Effective Date: March 1, 2019
Welcome! Thank you for visiting an offering of Aflac Incorporated and the Aflac group of insurance companies, including American Family Life Assurance Company of Columbus, its wholly owned subsidiary, American Family Life Assurance Company of New York, and Continental American Insurance Company ("CAIC") (the Aflac group of insurance companies are collectively, “Aflac,” “we,” our” or “us”). The aforementioned Aflac companies are separate legal entities. To help inform you, we provide this policy explaining our information practices and the choices you can make about the collection and use of information you submit or we collect (1) online through our websites www.moda371.com, www.aflacgroup.com, www.aflacny.com, and https://phs.moda371.com/aflac.phs.app/account/login, our mobile websites, and other applications (the “Site”), and (2) our offline services and tools, including call centers, offline enrollment tools, surveys, and other applications (“Offline Services”). The Site and Offline Services are collectively referred to in this policy as the “Services.” The Services are owned and operated by Aflac.
Contents & Summary
We collect the following information when you use these Services:
(c) Information to Respond to Your Requests: You may give us your personal information so we can respond to your requests for information, respond to and process applications, and send you newsletters and other communications.
(d) Social Media Information: When you sign in or engage with our Site through third-party social media sites, you agree to give us on-going access to your personal information.
(e) Video Information: We may collect analytical information about the videos you view on the Site. You consent to our collection of video viewing information on the Site and sharing this information with our affiliates and vendors.
(f) Survey Information: From time to time, we may ask you to complete surveys relating to your experiences with the Services. In connection with same, we may obtain your demographic information (e.g., city, state, account ID, date of birth).
(g) Information About Others: If you are an employer, Aflac broker or agent, you may submit applications or other information for your employees or clients. You confirm that you have obtained the required consent to submit this third party information to us.
(i) Mobile Information: We may collect additional information from you if you access our Site through a mobile device (e.g. your unique device identifier, location or GPS/geo-location).
(k) Geolocation: By using the site you expressly consent to our use of your geolocation to respond to your requests.
(m) Mobile Applications: When you download and use our mobile application(s), we may track and collect usage data to tell us what information has been accessed, viewed and/or downloaded to the application(s) based on your device number or other identifier.
We use information collected from you to provide our Services and contact you. Your information is retained for as long as we need it for our business and to provide you with the Services you request.
We may share your personal information and other information we collect with the following entities: (a) Aflac and the rest of our corporate family including company affiliates and subsidiaries; (b) our vendors and service providers; (c) other entities with your consent; (d) legal, regulatory and law enforcement authorities; (e) others if there is a change of control; (f) companies in the mobile app industry; (g) with others who visit our site if you share information on the Site; (h) others in accordance with state insurance and federal laws; and (i) others as required or permitted by law.
Aflac is fully committed to its compliance with the HIPAA Rules, including the Privacy Rule.
You can control how and when you want to receive notifications from Aflac by following instructions within the notices or contacting us as indicated in the Contact Us section below.
We and our service providers use tracking technologies (including cookies) to recognize you, protect your privacy, customize your experience on the Site, and target the content/advertising you see, including providing videos customized to your interests. You consent to our tracking of your video viewing through the Site or third-party social media.
You can review and edit your personal information by accessing your account on the Site or as otherwise indicated in the Contact Us section below.
If you are a California resident, you may request information about our practices related to disclosing your personal information and how we respond to Do Not Track signals.
We are not responsible for the privacy practices of third-party service providers or websites that are linked to or from our Site.
We protect your personal information using security measures.
Our Services are not intended for minors under the age of 18.
We store and process your personal information on our computers in the United States.
Scope and Consent
Information We Collect
Registration, Enrollment, and Account Information:
You can browse the Site without telling us who you are or revealing any personal information (e.g., name, username, password, PIN, email address, physical address, social security number, policy number, financial information, telephone number, mobile telephone number, text messages or email, health and medical information, audio, family and children’s information, date of birth, and photos) about yourself. If you register for an account with us, or enroll online or through a call center, you choose to give us your personal information and are not anonymous to us. When you register an account, enroll online or through a call center, create a profile, purchase Services, download a mobile application or otherwise apply for, request or engage with our Services on our Site or through another enrollment system, you may provide personal information. Personal information is only associated with your account/profile on the Site when you sign in as a registered user. Personal information is also collected via Offline Services when you provide it to us, such as applications submitted by you or on your behalf, information about your other transactions with us, and medical exams and tests you take in connection with your application or policy.
Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, internet protocol (IP) address, computer type, operating system name and version, device manufacturer and model, language, Internet browser type and version, and browser click-through and usage data. We may use this information for purposes such as analyzing the use of and interaction with our Site and Services, detecting fraud and diagnosing server problems.
The Aflac Careers sections of the Site give you the opportunity to create an “Application Account” to search and apply for jobs. To apply for a position, you will need to establish an “Application Account.” In order to do so, you will provide us with your email address, password, first and last name, physical address, phone numbers, and career data (e.g., work experience, education and certifications). Aflac is an equal opportunity employer. Your email and password will allow you to access your account later. You may choose to use third-party login credentials to establish and sign onto an Application Account. See the “Social Media Information” section below for more information on using third-party credentials to access the Site. Also, when you apply for a job or authorize us to obtain a consumer report (e.g., background check), we will collect personal and non-personal information (e.g., name, address, telephone number, resume, employment history, reference information, compensation, compensation history, education, social security number and so on).
Visit our employment application information policies for more information regarding the types of employment application information we collect and how we treat it.
You may give us your personal information when you submit a claim, or when you make changes to, check on, or update your claim.
Information to Respond to Your Requests:
You may give us your personal information so we can respond to your requests for information, review or process your application, and send you newsletters and other communications. Details of how you can opt-out of receiving any communications from us are detailed in the section headed “Your Choices” below.
Social Media Information:
We may offer sign-in services that allow you to use third-party login credentials to access the Site. We also may offer Services that allow you to share information with third-party social media websites such as Facebook, Google, Twitter, and others.
You agree that we may collect and share your video viewing with, or obtain information about your video viewing from, analytics service providers, advertising partners and third-party social media sites for two years or until you withdraw consent.
You agree that we may collect and share your demographic information (including city, state, and date of birth), claim number, policy holder or certificate holder information, to include your contact information, and other information you may provide to conduct policy holder or certificate holder surveys.
Information About Others:
Employers, Aflac brokers and agents, and their designees may choose to submit applications for other people, either on the Site or through an affiliate or vendor of ours. The applications for Aflac products and services may contain the applicants’ personal information. By submitting information on behalf of someone else to us, you represent and confirm that you have obtained consent from them to do so.
Information From Other Sources or Combined by Us:
The information about you that we collect may be combined with information we receive from other sources and from outside records (e.g., demographic information, navigation information, and/or additional contact information) that we have acquired in accordance with the law. If you are a policyholder or certificateholder of Aflac, personal information that you provide at Sites may be combined with certain other information we have collected about you through our policy application/administration procedures. In reviewing applications, policies, claims or performing our Services, we may collect additional information from you or others, such as from other insurance companies, consumer reporting agencies and credit bureaus as permitted by the Fair Credit Reporting Act, public records, public databases, government agencies, information clearinghouses and other third parties. In addition, you will have received a Privacy Notice from us explaining how we protect the privacy and security of information you provide and that is collected by Aflac (please see HIPAA Notice of Privacy Practices below in Section 5).
We may collect additional information from you if you access our Site through a mobile device (e.g., your unique device identifier, location or GPS/geo-location).
Technical Usage Information:
When you visit our Site, we collect usage information sent to us by your computer, mobile, or other access device that tells us how you are using the Site (“usage information”). We use tracking technologies (including cookies (including cookies stored in HTML-5), web beacons/GIFs, embedded scripts, and e-tags/cache browsers) to collect usage information.
We may also collect password information from you when you log in, as well as computer and/or connection information. During some visits we may use software tools to measure and collect session information, pages viewed, including page response times, files downloaded, download errors, time spent on certain pages, page interaction information, applications used, browser type, the user’s Internet service provider (ISP), and the user’s computer operating system.
Call Center Information:
When you contact our Call Center, we may collect your name, account ID and other information you provide so that we may assist you.
When you download and use our mobile application(s), we may track and collect usage data to tell us what information has been accessed, viewed and/or downloaded to the application(s) based on your device number or other identifier.
Uses and Retention
Provide Our Services:
We use the information collected to (i) respond to your requests; (ii) allow you to manage your policies and claims; (iii) allow us to service your policies and manage your claims; (iv) give you information about your account; (v) provide customer service (e.g., to resolve disputes, problems with your account/profile or the Services); (vi) personalize your experience by providing information and content about Aflac products and services to you that we believe may be of interest to you; (vii) operate our promotions (e.g., provide you with entries to and information regarding our sweepstakes and contests); (viii) manage, administer and improve our operations and Services, including Services via employers, brokers, agents and enrollment systems; (iv) conduct surveys; (v) allow you to use our online technologies; and (vi) provide you with a safe, efficient, and customized experience.
Analyze and Aggregate Non-Personal Information:
We use aggregate information about our users and non-personal information to administer, analyze and improve the Services and to analyze user behavior and prepare aggregated reports.
Communicate With You:
We use your information to contact you by U.S. mail, telephone, email, text message and other means to maintain the Services, your account, to comply with your stated communication preferences, to provide other services requested by you, as described at the time when we collect the information from you, to send you marketing communications, to respond to requests related to recruiting brokers, agents and clients or contact you for other purposes authorized by law.
We retain information as long as it is necessary and relevant for our operations, including servicing your account. You consent to our retention of your video viewing tracking data for as long as permissible under applicable law – up to one year after you close your account or otherwise withdraw consent for video tracking.
Information collected through the Services may be shared with:
The Aflac Corporate Family:
Service Providers and Other Third-Parties:
We may disclose your information to service providers under contract who help with our business operations and Services (such as, but not limited to, call centers, application and benefit enrollment services, policyholder or certificateholder claims processors and adjustors, survey providers, fraud investigations, advertising, computer software and hardware, site analytics and operations). We require these third parties not to further disclose your personal information to any other third party or use it for any other purpose.
Other Entities with Your Consent:
Other third-parties to whom you explicitly ask us to send your information (or about whom you are otherwise explicitly notified and consent to when using a specific service). You may have opportunities to express interest in or register for other services. If you do, we will provide information about you to those third-parties, or parties working on their behalf, to implement your request.
Legal, Regulatory and Law Enforcement:
Law enforcement, governmental agencies, or authorized third-parties, including but not limited to inspections, reviews, and in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Aflac user to legal liability. In this regard, we may share your information with third parties in response to a subpoena, court order, search warrant, other legal process and/or to others as required or permitted by law. In such events, we may disclose information relevant and necessary to the inspection, investigation or inquiry, such as name, city, state, zip code, telephone number, email address, user ID history, IP address, fraud complaints and anything else we may deem relevant to the investigation. As appropriate, we also may disclose information to persons identified in our records who have a legal or legitimate interest in your policy, such as mortgagees, lessors or lienholders.
Change of Control – New Owners:
Companies in The Mobile App Industry:
If you access the Services through a mobile device, we may also share your information with carriers, operating systems and platforms.
Information You Share Through the Services:
Notices of Information We Share Pursuant to State and Federal Laws:
Under various state laws and the Gramm-Leach-Bliley Act, insurers and agents must describe their information practices in addition to providing a HIPAA Notice of Privacy Practices.
Aflac policyholders select your appropriate notice or form below:
Aflac Group certificate holders select your appropriate notice or form below:
HIPAA Notice of Privacy Practices
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule provides individuals with the right to receive a notice that describes (1) how their individual health information, personal information and other protected health information (“PHI”) may be used and/or disclosed, (2) their privacy rights with respect to their PHI (including their right to access their PHI and other rights), and (3) Aflac’s obligations with respect to that information. Aflac is fully committed to its compliance with the HIPAA Rules, including the Privacy Rule, in safeguarding PHI.
For its HIPAA-covered insurance policies, Aflac is federally mandated to send a notice (Notice of Privacy Practices) to its insureds and to post the notice on its website. You should be aware that your state law may provide additional access and amendment rights to you which differ from those granted by HIPAA. If you would like additional information concerning the collection and disclosure of PHI and your rights under state law to access and amend such information, it will be furnished upon request. Please e-mail your request to firstname.lastname@example.org. If you are an CAIC account or certificate holder, please email your request to email@example.com.
In order to access Aflac’s HIPAA Notice of Privacy Practices, please select from the appropriate options below:
Aflac Group certificate holders:
Cookies and Tracking Technologies
A few additional important things you should know about our use of tracking technologies (e.g., cookies, HTML-5 stored technologies):
- We offer certain features that are available only through the use of tracking technologies.
- We use both session and persistent tracking technologies. Tracking technologies (e.g., cookies) can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser). You are always free to decline tracking technologies if your browser permits, although doing so may interfere with your use of the Site. Refer to the help section of your browser, browser extensions, or installed applications for instructions on blocking, deleting, or disabling tracking technologies such as cookies.
- We use tracking technologies with your prior consent as obtained through your use of this Site.
- We encode and protect the tracking technologies that Aflac sets, so that only we can interpret the information stored in them.
- You may encounter tracking technologies/cookies from our third-party service providers that we have allowed on our Site that assist us with various aspects of our Site operations and services, such as Google Analytics.
- You also may encounter tracking technologies from third-parties on certain pages of the websites that we do not control and have not authorized. (For example, if you view a web page created by another service user, there may be a cookie placed by that web page.)
- We may target and track the videos you view on the Site. You consent to our tracking of your video viewing through the Site or third-party social media for up to two years or as permitted by applicable law or until consent is withdrawn.
Accessing, Reviewing, and Changing Your Personal Information
Notice to California Residents
- Residents of the State of California may request a list of all third-parties to which our Site has disclosed certain personal information (as defined by California law) during the preceding year for those third-parties’ direct marketing purposes. If you are a California resident and want such a list, please contact us at firstname.lastname@example.org. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. In the body of your request, please provide enough information for us to determine if this applies to you. You need to attest to the fact that you are a California resident and provide a current California address for our response. Please note that we will not accept requests via the telephone, mail, or by facsimile, and we are not responsible for notices that are not labeled or sent properly, or that do not have complete information.
How We Respond to Do Not Track Signals for California Residents:
California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how Aflac responds to “Do Not Track” browser settings. Aflac does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
Our Site may contain links to other third-party websites, or they may provide services on our Sites. We are not responsible for the privacy practices or the content of these third-parties. Please refer to the privacy policies of these third-party sites to learn how they collect and use your information.
We store and process your information on our servers located in the United States. We maintain technical, physical, and administrative security measures designed to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use are firewalls, data encryption, physical access controls to our data centers and information access authorization controls. It is your responsibility to make sure that your personal information is accurate and that your password(s) and account registration information are secure and not shared with third-parties. Also, as a reminder, the Internet and email generally are not often/always secure, and they should not be used for sending sensitive personal information, such as your SSN, birthdate or financial information. Emails also can be intercepted and/or read by unintended recipients. If you choose to communicate with us by email, then in order to contact us in a more secure manner, and if applicable, log into your Aflac account on the Site, which has additional safeguards in place.
The Site is a general audience site and it is not directed to minors under the age of 18. We do not knowingly collect personal information via our Services from users in this age group.
Notification Regarding Updates
If your questions are not answered online through this Policy or websites, you may email us at email@example.com, or contact us as follows:
Aflac Worldwide Headquarters
1932 Wynnton Road
Columbus, Georgia 31999
1600 Williams St.
Columbia, South Carolina 29201
Mailing and Email Address
Aflac Worldwide Headquarters
Attn: Privacy Office
1932 Wynnton Road
Columbus, Georgia 31999
* Continental American Insurance Company (Aflac Group), a proud member of the Aflac group of insurers, is a wholly-owned subsidiary of Aflac Incorporated and underwrites group coverage. Continental American Insurance Company (Aflac Group) is not licensed to solicit business in New York, Guam, Puerto Rico, or the Virgin Islands. For groups sitused in California, coverage is underwritten by Continental American Insurance Company (Aflac Group). For groups sitused in New York, coverage is underwritten by American Family Life Assurance Company of New York.