Privacy Policy
Last Updated: November 9, 2023
Welcome to the website (the “Site”) of Pasito, Inc. (“we,” “us,” or “our”). Through the Site, mobile application, workshops, other communications, and third party integrations, we provide personalized benefits decision and engagement support to employees and their families so that they can spend more time with their loved ones and spend less time worrying about their benefits (such information, together with the Site, the “Service”).
This Privacy Policy explains what data we collect about you and your family, how we use and share that data to provide the Services and the choices you have regarding our data practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.
Please note that as part of the Services, we may process information that is subject to various federal and state law protections, such as the Health Insurance Portability and Accountability Act (“HIPAA”). When governed by HIPAA, this information is called “Protected Health Information” or “PHI.” Among other things, HIPAA regulates what health plans may do with your PHI. Where we are a HIPAA “business associate” of a health plan, we must also comply with HIPAA when handling your information.
Before using the Service or submitting any data to us, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service, including our web applications.
1. DATA AND INFORMATION WE COLLECT THROUGH THE SERVICE.
When you interact with us through the Service we may collect the following data from you:
Data and Information You Provide: When you use our Services, you will have an opportunity to provide certain information that identifies you and/or your family members. The information and data that we collect varies depending on what you choose to share, but it may include your name, email, telephone number, identification documents, financial goals, payment information, demographic information (e.g. number of members of your family), financial preferences, income, account balances, transaction history, employment information, health information, benefits information and asset information.
We also have pages on social media sites like Instagram, Facebook, Twitter, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
Internet Activity Data: When you visit, use, and interact with the Service, including our mobile application, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:
- Log Data: Information that your browser automatically sends whenever you visit the Site. Log data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
- Cookies Data: Please see the “Cookies” section below to learn more about how we use cookies.
- Device Data: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
- Usage Data: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
- Location Data: We derive a rough estimate of your location from your IP address.
- Email Open/Click Data: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn off cookies. Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site. Advertising networks may use cookies to collect data about you. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there. If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.
Online Tracking and Do Not Track Signals: We and our third party service providers, may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so., b
We may use the data and information we collect through the Services for the following purposes:
- To provide the Services to our clients;
- To respond to your inquiries, comments, feedback, or questions;
- To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
- To analyze how you interact with our Service;
- To maintain and improve the Service;
- To develop new products and services;
- To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
- To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
Aggregated and/or De-Identified Information. We may aggregate and/or de-identify personally identifiable information and use the resulting data to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated and/or otherwise de-identified information with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.
Marketing. We may use your contact information to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email, we may use that information to send you special offers and/or announce new programs. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. In addition, if at any time you do not wish to receive future marketing communications, you may contact us If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding other administrative matters and to respond to your requests. Please note that it may take up to 48 hours for your unsubscribe request to be processed.
3. SHARING AND DISCLOSURE OF DATA AND INFORMATION COLLECTED THROUGH THE SERVICE.
In certain circumstances we may share data and information collected through the Services with the following categories of third parties:
- Employers: To ensure our employers are able to offer you and your family
the best possible benefits and access to our Services, we may share
information about your account activity. We don’t share sensitive health
information that they don’t already have access to or that you don’t
authorize. - Family Members: If you are an employee and invite your family to the
Services, or if you join the Services as an invited family member, we may
share information about you and your benefits to your family members also
using our Services. - Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share data and information collected through the Service with our vendors and service providers.
- Business Partners: From time to time, we may give you the choice to have your data and information shared with our business partners and other companies that we trust for referrals to products and services and/or participation in other offers.
- Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your data and information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction.
- Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
4. UPDATING YOUR INFORMATION.
Please log in to your account or contact us if you would like to modify any of the information that you have submitted through the Service.
5. CHILDREN
Our Service is not directed to children who are under the age of 18. We do not knowingly collect information from children under the age of 18. If you have reason to believe that a child under the age of 18 has provided his or her information to us through the Service please contact us and we will endeavor to delete that information from our databases.
The Service may contain links to other websites not operated or controlled by us (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect data collected through the Service from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any data and/or information to us via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites
The Service is not intended for use outside the United States. If you elect nonetheless to use our Service from outside of the United States, you consent to the transfers of your data and information to us in the United States and to our data collection and use practices as described in this Privacy Policy.
The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with any data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
10.CONTACT US.
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address:
Pasito, Inc.
One Grand Central Place, 60 East 42nd Street, Suite 2300, New York, NY 10165
Contact Us
