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Hodges-Mace Product Privacy Policy

Effective Date: May 2020

This Privacy Policy describes how Hodges-Mace, LLC, an Alight company, and its affiliates, including Alight Solutions, LLC (collectively, “Hodges-Mace”, “Us”, or “We”) collects, uses, and protects personal information it receives in the course of providing its services. This Privacy Policy also describes the choices available to you regarding our use of your personal information and how you can access and update this information. This Policy applies to information collected on www.smartben.com and all other online offerings that post a link to this Policy, whether accessed via computer, mobile device or other technology (the “Sites”).

For purposes of this Policy, references to “Hodges-Mace” shall include Hodges-Mace, LLC, SmartBen Holdco, Inc., Alight Solutions, LLC, and all of their respective members, affiliates, subsidiaries, directors, officers, agents, and employees. Hodges-Mace is owned by, and part of, Alight Solutions LLC.

At Hodges-Mace, your privacy is very important. We strive to protect the personal information under our control and to maintain the security and integrity of that information. Please read this Policy carefully.

 

How Hodges-Mace Receives Personal Information
The personal information we receive relates to your participation in the compensation and benefits programs offered by your employer. There are several ways that we could receive personal information:

  • • You might provide the information directly to us, such as by visiting our websites, using our mobile applications, telephoning our benefits call center, filling out our forms and surveys, or by sending mail to our offices.
  • • Your employer or prospective employer ("employer") might provide the information to us. In such a case, we have no direct relationship with the individuals whose personal information we process. If you are an employee or prospective employee ("employee") of one of our clients and would no longer like us to process your information, please contact your employer directly.
  • • Another service provider engaged by your employer (such as payroll processors, insurance carriers, COBRA administrators, health plans, or mutual funds) that have a part in administering or servicing your employer's plans or programs might provide the information to us.

 

Additional Information may be collected if you access our Sites through mobile devices:

  • • If you access our websites on your mobile telephone or mobile device, we may also collect your unique device identifier and mobile device IP address, as well as information about your device's operating system, mobile carrier, and location information. We may also use cookies and other online tracking technologies, as described below.
  • • When you provide us your mobile device phone number as your contact phone number, you consent to the use of your mobile device phone number for the purposes identified in this Policy . If you choose to receive notifications from us on your mobile device (e.g. text notifications), you also consent to the use of your mobile phone number for that purpose.

 

Categories of Personal Information We Collect
In the preceding 12 months, categories of personal information we may have received or collected about you may include:

  • • Benefit program participation and coverage information, such as benefit elections, beneficiary information, claims information, benefit plan account numbers and balances, and date of retirement.
  • • Identifiers, such as real name, alias, date of birth, postal address, unique personal identifier, IP address, email address, account user name, accounts password, account PIN, employee ID, national identification number, financial account number, or other similar identifiers;
  • • Other personal information, such as your signature, telephone number, medical health insurance information, age, , gender, sex, marital status, medical condition and care information, health information, and similar information;
  • • Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our website;
  • • Professional or employment information, such as date of hire, employment status, pay history, tax withholding information, , leave information, and date of termination; or

 

How Hodges-Mace Uses Your Personal Information
The information we receive about you is used in connection with transactions that you expressly authorize or that are part of the services we provide to your employer. We may also use the information that we receive about you for the following business purposes:

  • • Assess the needs of your employer's business to determine suitable products.
  • • Send you communications in accordance with the services provided by us to you on behalf of your employer.
  • • Respond to customer service inquiries.
  • • Administer your employer's account.
  • • Collect and compile research information in accordance with the services provided by us to your employer.
  • • Provide our services.
  • • Enable you to post your resume, search job postings, and contact or be contacted by prospective employers to the extent such activities are in accordance with our services.
  • • Implement third party services on behalf of your employer.
  • • Send you transactional communications.
  • • Maintain the security of your account, our websites and the services that we provide.
  • • Identifying and repairing errors that may impair or impede our delivery of services to you or your employer.
  • • Comply with applicable law or legal process.

With your consent, we may also use your personal information for additional purposes.

Hodges-Mace's Commitment to Protecting Personal Information
We have implemented various technological, administrative and organizational security measures to protect the confidentiality of the personal information we process. We have policies, procedures, and controls to reduce the risk of unauthorized or accidental use, disclosure, or destruction of your personal information, and we train our employees on data security.
If you have any questions about security on our Sites, you can contact us here

Sharing
In the past 12 months, we may have shared your personal information with the following third-parties:
With our service providers: We may share your information, including your financial information and health-related information, with third-party service providers and vendors who perform services on our behalf but only if (a) the sharing of your personal information is necessary for them to carry out such support services and (b) those service providers are required to use any personal information they receive in accordance with Hodges-Mace’s instructions and pursuant to a data processing agreement that complies with the requirements of applicable data privacy law.
With our business partners: We may share your personal information with our business partners with whom we work to provide you with products and services. Such business partners include credit and fraud reporting agencies; debt collection agencies; insurers; reinsurers; and managed fund organizations for financial planning, investment products and trustee or custodial services related to banking and financial products in which you invest. In addition, we may share with our other partners such as insurers; reinsurers; other insurance intermediaries; insurance reference bureaus; medical service providers; fraud detection agencies; our advisors ­ such as loss adjusters, lawyers, and accountants; and others involved in the claims handling process if further legal requirements for this are fulfilled.
In the event of corporate change: We may disclose personal information to a successor to all or part of our business or in connection with a corporate merger; consolidation or restructuring; sale of substantially all of our stock or assets; or other corporate change, including, without limitation, during the course of any due diligence process. If necessary and legally required, we will obtain your separate consent in this regard. Disclosure may also be required for company audits or to investigate a complaint or security threat.
To comply with legal requirements: We will disclose your information (i) if we are required to do so by law or legal process, (ii) in response to lawful law enforcement authority or other government official requests, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iv) in connection with an investigation of suspected or actual illegal activity including any legal proceedings or prospective legal proceedings in order to establish, exercise or defend our or a third party’s legal rights or (v) as required for company audits or to investigate a complaint or security threat.
To companies within our corporate family: We may disclose your personal information to our corporate affiliates for organizational purposes based on a legitimate interest.

The personal information that may have been shared in the past 12 months includes the “Categories of Personal Information We Collect” listed above.
If we share information for other reasons, we will provide prior notice of such sharing to you. To the extent that our service providers, business partners, or other corporate affiliates have access to your personal information, they will follow practices that are at least as restrictive as the practices described in this Policy, will use your information solely for the purpose for which it was provided, and will not further disclose your information.
Although we may share information as explained above, we do not sell any personal information to third parties.

Access and Choice
You can access, correct, update, and request deletion of your personal information via our self-service website, sending us an email, or by directing your query to your employer. We will respond to your request within 30 days.
In some circumstances, only your employer, and not Hodges-Mace, may have the authority to update, correct, or delete your personal information. In these instances, please contact your employer directly. Otherwise, we will forward your request to your employer.
We will retain your information for as long as your account is active or as long as the data is reasonably necessary for the business purposes for which it was collected. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Cookies and Other Technology
Hodges-Mace and our partners, affiliates, and service providers, such as our analytics service providers, use tracking technologies such as cookies, beacons, tags and scripts. These technologies are used in analyzing trends, administering the site, tracking users' movements around the site and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited. For more information, please review our Cookie Notice.
We use Local Storage Objects (LSOs) such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use LSOs such as HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs.

Website Log Files – Hodges-Mace may also log information related to your website visit or mobile site visit. We may link this automatically collected data to other information we collect about you.
This information can include:

  • • The address (or "URL") of the web pages you visit
  • • The browser you used to view our website
  • • Your Internet Protocol (IP) address
  • • The type of computer or device you used to view our website
  • • Any clicks on a "Like" button
  • • Statistics on page views


Third Party Links – Our Sites may contain links to other sites that are outside of our control and are not covered by this Policy. If you access other sites using the links provided, the operators of those sites may collect information from you which will be used by them in accordance with their own privacy policies. We encourage you to read the privacy policies on other websites you visit. Hodges-Mace is not responsible for the content or privacy practices of linked sites or any use of those sites.
Please be aware that our Sites may contain links to sites maintained by other Hodges-Mace entities (including Alight Solutions, LLC) that are not governed by this Policy but are governed by privacy policies that may differ slightly from this Policy. We encourage you to review the privacy policy of each website you visit.
Google Analytics – We may use a tool called "Google Analytics" to collect information about use of this site. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics to improve this site. Google's ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.
Do Not Track – Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform and we may not respond to those signals.
Mobile Phone Numbers – Hodges-Mace may collect your mobile phone number(s), including from you or your employer. Although Hodges-Mace may store that number, we will not call or text you at that number without the notice or consent required by applicable laws or regulations. However, to the extent allowable by such laws or regulations, we may call or text your mobile number(s) in the event of an emergency consistent with pre-established criteria documented by Hodges-Mace.

Children
This site is a general audience site and is not intended for children under the age of 13. If we become aware that information is or has been submitted by or collected from a child under the age of 13, we will delete this information from our files within the time required by law.

Notice to Residents of California
Please read If you are a California resident, California law provides you with certain rights. These rights may be limited or inapplicable by law if you are an employee of Hodges-Mace.
In general, Hodges-Mace performs its Services for (or on behalf of) employers. If you are an employee of a Hodges-Mace client who receives or benefits from the Services performed by Hodges-Mace, your information will be received by Hodges-Mace solely for completing the business purpose of our client (i.e., your employer). Hodges-Mace does not use or disclosure your information except as necessary to accomplish the business purpose for which we received your information. In these circumstances, Hodges-Mace’s client remains primarily responsible for your information. As a result, we may re-direct a query about our use of your information to our client for response.
California Civil Code Section 1798.83 permits you to opt-out of the disclosure of your personal information by Hodges-Mace to third parties for the third parties’ direct marketing purposes. We do not disclose your personal information to third parties for the third parties’ direct marketing purposes unless you affirmatively agree to it. If this Policy were to change, you can opt-out of such disclosures by sending us an email at: privacy.info@alight.com or sending written request to Hodges-Mace, Attn: Chief Privacy Officer, 5775-E Glenridge Drive, Suite 500, Atlanta, Georgia 30328.
To make such a request, please send an email at: privacy.info@alight.com with a detailed description of the specific content or information. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal, even when requested.

Notice to Individuals Located in Canada
Hodges-Mace processes personal information for certain individuals who are located in Canada for the purposes described above. Hodges-Mace collects, uses and discloses personal information in accordance with Canadian data protection legislation, which includes the Personal Information Protection and Electronic Documents Act(Canada) and the Personal Information Protection Act (British Columbia). Data protection legislation authorizes Hodges to collect, use, and disclose personal information only for purposes that a reasonable person would consider appropriate in the circumstances and with consent (except where otherwise authorized by law).
If we intend to use personal information for a purpose other than the purpose for which we collected the data, we will provide you with information about this secondary purpose and any additional information necessary to ensure fair and transparent processing, before we engage in further processing.

 

Your Choice to Provide Information: You may choose not to provide personal information to Hodges-Mace by refraining from, among other things, using our services. You also may refrain from submitting information directly to us. However, if you do not provide personal information when requested, we may not be able to provide you with the full range of our products and services, or with information about our products and services, promotions, and other opportunities.
You also have the right to withdraw your previously-provided consent; however, if you withdraw your consent, once again we may not be able to provide you with the full range of our products and services, or with information about our products and services, promotions, and other opportunities. Your Rights: You may have certain rights under Canadian data protection laws regarding the personal information that we maintain about you, which in certain circumstances, you will be able to exercise. These rights are as follows:

  • • You may request access to the personal information that we maintain about you.
  • • You may request that we correct, amend, or delete personal information that is inaccurate or incomplete.


Individuals who desire to make an access request in accordance with Canadian data protection laws are directed to make such a request to us here or writing to us at the mailing address provided below. Such requests will first need to be verified by ‘reasonable means’ and an individual will be asked to specify the information the request relates to.
 

Complaints
If you have concerns about the way in which we have handled your personal information, please contact us (see below for “Contact information”) so that we can try to resolve the issue.
Our Sites are available in countries outside of Canada, and information you provide to us may be stored on servers and with third-party service providers outside Canada including the United States and other countries in which we do business and whose data protection laws may differ from the jurisdiction in which you live. When we transfer the personal information of users who are located in Canada for processing in the United States, we use an approved transfer mechanism in compliance with applicable laws.

Voice Recognition Retention and Destruction Policy
You may be offered, and you may choose to opt-in to a security and authentication program offered by us that collects certain data pertaining to your voice for authentication and security purpose. This data includes encrypted “voiceprints” and/or encrypted audio files of your voice. You will not be enrolled in the voice authentication and security program without your express consent. Should you choose to enroll in the voice recognition program, we will retain your information in accordance with the policy below.
Upon your opt-in enrollment into the voice recognition and authentication program, we will retain your voice recognition data for as long as it is needed to accomplish the related business purpose or to comply with applicable legal obligations Should you wish to dis-enroll in the voice recognition program and/or have your voice recognition data deleted at an earlier time, please contact us privacy.info@alight.com.

Updates to this Privacy Policy
Hodges-Mace may update this Privacy Policy at any time. When we update it, we will put the date of the last update at the top of the Privacy Policy. We will notify you of any material change to this Privacy Policy as required by law. We encourage you to periodically review our Privacy Policy so that you'll always know how we protect your personal information.

Contact Information
If you have any questions relating to this Privacy Policy, please contact us at privacy.info@alight.com.

You may also write to us at:
Hodges-Mace, LLC
ATTN: Chief Privacy Officer
5775-E Glenridge Drive NE, Suite 500
Atlanta, Georgia 30328