Notice of Privacy

For Your Information Only – No Response Necessary

Healthcare Community Securities Corp. (HCSC) [1]
d/b/a HANYS Benefit Services (HBS) d/b/a Strategic Benefit Services (SBS)

On behalf of Healthcare Community Securities Corp. and certain affiliates, this privacy document outlines policies designed to maintain the privacy of your nonpublic personal information. This Notice of Privacy also applies to the Website as provided by the Healthcare Association of New York State, Inc. (“HANYS®”).

We do not sell any information to third parties. However, to conduct regular business, we do collect and retain certain nonpublic personal information under the following categories:

  • Identifying information/personal information: This may include information reported by you on applications or other forms you provide to us, such as your name, Social Security number, and address; information about your mutual fund or annuity transactions with us or our affiliates, such as account balance and transaction activity.
  • Internet or other similar network activity. This may include your browsing history, search history or information on your interaction with a website, application or advertisement.
  • Geolocation data. This includes your physical location only.

We obtain the information listed above (a) directly from you (for example, on applications or other forms that you submit to us), and (b) indirectly from you (for example, from monitoring our Website usage). We may also receive an address from a third party when you have moved.

We may use the use the information we collect from you for the following business purposes:

  • providing, support and/or improving our products and services;
  • understanding general traffic patterns to our Website;
  • managing data security;
  • complying with or enforcing, agreements with you;
  • sending marketing messages and advertisements; and
  • performing other business activities with your consent.

We may disclose nonpublic personal information about you to other businesses, along with HANYS and our parent company, to perform certain services as noted below. Nonpublic personal information includes:

  • information we receive from you on applications or other forms, such as your name, address and Social Security number; and
  • information about your transactions with us, our affiliates or others, such as your vested account balance.

We may disclose such nonpublic personal information to perform the following services:

  • disclosing your name and address to mail mutual fund-related materials, such as prospectuses, annual reports, amendments and quarterly account statements;
  • disclosing information to another businesses (record keeper, trust, and custodian) to process account transactions that you request or authorize;
  • support of the Website and manage data security;
  • provide advertisements to you;
  • disclosing information in connection with legal proceedings, such as responding to a subpoena; and
  • disclosing information to a buyer or other successor in the event of a sale of some or all of HCSC’s business or assets.

Information shared with other businesses is not allowed to be used for any purpose other than to assist our servicing of your account(s).

If you close your account(s) or we lose contact with you, we will continue to share information in accordance with our current privacy policy and practices.

Website cookies and technologies

HANYS uses cookies and technologies such as pixel tags, web beacons and other identifiers on the Website to (a) make sure the Website functions as it should; (b) recognize you when you return to the website (so you do not have to re-enter login details on subsequent visits); (c) analyze how the Website is performing and how visitors engage in the Website; (d) present you with customized options relating to your interests based on what you have clicked on when visiting the Website; (e) provide advertisements when you visit other websites; and (f) measure the success of advertising campaigns. We also use Google Analytics, a web analytic service provided by Google, Inc. (“Google Analytics”) and Hotjar, a web analytic service provided by Hotjar Limited. These services help us track traffic on the Website to include which pages were accessed and how often, for which period of time a page was viewed and what links were clicked.

If you do not want HANYS, Google Analytics. Hotjar, Feathr or third other third parties to collect information about you through the use of cookies, then you have the will have the option to opt out with them.

If you do not want HANYS to collect information about you through the use of cookies, you have the option to delete or disable cookies on your internet browser. If you choose to delete or disable HANYS’ use of cookies, then the functionality of the Website will be impaired.

The HANYS Cookie Policy may be viewed at: http://strategicbenefitservices.com/legal/cookies/.

Safeguarding your nonpublic personal information

HCSC will internally safeguard your nonpublic personal information by restricting access to only those employees who provide products or services to you or those who need access to your information to service your account. In addition, we maintain physical, electronic, and procedural safeguards that meet federal and/or state standards to guard your nonpublic personal information. However, HCSC cannot and does not give absolute assurance any information you transmit to us will not be accessed inappropriately by third parties.

If you are under the age of 18, please do not use or access the Website. It is not our intention to collect or use personal information from anyone under 18 years of age, and we will not knowingly do so. If we are made aware that we have collected any personal information from children under the age of 18 and are asked to delete such information from our system, we will promptly do so.

For California residents only

As of Jan. 1, 2020, the California Consumer Privacy Act (CCPA) provides residents of the State of California with certain rights regarding the collection of personal information. Please note that the rights described under CCPA relating to personal information may not apply to all the information that HCSC collects because a large amount of the information that is collected and used by HCSC is excluded from CCPA’s scope or exempted from its provisions (for example, health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA “), the Fair Credit Reporting Act (“FCRA”), and the Gramm-Leach-Bliley Act (“GLBA”).

Please see the “Addendum to HCSC‘s Notice of Privacy: Compliance with the California Consumer Privacy Act” for more information.

The Website is not designed to respond to “do not track” requests from web browsers.

HCSC reserves the right at any time to change the Notice of Privacy for any reason. Any change will be disclosed to you via a mailing if you have an account with HCSC. You agree to review the Notice of Privacy when received by mail.

Updated versions of the Notice of Privacy will also be posted to the Website. For Website users, you agree to review the Notice of Privacy periodically to be aware of such changes. Your continued access or use of the website shall be deemed your conclusive acceptance of the Notice of Privacy, as modified.

Our privacy policy applies to customers that have a direct relationship with HCSC (One Empire Drive, Rensselaer, NY 12144) and its affiliates. If you receive investment services in the name of a third party broker dealer, bank or other financial service provider, that third party’s privacy policies may apply to you and our privacy policy may not.

If you have any questions about this privacy policy, please call (800) 388-1963.

If you choose to use the Website, your visit and any dispute over privacy is subject to this Notice of Privacy and the HANYS Website Terms of Use, including limitations on damages and application of the law of the State of New York.

Effective December 2020

1 HCSC is a wholly-owned subsidiary of Group Insurance Agency, Inc. ("GIA"), which itself is a wholly-owned subsidiary of HANYS.