Insurance Trust for Delta Retirees Privacy Notice
Effective Date: 10/11/23
This Privacy Notice describes how Insurance Trust for Delta Retirees (“”ITDR,” “our,” “we”) collects, uses, and shares personal information via our website at https://www.itdr.com/, and our other sites and online services that post this Notice (our “Site”). ITDR exists to support the provision of supplemental health insurance to eligible Delta retirees. We use the information visitors to our Site provide for a variety of purposes set forth below. Below, we also describe choices we offer with respect to your information. This Privacy Notice does not apply to information that cannot be identified to any individual, household, or their devices, such as de-identified or anonymized information.
This Privacy Notice does not apply to third parties, including those that may be linked from or support advertising accessible from or through our Site. We are not responsible for other third parties’ privacy practices or communications. You should contact these parties directly to understand their practices.
|Information We Collect |
How We Use Information We Collect
How We Secure Information
How We Share Information
|What Choices Do I Have? |
Updates to Our Privacy Notice
Information We Collect
We collect information from a variety of sources, including:
- Directly from you when you provide it to us.
- Automatically as you utilize the Site.
- From third parties, including advertising analytics providers.
Information you provide. If you are a user of our Site, we may collect information from you such as when you contact us or fill out forms on our Site. If you are an active or prospective participant, you may also choose to share information with our third party administrator.
Information we collect through automatic data collection technologies. We may collect data regarding your use of our Site through cookies, web beacons, and other automatically collected information. This data may include your IP address, date and time you access our Site and the pages and content you access during your visit, websites that you link to or from, whether you receive or open an email or other communication from us, and the links you click on within those emails. We may also collect information from your mobile device or your computer about how you interact with our Site, including the date of the visit, the time of arrival and length of visit to the Site, the type of device used and the operating system on that device, browser type, a list of files downloaded or pages viewed, your IP address, and any errors encountered. This information helps us address customer support issues, provide you with a personalized experience, prevent fraudulent use of our services, and manage the Site we provide, including gathering aggregated data about engagement.
Other parties may collect personally identifiable information about your online activities over time and across third-party websites when you use our Site, such as analytics and marketing services (including NextRoll) that help us understand our services. We do not control any personal information once collected by these parties. We do not respond to “do not track” signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services. However, we provide a cookie management tool that permits you to set cookie and tracking preferences. Please note that these preferences may be limited to the device or computer you used to access our Site when setting such preferences. You can use our cookie manager here.
Information we collect from third party sources. We may collect information about active or prospective participants, including name, date of birth, email address, phone number, mailing address, and expected or actual date of retirement. We may collect information from advertisers, affiliates, promotional partners, and application providers. These and other third parties provide us information in connection with content, widgets, components, or other tools we offer. These third parties may collect information from these source when you use our websites. The information third parties collect may be associated with your personal information or they may collect information about your online activities over time. They and we may use this information to provide you with interest-based advertising or other targeted content, and for other purposes (such as to better understand our Site’s audience).
How We Use Information We Collect
We may use data we collect to operate our business and for a variety of purposes, including the following:
- To provide our services, or enable others to provide health insurance benefits to eligible Delta retirees.
- To maintain, analyze, customize, and improve your experience on our Site.
- To manage your account with us.
- To permit our advertising vendors to measure and analyze traffic and browsing activity on our Site.
- To communicate with you and provide you information that you request from us, including direct marketing to you.
- To provide customer and technical support.
- To monitor and enforce our contracts, legal terms, acceptable use or other policies or similar terms.
- To comply with law and satisfy our regulatory and compliance obligations. Additionally, to support compliance efforts on behalf of others and ourselves that support our provision of services to you.
- To detect and prevent fraud and other prohibited, illicit or illegal activity, and to protect the rights and vital interests of you, others, and ourselves.
- To address existing or anticipated disputes.
- To otherwise operate our business, including support for transactions impacting our company as a whole (such as mergers, acquisitions, or asset purchases).
- To fulfill any other purpose for which you provide your information to us.
- For other purposes permitted by law, described to you when you provide your information or to which you consent.
As permitted by law, we may combine the information we gather about you in identifiable form, including information from third parties. We may use this information, for example, to improve and personalize our services, content and advertising.
How We Secure Information
We are committed to maintaining measures to protect the security of your information. Of course, despite these measures, no network or system is ever entirely secure and we cannot guarantee the security of networks and systems that we operate or that are operated on our behalf.
How We Share Information
We may share your information with third parties as reasonable to operate our business, to provide the Site to you and others, as permitted or required by law, or as directed or authorized by you. For example:
Affiliated Companies. We may share some or all of your information with our affiliates, subsidiaries, joint ventures, or other companies under common control with us.
Third Party Sharing. We work with third party parties to help us provide our Site and to support operations. They may use your information subject to their own privacy policies and to comply with their own legal and regulatory obligations. We work with different types of third parties, presently including:
- Data hosting service providers;
- Third party administrators, including Mercer;
- Security service providers;
- Analytics providers; and
- Marketing and promotions providers.
Professional Advisors, Law Enforcement and Regulators. We share your information with our professional advisors who provide legal, compliance, auditing, accounting, banking, consulting, or similar services, and with regulators, law enforcement, or government agencies to:
- comply with our legal and regulatory obligations, including those compliance obligations of federal, state or local regulators;
- protect our interests, property or legal rights, or those of our customers or third parties;
- respond to a subpoena, court order, or similar law enforcement request, or when we believe in good faith that the disclosure of personal information is necessary to prevent physical harm or financial loss, to report suspected illegal activity, or to investigate violations of this Privacy Notice or other applicable terms; and
- for other legal purposes, such as to enforce our terms and conditions, or to exercise or defend legal claims.
Other Disclosures. In addition to the above disclosures, we may disclose personal information in the event that we believe such disclosure is (i) necessary to provide our services or operate our business; (ii) in accordance with purposes we describe when you share it with us; (iii) permitted by law; or (iv) with your consent or at your direction.
If you are a visitor on our Site, we may share your information with advertisers and other promotional partners.
What Choices Do I Have?
Update personal information. If you are a user with an account, your account is being managed on a website hosted by Mercer, our third-party administrator. You may log in to your account to access and update your information. Your information may also be subject to their privacy notices and policies.
As permitted by law, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement, cause the information to be incorrect, or prevent the provision of our Site.
Marketing communications. You may receive marketing communications from ITDR, including our newsletters and e-blasts. You may opt out of receiving marketing emails by following the unsubscribe link in each email. Please note that you may continue to receive non-marketing emails from us after you opt-out.
Your information is being used for our own marketing purposes. Our advertising Partner, NextRoll, Inc., performs a hash of your email address in order to serve targeted advertising to other devices connected to you (via cross-device tracking). For more information, please see NextRoll’s Privacy Notice. If you are a website visitor from California, please see the California Residents section of NextRoll’s Service Privacy Notice.
Cookies. You have a number of choices regarding certain cookies. Most web browsers automatically accept cookies, but you may modify your browser’s setting to notify you of cookie placement or decline cookies. If you choose to decline cookies, certain features of our website may not function properly or at all as a result. We also provide a cookie management tool that permits you to set cookie and tracking preferences. Please note that these preferences may be limited to the device or computer you used to access our Site when setting such preferences. You can use our cookie manager here.
You may decline to have your personal data collected via third party tracking technologies by navigating to the settings feature in your browser and declining all third party cookies or declining third party cookies from specific sites. If you are visiting our Site from your mobile device, you can limit ad tracking or reset the advertiser identifier through the privacy settings on your mobile device.
Opting-Out. Our partners, such as NextRoll, may use non-cookie technologies that may not be impacted by browser settings that block cookies. Your browser may not permit you to block such technologies. You can use the following third party tools to decline the collection and use of information for the purpose of serving you certain interest based advertising:
- The Network Advertising Initiative’s opt-out platform
- The European Interactive Digital Advertising Alliance’s opt-out platform
- The Digital Advertising Alliance’s opt-out platform
Updates to Our Privacy Notice
We may update this Privacy Notice from time to time in order to provide clarification or notice of changes to our practices. If we make changes, we will revise the Effective Date at the top of this Privacy Notice. Changes to this Privacy Notice will be effective once they are posted unless otherwise indicated. We may choose to notify you by email to the email address in our records.
If you have any questions or concern about this privacy notice or the privacy practices at ITDR, please contact us by email at email@example.com.