Privacy Policy

Effective Date: January 1, 2020
Last modified: December 30, 2019
Last reviewed: December 30, 2019
ENROLLEASE INC. ("us," "we", or "Company") is committed to respecting the privacy rights of its customers, visitors, and other users of the ENROLLEASE website located at www.ease.com (the “Site”). We created this Privacy Policy (this “Policy”) to inform you how we gather and use and the circumstances under which we may disclose, information we may collect from you through the Site and/or in connection with the Service. This Privacy Notice supplements and is expressly made part of the information contained in the Terms of Service at https://ease.com/terms and applies to all visitors, users, and others (“consumers” or “you”). We adopt this Notice to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this Notice. We reserve the right, at any time, to change, update, or modify this Policy by posting such change, update, or modification on the Site and will only notify you of any material changes to the Policy. Any such change, update, or modification will be effective immediately upon posting on the Site. It is your responsibility to review this Policy from time to time to ensure that you continue to agree with all of its terms. This Policy is only applicable to sites belonging to this Site, and not to any other websites that you may be able to access from this Site, each of which may have data collection and use practices and policies that differ materially from this Policy.
1. INFORMATION THE COMPANY COLLECTS. In operating the Site, ENROLLEASE may request that you provide certain registration information and complete online benefit enrollment and other online forms that ask for your name, e-mail address, contact, and other personal information (“Personally Identifying Information”). Our Websites collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, our Websites have collected the following categories of personal information from its consumers within the last twelve (12) months:
Category
Collected
A. Identifiers. Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol Address, email address, Social Security number, driver’s license number, passport number, or similar identifiers.
YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, driver’s license, insurance policy number, employment, employment history, bank account number, medical information, or health information. Some Personal Information included in this category may overlap with other categories.
YES
C. Protected classification characteristics under California or federal law. Examples: Age (40 years or older), race, color, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation.
YES
D. Commercial information. Examples: Records of personal property, products or services purchased, obtained, or considered, or purchasing or consuming histories or tendencies.
NO
E. Biometric information. Examples: Genetic, physiological, behavioral, and biological characteristics, or activity pattern used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
NO
F. Internet or other similar network activity. Examples: Browsing history, search history, information on a consumer’s interaction with a website, application or advertisement.
NO
G. Geolocation data. Examples: Physical location or movements.
YES
H. Sensory data. Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
NO
I. Professional or employment-related information. Examples: Current or past job history or performance evaluations.
YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
NO
K. Inferences drawn from other personal information. Examples: Profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
NO
Personal information does not include:
  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA’s scope, like:
    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
Enrollease, Inc. obtains the categories of personal information listed above from the following categories of sources:
  • Directly from you. For example, from forms you complete or products and services you purchase.
  • Indirectly from you. For example, from your employer or insurance broker.
We may combine your Personal Information with Non-Identifying Information and aggregate it with information collected from other users or sources to attempt to provide you with a better experience, to improve the quality and value of our products and services, and to analyze and understand how our products and services are used. We may also use the combined information without aggregating it to serve you specifically.
2. COOKIES. From time to time we may use the standard cookies feature of major browser applications that allows us to store a small piece of data on your computer about your visit to our Site. We do not set any Personally Identifying Information in cookies, nor do we employ any data capture mechanisms on our Site other than cookies. Cookies help us learn which areas of our Site are useful and which areas need improvement. You can choose whether to accept cookies by changing the settings on your browser. However, if you choose to disable this functions, your experience at our Site may be diminished and some features may not work as they were intended.
3. USE AND SHARING OF INFORMATION. We will not share your Personally Identifying Information with any third party without your consent, except as necessary to provide you with the Services offered by us or to comply with the law or as set forth in this Policy.
We may use or disclose the personal information we collect for one or more of the following business purposes:
  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
  • To provide, support, personalize, and develop our Websites, products, and services.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.
  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
  • To personalize your Website experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).
  • To help maintain the safety, security, and integrity of our Websites, products and services, databases and other technology assets, and business.
  • For testing, research, analysis, and product development, including to develop and improve our Websites, products, and services.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Enrollease, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Enrollease, Inc. about our Website users is among the assets transferred.
Enrollease, Inc. will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Enrollease, Inc. may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
  • Service providers.
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, Enrollease has disclosed the following categories of personal information for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category G: Geolocation data.
We disclose your personal information for a business purpose to the following categories of third parties:
  • Service providers.
In the preceding twelve (12) months, Enrollease has not sold personal information.
4. SECURITY. We strive to protect your personal information and your privacy. The site has security measures in place to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration and we are not responsible for the theft, destruction, unauthorized access of information disclosed to third parties.
5. RIGHTS AND CHOICES. Consumers have specific rights regarding their personal information which are explained below.
Access to Specific Information and Data Portability Rights
You have the right to request that Enrollease, Inc. disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that Enrollease, Inc. delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
  • Calling us at +1 800-446-3273,
  • Emailing us at support@ease.com
  • Sending a letter to us at Enrollease, Inc., 1980 Festival Plaza Dr. Suite 810 Las Vegas, NV 89135
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
For instructions on exercising sale opt-out rights, see Personal Information Sales Opt-Out and Opt-In Rights below.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
6. AREAS BEYOND OUR CONTROL. The Site may include interactive forums such as message boards and chat rooms. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information. We are not responsible for conduct arising from the disclosure of your information publicly.
The Site may contain links to other websites. If you chose to visit other websites, we are not responsible for the privacy practices or content of those other websites, and it is your responsibility to review the privacy policies at those websites to confirm that you understand and agree with their policies. Our links to other websites or displays of any advertisements or third party content does not mean we endorse any other website’s privacy or information security practices.
7. CONTACT INFORMATION. If you have any questions about this Policy or our practices related to this Site please contact us at: privacy@ease.com or write to us at ENROLLEASE INC., 500 Treat Ave. Suite 200, San Francisco, CA 94110.