PRIVACY|CIPA | CPRA

Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 1 of 14
ASSURANCE BENEFITS | ABC-INCORP.COM | LICENSED INSURANCE AGENCY — ARIZONA
Master Privacy &
Compliance Notice
Effective Date: July 1, 2025 | Last Revised: July 2026 | Version 3.0
Consolidates: Privacy Policy | CCPA/CPRA | GLB | CIPA | COPPA | TCPA | CAN-SPAM | Cookie Policy
Consumer Health Data (WA/NV) | Multi-State Rights | ADA Accessibility | Health Plan Transparency
Accessibility — Alternative Access
This notice is available in alternative accessible formats upon request.
Call 623-780-0077 or visit abc-incorp.com/contact-2 — we respond within 2 business days.
Screen reader compatible. WCAG 2.1 AA remediation in progress — target: September 30, 2026.
Important Related Documents — Published Separately
The following are published as separate pages on our website and are incorporated here by reference:
HIPAA Notice of Privacy Practices — required by 45 CFR §164.520, updated February 2026
Terms of Use — governs your use of this website and our services
Medicare Disclaimer — required by CMS 42 CFR §422.2268
CONTENTS OF THIS NOTICE
1. Who We Are and Scope of This Notice
2. Information We Collect
3.How We Use Your Information
4.Call Recording — Medicare Calls Only (CIPA §632)
5.Website Electronic Monitoring (CIPA §631)
6.California Consumer Privacy Act (CCPA / CPRA)
7.Multi-State Privacy Rights
8.Consumer Health Data Privacy (Washington & Nevada)
9.Gramm-Leach-Bliley Financial Privacy (GLB)
10.TCPA — Phone & Text Communications
11.CAN-SPAM — Email Communications
12.Cookie Policy
13.Health Plan Transparency (CAA 2021)
14.Children’s Online Privacy (COPPA)
abc-incorp.com | 623-780-0077 | Not affiliated with any government agency
Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 2 of 14
15.Arizona Insurance Privacy Rights
16.Data Security & Breach Notification
17.Data Retention
18.Web Accessibility Statement
19.Dispute Resolution & Arbitration
20.Contact — How to Exercise Your Rights

  1. Who We Are and Scope of This Notice
    Assurance Benefits Corp. (operating as abc-incorp.com) is a licensed insurance agency headquartered in Arizona. We specialize in individual and family health insurance, Medicare Advantage and Part D, Medicare Supplement, group and employer health benefits, and ancillary lines including dental, vision, life, and disability insurance.
    This Master Privacy & Compliance Notice applies to all visitors to abc-incorp.com, all persons who contact us by phone, email, text, or any other means, and all clients and prospective clients of Assurance Benefits. It describes how we collect, use, share, and protect your personal information, and explains your rights under applicable federal and state law.
    Controller vs. Processor
    Where we determine the purposes and means of processing your personal information, this Notice applies. Where we process data on behalf of insurance carriers or employer group health plan sponsors, those entities are the data controller and their privacy notices govern. We generally cannot respond to individual rights requests for data we process solely on a carrier’s or employer’s behalf — please contact that entity directly.
  2. Information We Collect
    A. You Provide Directly
    •Personal identifiers: Name, date of birth, address, phone, email, SSN (enrollment only)
    •Health information: Medical history, conditions, medications, tobacco use — for quotes or enrollment
    •Financial information: Income, household size, employment — ACA subsidy eligibility (26 U.S.C. §36B)
    •Dependent information: Names, DOBs, relationships of household members enrolled
    •Communication data: Records of inquiries, emails, and calls
    B. Collected Automatically from Website
    •IP address, browser type, device information
    •Pages visited, time on site, navigation path
    •ONE strictly necessary WordPress session cookie — verified by Cookiebot.com (see Section 12)
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    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 3 of 14
    C. From Third Parties
    •Insurance carriers with whom you authorize us as agent of record
    •Health insurance marketplaces (Healthcare.gov / HealthSherpa) with your consent
    •CMS Medicare beneficiary data with your written authorization
  3. How We Use Your Information
    Purpose
    Legal Basis
    Data Used
    Obtain insurance quotes on your behalf
    Contractual necessity / Consent
    Health, financial, identifiers
    Submit enrollment applications
    Contractual necessity
    All categories
    Communicate plan options and changes
    Legitimate interest / Consent
    Contact information
    Comply with HIPAA, ACA, GLB, state law
    Legal obligation
    All categories as required
    Improve website and service operations
    Legitimate interest
    Usage data, session cookie
    Marketing to you (with consent)
    Consent / CAN-SPAM
    Contact information
    Fraud detection and security
    Legitimate interest / Legal obligation
    All categories
    We do NOT sell your personal information to data brokers or third parties for their independent marketing use. We do NOT use solely automated decision-making that produces legal or significant effects without human review.
  4. Call Recording — Medicare Calls Only
    Authority: California Penal Code §§632, 632.5, 632.7; CMS 42 CFR §§422.2264, 423.2264
    Plain Language Summary
    Assurance Benefits does NOT routinely record telephone calls.
    ONLY Medicare Advantage (Part C) and Medicare Part D sales calls are recorded.
    This is required by federal law (42 CFR §422.2264 / §423.2264 — CMS mandate) —
    not a business choice. All other call types are NOT recorded.
    Call Type
    Recorded?
    CIPA §632 Consent Required?
    Medicare Advantage (Part C) sales
    YES — CMS federal mandate
    YES — verbal consent before recording begins
    Medicare Part D sales
    YES — CMS federal mandate
    YES — verbal consent before recording begins
    ACA / Marketplace plan calls
    NO
    NO
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    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 4 of 14
    Call Type Recorded? CIPA §632 Consent Required?
    Group / employer benefits
    NO
    NO
    Dental, vision, life, disability
    NO
    NO
    General service / inquiry calls
    NO
    NO
    Medicare Call Consent Process
    At the start of every Medicare sales call, our agent states the federal recording requirement and requests your verbal consent before recording begins. You may decline — the sale cannot be completed by phone without recording, but we will arrange an alternative method at no cost or inconvenience. Medicare call recordings are retained for 10 years minimum per CMS requirements.
    All-Party Consent — California and Multi-State
    California Penal Code §632 requires all-party consent before recording any call where any party is located in California. This requirement applies regardless of where Assurance Benefits is located (Arizona). The same or similar requirements apply in Florida, Illinois, Pennsylvania, Washington, Massachusetts, Maryland, Michigan, Nevada, Connecticut, Oregon, and Montana. Our Medicare call consent process satisfies all of these requirements simultaneously.
    Your Right to Opt Out of Recording
    For Medicare calls: inform the agent at the start of the call that you do not consent to recording. We will disable recording and arrange an alternative enrollment method. Declining recording will never affect your ability to receive services or coverage.
  5. Website Electronic Monitoring (CIPA §631)
    Authority: California Penal Code §631; §638.51 (pen register / trap and trace)
    Class Action Exposure — Why This Section Matters
    CIPA §631 has been extended by California courts to cover website interactions including
    session replay tools, chat widgets, embedded analytics, pixels, and keystroke logging,
    even when operated by third-party vendors. Civil damages: $5,000 per violation per person,
    no statutory cap. Key cases: Javier v. Assurance IQ (9th Cir. 2022).
    Current Status — Independently Verified July 2026
    abc-incorp.com uses ONE (1) strictly necessary WordPress session cookie.
    NO analytics scripts, NO session replay, NO advertising pixels, NO chat widgets.
    Verified by Cookiebot.com independent scan. Updated immediately upon any change.
    BY CONTINUING TO USE THIS WEBSITE AFTER READING THIS NOTICE, YOU EXPRESSLY CONSENT — under California Penal Code §631 — to the collection of session data, server logs, and the single WordPress session cookie described above. This consent is not a condition of purchasing any insurance product or service.
    abc-incorp.com | 623-780-0077 | Not affiliated with any government agency
    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 5 of 14
    Before Any New Tool Is Activated
    Before activating any non-necessary monitoring tool, we will: (1) update this Notice; (2) implement a cookie consent banner that blocks the tool until you consent; and (3) provide a functional opt-out. We will never load a third-party monitoring script without your prior active consent.
    Server Log Disclosure — §638.51
    Website server logs (IP address, timestamp, browser type, pages visited) may qualify as trap and trace data under §638.51. We disclose this in compliance with the ordinary-course-of-business notice exception. Server log data is retained up to 90 days then purged.
    Your Opt-Out Rights
    •
    Cookie consent banner: select Decline to block non-necessary tools before they load
    •
    Browser settings: block third-party cookies or use private/incognito mode
    •
    Digital Advertising Alliance: optout.aboutads.info
    •
    Network Advertising Initiative: optout.networkadvertising.org
    •
    Direct request: 623-780-0077 or abc-incorp.com/contact-2
  6. California Consumer Privacy Act (CCPA / CPRA)
    Authority: CCPA Cal. Civ. Code §1798.100 et seq.; CPRA eff. January 1, 2023; CalOPPA Cal. Bus. & Prof. Code §22575
    Categories of Personal Information We Collect
    •
    Identifiers: name, address, email, IP address, SSN
    •
    Personal information per Cal. Civ. Code §1798.80(e): financial, medical
    •
    Protected classification characteristics: age, sex, medical condition
    •
    Internet/network activity: browsing history on our site
    •
    Geolocation data: approximate location derived from IP address
    •
    Inferences to create a consumer profile: coverage needs assessment
    •
    Sensitive personal information: SSN, health data, financial accounts
    Your CCPA / CPRA Rights
    Right to Know (§1798.110)
    Request what personal information was collected, used, disclosed, or sold in the past 12 months.
    Right to Delete (§1798.105)
    Request deletion, subject to HIPAA, GLB, ACA, and regulatory retention exceptions.
    Right to Correct (CPRA)
    Request correction of inaccurate personal information we maintain about you.
    Right to Opt Out of Sale
    We do not sell personal information. Right honored upon any request received.
    Limit Sensitive Info Use
    Request we limit use of sensitive personal information to service-delivery purposes only.
    Opt Out of Profiling
    Request we not use automated decision-making for decisions with significant effects on you.
    Non-Discrimination (§1798.125)
    We will not deny services or charge different rates for exercising any CCPA right.
    Data Portability
    Request your personal information in a portable, machine-readable format.
    abc-incorp.com | 623-780-0077 | Not affiliated with any government agency
    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 6 of 14
    California Notice at Collection (CPRA §1798.100(a)(2))
    Notice at Collection — Required at Point of Every Web Form
    BEFORE OR AT THE TIME you submit a form on abc-incorp.com, we are required to disclose:
    CATEGORIES COLLECTED: identifiers, health information, financial information, contact data.
    PURPOSE: to obtain insurance quotes, process enrollments, and respond to your inquiry.
    SENSITIVE DATA: SSN and health data used only as necessary to provide requested services.
    DO NOT SELL: We do not sell your personal information.
    RETENTION: Per the schedule in Section 17 of this Notice.
    For full detail: see this complete Notice. CCPA rights requests: 623-780-0077.
    Submit CCPA requests: abc-incorp.com/contact-2 or 623-780-0077. Response: 45 days (extendable to 90 with notice). Two free requests per 12-month period. Authorized agents accepted with written permission from the consumer.
    Do Not Track (Cal. Bus. & Prof. Code §22575): Our website does not currently respond to browser DNT signals. We will update this disclosure if our practices change.
    CCPA Complaints: California Privacy Protection Agency — cppa.ca.gov
  7. Multi-State Privacy Rights
    Residents of the following states have additional privacy rights under their respective state laws. We honor all applicable rights and provide responses within each law’s required timeframe.
    State / Law
    Key Rights Granted
    Response Window
    Effective Date
    Virginia — VCDPA
    Know, Access, Delete, Correct, Opt Out of Sale/Profiling
    45 days (+45)
    Jan 1, 2023
    Colorado — CPA
    Know, Access, Delete, Correct, Portability, Opt Out
    45 days (+45)
    Jul 1, 2023
    Connecticut — CTDPA
    Know, Access, Delete, Correct, Portability, Opt Out
    45 days (+45)
    Jul 1, 2023
    Texas — TDPSA
    Know, Access, Delete, Correct, Portability, Opt Out
    45 days (+45)
    Jul 1, 2024
    Florida — FDBR
    Know, Access, Delete, Correct, Portability, Opt Out
    45 days (+45)
    Jul 1, 2024
    Oregon — OCPA
    Know, Access, Delete, Correct, Portability, Opt Out
    45 days (+45)
    Jul 1, 2024
    Montana — MCDPA
    Know, Access, Delete, Correct, Opt Out
    45 days (+45)
    Oct 1, 2024
    How to Appeal a Denied Request
    If we deny your request, reply to our denial communication to appeal. If the appeal is denied, contact your state Attorney General: Virginia: oag.state.va.us | Colorado: coag.gov |
    abc-incorp.com | 623-780-0077 | Not affiliated with any government agency
    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 7 of 14
    Connecticut: portal.ct.gov/AG | Texas: texasattorneygeneral.gov | Florida: myfloridalegal.com | Oregon: doj.state.or.us | Montana: doj.mt.gov
  8. Consumer Health Data Privacy (Washington & Nevada)
    Authority: Washington My Health My Data Act (RCW 70.372, eff. March 31, 2024); Nevada Health Data Privacy Act (SB 370 / NRS 603A)
    This section applies to Washington and Nevada residents. In the event of conflict between this section and the rest of this Notice, this section controls for consumer health data.
    What Is Consumer Health Data?
    Personal information linked or reasonably linkable to you that identifies your past, present, or future physical or mental health status — including health conditions, diagnoses, treatments, medications, procedures, reproductive health, gender-affirming care, and inferences about health derived from other data.
    What We Collect and Why
    •
    Health conditions, diagnoses, medical history — provided in insurance applications to obtain quotes
    •
    Prescription medication information — for health plan enrollment or underwriting
    •
    Information about health care services sought or received — as you provide it
    •
    Insurance claims data involving health conditions — received from carriers with your authorization
    What We Do NOT Do with Consumer Health Data
    •
    We do NOT sell consumer health data
    •
    We do NOT use it for targeted advertising
    •
    We do NOT share it with third parties for their own purposes
    Your Rights (WA and NV Residents)
    Right to Confirm
    Confirm whether we collect, share, or sell your consumer health data.
    Right to Access
    Access your consumer health data and a list of all third parties to whom we disclosed it.
    Right to Delete
    Request deletion, subject to HIPAA and GLB retention requirements.
    Right to Withdraw Consent
    Withdraw consent to collection, use, or disclosure. We stop upon receipt, subject to legal obligations.
    Non-Retaliation (WA)
    We will not discriminate against you or deny services for exercising these rights.
    Right to Appeal
    Appeal any denied request. If denied on appeal, contact WA or NV Attorney General.
    Submit requests: 623-780-0077 or abc-incorp.com/contact-2. Response within 45 days (extendable to 90). Identity verification required. Authorized agents accepted with written permission.
    Appeals: WA — atg.wa.gov/file-complaint | NV — ag.nv.gov/Contact/
    abc-incorp.com | 623-780-0077 | Not affiliated with any government agency
    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 8 of 14
  9. Gramm-Leach-Bliley Financial Privacy
    Authority: GLB Act 15 U.S.C. §6801 et seq.; FTC Safeguards Rule 16 CFR Part 314 (June 2023 update); A.R.S. §20-2301
    Sharing Type
    Do We Share?
    Can You Opt Out?
    Everyday business purposes (process transactions, maintain accounts)
    Yes
    No
    Our marketing to you
    Limited
    Yes — call 623-780-0077
    Joint marketing with other financial companies
    No
    N/A
    Affiliates for their own marketing
    No
    N/A
    Nonaffiliated third parties for their marketing
    No
    N/A
    We maintain a written Information Security Program per 16 CFR Part 314 covering risk assessment; administrative, technical, and physical safeguards; vendor oversight; incident response; and annual employee training. A qualified individual oversees our information security program.
  10. TCPA — Phone and Text Communications
    Authority: Telephone Consumer Protection Act 47 U.S.C. §227; FCC 23-107 (effective January 27, 2025 — one-to-one consent per company)
    Consent Not Required to Purchase Insurance
    We obtain PRIOR EXPRESS WRITTEN CONSENT before placing auto-dialed calls, pre-recorded
    calls, or marketing text messages to your mobile phone. The January 27, 2025 FCC rule
    requires consent to be given individually to each company — not through a lead generator.
    To revoke consent: 623-780-0077 or abc-incorp.com/contact-2. Honored within 10 business days.
    •
    We identify ourselves and the purpose on every outbound call
    •
    We maintain an internal Do Not Call list per 47 CFR §64.1200(d)
    •
    We honor the National Do Not Call Registry (FTC, donotcall.gov)
    •
    Text opt-out: reply STOP to any message | HELP for assistance | Message rates may apply
  11. CAN-SPAM — Email Communications
    Authority: CAN-SPAM Act 15 U.S.C. §7701 et seq.
    •
    All marketing emails include our physical address and a working unsubscribe link
    •
    Unsubscribe requests are processed within 10 business days
    •
    We do not use false or misleading subject lines or sender information
    •
    Transactional and regulatory notices (required HIPAA notices, plan confirmations) cannot be unsubscribed from
    •
    To opt out of marketing emails: click Unsubscribe in any email, or call 623-780-0077
    abc-incorp.com | 623-780-0077 | Not affiliated with any government agency
    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 9 of 14
  12. Cookie Policy
    Authority: CalOPPA Cal. Bus. & Prof. Code §22575; CCPA/CPRA; ePrivacy Directive (international visitors)
    Current Cookie Status
    Low Risk — Verified by Independent Scan
    abc-incorp.com currently uses ONE (1) strictly necessary WordPress session cookie.
    NO marketing cookies, NO analytics, NO session replay, NO advertising pixels are active.
    Independently verified by Cookiebot.com. Last scan: June 2026.
    Type
    Purpose
    Consent Required?
    Duration
    Status
    Strictly Necessary
    WordPress session; CSRF security token
    No — legally exempt
    Session only
    ACTIVE
    Analytics (if added)
    Usage measurement (e.g. Google Analytics)
    Yes — prior consent
    Up to 13 months
    NOT ACTIVE
    Marketing (if added)
    Advertising retargeting
    Yes — prior consent
    Up to 24 months
    NOT ACTIVE
    Before Any New Cookie or Script Is Activated
    We will update this Notice, implement a cookie consent banner (Complianz or equivalent) that blocks the script before it loads, and provide a functional opt-out. We will not activate any non-necessary script without your prior active consent.
    Managing Cookies
    •
    Chrome: Settings > Privacy and Security > Cookies
    •
    Firefox: Options > Privacy & Security > Cookies and Site Data
    •
    Safari: Preferences > Privacy > Manage Website Data
    •
    Edge: Settings > Cookies and Site Permissions
    •
    DAA opt-out: optout.aboutads.info | NAI opt-out: optout.networkadvertising.org
    Third-Party Cookies
    External links (HealthSherpa, medicareforaz.com, carrier portals) use their own cookies governed by their own policies. We do not control cookies set by third-party sites.
  13. Health Plan Transparency (Employer Clients)
    Authority: Consolidated Appropriations Act 2021 (CAA 2021); Transparency in Coverage Rule 45 CFR §§147.210-212; No Surprises Act; MHPAEA (29 U.S.C. §1185a)
    This section applies to employer clients who sponsor group health plans. Individual ACA and Medicare clients: these obligations are managed by your carrier.
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    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 10 of 14
    Machine-Readable Files (MRFs) — Required
    The Transparency in Coverage Rule requires group health plans to post machine-readable files (MRFs) of in-network provider rates and out-of-network allowed amounts on a publicly accessible website. Fully insured plan sponsors: your carrier posts these files — we will provide the carrier’s MRF URL. Self-funded plan sponsors: you bear direct posting responsibility.
    Key CAA 2021 Compliance Deadlines
    Requirement
    Deadline
    Responsibility
    In-Network Provider Rates MRF
    July 1, 2022 (ongoing)
    Carrier (fully insured) / Plan sponsor (self-funded)
    Out-of-Network Allowed Amounts MRF
    July 1, 2022 (ongoing)
    Carrier / Plan sponsor
    500 Shoppable Services Cost Estimator
    Jan 1, 2023 (ongoing)
    Carrier / Plan sponsor
    All Items & Services Cost Estimator
    Jan 1, 2024 (ongoing)
    Carrier / Plan sponsor
    Gag Clause Attestation (GCPCA)
    December 31 annually
    Plan sponsor — we assist with submission
    RxDC Prescription Drug Report
    June 1 annually
    Carrier typically submits for fully insured
    No Surprises Act Protections
    The No Surprises Act (CAA 2021, Div. BB; 45 CFR §§149.110-149.140) prohibits balance billing for emergency services from out-of-network providers and non-emergency services from out-of-network providers at in-network facilities without proper notice and consent. Plan documents, SBC, and EOBs must reflect these protections.
    MHPAEA — Mental Health Parity
    Group health plans must ensure mental health and substance use disorder (MH/SUD) benefits are no more restrictive than medical/surgical benefits. The January 2025 Final MHPAEA Rule requires annual Nonquantitative Treatment Limitation (NQTL) comparative analyses, available to DOL or plan participants upon request.
    As your broker, we assist with MRF URL verification, GCPCA attestation filing, SBC updates, and compliance documentation. This information is educational — consult qualified ERISA counsel for plan-specific guidance.
  14. Children’s Online Privacy (COPPA)
    Authority: 15 U.S.C. §6501 et seq.; FTC Rule 16 CFR Part 312
    Our website is NOT directed to children under 13. We do not knowingly collect personal information from children under 13. Dependent children’s health data on insurance applications is used only to administer their coverage and is protected under HIPAA.
    If you believe we have collected information from a child under 13, contact us immediately at 623-780-0077. We will delete the information within 72 hours of confirmed notification.
    abc-incorp.com | 623-780-0077 | Not affiliated with any government agency
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  15. Arizona Insurance Privacy Rights
    Authority: A.R.S. §20-2301 et seq. (NAIC Model Privacy Protection Act); A.R.S. §18-551 (Data Breach)
    •
    Right to receive this notice upon becoming a client and annually thereafter (A.R.S. §20-2301)
    •
    Right to opt out of information sharing with nonaffiliated third parties — call 623-780-0077
    •
    Right to access and request correction of information we maintain about you
    •
    Data breach notification without unreasonable delay (A.R.S. §18-551)
    •
    Breaches affecting 500+ Arizona residents trigger Arizona Attorney General notification
    •
    Arizona has no comprehensive consumer privacy law as of this notice’s effective date — this section updates upon enactment
    Annual NAIC privacy notice distribution: We send this notice to all active insurance clients annually as required by A.R.S. §20-2301. Email delivery is acceptable with confirmation.
  16. Data Security and Breach Notification
    We implement safeguards consistent with HIPAA Security Rule (45 CFR Part 164 Subpart C), FTC Safeguards Rule (16 CFR Part 314), and the NIST Cybersecurity Framework:
    •
    TLS 1.2+ encrypted data transmission on all web communications
    •
    PHI access controls — restricted on a need-to-know basis
    •
    Annual employee privacy and security training per 45 CFR §164.530(b)
    •
    Executed Business Associate Agreements (BAAs) with all vendors handling PHI
    •
    Documented incident response plan and breach notification procedures
    •
    Vendor risk management and ongoing security policy review
    Breach Notification Timelines
    Regulation
    Who Gets Notified
    When
    HIPAA Breach (45 CFR §164.404)
    Affected individuals + HHS OCR
    Within 60 days of discovery
    500+ individuals — HIPAA
    Prominent media in affected state
    Within 60 days
    Arizona (A.R.S. §18-551)
    Affected AZ residents
    Without unreasonable delay
    500+ AZ residents
    Arizona Attorney General
    Without unreasonable delay
    No system is 100% secure. We cannot guarantee absolute security of internet transmissions. Please do not send sensitive health or financial data via unencrypted email.
  17. Data Retention
    Data Type
    Retention Period
    Authority
    PHI / HIPAA records
    6 years from creation or last effective date
    45 CFR §164.530(j)
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    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 12 of 14
    Data Type Retention Period Authority
    Insurance applications and policy records
    5 years after policy termination
    A.R.S. §20-158 / NAIC
    ACA enrollment records
    10 years
    IRS / ACA §1502; 26 CFR §54.4980H
    Medicare call recordings
    10 years minimum
    CMS MCMG / 42 CFR §422.2264
    GLB financial records
    5 years minimum
    16 CFR Part 314; 15 U.S.C. §6801
    CCPA / WA-NV rights request records
    24 months
    Cal. Civ. Code §1798.105; RCW 70.372
    Website session cookies (current)
    Session duration only
    Cookiebot verified
    Email and marketing records
    3 years
    CAN-SPAM / litigation hold policy
    Server logs
    90 days
    CIPA §638.51 / security policy
    Records are securely deleted or de-identified upon expiration of applicable retention periods. Litigation holds may extend retention requirements.
  18. Web Accessibility Statement
    Authority: ADA Title III (42 U.S.C. §12181); WCAG 2.1 Level AA (W3C Recommendation)
    Partial Conformance — Active Remediation in Progress
    Target standard: WCAG 2.1 Level AA. Current Pope Tech AIM score: 5.6/10.
    Known issues: missing alt text, form labels, skip links, color contrast, heading hierarchy.
    Remediation target: 8.0+ AIM score by September 30, 2026.
    ALTERNATIVE ACCESS: Call 623-780-0077. We provide all information and services by phone.
    Documents available in large print, plain text, or read aloud upon request — at no charge.
    How to Report an Accessibility Issue
    Call 623-780-0077 or visit abc-incorp.com/contact-2. We acknowledge all accessibility reports within 2 business days and aim to resolve or provide an alternative within 10 business days.
    Escalation: U.S. DOJ ADA Information Line: 1-800-514-0301 | ada.gov | Arizona Center for Disability Law: acdl.com | 602-274-6287
  19. Dispute Resolution and Mandatory Arbitration
    IMPORTANT — READ CAREFULLY
    THIS SECTION REQUIRES BINDING INDIVIDUAL ARBITRATION AND WAIVES YOUR RIGHT
    TO A JURY TRIAL AND YOUR RIGHT TO PARTICIPATE IN A CLASS ACTION.
    abc-incorp.com | 623-780-0077 | Not affiliated with any government agency
    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 13 of 14
    Enforceable under: AT&T Mobility v. Concepcion, 563 U.S. 333 (2011);
    Epic Systems v. Lewis, 584 U.S. 497 (2018); Federal Arbitration Act 9 U.S.C. §1.
    Agreement to Arbitrate
    EXCEPT AS NOTED BELOW, YOU AND ASSURANCE BENEFITS AGREE THAT ANY DISPUTE, CLAIM, OR CONTROVERSY ARISING FROM THIS NOTICE, OUR WEBSITE, ANY ALLEGED CIPA OR PRIVACY LAW VIOLATION, OR ANY COMMUNICATION WITH ASSURANCE BENEFITS SHALL BE RESOLVED EXCLUSIVELY THROUGH BINDING INDIVIDUAL ARBITRATION UNDER THE FEDERAL ARBITRATION ACT, 9 U.S.C. §1 ET SEQ. — NOT IN COURT.
    Arbitration Rules
    •
    Administrator: JAMS (jamsadr.com) — Streamlined Rules (under $250K); Comprehensive Rules ($250K+)
    •
    Location: Maricopa County, Arizona — or by video/phone at either party’s request
    •
    Governing law: FAA for arbitrability; Arizona substantive law for all other issues
    CLASS ACTION WAIVER
    YOU AND ASSURANCE BENEFITS MAY ONLY BRING CLAIMS AGAINST EACH OTHER IN AN INDIVIDUAL CAPACITY — NOT AS A CLASS MEMBER IN ANY CLASS ACTION, COLLECTIVE ACTION, MASS ACTION, PAGA ACTION, OR REPRESENTATIVE PROCEEDING.
    Mandatory Notice and Cure — 30 Days Before Filing
    Before initiating arbitration, you must provide written notice identifying: (1) the specific violation alleged; (2) the conduct at issue; (3) the date(s); and (4) damages claimed. Send to: abc-incorp.com/contact-2. We have 30 days to investigate and cure. If cured within 30 days, no claim may be filed. Failure to provide this notice results in dismissal.
    Exceptions
    •
    Emergency injunctive relief to prevent irreparable harm (pending arbitration)
    •
    Claims that qualify for and remain in Maricopa County small claims court on an individual basis
  20. Contact — How to Exercise Your Rights
    Right
    Law
    Response Time
    How to Request
    CCPA Know / Delete / Correct
    Cal. Civ. Code §1798.100
    45 days
    Phone, online, or written
    Multi-state privacy rights
    VCDPA, CPA, CTDPA, etc.
    45 days
    Phone, online, or written
    WA/NV Consumer Health Data
    RCW 70.372 / NRS 603A
    45 days
    Phone, online, or written
    GLB Financial Opt-Out
    15 U.S.C. §6802
    30 days
    Phone or written
    abc-incorp.com | 623-780-0077 | Not affiliated with any government agency
    Assurance Benefits | Master Privacy & Compliance Notice v3.0 Page 14 of 14
    Right Law Response Time How to Request
    CIPA Call Recording Opt-Out
    CA Penal Code §632
    Immediate
    Verbal at call start
    AZ Insurance Privacy Rights
    A.R.S. §20-2301
    30 days
    Written request
    COPPA Parental Access/Deletion
    15 U.S.C. §6501
    72 hours
    Phone or email
    Accessibility Accommodation
    ADA Title III
    2 business days
    Phone or online
    HIPAA PHI Rights
    See HIPAA NPP page
    30–60 days
    See HIPAA NPP page
    CONTACT OUR PRIVACY OFFICER
    Assurance Benefits Corp. | abc-incorp.com
    Phone: 623-780-0077 (fastest response)
    Web: abc-incorp.com/contact-2
    HIPAA Complaints: hhs.gov/hipaa/filing-a-complaint | 1-800-368-1019
    CCPA Complaints: cppa.ca.gov
    AZ Insurance: difi.az.gov | 602-364-3100 | FTC: ftc.gov | 1-877-382-4357
    Last reviewed: July 2026 | Annual review scheduled: July 2027
    This Master Privacy & Compliance Notice covers: HIPAA (45 CFR Parts 160 & 164), HITECH (Pub. L. 111-5), CCPA/CPRA (Cal. Civ. Code §1798.100), VCDPA, Colorado CPA, CTDPA, TDPSA, FDBR, OCPA, MCDPA, CIPA (CA Penal Code §§630-638.55), COPPA (15 U.S.C. §6501; 16 CFR Part 312), GLB Act (15 U.S.C. §6801; 16 CFR Part 314), FTC Safeguards Rule, CalOPPA (Cal. Bus. & Prof. Code §22575), TCPA (47 U.S.C. §227; FCC 23-107), CAN-SPAM (15 U.S.C. §7701), NAIC Model Privacy Act, A.R.S. §§18-551 and 20-2301, CMS MCMG (42 CFR §§422.2264, 423.2264), CAA 2021, Transparency in Coverage Rule (45 CFR §§147.210-212), ADA Title III (42 U.S.C. §12181), Washington My Health My Data Act (RCW 70.372), Nevada Health Data Privacy Act (NRS 603A), FAA (9 U.S.C. §1). Attorney review strongly recommended before publication. (C) 2026 Assurance Benefits Corp. | Licensed in Arizona | Not affiliated with any government agency.
    abc-incorp.com | 623-780-0077 | Not affiliated with any government agency