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PRIVACY AND COMPLIANCE

Discover important information from Inspira about how we safeguard your privacy
and security, handle your personal information, and manage your services.


Privacy
Privacy policyCalifornia privacy noticeInspira Financial Trust, LLC U.S.
Consumer Privacy NoticeInspira Financial Health, Inc. U.S. Consumer Privacy
NoticeManage your dataSocial media community guidelines
Security
Security
Code of ethics
Code of ethics
Terms of use
Terms of use
Accessibility
Accessibility
TopicsPrivacy policy
Privacy
Privacy policyCalifornia privacy noticeInspira Financial Trust, LLC U.S.
Consumer Privacy NoticeInspira Financial Health, Inc. U.S. Consumer Privacy
NoticeManage your dataSocial media community guidelines
Security
Security
Code of ethics
Code of ethics
Terms of use
Terms of use
Accessibility
Accessibility


INSPIRA FINANCIAL PRIVACY POLICY

We at Inspira Financial Trust, LLC, including its affiliates Inspira Financial
Health, Inc. and Inspira Financial Health Holdings, Inc. (collectively, “Inspira
Financial”) respect your concerns about privacy. This Privacy Policy (the
“Privacy Policy”) explains what personal information we collect when you
interact with us via phone or online, including via our websites, platforms,
portals, applications or similar (collectively, “Online Services”), how we
collect, use, and protect it, and why, in certain cases, we may share it with
select third parties. This Privacy Policy also explains your rights in relation
to your personal information, including your sharing and use choices.

 


WHAT TYPES OF PERSONAL INFORMATION ARE COLLECTED?

The types of personal information we may collect and use will depend on how you
interact with us. This information can include:

 * Personal identifiers, such as Social Security number, driver’s license, date
   of birth, voiceprints, voice biometrics, face geometry and/or face biometrics
   and other personal information necessary to verify your identity, and access
   authorization information, such as username, passcode and security questions
   and answers

 * Information you provide on applications or other forms in order to receive
   our products and services, such as banking information and demographic
   information 

 * Account-related and transaction data, such as account number, balance and
   transactions and information about beneficiaries 

 * Recordings and transcripts of customer service calls and communications

 * Recordings of voiceprints and voice biometrics you provide for account
   services

 * Contact information you provide, such as name, email address, and telephone
   number(s) in order to receive transactional, product and marketing
   information from us

 * Device data, such as device type, web browser type and version, operating
   system type and version, internet protocol address, mobile network
   information, general location (e.g., city, state, or country), cookie IDs,
   device IDs, mobile advertising IDs, and likely connections among different
   browsers and devices that you use 

 * Online/mobile activity data, such as login data, search history, language,
   statistical identifiers, and information about how you use and interact with
   our Online Services or advertising

 * Marketing data, such as marketing preferences, information about products or
   services we think you might like, and inferences based on your interactions
   with us or information we learn about you

 * Communications data, such as your communication preferences and details or
   the content of your communications with us 

 * Inferences drawn from any of the information identified in this subdivision
   to create a profile about a consumer reflecting the consumer’s preferences,
   characteristics, psychological trends, predispositions, behavior, attitudes,
   intelligence, abilities, and aptitudes

If you disclose any information relating to other people to us when you visit or
use our Online Services, you represent that you have the authority to do so and
to permit us to use the information in accordance with this Privacy Policy.

We retain personal information for a period of time as required by laws and
regulations and the necessary business purpose. We securely delete personal
information as soon as legally permitted and in accordance with our internal
retention policy.

 


HOW DOES INSPIRA FINANCIAL COLLECT MY PERSONAL INFORMATION? 
 

We collect information in a variety of contexts when you use our Online
Services. For example, we may collect information:

 * Directly from you - We collect information directly from you when you submit
   information to us, such as when you open an account or withdraw or deposit
   money, pay fees or conduct transactions through your account, use your credit
   or debit card or provide banking information, register for a product or
   service or request information about a product or service, submit or upload
   information or documents, or input in any free-text boxes or forms through
   our Online Services, or complete a survey, sweepstakes or other promotion.

 * Automatically when you use our Online Services - We, and others on our
   behalf, may collect the information described in this policy, such as device,
   online/mobile, or communications data, automatically when you interact with
   us online. This includes using cookies to collect information such as site
   visitorship and device data, user navigation and user behavior.

 * From our service providers – We may also collect information from third-party
   service providers who assist us in providing our services to you. These
   service providers may include your health insurance company or other third
   parties we contract with to provide our services.  We may receive information
   from these service providers in various ways.

We may also collect information in other contexts, such as from our phone calls,
chats and emails with you, or from third-party data sources for fraud
prevention, identity verification, or marketing purposes.

 


HOW CAN PERSONAL INFORMATION BE USED?

 

We use personal information that is collected about you for many purposes, such
as: 

 * Providing, maintaining and servicing your accounts and delivering products
   and services, by verifying your identity, processing applications for
   products or services such as to open an account, and processing transactions 

 * Determining your financial interests and needs in order to recommend relevant
   products and services

 * Authenticating your identity, preventing fraud, and keeping your information
   and financial transactions secure

 * Advertising and marketing

 * Optimizing your online and mobile experience and improving our products and
   services

 * Performing analytics using aggregated and de-identified information regarding
   your use of our Online Services

 * Complying with and enforcing applicable legal requirements, industry
   standards, contractual obligations and our policies

 * Managing workforce activities and personnel generally, including for
   recruitment, performance management, career development, payments
   administration, employee training, leaves and promotions

 


HOW DOES INSPIRA FINANCIAL PROTECT MY PERSONAL INFORMATION?

To protect your personal information from unauthorized access, use, or
disclosure, we maintain technical and organizational security measures that
comply with federal and state laws. These measures include computer safeguards,
secured files and restricted access to buildings, as well as training employees
to comply with privacy standards and policies which are designed to protect
personal information. 

 


WHEN CAN INFORMATION BE SHARED? 

We do not sell for money or otherwise share personal information about you,
except as described in this Online Privacy Notice.  We share personal
information with third parties who perform services on our behalf.  These third
parties are not authorized by us to use or disclose the information except as
necessary to perform services on our behalf or comply with legal requirements. 
We also may share the personal information we obtain with our affiliates and
joint marketing partners. 

We also may disclose information about you (i) if we are required to do so by
law or legal process, (ii) in response to requests by government agencies, (iii)
for the purpose of or in connection with legal proceedings, or otherwise for the
purpose of establishing, exercising or defending our legal rights, or (iv) when
we believe disclosure is necessary or appropriate to prevent physical harm or
financial loss, or in connection with an investigation of suspected or actual
fraudulent or illegal activity. 

If applicable to you, please refer to the U.S. Consumer Privacy Notices here:

inspirafinancial.com/privacy-policy/privacy/us-financial-consumer-privacy-notice

inspirafinancial.com/privacy-policy/privacy/us-health-consumer-privacy-notice

This Privacy Policy was last updated on January 8, 2024 and may be amended from
time to time.



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© 2024 Inspira Financial is the brand name used for products and services
provided by one or more of the Inspira Financial group of companies, including
Inspira Financial Trust, LLC (formerly known as Millennium Trust Company, LLC)
and Inspira Financial Health, Inc. (formerly known as PayFlex Systems USA,
Inc.). Retirement and custody services are provided by Inspira Financial Trust,
LLC and consumer directed benefits are administered by Inspira Financial Health,
Inc. Inspira Financial Trust, LLC and Inspira Financial Health, Inc. are
affiliates. Inspira Financial Trust, LLC and its affiliates perform the duties
of a directed custodian and/or an administrator of consumer directed benefits
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