Privacy Policy

Sompo Services Privacy Policy

Last Updated: August 22nd, 2023

Sompo Horizons LLC and its subsidiaries and affiliates (collectively, Sompo or we) offer(s) a web and mobile web service and other related services that facilitate caregiving planning by employees and care team members for care recipients (Sompo Services). Sompo provides this Privacy Policy to explain the personal information that Sompo processes and how and why Sompo processes it.

I.  KEY DEFINITIONS

For your convenience, many of the capitalized terms that we use in this Privacy Policy are defined in this Section:

  • Business Purposes means performing the Sompo Services; managing and processing interactions and transactions with Users; securing and debugging the Sompo Services; advertising and marketing; quality assurance; research and development; and other Business Purposes as may be defined in CCPA from time to time.
  • User (or you) means the person accessing and using the Sompo Services to help with caregiving responsibilities.
  • personal information means information that identifies or can be used to identify an individual person.
  • processing means any operation (or set of operations) performed on personal information, such as collecting, combining, and storing personal information.
  • sale or selling means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a User’s personal information by Sompo to a third party for monetary or other valuable consideration.
  • share or sharing means sharing, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating a User’s personal information by Sompo to a third party for cross-context behavioral advertising.
  • Sompo Partners means businesses that offer products and services through Sompo Services.
  • U.S. Privacy Laws means the California User Privacy Act (as amended by the California Privacy Rights Act) (CCPA); Colorado Privacy Act (CPA); Connecticut’s Act Concerning Personal Data Privacy and Online Monitoring (CTPA); Utah User Privacy Act (UCPA); and Virginia User Data Protection Act (VCDPA); each as amended, repealed, consolidated or replaced from time to time.
  • Vendors means service providers that process personal information on behalf of Sompo and contractors and other organizations with which Sompo shares personal information pursuant to a contract for Business Purposes.

This Privacy Policy also serves as our Notice at Collection for purposes of CCPA.

II.  WHEN AND WHERE DOES THIS PRIVACY POLICY APPLY?

  • This Privacy Policy covers the twelve (12) months prior to the Last Updated date and is updated at least once per year. If Sompo’s processing materially changes between updates to this Privacy Policy, Sompo will provide a supplemental notice when or before the changes apply.
  • This Sompo Services Privacy Policy applies to individuals who reside in the United States.

III.  TO WHICH PROCESSING DOES THIS PRIVACY POLICY APPLY?

This Privacy Policy applies to Sompo’s collection, use, disclosure and other processing of your personal information.

Sompo collects personal information:

  • directly from you
  • from your computer and mobile devices
  • from our affiliates
  • from our service providers
  • from public sources of data
  • from other businesses or individuals

Generally, Sompo processes personal information to provide the Sompo Services and as otherwise related to the operation of our business, including for Business Purposes.

Sompo also discloses personal information: to our Vendors; to you or to other third parties at your direction or through your actions; for the additional purposes explained at the time of collection; as required or permitted by applicable law; to the government or private parties to comply with law or legal process or protect or enforce legal rights or obligations or prevent harm; and as part of an acquisition, merger, asset sale or other transaction in which a third party assumes control over all or part of Sompo’s business. These disclosures are concluded in a context that is not a “sale” or “share” (as defined in the U.S. Privacy Laws.)

Subject to restrictions and obligations under U.S. Privacy Laws, our Vendors also may use your personal information for Business Purposes and other approved purposes, as well as may engage their own Vendors to help perform services for us.

IV.  WHAT ARE OUR PERSONAL INFORMATION PROCESSING AND DISCLOSURE PRACTICES?

This table sets out the personal information we collect:

Categories of Personal Information

1. Identifiers including name, alias, postal address, unique personal identifiers, online identifier, Internet Protocol address, e-mail address, and account name.

2. Personal Records 

including name, signature, description, address, telephone number, and financial information

3. Personal Characteristics or Traits

including age, gender, nationality, race, or medical conditions

4. Customer Account Details/Commercial Information

including records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

5. Internet Usage Information

including browsing history, search history, and other information regarding your interaction with the Sompo Services.

6. Geolocations

7. Sensory Data

8. Professional or Employment Information

9. Inferences From Personal Information Collected

Categories of Recipients

  • Service providers that perform services on our behalf (e.g., data analytics, data security, cloud storage, and ecommerce providers.)
  • Sompo partners.
  • Potential or actual acquirers or investors, in connection with an actual or proposed merger, acquisition, or investment.
  • Professional advisers, such as lawyers, accountants, insurers, and information security and forensics experts.
  • Governmental entities and competent law enforcement and/or
  • Other third parties, with your consent.


       Sale/Share: Share.

  • Service providers that perform services on our behalf (e.g., data analytics, data security, cloud storage, and ecommerce providers.)
  • Sompo partners.
  • Potential or actual acquirers or investors, in connection with an actual or proposed merger, acquisition, or investment.
  • Professional advisers, such as lawyers, accountants, insurers, and information security and forensics experts.
  • Governmental entities and competent law enforcement; and/or
  • Other third parties, with your consent.


       Sale/Share: Share.

       Same as 1. above

       Sale/Share: Share

  • Marketing Vendors that help promote the Service.
  • Service providers that perform services on our behalf (e.g., data analytics, data security, cloud storage, and ecommerce providers.)
  • Sompo partners.
  • Potential or actual acquirers or investors and their professional advisers, in connection with an actual or proposed merger, acquisition, or investment.
  • Our professional advisers, such as lawyers, accountants, insurers, and information security experts.
  • Governmental entities and competent law enforcement.
  • Other third parties, with your consent.


      Sale/Share: Share

       Same as 7. above

       Sale/Share: Share

  • Marketing Vendors that help promote the Service.
  • Service providers that perform services on our behalf (e.g., data analytics, data security, cloud storage, and ecommerce providers.)
  • Sompo Partners.
  • Potential or actual acquirers or investors and their professional advisers, in connection with an actual or proposed merger, acquisition, or investment.
  • Our professional advisers, such as lawyers, accountants, insurers, and information security experts.
  • Governmental entities and competent law enforcement.
  • Other third parties, with your consent.


       Sale/Share: Share

  • Marketing Vendors that help promote the Service.
  • Service providers that perform services on our behalf (e.g., data analytics, data security, cloud storage, and ecommerce providers.)
  • Sompo Partners.
  • Potential or actual acquirers or investors and their professional advisers, in connection with an actual or proposed merger, acquisition, or investment.
  • Our professional advisers, such as lawyers, accountants, insurers, and information security experts.
  • Governmental entities and competent law enforcement.
  • Other third parties, with your consent.


       Sale/Share: Share

       Same as 7. above

       Sale/Share: Share

       Same as 7. above

       Sale/Share: Share

Purpose for Disclosure

  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Commercial purposes, including advertising and marketing.
  • Internal research, quality, and safety.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes, including advertising and marketing.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes, including advertising and marketing.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes, including advertising and marketing.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes, including advertising and marketing.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes, including advertising and marketing.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes, including advertising and marketing.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes, including advertising and marketing.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes, including advertising and marketing.

Category of Sensitive Personal Information

10. Account Log-In

including username and password to online account

11. Financial Data

including financial account numbers or credentials.

12. Precise Geolocation

13. Sensitive Personal Characteristics

including racial or ethnic origin, religious or philosophical beliefs, citizenship or immigration status, or union membership

14. Genetic Data

Categories of Recipients

       Same as 7. above

       Sale/Share: N/A

       Same as 7. above

       Sale/Share: N/A

  • Marketing Vendors that help promote the Service.
  • Service providers that perform services on our behalf (e.g., data analytics, data security, cloud storage, and ecommerce providers.)
  • Sompo Partners.
  • Potential or actual acquirers or investors and their professional advisers, in connection with an actual or proposed merger, acquisition, or investment.
  • Our professional advisers, such as lawyers, accountants, insurers, and information security experts.
  • Governmental entities and competent law enforcement.
  • Other third parties, with your consent.


       Sale/Share: N/A

       Same as 12. above

       Sale/Share: N/A

       Same as 12. above

       Sale/Share: N/A

Purpose for Collection / Disclosure

  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes, including advertising and marketing.
  • Auditing related to counting impressions, positioning and quality of ads.
  • Security and debugging.
  • Short-term, transient use.
  • Performing services (to maintain accounts, verify user identity, and facilitate purchases).
  • Internal research, quality, and safety.
  • Commercial purposes, including advertising and marketing.
  • Security and debugging.
  • Short-term, transient use.
  • Internal research, quality, and safety.

Retention periods for the above categories of personal information may vary. Sompo retains personal information for as long as we have a legitimate purpose for doing so. Generally, Sompo retains personal information for as long as the User account is active and otherwise for as long as necessary to carry out the purposes described above. Sompo also retains personal information for as long as Sompo believes necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements.

V.  WHAT USER PRIVACY RIGHTS ARE AVAILABLE TO YOU?

 1. Privacy Rights

Subject to our verification requirements, Sompo provides Users with the privacy rights described in this section. 

To submit a privacy rights request or to submit a request as an authorized agent, use our Contact Us link https://sompohorizon.com/contact/ or email us at [email protected]. Sompo does not accept or process requests through other means.

  a. Right to Know/Access

You have the right to request access to personal information collected about you and information regarding the source of that information, the purposes for which we collect it and the third parties and service providers with whom we share it. You are entitled to access your personal information up to twice in a 12-month period, with subsequent requests subject to a service fee.

You may request any of the following for the period that is 12-months prior to the request date:

    • Categories of Personal Information, including the categories we have collected from you; the categories of sources from which we have collected your personal information; the Business Purposes or commercial purposes for our collecting, selling or sharing your personal information; the categories of third parties to whom we have disclosed your personal information; a list of the categories of personal information disclosed for a Business Purpose and, for each, the categories of recipients or that no disclosure occurred; a list of the categories of personal information sold or shared about you and, for each, the categories of recipients or that no sale or share occurred.
    • Specific Pieces of Personal Information, including confirmation that we are processing your personal information and, if we are, to obtain a transportable copy, subject to applicable request limits, of your personal information that we have collected and are maintaining. For your specific pieces of personal information, as required by applicable U.S. Privacy Laws, Sompo will apply heightened verification standards. We have no obligation to re-identify information or to keep personal information longer than we need it or are required to by applicable law to comply with access requests.

  b. Right to Delete

You have the right to request that we delete your personal information unless Sompo has a basis for keeping it under applicable law.

  c. Right to Correct

You have the right to correct inaccurate personal information about you that Sompo maintains. Correction requests are subject to certain limitations, and we may choose to delete rather than correct your personal information in some circumstances.

  d. Do Not Sell / Share / Target

U.S. Privacy Laws have broad and differing concepts of “Selling” personal information for which an opt-out is required, and “Sharing” for “Cross-Context Behavioral Advertising” (i.e., use of personal information from different businesses or services to target advertisements). States also have an opt-out of “Targeted Advertising” (defined differently but also addressing tracking, profiling and targeting of advertisements). Sompo may sell or share your personal information and/or use your personal information for Targeted Advertising, as these terms apply under U.S. Privacy Laws.

Sompo provides Users an opt-out of Sale/Sharing/Targeting that is intended to combine these state opt-outs into a single opt-out available regardless of state of residency.

Third-party digital business may associate cookies and other tracking technologies that collect personal information about you on the Sompo Services or otherwise collect and process personal information that we make available about you, including digital activity information. We understand that giving access to personal information on the Sompo Services or otherwise to third-party digital business could be deemed a sale and/or share under some U.S. Privacy Laws and thus Sompo will treat such personal information (e.g., cookie ID, IP address and other online IDs and internet or other electronic activity information) collected by third-party digital business, where not limited to acting as our service provider, as a sale and/or share and subject to a Do Not Sell/Share/Target opt-out request. We will not sell your personal information, share your personal information for Cross-Context Behavioral Advertising or process your personal information for Targeted Advertising if you make a Do Not Sell/Share/Target opt-out request.

Opt-out for non-cookie personal information: If you want to limit our processing of your non-cookie personal information (e.g., your email address) for Targeted Advertising or opt-out of the sale/sharing of such data, make an opt-out request to [email protected]. 

Opt-out for cookie personal information: If you want to limit our Processing of your cookie-related personal information for Targeted Advertising or opt-out of the sale/sharing of such personal information, you need to opt-out using our cookie management tool enables you to exercise such an opt-out request and enable certain cookie preferences on your device. Since your browser opt-out is designated by a cookie, if you clear or block cookies, your preferences are no longer effective, and you must enable them again via our cookie management tool. Beware that if you use ad blocking software, our cookie banner may not appear when you visit the Sompo Services, and you may have to use the link above to access the tool. 

We do not knowingly sell or share the personal information of Users under 16, unless we receive affirmative authorization (“opt-in”) from either the User who is between 13 and 16 years old or the parent or guardian of a User who is less than 13 years old. If you think we may have unknowingly collected personal information of a User under 16 years old, please contact us at [email protected].

Sompo may disclose your personal information for the following purposes, which are not a sale or share:  (i) if you direct us to disclose personal information; (ii) to comply with any User rights request you submit to us; (iii) disclosures amongst the entities that constitute Sompo or as part of a Corporate Transaction; and (iv) as otherwise required or permitted by applicable law.

  e. Right to Limit Sensitive Personal Information Processing

For personal information that qualifies as sensitive personal information under U.S. Privacy Laws, you have the right to request that we limit our use of your sensitive personal information. U.S. Privacy Laws do not allow you to limit the following processing purposes: (i) that which is necessary to perform the services reasonably expected by the average User; (ii) to ensure security and integrity; (iii) short term transient use; (iv) performing services for you; and (v) maintaining the quality or safety of the Sompo Services.

 2. How to Exercise Your Privacy Rights

To submit a request to exercise your User privacy rights or to submit a request as an authorized agent, visit https://sompohorizon.com/contact/, call us at 1-347-218-5847 or email us at [email protected].  Please check for and respond to any follow-up inquiries we make. Please be aware that we do not accept or process requests through other means (e.g., via fax).

 3. Verification of Privacy Rights Requests

To submit your request, please be prepared to provide verifying information, such as your name, email address, telephone number, and/or account information. We will not fulfill your Right to Know / Access, Right to Delete or Right to Correct request unless you have provided sufficient information for us to reasonably verify you are the User about whom we collected personal information.  We do not verify opt-outs of Sell/Share/Target or Limitation of Sensitive personal information requests unless we suspect fraud.

To protect Users, if we are unable to verify a privacy rights request, we are unable to honor the request. We will use personal information provided in a verified privacy rights request only to verify identity or authority to make the privacy rights request and to track and document responses unless Sompo also received the personal information for another purpose.

 4. Agent Requests

You may use an authorized agent to make a request for you, subject to our verification of the agent, the agent’s authority to submit requests on your behalf and of you. Any request submitted by your agent is subject to an identity verification process (except Do Not Sell/Share/Target requests).  Generally, we will request that your agent provide proof, such as a signed affidavit indicating you permitted your agent to submit the request on your behalf and as allowed by U.S. Privacy Laws, we may also require you to either verify your identity or directly confirm with us that you provided the agent permission to submit the request.  Once your agent’s authority is confirmed, they may exercise rights on your behalf subject to the agency requirements of applicable U.S. Privacy Laws.

 5. Appeals of Privacy Rights Requests

You may appeal Sompo’s decision regarding a request by email at [email protected]. Please use the same email address that you used to submit the initial request to submit your Request to Appeal. Otherwise, we may not be able to tie your Request to Appeal to your initial request.

 6. Sompo’s Responses to Your Privacy Rights Requests

We aim to complete requests as soon as reasonably practicable. Please note that it may take additional time to verify and fulfill agent-submitted requests. If you have an account with us, you may also make certain changes directly through your account profile page.

Some personal information that we maintain is insufficiently specific for us to be able to associate it with a verified User (e.g., data tied only to a pseudonymous browser ID). We do not include that personal information in response to those requests.  If we deny a request, in whole or in part, Sompo will explain the reasons in our response. 

Sompo will make commercially reasonable efforts to identify personal information that we process to respond to a privacy rights request.  In some cases, particularly with voluminous and/or typically irrelevant data, we may suggest you receive the most recent or a summary of your personal information and give you the opportunity to elect whether you want the rest.  We reserve the right to direct you to where you may access and copy responsive personal information yourself.  We will typically not charge a fee to fully respond to your requests; provided, however, that we may charge a reasonable fee or refuse to act upon a request, if your request is excessive, repetitive, unfounded or overly burdensome.  If we determine that the request warrants a fee or that we may refuse it, we will give you notice explaining why we made that decision.  You will be provided a cost estimate and the opportunity to accept such fees before we will charge you for responding to your request.

VI.  WHAT ELSE DO USERS NEED TO KNOW?

 1. Non-Discrimination / Non-Retaliation

We will not discriminate against you for exercising your rights under the U.S. Privacy Laws. We may charge a different price or rate or offer a different level or quality of good or service, to the extent that doing so is reasonably related to the value of the applicable personal information.

 2. Notice of Financial Incentive Programs

We may offer discounts or other benefits to users enrolled in certain rewards or promotional programs.

Sompo Services does not generally assign monetary or other value to Users’ personal information and our promotions activity changes continually. To the extent the law requires that a value be assigned to such programs, or the price or service differences they involve, Sompo Services values the personal information collected and used under each program as being equal to the value of the discounts or other financial incentives provided in each such program, based upon a practical and good-faith effort to assess on an aggregate basis for all collected information: (1) the type of personal information collected in each program (e.g., email address), (2) the use of such information by Sompo Services in connection with its marketing activities, (3) the range of discounts provided (which can depend on each User’s purchases under such offers), (4) the number of individuals enrolled in respective programs, and (5) the products for which the benefits (such as price difference) can apply. These values can change over time. Note that this description is without waiver of any proprietary or business confidential information, including trade secrets, and it does not constitute any representation about generally accepted accounting principles or financial accounting standards.

 3. Our Rights and the Rights of Others

Sompo may collect, use and disclose your personal information as required or permitted by applicable law, which may override your rights under U.S. Privacy Laws. Sompo is not required to honor requests if doing so would infringe Sompo’s or another party’s rights or conflict with applicable law.

 4. California Shine the Light Law

We may share personal information with third parties for such third parties’ own direct marketing purposes. California residents may opt-out of this sharing by contacting us at [email protected] or [email protected] (Attn: Privacy).

You must put the statement “Shine the Light Request” in the body of your correspondence. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. This right is different than, and in addition to, the privacy rights above, and must be requested separately. However, a Do Not Sell/Share/Target opt-out is broader and will limit our sharing with third parties for their own direct marketing purposes without the need for making a separate Shine the Light request. We will not accept Shine the Light requests by telephone or by fax and are not responsible for requests not labeled or sent properly, or that are incomplete.

VII.  HOW CAN I CONTACT SOMPO WITH QUESTIONS?

If you have questions or comments about this Privacy Policy or Sompo’s privacy practices, please contact us:

  • by email at [email protected]
  • by phone number at 1-844-729-0706
  • by mail at: 1221 Avenue of the Americas, 18th Floor, New York, NY 10020