Benefit & Risk Management Services Privacy Policy
                
                    This notice describes the privacy policy of Benefit and Risk Management Services (BRMS). This
                    Privacy Policy applies to BRMS users of family of websites located at www.vbas.com, www.MyHealthBenefits.com or any website or service maintained by BRMS that links to or refers to this Policy (collectively, the "Web Sites").
                    For existing BRMS customers, your access and use of the Web Sites are governed by the
                    terms and conditions of the agreements already entered into with BRMS, and are not subject to this
                    policy.
                
                
                    We carefully guard your confidential, individual-identifiable information (commonly referred to as
                    your personal information). Personal information includes information that identifies you, such as
                    your name, address, telephone number, email address, social security number and date of birth, wage
                    and job classification, and information related to your health coverage. BRMS obtains your personal
                    information through its administrative, clinical management, network services and various services
                    related to health plans, and insurance policies, and when you send information to us (through these
                    Web Sites or otherwise). We limit our collection and use of information to the minimum required to
                    deliver health benefits services.
                
                User Information Gathered by Our Web Sites
                
                    We gather these types of information through our Web Sites:
                    
                        - 
                            Information You Give Us: We receive and store any information you give us to respond to
                            your requests and to communicate with you. Such information will be deemed the minimum
                            necessary to provide the services contracted by your employer.
                        
 
                        - 
                            Automatic Information: We receive and store information whenever you interact with us.
                            For example, through "cookies," we obtain information when your Web browser accesses our
                            Web Sites. A "cookie" is a small amount of data that is stored on your computer for
                            record keeping purposes and aids in tracking your preferences, and navigation through our
                            Web Sites. The cookie does not extract personal information.
                        
 
                    
                
                Sharing Information
                
                    We only use the information gathered by our Web Sites, or provided by you on our Web Sites, for
                    health benefits services. This information is shared with other entities providing health benefit
                    services to you; however, we do work with business partners under non-disclosure agreements and
                    may share with them certain information to develop a relationship with them.
                    
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                            Affiliated Businesses We Do Not Control: We may provide certain de-identified visitor
                            information under non-disclosure agreements to our affiliated businesses and partners to assist
                            us in developing a relationship with you.
                        
 
                        - 
                            Compliance with the Law: We may release account and other personal information to comply
                            with law, or to protect the rights, property, or safety of BRMS, our users, or others. Such release
                            includes responding to subpoenas, compliance with court orders and legal requests.
                        
 
                    
                
                Personal Health Information
                
                    BRMS undertakes to comply with all health information privacy laws that apply to us. Information
                    about you may include Protected Health Information (PHI) as defined by the Health Insurance
                    Portability & Accountability Act of 1996 (HIPAA), and Title 45, Parts 160 through 164 of the Code
                    of Federal Regulations and other associated laws and regulations. Consistent with our respect for
                    you and your privacy, we will not use or share your PHI for purposes other than treatment, payment
                    or health care operations (including, but not limited to, quality assessment, fraud detection,
                    regulatory and mandatory legal activities), or for other purposes as allowed under HIPAA.
                
                Conditions of Use, Notices, and Revisions
                
                    If you choose to visit our Web Sites, your visit and any dispute over privacy is subject to this Policy.
                    Please send any concerns you may have about privacy on our Web Sites to the following email
                    address: info@brmsonline.com. BRMS will respond to your request and attempt to resolve any
                    matters that violate BRMS policies. Our business changes constantly. This Policy may change, and
                    use of information that we gather now is subject to the Privacy Policy in effect at the time of use.
                    We may send, via e-mail, periodic reminders of our notices, unless you have instructed us not to, but
                    please check our Web Sites frequently for recent changes.