This Policy does not apply to information collected by us offline, through any other means, or through the practices of any third-party, including any website or content (including advertising) that may be linked to or accessible from or through this Website.
People Under the Age of Eighteen
Our Website is not intended for children under eighteen (18) years of age. We do not knowingly collect personal information from people under eighteen (18).
If you are under eighteen (18), do not provide any information about yourself (including, but not limited to, name, address, telephone number, e-mail address, or any username you may use) on this Website through any of its features, do not register on the Website, and do not use the Website. If we learn we have collected or received personal information from a person under the age of eighteen (18), we will delete that information.
Information Protected by the HIPAA
We treat personal health information and personally identifiable information that we receive from insureds, applicants, and others in accordance with the requirements of the Health Insurance Portability and Accountability Act of 1996, the HITECH Act amendments, and other applicable state and federal laws and regulations. We do not share such information except for legitimate insurance functions as allowed by applicable state and federal laws governing the privacy of health information.
Information We Collect About You
Depending on your relationship with EmPRO, we may collect and process various types of personal information and private information (hereinafter referred to collectively as “information”), most of which is obtained by asking you to provide it to us. The types of information we may collect include the following:
- Contact Information – such as name, email address, mailing address, and phone number;
- Personal Identifiers – such as your Social Security number, driver’s license/state ID number, medical license number, policy number, claim information, and account number;
- Financial Information – such as credit/debit card number, bank account number;
- Employment Information – such as occupation, title;
- Demographic Information – such as age, date of birth, gender, and ethnicity;
- Internet or other electronic/online network activity information* – such as IP address, browsing history, search history, and device type;
- Inferences drawn and aggregates of data from the above categories of personal information reflecting your preferences, characteristics, behaviors, attitudes, and abilities.
In addition to the above categories, you may provide us with additional pieces of information when you apply for coverage, report a claim, create an account, update, or add information to your account.
How Long We Keep Your Information
EmPRO may retain your Information while your policy or other accounts with EmPRO are in existence or as needed to provide you our services and for legitimate and essential business purposes, such as maintaining or enhancing the performance of EmPRO services, complying with our legal obligations, and resolving disputes.
Because your Information may be collected in a variety of different manners and in different contexts, there is not a single retention period that applies to all categories of collected information. Nevertheless, EmPRO does not intend to retain your information for periods longer than reasonably necessary for fulfillment of the purpose(s) for which such information is collected. In general, EmPRO will retain your information to the extent needed to comply with our legal, tax, audit, and accounting obligations, for which periods of time could extend for a period of seven (7) years or greater. Thus, the criteria utilized by EmPRO with respect to the retention of your Information may involve an assessment of various state and federal laws and regulations, various Department of Insurance regulations and guidelines, and may vary depending on the context, circumstances, and purposes for which the information was collected.
How Do We Collect Information?
EmPRO may collect your Information from a variety of sources, including:
- You or your agent, whether in an electronic or hard copy format;
- Your employer(s);
- Other insurance entities, such as other insurers, reinsures, brokers, and third-party administrators;
- Claims adjusters;
- Credit agencies;
- Government and non-governmental databases of public information, such as medical boards;
- Claimants and their legal representatives;
- Social media utilized by EmPRO, including LinkedIn, Facebook, and Twitter;
- Medical research partners, certification organizations; and
- Other third-parties, service providers, business partners, or data brokers*.
Reasons We Collect/Use Information
There are a variety of reasons why EmPRO may collect and disclose your personal information. Some examples are provided below:
- Provide services and respond to requests: We may use information to analyze and underwrite your policy/submission, including through the use of automated decision-making systems, provide the services or products you buy, administer and handle claims (if any), provide a vigorous multi-disciplinary defense, and perform other services requested by you;
- Protection and Security: We may use information to protect the security and integrity of EmPRO, our users, and others;
- Administrative communications: We may use information to send you important information regarding our services, such as changes to our terms, conditions, and policies, and/or other administrative information;
- Marketing communications and mailing lists: We may use information to show you content based on your interests, including to notify you about our events or invite you to participate in surveys;
- Research and surveys: We may use information from you, our service providers, publicly available sources, and other third-parties to conduct healthcare research to improve care and outcomes, including sharing information with academic, professional, or other entities engaged in this research;
- Internal Business purposes: We may use information collected form the categories mentioned above for our internal business purposes, such as data analysis, audits, developing new products, and monitoring or improving the use and satisfaction of our services;
- Legal and Regulatory: We may use information to comply with our legal or regulatory obligations.
The types of information that may be gathered by EmPRO in connection with your use of our website, which we would ask you to provide us, include information relevant to your policy and coverage, including information about your training, credentials, work history, and license status. We may also gather information concerning any claims previously instituted against you by patients or actions by licensing bodies.
The information above illustrates, but does not exhaust, the kind of information that may be necessary for EmPRO to collect to serve our clients’ insurance-related needs.
Subject to the provisions above, we will not intentionally disclose any information of a confidential or sensitive nature unless authorized or we are required to disclose the information pursuant to a court order or request from the courts, law enforcement, or regulatory officials.
Neither EmPRO, its parent company, Physicians’ Reciprocal Insurers (PRI), nor EmPRO’s affiliates or subsidiaries, including, but not limited to, PRIMMA, LLC, sell, trade, rent, or otherwise offer financial incentive for the use of your information.
Disclosure of Information
EmPRO may disclose your information, which is collected by us, to business partners, such as:
- Service Providers and Contractors: We may disclose information to service providers who provide us with services such as data analytics, online advertising, order fulfillment, IT services, customer service, and/or other similar services. We grant service providers access to personal information only to the extent needed for them to perform their functions and require them to protect the confidentiality and security of such information;
- Third Parties: We may disclose information to unaffiliated third parties who partner with EmPRO to deliver our services or on our commercial activities including reinsurers, brokers, third-party administrators, appointed legal counsel, and other claims professionals. Depending on the nature of the use of the information, these third parties may contact you regarding products or services. However, we do not sell information to unaffiliated third parties for their own marketing purposes.
- Business Transfers or Assignments: In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business or assets (including without limitation in connection with any liquidation or similar proceedings), we may transfer any information that we collect from site users or offline to a third party.
- Law enforcement, emergencies, compliance: We may disclose information about you to others we believe to be appropriate:
- under applicable law including laws outside your country of residence;
- to comply with legal process;
- to respond to requests from public and government authorities including public and government authorities outside your country of residence;
- to enforce our terms and conditions;
- to protect our operations and property interest;
- to protect the rights, privacy, safety, or property of EmPRO, our employees, users of our service, or others; and
- to permit us to pursue available remedies or limit the damages we may sustain.
Safeguarding of Information
EmPRO aims to protect your information through a system of organizational and technical security measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we have undertaken and continue to implement safeguards to protect your information, transmission of information to and from our Site is at your own risk. You should only access the Site and our services within a secure environment.
Your Options Regarding Your Information
You may review, change, or terminate your account at any time. This would be completed by logging into your account settings and updating your account and/or contacting us using the contact information provided below.
You may also opt-out of marketing and promotional communications. This can be done via clicking the “unsubscribe link” in the emails that we send. You will then be removed from our marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, invoices, and to respond to service requests.
Tracking Technologies (Cookies, etc.)
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove or reject cookies, this may affect certain features or services on our Site.
Third-party sites hyperlinked from EmPRO may contain cookies that are collected by the third-party site owner. These cookies are beyond the control of EmPRO and we do not have access to this information.
Third-Party Websites and Social Media
EmPRO is domiciled in the State of New York in the United States. This Website is provided only for the use of individuals located within the United States, specifically where EmPRO is licensed to provide products and/or services. We make no claims that the Website, its accessibility, or its content is appropriate or your access to it is legal outside of the United States. If you access the Website from outside the United States, you do so at your own discretion and risk; in doing so, you may consent to the potential processing, collection, and/or transfer of your information to a country that may have different privacy laws than the United States and which may or may not be as comprehensive as your own state/country.
This section applies only to Connecticut Residents. Under the Connecticut Data Privacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
- Right to be informed whether or not we are processing your personal data;
- Right to access your personal data;
- Right to correct inaccuracies in your personal data;
- Right to request deletion of your personal data;
- Right to obtain a copy of the personal data you previously shared with Us;
- Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)
To submit a request to exercise these rights described above, please email: email@example.com or submit a data subject access request.
If we decline to take action regarding your request and you wish to appeal our decision, please email us at firstname.lastname@example.org. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Mail: EmPRO Insurance Company, 1800 Northern Boulevard, Roslyn, New York, 11576