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Privacy Policy

Effective Date: July 25, 2024

Curae, LLC dba Curae Personal Business Management (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.  This policy describes the types of information we may collect from you when you engage us to perform daily money management services (“Services”) or that you may provide when you visit CuraePBM.com (“Website”)  as well as our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect on the Website and in email, text, and other electronic messages between you and this Website and otherwise when you use the Services, whether as a Client or a visitor or other use of the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website or use the Services. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time and your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

Information We Collect:

We collect several types of information from and about our clients who engage us to perform Services and users of the Website, including:

  • information by which you may be personally identified, such as name, postal address, email address, telephone number any other identifier by which you may be identified or contacted online or offline (“PII”);
  • information that is about you but individually does not identify you, such as your IP address and/or about your internet connection, the equipment you use to access our Website, and usage details;
  • protected health information which is any information that identifies an individual and relates to the individual’s past, present or future physical or mental health or condition and includes but is not limited to explanation of benefits, hospital and doctor records, and medical bills and statements (“PHI”);
  • financial information which may include  any information or documents collected from a client that relates to their banking, insurance, or other payments including but not limited to bank records and statements, insurance policies, investment, credit card and loan information, tax records, and bills, invoices and other statements (“FI”).

We collect this information directly from you when you provide it to us or automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, or other tracking technologies.

The technologies we use for this automatic data collection may include Cookies (or browser cookies), which are small files placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.

Third-Party Use of Cookies.   Some content or applications are served by third-parties who may use cookies alone or in conjunction with other tracking technologies to collect information about you when you use the Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. We do not control these third parties’ tracking technologies or how they may be used.

Website Analytics.   We use Google Analytics to evaluate the use of our Website. These third-party service providers use automated devices and applications to evaluate use of our Website and services. We or our service providers use these tools to help us improve our Website, performance, and user experiences. These entities may use cookies and other tracking technologies, such as web beacons or Flash LSO, to perform their services.

How We Use Your Information.   We use information that we collect about you or that you provide to us, including PII, to provide our Services, present our Website and its contents to you, provide you with information, products, or services that you request from us, fulfill any other purpose for which you provide the information, and to carry out our obligations and enforce our rights under this policy, our Terms of Use, or any other contracts entered into between you and us, including for billing and collection.  We also use your information to notify you about changes to our Website or any products or services we offer or provide as well as for any other reason with your consent.

Disclosure of Your Information.   We may disclose aggregated information about our users and information that does not identify any individual, without restriction.  We may disclose PII or other information that we collect:

  • To our subsidiaries and affiliates;
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep PII and other information confidential and use it only for the purposes for which we disclose it to them;
  • With third party software providers including but not limited to Quicken, QuickBooks, Xero, financial based institution web-based record and bill pay software and with password or biometric protected computers, devices or cloud storage servers provided by third-party service providers.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding;
  • To fulfill the purpose for which you provide it. For example, when you give us PII, PHI or FI in order to perform the Services, we will use that information for that purpose;
  • For any other purpose disclosed by us when you provide the information and otherwise
  • With your consent.
  • See Disclosure of PHI below

We may also disclose PII, PHI or FI to comply with any court order, law, or legal process, including to respond to any government or regulatory request, court order or subpoena, discovery request or other lawful process, to enforce this policy, the Terms or Use, and other agreements, including for billing and collection purposes; if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our Clients, or others.

We reasonably ensure that the PII, PHI, FI and any other information we request, use and disclose for the performance of our Services or any purpose hereunder is the minimum amount of PII, PHI and FI in order to fulfill the objectives set forth here and in a Client’s individual Engagement Letter.   

We do not use or disclose any information collected hereunder for marketing purposes. No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

Data Security.   We will take reasonable precautions to protect PII, PHI and FI and collected from you, from loss, misuse and unauthorized access, disclosure, alteration, and destruction. All information that you provide to us either in paper or electronic form is securely stored and protected. Transactions initiated by us will be encrypted or utilize tools that ensure safe transfer of information and data. However, these measures, standing alone, are not sufficient to ensure the security of your information. We cannot guarantee the security of your data transmitted to us without using encryption or other secure ways to transmit data, thus any transmission is at your own risk. It is also important for you to guard against unauthorized access to your passwords and the unauthorized use of your computer.

PHI Disclosure.   We will disclose PHI regarding victims of abuse, neglect or domestic violence. We will  disclose PHI about disabled adult, nursing home resident, or person over 60 years of age whom we reasonably believe to be a victim of abuse or neglect to the appropriate authorities as required by law or, if not required by law, if the individual agrees to the disclosure. This includes elder abuse and exploitation, abused and neglected nursing home residents, or disabled adults abuse.

Your State Rights.   California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Montana, Oregon, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:

  • Confirm whether we process their personal information.
  • Access and delete certain personal information.
  • Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose (excluding Iowa and Utah).
  • Data portability.
  • Opt-out of personal data processing for:
  • targeted advertising (excluding Iowa);
  • sales; or
  • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
  • Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state.

To exercise any of these rights please email info@curaepbm.com. To appeal a decision regarding a consumer rights request, contact us at (804) 500-0922.

Nevada provides its residents with a limited right to opt-out of certain personal information sales, however, please know we do not currently sell data triggering that statute’s opt-out requirements.

Changes To Privacy Policy.   We reserve the right, at any time and without prior notice, to add to, update, or modify this Privacy Policy. We will notify you by providing a link to our Website and sending you a notification through email. Any such change, update or modification will be effective immediately upon posting on our Website.

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