PRIVACY POLICY

Please read this Policy carefully. It explains what personal information Helpha collects, how we use and disclose it, and the choices and rights that may be available to you. Insurance carriers, government programs and other third parties may provide separate privacy notices that also apply to information they receive.

1. Who We Are

Helpha, LLC ("Helpha," "we," "us" or "our") is a licensed health insurance agency. We help consumers research, compare and enroll in Medicare and other insurance products through licensed insurance agents and technology-enabled services. Helpha is not an insurance company and is not affiliated with or endorsed by the U.S. government or the federal Medicare program.

For purposes of applicable privacy law, Helpha is the business or controller responsible for the personal information described in this Policy, except where we process information solely on behalf of an insurance carrier, plan sponsor or another organization under a separate agreement.

2. Scope of This Policy

This Policy applies when you visit our websites, use our applications or portals, request plan information or a quote, communicate with an agent, consent to calls or text messages, submit an insurance application through our services, receive customer support, or otherwise interact with Helpha.

This Policy does not govern an insurance carrier’s independent practices, Medicare.gov, websites or services that Helpha does not control, or workforce information relating to employees and job applicants where a separate notice applies.

3. Personal Information We Collect

The information we collect depends on how you interact with us and which services you request. We may collect the following categories:

Identifiers and contact information. Name, postal address, email address, telephone number, date of birth, account identifiers, electronic signatures and similar identifiers.

Demographic and eligibility information. Age, gender where relevant to an insurance quote, ZIP code, county, state of residence, language preferences, Medicare eligibility and enrollment periods, and other information needed to determine plan availability or eligibility.

Health and insurance information. Current coverage, insurance preferences, doctors and other providers, hospitals, pharmacies, prescription drugs, health-related eligibility information and other information you choose to provide so that we can compare plans or assist with enrollment. This information may be considered sensitive personal data under applicable law.

Application and enrollment information. Plan selections, application responses, enrollment status, requested effective dates, beneficiary or member identifiers, and other information required by the selected insurance carrier or enrollment platform. We do not request highly sensitive enrollment identifiers through general lead-generation forms; when required for enrollment, they should be collected through an appropriate secure process.

Communications and consent records. Emails, chats, text messages, call recordings, transcripts, voicemail, agent notes, appointment records, customer-support requests, opt-in and opt-out records, the language presented when consent was obtained, timestamps, source URLs, device or IP information associated with consent, and related audit records.

Device, internet and usage information. IP address, browser and device type, operating system, referring URLs, pages viewed, clicks, session information, cookie and advertising identifiers, general location inferred from an IP address, and information about how our services perform and are used.

Inferences and preferences. Preferences or likely interests derived from information you provide or from your interactions with our services, such as preferred contact method or coverage priorities. We do not use health or Medicare enrollment information to make unlawfully discriminatory decisions.

4. Sources of Personal Information

We collect information directly from you; automatically from your browser or device; from licensed agents and authorized Helpha personnel; and, where permitted, from insurance carriers, plan sponsors, enrollment platforms, field marketing organizations, service providers, referral sources and business partners. We may also receive information when another person, such as an authorized representative or caregiver, acts with appropriate authority on your behalf.

5. How We Use Personal Information

We may use personal information to:

• Provide requested services. Respond to inquiries; identify available plans; generate quotes and comparisons; verify eligibility information; schedule appointments; support applications and enrollment; and provide post-enrollment customer service.
• Communicate with you. Send requested information, appointment reminders, application or enrollment updates, service messages, customer-support responses, and marketing communications when permitted by law and consistent with your choices.
• Operate and improve our services. Maintain accounts and records, troubleshoot technical issues, analyze performance, develop features, train authorized personnel, conduct quality assurance and improve user and agent experiences.
• Protect people and systems. Authenticate users, detect and prevent fraud or abuse, maintain security, enforce our terms and protect the rights, safety and property of consumers, Helpha and others.
• Comply with legal and contractual duties. Maintain records, respond to regulatory or legal process, administer privacy requests, satisfy carrier and Medicare program requirements, and support audits, investigations and dispute resolution.
• Advertising and analytics. Measure campaigns, understand website use and, subject to applicable rights and restrictions, display or measure advertising for Helpha services. We do not use prescription, provider, medical-condition, beneficiary identifier or enrollment-application information for cross-context behavioral advertising.

6. Medicare, Health and Other Sensitive Information

Information about health, prescriptions, providers, Medicare eligibility and insurance coverage may be sensitive personal data. We process such information only for purposes reasonably necessary to provide requested insurance comparison, enrollment and support services; comply with law and contracts; maintain security; or for another purpose with appropriate consent.

Depending on the activity and the parties involved, certain information may be governed by the Health Insurance Portability and Accountability Act (HIPAA), the Gramm-Leach-Bliley Act (GLBA), insurance privacy laws, carrier privacy notices or other specialized rules. This Policy does not replace a Notice of Privacy Practices or carrier privacy notice that applies to information held by another organization.

7. Calls, Text Messages, Email and Chat

When you provide the applicable affirmative consent, Helpha may send recurring marketing and informational text messages and may place marketing or informational calls regarding Medicare Advantage, Medicare Supplement Insurance, prescription drug plans and other products or services offered through Helpha. Communications may include responses to plan-information requests, appointment scheduling and reminders, consultation follow-ups, enrollment assistance, application updates, renewal communications and customer support.

Where disclosed in the consent request, calls or messages may be made using an automatic telephone dialing system, automated technology, or an artificial or prerecorded voice. Consent to marketing calls or texts is not a condition of purchasing any property, goods or services. Message frequency varies. Message and data rates may apply.

Text-message choices. Reply STOP to any Helpha text to opt out of further text messages from that messaging program. Reply HELP for assistance. Carriers are not liable for delayed or undelivered messages.

Calls. Ask the agent to place you on Helpha’s internal Do Not Call list, call 1-877-466-8086, or submit a request through our Privacy Choices page.

Email. Use the unsubscribe link in a marketing email or contact us using the information below.

You may revoke consent through any reasonable method that clearly communicates your request. An opt-out does not prevent non-marketing communications that are necessary to complete a transaction you requested, service an existing relationship, protect security, comply with law, or confirm the opt-out where permitted. We maintain consent and suppression records to document and honor communication preferences.

8. Call Recording and Quality Assurance

We may monitor or record calls and web-based audio interactions for quality assurance, training, compliance, security and recordkeeping. We provide notice when required. Medicare marketing and sales calls may be recorded and retained for the period required by applicable CMS rules, carrier contracts and other law. Do not continue a recorded interaction if you do not wish to be recorded; ask the representative whether another permitted communication method is available.

9. How We Disclose Personal Information

We may disclose personal information to the following categories of recipients for the purposes described below:

• Insurance carriers, plan sponsors and enrollment partners. To provide plan information, verify availability, transmit an application at your direction, administer enrollment and support an existing policy or requested service.
• Field marketing organizations and authorized insurance partners. To support contracting, compliance, enrollment, carrier relationships, commission administration and other functions involved in providing insurance services.
• Technology and operational service providers. Cloud hosting, cybersecurity, identity verification, CRM, analytics, customer support, communications, dialer, SMS, email, call recording, transcription, document management and other vendors that process information to provide services to Helpha.
• Advertising and measurement partners. To measure campaigns or provide advertising using non-sensitive identifiers and website activity, subject to applicable opt-out rights. We do not disclose Medicare beneficiary identifiers, application information, prescriptions, provider selections or medical-condition information to third parties for their independent marketing.
• Professional advisers and authorities. Lawyers, auditors, consultants, regulators, law enforcement, courts and other parties when reasonably necessary to comply with law, protect rights or safety, conduct an audit, investigate misconduct or resolve a dispute.
• Corporate transaction recipients. Potential or actual buyers, investors, lenders, successors and advisers in connection with financing, due diligence, merger, acquisition, reorganization, sale of assets or similar transaction, subject to appropriate safeguards.
• At your direction or with consent. Other parties when you direct us to disclose information or when we provide a separate notice and obtain consent where required.

10. Mobile Information

No mobile information will be shared with third parties or affiliates for their marketing or promotional purposes. Text-messaging originator opt-in data and consent will not be shared with third parties for their marketing or promotional purposes. We may disclose mobile information and consent records to service providers, telecommunications carriers and platform providers solely as necessary to deliver messages, operate the program, maintain security, document consent and comply with law.

11. Sale, Sharing and Targeted Advertising

Helpha does not sell personal information for money. We do not sell sensitive personal data, and we do not use health, prescription, provider, beneficiary identifier or enrollment-application information for targeted advertising.

We may allow analytics or advertising technologies to collect non-sensitive identifiers and website activity. Some state laws may define certain disclosures through these technologies as a "sale," "sharing" or processing for targeted advertising even when no money is exchanged. Where applicable, you may opt out through our Privacy Choices page or another mechanism presented on our website. We will also honor legally recognized universal opt-out preference signals where required.

12. Cookies and Similar Technologies

We and our service providers may use cookies, pixels, local storage, software development kits and similar technologies to operate the services, remember preferences, maintain security, measure performance, understand traffic and support advertising. You may control cookies through browser settings and any privacy controls made available on our website. Blocking some technologies may affect functionality. Third parties may independently process information under their own privacy policies.

13. Data Retention

We retain personal information only for as long as reasonably necessary for the purposes described in this Policy, including to provide services, maintain accurate consent and suppression records, comply with insurance and Medicare requirements, satisfy legal and contractual obligations, protect security, resolve disputes and enforce agreements. Retention periods vary by the type of record and applicable requirements.

For example, where CMS rules apply, Medicare marketing and sales call records may be retained for at least six years, with the format maintained as required during that period. Application, enrollment, customer, consent and compliance records may be retained for longer periods when required by a carrier contract, insurance law, litigation hold or other legal obligation. When information is no longer required, we take reasonable steps to delete, deidentify or securely dispose of it.

14. Security

We maintain administrative, technical and physical safeguards designed to protect personal information against unauthorized access, destruction, loss, alteration or disclosure. Safeguards may include access controls, encryption where appropriate, logging, workforce training, vendor management, secure development practices and incident-response procedures. No system is completely secure, and we cannot guarantee absolute security.

15. Your Privacy Rights and Choices

Depending on where you live and subject to applicable exceptions, you may have the right to:

• Confirm and access. Confirm whether we process your personal information and obtain access to or a portable copy of qualifying information.
• Correct. Request correction of inaccurate personal information.
• Delete. Request deletion of personal information, subject to legal, regulatory, contractual and operational exceptions.
• Opt out. Opt out of targeted advertising, qualifying sales of personal information or certain profiling that produces legal or similarly significant effects.
• Withdraw consent. Withdraw consent for processing that relies on consent, without affecting processing completed before withdrawal.
• Appeal. Appeal a decision we make concerning a privacy-rights request where applicable law provides that right.
• Non-discrimination. Exercise applicable privacy rights without unlawful discrimination or retaliation.

To submit a request, email compliance@helpha.com, call 1-877-466-8086, or use the Privacy Choices form at https://www.helpha.com/dont-call-us. Please identify the right you wish to exercise and provide information reasonably necessary to verify your identity and locate relevant records. We will not require you to create a new account solely to make a request.

We generally respond to verified requests within 45 days or the period required by applicable law. If reasonably necessary and legally permitted, we may extend the response period and will provide notice. If we deny a request, we will explain the basis where required and provide instructions for appeal. To appeal, reply to our decision or email compliance@helpha.com with the subject line "Privacy Appeal." If an appeal is denied, you may contact the appropriate state regulator, including the Texas Attorney General for Texas residents.

You may use an authorized agent where permitted by law. We may request proof of the agent’s authority and may need to verify your identity directly. Certain information may be exempt from state privacy rights because it is governed by HIPAA, GLBA, insurance law or another specialized legal framework.

16. Children’s Privacy

Our services are intended for adults seeking insurance information or acting with lawful authority for another person. We do not knowingly collect personal information online from children under 13. If you believe a child has submitted personal information to us without appropriate authorization, contact us so that we can evaluate and address the request.

17. Third-Party Services and Links

Our services may link to or integrate with insurance carriers, enrollment platforms, government resources and other third-party services. Their privacy practices are governed by their own notices. A link or integration does not mean that Helpha controls or endorses a third party’s privacy practices.

18. Changes to This Policy

We may update this Policy to reflect changes in our services, technology, legal requirements or business practices. We will post the revised Policy and update the effective or last-updated date. If a change materially affects how we use information previously collected, we will provide additional notice or obtain consent where required by law.

19. Contact Us

Questions, objections, privacy requests or communication-preference requests may be directed to: