Privacy Notice

1. Introduction

Employee Pooling reviewed and updated this Privacy Notice on February 25, 2024

Employee Pooling is a business process outsourcing (“BPO”) and back-office support company with operations in India. We provide Our services to US-based insurance carriers, distributors, financial institutions, and software companies. To deliver these services, We may collect, use, and share Personal Information about Our clients (collectively and hereafter, “You” or “Your”). s a service provider to highly regulated business entities, We may also collect, use, and share Personal Information about Our clients’ customers (“consumer” or “consumers”) under the direction and supervision of Our clients.

Employee Pooling comprises two separate legal entities. Employee Pooling, LLC is Our headquarters, based in Nashville, Tennessee. Employee Pooling Resources, Pvt. Ltd., based in India, is owned and controlled by Employee Pooling, LLC. For purposes of this Privacy Notice, We refer to these businesses as “Employee Pooling” unless stated otherwise. We also do business as and under the following names to which this Privacy Notice also applies: EP Insurance Services and EP Mortgage Services.

This Privacy Notice summarizes Our privacy practices and how to contact us if You have questions or concerns about these practices.

2. Scope

This Privacy Notice applies to Personal Information collected, used, and shared by Employee Pooling (collectively and hereafter, “Employee Pooling”, “EP”, “Us”, “Our”, and “We”) via Our website (employeepooling.com) and associated services. For purposes of this Privacy Notice, “Personal Information” means information that identifies You (or Your customers if using Our services) or relates to You or Your customers as an identifiable person(s). “Personal Information” does not mean publicly available information about individuals.

Our website and associated services are intended for use by business professionals acting in the capacity of an owner, co-owner, shareholder, officer, director, agent, employee, or contractor of a business entity. Our website and associated services are not intended for use by consumers of financial/insurance products or services.

Employee Pooling’s services may fall within the scope of certain federally-regulated activities, including those defined under the Health Insurance Portability and Accountability Act (HIPAA), the Gramm-Leach-Bliley Act (GLBA), the Fair Credit Reporting Act (FCRA), and others. In such cases, Our obligations to safeguard the privacy of Personal Information under federal law may preempt those requirements defined in state-level data protection laws and regulations.

Where indicated, this Privacy Notice also applies to Our collection, use, and sharing of Personal Information about consumers, under the direction of Our clients.

3. Collection of Personal Information

We may collect Personal Information about You and/or Your customers so that We can provide the services You request. We may also collect Your Personal Information to market Our services to You, or to consider Your application for a job with us. In such cases, We limit Our collection of Personal Information to what We need for Our legitimate business purposes. Where appropriate, We obtain Your consent prior to collecting Your Personal Information.

3.1. When and Why We Collect Your Personal Information

We may collect Personal Information directly from You (or Your customers, where applicable) when You:

Use Our services.
Transact business with us.
Register an account or edit details of Your profile in Our online portal.
Interact with us on Our social media pages.
Contact us via the web, email, telephone, facsimile, or other digital means.
Apply for employment with us.

We may collect Personal Information about You indirectly from third-parties, when We:

Attend industry events and conferences.
Contract with industry partners and referral agents.
Purchase lists of industry professionals from data brokers and marketing firms.
Obtain lists of industry professionals from public sources, such as business directories or social media sites like LinkedIn.
Process and administer payments from You with financial institutions.
Access, by logging in to a third-party software (e.g., Ebix SmartOffice®) that You provide Us access to in the course of Us providing You Our services

We avoid purchasing, leasing, or otherwise collecting Personal Information from third parties when We know or suspect that a given third party obtained such Personal Information pursuant to the commission of a crime and/or unauthorized access.

3.2. Categories of Personal Information We Collect

The following is a list of the categories of Personal Information We may collect from or about You (or Your customers where applicable, if and when You use Our services):

Name and Contact Information: Your, Your consumers’ or agents’ or their customers’ name(s), email address(es), mailing address(es), phone number(s), title(s), business or home address(es), Your business team member names and their contact information, and related information.
Financial information: Your, Your consumers’ or agents’ or their customers’ bank account details, payment (credit/debit) card information, creditworthiness, financial condition, annual income and net worth, and related information. As of the date of this Privacy Notice, we do not store any payment card or bank account information – we use PayPal and QuickBooks for credit card and bank transactions; however, we may use applications of software that You control and give Us access to for Us to provide services that use this information.
Insureds’ Insurance Policy information: Your consumers’ or agents’ or their customers’ insurance policy owner information; account numbers; carrier or insurer name; beneficiary information and details; premium, plan, and rider information; existing insurance policies and replacement policies; agents’ relationships to clients; contact details and computer application login information; insurance carrier license and contracting identification numbers; tax records or information; and related information.
Personal medical history and health information: Your, Your consumers’ or agents’ or their customers’ personal health records, which may in some cases but not always be Protected Health Information (“PHI”) as defined in the Health Insurance Portability and Accountability Act (“HIPAA”) of 1996 and its related regulations.
Government identifiers: Your, Your consumers’ or agents’ or their customers’ Social Security number(s), Federal Employment Identification Number(s) (“FEIN”), or other taxpayer/government identification.
Transaction Information: Payment type used, date and time, payment amount, billing information, and other related details.
Employment Information: Your, Your consumers’ or agents’ or their customers’ demographics, career history, background screening reports, and other employment-related details.

3.3. Collection of Personal Information About Consumers on Clients’ Behalf

We may collect Personal Information, such as those in the categories listed above, about consumers on Our clients’ behalf when You use Our services. We collect consumers’ Personal Information for the limited purposes of providing Our services, which may include administering and supporting insurance, annuities, and other financial products. We collect no more Personal Information than necessary to fulfill regulatory and contractual obligations to Our clients. Our clients formally authorize and closely monitor Our Personal Information collection practices to ensure compliance with relevant laws and regulations.

3.4. Information We Collect Automatically

When You use visit Our website and/or use Our services, We may automatically collect and store certain information in Our server logs to get a better understanding of how people use Our services, for system administration purposes including system audits, and to ensure We provide excellent client service. This may include information about when, how, and what parts of the website and/or services You use. Generally, this information is not personally identifiable, and we do not intentionally engage in any activity that will personally identify You as a website visitor.

Location Information: Your IP address or mobile device geolocation signal may provide us with Your precise or approximate location information. You can turn this function off and on through the settings options on Your device.
Usage Information: The pages or content You view on Our website or in Our services may be collected to provide usage metrics.
Device Information: Your device’s unique identifiers, operating system, setting preferences (e.g., screen resolution), and mobile network information, including the IP address.
Log Information: Details about how You used Our website and/or services, such as when You click on a link to a third-party application, access dates and times, hardware and software information, crash data, and cookie data (when activated).
Cookies and Similar Technologies: Review the “Cookies, Tracking Pixels, and Related Technologies” section below to learn more about how We may collect Your Personal Information using cookies, tracking pixels, and other technologies.

4. Uses of Personal Information

4.1. Ways We Use Your Personal Information

We may use the Personal Information We collect about You (or Your customers, where applicable) as follows:

Service Delivery: To provide, maintain, and improve Our services tailored to You and Our partners’ customers.
Communication: To send operational notifications, updates, and to respond to inquiries or feedback.
Billing and Payments: To process transactions, send invoices, and manage Your accounts.
Compliance and Legal Obligations: To fulfill statutory, regulatory, and/or contractual requirements, enforce Our terms and policies, and protect against fraudulent or illegal activities.
Analysis and Improvement: To conduct analytics, identify usage trends, and enhance the effectiveness of Our website and services.
Marketing and Promotions: To offer new services, promotions, or events that might be of interest, unless You opt out.
Security: To ensure the confidentiality, integrity, and availability of Our information systems and the data We process.

4.2. Ways We Use Personal Information About Consumers on Clients’ Behalf

We may use (or process) Personal Information about consumers on Our clients’ behalf. We use Your consumers’ Personal Information for the limited purposes of administering and supporting services for which You contract EP in the areas of insurance, annuities, and other financial products. We use no more Personal Information than necessary to fulfill regulatory and contractual obligations to Our clients. Our clients formally authorize and closely monitor Our Personal Information processing practices to ensure compliance with relevant laws and regulations.

5. Sharing Personal Information with Third Parties

We do not sell Your (or Your customers’, where applicable) Personal Information with anyone. We do not share Your (or Your customers’, where applicable) Personal Information with anyone, except to help us operate Our business as permitted by law or as allowed under Our contractual terms with You. Where necessary, We seek Your consent prior to sharing Your Personal Information with third parties.

We may share Your Personal Information with third parties for the following purposes:

With insurance carriers and financial institutions, as necessary to facilitate the provision of Our services, for example, when EP must connect to a carrier website on Your behalf to administer or manage insureds’ account(s) under Your direction.
With Our service providers and suppliers, as necessary to support Our business operations.
With industry consultants, accountants, legal professionals, and others under similar confidentiality obligations, so that they can help us continuously improve Our business operations; for example, companies we’ve hired to protect and secure our computer systems and services. We may also have to disclose Personal Information as part of a corporate transaction, such as a merger or sale of assets.
With law enforcement and other government officials.
In response to subpoenas, court orders and other legal requests.
As required or otherwise permitted by law.

6. Cookies, Tracking Pixels, and Related Technologies

If You visit Our website, We may use first- and third-party “cookies” (small text files sent from Our website to Your hard drive), tracking pixels, and/or related technologies to help us understand how Our visitors interact with the website. Cookies, tracking pixels and related technologies help us to recognize repeat visitors and improve the functionality and effectiveness of Our website. In limited cases, We may use cookies, tracking pixels, and related technologies to gather information about You. You may use the settings in Your web browser to opt-out of (i.e., block) such cookies, tracking pixels, and related technologies.

7. How We Protect the Personal Information We Collect About You

Employee Pooling constantly strives to align Our information security practices with industry-accepted standards, including ISO/IEC 27001:2022, for securely handling, transmitting, and storing Personal Information. To prevent unauthorized access, maintain data accuracy and ensure the correct use of information, We implement and maintain administrative, physical, and technical measures to protect the Personal Information We collect.

Employee Pooling limits access to Personal Information to only those authorized employees, contractors, agents, and service providers who need it for legitimate business purposes. We take reasonable measures to secure Our website and protect Personal Information shared over the website. Nevertheless, this Privacy Notice applies only to our website, services, and products. It does not apply to other companies or subcontractors that we do not own.

We select Our third-party service providers carefully and seek contractual assurances that each third-party service provider reasonably safeguards Your Personal Information in a manner consistent with Our policies and practices. In a similar manner, We recommend that You view privacy notice statements of any other companies, individuals, or organizations that may interface with EP to understand how they may collect, use, and share Your information. If You integrate or get our assistance with integrating any other online or offline service or software, then You are solely responsible for understanding, abiding by and agreeing to their respective privacy policy statements, terms and conditions.

Since the Internet is not a secure environment, We cannot ensure or warrant the security of any information You transmit to us. Employee Pooling offers no guarantees that information cannot or will not be accessed, disclosed, altered, or destroyed by a breach of any of Our administrative, physical, or technical measures.

8. Retention of Your Personal Information

Employee Pooling may retain Your Personal Information as necessary to fulfill Our business purposes, comply with Our legal obligations, resolve disputes, and enforce Our agreements. Except where required, We have no obligation to store Your Personal Information, and disclaim any liability arising out of or related to the destruction of such Personal Information. It may not always be possible to completely delete or remove all Your Personal Information from our records or databases without some residual data remaining. The reasons for this are that we may be required to keep backups in certain circumstances, and the nature of technology often does not allow a complete removal of all information without a trace remaining. We are under no obligation to notify You if/when We delete Your Personal Information from Our records.

9. Notification in Event of Data Breach

International, federal, and state laws and regulations may require Employee Pooling to notify Our clients and/or individual victims in the event of a breach of Personal Information. In such an unfortunate event, We will promptly notify Our clients and/or data breach victims, in accordance with notification procedures defined in Our internal policies, by Our contractual obligations, and as required by applicable law.

10. Your Privacy Rights

You have certain privacy rights relative to Our collection, use, and sharing of Personal Information, as follows:

Access: You have the right to request that We provide You with access to a copy of Your Personal Information held by Employee Pooling, covering the twelve (12) calendar months preceding Your request.
Portability: You have the right to receive Your Personal Information held by Employee Pooling in a structured, commonly-used, and machine-readable format. You also have the right to transmit Your Personal Information to another organization without hindrance from Employee Pooling.
Correction, Amendment, and Deletion: You have the right to request a correction or amendment of Your Personal Information held by Employee Pooling. You also have the right to request that Employee Pooling deletes certain Personal Information about You.
Opt-Out of Sharing: You have the right to request that We do not share Your Personal Information with third parties. For instance, You may opt-out of email communications from us by clicking the “unsubscribe” link in the email message, where available.
Prohibition on Discrimination: You have the right to exercise Your rights under relevant laws without fear of discrimination by Employee Pooling.

If You wish to exercise any of Your rights, as described above, please submit Your request to Employee Pooling via the “How to Contact Us” section below. Note that if You choose to opt out, alter, or delete certain Personal Information, or not to provide us with certain Personal Information, You may not be able to take advantage of some or all the services that we offer. It is impossible to provide many of our services without Personal Information. You should not use our services if You do not want us to have access to Your Personal Information.

11. Links

This website may contain links to and from other third-party sites. Please be aware that Employee Pooling is not responsible for the privacy practices of these third-party sites. We do not control certain privacy settings and preferences maintained by social media sites. If You wish to make changes to those settings and preferences, You may do so by visiting the settings page of the appropriate social media website.

12. Use of Website and Services by Minors

Employee Pooling does not knowingly collect, use, or share Personal Information from children under thirteen (13) years old. We ask that any person under age 13 refrains from using Our website and associated services. If We learn that We have collected the Personal Information of a minor, We will take steps to delete the Personal Information as soon as possible.

13. How to Contact Us

If You have any questions or concerns about this Privacy Policy, or Your experiences with our services, You may contact Employee Pooling by post, telephone, or email:

Employee Pooling, LLC
2000 Glen Echo Road
Suite 111
Nashville, TN 37215
Attn: Privacy Official
615-610-5585 (ex 204)
privacy | at | employeepooling |dot| com

14. Privacy Notice Revisions

We reserve the right, at Our discretion, to change, modify, add, or remove portions of this Privacy Notice at any time. Your continued use of this website and Our services, following reasonable notice of such modifications, constitutes Your acceptance of any changes to this Privacy Notice.