PlanSource Services Privacy Notice

Last Updated: October 9, 2026  

INTRODUCTION 

This Privacy Notice describes how PlanSource Holdings Inc. and its subsidiaries (“PlanSource”, “we”, “us”, “our”) collects, uses and discloses information about individuals who use our applications, portal, services, tools and features or otherwise interact with us as a user of our services (collectively, the “Services”). For the purposes of this Privacy Notice, “you” and “your” means you as the user of the Services, whether you are a customer or representative of a company with whom we do business, or another individual whose information we have collected pursuant to this Privacy Notice.  

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not agree to this Privacy Notice, please do not use or access the Services. 

If you are an employee accessing the Services pursuant to your employer’s employee benefits plan or payroll, please also note that this Privacy Notice does not apply to your employer’s collection or use of information. Please consult your employer if you have questions about their data collection and use practices. 

The English language version of this Privacy Notice shall control.  

1. CHANGES TO THIS PRIVACY NOTICE 

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice.  If we make material changes to the way in which we use or disclose information we collect, we will use reasonable efforts to notify you (such as by emailing you at the last email address you provided us, by posting notice of such changes on the Services, or by other means consistent with applicable law) and will take additional steps as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services. 

2. BENEFITS PLATFORM DATA COLLECTION AND USAGE 

When you use or access the Services, we collect certain information about you from a variety of sources that identifies you and/or your dependents and beneficiaries (“Personal Data”). 

Information You Provide to Us 

Some features of the Services may require you to directly provide us with certain information about yourself and/or your dependents and beneficiaries. You may elect not to provide this information, but doing so may prevent you from using or accessing these features. Information that you directly submit through our Services includes: 

• Basic identifiers, such as your full legal name, date of birth, postal address, phone number, personal email address, and work email address.  
• Professional and employment information, such as your professional / employer contact information (e.g., work email or phone number), job title, the organization you represent, and your organization’s details and location. 
• Account information, such as username and password. If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend that you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately. 
• Demographic information, such as your age, gender, race, ethnicity, and/or marital status. 
• Government identifiers, such as your Social Security number.  
• Health Information, such as your health history or your family health history, and other information to determine appropriate insurance coverage as needed to deliver the Services. 
• Health Care Election/Coverage Information, such as your previous and current benefits enrollment selections as needed to deliver the Services.  
• Any other information you choose to include in communications with us, for example, when sending a message through the Services or submitting information to us (e.g., through a contact or request form on the Services). 

All categories of personal information described above exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties, excluding aggregators and providers necessary to deliver the text messaging service. 

Information We Collect Automatically 

We also automatically collect certain information about your interactions with the Services (“Usage Data”).  To do this, we may use cookies or other tracking technologies used by Company such as, for example, cookies, pixels, web beacons/clear gif, and other tracking technologies. (“Tracking Technologies”). Usage Data includes: 

• Device information, such as device type, operating system, device ID numbers and unique device identifier, media access control (MAC) address, and internet protocol (IP) address.  
• Location information, such as imprecise geolocation (based on IP address). 
• Other information regarding your interaction with the Services, such as operating system, browser type, log data, date and time stamps, device screen resolution, the pages you access on the Services, the websites you access before and after visiting the Services, the length of time you spend on the Services, clickstream data, and ad impressions. 

For more information on how we use Tracking Technologies and your choices, see the section below, Cookies and Other Tracking Technologies. 

Information Collected from Other Sources 

We may obtain information about you from outside sources, including information that we collect directly from third parties and information that you choose to share with us. Such information includes: 

• Your Employer. Information, such as your hire date, that we receive from your employer. 
• Analytics Data. Information such as aggregate information about your interactions with the Services that we receive from analytics providers. 
• Health Information. Collected via claims information at your present and past health carriers when you use the Services.  

Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third Party Websites and Links. 

Finally, we may deidentify information about you such that it cannot reasonably be used to infer information about you or otherwise be linked to you (or we may collect information that has already been identified), and we may use such deidentified information for any purpose.  To the extent we possess or process any deidentified information, we will maintain and use such information, we will maintain and use such information in deidentified form and not attempt to re-identify the information, except solely for the purpose of determining whether our deidentification process satisfies legal requirements. 

Chatbot Functionality  

In the use of the Services, you may interact with certain chatbot functionality. A “chatbot” or “bot” is a computer application that attempts to simulate human conversation, in order to allow people to interact with digital devices as if they were communicating with a real person. The data from the chats is retained for as long as the data is needed. Chat outputs are monitored and tested by humans for continuing accuracy. Chatbot functionality may be provided by a third party, and, therefore, such third party may have access to information about you based upon the information you disclose and/or your interaction with the chatbot. Although we have implemented technical safeguards to prevent your Personal Information from reaching third party chatbot providers, we suggest that you do not submit Personal Information or other sensitive information into these chatbots. 

3. USES OF INFORMATION

With respect to the categories of information we collect, we use information about you as described below: 

How we may use your Personal Information	The Reasons
Services Administration and Purpose Collected; Communication with You	For the purpose for which you disclosed and we collected information about you, for example, to process and communicate with you in connection with your use of the Services, to process your requests for information, to display requested content, our business activities, to provide user support to users of the Services.
Provision of Benefits	We use information we collected about you for the purpose of processing and managing employee benefits, employee payroll, and business-to-business transactions.
Personalization; Advertising; Analytics	To tailor the content and information that we may send or display to you, to suggest personalized help and instructions, and to personalize your experience while visiting or using our Services; sharing it with our third party service providers to understand how our Services are used and to improve the Services; so we and our third party service providers to target advertisements for goods and services and to display those advertisements on other websites. For more information, please see the Cookies and Other Tracking Technologies section below.
Marketing Communications	To send you marketing communications about our business, products, Services, and other programs that may be of interest to you. In order to provide you with a personalized experience, these communications may be tailored to your preferences based on, for example, inferences we make using your visits to the Services or the links you click on in our emails. Please note that pixel tags, cookies and other online trackers may be used within emails to track your interactions with those websites and when emails are opened. You may opt out of receiving marketing communications from us at any time by following the unsubscribe instructions contained in the applicable email. Specifically with regard to text messaging, if you opt in to receiving text messages (SMS and MMS) on the Services when prompted, we may send you autodialed and other text messages at the telephone number you provide relating to your use of the Services. Consenting to receiving text messages is not required to buy goods or Services or to do business with us. Message and data rates may apply. Note that, even if you opt out of receiving promotional communications from us, you may still receive administrative communications from us with respect to your use of the Services.
Evaluation and Improvement	To analyze, develop, and improve the content, materials, products, and the Services; to inform marketing and communication plans; to understand user demographics and preferences; to analyze the effectiveness of the Services; and to evaluate user experiences (e.g., analyzing which features and portions of the Services are most popular; for troubleshooting, for statistical purposes).
Quality Assurance	To perform quality assurance; to assist with fraud identification, and to assist our customer relationship representatives (for example, through representatives in our call center), we use tools to monitor and record certain user experience information, including, without limitation, audio of customer service calls and information resulting from such calls.
With Your Consent	With your consent, we may use and share information about you in ways not specifically described in this Privacy Notice.

COOKIES AND OTHER TRACKING TECHNOLOGIES 

Cookies are an example of the automatic data collection technology that we use. A cookie is a text file placed on the browser to automatically store your preferences. The limited information that may be collected using cookies includes your browser type, the date and time of your visit, the pages you visit, and the amount of time spent on each device.  

Information collected using cookies is anonymous and used for analytical purposes only. 

Analytics Tools & Providers  

As noted above, the Services uses third-party analytics tools to collect and process data about your use of the Services. Our analytics providers may set and read cookies to collect this data, and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Services’ structure and content. 

4. DISCLOSURE OF INFORMATION 

We may disclose information about you to third parties for legitimate purposes subject to this Privacy Notice, including the following categories of third parties: 

• Affiliates: Our affiliates, subsidiaries, or others within our corporate group. 
• Service Providers: Vendors or other service providers who help us provide the Services, including for system administration, cloud storage, security, website hosting, mailing, customer relationship management, marketing communications, web analytics, payment networks, and payment processing. 
• Carriers & Point Solution Partners: Insurance carriers and providers for the purpose of sharing your coverage selections to fulfill the Services.  
• Your Employer: Your company platform Administrators or Human Resources or equivalent team.  
• At Your Direction: Third parties to whom you request or direct us to disclose information, such as through your login integration. 
• Advisors: Professional advisors, such as auditors, law firms, or accounting firms.  
• Bankruptcy and Other Business Transactions: Third parties in connection with or anticipation of an asset sale, merger, or other business transaction, including in the context of a bankruptcy.  

We may also disclose information about you as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users. 

5. THIRD PARTY WEBSITES, LINKS, AND EMBEDDED CONTENT 

We may provide links to third party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies, and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third party social networking platforms, may also be viewable by other users of the Services and/or users of those third party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owner or operators. 

The Services may also incorporate features, add-ons, portals, and content including feeds, scripts embedded in the Services’ code, and visible content (e.g., videos), provided by third parties. In some cases, those third parties collect data about how you interact with their content.  

6. CHILDREN’S PRIVACY 

The Services are designed for and directed to adults. Children under the age of 13 are not permitted to use the Services, and we do not seek or knowingly collect any personal information about children under 13 years of age. If we are notified that we have unknowingly collected personal information of a minor under the age of 13, except in connection with such minor being a dependent in connection with a benefit program to which you have enrolled them in or they are required to be enrolled in, we will promptly make commercially reasonable efforts to delete such information. If you submit personal information relating to a minor, you are consenting to allow us to process that information for purposes of administering the Services.  

Parents or guardians of children under 13 years of age who have provided us with their personal information may contact us using the information below to request that such information be deleted. Such requests will be subject to authenticating the parental/guardian identity and status. If you believe we might have any information from or about a child under 13 that was not obtained voluntarily from the child’s parent or legal guardian in connection with the administration of our Services, please contact us at compliance@plansource.com. 

7. DATA SECURITY AND RETENTION 

Despite our reasonable efforts to protect information about you, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information. 

Information you provide to us should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up to date. We retain information about you for as long as it is reasonably necessary for the purposes specified in this Privacy Notice and in accordance with our internal policies and procedures (including, without limitation, backup and archival processes).  

8. CALIFORNIA RESIDENTS 

This section applies to you only if you are a California resident (“resident” or “residents”). For purposes of this section, references to “personal information” shall include “sensitive personal information,” as these terms are defined under the California Consumer Privacy Act (“CCPA”).  

Processing of Personal Information 

In the preceding 12 months, we (i) collected the following categories of personal information about residents for the following purposes, and (ii) (where indicated below) disclosed for a business or commercial purpose (as identified below) to third parties the following categories of personal information: 

Category	Categories of Purposes (defined in the Use of Information section above)	Categories of Recipients (defined in the Disclosure of Information section above)
Identifiers such as name, telephone number, e-mail address, IP address	Services Administration and Purpose Collected; Communication with You Provision of Benefits Personalization; Advertising; Analytics Marketing Communications Evaluation and Improvement Quality Assurance Lawful Processes; Protection of Company	Affiliates Service Providers Marketing Providers At Your Direction Advisors Bankruptcy and Other Business Transactions
Characteristics of protected classifications under California or federal law such as race, national origin or ancestry, sex (including gender, pregnancy, sexual orientation, and gender identity), age, physical or mental disability, and veteran status.	Services Administration and Purpose Collected; Communication with You Provision of Benefits	Affiliates  Your Employer Carriers & Point Solution Partners
Sensitive personal information such as:  Government identifiers such as drivers license numbers and social security numbers;  Account access credentials such as account log-in and password; Sensitive demographic information such as race or ethnicity; Precise geolocation data	Services Administration and Purpose Collected; Communication with You Provision of Benefits Lawful Processes; protection of Company	Affiliates  Your Employer Carriers & Point Solution Partners
Commercial information such as records of products or services requested or that you requested information on	Services Administration and Purpose Collected; Communication with You Provision of Benefits Personalization; Advertising; Analytics Marketing Communications Evaluation and Improvement Quality Assurance Lawful Processes; Protection of Company	Affiliates Service Providers Marketing Providers At Your Direction Advisors Bankruptcy and Other Business Transactions
Internet or other similar network activity such as Usage Data (as defined above)
Approximate geolocation data, such as IP address
Visual information, such as photographs, you optionally elect to upload to the platform
Professional or employment-related information such as title of profession, employer, professional background

We only use and disclose sensitive personal information for the purposes specified in the CCPA. We do not sell or share sensitive personal information with third parties for cross-contextual behavioral advertising.  

The criteria we use to determine how long to retain personal information about you is described in the section above, Data Security and Retention. 

No Selling and/or Sharing of Personal Information 

We do not “sell” or “share” (as those terms are defined under the CCPA and used throughout this section) personal information with respect to the Services.  

9. YOUR PRIVACY RIGHTS

Certain jurisdictions (for example, California) provide their residents certain rights and options with respect to their personal information. Depending on your residence, location, and laws applicable to our processing of your personal information, you may have the ability to exercise the rights listed below. Subject to foregoing and all application limitations, exemptions, or exceptions these rights you may have the right to: 

• Right to Know: Know (1) the categories of personal information collected, disclosed, sold and/or shared; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collecting, selling, and/or sharing personal information; (4) the categories of third parties with whom we disclosed, sold, and/or shared personal information; and (5) the specific pieces of personal information we have collected about you.  
• Right to Data Portability: Access and receive the specific personal information we process about you in a structured, commonly used and machine-readable format, and to transmit it to another entity where this is technically feasible. 
• Right to Delete: Delete personal information about you. 
• Right to Correct: Correct personal information about you. 
• Right to No Discrimination: Not be discriminated against due to your exercise of the rights provided under applicable California law that are applicable to our processing of your personal information. 
• Right to Lodge a Complaint: To lodge a complaint with a government regulator (e.g., your state attorney general) or supervisory authority, in the jurisdiction that you reside in, if you consider that the collection or use of personal information about you violates this Privacy Notice or applicable law. 

We do not use personal information about you in furtherance of automated profiling decisions that produce a legal or similarly significant effect.  

To exercise these rights, please see the Exercise Your Rights section below.  

10. EXERCISE YOUR RIGHTS

As noted above, you may have certain rights, or applicable law grants you certain rights as it relates to the Services and information we collect about. You may submit a request to us by:  

• Visiting: https://info.plansource.com/privacy-policy 
• Emailing: compliance@plansource.com 

For clarity, to exercise your right to opt-out of targeted advertising, or the “selling” or “sharing” of personal information about you, you must follow the instructions provided under the Right to Opt Out of Selling and/or Sharing of Personal Information section above. 

To verify certain requests—for example, requests to know, delete, or correct—we may need to collect additional information to verify your identity and the request, such as your email address or phone number, before providing a substantive response to the request.   

You may also authorize an agent to make requests on your behalf to exercise your rights. If you have a registered agent to act on your behalf, we have the right to authenticate such agent’s authority to act. 

11. HOW TO CONTACT US 

Should you have any questions about our privacy practices or this Privacy Notice, please email us at compliance@plansource.com or contact us at 122 W. Pine Street, Suite 203, ATTN: Legal & Compliance, Orlando, FL 32801. 

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