NEA Member Benefits Privacy Policy

Effective: July 1, 2020.

I. INTRODUCTION

NEA Member Benefits (NEA MB) is a nonprofit corporation that values the trust and privacy of National Education Association (NEA) members and others. Our privacy practices are aimed at supporting our nonprofit mission of serving NEA members and providing them with valuable benefits to make their lives better. This Privacy Policy explains: (1) the types of information that we collect and how we collect it—whether online through the NEA MB Website, our mobile applications, our email communications or short messaging services (SMS) or offline through paper forms, telephone conversations, or data exchanges with NEA MB-Related Organizations and our Product Providers; (2) how we use it; (3) under what circumstances it is shared; (4) what choices are available; and (5) what security we use to protect it. This Privacy Policy also provides some additional information for users of the NEA MB Website, along with certain disclosures for California and Nevada residents. If you have any questions regarding our privacy practices, please contact us at privacy@neamb.com.

II. DEFINITIONS

As used in this Privacy Policy, the following terms have the meanings indicated below:

  1. “We” or “us” means NEA Member Benefits, a nonprofit corporation with its headquarters located in Gaithersburg, Maryland.

  2. “You” means a current or former NEA member, NEA MB program or product participant, person who has used the NEA MB Website or our mobile applications or has subscribed to an NEA MB-produced electronic communication, such as our email communications or SMS, or any other person about whom we collect personal information.

  3. “Cookie” means a small file that is placed on your computer (or mobile device) when you are viewing a website. The cookie contains a unique device identifier, and can be linked to Personal Information if you register to use the website. There are both session cookies (which expire when you close your web browser) and persistent cookies (which stay on your computer or mobile device until the cookies expire or you delete them).

  4. “NEA MB Website” means NEA MB’s external website located at neamb.com and any related future websites that we may develop for NEA members.

  5. “NEA MB-Related Organization” means NEA, its state or local affiliates, NEA Members Insurance Trust, NEA Foundation, NEA Professional Services Corporation, NEA 360, LLC, or any other entity created by or affiliated with NEA MB or NEA.

  6. “Non-Personal Information” means anonymous, deidentified or aggregate data that cannot reasonably be used to identify you or publicly available information, that is, information that is lawfully available from federal, state, or local government records. To the extent that Non-Personal Information is combined or linked with Personal Information, it will be treated as Personal Information unless it is later de-identified from the Personal Information.

  7. “Personal Information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or can reasonably be linked, directly or indirectly, to an individual or household. The types of Personal Information that we collect, are described in more detail in Section III.

  8. “Product Provider” is a Third Party that offers NEA MB products or services to NEA members through NEA MB. Our Product Providers deliver the products and services featured on the NEA MB Website.

  9. “Third Party” means an individual or entity that is not affiliated with NEA MB or any NEA MB-Related Organization. As used in this Privacy Policy, Product Providers, Vendors, and social and digital advertising networks are types of Third Parties.

  10. “Tracking Pixel” means a tiny digital image embedded on a webpage or in an email. Tracking pixels are also referred to as web beacons or tags.

  11. “Tracking Technologies” mean Cookies, Tracking Pixels, or other similar identifiers.

  12. “Vendor” is a Third Party that performs services on behalf of NEA MB, such as our print mail and email vendors, data analytics providers, or data brokers.

III. TYPES OF PERSONAL INFORMATION COLLECTED AND HOW WE COLLECT IT


We collect the following types of Personal Information about you in the following ways:

  1. Personal Information That You Voluntarily Provide Us Or An NEA MB-Related Organization

    We collect your Personal Information when you voluntarily provide it to us or an NEA MB-Related Organization. For example, when you join NEA and your state and local affiliates, you voluntarily provide certain Personal Information as part of the membership enrollment process and that Personal Information is shared with us so that we may provide you with valuable member benefits. Below are the types of Personal Information that we may collect from you directly or indirectly through an NEA MB-Related Organization:
    • Contact Information: This includes, but is not limited to, name, postal address, email address, and telephone number;
    • Demographic Information, including certain legally protected characteristics: This includes, but is not limited to, birthdate, age, gender, marital status, and familial relationships;
    • Professional/Employment-Related Information: This includes, but is not limited to, your employer and grade level that you teach;
    • Membership Information: This includes, but is not limited to, membership type, dates, and cancellations;
    • NEA Members Insurance Trust Information: This includes, but is not limited to, beneficiary information, claims information, death date, last four digits of social security number, and other Personal Information that you provide or that we receive in connection with NEA Members Insurance Trust products;
    • NEA MB Member Advocacy Center Communications: This includes, but is not limited to, any Personal Information provided in communications to and from the NEA MB Member Advocacy Center;
    • Website Registration Information: This would include, but is not limited to, login and access credentials when you register to use the NEA MB Website, such as username; and
    • Communications, Preferences, and Similar Personal Information: This includes, but is not limited to, our communication history with you and any requests by you to opt-out of communications, signup for communications, or make requests under this Privacy Policy.
  2. Personal Information That We Receive From Third Parties

    We collect Personal Information about you from Third Parties, such as our Product Suppliers and Vendors. For example, when you purchase an NEA MB product or service, our Product Supplier may notify us of that purchase so that we can better manage our programs and assist if you encounter any problems. We also license Personal Information from data brokers to update and improve the Personal Information that we already maintain to efficiently and effectively serve NEA members. Below are the types of Personal Information that we may collect from Third Parties:
    • MB Products Purchased or Obtained: This includes, but is not limited to, NEA MB products or services purchased or obtained;
    • Demographic Information, including certain legally protected characteristics: This includes, but is not limited to, birthdate, age, gender, marital status, familial relationships, home owner status and other similar demographic information that we receive from Third Parties;
    • Professional/Employment-Related Information: This includes, but is not limited to, grade level that you teach;
    • Commercial Information: This includes, but is not limited to, consumer purchasing tendencies; and
    • NEA Members Insurance Trust Information: This includes, but is not limited to, beneficiary information, claims information, death date, last four digits of social security number, and other Personal Information provided by Product Providers in connection with NEA Members Insurance Trust products.
  3. Personal Information Collected Through Technology

    We collect information, some of which is Personal Information, through technology when you use the NEA MB Website or mobile applications or when we communicate with you via email, SMS or other digital channels. For example, we use standard technologies, such as Tracking Technologies and Vendor-provided web analytics tools, to tailor articles, advertisements, products and services that are offered to you and to measure and assess the effectiveness of our digital communications.

    We also work with Third Parties that use Tracking Technologies to serve advertisements tailored to meet your interests while on the NEA MB Website or other sites on the Internet. While we use Tracking Technologies as described in this Privacy Policy, any Third Party use of Tracking Technologies is governed by their own privacy policies, not ours.

    Below are the types of information that we may collect from you through technology when you use the NEA MB Website, our mobile applications and other digital communications:
    • Device Information: This includes, but is not limited to, browser type, operating system version, device type (e.g., laptop, iphone, tablet), Internet service provider (ISP), and other related information for that device;
    • Unique Electronic Identifiers: This includes, but is not limited to, your internet protocol (IP) address, device identifiers and other similar unique electronic identifiers;
    • Website Activity Information: This includes, but is not limited to, the date and time that you visit the NEA MB Website, the files downloaded and the web pages that you view on the NEA MB Website (including the time spent on each page), and the address of the previous website that you visited and the next website that you visit if such websites are linked to the NEA MB Website;
    • Email Activity Information: This includes, but is not limited to, whether you opened an email communication from us or clicked on a link contained therein;
    • Location Information: Your IP address may be used to generally estimate your location, but we do not collect information that identifies your precise physical location; and
    • Audio, Electronic, or Similar Sensory Information: This includes, but is not limit to, audio recordings and chat of your communications to the NEA MB Member Advocacy Center which are recorded and collected for quality assurance purposes.
  4. Inferred Personal Information

    We derive Personal Information or draw inferences about you using Personal Information that we collect, such as MB Product Participation, Email Activity, and Website Activity. For example, we may create models that we use to tailor offers based on your preferences and past behaviors, and we may share such models with our Product Providers. Similarly, our Product Providers may also create such models about you and share them with us.

IV. HOW WE USE YOUR PERSONAL INFORMATION


We use the Personal Information that we collect to support our nonprofit mission of serving NEA members and providing them with valuable benefits to make their lives better. This includes, but is not limited to, the following specific uses:
  • To communicate with NEA members;
  • To confirm eligibility for NEA member benefits when a person seeks to purchase or use an NEA MB product or service or registers to use the NEA MB Website;
  • To manage the NEA MB program, products and services;
  • To provide administrative and marketing services to the NEA Members Insurance Trust;
  • To respond to NEA member requests and inquiries, including investigating and resolving any concerns or complaints;
  • To ensure quality interactions with our representatives in the NEA MB Member Advocacy Center;
  • To fulfill requests for content and information;
  • To facilitate the creation of and securely manage NEA MB Website registrations;
  • To keep records related to our marketing communications with NEA members and NEA member preferences for such communications, including requests to opt-out;
  • To personalize the NEA MB Website experience by delivering curated content, products, and other digital communications, including advertisements, that are valuable to NEA members;
  • To test, measure, assess, and improve the NEA MB program, products and services, the NEA MB Website, including, but not limited to, performing data analytics and modeling data;
  • To conduct contests, giveaways, and surveys;
  • To maintain the security of the NEA MB products and services, the NEA MB Website, our databases and other digital infrastructure;
  • To comply with applicable law; and
  • To perform other legitimate business purposes consistent with our brand values and nonprofit mission of serving NEA members.
We may also create Non-Personal Information from Personal Information by excluding information, like your name, that would allow identification of a specific person. We may use such Non-Personal Information, along with other Non-Personal Information that we may receive from Third Parties to analyze performance and usage of products and services; improve our products and services; and manage the NEA MB program.

V. HOW WE SHARE YOUR PERSONAL INFORMATION

In order to efficiently and effectively serve NEA members in support of our nonprofit mission, we routinely share the Personal Information that we collect about you, as described in Section III (Types of Personal Information Collected and How We Collect It) with NEA MB-Related Organizations. We also share Personal Information with Third Parties as described below:
  • Product Providers: We share Personal Information with our Product Providers. Through legal contracts, we require that our Product Providers treat any Personal Information that we share as confidential, and use it solely in connection with the NEA MB program. If you purchase a product from our Product Providers, our Product Providers will separately collect Personal Information about you, and may share some of it with us, as described in Section III (Types of Personal Information Collected and How We Collect It). We will use this Personal Information as described in Section IV (How We Use Your Personal Information). Our Product Providers will use any Personal Information that they independently collect as described in their own privacy policies.
  • Vendors: We share Personal Information with our Vendors. Like our Product Providers, our Vendors are required by legal contracts to treat any Personal Information that we share as confidential, and to use it solely to provide the services that they perform on our behalf.
  • Social and Digital Advertising Networks: We share Personal Information with social and digital advertising networks to deliver targeted advertising on their network. The Personal Information shared is limited (generally email address, phone number, and/or physical address) and is used by the network to confirm delivery of our content to the proper recipient. Your ability to opt-out of such content is governed by the privacy policies of the social and digital advertising networks, not this Privacy Policy.
  • In addition to the above disclosures, we also may share your Personal Information with other Third Parties as follows:
    • To comply with applicable law;
    • To perform a legitimate business purpose that is consistent with our brand values and nonprofit mission of serving NEA members;
    • To protect against any security threats, fraud and other wrongdoing; and
    • In accordance with any consents that you may provide us.
Any shared Personal Information, when transmitted via electronic means or otherwise, is secured and protected from unauthorized use. Finally, we routinely share Non-Personal Information that we collect with Third Parties in support of the NEA MB program.

VI. WHAT CHOICES ARE AVAILABLE TO YOU

Below are the choices available to you regarding how we treat your Personal Information:

  1. Updating Your Personal Information
    NEA members may update their personal information at any time. Please contact us at ask-us@neamb.com or 1-800-637-4636 to update your information.

  2. NEA MB-Produced Electronic Communications
    If you subscribe to any NEA MB-produced electronic communication, whether online, SMS- or email-based, you may opt out at any time by following the instructions contained in any such communications. If you have any problems, please contact us at ask-us@neamb.com.

  3. Cookies
    Most web browsers are set to accept cookies by default. If you wish, you may be able to set your web browser to reject or remove cookies. Check the “help” section of your web browser to learn how to modify your cookie preferences. Please note that, if you opt to limit the use of cookies, some parts of NEA MB Website may not function properly and you may not be able to obtain certain content, products or services.

VII. HOW WE PROTECT YOUR PERSONAL INFORMATION


We maintain administrative, technical, and physical safeguards designed to: (1) provide security and confidentiality of your Personal Information; (2) protect against any anticipated threats or hazards to the security or integrity of such information; and (3) protect against unauthorized access to or use of such information. For more information on our information security policies, please contact us at privacy@neamb.com to request a copy of the NEA MB Information Security Program.

VIII. ADDITIONAL INFORMATION FOR USERS OF THE NEA MB WEBSITE

  1. Children
    The NEA MB Website is a general website, and we do not knowingly collect any Personal Information from children under the age of 13 or knowingly allow such persons to provide us with their Personal Information.

  2. External Links
    This Privacy Policy applies only to the NEA MB Website. It does not cover any websites that are linked to or from the NEA MB Website for which we are not responsible (“linked-sites”). These linked-sites will have their own policies and practices which may be different from ours. We encourage you to familiarize yourself with the policies and practices of the linked-sites especially if you provide Personal Information to them.
IX. ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

If you are a California resident, you have the right under state law to ask entities with whom you have an established business relationship to provide certain information regarding the sharing of Personal Information for direct marketing purposes during the past 12 months. NEA MB will honor such a request coming from any current or former NEA member or other person who has provided personal information to us in connection with obtaining an NEA MB product or service—whether residing in California or not—submit a request to us at one of the following addresses: privacy@neamb.com or NEA MB Office of the General Counsel, 900 Clopper Rd., Ste. 300, Gaithersburg, MD 20878-1356, and we will respond within 30 days of receiving your request.

X. ADDITIONAL INFORMATION FOR NEVADA RESIDENTS

If you are a Nevada resident, you have the right under state law to opt-out of the sale of certain types of Personal Information collected online, such as name, postal address, and email address. If you exercise that right, it means that website operators must ensure that such Personal Information is not sold to a Third Party that will further license or sell the Personal Information to others. If you are a Nevada resident and would like to opt-out of such sales, submit a request to us at one of the following addresses: privacy@neamb.com or NEA MB Office of the General Counsel, 900 Clopper Rd., Ste. 300, Gaithersburg, MD 20878-1356, and we will respond within 60 days of receiving your request.

XI. EFFECTIVE DATE, AMENDMENTS, AND CONSENT TO THIS PRIVACY POLICY

This Privacy Policy is effective July 1, 2020. We retain the right to amend or otherwise update this Privacy Policy at any time for any reason. By joining the NEA or using the NEA MB Website, you consent to the collection, use, and sharing of personal information as we have described herein. If we amend or update our Privacy Policy, we will post the changes online at the NEA MB Website so that you are always aware of NEA MB’s current practices. Your continued use of the NEA MB Website constitutes your acceptance of any such revised privacy policies.

XII. CONTACT US

If you have any questions regarding this Privacy Policy, please contact us at privacy@neamb.com.