Privacy Policy

Last Updated: May 17, 2024

Thank you for visiting www.pandapeople.com (“Website”). Our Website is owned and operated by PandaECS, Inc.  (“Company”). As used herein, terms such as "we," "us," "our," and "Company" refer to current and future affiliated entities, contractors, agents, subsidiaries, or vendors of the Company, shall all be incorporated into the definition of Company.

We are dedicated to treating the personal and corporate information of our users with care and confidentiality. Our commitment to privacy is outlined in this Privacy Policy.

1. Scope

This Policy outlines the types of information we may collect or anyone using or viewing our Platform (“you”) may provide when utilizing the Company's services through any medium mentioned above, whether communicated in writing or verbally, and whether accessed on your PC, laptop, or mobile device. (collectively "Platform").  Our full-scale approach includes protecting, storing, processing, and sharing this data. This Policy applies to any interaction with our Company and any of our services such as our website, perks and deals.

Your Assent to this Policy: If you disagree with our policies and practices, you are not permitted to use the Platform, please stop using it immediately. By accessing or using this Platform, you are indicating your full  agreement to our data handling program described in this Policy and our Terms and Conditions.

Relationship: This Policy is not designed to, nor does it establish legal rights or relationship of any form nor for or on behalf of any party.

2. Situs

Our Platform was designed with intention to be used solely by United States users, if you are not from the United States, please exit this Platform immediately. This Policy was designed to comply with, in a uniform fashion. the:

· California Consumer Privacy Act (“CCPA”);

· Colorado Privacy Act (“CPA”);

· Connecticut Data Protection Act (“CTDPA”);

· Virginia Consumer Data Protection Act (“VCDPA”); and

· Utah Consumer Privacy Act (“UCPA”).

3. Modifications

We reserve the right to modify this Policy at our discretion and will notify you by posting such changes here. Please check the Platform regularly, as continued use of the Platform following any modifications, to the extent permitted by law, will be construed as acceptance of such changes.

4. Information Collection

Gathering Methods: We collect information about you in two ways: (a) by you providing us such directly; and (b) that we collect from you automatically.

PI Exclusions: We may collect information that identifies, describes or relates to you and is accordingly, would be deemed personal information (“PI”) under applicable state laws. This information collection may also apply to any information that directly or indirectly can be associated with, or linked to, you or your household members. PI does not include:

-  Publicly available information as defined under applicable state laws.

-  De-identified or aggregated information as defined under applicable state laws.

-  Information governed by federal laws such HIPAA or the Gramm Leach Bliley Act.

HIPAA Governed Information: In some circumstances, our collection and use of Personal Information (“PI”) may be subject to the requirements of the Health Insurance Portability and Accountability Act (“HIPAA”). Identifiable information we collect will be treated as protected health information (“PHI”) under HIPAA, Section 10 below will apply.

4.1. In the past 12 months, we may have collected the following categories of PI:

· Identifiers: Such as contact information, online identifiers, date of birth, and government-issued ID numbers;

· Financial Information: Such as bank account numbers.

· Characteristics of Protected Classifications: Under state or federal law, such as age and medical conditions;

· Commercial Information: Such as transaction information and purchase history;

· Internet or Network Activity Information: Such as interactions with our Platform, Internet Protocol (IP) address, Media Access Control (MAC) address; operating system (OS) and version; Internet browser type and version;

· Geolocation Data: Such as device location;

· Audio, Electronic, Visual and Similar Information: Such as call and video recordings; and

· Professional Information: Such as place of employment and job title.

Sources: We may collect this PI from our affiliates, vendors, joint marketing partners, insurance agent/other insurers, our service providers, public records, internet service providers and social media platforms.

4.2. Tracking Technologies (“Cookies”)

What We Collect: We use certain tracking technologies, such as cookies, to automatically collect information and may use this to enhance your user experience. This may include technical data about the device used to interact with our Platform (i.e. laptop, mobile phone) browser data, and browsing behaviors such as browsing frequency or choices. We may also use third party tools, such as Google Analytics, to service our Platform.

Subsequent Log-In: As described, we may use tracking technologies, with your prior consent to identify your device when you return to our Platform and to support the auto login feature of the Platform. Note: If you fail to log off of your Panda account, you may still be logged in upon your next visit to the Platform (this would also apply to the next person to use your device).

Cookie Types: We may gather the above by means of Cookies. Cookies are typically defined as small text files that may be placed on your computer when you use the Platform. This can include single-session cookies which generally record for only one visit to our Platform and are then deleted. We may also place persistent cookies which remain on a device unless erased or expired.

Disabling Cookies: You can disable many tracking technologies by modifying your browser settings; however, doing so may restrict your access to some features on some sites including out Platform.

Why We Collect: We collect such activity information to enhance your experience including determining the best way and time to contact you. Unless restricted by this Policy or by law, we may use and share your data collect by means of tracking technologies in various ways, such as:

· Personalizing your experience by managing and recording your preferences

· Verifying your account data

· Marketing, product development, and research

· Monitoring data accessed on our Platform

· Creating reports on Platform usage, activity, and statistics

· Assisting users with service-related issues

· Enabling specific functions and tools on the Platform

· To deter fraudulent activities, enhance security and administer systems (these uses generally do not require consent).

· To evaluate the effectiveness of our Platform, including through analytics, to enhance the content available on the Platform.

We and our third-party service providers may utilize cookies to present content, including advertisements, that align with your interests on our Platform, based on your interactions with content. You have the choice whether to accept the use of cookies. Check for more information about disabling cookies http://www.networkadvertising.org/choices/ and http://www.allaboutcookies.org/manage-cookies/.

4.3. Children’s Privacy

We do not intentionally collect personal information from children under the age of 13 through this website without parental consent. If you believe we have inadvertently collected such information, please contact us immediately. The Site is intended for a general audience and is not directed at minors under the age of 18. We do not knowingly gather personal information from users in this age group via our Services.

5. PI Usage

Our aim is to gather and utilize only the PI necessary for our legitimate business purposes. We may use personal information for various purposes, including:

  • To respond to your emails or specific requests.

  • Provide you with account information or customer service

  • To adhere to applicable laws, regulations, and legal processes.

  • To safeguard someone's health, safety, or welfare.

  • To protect our rights or the rights of our affiliates or related third parties, and to take appropriate legal action, including enforcing our Terms.

  • To maintain records of our transactions and communications.

  • For other business purposes as necessary, provided such use is allowed by law.

  • Manage and improve operations

  • Provide you with a secure experience and prevent fraud

6. PI Sharing

We will share your PI with third parties only as described in this Policy and as permitted by law.

PI may be disclosed if the Company endures a corporate transformation such as a merger, sale, acquisition, dissolution or something similar.

We may also cooperate with law enforcement to investigate and prosecute illegal activities, violations of our rules, or actions harmful to other visitors.

We may share your PI with third parties at your request or when you are notified and consent to such while using the Platform or maintaining an ongoing relationship with our Company. For instance, if you express interest in or register for other services.

We may share PI within the Company and combine the data you provide through this Platform with other information we received from you or from other sources.

7. Your Data Access Rights (for Colorado, Virginia, Connecticut, California and Utah residents):

You may have the following rights to your PI:

7.1  Right to Access:

With respect to the PI we have collected about you in the prior 12 calendar months, you have the right to request (up to twice per year and subject to certain exceptions):

-  Whether we are processing your PI

-  categories of PI we have collected about you;

-  the sources from which we collected PI;

-  our business purposes for processing that PI;

-  the categories of third parties to whom we have disclosed that PI; and

-  a copy of the specific pieces of your PI we have collected.

California Residents: 

California residents have the right to request a list of categories of personal information (as defined by California law) disclosed by our Site to third parties for direct marketing purposes during the previous year. To obtain such a list, please contact us at privacy@panda.com and include "Your California Privacy Rights" in the body of your request, along with your name, street address, city, state, and zip code. Provide enough information in your request for us to determine applicability, attest to your California residency, and furnish a current California address for our response. Please note that we do not accept requests via telephone, mail, or fax, and we are not responsible for incomplete or improperly labeled notices.

7.2. Right to Correct:

You have the right to request that we correct any errors in your PI or to correct the purposes for processing of your PI.

7.3. Right to Delete:

Subject to certain conditions and exceptions, you may request deletion of PI that we collected about you or that you have provided.

7.4. Right to Opt-Out of Automated Decision Making:

Colorado residents have the right to opt out of the automated processing of your PI by us for decisions that produce significant effects concerning you.

7.5. Right to Non-Discrimination:

We will not discriminate against you for exercising any of the rights described in this section.

7.6. Right to a General Opt Out:

To exercise the rights outlined above, including opting out of targeted marketing, please reach out to us at Privacy@panda.com or send a letter to: [Address], ATTN: Privacy Office. When contacting us, kindly specify that you are making a request related to your Privacy Rights.

To process your request, we require your name, email address, home address, and date of birth. We will attempt to verify your identity by comparing the information provided with our records. Additional information may be requested if needed to verify or process your request fully.

If we encounter difficulties verifying your request, we will inform you accordingly.

You have the right to request limitations on the use and disclosure of sensitive personal information beyond what is necessary for our services or permitted by applicable laws. Should you wish to exercise this right, please email us at privacy@panda.com or mail us at [Address]. Upon receiving your request, we will note your preference to restrict the use and disclosure of sensitive personal information.

California Opt-Out

We Respond to Do Not Track Signals as follows: Pursuant to California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014), California residents are entitled to know how Aflac addresses "Do Not Track" browser settings. At present, Aflac does not take action to respond to Do Not Track signals due to the absence of a uniform technological standard. We continuously evaluate emerging technologies and may adopt a standard once one becomes available.

7.7. Right to Appeal

If we deny your request, you have the option to appeal. We will inform you of our decision along with the reasons and instructions for initiating an appeal.

For Colorado residents, if you disagree with the outcome of the appeal, you have the right to contact the Colorado Attorney General.

To ensure the validity of your request, we will verify the information provided by comparing it with our records.

Please note that we may reject your request under the following circumstances: (1) if linking your personal information would be unreasonably burdensome; (2) if we do not utilize the information to identify or respond to you specifically, or to link it with other data about you; and (3) if we do not sell the information to any third party or voluntarily disclose it to any third party other than a processor, except as permitted by applicable law.

7.8. Right to Data Portability

You have the right to receive a copy of your previously provided Personal Data in a portable format that is technically feasible and readily usable. This allows you to transmit your Personal Data to another controller without hindrance, provided that the processing is done through automated means.

7.9. How we Respond to Requests

We are unable to address your request or furnish personal information unless we can authenticate your identity or verify your authority to make such a request and confirm that the personal information pertains to you. Creating an account with us is not necessary to submit a verifiable consumer request. The personal information you supply when submitting a consumer request will only be utilized to authenticate the requester's identity or authority.

Verification Procedure: To verify your identity, we will require the following information:

• For online requests: Upload a photo ID card and confirm your identity.

• For phone requests: Provide a valid phone number and email address.

• For mail requests: Submit proof of identity.

Additional information we may request for identity verification: We may ask for other account details, responses to security queries, your name, government ID number, date of birth, contact information, or other personal identifying information.

Timing: We aim to acknowledge receipt of your request to access, delete, or rectify your personal information within 10 days and to provide a verified response within 45 days of receiving it. If more time is needed (up to 90 days), we will notify you in writing, explaining the reason and extension period.

Response Format. The response will include explanations if we are unable to fulfill a request. For requests to access specific pieces of information we have collected, we will select a format that facilitates the use of your personal information and enables transmission between entities without impediment.

Cost: We do not levy a fee to process or respond to your verifiable consumer request unless it is deemed excessive, repetitive, or patently unfounded. If a fee is deemed necessary, we will explain the rationale and provide a cost estimate before fulfilling your request.

8. Third Party Links

Our Policy does not apply to the practices of other websites or applications that may be linked to our Platform. We may also allow third parties to track browsing activity over time and across third party sites such as browsers used to read our websites.

We do not control these third party technologies and their use is governed by their privacy policies.

We may share PI with other third parties that we collaborate with or hire on our behalf. For instance, we may hire a company to help us manage emails, and may provide such company with your email address.

9. Permissible Uses and Disclosures of Your PHI

The following how we may use or disclose your PHI without your permission or authorization:

9.1. As Required by Law

If federal, state, and/or local law mandates the sharing or utilization of your PHI, we will do so to the extent required by law. If multiple laws govern the same use or disclosure, we will adhere to the stricter laws or regulations.

9.2  Judicial and Administrative Proceedings

We may disclose your PHI in judicial and administrative proceedings or disclose it in response to the following or similar legal requests:

  an court or administrative tribunal order of a court subpoena, summons or warrant discovery request

9.3. Law Enforcement

We may disclose your pertinent PHI to law enforcement when required to do so, such as in response to:

  a court order or court-ordered warrant  subpoena or a summons issued by a judicial officer

We may also disclose relevant PHI to identify or locate a fugitive, suspect, material witness, or missing person. Furthermore, we may utilize or share your PHI if we believe, in good faith, that such action is necessary to prevent or mitigate a serious threat to the safety of an individual or the public.

 In emergency situations, or if you are unavailable or incapacitated, we may disclose your PHI to a family member, friend, disaster relief agency, or another individual previously designated by you. We will exercise professional judgment and experience to assess whether the disclosure is in your best interests, and if so, we will disclose only the minimum amount of PHI necessary.

 If mandated by law, we will release your PHI to the Secretary of the Department of Health and Human Services for enforcement of HIPAA.

9.4. Your Authorization

Except as outlined above, we will not use or disclose your PHI unless you signed a form authorizing the use or disclosure. You may revoke that authorization in writing except to the extent that we have taken action in reliance upon the authorization.

9.5. Breach of Unsecured PHI

If we cause a breach to occur that involved your unsecured PHI, we are required by law to notify you of the incident.

Regarding PHI, it's important to note that your state law might offer additional access and amendment rights, distinct from those provided by HIPAA. If you seek further details regarding the collection and disclosure of PHI and your rights under state law to access and amend such information, please don't hesitate to request it.

10. Individuals' Rights

The following are your rights concerning your PHI.  If you would like to use any of the following rights, please contact us using the information at the end of this Notice.

10.1. Right to Request Restrictions

You are entitled to request restrictions on the use and disclosure of your PHI. For instance, you may ask that we refrain from disclosing your PHI to your spouse. Your request should outline the restriction you are seeking in detail. While we are not obligated to agree to your request, we will accommodate it when appropriate. We reserve the right to terminate an agreed-upon restriction if we deem it necessary. If such termination occurs, we will notify you accordingly.

10.2. Right to Request Confidential Communications

You also have the right to request alternative means or locations for us to communicate with you about your PHI. This applies only if the standard communication methods could endanger you. While you do not need to provide a reason for your request, you must indicate that the information could jeopardize your safety if communicated through the standard means or location. We must fulfill your request if it is reasonable and specifies the alternative means or location for delivering your PHI.

10.3. Right to Access and Receive a Copy of your PHI

With limited exceptions, you have the right to review copies of your PHI by submitting a signed written request. You may also request copies in a format other than reproductions, which we will provide unless impractical. If we deny your request, we will provide a written explanation along with information on how to request a review of the denial reasons. If you opt for mail delivery, we may charge for copying and postage.

10.4. Right to Amend your PHI

You have the right to request amendments to your PHI if you believe it contains inaccurate information. Your request must be submitted in writing and should detail the reasons for the requested changes. While we may deny your request under certain circumstances, such as if we did not create the information in question and the original creator is capable of making the amendment, we will provide a written explanation for any denials. If you disagree with our decision, you may submit a statement expressing your disagreement, which will be appended to the PHI in question.

If we approve your request for amendments, we will take reasonable steps to notify relevant parties, including those you specify, of the changes and incorporate them into any future disclosures of the information.

10.5. Right to Receive an Accounting of Disclosures

You have the right to receive a list of occurrences within the last 6 years in which we disclosed your PHI. If you request such more than once per calendar year, we may charge you a reasonable fee for responding to these further requests. We will provide you with more information on our fees at the time of your request. Some examples of disclosures that we must account for include those pursuant to valid legal process. Your requests must be in signed written form.

10.6. Timing

We will respond to your telephonic or written request within 30 business days of receipt.

If any law, apart from HIPAA, imposes restrictions or significantly limits our use and disclosure of PHI as outlined in this policy, we will adhere to the stricter standard. We are obligated to comply with the terms of this policy for as long as it remains valid.

11. Security

We maintain reasonable administrative, technical and physical safeguards designed to protect the information that you provide on this Platform.

Some of the safeguards we use are data encryption, physical and information access controls.

12. Communication

If you have any questions about this Policy, you can contact us in writing or by phone using the contact information listed below.

Panda

Attn: Privacy Officer, Compliance Department
 Address

Phone Number: ____________

13. Google Analytics

We utilize a tool known as "Google Analytics" to gather data regarding the usage of this website. This includes information on how frequently users visit the site, which pages they access, and the sites they visited before arriving here. The data collected through Google Analytics is solely used for the enhancement of this website. Google Analytics only captures the IP address assigned to you on the date of your visit, without obtaining any other identifying information. We do not merge the data obtained via Google Analytics with personally identifiable information. Although Google Analytics installs a persistent cookie on your web browser to recognize you as a unique user upon your subsequent visits, this cookie is solely accessible by Google. Google's ability to utilize and share the data collected by Google Analytics is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. You can prevent Google Analytics from recognizing you during return visits to this site by disabling cookies in your browser.

14. General Data Table

Categories of PI We CollectDisclosure for Business PurposeDisclosure for SharingRetention
Personal Identifiers: your name, postal address, email address, unique personal identifier, online identifier, Internet Protocol address, or other similar identifiers.
  • Affiliates

  • Group policy sponsors, such as employers and affinity groups

  • Insurance producer/agents

  • Service providers

  • Reinsurers and other insurance companies

  • Government, judicial, and law enforcement agencies and agents

  • Attorneys, accountants, and auditors

  • Your fiduciary or legal representatives

  • Persons holding a legal or beneficial interest relating to you

  • Advertising networks

  • Data analytics providers

  • Internet service providers

  • Advertising networks

  • Data analytics providers

  • Social networks

We retain your PI for as long as necessary to achieve the purposes for which we collected the PI and as needed to comply with our legal obligations.
Credit card and debit card number, or any other financial information, health, or other insurance information, including your claims history.
Protected classification characteristics under federal or state law: your age, gender, familial status, disability, sex, national origin, religion, color, race, sexual orientation, gender identity and gender expression, marital status, veteran status, medical condition, ancestry, source of income, and genetic information.
Internet or other electronic network activity information: information about your interaction with a Website, online application and advertisements, and geolocation data.
  • Advertising networks

  • Data analytics providers

  • Social networks

Electronic information, including voice signatures and recorded calls, and inferences drawn from any of the above categories of information to create a profile about you: Information about your preferences, characteristics, and behavior.
Professional or employment-related information: such as your job title.
Sensitive PI: PI relating to a consumer that reveals:
  • precise geolocation

  • contents of consumers’ mail, emails, or texts, unless the business is the intended recipient of that information

  • PI collected and analyzed concerning consumer’s health

Cookies Consent

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