Privacy Policy

Privacy of Personal Information


FinWell Group and its affiliates are committed to the responsible use of personal information collected from and about FreedomID members and others who provide such information to us and in compliance with both state and federal regulations concerning the use of personal information. Such personal information includes any number that may be used, alone or in conjunction with any other information, to identify a specific individual; or other personal information that could be used to cause financial reputational harm to an individual. This policy applies to the information that is collected by any means whether electronically, through our website, by telephone, or on paper.


We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such sale or transfer occur, we will use reasonable efforts to direct the transferee to use personal information you have provided by any means in a manner that is consistent with this Privacy Statement.


Limits on Use and Access


The responsible use of personal information requires that FinWell Group and its affiliates respect individual privacy, protect against identity theft and other unauthorized uses, and comply fully with all laws and government regulations in the collection, use, storage, display, distribution and disposal of such information. As such, we take reasonable and appropriate measures to keep personal information confidential in a secure environment, including taking appropriate actions in an event of unauthorized disclosure. Authorized uses of personal information within FinWell Group and its affiliates are limited to those which are a) necessary to meet legal and regulatory requirements; b) facilitate access to services, transactions, facilities and information; or c) support efficient administrative processes. We limit access to personal information to a) the individual whose information is produced or displayed; b) a FinWell employee, affiliate or agent of FinWell with authorized access based upon a legitimate interest and a need to know; c) an organization or person authorized by the individual to receive the information; d) a legally authorized government entity or representative, or other circumstances in which FinWell Group and its affiliates are legally compelled to provide access to personal information; or e) other individuals or entities, as allowed by law, for purposes judged to be appropriate or necessary for the reasonable conduct of FinWell business and FreedomID administration.


Social Security Numbers


State law protects the use of Social Security numbers. FinWell and its affiliates may continue to collect and maintain Social Security numbers in all instances in which that number is required by law for reporting or other uses such as operating purposes for which there is no reasonable substitute. Social Security numbers are always considered confidential, and therefore subject to the access restrictions described above. Furthermore, it is against both state law and FinWell policy to a) publically post or display the Social Security number in any manner; b) print the Social Security number on any card required to access services; c) require and individual to transmit his or her Social Security number over the Internet unless the connection is secure or the number is encrypted; d) require an individual to use his or her Social Security number to access an Internet site unless a unique password or PIN is also required, or e) print a Social Security number on any materials that are mailed unless required by a state or federal agency, unless state or federal law requires the Social Security number to be on the document to be mailed. Also, Social Security numbers may be included in the applications and forms sent by mail, including documents sent as part of an application or enrollment process, or to establish, amend or terminate an account, contract or policy, or to confirm the accuracy of the Social Security number.

Online Collection of Personal Information


We do not sell or otherwise disclose personal information about our website visitors, except as described here. We may share information provided by and collected from our visitors with a) service provider we have retained to perform services on our behalf; b) third party service providers whose services are requested by visitors as part of their FreedomID benefits.


Our website may contain links to other sites. Please be aware that FinWell Group and its affiliates are not responsible for the privacy practices of other such sites. We encourage our visitors to be aware when they leave the FreedomID or related sites and to read the privacy statements of other sites that collect personal identifiable information. This privacy statement applies solely to information collected by FinWell Group, its affiliates and related sites.

Privacy Policy Changes


Our privacy policy may change from time to time without notification. Plan members are therefore encouraged to check the privacy policy for any such changes as the posted policy will apply notwithstanding the terms and conditions contained in previous policies and promotional materials. Your continued use of the FreedomID websites signifies your consent to the collection, use, storage and disclosure of your personal information according to the most recent version of the Privacy Policy in effect. If you stop using the websites or membership is terminated, FinWell and its affiliates may continue to use and disclose your personal information in accordance with the Privacy Policy as amended from time to tim