Privacy Statement and Cookie Policy

Privacy Statement and Cookie Policy

Last updated: 6.16.2020

Benefit Allocation Systems, LLC (“BAS," "us," or "we") is fully committed to protecting your privacy.  We want you to understand how we collect, use, and disclose information relating to you, your computer, or your device that enables your identification ("Personal Information"). This Privacy Statement and Cookie Policy is designed to answer your important questions about privacy and describes BAS practices with information that we (or our service providers) collect from a user (sometimes referred to as "you" or "your") through our website (the "Site"). This Privacy Statement and Cookie Policy addresses information collected directly through or from our Site – it does not address or govern any information gathering, use, or dissemination practices related to information collected from you other than directly through or from the Site, such as from telephone, facsimile, postal mail, personal delivery, our other webportals, offline means or media.

By using the Site, you agree and consent to this Privacy Statement and Cookie Policy.

If you have questions about this Privacy Statement and Cookie Policy, contact us at:

Benefit Allocation Systems, LLC
c/o General Counsel
PO Box 62407
King of Prussia, PA 19406
Email: security@basusa.com
Phone: 800-945-5513

1. Collection of Personal Information From Users

When you interact with us through the Site, we may collect information from you as described below.

a. Information you Provide

We collect the Personal Information that you knowingly choose to submit through the Site in order to benefit from specified features or to participate in certain activities, such as information that you provide when you contact us through the "Contact Us" portion of the Site or when you sign up for an email newsletter. For example, if you register for a BAS newsletter, you may provide us with information such as your name, telephone number, and email address. If you apply for a job with BAS, you may submit your resume or other information through the Site.

We may combine information you submit through the Site with other information we have collected from you, whether on-line or off-line. We treat the combined information in accordance with this Privacy Statement and Cookie Policy.

b. Location Information

Any comment system on the Site may utilize an opt-in Geolocation service in accordance with a prevailing community standard such as HTML 5. Such Geolocation opt-in ability is managed by the user’s browser settings. If a user chooses to opt-in to the Geolocation service, the user's comments may be associated with the user's location, both internally within BAS and publicly on the Site.

c. Passive Information Collection, Cookies, Use, and Choices

As you navigate the Site, certain Personal Information may be passively collected, meaning it is gathered without you actively providing it. This is done using the following techniques in the following ways:

  • IP Addresses: An IP address is a unique identifier that certain electronic devices use to identify and communicate with each other on the Internet. When you visit our Site, we may view the IP address of the device you use to connect to the Internet. We use this information to determine the general physical location of the device and understand from what geographic regions our website visitors come. We may use this information to enhance our Site.
  • Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.
  • Social Media Widgets: Our Site may include social media tools, including social media widgets or plug-ins, to connect you to your social media accounts. These features may set a cookie or use other automatic collection and tracking technologies to collect information about you and your use of the social media features through and in connection with our Site. These social media tools may be hosted by a third party. Your interactions with these tools and the corresponding social media platforms are governed by the privacy policies of the companies that provide such platforms.
  • Cookies: Like many companies, our Site may use "cookies" to help make sure the Site is meeting the needs of its users and to help us make improvements. Cookies are bits of text that are placed on your computer's hard drive when you visit certain websites. We may use cookies to tell us, for example, whether you have visited us before or if you are a new visitor. We use third-party cookies set by our service providers to collect information about how visitors use the Site, including how long you spend on each page, and how you got to the Site. We do not use data collected by cookies to identify who you are. We do not allow our service providers to use or share our analytics data. Specifically, our website hosting provider, Hubspot, uses the following cookies if you use the Site:

Essential/Necessary Cookies

__hs_opt_out

  • This cookie is used to remember not to ask the visitor to accept cookies again.
  • This cookie is set when visitors are given the choice to opt out of cookies.
  • It contains the string "yes" or "no".
  • It expires in 13 months.

 

__hs_do_not_track

  • This cookie is set to prevent the tracking code from sending any information to HubSpot.
  • This cookie allows anonymized information to be sent to HubSpot.
  • It contains the string "yes".
  • It expires in 13 months.

 

__hs_initial_opt_in

  • This cookie is used to prevent the banner from always displaying when visitors are browsing in strict mode.
  • It contains the string "yes" or "no".
  • It expires in seven days.

 

hs-messages-is-open

  • This cookie is used to determine and save whether the chat widget is open for future visits.
  • This cookie is set in the visitor's browser when they start a new chat and resets to re-close the widget after 30 minutes of inactivity.
  • It contains a boolean value of Trueif present.
  • It expires in 30 minutes.

 

hs-messages-hide-welcome-message

  • This cookie is used to prevent the chat widget welcome message from appearing again for one day after it is dismissed.
  • It contains a boolean value of Trueor False.
  • It expires in one day. 

 

__cfduid

  • This cookie is set by HubSpot’s CDN provider, Cloudflare. It helps Cloudflare detect malicious visitors to the website and minimizes blocking legitimate users.
  • It may be placed on a visitor’s device to identify individual clients behind a shared IP address and apply security settings on a per-client basis. It is necessary for supporting Cloudflare's security features.
  • It is a session cookie that lasts a maximum of 30 days.

 

__cfruid

This cookie is set by HubSpot’s CDN provider because of their rate limiting policies. It expires at the end of the session.

Consent Banner Cookies 

__hstc

  • This is te main cookie for tracking visitors.
  • It contains the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session).
  • It expires in 13 months.

 

hubspotutk

  • This cookie keeps track of a visitor's identity. It is passed to HubSpot on form submission and used when deduplicating contacts.
  • It contains an opaque GUID to represent the current visitor.
  • It expires in 13 months.

 

__hssc

  • This cookie keeps track of sessions.
  • This is used to determine if HubSpot should increment the session number and timestamps in the __hstc cookie.
  • It contains the domain, viewCount (increments each pageView in a session), and session start timestamp.
  • It expires in 30 minutes.

 

__hssrc

  • Whenever HubSpot changes the session cookie, this cookie is set to determine if the visitor has restarted their browser.
  • If this cookie does not exist when HubSpot manages cookies, it is considered a new session.
  • It contains the value "1" when present.
  • It expires at the end of the session.

Chat Cookies 

messagesUtk

  • This cookie is used to recognize visitors who chat via the chatflows tool. If the visitor leaves the site before they're added as a contact, they will have this cookie associated with their browser.
  • If a chat visitor later returns to the site in the same cookied browser, the chatflows tool will load their conversation history.
  • It contains an opaque GUID to represent the current chat user.
  • It expires in 13 months.

You can refuse our use of some or all cookies by turning off the use of cookies in your web browser. You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. If you use your browser settings to block all types of cookies you may not be able to access all or parts of our Site or functionality may be limited.

Changing your Internet browser settings can prevent the use of cookies. Each browser has a different procedure for disabling the use of cookies. The Help function within your browser should tell you how to perform the function for your particularly browser. You can also visit http://www.aboutcookies.org where you can review information on how to control cookies, delete cookies and get other general information about cookies.

We do not track your behavior across third party websites. Our Site currently does not respond to "Do Not Track" (DNT) signals and we operate as described in this Privacy Statement whether or not a DNT signal is received, as there is no consistent industry standard for compliance.

d. Sensitive Information

We ask that you not send or otherwise disclose to us through the Site your racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background, or trade union membership. Where you provide us with such information, we reserve the right to erase any such information at our discretion.

e. Information About Minors

The Site is not intended for persons under the age of 18. We do not knowingly collect Personal Information online from persons in this age group. We reserve the right to delete any information identified as having been provided by such persons at our discretion.

2. How We Use the Information We Collect

We use Personal Information submitted by you or otherwise collected through the Site and through other sources for the purposes described in this Privacy Statement and as otherwise described to you at the point of collection. Generally, we use the information you provide to us for the reason for which it was provided. For example, if you sign up to receive email notifications, we will contact you by email. If you provide us with information to register for whitepaper, we will use the information to provide the whitepaper. Specifically, we may use Personal Information from or about you:

  1. to respond to your inquiries and fulfill your requests, such as to send you alerts for which you have subscribed;
  2. to send you important information regarding our relationship with you or regarding the Site, changes to our terms, conditions, and policies, and other administrative information;
  3. to notify you about products or services that may be of interest to you;
  4. to promote our services;
  5. to provide support and to respond to your request and inquiries;
  6. to personalize your visit to the Site and assist you when you use the Site;
  7. to protect the security and integrity of the Site and correct technical problems; and
  8. for our business purposes, such as data analysis, audits, recordkeeping, developing new products or services, enhancing the Site, improving our services, identifying Site usage trends, personalizing your experience on the Site, and determining the effectiveness of our campaigns.

We may use any information that does not personally identify you, your computer, or your device, for any purpose.

3. Our Disclosure of Your Information

BAS does not sell your Personal Information. We may share your Personal Information with third parties only as described in this Privacy Statement or as otherwise described at the point where we collect the information from you, including:

  1. to the companies or individuals that we hire to provide services to us, such as website hosting services;
  2. to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings).

4. Uses and Disclosures to Comply with Laws

In addition, we use and disclose Personal Information collected through the Site as we believe to be necessary or appropriate: (i) under applicable law, including laws outside your country of residence; (ii) to comply with legal process; (iii) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iv) to enforce our terms and conditions; (v) to protect our operations or those of any of our affiliates; (vi) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (vii) to allow us to pursue available remedies or limit the damages that we may sustain.

5. Links to Third Party Sites

The Site may contain links to other websites for the convenience of users in locating information, products, or services that may be of interest. If you access a third party website from a link on this Site, any information you disclose on that website is not subject to this Privacy Statement. It is possible that these links may be used by third parties or others to collect personal or other information about you. BAS is not responsible for the privacy practices of such websites, advertisers, or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites. BAS does not control these third parties' use of cookies, collection of information, or how they manage such information. It is solely your obligation to review and understand the privacy practices and policies of these other websites, advertisers and any third parties.

6. Where Your Information is Processed

BAS is based in the United States. No matter where you are located, you consent to the processing and transfer of your Personal Information in and to the United States and other countries. The laws of the United States and other countries governing data protection may not be as comprehensive or as protective as the laws in the country where you live.

7. Security

BAS will take reasonable steps to protect the information collected and provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, you should understand that no transmission over the Internet is ever fully secure. BAS uses reasonable efforts to ensure that the Site is generally available. However, there will be occasions when access to the Site will be interrupted or unavailable. BAS will use reasonable efforts to minimize such disruption where it is within its reasonable control. You agree that BAS shall not be liable to you for any modification, suspension or discontinuance of the Site.

8. Data Retention

We generally retain Personal Information for so long as it may be relevant for the purposes identified in this Privacy Statement or at the time the information is collected, unless a longer period of time is required by law.

9. Lawful Bases for Processing Your Personal Information

The laws in some countries require us to tell you about the lawful grounds we rely on to collect, use, disclose, and otherwise process your Personal Information. To the extent those laws apply, our lawful bases for processing your Personal Information are:

  1. To comply with a legal obligation: We need to use and disclose Personal Information in certain ways to comply with our legal obligations.
  2. With your consent: Where permitted by law, we handle Personal Information on the basis of your implied or express consent.


10.
Your Data Rights and Choices

You can unsubscribe from certain emails by clicking on the "unsubscribe" link they contain. You can opt-out of the use of certain cookie-related processing by following the instructions above (Passive Information Collection, Cookies, Use, and Choices).

The laws in some countries may give you particular rights with respect to your Personal Information, including the right to access the Personal Information that we maintain, and the right to object to certain processing of Personal Information by BAS. If you would like to submit a data access, correction, restriction, or deletion request, or if you would like to object to certain processing, you can do so by contacting us by email at security@basusa.com and we will process such request with respect to any Personal Information that we are able to link to you individually based on the information that you can provide to us. These rights and options that you have with respect to Personal Information are subject to limitations and exceptions under applicable law. In addition to those rights, if you live in certain jurisdictions, you have the right to submit a complaint to your relevant supervisory authority. However, we encourage you to contact us first by emailing security@basusa.com and we will try to resolve your concerns.

11. California Privacy Rights

Under California Civil Code Section 1798.83 California residents may request certain information about our disclosure of personal data during the prior calendar year to third parties for their direct marketing purposes. We do not share your personal data with third parties or corporate affiliates for their direct marketing purposes.

Depending on the circumstances, California residents may also have other rights with respect to their personal data under the California Consumer Privacy Act.

12. Disclaimer

The information contained on our Site, including blog entries and news alerts, is for informational purposes only.  This site is not intended to be a substitute for professional legal, medical, financial, coverage or any other advice and should not be construed as such.  BAS in no way represents or warrants that this site provides any advice or assurances.

This site uses original photography as well as licensed stock photography for illustrative purposes; not all persons depicted are BAS employees.

THIS SITE AND THE DATA, SERVICES, PRODUCTS, INFORMATION AND OTHER MATERIALS ON, IN AND MADE AVAILABLE THROUGH THIS SITE ARE MADE AVAILABLE “AS IS” AND “WITH ALL FAULTS” AND AT YOUR OWN RISK.  BAS MAKES NO REPRESENTATIONS OR WARRANTIES, AND DISCLAIMS ALL REPRESENTATIONS AND WARRANTIES, WITH RESPECT TO THIS SITE INCLUDING, WITHOUT LIMITATION, THE IMPLIED WARRANTIES OF MERCHANTABILITY AND FITNESS FOR A PARTICULAR PURPOSE.

13. Right to Change Privacy Statement and Cookie Policy

BAS reserves the right at any time to modify, alter, or update this Privacy Statement and Cookie Policy. Your use of the Site following any changes means that you agree to follow and be bound by the Privacy Statement and Cookie Policy as changed, subject to limitations under applicable law. Any change to this Privacy Statement and Cookie Policy shall be effective as to any user who has visited the Site before the change was made. Please review this policy periodically, and especially before you provide any Personal Information to us. The Privacy Statement and Cookie Policy was last updated on the date indicated below.

If you have comments or questions about our privacy policy, please send them to this email address: compliance@BASusa.com.

You may also reach us at Benefit Allocation Systems, LLC, c/o General Counsel, PO Box 62407, King of Prussia, PA 19406.