Privacy Policy

Pareto Captive Services, LLC, ParetoHealth, LLC, and Pareto Underwriting Partners, LLC, together with their respective subsidiaries (collectively, “Pareto”), respects your privacy and is committed to protecting it though its compliance with this policy. This policy describes the types of information that Pareto may collect from you or that you may provide to Pareto when you visit the website paretohealth.com (this “Website”) and Pareto’s practices with respect to collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to the information Pareto collects or receives on or through this Website. It does not apply to information collected or received by Pareto through any other means, including offline, through direct communications between you and Pareto, from third parties, or through any other website operated by Pareto or any other third party.

Please read this policy carefully to understand Pareto’s policies and practices regarding your information and how Pareto will treat it. If you do not agree with Pareto’s policies and practices set forth in this policy, your choice is to not use the Website. By accessing or using the Website, you agree to this privacy policy. This policy may change from time to time, which changes, when made, will be posted on the Website. Your continued use of the Website after Pareto makes changes to the policy is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Pareto collects several types of information from and about users of the Website, including information:

• By which you and/or your employer, company, or organization may be identified, such as your name, postal address, email address, telephone number, employment history, as well as the name, postal address, email address, and telephone number of your current or past employer, company, or organization, or any information about you or your employer, company, or organization that you voluntarily provide through the Website’s interactive chatbot features (“personal information”).
• Additional information about you and your employer that may be publicly available online, including information on any social media website where you or your employer maintain an account.
• About your internet connection, the equipment you use to access the Website, usage details and browsing history across other websites.

Pareto collects this information:

• Directly from you when you provide it through the Website.
• From third-party service providers retained by Pareto to gather additional information about the Website users and their employers that may be publicly available online, based on the information you provide to Pareto through the Website.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

The information Pareto collects on or through the Website directly from you may include:

• Information that you provide by filling out forms on the Website. This includes information that you provide at the time you request information about Pareto’s products or services.
• Information that you provide when you submit an employment application through the Website.
• Any information that you provide through the Website’s interactive chatbot feature.
• Your search queries on the Website.
• Records and copies of your correspondence (including email addresses) if you contact Pareto through the Website.

Your submission of any of the aforementioned information through the Website is completely optional. If you do not wish to provide your personal information to Pareto, you should not complete any of the online forms or applications, utilize the Website’s chatbot feature, perform any search queries on the Website, or contact Pareto through the Website.

When you provide certain 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 information about you and your employer that may be publicly available online, such as your and your employer’s geographical location, social media profile information, your role with your employer, nature of your employer’s business, your employer’s size, revenue, and market cap, identity of your employer’s parent company, and other similar information that may be available online. This information helps Pareto better understand your employer’s business and your role with your employer and communicate with you about Pareto’s products and services more effectively.

As you navigate and interact with the Website, Pareto may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

Pareto may also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Similarly, third parties may also be able to collect information about your online activities over time and across different websites when you visit and navigate Pareto’s Website. At present time, Pareto does not have a mechanism to respond and does not respond to any “do-not-track” browser settings or similar mechanisms that you may utilize to restrict or limit behavioral tracking.

The information that Pareto collects automatically is only statistical data and does not include personal information, but Pareto may maintain it or associate it with personal information that Pareto collects in other ways through the Website. It helps Pareto to improve the Website and to deliver a better and more personalized service, including by enabling Pareto to:

• Estimate Pareto’s audience size and usage patterns.
• Store information about your preferences, allowing Pareto to customize the Website according to your individual interests.
• Speed up your searches.
• Recognize you when you return to the Website.

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts or features of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, Pareto’s system will issue cookies when you direct your browser to the Website.
• Web Beacons. Pages of the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Pareto, for example, to count users who have visited those pages and for other related Website statistics (for example, recording the popularity of certain Website content and verifying system and server integrity).

Pareto may use the information provided by you or collected by Pareto on or through the Website, including personal information:

• 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 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 evaluate your candidacy for employment with Pareto and/or contact you regarding potential employment opportunities with Pareto.
• To help maintain the safety, security, and integrity of the Website, products and services, databases and other technology assets, and Pareto’s 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.
• 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.
• In any other way Pareto may describe when you provide the information.
• For any other purpose with your consent.

Pareto may disclose aggregated information about the Website users, and information that does not identify any individual, without restriction.

Pareto does not sell personal information to third parties.

Pareto may disclose personal information that Pareto collects from or about you, or you provide to Pareto, on or through the Website pursuant to this policy:

• To contractors, service providers, vendors, and other third parties that Pareto utilizes to support its business, including any contractor, vendor, or service provider utilized by Pareto to store your personal information.
• To a buyer or other successor of Pareto in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Pareto’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Pareto about its Website users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by Pareto when you provide the information.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce Pareto’s rights arising from any contracts entered into between you/your organization and Pareto, including for billing and collection.
• If Pareto believes disclosure is necessary or appropriate to protect the rights, property, or safety of Pareto, its customers, or other third parties.
• With your consent.

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, visit California Privacy Policy 2021

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: