled services on your device (which typically provide GPS or Wi-Fi access point details).

Note that you may choose to set your web browser to refuse, limit, or to alert you of certain information practices regarding Usage Information. On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising. If you do make such changes, please note that some parts of our Services, designed to combine digital guidance and human touch, may not function properly, and we may not be able to offer you a personalized experience.

3. Information Third Parties Provide to Us About You

To provide you with more personalized product recommendations, we collect information about you from third parties and from other sources, such as contracted parties, government data sources, public data sources, or an authorized proxy. For example, we may collect information from a third party to verify the address you provided, to help us understand your occupational background, to confirm you are not a bot, or to prevent entering fraudulent information. This also includes when you provide a third-party information and consent to share that information with us to help generate a personalized quote for you.

How We Use the Information We Collect

We use the information we collect from you and third parties to operate our Services, including to provide you with insurance quotes, communicate with you, and take steps to improve your experience. Such business and commercial purposes include:

• To provide personalized Services to you. We use the information we collect to provide Services to you in a personalized way including offering a quote, processing transactions, maintaining and servicing your account or policy, providing customer service. We also may collect information in our capacity as a service provider on behalf of a financial service providers (e.g., insurance carriers, financial institutions). Many of the products we offer are complex, and consumers look to us to guide them to find the one that best fits their needs and goals. The information we collect gives us a more detailed picture of who you are so we can help you find the right product.
• To improve and debug our Services. We are constantly trying to improve our Services. The information we collect may be used to conduct internal research and analysis including data analytics, modeling, and recommendation Services. The information we collect also helps us improve the experience we provide to consumers, the intended functionality of our Services, and the way we match consumers to product recommendations in real time. For example, in some instances, we may use information you have provided, even if you have not completed the web flow, so that if you return to the Website this information will be pre-loaded for your convenience.
• To detect, investigate, and prevent fraud, misuse, or malicious activities. We respect your privacy and safety and therefore may use the information we collect to detect, investigate, prevent, or take action regarding incidents, threats, and misuse of natural persons, your information, or our systems. This includes suspected theft, fraud, malicious, deceptive or illegal activities, or violations of our policies. As a result, we may also use the information we collect to verify your identity.
• To communicate with you and advertise to you. Part of providing personalized service is quickly connecting you with real people who can help walk you through your Service options, communicating to you about potential topics of interest, marketing and advertising to you, and responding to your requests and inquiries. For example, if you provide your phone number and email and then consent to being contacted by us, we may call you to connect you with one of our licensed insurance agents. We may also text and email you information about how to contact us, personalized marketing messages, information about your shopping journey, offers, and other information pertinent to your financial services inquiry.
• Opting Out of Further Communication. Many of the products we offer are complex, and consumers look to us to guide them to find the one that best fits their needs and goals. If you’d prefer we do not contact you, please opt-out of further communications from us by requesting to be placed on our Do Not Call list, by replying “STOP” to our text messages, by unsubscribing to our email list, or by using our Communication Opt-Out form.
• As required by governing law and for legal reasons. We operate in a regulated industry and therefore reserve the right to access, use, preserve, transfer or disclose, at any time without notice to you, information related to your use of our Services as reasonably necessary to do any of the following: comply with applicable law; respond to complaints, legal actions or governmental requests; enforce our Terms of Service; protect our rights, privacy, safety, or property; or respond to other similar matters. We may also use third-party services to record your actions on our Websites to help meet our compliance and legal obligations.
• As part of a corporate change. We may use, disclose, and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets.
• We may also use personal information for any other purposes that we may specifically disclose at the time we collect your information.

Who We Share Information With

As a distributor of financial services products, we work with a number of partners to deliver the Services to help a consumer meet their financial needs, and therefore share information with those partners. Although we aim to directly meet all of our consumers’ needs, we also may sell the information you provide us to third parties, to market their financial products and services, and to select insurers, financial institutions, and their Agents who may make insurance, credit, and other offers.

The following is a general list of how we may share your information in connection with your use of our Services:

• Share information with our business and financial service partners (e.g., insurance carriers) to provide and improve our personalized Services.
• Share information with third-party service providers acting on our behalf.
• Share information with advertising networks, social media networks, and marketing affiliates to communicate to you about our Services. This includes joint marketing and communications about your consents and preferences.
• Share information to third-party partners, to provide you or communicate to you about their products and services. These third parties may be other insurance agencies, insurance carriers, financial services providers, or other entities that facilitate the process of connecting customers with financial services providers. These third parties, or the entities they work with, may contact you based on the consent you have provided.
• As Part of a Corporate Change. We may disclose and transfer information about you to a third party as part of, or in preparation for, a change of control, restructuring, corporate change, or sale or transfer of assets.
• For Legal Reasons. We reserve the right to transfer or disclose information about you to third parties for certain legal purposes as described above.

The table outlines who we may share your information with in connection with our Services:

Tracking & Analytics Technologies

We may use various technologies to collect and store information in connection with your use of our Services. These may include things like cookies, browser storage, web beacons, and other tracking technologies.

• Cookies. Cookies are a standard feature of our Services that allow us to store small amounts of data about your use of our Websites. A cookie is a small piece of information that a website can send to your browser. It acts as a tag that identifies your computer but may not identify you personally. Cookies store information such as web pages viewed, advertisements clicked, browser preferences, etc.
• Pixel Tags. Pixel tags, also known as clear GIF or web beacons, are placed on certain pages of our Websites. When you access our Services, pixel tags generate a generic notice of that visit. They usually work in conjunction with cookies, for example, registering when a particular device visits a particular page. If you turn off cookies, the pixel tag will simply detect an anonymous visit.

UniversalBenefitProgram uses cookies and pixel tags to:

• provide better customer service
• analyze how visitors use and navigate our Services
• evaluate our advertisements on other websites
• identify areas which may need improvement
• enhance navigation and the functionality of our Services
• securely maintain a session for users accessing password-protected areas
• personalize aspects of your experience such as articles and education materials

We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.

You may also wish to refer to https://www.allaboutcookies.org/manage-cookies/index.html. If, however, if you do not accept cookies, you may experience some inconvenience in your use of the Services and you may not receive advertising or other offers from us that are relevant to your interests and needs.

Online Advertising

We, or other parties we do business with, may place or recognize unique cookies or other technologies on your browser when you interact with our Websites to collect information about your use of our Services and your other online activities (over time and across different websites), and may use that information to serve interest-based advertisements and behavioral advertisements to you as you browse the Internet.

To learn more about this information and to learn how to opt out of it in desktop and mobile browsers on a particular device, please review the information below:

• To opt-out of such collection and use for online behavioral advertising by the Digital Advertising Alliance (DAA) participating companies in the United States, please visit: DAA Choices and DAA AppChoices.
• To opt-out from the use of information about your online activities for online behavioral advertising by NAI member companies, visit: NAI. Please note that even if you opt-out, you may still receive advertisements that are not customized based on your Activity Information.
• To opt-out of the sale/sharing of information for behavioral advertising, please visit: Global Privacy Control.

Analytics

Our Websites may also use Google Analytics. Google Analytics uses cookies and similar technologies to collect information about how visitors use our Services. We use the information to compile reports and to help us improve the Services. Google Analytics may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

Our Websites may also use third-party analytics tools such as Verisk Analytics, ActiveProspect, Jornaya, LogRocket, Datadog, Microsoft Clarity, and Google Tag Manager to track page content and click/touch, movement, scroll, and keystroke activity.

How We Protect Your Information

We seek to use reasonable administrative, technical and physical safeguards, and other security measures to protect personal information within our organization from growing threats. Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate personal information to us through the use of the Services. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the contact methods provided below.

How Long We Retain Information

We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

Changes to this Policy

This Privacy Policy is effective as of July 2023. We reserve the right to change this Privacy Policy at any time. We will note within the Privacy Policy when it was last updated. Any changes to this Privacy Policy will be effective as of the day they are posted. Use of our Services following these changes signifies acceptance of the revised Privacy Policy.

Contact Us

We appreciate you taking the time to read this. If you have questions regarding this policy or information practices, you can email us at support@UniversalBenefitProgram.com