California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding Pareto’s use and disclosure of your personal information. To learn more about your California privacy rights, please read below.

Pareto has implemented commercially reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the Internet and electronic storage of such information is not completely secure. Although Pareto has taken commercially reasonable measures to protect your personal information, Pareto cannot guarantee the security of your personal information transmitted to or through the Website or subsequent storage of such information. Any transmission of personal information is at your own risk, and Pareto is not responsible for circumvention of any privacy settings or security measures contained on the Website or at the location where the information is stored.

Pareto’s Website is not intended for children under 16 years of age. No one under the age of 16 may provide any personal information on or through the Website. Pareto does not knowingly collect personal information from children under 16. If you are under the age of 16, do not use this Website (including any of this Website’s interactive features) or provide any information on this Website or through any of its features. If Pareto learns that it has collected or received personal information from a child under 16 without verification of parental consent, Pareto will delete that information. If you believe that Pareto might have received any information through the Website from or about a child under the age of 16, please contact Pareto at the contact information listed below.

It is Pareto’s policy to post any changes to this privacy policy on this Website. If Pareto makes material changes to how it treats the Website users’ personal information, it will notify you through a notice on the Website home page and/or by email at the email address that you provide to Pareto through this Website. The date when the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring that Pareto has an up-to-date active and deliverable email address for you, and for periodically visiting Pareto’s Website and this privacy policy to check for any changes.

If you have any questions or comment about this privacy policy, please contact Pareto by any method listed below:

This Privacy Policy for California Residents (the “California Privacy Policy”), adopted by Pareto Captive Services, LLC, Pareto Health, LLC, and Pareto Underwriting Partners, LLC, together with their respective subsidiaries (collectively, “Pareto”), supplements the information contained in general website privacy policy (the “General Privacy Policy”), which governs Pareto’s collection, use, and disclosure of the information that Pareto may collect from or about visitors to Pareto’s website paretohealth.com (the “Website”). This California Privacy Policy applies solely to the individuals who reside in the State of California (“consumers” or “you”). Pareto adopts this California Privacy Policy to comply with the California Consumer Privacy Act of 2018 (CCPA), and any terms defined in the CCPA have the same meaning when used in this California Privacy Policy.

This California Privacy Policy does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals. See for Pareto’s CCPA Notice of Collection for California Employees and Applicants.

Where noted in this California Privacy Policy, the CCPA temporarily exempts personal information reflecting a written or verbal business-to-business communication (“B2B personal information”) from some of its requirements.

Pareto collects certain information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information specifically excluded from the CCPA’s scope, including health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA), clinical trial data, or other qualifying research data.

In particular, the chart below describes different categories and types of information that CCPA defines as personal information and sets forth whether Pareto collects such personal information:

Pareto obtains the categories of personal information listed above from the following categories of sources:

• Directly from you when you provide it through the Website. For example, Pareto obtains such personal information as name, address, email address, telephone number, and your current employer from the forms that you complete on the Website.
• When you provide certain personal information about yourself and/or your employer to Pareto through the Website, such as your name, address, email address, name and address of your employer, Pareto, through third-party service providers, may search for and collect other personal information that may be publicly available online, such as your geographical location, any personal information listed above that you may post on social media, and other personal information that may be publicly available elsewhere online.
• Indirectly from you when you navigate the Website. For example, Pareto obtains information about your IP address, type of computer equipment you use, your geographic location, browsing history, interests and preferences when you access and interact with the Website.
• From Pareto’s clients. For example, if your employer is a client of Pareto, your employer may provide Pareto with your personal information as part of its business relationship with Pareto.

Pareto may use any category of personal information described above for one or more of the following purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about Pareto’s products or services, Pareto will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, Pareto will use that information to process your payment and facilitate delivery. Pareto may also save your information to facilitate new product orders or process returns.
• To contact you in the future regarding Pareto’s other products or services.
• To provide, support, personalize, and develop Pareto’s Website, products, and services.
• To create, maintain, customize, and secure your account with Pareto.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To carry out Pareto’s obligations and enforce Pareto’s rights arising from any contracts entered into between you/your organization and Pareto, including for billing and collection.
• To provide services to your employer if your employer is a client of Pareto.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To notify you about changes to the Website or any products or services that Pareto offers or provides though it.
• To personalize your Website experience and to deliver content and product and service offerings relevant to your interests.
• To allow you to participate in the interactive features on the Website, such as the chatbot feature.
• To help maintain the safety, security, and integrity of the Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve the Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Pareto about the Website users is among the assets transferred.

Pareto will not collect additional categories of personal information or use the personal information that was collected for materially different, unrelated, or incompatible purposes without providing you with a notice of such change.

Pareto may share your personal information by disclosing it to a third party for a business purpose. Pareto only makes these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing under the applicable contract. In the preceding twelve (12) months, Pareto has disclosed personal information for business purpose to the categories of third parties set forth in the chart below.

Pareto does not sell personal information.

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that Pareto disclose certain information to you about its collection and use of your personal information over the past 12 months (the “right to know”). Once Pareto receives your request and confirms your identity, Pareto will disclose to you:

• The categories of personal information Pareto collected about you.
• The categories of sources from whom Pareto collected personal information about you.
• Pareto’s business or commercial purpose for collecting or sharing that personal information.
• The categories of third parties with whom Pareto shares that personal information.
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
• The specific pieces of personal information we collected about you (also called a data portability request).

Pareto does not provide a right to know or data portability disclosure for B2B personal information.

Right to Delete

You have the right to request that Pareto delete any of your personal information that Pareto collected and retained, subject to certain exceptions (the “right to delete”). Once Pareto receives your request and confirms your identity, Pareto will review your request to see if an exception allowing Pareto to retain the information applies. Pareto may deny your deletion request if retaining the information is necessary for Pareto or its service provider(s) to:

1. Complete the transaction for which Pareto collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of Pareto’s ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform Pareto’s contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with Pareto.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Pareto will delete or deidentify personal information not subject to one of these exceptions from its records and will direct Pareto’s service providers to take similar action.

Pareto does not provide these deletion rights for B2B personal information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information.

You may only submit a request to know twice within a 12-month period. Your request to know or delete must:

• Provide sufficient information that allows Pareto to reasonably verify that you are the person about whom Pareto collected personal information or an authorized representative of such person, which may include, depending on the type and sensitivity of the personal information in question:
  • Answers to questions about personal information provided to Pareto that only the person to whom the personal information pertains would know.
  • A response from you to a verification email sent by Pareto.
  • A signed declaration under penalty of perjury stating that the personal information requested is about the requestor.
  • If you are attempting to exercise your rights to know or delete though an authorized representative, documentation (e.g., a valid power of attorney) that the representative is authorized to make the request on your behalf.
• Describe your request with sufficient detail that allows Pareto to properly understand, evaluate, and respond to it.

Pareto cannot respond to your request or provide you with personal information if it is unable to verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with Pareto to submit a request to know or delete.

Pareto will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

Pareto will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact Pareto at the contact information listed below.

Pareto endeavors to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If Pareto requires more time (up to another 45 days), Pareto will inform you of the reason and extension period in writing.

The written response to your request will be delivered by mail or electronically, at your option.

Any disclosures that Pareto provides will only cover the 12-month period preceding Pareto’s receipt of your request. The response that Pareto provides will also explain the reasons that it cannot comply with a request, if applicable. For data portability requests, Pareto will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Pareto does not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If Pareto determines that the request warrants a fee, Pareto will let you know the reason for such decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

Pareto does not currently sell personal information. If Pareto starts selling personal information in the future, it will update this California Privacy Policy to provide you with the option to direct Pareto not to sell your personal information (or, for consumers under the age of 16, an option to authorize Pareto to sell their personal information).

Pareto does not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Pareto will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, Pareto may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive that may be offered by Pareto will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.

Pareto reserves the right to amend this California Privacy Policy at its sole discretion and at any time. When Pareto makes changes to this California Privacy Policy, it will post the updated notice on the Website and update the California Privacy Policy’s effective date. Your continued use of Pareto’s Website following the posting of changes constitutes your acceptance of such changes.

If you have any questions or comments about this California Privacy Policy, the ways in which Pareto collects and uses your information described herein and in the General Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact Pareto at:

If you need to access this Policy in an alternative format due to having a disability, please contact Pareto by any method listed above.