Iris' Legal Information

Generali Global Assistance, Inc., dba Iris^® Powered by Generali Privacy Policy

Generali Global Assistance, Inc., dba Iris^® Powered by Generali (“Iris” or “We”) values the privacy of our users and others (collectively “Users” or individually each a “User”) who visit and use any Iris website and its associated services (the “Website”). This statement (the “Privacy Policy”) governs information provided to us by you as a User of the Website (“You”), or that we learn from Your use of the Website. BY ACCESSING, BROWSING, OR USING THE WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE RECEIVED, READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THE FOLLOWING PRIVACY POLICY AND ANY UPDATES TO IT.

Personal Information That We Collect Or Process
Depending on your relationship with Iris (for example, as a policyholder; insured person benefiting under another policyholder’s policy, or claimant; Website User; or other person relating to our business),  Personal Information collected or processed about You and Your dependents may include:

• General identification and contact information
  Your name; address; e-mail and telephone details; gender; marital status; family status; date of birth; passwords on our systems; educational background; physical attributes; activity records, such as driving records; photos; employment history, skills and experience; professional licenses and affiliations; relationship to the policyholder, insured or claimant; and date and cause of death, injury or disability.
• Identification numbers issued by government bodies or agencies
  Passport number; tax identification number; military identification number; or driver’s or other license number.
• Financial information and account details
  Payment card number; bank account or other financial account number and account details.
• Medical condition and health status
  Current or former physical or mental or medical condition; health status; injury or disability information; medical procedures performed; personal habits (for example, smoking or consumption of alcohol); prescription information; and medical history.
• Other sensitive information
  We may obtain information about your criminal record or civil litigation history in the process of preventing, detecting and investigating fraud.  We may also obtain sensitive information if you voluntarily provide it to us (for example, if you express preferences regarding medical treatment based on your religious beliefs).
• Telephone recordings
  Recordings of telephone calls to our representatives and call centers.
• Photographs and video recordings
  Photographs or video recordings created in connection with our insurance or other business activities, including for claims assessment, processing, settlement, and disputes, or for other relevant purposes as permitted by law.
• Information to investigate or prevent crime, including fraud and money laundering 
  For example, insurers commonly share information about their previous dealings with policyholders and claimants for this purpose.
• Information enabling us to provide products and services
  Location and identification of property insured (for example, property address, vehicle license plate or identification number); travel plans; age categories of individuals you wish to insure; policy and claim numbers; coverage/peril details; cause of loss; prior accident or loss history; your status as director or partner, or other ownership or management interest in an organization; other insurance you hold; and details on products for which you have or seek a warranty.
• Marketing preferences, customer feedback and survey responses
  You may let us know your marketing preferences or respond to a voluntary survey.
• Social media account and information from Apps
  We may receive certain Personal Information about you when you use our Apps or Social Media Pages, including your social media account ID and profile picture.
• Information from Other Sources
  We and our service providers may supplement the Personal Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from our affiliates or business partners.

How We Use Personal Information
Iris may use your personal information collected through the Website for various purposes, including:

• Communicating with you, including responding to your requests for information and other inquiries;
• Improving the Website, facilitating your user experience and improving performance;
• Monitoring the Website and analyzing usage trends and user activities;
• Preventing, investigating, identifying, or taking other actions with regard to suspected or actual fraudulent or illegal activity or activities that violate our policies;
• Complying with applicable laws, regulations, legal processes, industry standards, and our company policies; and
• For any other purpose with your consent.

Non-Personal Information

Your use of the Website indicates Your consent to our collection of non-personal information about You. We collect this information through the use of cookies, web beacons, or log files. A cookie is a small text file that is stored on your hard drive for record keeping purposes. A web beacon is a small invisible GIF file, usually embedded in the website that helps track the online movements of Users. We also gather information in our log files, as do most web sites. This information includes Internet protocol (“IP”) addresses, browser types, referring pages and other information. The information in the log files is aggregated and does not identify individual Users. We use the information collected through cookies, web beacons and log files to understand how our Users navigate our Website, and to determine common traffic patterns. We may use this information to improve the Website, to make Website navigation recommendations and to help redesign the Website in order to make Your experience on the Website more efficient and enjoyable. You also have choices with respect to cookies. By changing Your internet browser settings, You have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies.

HIPAA Information

Certain information held on the Website may be considered “Protected Health Information” as defined in the Health Insurance Portability and Accountability Act of 1996, (Pub. L. 104-191, August 21, 1996, 110 Stat. 1936), 42 U.S.C. § 1320d – 1320d-8, as amended (“HIPAA”). That information is retained, processed and communicated in accordance with HIPAA. Iris does not share Protected Health Information of Users with nonaffiliated third parties unless doing so is appropriate to carry out a User’s request or Iris reasonably believes that doing so is legally required, facilitates Iris’ operations or is in Iris interest to protect its property or other legal rights or the rights or property of others, in any case only as permitted by law.

Children

Consistent with the Children’s Online Privacy Protection Act of 1998 (COPPA), Iris will never knowingly request information from anyone under the age of thirteen (13) without requiring parental consent, and no part of the Website is directed to persons under thirteen (13). IF YOU ARE UNDER THIRTEEN (13) YEARS OF AGE, THEN PLEASE DO NOT USE OR ACCESS THE WEBSITE AT ANY TIME OR IN ANY MANNER.  If you believe the personally identifiable information of anyone under the age of thirteen (13) has been provided to Iris, and you are the parent or guardian of that individual, you may contact us to request that we delete any such personally identifiable information, at legal@us.generaliglobalassistance.com

California Residents

California's "Shine the Light" law (Civil Code Section § 1798.83) provides certain rights to California residents that have an established business relationship with us with regard to the disclosure of certain types of personal information to third parties for their direct marketing purposes. To opt-out of having your personal information disclosed to third parties for their direct marketing purposes, please: (i) email legal@us.generaliglobalassistance.com or (ii) using the Personal Data Request Form on the Iris website. For further information, California residents should see our Privacy Notice for California Consumers for more information on your rights. For further information, California residents should see our Privacy Notice for California Consumers for more information on your rights.

Nevada Residents

Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt-out of future sales of certain covered information that a website operator has collected or will collect about the resident. You may exercise your Nevada opt-out rights by either: (i) sending an email to legal@us.generaliglobalassistance.com or (ii) using the Personal Data Request Form on the Iris website. 

Texas Residents

Texas law provides Texas residents with rights to: (i) confirm whether a controller is processing personal data and access to their personal data, (ii) correct inaccuracies in their personal data, (iii) delete personal data provided by or obtained about the consumer, (iv) obtain a copy of their personal data, if available, in a portable and readily usable format and (v) opt out of processing personal data for targeted advertising, the sale of personal data, or its use for profiling.  If you are a Texas resident, you also have a right not to receive discriminatory treatment for the exercise of your privacy rights. The Texas Data Privacy and Security Act defines “Personal Data” to mean “any information, including sensitive data, that may be reasonably linked to an identifiable individual.” The Texas Data Privacy and Security Act also explicitly states that pseudonymous data used alongside additional information is considered personal data.  When we use the term “personal information” in our Privacy Policy, it includes Personal Data covered by this definition. You or your authorized agent may submit a request to exercise your access, deletion, and correction rights by either: (i) sending an email to consumerprivacy@us.generaliglobalassistance.com or (ii) using the Personal Data Request Form on the Iris website.

Our Commitment to Data Security

No data transmissions over the internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information You transmit to us and You do so at Your own risk. Once we receive Your transmission of information, Iris implements reasonable administrative, technical and physical safeguards designed to ensure the security and confidentiality of Your information, protect against any anticipated threats or hazards to the security or integrity of such information, and protect against unauthorized access to or use of such information that could result in substantial harm or inconvenience to any User. These safeguards include use of a firewall, content filtering, intrusion detection, SSL encryption and access controls. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical or administrative safeguards. If Iris learns of a security systems breach, then we may attempt to notify You electronically so that You can take appropriate protective steps. By using the Website, You agree that Iris can communicate with You electronically regarding security, privacy and administrative issues relating to Your use of the Website. Iris may post a notice on the Website if a security breach occurs. Depending on where You live, You may have a legal right to receive notice of a security breach in writing. To receive a free written notice of a security breach (or to withdraw Your consent from receiving electronic notices), You must notify Iris via email at legal@us.generaliglobalassistance.com.

Note to International Visitors

All matters relating to our Services are governed by the laws of Washington DC in the United States of America. If you visit our Services or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) that by using our Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.

Changes and Updates to this Privacy Policy

Iris may occasionally update this Privacy Policy. Your agreement to this Privacy Policy and any updates. Updates will only apply after the effective date of the update.

Effective Date. This Privacy Policy was last revised on, and is effective as of, January 8, 2025.

Terms of Service

 Generali Global Assistance, Inc., dba Iris® Powered by Generali (“Iris”) welcomes you to its website. The following Terms of Service (as defined below) apply to all users of any Iris website (the “Website”). The following Terms of Service for the Website is an agreement between you, an individual user (“You”), and Iris regarding your use of the Website. You and Iris are referred to herein individually as “Party” or collectively as the “Parties”. When using the Website, You will be subject to any additional posted rules applicable to specific services and features which may be posted from time to time (the “Rules”). All Rules are hereby incorporated by reference into the Terms of Service. 

BEFORE USING THE WEBSITE, PLEASE READ THE FOLLOWING TERMS OF SERVICE CAREFULLY. BY ACCESSING, BROWSING, OR USING THE WEBSITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THE FOLLOWING TERMS, INCLUDING THE RULES, AND ANY FUTURE MODIFICATIONS (COLLECTIVELY, THE “TERMS OF SERVICE” OR “TOS”). IF AT ANY TIME YOU DO NOT AGREE TO THE TOS, PLEASE IMMEDIATELY TERMINATE YOUR USE OF THE WEBSITE.  

1.  Privacy Notice. Your privacy is important to Iris. Iris’s Privacy Policy is hereby incorporated into the TOS by reference, which may be found on the Website. 

2. Eligibility. In order to use the Website, You must be the age of majority in Your jurisdiction and fully able and competent to enter into the TOS, conditions, obligations, affirmations, representations and warranties set forth in the TOS and to abide by and comply with the TOS. You represent that You meet the eligibility requirements in this Section and that You are over the age of 13, as the Website is not intended for children under the age of thirteen (13).

3.  Modification of the TOS. From time to time, Iris may change, remove, add to (including without limitation by way of additional terms) or otherwise modify the TOS, and reserves the right to do so in its discretion. In that case, Iris will post the updated TOS, as relevant, to the Website and indicate the date of revision. Iris encourages you to periodically review the TOS. Your continued use of the Website after new and/or revised TOS have been posted indicates that You have read, understood and agreed to the current version of the TOS.

4. Ownership; Proprietary Rights. As between the Parties, the Website, including the content, visual interfaces, interactive features, information, graphics, design, compilation, computer code, software, services, and all other elements of the Website that are provided by Iris (“Iris Materials”) are owned and/or licensed by Iris. Except as expressly authorized by Iris, You agree not to sell, license, distribute, copy, modify, publicly perform or display, transmit, publish, edit, adapt, create derivative works from, or otherwise make unauthorized use of the Website or the Iris Materials. Iris reserves all rights not expressly granted in the TOS. You shall not acquire any right, title, or interest to the Iris Materials, except for the limited rights set forth in the TOS.

5. Website Access. Iris grants You permission to use the Website, as set forth in the TOS, provided that, and for so long as (i) You use the Website solely to obtain information available on the Website to the general public regarding Iris and its services; (ii) except as expressly permitted in the TOS, You do not download, reproduce, redistribute, retransmit, publish, resell, distribute, publicly display or otherwise exploit any portion of the Website in any medium without Iris’s express prior written authorization; (iii) You do not alter or modify any part of the Website; (iv) You do not engage in any of the prohibited uses described below; and (v) You otherwise fully comply with the TOS. The Website is controlled and offered by Iris from its facilities in the United States of America. Iris makes no representations that the Website is appropriate or available for use in other locations. If You are accessing or using the Website from other jurisdictions, You do so at your own risk and You are responsible for compliance with local laws.

6. Prohibited Uses of the Website.

(a) As a condition of your use of the Website, You hereby represent and warrant that You will not use the Website for any purpose that is unlawful or prohibited by the TOS including, without limitation, the prohibitions in this Section.

 (b) Any use by You of any of the Iris Materials and the Website, other than to obtain information available on the Website to the general public regarding Iris and its services, is prohibited. You agree not to reproduce, duplicate, copy, sell, trade, resell, distribute, or exploit any portion of the Website, use of the Website, or access to the Website.

 (c) You agree not to use the Website if You do not meet the eligibility requirements described in Section 2 above.

 (d) You agree not to defame, harass, abuse, threaten, stalk or defraud users of the Website, or collect, or attempt to collect, personal information about users or third parties.

 (e) You agree not to intentionally interfere with or damage, impair or disable the operation of the Website or any user’s enjoyment of it, by any means, including uploading or otherwise disseminating viruses, worms, spyware, adware, or other malicious code.

 (f) You agree not to remove, circumvent, disable, damage or otherwise interfere with any security-related features of the Website, features that prevent or restrict the use or copying of any part of the Website, or features that enforce limitations on the use of the Website.

 (g) You agree not to attempt to gain unauthorized access to the Website, or any part of it, or other computer systems or networks connected to the Website, through hacking, password mining or any other means or interfere or attempt to interfere with the proper working of the Website or any activities conducted through the Website.

 (h) You agree not to obtain or attempt to obtain any materials or information through any means not intentionally made available through the Website. You agree neither to modify the Website in any manner or form, nor to use modified versions of the Website, including (without limitation) for the purpose of obtaining unauthorized access to the Website, or any portion thereof.

 (i) You agree not to use any Iris logos, graphics, or trademarks as part of the link without Iris’s express written consent.

 (j) Except as otherwise expressly permitted by Iris in a separate written agreement between You and Iris, You agree not to make unsolicited offers, advertisements, proposals, or send junk mail or spam to other users of the Website. This includes, but is not limited to, unsolicited advertising, promotional materials or other solicitation material, bulk mailing of commercial advertising, chain mail, informational announcements, charity requests, and petitions for signatures.

 (k) You agree not to reverse engineer, decompile, disassemble or otherwise attempt to discover the source code of the Website or any part thereof.

 (l) You agree not to impersonate another person or entity, or falsely state or otherwise misrepresent your affiliation with a person or entity.

7. Links and Third-Party Websites. Iris or third parties may provide links on the Website to other websites including the content therein (“Other Websites”). Iris has no control over such Other Websites or their content and therefore makes no claim or representation regarding, and expressly disclaims responsibility for, the accuracy, quality, legality, nature, availability, or reliability of Other Websites or content linked to by the Website. Iris provides links to You only as a convenience, and the inclusion of any link on the Website does not imply our affiliation, endorsement, or adoption of the linked Website or any information therein. ACCESS AND USE OF OTHER WEBSITES, INCLUDING THE INFORMATION, MATERIAL, PRODUCTS, AND SERVICES ON OTHER WEBSITES OR AVAILABLE THROUGH REFERENCE WEBSITES, IS SOLELY AT YOUR OWN RISK. Our TOS and policies do not govern your use of any website other than the Website. You should review applicable TOS and policies, including the privacy and data gathering practices, of any Other Websites.

8. Terms of Service Violations; Termination.

 (a) You. Your only remedy with respect to any dissatisfaction with (i) the Website, (ii) any term of the TOS, (iii) any policy or practice of Iris in operating the Website, or (iv) any content or information transmitted through the Website, is to discontinue your use of any and all parts of the Website.

(b) Iris. You agree that Iris, in its sole discretion and for any or no reason, may terminate availability of the Website (or any part thereof). You agree that your access to the Website, or portion thereof, may be terminated without prior notice and You agree that Iris shall not be liable to You or any third-party for any such termination. These remedies are in addition to any other remedies Iris may have at law or in equity.

9. Availability of Service. Iris may make changes to or discontinue any of the services described on the Website at any time, and without notice. The media or services on the Website may be out of date, and Iris makes no commitment to update these materials on the Website.

10. INDEMNIFICATION. YOU AGREE TO INDEMNIFY AND HOLD HARMLESS Iris, AND ITS SUBSIDIARIES, AFFILIATES OR ANY RELATED COMPANIES (INCLUDING THOSE WHICH SHARE SUBSTANTIALLY COMMON OWNERSHIP), AND THE OFFICERS, DIRECTORS, STOCKHOLDERS, EMPLOYEES, AGENTS AND REPRESENTATIVES OF ANY OF THEM FROM ANY AND ALL CLAIMS, LOSSES, OBLIGATIONS, DAMAGES, LIABILITIES, COSTS, DEBT, AND EXPENSES (INCLUDING ATTORNEY’S FEES) ARISING OUT OF (I) YOUR USE OR MISUSE OF THE WEBSITE; (II) YOUR VIOLATION OF THE TOS; (III) YOUR VIOLATION OF THE RIGHTS OF ANY OTHER PERSON OR ENTITY USING THE WEBSITE; AND (IV) YOUR BREACH OF THE FOREGOING REPRESENTATIONS, WARRANTIES, AND COVENANTS. Iris RESERVES THE RIGHT, AT YOUR EXPENSE, TO ASSUME THE EXCLUSIVE DEFENSE AND CONTROL OF ANY MATTER FOR WHICH YOU ARE REQUIRED TO INDEMNIFY US AND YOU AGREE TO COOPERATE WITH OUR DEFENSE OF THESE CLAIMS. YOU AGREE NOT TO SETTLE ANY MATTER WITHOUT THE PRIOR WRITTEN CONSENT OF Iris. Iris WILL USE REASONABLE EFFORTS TO NOTIFY YOU OF ANY SUCH CLAIM, ACTION, OR PROCEEDING UPON BECOMING AWARE OF IT.

11. Disclaimers; No Warranties.

 (a) Acknowledgement. YOU EXPRESSLY ACKNOWLEDGE THAT AS USED IN THIS SECTION 11, THE TERM Iris INCLUDES Iris’S OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, STOCKHOLDERS, AFFILIATES, AND SUBCONTRACTORS.

 (b) No Warranties. TO THE FULLEST EXTENT PERMISSIBLE PURSUANT TO APPLICABLE LAW, Iris DISCLAIMS ALL WARRANTIES, STATUTORY, EXPRESS, OR IMPLIED, INCLUDING, BUT NOT LIMITED TO, IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, AND NON-INFRINGEMENT OF PROPRIETARY RIGHTS. NO ADVICE OR INFORMATION, WHETHER ORAL OR WRITTEN, OBTAINED BY YOU FROM Iris OR THROUGH THE WEBSITE, WILL CREATE ANY WARRANTY NOT EXPRESSLY STATED HEREIN.

 (c) “As is” and “As available” and “With All Faults.” YOU EXPRESSLY AGREE THAT THE USE OF THE WEBSITE IS AT YOUR SOLE RISK. THE WEBSITE IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE”, “WITH ALL FAULTS” BASIS AND WITHOUT WARRANTIES OR REPRESENTATIONS OF ANY KIND, EITHER EXPRESS OR IMPLIED.

 (d) Website Operation. Iris DOES NOT WARRANT THAT THE Iris MATERIALS WILL BE UNINTERRUPTED, OR FREE OF ERRORS, VIRUSES, OR OTHER HARMFUL COMPONENTS AND DOES NOT WARRANT THAT ANY OF THE FOREGOING WILL BE CORRECTED.

 (e) Accuracy. IrisDOES NOT WARRANT OR MAKE ANY REPRESENTATIONS REGARDING THE USE OR THE RESULTS OF THE USE OF THE WEBSITE OR ANY OTHER WEBSITES IN TERMS OF CORRECTNESS, ACCURACY, RELIABILITY, OR OTHERWISE.

 (f) Harm to Your Computer. YOU UNDERSTAND AND AGREE THAT YOUR USE, ACCESS, DOWNLOAD, OR OTHERWISE OBTAINING INFORMATION, MATERIALS, OR DATA THROUGH THE WEBSITE IS AT YOUR OWN DISCRETION AND RISK AND THAT YOU WILL BE SOLELY RESPONSIBLE FOR ANY DAMAGE TO YOUR PROPERTY (INCLUDING YOUR COMPUTER SYSTEM) OR LOSS OF DATA THAT RESULTS FROM THE DOWNLOAD OR USE OF SUCH MATERIAL OR DATA.

12. Limitation of Liability and Damages.

 (a) Limitation of Liability. UNDER NO CIRCUMSTANCES, AND UNDER NO LEGAL THEORY, INCLUDING, BUT NOT LIMITED TO, NEGLIGENCE, SHALL Iris OR ITS AFFILIATES, CONTRACTORS, EMPLOYEES, AGENTS, OR THIRD PARTY PARTNERS OR SUPPLIERS, BE LIABLE FOR ANY SPECIAL, INDIRECT, INCIDENTAL, CONSEQUENTIAL, OR EXEMPLARY DAMAGES (INCLUDING WITHOUT LIMITATION, LOSS OF PROFITS, DATA OR USE OR COST OF COVER) ARISING OUT OF OR RELATING TO THE TOS OR THAT RESULT FROM YOUR USE OR THE INABILITY TO USE THE Iris MATERIALS, THE WEBSITE ITSELF, OR ANY OTHER INTERACTIONS WITH Iris, EVEN IF Iris OR A Iris AUTHORIZED REPRESENTATIVE HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.

 (b) Limitation of Damages. IN NO EVENT SHALL Iris OR ITS AFFILIATES, CONTRACTORS, EMPLOYEES, AGENTS, OR THIRD PARTY PARTNERS, LICENSORS OR SUPPLIERS’ TOTAL LIABILITY TO YOU FOR ALL DAMAGES, LOSSES, AND CAUSES OF ACTION ARISING OUT OF OR RELATING TO THE TOS OR YOUR USE OF THE WEBSITE (WHETHER IN CONTRACT, TORT (INCLUDING NEGLIGENCE), WARRANTY, OR OTHERWISE) EXCEED FIVE HUNDRED DOLLARS (USD$500.00).

13. Limitations by Applicable Law; Basis of the Bargain.

 (a) Limitations by Applicable Law. CERTAIN JURISDICTIONS DO NOT ALLOW LIMITATIONS ON IMPLIED WARRANTIES OR THE EXCLUSION OR LIMITATION OF CERTAIN DAMAGES. IF YOU RESIDE IN SUCH A JURISDICTION, SOME OR ALL OF THE ABOVE DISCLAIMERS, EXCLUSIONS, OR LIMITATIONS MAY NOT APPLY TO YOU, AND YOU MAY HAVE ADDITIONAL RIGHTS. THE LIMITATIONS OR EXCLUSIONS OF WARRANTIES, REMEDIES, OR LIABILITY CONTAINED IN THE TOS APPLY TO YOU TO THE FULLEST EXTENT SUCH LIMITATIONS OR EXCLUSIONS ARE PERMITTED UNDER THE LAWS OF THE JURISDICTION IN WHICH YOU ARE LOCATED.

 (b) Basis of the Bargain. YOU ACKNOWLEDGE AND AGREE THAT Iris HAS PERMITTED YOU TO ACCESS THE WEBSITE IN RELIANCE UPON THE WARRANTY DISCLAIMERS AND THE LIMITATIONS OF LIABILITY SET FORTH HEREIN, THAT THE WARRANTY DISCLAIMERS AND THE LIMITATIONS OF LIABILITY SET FORTH HEREIN REFLECT A REASONABLE AND FAIR ALLOCATION OF RISK BETWEEN YOU AND Iris, AND THAT THE WARRANTY DISCLAIMERS AND THE LIMITATIONS OF LIABILITY SET FORTH HEREIN FORM AN ESSENTIAL BASIS OF THE BARGAIN BETWEEN YOU AND Iris. YOU ACKNOWLEDGE AND AGREE THAT Iris WOULD NOT BE ABLE TO PROVIDE THE WEBSITE TO YOU ON AN ECONOMICALLY REASONABLE BASIS WITHOUT THESE LIMITATIONS.

14. Digital Millennium Copyright Act Compliance.  

If You are a copyright owner or an agent thereof and believe that any third-party content on the Website infringes upon Your copyrights, You may submit a notification pursuant to the Digital Millennium Copyright Act (“DMCA”) by providing our Copyright Agent with the following information in writing (see 17 U.S.C § 512(c)(3) for further detail).

 (i) A physical or electronic signature of a person authorized to act on behalf of the owner of an exclusive right that is allegedly infringed;

 (ii) Identification of the copyrighted work claimed to have been infringed, or, if multiple copyrighted works on the Website are covered by a single notification, a representative list of such works from the Website;

 (iii) Identification of the material that is claimed to be infringing or to be the subject of infringing activity and that is to be removed or access to which is to be disabled, and information reasonably sufficient to permit Iris to locate the material;

 (iv) Information reasonably sufficient to permit Iris to contact the complaining party, such as an address, telephone number, and, if available, an electronic mail address at which the complaining party may be contacted;

 (v) A statement that the complaining party has a good faith belief that use of the material in the manner complained of is not authorized by the copyright owner, its agent, or the law; and

 (vi) A statement that the information in the notification is accurate, and under penalty of perjury, that the complaining party is authorized to act on behalf of the owner of an exclusive right that is allegedly infringed.

 Iris’s designated Copyright Agent to receive notifications of claimed infringement is:

Paige Schaffer
1250 24th Street, N.W.
Washington DC 20037
Email: legal@us.generaliglobalassistance.com 
Telephone: 1-844-728-0394

 15. International Visitors.  All matters relating to our Services are governed by the laws of the State of Florida in the United States of America. If you visit our Services or contact us from outside of the United States of America, please be advised that (i) any information you provide to us or that we automatically collect will be transferred to the United States of America; and (ii) that by using our Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States of America in accordance with this Privacy Policy.

16. Miscellaneous.

 (a) Notice. Iris may provide You with notices, including those regarding changes to the TOS, by postings on the Website.

 (b) Governing Law. The TOS shall be governed by and construed in accordance with the laws of Washington DC, without giving effect to any principles of conflicts of law.

 (c) Jurisdiction. You agree that any action at law or in equity arising out of or relating to the TOS or the Website shall be filed only in the state or federal courts in and for Washington DC and You hereby consent and submit to the personal and exclusive jurisdiction and venue of such courts for the purposes of litigating any such action.

 (d) Waiver. A provision of the TOS may be waived only by a written instrument executed by the party entitled to the benefit of such provision. The failure of Iris to exercise or enforce any right or provision of the TOS will not constitute a waiver of such right or provision.

 (e) Severability. If any provision of the TOS shall be unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from the TOS and shall not affect the validity and enforceability of any remaining provisions.

 (f) Independent Contractor. You agree that no joint venture, partnership, employment, or agency relationship exists between You and Iris as a result of the TOS or use of the Website.

 (g) Claims. YOU AGREE THAT ANY CAUSE OF ACTION BROUGHT BY YOU ARISING OUT OF OR RELATED TO THE WEBSITE MUST COMMENCE WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES. OTHERWISE, SUCH CAUSE OF ACTION IS PERMANENTLY BARRED.

(h)  Disclosures. The services hereunder are offered by:

1250 24th Street, N.W.
Washington DC 20037
Email: legal@us.generaliglobalassistance.com 
Telephone: 1-844-728-0394

If you are a California resident, you may have this same information emailed to you by sending a letter to the foregoing address with your email address and a request for this information.

 

California Privacy Policy

This California Privacy Policy applies only to California consumers (“you” or “your”) and supplements the Privacy Policy of Generali Global Assistance, Inc., dba Iris^® Powered by Generali (“Iris” or “we”). The California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”), collectively referred to as “California Consumer Privacy Laws”, provide California consumers with specific rights regarding their personal information. This California Privacy Policy describes your privacy rights under the California Consumer Privacy Laws, explains how you may exercise your privacy rights, and provides an overview on the types of personal information we collect. 

Scope:
Iris may have collected the following categories of CCPA Personal Information from consumers within the last 12 months:

 

Personal Information does not include:

1. Publicly available information from government records,
2. Information excluded from the CCPA/CPRA’s scope, such as:
   • Protected Health Information under HIPAA, information subject to the California Confidentiality of Medical Information Act, or clinical trial data; or
   • “Business to business” information, which is information related to communications or transactions between a business collecting the information and a consumer who is acting on behalf of another business where the communications or transaction relate solely to an exchange of products or services between the two businesses.

Collection of Your Personal Information:
Iris collect’s each of the categories of Personal Information listed above in one or more of the following ways:

• When you contact us (i.e. from forms you complete).
• Automatically when you use Iris services.
• From other sources, including the Internet and other publicly-available sources and databases, data aggregators, marketing companies, and other third parties. 

How We Use Your Personal Information:
Iris may use or disclose each of the categories of Personal Information described above for one or more of the following business purposes:

• Information: Iris may use your Personal Information to verify your identity or provide you the information, products, and services that you request.
• Experience: Iris may use your Personal Information to personalize and enhance your experience.
• Business Transaction: If Iris is exploring or go through a business transition, such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, securities offering, or sale of all or a portion of Iris assets.
• Legal Purposes: Iris will use your Personal Information when we think it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant or similar legal process; or if necessary to assert or protect our rights or assets.

Sharing Your Personal Information:
Iris may share your Personal Information with the following categories of third parties for a business purpose:

• Internally: (i.e. with our group companies and affiliates).
• Vendors: Iris may share your Personal Information with our vendors (including third-party hosting providers) that provide services on our behalf, such as for email marketing, advertising, promotions, newsletters, notices and other communications, or that assist us in monitoring, improving, and hosting services.
• Business Transaction: If Iris is exploring or go through a business transition, such as a merger, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, securities offering, or sale of all or a portion of Iris assets.
• Legal Purposes: Iris may disclose your Personal Information when it thinks it is necessary to investigate or prevent actual or expected fraud, criminal activity, injury or damage to us or others; when otherwise required by law, regulation, subpoena, court order, warrant or similar legal process; or if necessary to assert or protect our rights or assets.

Security Measures:
Iris restricts access to your personal information to employees who we have determined need it in order to provide products or services to you. Further, Iris provides thorough training to its employees to safeguard customer personal information. We maintain strict physical, electronic and procedural safeguards to protect your personal information from unauthorized access by third parties. 

Rights and Choices under the CCPA/CPRA:

• Right to Access:  You have the right to access your Personal Information that we may collect or retain about you. If requested, we shall provide you with a copy of your Personal Information that we collect as permitted by the CCPA/CPRA.
• Right to Know: You have the right to request that we disclose the following about your Personal Information, as defined by the CCPA/CPRA:
  • The specific Personal Information we may collect;
  • The categories of Personal Information we may collect;
  • The categories of sources from which we may collect your Personal Information;
  • The business purpose(s) for collecting or sharing your Personal Information;
  • The categories of Personal Information we may disclose for business purposes; and
  • The categories of third parties to whom we may share your Personal Information.
• Right to Deletion:
  • You have the right to request that we delete any of your Personal Information that Iris collected from you and retained, subject to certain exceptions. Any requests for deletion should be directed at legal@us.generaliglobalassistance.com.
  • Iris may deny your deletion request for reasons permitted by the CCPA/CPRA. (i.e. if the information is excluded from the CCPA/CPRA or does not constitute Personal Information).
• Right to Opt Out: You have the right to opt out of the sale or sharing of personal information. If we sell any of your personal information, you have the right, at any time, to tell us not to sell your personal information. At the time this California Privacy Policy was last updated, we do not sell any personal information. You also have the right to request that we do not share your personal information.
• Right to Correct: You have the right to request the correction of any personal information we maintain about you.
• Right to Limit Use or Disclosure of Sensitive Personal Information (“SPI”): You have the right to limit the use and disclosure of your SPI, if we are using your SPI beyond what is reasonable and proportionate to provide the requested goods or services.
• Response Timing and Format: Once verified the request is from a California consumer, Iris will try to respond within 45 days. If we need more time, we will tell you in writing why and how much longer we need, either by mail or electronically (based on your choice).
• Non-Discrimination: Iris will not discriminate against you for choosing to exercise any of your CCPA/CPRA rights, including with respect to any Iris services.
• Alternative Format: To obtain this California Privacy Policy in an alternative format please contact Iris at 1-844-728-0394.

Changes and Updates to this Privacy Policy:
Iris may occasionally update this California Privacy Policy. Your continued use of the Website constitutes Your agreement to this California Privacy Policy and any updates.  

Contacting Us:
If you have any questions or comments about this Supplement, including how we collect and use your Personal Information or your choices and rights regarding such use, or if you wish to exercise your rights under California law, please contact us by either:

Generali Global Assistance, Inc., dba Iris^® Powered by Generali 
1250 24th Street, N.W.
Washington DC 20037
Email: legal@us.generaliglobalassistance.com 
Telephone: 1-844-728-0394

GDPR Privacy Policy

Introduction

Generali Global Assistance, Inc., dba Iris® Powered by Generali (“Iris”) recognizes that the personal information we receive is held in a position of trust. We therefore seek to fulfil that trust by adhering to general principles regarding the protection of personal information. This Privacy Policy explains how we collect, use, share, and protect information gathered through this Site and during other interactions you may have with Iris.

Scope

This Privacy Policy applies to personal information collected on websites, mobile applications, or controlled widgets embedded in communication platforms (“Sites”) and personal information collected in connection with Iris’ business operations, such as information from patients, health care professionals or employees’ human resource data. Personal Information as used herein, is any information that can be used either alone or combined with other information to identify an individual or that can be directly linked to an individual. This Privacy Policy describes Iris’ collection, use, and distribution practices with respect to personal information.

Information Collection

Iris does not require you to provide Personal Information to access any portion of our public website. Only Personal Information you voluntarily provide to us is collected. Iris maintains physical, technical, and administrative safeguards to protect your nonpublic personal information. Personal Information collected via Iris Sites may include, but is not limited to:

• Contact information, such as name, address, email, telephone number, fax number, and/or job title
• Unique identifiers and preference information marketing preferences, internet protocol (IP) address, browser type, operating system, computer or mobile device, or navigation and clickstream behavior

Iris may collect, keep, and use Personal Information obtained through the Sites to provide you with access to the Sites. This information may be collected when you:

• Create an account with Iris
• Request a product demo or receive information about our products
• Request customer or technical support
• Apply for employment
• Request to be contacted, i.e. through our website or at exhibitions
• Receive our products or services

Basis for Using Personal Information

• Compliance with legal requirements or obligations – Iris may disclose Personal Information as permitted or required by law when we believe in good faith it is necessary for safety purposes, required for legal reporting, necessary to protect our legal rights or enforce our Terms of Use or any applicable rules or to protect the rights of others.
• For establishment or performance of a contract – The use of Personal Information may be necessary to perform the contract that you have with us or your insurance provider has with Iris. 
• Consent – Iris will rely on consent, which is (i) gained through a contractual relationship or (ii) in some cases may be implied, to use technical information such as cookie data and geolocation data as described in this Privacy Policy. Consent may be withdrawn at any time by contacting us through the mediums described within this Privacy Policy. We may obtain Personal Information through healthcare professionals or users of our products and services, in which case that healthcare professional or product/services user is responsible for the management of consent, where required.
• Legitimate interests – Iris may use Personal Information for our legitimate interests to improve our products, services and website content and for administrative purposes.

Marketing

Iris markets in a number of ways, including, but not limited to, email marketing campaigns. We may use your Personal Information to inform you of other products or services offered by Iris. We do not sell, rent, or lease our customer’s lists to third parties. In order to help provide our services, we occasionally provide information to other affiliate companies that work on our behalf.

Tracking Tools

Your browser may give you the ability to control cookies. How you do so depends on your browser and the type of cookie. Certain browsers can be set to reject all browser cookies. If you configure your computer to block all cookies, you may disrupt certain web page features and limit the functionality we can provide when you visit or use our Sites. If you block or delete cookies, not all of the tracking that we have described in this Policy will stop. Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked.

How Long We Keep Information

Iris will retain your Personal Information for as long as reasonably necessary for legitimate business purposes.

Security

The security and confidentiality of your Personal Information matters to us. For this reason, Iris has physical, technical and administrative controls in place to protect your Personal Information from unauthorized access, use and disclosure. Iris evaluates these safeguards on an ongoing basis to help minimize risks from new security threats as they become known. However, as is the case with all websites, Iris is not able to guarantee security for data collected through our Site.

Rights

You may contact us at any time to request access to or rectify your Personal Information. You also have a right to the objection to or restriction of processing, as well as the right to data portability, when applicable. If Iris has processed your Personal Information based on your consent, you have a right to withdraw it at any time. To exercise your rights, please write to us at the contact information provided below. Please note that additional information will likely be requested from you in order to honor the request. If you receive any marketing email from Iris, you may request to have your Personal Information removed using the unsubscribe link, or reply email address, provided within the content.

Processing of Personal Data 

The subject matter and duration of the processing of Personal Information by Iris is set out in contractual agreements with its clients. 

Updates

This Privacy Policy may be amended at any time. If material changes are made in how Personal Information is collected, used, disclosed, or otherwise processed, this Privacy Policy will be updated. 

Generali Global Assistance, Inc., dba Iris^® Powered by Generali
1250 24th Street, N.W.
Washington DC 20037
Email: legal@us.generaliglobalassistance.com 
Telephone: 1-844-728-0394

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