Privacy Principles

Privacy Vision

The Berwyn Group, Inc. (“The Berwyn Group,” “our,” or “we”) is committed to the responsible use of information and protection of individual privacy rights. The Berwyn Group strives to provide products and services to businesses, nonprofit organizations and government agencies that help reduce and prevent fraud, mitigate risk, and fulfill fiduciary responsibilities in ways that protect individuals’ privacy. We aspire to protect individuals’ privacy through the design of our products and services, by credentialing, monitoring, and auditing our business clients as appropriate, and through other information security safeguards. We also strive to promote transparency through privacy principles and policies.

Privacy Principles

The Berwyn Group’s Privacy Principles (the “Principles”) speak to personally identifiable information, including sensitive personally identifiable information, collected, maintained, used, disclosed, or processed in connection with products and services offered by The Berwyn Group.

The Berwyn Group offers products and services only for use in the U.S. and applies the Principles to our products and services where appropriate. In addition, other uses or disclosures may occur as required by applicable law, such as the Fair Credit Reporting Act and its state analogues (“FCRA”), the Driver’s Privacy Protection Act and its state analogues (“DPPA”), and the Gramm-Leach-Bliley Act (“GLBA”). The Principles may not apply (i) where the law requires or upon request of law enforcement, or, (ii) where necessary, to prevent fraud or to protect our company systems. From time to time, The Berwyn Group may revise the Principles by posting changes on The Berwyn Group websites.

1. SECURITY

Data security is a company imperative. The Berwyn Group strives to protect personally identifiable information that we collect, maintain, process, or disclose, including by using appropriate administrative, physical, and technical safeguards.

2. PROTECTION OF PERSONALLY IDENTIFIABLE INFORMATION

The Berwyn Group strives to provide additional safeguards for sensitive personally identifiable information, such as government identifiers. The Berwyn Group strives to limit the availability of and access to government identifiers and strives to protect the confidentiality of government identifiers by limiting access to government identifiers to certain legitimate and authorized users, such as: state, local and federal government entities; financial institutions; insurers; employers; and other user types to which The Berwyn Group may decide to provide such access. A limited number of public records may contain government identifiers that are already available to the public and, if such public records are accessed through The Berwyn Group’s products and services, our products and services may provide access to such government identifiers. The Berwyn Group prohibits the unlawful disclosure of government identifiers.

3. ACCURACY

The Berwyn Group strives to accurately report information in our products and services. The Berwyn Group also strives to accurately report information we receive from our data sources and business clients. The Berwyn Group recognizes that data sources and business clients’ records may be incomplete or inaccurate and reporting and data entry errors may occur.  The Berwyn Group assists our business clients, where appropriate and practicable, to dispute and correct information that we report, as discussed further in Principle 7 on Access and Correction.

4. EDUCATION

The Berwyn Group strives to inform its employees and business client users about appropriate use of The Berwyn Group’s products and services, privacy and security issues associated with The Berwyn Group’s products and services, and the responsible use of personally identifiable information, including sensitive personally identifiable information.

5. REPUTABLE SOURCES

The Berwyn Group strives to acquire personally identifiable information from established, reputable sources in the government and private sectors. The Berwyn Group may also acquire personally identifiable information from public sources. In support of this Principle, The Berwyn Group takes reasonable steps to assess the reputation and reliability of our data sources before incorporating personally identifiable information from the source into The Berwyn Group’s products and services. The Berwyn Group also strives to obtain assurances from our data suppliers that they have the legal right to provide data to The Berwyn Group.

6. NOTICE

The Berwyn Group publicly posts the Principles on our websites.

For additional information about the Principles, contact The Berwyn Group at 216-765-8818 or email help@berwyngroup.com.

7. ACCESS & CORRECTION

As appropriate and practicable, The Berwyn Group strives to:

  • Provide business clients with a central point of contact regarding their questions about The Berwyn Group and our commitment to the responsible use of personally identifiable information.
  • Inform business clients about the nature of public records, nonpublic information, and publicly available information that The Berwyn Group makes available in our products and services.
  • Provide opportunities for individuals to dispute and correct information by assisting them in identifying the potential information sources at which corrections should be made.
  • Direct individuals to the government and private entities that collect and maintain public records and publicly available information to correct any claimed inaccuracies found in that data.
  • Direct individuals to consumer reporting agencies where such agency is the source of the information about the individual and where the individual seeks to correct claimed inaccuracies found in that data.

8. ACCOUNTABILITY

The Berwyn Group supports accountability of information industry standards and practices, responsible and effective federal regulation of the data industry, and legislation governing the practices of all data providers. The Berwyn Group also supports industry oversight and active engagement with the privacy community. The Berwyn Group believes that strong privacy and information security protections are vital for an effective and trusted industry.

9. ONLINE PRIVACY

The Berwyn Group strives to protect the privacy of personally identifiable information obtained over the Internet and strives to apply the Principles and evolving standards to the online environment.

10. IDENTITY THEFT

The Berwyn Group strives to prevent the acquisition of information from our products and services for improper purposes, such as identity theft. The Berwyn Group understands the importance of notifying data owners where individuals’ sensitive personally identifiable information was acquired by an unauthorized individual.

11. COMPLIANCE

The Berwyn Group will obtain assessments from an independent auditor, who uses procedures and standards generally accepted in the profession to assess The Berwyn Group’s controls relevant to security, availability, and confidentiality, as appropriate.

Privacy Policy

The Berwyn Group works with pension plans, insurance companies, financial institutions, government entities, benefit plan sponsors, and other clients to help locate people who may be eligible for benefits. We also help with our clients’ other legitimate business purposes, such as preventing fraud or avoiding overpayment of benefits to deceased individuals.

Where personal information is provided to The Berwyn Group by those organizations, The Berwyn Group is a data processor, service provider or contractor to such organizations, as those terms are used in applicable privacy laws. As the controller of personal information related to you, your pension plan, insurance company, or other business is the proper entity to address any questions or requests related to your personal information.

1. About This Privacy Policy

This privacy policy explains The Berwyn Group’s general practices for collecting, using, disclosing and protecting personal information. This privacy policy may be supplemented by additional privacy statements, terms or notices as provided on The Berwyn Group’s websites or applications.

This privacy policy does not apply to workforce-related personal information collected from The Berwyn Group’s employees, job applicants, contractors, or similar individuals. Please contact our human resources department at HR@longevity.inc with questions about workforce-related personal information.

The Berwyn Group’s services, websites, and applications are not intended for residents outside of the United States. Berwyn provides business-to-business services and does not provide services to individual consumers.

2. Collecting Personal Information

The Berwyn Group may collect information about individuals:

  • Directly from the individual, including by phone, mail or internet forms, or in-person contact;
  • Indirectly from use of The Berwyn Group’s services, websites, or applications;
  • From another company within our family of companies; and
  • From third parties, such as The Berwyn Group’s business clients.

The Berwyn Group may collect or process for The Berwyn Group’s business clients the following categories of personal information about individuals:

  • Contact details, such as name, email address, postal address and phone number;
  • Account login credentials, such as usernames and passwords;
  • Other account registration information, such as job title;
  • Other information provided to The Berwyn Group, including search query data and questions or information you send to customer support;
  • Payment information, such as a credit or debit card number;
  • Comments, feedback and other information submitted to The Berwyn Group or our services, websites, and applications;
  • Communication preferences;
  • Computer, device and connection information, such as IP address, browser type and version, operating system, mobile platform and unique device identifier and other technical identifiers, error reports and performance data; and
  • Usage data, such as click stream data, including date and time stamp, and referring and exit pages, search terms you used and pages you visited or searched for on our services, websites, and applications.

The Berwyn Group may use and disclose information that does not reveal an individual’s identity or permit direct association with any specific individual, such as browser and device information, anonymous usage data and aggregated information, for any purpose, except where we are restricted by law. We may collect this information through our servers and the use of cookies and other technologies. You may control cookies through your browser’s settings and other tools. For example, if you view a webinar or other video on The Berwyn Group’s YouTube account, you can opt-out of YouTube cookies by changing the settings in your web browser. However, if you block certain cookies, you may not be able to register, login, access certain parts, or make full use of The Berwyn Group’s services, websites, and applications.

The Berwyn Group may collect or process personal information that is subject to certain privacy laws and regulations.

3. Using Personal Information

The Berwyn Group may use (including on behalf of The Berwyn Group’s business clients) personal information to:

  • Provide, activate, and manage your access to and use of our services, websites and applications;
  • Process and fulfill a request, order, download, subscription, or other transaction;
  • Provide technical, product and other support and to help keep our services, websites and applications working, safe and secure;
  • Respond to your requests, inquiries, comments and concerns;
  • Provide, evaluate and improve our services, websites, and applications, and to develop new products, services, websites, applications, and benefits;
  • Offer you customized content and individualized personalization of our services, websites and applications to make it more relevant to your interests and needs;
  • Notify you about changes, updates and other announcements related to our services, websites, and applications;
  • Deliver information about our services, websites and applications as well as other products, events and services of ours or our affiliates;
  • Invite you to participate in user testing and surveys;
  • Identify usage trends and for data analysis, including for purposes of research, audit, reporting and license fees to third-party providers, such as data providers, or other business operations, including evaluating our business performance, or in other ways to which you or a third party acting on your behalf have expressly agreed in an agreement; and
  • Comply with our legal obligations, resolve disputes, and enforce our agreements.

The Berwyn Group may match or combine personal information with information that we obtain from other sources or that is already in our records, whether collected online or offline or collected by a predecessor or another company in our family of companies, for the purposes described above.

4. Disclosing Personal Information

The Berwyn Group may disclose personal information to process the information, based on our instructions or instructions by our business clients and in accordance with this privacy policy and any other appropriate confidentiality and security measures. We may disclose personal information to:

  • Another company in our family of companies;
  • Our service providers, suppliers, contractors, agents and representatives;
  • Our clients pursuant to servicing or licensing agreements; and
  • An individual’s business entity sponsor, if the individual accesses The Berwyn Group’s services, websites, or applications under an entity’s agreement (for example, a company, corporation, nonprofit, partnership, bank or other business entity).

The Berwyn Group may also disclose personal information:

  • To (i) meet any applicable law, regulation, legal process or other legal obligation; (ii) detect, investigate and help prevent security, fraud or technical issues; (iii) enforce and protect our rights and properties; or (iv) protect the rights, property or safety of our users, employees and others; or
  • If The Berwyn Group or our services, websites, or applications, or a related asset or line of business is acquired by, transferred to or merged with another company.

5. Data Security

The Berwyn Group recognizes the importance of protecting personal information. We use a variety of administrative, physical and technical security measures intended to safeguard your personal information.

Our services, websites, or applications may contain links to other sites. The Berwyn Group is not responsible for the security, privacy practices or the content of such linked sites.

6. Updating Personal Information

The Berwyn Group works with pension plans, insurance companies, and other businesses across the United States. Personal information is provided to The Berwyn Group from or on behalf of those organizations, and The Berwyn Group is a service provider, contractor, or data processor/collector to such organizations. If you would like to update your personal information, please contact your pension plan, insurance company or other business. As the business and controller of personal information related to you, your pension, insurance company, or other business is the proper entity to update your personal information.

The Berwyn Group cooperates with its business clients (which are the data owner or controller of personal information) to respond to verified consumer requests. If the data owner, controller, or business requests The Berwyn Group to delete your personal information, The Berwyn Group will endeavor to fulfill such request in accordance with our policies, but some personal information may be retained in backup copies for a certain period of time and as necessary for legitimate business purposes or to comply with our legal obligations, resolve disputes and enforce our agreements.

Access to personal information that The Berwyn Group gathers from certain sources is subject to applicable laws and our data sharing policy.

7. Children’s Privacy

We do not knowingly collect information from children under the age of 13 or target our services, websites, and applications to children under 13. If it comes to our attention that we have collected personal information from children under the age of 13, we may delete this information without notice. If you have reason to believe that The Berwyn Group has collected information from children under the age of 13, please contact The Berwyn Group at 216-765-8818 or email help@berwyngroup.com.

8. Changes

The Berwyn Group will notify you of changes or updates to our services, websites, or applications or to this privacy policy whenever necessary, in The Berwyn Group’s discretion, through email, invoice announcements, the functionality of our services, websites, or applications, or by updating The Berwyn Group’s websites, or applications. If you have an account with The Berwyn Group, we may notify you through such account. Any changes to this privacy policy will be posted on this page with an updated revision date. Your continued use of The Berwyn Group’s services, websites, and applications following the posting of changes constitutes your acceptance of such changes.

9. Contact Us

If you have any questions, comments or requests regarding this privacy policy or our processing of your information, please contact The Berwyn Group at 216-765-8818 or email help@berwyngroup.com.

If you use assistive technology (such as a Braille reader, a screen reader, TTY, etc.) and the format of this privacy policy interferes with your ability to access this privacy policy, contact The Berwyn Group for assistance. Please indicate the nature of your accessibility problem, the preferred format you would like to receive this privacy policy, and your contact information so that we may respond in a manner most helpful to you.

Last Revision: 5/1/2024