Privacy Policy

Website Privacy Policy Last Modified March 2021

Introduction

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.

Information That Pareto Collects and How Pareto Collects It

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.

Information You Provide to Pareto

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.

Information Pareto Collects Through Third-Party Service Providers

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.

Information Pareto Collects Through Automatic Data Collection Technologies

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).

How Pareto Uses Your Information

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.

Disclosure of Your Information

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.

Your 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, visit California Privacy Policy 2021

Data Security

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.

Children Under the Age of 16

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.

Changes to Pareto’s Privacy Policy

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.

Contact Information

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

Email:

Mailing address:

Pareto Health, LLC
Attn: Marketing
2929 Walnut Street, Suite 1500
Philadelphia, PA 19104

Phone number:

1-800-317-9876

Privacy Policy for California Residents

Introduction

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.

Information That Pareto Collects and How Pareto Collects It

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:

Category Examples Collected by Pareto?
A. Identifiers. A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. Pareto collects names, aliases, online identifiers, postal addresses, Internet Protocol addresses, and email addresses.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

Pareto collects names, physical characteristics, addresses, telephone numbers, education information, employment information, employment history, and health insurance information.
C. Protected classification characteristics under California or federal law. Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). Pareto does not collect personal information listed in this category.
D. Commercial Information. Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Pareto collects information regarding the products or services purchased and the consumers’ purchasing or consuming histories or tendencies.
E. Biometric information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. Pareto does not collect personal information listed in this category.
F. Internet and other similar network activity. Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Pareto collects information about consumers’ browsing history, search history, and information about consumers’ interactions with Pareto’s Website.
G. Geolocation data. Physical location or movements. Pareto collects geographical locations of consumers.
H. Sensory data. Audio, electronic, visual, thermal, olfactory, or similar information. Pareto does not collect personal information listed in this category.
I. Professional or employment-related information. Current or past job history or performance evaluations. Pareto collects information about consumers’ current employers, employment positions, and job history.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. Pareto does not collect personal information listed in this category.
K. Inferences drawn from other personal information. Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. Pareto collects information about consumers’ interests and preferences.

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’s Use of Personal Information

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.

Sharing Personal Information

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.

Personal Information Category Category of Third-Party Recipients
A. Identifiers. Cloud storage service providers.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Cloud storage service providers.
C. Protected classification characteristics under California or federal law. None. Pareto does not collect this category of personal information.
D. Commercial Information. None.
E. Biometric information. None. Pareto does not collect this category of personal information.
F. Internet and other similar network activity. None.
G. Geolocation data. None.
H. Sensory data. None. Pareto does not collect this category of personal information.
I. Professional or employment-related information. Cloud storage service providers.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). None. Pareto does not collect this category of personal information.
K. Inferences drawn from other personal information. None.

Your Rights and Choices

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:

Email:

Mailing address:

Pareto Health, LLC
Attn: Marketing
2929 Walnut Street, Suite 1500
Philadelphia, PA 19104

Phone number:

1-800-317-9876

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).

Non-Discrimination

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.

Changes to Pareto's California Privacy Policy

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.

Contact Information

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:

Email:

Mailing address:

Pareto Health, LLC
Attn: Marketing
2929 Walnut Street, Suite 1500
Philadelphia, PA 19104

Phone number:

1-800-317-9876

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

California Employment Applicant Notice of Collection

CCPA Notice of Collection for California Employees and Applicants

Pareto Captive Services, Pareto Health, LLC, and Pareto Underwriting Partners, LLC, together with their respective subsidiaries (collectively, “Pareto”), collects and uses personal information submitted by employment applicants through Pareto’s website paretohealth.com (the “Website”) for human resources, employment, benefit administration, health and safety, and business-related purposes and to be in legal compliance. Below are the categories of personal information that Pareto may collect from employment applicants and the purposes for which Pareto intends to use this information:

  • Identifying information, such as your full name, gender, date of birth, and signature.
  • Demographic data, such as race, ethnic origin, marital status, disability, and veteran or military status.
  • Contact information, such as your home address, telephone numbers, email addresses, and emergency contact information.
  • Dependent’s or other individual’s information, such as their full name, address, date of birth, and Social Security numbers (SSN).
  • National identifiers, such as SSN, passport and visa information, and immigration status and documentation.
  • Educational and professional background, such as your work history, academic and professional qualifications, educational records, references, and interview notes.
  • Employment details, such as your job title, position, hire dates, compensation, performance and disciplinary records, and vacation and sick leave records.
  • Financial information, such as banking details, tax information, payroll information, and withholdings.
  • Health and safety information, such as health conditions (if relevant to your employment), job restrictions, workplace illness and injury information, and health insurance policy information.
  • Information systems information, such as your search history, browsing history, login information, and IP addresses on Pareto’s information systems and networks.
  • Geolocation data, such as time and physical location related to use of an internet website, application, device, or physical access to Pareto’s office location.
  • Sensory or surveillance information, such as COVID-19 related temperature checks and call monitoring and video surveillance.
  • Profile or summary about an applicant’s/employee’s preferences, characteristics, attitudes, intelligence, abilities, and aptitudes.

Pareto collects personal information in the context of your employment applications, subsequent employment-related communications with Pareto, and/or subsequent employment with Pareto to use or disclose as appropriate to:

  • Comply with all applicable laws and regulations.
  • Recruit and evaluate job applicants and candidates for employment.
  • Conduct background checks.
  • Manage your employment relationship with Pareto, including for:
    • onboarding process;
    • timekeeping, payroll, and expense report administration;
    • employee benefits administration;
    • employee training and development requirements;
    • creation, maintenance, and security of your online employee accounts;
    • reaching your emergency contacts when needed, such as when you are not reachable or are injured or ill;
    • workers’ compensation claims management;
    • employee job performance, including goals and performance reviews, promotions, discipline, and termination; and
    • other human resources purposes.
  • Manage and monitor employee access to Pareto’s facilities, equipment, and systems.
  • Conduct internal audits and workplace investigations.
  • Investigate and enforce compliance with and potential breaches of Pareto’s policies and procedures.
  • Engage in corporate transactions requiring review of employee records, such as for evaluating potential mergers and acquisitions of Pareto.
  • Maintain commercial insurance policies and coverages, including for workers’ compensation and other liability insurance.
  • Perform workforce analytics, data analytics, and benchmarking.
  • Administer and maintain Pareto’s operations, including for safety purposes.
  • For client marketing purposes.
  • Exercise or defend the legal rights of the Pareto and its employees, customers, contractors, and agents.

If you have any questions about this notice or need to access this notice in an alternative format due to having a disability, please contact Pareto by any method listed below:

Email:

Mailing address:

Pareto Health, LLC
Attn: Marketing
2929 Walnut Street, Suite 1500
Philadelphia, PA 19104

Phone number:

1-800-317-9876