1. Introduction
Welcome to Purl Pal ("we," "us," "our"). We provide a conversational AI-powered platform ("Services") designed to assist licensed health insurance agents and agencies ("Agents") in simplifying the Medicare and ACA enrollment process for their clients ("Consumers").
This Privacy Policy explains how we collect, use, disclose, and safeguard information when you, as an Agent, use our website and Services. It also outlines our role and responsibilities concerning any information, including Protected Health Information (PHI), that may be processed through our platform on your behalf.
Please read this policy carefully. By using our Services, you agree to the collection and use of information in accordance with this policy.
2. Information We Collect
We collect information in two primary ways: information you provide to us directly as an Agent, and information processed by our AI on behalf of your Consumers.
A. Information We Collect from Agents
When you register for and use Purl Pal Services, we collect personal information about you, including:
- Account Information: Your name, email address, phone number, agency name, and payment information.
- Communication Data: Any information you provide when you contact us for support or other inquiries.
- Usage Data: Information about how you interact with our website and Services, such as IP address, browser type, and pages visited.
B. Information We Process on Behalf of Agents (Consumer Data)
Our AI is designed to have conversations with your Consumers to guide them through the enrollment process. In this capacity, we act as a "Business Associate" under HIPAA. The Agent is the "Covered Entity" responsible for this data. The information we process on your behalf may include:
- Personally Identifiable Information (PII): Name, date of birth, address, phone number, etc.
- Protected Health Information (PHI): Information related to a Consumer's health status, eligibility for Medicare/ACA, plan selections, and other data necessary for the enrollment process.
We process this Consumer data solely at your direction and for the purpose of providing the Services as outlined in our Business Associate Agreement (BAA) with you.
3. How We Use Your Information
A. Use of Agent Information
We use the information we collect from you as an Agent to:
- Provide, maintain, and improve our Services.
- Process your subscription payments.
- Communicate with you about your account, including updates and support.
- Market our products and services to you (you may opt out at any time).
- Comply with legal obligations and enforce our terms.
B. Use of Consumer Information
We use the Consumer information we process on your behalf strictly to:
- Provide the voice-guided, conversational AI enrollment service.
- Facilitate the completion of enrollment forms via your PURL.
- Transmit the collected information back to you, the Agent, through our secure platform.
We do not use Consumer PHI for our own marketing purposes or for any purpose not explicitly authorized by you in our BAA.
4. Data Sharing and Disclosure
We do not sell your personal information or the Consumer information we process. We may share information under the following limited circumstances:
- With Service Providers: We may share information with third-party vendors who perform services on our behalf, such as payment processing and data hosting. These vendors are contractually obligated to protect your data and are not permitted to use it for their own purposes.
- As Directed by You: We will share Consumer information with you, the Agent, as the core function of our Service.
- For Legal Reasons: We may disclose information if required by law, subpoena, or other legal process, or if we believe in good faith that disclosure is necessary to protect our rights, your safety, or the safety of others.
- Business Transfers: In the event of a merger, acquisition, or sale of all or a portion of our assets, your information may be transferred as part of that transaction.
5. Data Security
We implement and maintain robust administrative, physical, and technical safeguards to protect the security, confidentiality, and integrity of all information we handle. This includes:
- Encryption: Data is encrypted both in transit (using TLS) and at rest.
- Access Controls: Access to sensitive information, particularly PHI, is strictly limited to authorized personnel on a need-to-know basis.
- HIPAA Compliance: We maintain compliance with the applicable provisions of the HIPAA Security Rule and will enter into a Business Associate Agreement (BAA) with all Agent clients.
While we take extensive measures to secure your data, no security system is impenetrable. We cannot guarantee the absolute security of your information.
6. Your Data Rights and Choices
Depending on your location, you may have certain rights regarding your personal information.
- For Agents: You have the right to access, correct, or delete your account information. You can also opt out of marketing communications at any time by using the "unsubscribe" link in our emails.
- For Consumers: As we process your data on behalf of an Agent, any requests to exercise your data rights (such as access or deletion under CCPA/CPRA or HIPAA) should be directed to the insurance agent or agency that provided you with the Purl Pal service. We will assist our Agent clients in responding to these requests as required by law.
- California Residents (CCPA/CPRA): You have specific rights regarding your personal information. Please contact us at the email below for more information on how to exercise these rights.
7. Children's Privacy
Our Services are not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children.
8. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the "Last Updated" date. We encourage you to review this policy periodically.
9. Contact Us
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
Purl Pal
Email: [email protected]