We respect your privacy and are committed to protecting it through our compliance with this Privacy Policy. This Privacy Policy describes the types of information AXAD, LLC, a New York based limited liability company (collectively, “we,” “us,” or “our”) collects from and about you when you visit our website, www.getmemymedicare.com (the “Site”), or otherwise contact or interact with us offline (“Offline Services”). The Site and Offline Services are collectively the “Services.” This Privacy Policy also explains how we may use and disclose that information.

Please read this Privacy Policy and our Terms of Use carefully to understand our policies and practices regarding your personal information and how we will treat it. By accessing, using or submitting information through the Services, you agree to this Privacy Policy and our Terms of Use. This Privacy Policy may change from time to time and your continued use of the Services is deemed to be acceptance of such changes, so please check periodically for updates (see Changes to this Privacy Policy below).

Please note that the Services are operated in and targeted to consumers in the United States. The Services are not intended for residents of the European Union or Canada or any other country outside the United States. If you are located in the European Union, Canada or elsewhere outside of the United States, please be aware that any information you provide to us will be transferred to the United States and may be stored on servers in the United States.

1. INFORMATION WE COLLECT

There are several ways we may obtain information from or about users of the Services, including the information described below.

A. Information You Provide

We collect personal information from you when you choose to share it with us. This may include when you use our Services, request a quote, fill out forms or fields on the Site, create or submit an application, request information from us, sign up for newsletters or our email list, participate in a survey or promotion, or when you otherwise communicate with us or request information from us, whether via email or other means.

The personal information we collect may include your name, postal address, e-mail address, and phone number. You may also be required to provide certain information to complete an online application, request a quote, or receive certain offers. This information may include, but may not be limited to, gender, zip code, birth date, government-issued identification number (such as a Driver’s License number), Social Security Number (SSN), credit/debit card number and/or financial account information, or certain medical and health information.

B. Information Automatically Collected on the Site

Whenever you visit or interact with the Site, we may use a variety of technologies, such as cookies, web beacons, pixel tags, log files, local shared objects (Flash cookies), HTML5 cookies, or other technologies, to automatically or passively collect certain information about visitors to our Site and interactions with our emails, online advertisements and offers.

Please note that we automatically collect the following information about you:

• Computer or Device Information. We may automatically collect your Internet Protocol (“IP”) address or other unique identifier or information from the computer, mobile device, tablet or other device you use to access the Site, including but not limited to your browser type, device type, operating system, software version, phone model, phone operating system, and the domain name from which you accessed the Site.
• Usage Information. We also may collect information about your use of the Site, including the date and time you visit the Site, the areas or pages of the Site that you visit, the amount of time you spend viewing or using the Site, the number of times you return to the Site, other click-stream or site usage data, emails that you open, forward or click-through to our Site, and other sites that you may visit.
• Our Third Party Service Providers. We may use third party service providers to support our Site. Some of these service providers may use technology such as cookies, web beacons, pixel tags, log files, Flash cookies, or HTML5 cookies to receive, collect, and store information
• Use of Third Party Analytics and Technologies. We may use third parties’ analytics and tracking tools to better understand who is using the Site, how people are using the Site, how to improve the effectiveness of the Services and related content, to help us or those third parties serve more targeted advertising to you online or offline, and to better understand the demographics and interests of our visitors. These tools may use technology such as first-party or third-party cookies, web beacons, pixel tags, log files, or other technologies to automatically or passively collect and store certain information. They may also combine information they collect from your interaction with the Site with information they collect from other sources. We do not have access to, or control over, these third parties’ use of cookies or other tracking technologies.

 C. Information Collected From Other Sources

We may acquire information from other sources as follows:

• From other trusted third-party sources to update or supplement the information that you provide or that we collect automatically. This includes, for example, information from public databases or data aggregators (which may include your demographic information, previous purchases, lifestyle preferences, or information to validate or update the information we collect from or about you).
• From our partners and service providers (including, for example, business partners, analytics vendors, advertising networks and search information providers).

We may use this information to help us maintain the accuracy of the information we collect, personalize your experience with the Services, target our communications so that we can inform you of products, services or other offers that may be of interest to you, to measure ad quality and responses, and for internal business analysis or other business purposes.

D. Combination of Information

We may combine the information we receive from and about you, including information you provide to us and information we automatically collect through our Services, as well as information collected offline, across other computers or devices that you may use, or from third party sources.

2. HOW WE USE YOUR INFORMATION

A. Information Use by or on Behalf of Us

We may use the information we collect from or about you to:

• Confirm, process, or otherwise complete a transaction or transactions requested by you;
• Provide customer support (including, responding to your requests), troubleshoot and resolve problems and disputes;
• Contact you to verify the information you provide to us, or otherwise contact you when necessary;
• Understand and anticipate your needs and preferences;
• Provide you with customized Site content, targeted offers, and advertising on the Site, via email, direct mail, by phone, or across other websites, mobile applications, social media or online services from us or on behalf of our partners and affiliates;
• Provide you with promotional materials, newsletters, offers and personalized information from us or on behalf of our partners and affiliates;
• Protect the security and integrity of the Services, and our business;
• Conduct internal reviews of the Services, administer this Site’s systems, and review the usage and operations of our Services and improve our content, products, and services;
• Comply with, monitor compliance with and enforce this Privacy Policy, our Terms of Use and any other applicable agreements and policies;
• Develop, analyze, enhance and market our products and services or the products and services of third parties;
• To use your data in an aggregated non-specific format for analytical and demographic purposes;
• Manage our business and operations;
• Meet legal and regulatory requirements;
• Provide administrative communications to you;
• Submit your credit card or other payment information when ordering and/or purchasing products and/or services through the Services; and
• For other purposes as may be disclosed when you provide personally identifiable information or in this Privacy Policy.

Additionally, if you use the Services to connect with third party services you authorize us to use information from and about you, on your behalf, to interact with these third party services based on your requests.

B. How We Use Your Information for Interest-Based Advertising

We may use third parties to measure and target advertisements on our behalf about our products and services that are tailored to your online interests. We allow these third-party companies to use cookies, web beacons, pixels and similar technologies to collect certain data and other information about your online activity. This information is used to display advertisements for us on the Site or across other websites, mobile applications, social media or online services that you use, or to send you promotional materials or offers via email or direct mail.

We also may display interest-based ads through Facebook, Twitter, or other social media platforms or websites. This is done through the Facebook Custom Audiences, Twitter Tailor Audiences, or other similar business tools. These tools allow us to personalize our ads based on your shopping experience with us, without having to share your personal information with these social media platforms. We do this only by sharing hashed information (which converts your email or phone number to a unique string of numbers and letters) that the social media platform then matches data against its own data for the limited purpose of serving advertisements (either directly to you or to other lookalike audiences). The matched and unmatched hashes are then deleted, and are not used for any other purpose.

For information on your choices with respect to interest-based ads, see the “Interest Based Advertising Choices” section below.

3. DISCLOSURE OF YOUR INFORMATION

A. Information You Disclose to Third Parties

You may be presented with an opportunity to receive information and/or marketing offers from third parties in connection with this Site. All information you disclose to such third parties will be subject to the privacy policy and practices of such third parties. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review the privacy policies and practices of such third parties prior to disclosing information to them. If you later decide that you no longer want to receive communications from a third party, you will need to contact that third party directly.

B. Information We Share with Others

We may disclose the information we collect from or about you as described below:

• Subsidiaries and Affiliates: We may share your information with our affiliated companies (i.e., companies under common ownership, control or management with us) for business, operational, promotional and marketing purposes.
• Service Providers: We may share your information with our third party service providers so that they may provide support for our internal and business operations, including for the handling of data processing, data storage, surveys, research, internal marketing, delivery of promotional and transaction materials, and this Site’s maintenance and security;
• Third Parties: We may disclose your information to third parties when you (i) engage in certain activities on this Site that are sponsored by them, such as purchasing products or services offered by a third party, electing to receive information or communications from a third party, or electing to participate in programs sponsored in whole or in part by a third party; (ii) respond to promotional materials from us and you authorize a third party to use your personal information to, for example, send you additional promotional materials or provide you a product or service; and/or make a Request or submit an Application (as described below). When we disclose your personal information to these third parties, your personal information will become permanently subject to the information use and sharing practices of the third party, and the third party will not be restricted by this Privacy Policy with respect to its use and further sharing of your personally identifiable information;
• For Promotional Purposes: We may disclose your information to our sponsors, partners, advertisers or other third parties to provide you with product information and promotional and other offers on our Site, or across other third party sites, mobile application, social media, or other online services. This information may be used by such third parties for those parties’ own purposes, such as to offer products or services that may interest you.
• Your Agent: To any person who, in our reasonable judgment, is authorized to receive your personally identifiable information as your agent, including as a result of your business dealings with that person (for example, your attorney);
• Legal Matters; Safety: We may access and disclose your information to respond to subpoenas, judicial processes, or government requests and investigations, or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law (including in the event of any act of terrorism or instance of local, regional or national emergency). We may disclose your information to protect the security of our Site, servers, network systems, and databases. We also may disclose your information as we deem necessary, if we believe that there has been a violation of our Privacy Policy, Terms of Use, any other legal document or contract related to our services, if we believe that you are violating any applicable law, rule or regulation, or are otherwise interfering with the rights of any third party.
• Sale or Transfer of Business or Assets: In connection with a Business Transfer, as defined below (see Business Transfers below); and We specifically and expressly reserve the right to disclose, lease, sell, assign or transfer your personally identifiable information collected through this Site, and any of its databases, together with any personally identifiable information contained in such data bases, to third parties in connection with a Business Transfer. A “Business Transfer” means a sale, acquisition, merger, consolidation, reorganization, bankruptcy or other corporate change involving us and/or our affiliates, even if the Business Transfer is only being contemplated and regardless of whether the Business Transfer relates to a part or a whole of our business. Nothing in this Privacy Policy is intended to interfere with our ability to transfer all or part of our business, equity, and/or assets (including this Site) to an affiliate or independent third party at any time, for any purpose, without any limitation, without notice, any without any compensation to you, whatsoever.
• Aggregate or Anonymous Non-Personal Information: We may also share aggregate, anonymous, or de-identified non-personal information with third parties for their marketing or analytics uses.

We also may share your information as otherwise disclosed to you at the time of collection.

C. Your Requests for Quotes and Services or Submission of Online Applications

Certain portions of this Site may allow you to provide your personal information to one or more third parties, such as insurance providers (“Requested Service Providers”) in order to request a quote, services or information from Requested Service Providers (e.g., by clicking “Submit” or “get your quotes”) (a “Request”) or to submit your information to Requested Service Providers through an online application (“Application”). If you make a Request or submit an Application, we may share, loan, rent or sell your personal information to the Requested Service Providers or other affiliates that we match with your Request or Application, your current provider, or to other third parties that may match you with a Requested Service Provider. In addition, the Requested Service Providers and such third parties may further disclose, share and use any personal information provided by you in connection with your Request or Application. If you make a Request or submit an Application, you expressly consent to such disclosure and use of your personal information. If you do not want your personal information shared as described above, then you should not make a Request or submit an Application.

If you make a request or submit an application, the requested service providers may contact you directly via telephone, fax, and/or email. you may receive telephone calls as a consequence of submitting a request on this site, even if you are on the national do not call registry or any other do not call registry.

If you are matched with Requested Service Providers, you expressly consent to the Requested Service Providers conducting any research necessary to provide you with quotes for your Request, or to process your Application. Requested Service Providers may need to share your personal information to conduct such research. If you do not want Requested Service Providers to conduct necessary research to provide you with a quote for your Request or to process your Application, then you should not make such Request or submit such Application.

Please note that if you make a Request or submit an Application on this Site, and we share your information as described above in connection with your Request or Application, you will not have the opportunity to opt out of the disclosure of your information in connection with that Request or Application.

4. YOUR CHOICES AND OPT-OUT OPTIONS

A. Cookies, Tracking Options and California Do Not Track Disclosures

Certain parts of our Site require cookies. You may adjust your device or Internet browser settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features on the Site or take full advantage of all of our offerings. Please refer to your device’s settings or your Internet browser’s “Help” section for more information on how to delete and/or disable your device or browser from receiving cookies or controlling your tracking preferences.

Our system may not respond to Do Not Track requests or headers from some or all browsers. We may use cookies or other technologies to deliver more relevant advertising and to link data collected across other computers or devices that you may use.

B. Interest-Based Advertising Choices

To understand your choices for receiving more relevant advertising provided on the Service or across other websites and online services, please review the information below:

• To learn more about such interest-based advertising, and to opt out of such collection and use for interest-based advertising by the AXAD LLC participating companies, please visit https://www.optout.axad.com
• To learn more about how to opt out of receiving direct mail, please visit https://thedma.org/accountability/dma-choice/
• On your mobile device, you may also adjust your privacy and advertising settings to control whether you want to receive more relevant advertising.

Even if you opt out, you still may receive advertising from us that is not customized based on your Site or usage information, or advertising from other third parties if they are not a AXAD or participating companies

C. Opting-Out of our Marketing Communications

We provide our customers with the opportunity to opt-out of having their information used for purposes not directly related to placement, processing, fulfillment, or delivery of a product or service. To opt-out of marketing communications or to request to be added to our Do Not Call List or Do Not Mail List, you may use one of these convenient methods:

• Electronic Promotional Offers. If you do not wish to receive email offers or newsletters from us, you can opt-out of receiving email information from us (other than emails related to the completion of your registration, correction of user data, change of password and other similar communications essential to your transactions through the Services) by using the unsubscribe process at the bottom of any email.
• Direct Mail Promotional Offers. If you do not want us to send you any promotional offers through direct mail, you may: (i) call us at 1-914-427-7860; or (ii) mail us with “Do Not Mail” in the subject line at the address set forth in the “Contact Us” section.
• Telemarketing. If you do not want to receive marketing phone calls from us, you may: (i) call us at 1-914-427-7860; (ii) ask to be placed on our Do Not Call list when you receive a call from us; or (iii) mail us with “Do Not Call” in the subject line at the address set forth in the “Contact Us” section.

Your instructions to limit the use of your information for these purposes will be processed as soon as reasonably practicable. Additionally, we are not responsible for informing third parties (including without limitation our third party service providers or partners) with whom we have already shared your personal information of any changes requested pursuant to this section, or for removing information from or causing information to be removed from the databases or records of such entities.

D. Access to Your Personal Information

If this Site allows you to create an account with us, then you can review and update your personal information by logging into this Site, visiting your account profile page and making changes. If you need to update your information after you make a Request or submit an Application through the Services, then you may contact us at the address set forth in the “Contact Us” section.

5. YOUR CALIFORNIA PRIVACY RIGHTS

California law allows users of this Site that reside in California to know the third parties with whom we shared their personal information for those parties’ own marketing purposes. The type of information and instances in which we share such information is detailed in this Privacy Policy. However, if you are a resident of California and you would like to know the specific companies with whom we shared your personal information and the categories of the information we shared, you may send us a written request for such information to the following address:

AXAD LLC

31W 34^th Street

New York, NY 10001

Attention: Customer Service (California Privacy Rights)

You must put the statement “California Privacy Rights” in the subject field. We are not responsible for notices that are not labeled or sent properly, or do not have complete information. If you have any further questions about your rights under California law, you should send us an inquiry via the methods listed above.

Non-affiliated third parties are independent from us and if you wish to receive information about your disclosure choices or stop communications from such third parties, you will need to contact those non-affiliated third parties directly.

6. CHILDREN’S PRIVACY

The Services are not intended for children under 18 years of age and we do not knowingly collect personal information from children under 18. You must be at least 18 years of age to register with or use certain portions of the Services. If you are under 18 years of age, please do not send any information about yourself to us or on this Site, including your name, address, telephone number or e-mail address. In the event that we learn that we have collected personal information from a child, we will delete that information and otherwise comply with the requirements of the Children’s Online Privacy Protection Act and applicable law. If you believe that we might have any information from or about a child, please contact us at the address set forth in the “Contact Us” section.

7. DATA SECURITY

We have taken certain physical, administrative, and technical steps to safeguard the information we collect from and about our customers through the Services. While we make every effort to help ensure the integrity and security of our network and systems, we cannot guarantee our security measures

8. THIRD-PARTY CONTENT, LINKS, AND PLUG-INS

This Site, as well as the e-mail messages sent with respect to this Site, may contain links to third-party websites, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites, and such are not an endorsement by us of such third parties, their websites, their products, their services, or their practices. The Site may also offer you the ability to interact with social plugins from social media sites, which may allow us and/or the social media site to receive data from or about you. In some cases, we may know that you clicked on a social plugin, such as a Twitter Follow button, or receive other information from the social media sites. Similarly, if you have previously provided personal information to a third-party operating a plug-in on this Site, then such third-party may recognize you on this Site. Your use of social network plugins is subject to each social media site’s privacy policy, which may be different from ours, so please read these policies carefully to understand their policies and your options. As with linked sites, we have no control over the information that is collected, stored, or used by social network plugins, and are not responsible for the practices of such sites.

9. CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at any time. Amendments will take effect immediately upon us posting the updated Privacy Policy on this Site. You are encouraged to revisit this Privacy Policy from time to time in order to review any changes that have been made. The date on which this Privacy Policy was last updated will be noted immediately above this Privacy Policy. Your continued use of the Services following the posting of changes to these terms means you accept these changes.

10. MEDICARE ADVANTAGE / MAPD / PDP CALLS

You agree that you may be presented with Medicare Supplement, Medicare Advantage and/or Prescription Drug Plans available in your area.

11. CONTACT US

If you have questions or concerns about our privacy practices or wish to make a request regarding your personally identifiable information, please contact us at:

• Via mail: AXAD, LLC, 31W 34th Street, New York, NY 10001