Privacy Notice

This page is used to inform website visitors regarding our policies with the collection, use, and disclosure of Personal Information if anyone decided to use our service.

If you choose to use our Service, then you agree to the collection and use of information in relation with this notice. The Personal Information that we collect are used for providing and improving the Service. We will not use or share your information with anyone except as described in this Privacy Notice. We do not sell your Personal Information.

The terms used in this Privacy Notice have the same meanings as in our Terms and Conditions unless otherwise defined in this Privacy Notice.

If you are a resident of California, please click here to find a specific notice regarding your privacy rights.

Protecting Your Personal Information

We maintain physical, electronic, and procedural safeguards to protect your personal information. The people authorized to access your personal information need it to do their jobs, and we require that they keep your information secure and confidential.

Personal Information We Collect

We collect your personal information from you, such as when you fill out applications and other forms, when you visit or enter personal details on our websites, when you respond to our emails, and when you provide information over the telephone. We also collect personal information about you that others give to us. Collectively, this personal information includes, for example:

  • first and last name;
  • address, email address, telephone number, and other contact information;
  • employment and occupation, including union membership;
  • insurance information;
  • participant information from organizations that purchase products or services from us for the benefit of their members or employees;
  • information gathered from your internet or network activity.

Using Your Information

We use your personal information for various business purposes, including:

  • normal everyday business purposes, such as contacting you, providing services to you, and administrating your account or policy;
  • business research and analysis;
  • data analytics, modeling, and the deployment of tools;
  • marketing products and services of LaborFirst and other companies that may interest you;
  • detecting and preventing identity theft, fraud, or misuse of your accounts;
  • and otherwise as required by law.

Sharing Your Information

We may share your personal information, including information about your transactions and experiences, among LaborFirst companies and with other non-LaborFirst companies who perform services for us or on our behalf, for our everyday business purposes, such as providing services to you, or administering your account or policy. We may also share your personal information with a financial institution if you agree that your account or policy can be transferred to that financial company.

We may share your personal information among LaborFirst companies so that the LaborFirst companies can market their products and services to you. We may also share consumer report information among LaborFirst companies which may include information about you from credit reports and certain information that we receive from you and from consumer reporting agencies or other third parties. You can limit this sharing by following the instructions described in this Notice.

For those customers who have one of our products through a plan sponsored by an employer or other organization, we will share your personal information in a manner consistent with the terms of the plan agreement or consistent with our agreement with you.

We may also share your personal information as permitted or required by law, including, for example, to law enforcement officials and regulators, in response to subpoenas, and to prevent fraud.

Unless you agree otherwise, we do not share your personal information with non-LaborFirst companies for them to market their products or services to you. We may tell you about a product or service that other companies offer and, if you respond, that company will know that we selected you to receive the information.

Log Data

We want to inform you that whenever you visit our Site, we collect information that your browser sends to us that is called Log Data. This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser version, pages of our Service that you visit, the time and date of your visit, the time spent on those pages, and other statistics.

Security

We value your trust in providing us your Personal Information, thus we are striving to use commercially acceptable means of protecting it. But remember that no method of transmission over the internet, or method of electronic storage is 100% secure and reliable, and we cannot guarantee its absolute security.

LaborFirst does not warrant that the website will operate error free or is free from viruses, worms, Trojan horses, or other destructive or harmful code. LaborFirst assumes no liability or responsibility for any damages to you, your computer, or other property due to your access to, use of, or downloading of content. If you download or copy content from this website, you are responsible for taking all reasonable precautions necessary to ensure the security and integrity of your computer and systems, including employing current virus protection software.

Links to Other Sites

Our Service may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Notice of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Changes to This Privacy Notice

We may update our Privacy Notice from time to time. Thus, we advise you to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Notice on this page with the date it was last updated. These changes are effective immediately after they are posted on this page.

Product and Service InformationServices described in this web site are provided solely for general informational purposes. The information and descriptions contained herein are not intended to be complete descriptions of all terms, conditions, and exclusions applicable to the products and services provided by LaborFirst. The precise coverage afforded is subject to the terms, conditions, and exclusions in the actual policies as issued.

Tracking Visits and Use

To improve the Site and for our own business purposes, we may compile records of your visits to the Site and/or your visits to or use of various elements of the Site.

Children

This website does not intend to market any LaborFirst products or services to children under sixteen (16) years of age. LaborFirst does not knowingly gather or solicit data from children under sixteen (16) years of age through this website for marketing purposes. By using this website you represent that you are not under sixteen (16) years of age.

Cookie Notice

A cookie is a small amount of data sent to your browser from our computer. We use cookies to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. You may set your browser so that it does not accept cookies, although this would affect the usability of the Site.

We or our service providers (such as Google Analytics) may collect data related to your use of the Service, including which of our pages you access, the frequency of such access, and your product and service preferences. This data collection may be accomplished by using cookies, web beacons, page tags or similar electronic tools. Such web surfing data may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Site. Web surfing data and similar information may be used for administrative purposes, to assess the usage, value, and performance of our online products and services, and to improve your experience with the Service. As with cookies, the web surfing information collected is aggregated, anonymous “click stream” and transactional data, and is not associated with any users as individuals.

If you would prefer not to see advertising based on your personal preferences, you can change your personal settings in Google (look for “Ad Settings”) or visit the website of the Network Advertising Initiative located at: http://www.networkadvertising.org/choices/#completed.

Limiting Our Use – Opt-Out/Privacy Choice

You may tell us not to share your personal information among LaborFirst companies for marketing purposes, and not to share consumer report information among LaborFirst companies, by “opting out” of such sharing. To limit our sharing for these purposes:

  • call us at: 856-291-4617; or
  • email us at: klundgren@laborfirst.com; or
  • send us written correspondence at: Labor First, LLC, 1000 Midlantic Drive, Suite 100, Mt. Laurel, New Jersey 08054.

You are not able to limit our ability to share your personal information among LaborFirst companies and with other non-LaborFirst companies for servicing and administration purposes.

Third Party Sites

You might navigate to websites maintained by third parties by clicking on a link from our Site. For example:

  • We use third parties to perform services for the Site, such as hosting services, electronic signature providers, electronic payment service providers, and services that verify the qualification of investors.
  • From time to time we might allow third parties place banner advertisements on our Site. When you click on a banner advertisement, you are transferred from our servers to the servers of the third party.

In these and all other cases, once you leave our Site, the terms of this Privacy Notice no longer apply and we have no control over the collection or use of personal information you provide to such websites.

Notice to California Residents

Your privacy is important to us. This California Resident Privacy Notice, as required by the California Consumer Privacy Act of 2018 (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) applies to visitors, users, and others (e.g., employees, customers, and prospects) who reside in the State of California. The information in this Privacy Notice is provided by LaborFirst, as well as its parents, subsidiaries, and affiliates. The LaborFirst entities providing this Privacy Notice are referred to herein as “we” or “us,” consistent with our Terms and Conditions. This Privacy Statement explains how we collect, use, and disclose personal information relating to California residents (referred to herein as “You” and “Your”).

To exercise your privacy rights, you may contact our Privacy Officer:

Kim Lundgren
Senior Vice President, IT
Labor First, LLC
1000 Midlantic Drive, Suite 100
Mt. Laurel, NJ 08054
Phone: 856-291-4617
klundgren@laborfirst.com

What is Personal Information?

Under the CCPA, as amended by CPRA, “Personal Information” is information that identifies, relates to, describes, references, or is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or device.

Personal Information does not include de-identified or aggregate consumer information (such as demographic level data or data that can no longer be tied to a single identifiable individual), or information that is publicly available (such as information from public records).

Our Collection, Use, and Disclosure of Personal Information

We collect Personal Information relating to California residents in a variety of contexts. For example, we collect Personal Information relating to individuals who request or obtain our products or services for themselves or a business, apply for employment with us, or are our employees, vendors, contractors, or similar personnel, visitors to our locations or facilities, or our shareholders. The specific Personal Information that we collect, use, and disclose relating to a California resident will depend on our relationship or interaction with that individual.

Categories of Personal Information Collected

The personal information we collect about California residents includes information within the categories below.

These categories are defined by California law and represent the covered categories of personal information that we have collected about California residents, and how they have been shared, over the past twelve months. We do not necessarily collect all information listed in a particular category, nor do we collect all categories of information for all individuals.

We collect this Personal Information directly from you and from the following types of sources: employers and unions.

Categories of Personal Information collected include:

  • first and last name;
  • address, email address, telephone number, and other contact information;
  • employment and occupation;
  • insurance information;
  • participant information from organizations that purchase products or services from us for the benefit of their members or employees;
  • information gathered from your internet or network activity, such as identifiers including, but not limited to internet protocols (IP) address;
  • geolocation information including, but not limited to device location; and
  • professional or employment-related information including, but not limited to work history, prior employer, and other information necessary for verifying employment eligibility.

We also collect the below categories of sensitive personal information as defined under California law. We generally use sensitive personal information only for the necessary purposes below or as otherwise permitted by law.

Categories of sensitive personal information collected include:

  • union membership.

Sensitive Personal Information

We generally do not use or disclose your sensitive personal information for purposes other than the following:

  • to perform the services or provide goods requested by you;
  • to detect security incidents;
  • to resist malicious, deceptive, fraudulent, or illegal actions directed at us;
  • to ensure the physical safety of natural persons;
  • for short-term transient use, including non-personalized advertising;
  • to maintain or service accounts, provide customer service, process or fulfill orders and transactions, verify your information, process payments, provide analytic services, or provide storage on our behalf;
  • for employment and diversity purposes; or
  • to verify or maintain the quality or safety of a service or device owned or controlled by us.

Purpose and Use of Personal Information Collected

The purposes for which we use the Personal Information that we collect depend on our relationship or interaction with a specific California resident. We use Personal Information:

  • to operate, manage, and maintain our business;
  • to provide our products and services;
  • for our employment and vendor management purposes; and
  • as directed by the individual the Personal Information is about or with their consent.

For example, we use Personal Information to personalize, develop, and market our products and services; conduct research and data analysis; maintain our facilities and infrastructure, protect health and safety; operate and manage IT and communications systems; facilitate communications; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with the law, legal process, and internal policies; maintain

records; as well as to exercise and defend legal claims.

Disclosure of Personal Information for Business Purposes

In the past twelve months, we have disclosed the following categories of Personal Information relating to California residents to certain third parties for our business purposes: personal identifiers, online use of information, and geolocation information.

The purposes for which we disclose Personal Information depend on our relationship or interaction with a specific California resident. We disclose for the purposes below:

  • to operate, manage, and maintain our business;
  • to provide our products and services;
  • for employment purposes;
  • to confirm the accuracy of data received; and
  • as directed by the individual the Personal Information is about or with their consent.

Retention of Personal Information

We retain personal information, in compliance with our records retention policies and for as long as needed based on the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

  • the length of time we have an ongoing relationship with you and provide you with the products and services you request;
  • whether there is a legal obligation we are subject to (for example, certain laws require us to keep records of certain transactions for a certain period of time before we can delete them);
  • if there is a contractual obligation to which we are subject; or
  • to different retention periods based on the factors listed above.

Rights of California Residents

If you are a California resident, you have the following privacy rights regarding your personal information.

These rights may not apply with respect to information that we collect about you in connection with providing products or services for personal, family, or household purposes or for long-term care or individual health products.

Your Right to Access

You have the right to request the following information collected and disclosed by us for the preceding twelve months:

  • the categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
  • the business or commercial purpose for collecting, selling, or sharing Personal Information about you;
  • the categories of Personal Information about you that we disclosed to third parties for a business purpose and the categories of third parties to whom we disclosed Personal Information (if applicable); and
  • the specific pieces of Personal Information we have collected and retained about you.

Your Right to Delete

If you are a California resident, you may also request that we delete the Personal Information we have collected about you. We may decline to honor your request, in full or part, for certain reasons, such as a legal exemption or where the information is required to fulfill a legal obligation, is necessary to exercise or defend legal claims, or where we are required or permitted to retain the information by law. For example, we cannot delete information about you while continuing to provide you with products or services or where required to be retained for regulatory purposes.

For example, if the information you are requesting is subject to certain federal privacy laws, like the Health Insurance Portability and Accountability Act (“HIPAA”) that are outside the scope of the CCPA rights requests, we may decline to honor your request.

Your Right to Correct

If you are a California resident, you may also request that we correct inaccurate Personal Information that we maintain about you. We must verify your identity before honoring your request. We may also deny a request to correct if we determine that the contested Personal Information is more likely than not accurate based on the totality of the circumstances.

We do not sell or share your information with non-LaborFirst companies.

If you are a resident of Virginia, Colorado, Connecticut, Utah, or other states, you may have differing or additional privacy rights not specifically enumerated in this Privacy Notice.

Privacy Contact

If you would like to exercise your privacy rights, have any questions about your data, or would like to speak to our Privacy Officer, please contact:

Kim Lundgren
Senior Vice President, IT
Labor First, LLC
1000 Midlantic Drive, Suite 100
Mt. Laurel, NJ 08054
Phone: 856-291-4617
klundgren@laborfirst.com

For some privacy rights requests, we must verify that you are who you say you are. Information collected for purposes of verifying your request will only be used for verification and to respond to your Personal Information request. For deletion requests, once you submit a verifiable request for deletion you will be asked to confirm separately that you want personal information about you deleted.

Limiting or Declining Your Request

We may limit the response or decline to honor your request where:

  • providing such information would be impossible or involve disproportionate effort (g., greater than twelve months prior to your request);
  • we cannot verify your identity or confirm that the Personal Information that we maintain relates to you;
  • we cannot verify that you have the authority to make a request on behalf of another individual;
  • an exception applies, such as where the disclosure of Personal Information would adversely affect the rights and freedoms of another consumer; or
  • we may also decline to honor your request where the Personal Information that we maintain about you is not subject to the CCPA’s access and/or deletion right.

 Your Right to be Free from Discrimination

We are prohibited by California law from discriminating or retaliating against you (e.g., employees, applicants, independent contractors) for exercising any of these privacy rights.