Leeway Privacy Policy

OVERVIEW

This Privacy Policy describes how Leeway, Inc., a Delaware corporation, and its subsidiaries and affiliates (collectively, "Leeway"), including Leeway Insurance Services LLC, collect, use, disclose, and otherwise process personal information in connection with Leeway's websites, platform, applications, and related products and services (collectively, the "Services"). In this Privacy Policy, "you" means any individual who accesses or uses the Services or whose personal information Leeway processes in connection with the Services, as applicable.

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By accessing or using the Services, you acknowledge the practices described in this Privacy Policy.

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This Privacy Policy is incorporated by reference into Leeway's Terms of Service. Certain information processed through the Services may also be subject to agreements between Leeway and its customers, business associates, or other parties. To the extent applicable, Leeway will process such information in accordance with those agreements and applicable law.

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INFORMATION WE COLLECT

Leeway may collect personal information directly from you, from employers, plan sponsors, benefit advisors, brokers, general agencies, insurance carriers, service providers, and other authorized third parties, and automatically through your use of the Services.

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Depending on how you interact with the Services, this information may include:

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  • name, address, email address, telephone number, date of birth, and other identifying information;
  • employment and benefits eligibility information;
  • information about spouses, dependents, and other household members;
  • health insurance enrollment, plan, premium, and coverage information;
  • financial, payment, and transaction information;
  • insurance producer, broker, agency, and licensing information;
  • communications and information you provide to Leeway;
  • account credentials and authentication information;
  • device, browser, IP address, log, usage, and other technical information; and
  • other information necessary to provide, administer, secure, or support the Services.

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Some information processed through the Services may constitute protected health information ("PHI") under the Health Insurance Portability and Accountability Act ("HIPAA") or other sensitive information protected by applicable law.

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INFORMATION FROM EMPLOYERS AND AUTHORIZED REPRESENTATIVES

In connection with benefits administration, enrollment, and related Services, Leeway may receive personal information from employers, plan sponsors, benefit advisors, brokers, general agencies, administrators, and other authorized representatives.

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These parties may provide information or take actions on behalf of individuals where authorized to do so.

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HOW WE USE INFORMATION

Leeway may use personal information to:

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  • provide, administer, operate, maintain, and support the Services;
  • establish and manage accounts;
  • determine eligibility and facilitate benefits enrollment and administration;
  • facilitate insurance applications, enrollment, premium payments, reimbursements, and related transactions;
  • communicate with users, customers, benefit advisors, insurance carriers, and other parties involved in providing the Services;
  • authenticate users and protect the security and integrity of the Services;
  • prevent fraud, misuse, and unauthorized access;
  • troubleshoot, analyze, maintain, develop, and improve the Services;
  • comply with legal, regulatory, contractual, and reporting obligations;
  • enforce Leeway's agreements and protect Leeway's rights and interests; and
  • otherwise process information as permitted by applicable law or with your authorization.

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Where Leeway processes information on behalf of a customer, Leeway may also process that information in accordance with the customer's instructions and applicable agreements.

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HOW WE DISCLOSE INFORMATION

Leeway may disclose personal information as reasonably necessary to provide and administer the Services, including to:

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  • employers and plan sponsors;
  • benefit advisors, brokers, general agencies, and other authorized representatives;
  • insurance carriers and insurance-related service providers;
  • financial institutions, payment processors, custodians, and banking partners;
  • technology, hosting, communications, security, analytics, and other service providers;
  • professional advisors, auditors, and consultants;
  • government agencies, regulators, courts, law enforcement, or other parties when required or permitted by law; and
  • other parties at your direction or with your authorization.

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Leeway may also disclose information in connection with an actual or proposed merger, acquisition, financing, reorganization, sale of assets, or similar business transaction.

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Leeway does not disclose PHI except as permitted by HIPAA, applicable Business Associate Agreements, and other applicable law.

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AGGREGATED AND DE-IDENTIFIED INFORMATION

Leeway may create, use, retain, and disclose aggregated or de-identified information for lawful business purposes, including operating, analyzing, improving, and developing the Services, provided such information is handled in accordance with applicable law.

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COOKIES AND SIMILAR TECHNOLOGIES

Leeway and its service providers may use cookies and similar technologies to operate the Services, remember preferences, understand usage, improve performance, and protect the security of the Services.

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You may be able to manage certain cookie settings through your browser or other controls made available by Leeway.

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THIRD-PARTY SERVICES

The Services may integrate with or provide access to services operated by third parties. Third-party services may collect or process information in accordance with their own privacy policies and terms.

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MARKETING COMMUNICATIONS

You may opt out of promotional emails from Leeway by using the unsubscribe link included in those communications.

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Opting out of marketing communications will not prevent Leeway from sending service-related, transactional, legal, or other non-promotional communications.

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DATA RETENTION

Leeway retains personal information for as long as reasonably necessary for the purposes for which it was collected or processed, including to provide the Services, comply with legal and regulatory obligations, satisfy contractual requirements, resolve disputes, enforce agreements, and maintain appropriate business and compliance records.

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A request to delete personal information does not require Leeway to delete information that Leeway is required or permitted to retain under applicable law or an applicable agreement.

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SECURITY

Leeway maintains administrative, technical, and physical safeguards designed to protect personal information against unauthorized access, use, alteration, or disclosure.

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No method of transmission or electronic storage is completely secure, and Leeway cannot guarantee absolute security.

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INDIVIDUAL PRIVACY REQUESTS

Depending on applicable law and the nature of Leeway's relationship with you, you may have rights regarding your personal information, including rights to request access, correction, deletion, or a copy of certain personal information.

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To submit a privacy request, contact Leeway at legal@leewayhq.com.

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Leeway may verify your identity before processing a request. Leeway may deny or limit a request where permitted or required by applicable law.

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If Leeway processes your personal information on behalf of your employer, plan sponsor, or another customer, Leeway may direct your request to that organization or process the request in accordance with its instructions.

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STATE PRIVACY RIGHTS

Residents of certain U.S. states may have additional rights under applicable privacy laws, which may include rights to access, correct, delete, or obtain a copy of certain personal information, or to opt out of certain uses or disclosures.

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These rights are subject to applicable legal thresholds, exceptions, and limitations. Requests may be submitted to legal@leewayhq.com.

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HIPAA AND HEALTH INFORMATION

When Leeway receives or maintains PHI as a business associate under HIPAA, Leeway processes that information in accordance with HIPAA and the applicable Business Associate Agreement.

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Certain requests concerning PHI may need to be submitted to the applicable health plan, employer, plan sponsor, or other covered entity rather than directly to Leeway.

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Nothing in this Privacy Policy is intended to limit or replace rights or obligations established under HIPAA or an applicable Business Associate Agreement.

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CHILDREN

The Services are not directed to children for their independent use. Information concerning minors may be processed when provided by a parent, legal guardian, employer, plan sponsor, or other authorized person in connection with benefits administration or other Services.

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CHANGES TO THIS PRIVACY POLICY

Leeway may update this Privacy Policy from time to time. The current version will be identified by its effective date and version number.

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Where required by applicable law, Leeway will provide additional notice of material changes.

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CONTACT US

Questions, concerns, or requests concerning this Privacy Policy or Leeway's privacy practices may be directed to:

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Leeway, Inc.
Email: legal@leewayhq.com

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