ABE Privacy Policy

American Bar Endowment

Privacy Policy

Effective Date: February 21, 2022

I. Introduction: Our Primary Goal -- Your Privacy

This Privacy Policy explains how the American Bar Endowment (ABE) collects, uses, shares and safeguards Personal Data and Non-Personal Data (collectively, the “Collected Data”) collected from the www.abendowment.org website, ABE microsites, and any other digital services and platforms officially operated or used by the ABE (the “Sites”), as well as Personal Data and Non-Personal Data provided by you by phone, email, or on a paper application for our insurance services. We are strongly committed to providing a clear, concise, and informative experience to our members, insureds, and donors while at the same time protecting your privacy.

 

II. Changes to the Privacy Policy

As the ABE, its membership, plans, and services change from time to time, this Privacy Policy is expected to change as well. We reserve the right to amend the Privacy Policy at any time, for any reason. The date of the last revision to the Privacy Policy will be indicated by the “Effective Date” at the top of this page.

By using the Site, you agree on behalf of yourself and any organization that you represent (together, “you”) that you have read and understand this Privacy Policy. We may modify this Privacy Policy at any time. All changes will be effective immediately upon posting to the Site. Material changes will be conspicuously posted on the Sites or otherwise communicated to you.

For California residents, please consult Section VIII “California Privacy Rights” for additional considerations.

 

III. Website Terms

If you visit or use these Sites, you must comply with our Terms of Use (“Terms”) found on our website.

 

IV. Types of Data We Collect

You can visit ABE Sites without submitting personal data.  If you elect to provide data that enables the ABE to identify or contact you (“Personal Data”) to carry out our business purposes such as by completing an application form, contacting us through our Contact Us form (where we may retain your message’s content and our response), and receiving or requesting data from us, we will collect, use, and share such Personal Data pursuant to this Privacy Policy and applicable law. The Sites collect this information for a variety of business reasons, including but not limited to, providing information about insurance generally, specific insurance plans, plan dividends, premium payments, and charitable grants.

Personal Data

The types of Personal Data we collect include, but are not limited to:

  • General data (e.g., names, dates of birth, home and business addresses, email addresses, mobile/landline/personal telephone numbers, height and weight estimates, marital status, and family member information that is provided by our members/insureds);
  • Government-issued identification numbers (e.g., social security numbers);
  • Financial information (e.g., routing numbers, Certificate Holder ID numbers, and billing numbers as further described below);
  • Your transactions with us and payment records (such as policy coverages, premium payments, payment status and history);
  • Information received from the American Bar Association (ABA) for the ABE’s use in promoting insurance plans to ABE members; and
  • Other identification information.

Application Form. ABA Members can apply for ABE-sponsored insurance plans online or by using a paper application.  All applications and relevant Personal Data are submitted to New York Life websites. We are not responsible for New York Life’s privacy policies or practices. This Privacy Policy does not apply to any websites or to any data that you provide to third parties to apply for ABE-sponsored insurance. You should read New York Life’s Terms of Use and Privacy Policy for each website that you visit in order to apply for ABE insurance coverage.

Insurance Premium Payments. To make insurance premium payments through the Site, you must submit your Certificate Holder ID Number and Bill Number. All payment information is hosted by our third-party payment processor Harris Bank. All payments are sent to and processed by Harris Bank and we receive information regarding payment status from them. While we do not directly access, handle, or store your credit or debit card or payment information, we may keep a record of your payments. We may store your Certificate Holder ID Number and Billing Number to facilitate billing payments and we may collect related Personal Data, such as your name and contact information, to facilitate the applicable transaction. The Harris Privacy Policy in the bank’s website can be consulted for additional information.

Non-Personal Data

We may collect and store information that does not directly identify you as you interact with our Sites, Insurance Specialists, or promotional material (“Non-Personal Data”). The types of Non-Personal Data we collect include, but are not limited to: your Internet protocol (“IP”) address, geolocation, type of browser, operating system, search requests, website traffic information, the date and time you visited our Sites, the amount of time you used the Sites, the pages you visited on our Sites, any device you are using to access the Sites, the Sites you visited after leaving our Sites, and any hyperlinks you click on when using the Sites.

  • De-Identified Data. Any Personal Data that has been de-identified and/or aggregated so that it no longer contains Personal Data and will be treated as Non-Personal Data.
  • IP Address and Geolocation. IP address and geolocation will be treated as Non-Personal Data except in locations where otherwise required by applicable law.
  • Ownership. ABE is the sole and exclusive owner of any Non-Personal Data received by ABE or its third-party service providers or licensors through your use of the Sites, cookies, web beacons or anything similar.

 

V. How We Use Your Data

In addition to the uses described above, we use your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways including, but not limited to the below.

Service Communications. We may use Personal Data for the purposes of communicating services, such as billing reminders and customer service messages.

As Stated or Agreed to at the Point of Collection. We may use Personal Data for the purposes stated or agreed to (or as is obvious) at the point of collection.  For example, we use Personal Data to provide insurance plan information you request or that we think you may be interested in and to answer your questions, comments, or complaints.  We may also use Personal Data as requested or consented to by you.

Charitable Gift Accounts, Opportunity Grants, and Dividend Donations. We may use Personal Data for the purposes of establishing a Charitable Gift account, completing application for an Opportunity Grant, and to assist Members in donating any available dividends to ABE.

Administration. We may use Personal Data for administrative purposes, such as managing your accounts, facilitating transactions, to inform you of our business strategies, to understand the Sites’ demographics and user preferences, for evaluating applications, and managing profiles. In addition, we may use Personal Data in the aggregate to help us better serve our insureds.

Site Management.  We may use Personal Data for Site management, such as troubleshooting problems, improving the content and functionality of the Site, statistical and other analyses of the Site, and to customize the Site for you and our users.

Promotions. We may use Personal Data to send targeted promotions or to perform targeted promotions for members, to notify you of new services, products or programs, to notify you of new features of our Sites, to notify you of changes to this Privacy Policy and for other similar communications.

To Protect Our Rights. We may use Personal Data to protect our legal rights or interests, or those of third parties, including to bring a legal action against you or anyone who may be causing harm to us, our Sites, or to other users of the Sites.  We may also use Personal Data to seek any business, financial or legal advice, and to respond to other legal requests.

Analytics. The Sites may use third-party analytics tools to collect and process data about your use of the Sites, including when you visit the Sites, URLs of the websites that you visit prior to visiting the Site and when you visit those websites, and IP addresses assigned to the devices from where you access the Internet. Our analytics providers may set and read cookies to collect this data and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we may use to improve the structure and content of the Sites.

Online Behavioral Advertising. We may occasionally use advertising networks and services provided by third-party vendors. These services collect data about your interactions with the Site and other websites across the Internet and use such data to target personal content and advertisements for goods and services. The data collected may be associated with your Personal Data. The targeted content and advertisements may appear on the Sites and on other websites and may be sent to you via email. Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests.

 

VI. How We Share Your Data

We share your Personal Data, sometimes combined with Non-Personal Data, in a variety of ways and in compliance with applicable laws, including but not limited to:

  • Employees and Affiliates. We may share Personal Data with our employees and affiliates who have a need to know the information for our business purposes.
  • Our Affiliated Insurance Companies and Regulatory Agencies. In the course of providing insurance, we may share Personal Data with our affiliated insurance companies and parties who perform an insurance function for ABE.  For example, we may provide New York Life with information confirming your insurance premium has been received for a specific period of time and communicate with insurance regulatory agencies in connection with the regulation of our business.
  • Third-Party Service Providers. We may share data with third parties to fulfill service requests and to perform business functions for our third-party service providers, suppliers, consultants, agents, resellers, partners and representatives (collectively, “Service Providers”).  For example, the ABE contracts with Service Providers on our behalf such as mailing and delivering services, and customer support.  In addition, we may share Personal Data with Service Providers to help us host and manage the Sites; provide targeted advertising and other marketing; improve the content and functionality of the Sites; perform data analysis and statistical analysis; troubleshoot problems with the Sites; provide premium services; provide public relations; provide learning management systems; provide email services; provide data processing; and provide the security of the Sites.
  • Government Officials / Law Enforcement. We may share data with third parties as required by law or to protect the ABE in the good-faith belief that such action is necessary to conform to legal requirements or comply with legal process served on the ABE; to protect and defend the ABE’s rights or property; or protect the personal safety of ABE personnel, members, or members of the public in appropriate circumstances.
  • Change in Ownership. In the event the ABE is the subject of a change of control or in the event the Site changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide Personal Data to the subsequent owner(s).
  • Other.We may share Personal Data with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the Personal Data to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).

Your email address will be used only by the ABE and ABE vendors performing member services. Any information that you provide to us or that we obtain about you, will not be sold, rented, leased, or given to a non-affiliated third party without your consent.

ABE may collect, use, share, transfer and otherwise process Non-Personal Data received or created by ABE (or its Service Providers) for any business purposes in its sole discretion, in compliance with applicable laws.

 

VII. How You Can Manage the Processing of Your Data

ABE sends out three types of email – promotional information on available insurance plans, emails of a more administrative nature highlighting plan changes and enhancements, and informational emails highlighting ABE’s charitable mission and grants. You may opt out of receiving any one or more of these types of email by contacting us and requesting that your name and email address be removed from any email lists utilized for those purposes. For California residents, please consult the next section for additional considerations.

 

VIII. California Privacy Rights

In addition to the rights as explained in the Privacy Policy, under California’s “Shine the Light” law, California residents who provide personal information (as defined in the statute) in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the personal information we shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in 2022 will receive information about 2021). To obtain this information please write to us at: American Bar Endowment, Ste. 1400, 321 N. Clark St., Chicago, IL 60654 Attn: Compliance -- California Privacy Law. Please include your full name and address and ABA member number, if applicable.

CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT.  WE CURRENTLY DO NOT HONOR “DO NOT TRACK” REQUESTS.

 

IX. Children

We are committed to protecting children’s privacy. We do not knowingly collect, use, or share Personal Data from, or promote to, children under the age of 18. If a parent or legal guardian learns that their child provided us Personal Data without his or her consent, please contact us and we will make commercially reasonable attempts to delete such Personal Data.

 

X. How We Protect Personal Data

The ABE implements commercially reasonable security measures to help protect against unauthorized access to, or unauthorized alteration, disclosure, or destruction of, data. Except for the sharing of information as set forth in the Privacy Policy, we restrict access to Personal Data to certain companies who need the data to operate, develop, or improve our services to our members. These individuals or partner organizations are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations.

Unfortunately, no data transmission over the Internet or electronic storage is fully secure. Accordingly, and despite our reasonable efforts to protect your Personal Data from unauthorized access, use, disclosure, the ABE cannot guarantee or warrant the security of the Personal Data you transmit to us, or to or from our online website. If you have questions about this Privacy Policy, please contact us using the Contact Information provided below.

YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL DATA, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL DATA AND YOU PROVIDE PERSONAL DATA AT YOUR OWN RISK.

 

XI. Linking to Other Internet Sites and Third-Party Websites

You should be aware that other Internet sites may link to or be linked from the ABE website or an ABE email message may contain privacy provisions that differ from the provisions of this Privacy Policy. To ensure your privacy is protected, we recommend that you review the privacy statements of these other linked sites, applications, or other digital platforms.  We are not responsible for third-parties’ privacy policies or practices. This Privacy Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.

 

XII. Cookies and Other Tracking Web Devices

Our website sends cookies (e.g., pieces of code or text placed on your computer by us or third parties when you browse our Site) to your web browser (if your browser’s preferences allow it) to collect data when you browse our Site.  Cookie settings can be controlled in your Internet browser to automatically reject some forms of cookies.  If you view our Site without changing your cookie settings, you are indicating your consent to receive all cookies from our Site.  If you do not allow cookies, some features and functionality of our Site may not operate as expected. In addition to cookies, we place technological tools (and allow certain third parties to place technological tools) such as tags and beacons (e.g., code scripts that are primarily used to track visitors’ activities on our Site by web analytics software), Internet Protocol (IP) addresses, and other tools, to collect your data for the purposes listed in this Privacy Policy.

 

XIII. Social Media

We are active on social media, including Facebook, Twitter, and LinkedIn (“social media”). You may comment on social media regarding ABE and our products and services.

 

The Site allows you to connect and share data with social media. These features may require us to use cookies, plug-ins, and APIs provided by such social media to facilitate those communications and features.

 

Anything you post on social media is public information and will not be treated confidentially. We may post (or re-post) on the Site and on our Social Media pages any comments or content that you post on our Social Media pages. You agree to hold ABE harmless and without liability for the results of any and all content you post on ABE’s social media.

 

Your use of social media is governed by the privacy policies and terms of the third parties that own and operate those websites and not by this Policy. We encourage you to review those policies and terms.

 

The Site may use advertising networks and services offered by social media to deliver advertising content. Use of these services requires social media to implement cookies or pixel tags to deliver ads to you while you access the Site.

 

XIV. Governing Law 

Unless otherwise expressly required by the applicable law of your country of residence, this Privacy Policy is governed by the laws of the State of Illinois, United States, without regard to conflict of laws principles.  You agree to venue and personal jurisdiction exclusively in Chicago, Cook County, Illinois with respect to any dispute arising under this Privacy Policy.

 

XV. Access from Outside the United States

This Site is operated and maintained by ABE from the United States and is intended solely for a United States audience. If you access the Site from outside the United States, please be aware that Collected Data may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of Personal Data in the United States to be equivalent to that required by the authorities in other jurisdictions.

 

XVI. Breach Notification

We use commercially reasonable technical and organizational measures to help secure Personal Data against loss, misuse, and alteration appropriate to the type of Personal Data processed.  In the event we determine that there has been a data security incident, we will notify you of the incident by email, U.S. mail, telephone, or other means if required under applicable law.

 

XVII. Contact Information

If you have questions, comments, or complaints concerning our privacy practices or if you wish to change or remove your Personal Data, please contact us as indicted below. We will attempt, where practical, to respond to your requests and to provide you with additional privacy-related information.

American Bar Endowment
321 North Clark Street
Chicago, IL 60654
(800) 621-8981 or (312) 988-6400
abendowment.org