BLUESTAR RETIREMENT SERVICES, INC.
Privacy Policy
June 2020
This Privacy Policy Will Address:
- Personal Information We Collect
- How We Use Personal Information
- How We Share Personal Information
- Children
- Security
- Third Party Sites
- Additional Privacy Information for California Residents
- GLBA Notices
BlueStar Retirement Services, Inc. (“BlueStar”) takes privacy issues seriously and we are committed to protecting and respecting the privacy and security of your personal information. This Privacy Policy describes our practices in connection with information that we collect through this website. This policy sets out important information regarding BlueStar, and how your personal information will be collected, used, and protected. Please note that certain portions of this policy may, or may not. be applicable to you based on the services and products in which you are enrolled and applicable laws.
Personal Information We Collect
We intend to limit the amount of personal information collected by us to the minimum amount necessary to deliver the products or services you expect from us.
Information collected directly from you
The types of Personal Information we collect depends on the product you have with us, or about which you have inquired, or the services we provide. We collect information from you when you communicate with us by email, visit our website, use the chat function, through written correspondence, or by phone. This information can include identifying information about you such as your name, address, and date of birth, as well as certain financial information, information about your beneficiaries or your employment information.
Information collected from third parties
We also collect information about you from third parties such as employers, sponsors, advisors, or other plans, or from your representative when you complete applications and forms for various products or services. This information may include, but is not limited to, certain financial, employment, and retirement information.
Information collected automatically
When you access our website, we use a variety of technologies, such as cookies, that automatically collect data (such as, without limitation, your device type, browser type, internet protocol address, operating system used, number of visits, average time spent on the site, and pages viewed). This data is used to operate the website more efficiently, maintain the security of your online session, and improve our website design.
How We Use Personal Information
BlueStar uses your personal information to respond to your requests and inquiries and to provide you with services. If you are enrolled in a retirement plan that is administered by BlueStar pursuant to a services agreement with the plan sponsor (your employer or former employer) of your retirement plan, BlueStar will process your data to perform its services for the Plan Sponsor. BlueStar may also use your personal information to make retirement projections or make distributions or loans. We may also use your personal information to fulfill our compliance obligations. We may also use your information to offer you other financial products or services that may be of interest to you. We will use your personal information for other purposes as permitted by law, including to protect your interests and ours in the detection, prevention and mitigation of fraud, to meet the requirements of applicable laws and regulations, to comply with requests of regulators with jurisdiction over our services, and for product development and delivery.
How We Share Personal Information
We limit the information we share with third parties. We do not sell your personal data. What we share depends upon the types of products and services you have procured and applicable law. Personal data may be shared as necessary to effect, administer, or enforce a transaction you request or authorize, or with your consent, at your direction, or as allowed by applicable law. For example, such data may be shared with:
- Plan Sponsors
- Service providers hired by the Plan Sponsors, including investment managers and advisors
- Fraud prevention vendors
Other disclosures of your personal information that may be made, subject to applicable law, includes disclosures:
- To protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability.
- For institutional risk control, or for resolving customer disputes or inquiries.
- To persons acting in a fiduciary or representative capacity on your behalf.
- To provide information to persons assessing our compliance with industry standards, and our attorneys,
accountants and auditors. - To protect the confidentiality or security of our records pertaining to you, the service or product, or the transaction
therein. - To comply with federal, state, or local laws, rules, and other applicable legal requirements.
- To comply with a properly authorized civil, criminal, or regulatory investigation or subpoena or summons by
federal, state, or local authorities having jurisdiction over the financial institution for examination, compliance, or
other purpose as authorized by law. - For purposes otherwise permitted or required by law.
Children
BlueStar will not knowingly collect personal data from children under the age of 16 without seeking prior parental consent if required by applicable law. We will only use or disclose personal data about a child to the extent permitted by law, to seek parental consent pursuant to local law and regulations, or to protect a child. The definition of “child” or “children” may be slightly different as set forth in various applicable laws.
Security
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or any data storage system can be guaranteed to be 100 percent secure. If you have reason to believe that your interaction with us is no longer secure, please contact us at the address below.
Third Party Sites
This Privacy Policy does not address, and we are not responsible for, the privacy information gathered, or other practices of any third parties, including any third party operating any site, if we provide a link. The inclusion of a link on this site does not imply endorsement of the linked site by us or our affiliates.
Additional Information For California Residents – California Consumer Privacy Act Notice
June 2020
The California Consumer Privacy Act of 2018 (“CCPA”) gives California consumers the right to know what Personal Information is collected about them, and how it will be used, disclosed, and sold. The CCPA also gives California consumers the right to request access to and deletion of their personal information, and the right to request that their personal information not be sold.
The purpose of this notice is to provide consumers with a description of our practices regarding the collection, use, disclosure, and sale of Personal Information and instructions for submitting CCPA data privacy requests.
Much of the Personal Information that we collect, use, and disclose may be exempt from the CCPA because it is regulated by other federal and state laws. But because we are concerned about privacy issues, we want you to be familiar with how we collect, use, and disclose your Personal Information.
Collection of Personal Information
The types of Personal Information we collect, use, and disclose depend on your relationship with us. If the nature of your relationship with us changes, an additional privacy notice may apply and will be provided to you. We have collected in the preceding 12 months or may collect in the future the following categories of Personal Information about California consumers:
| Types of Personal Information | Examples | Primary Purpose for Collection |
| Identifying information about you. | Identifiers such as name, postal address, internet protocol (IP) address, email address, account name, Social Security number, or other similar identifiers including signature, physical characteristics or description, telephone number, bank account number, any other financial information |
To respond to your requests and inquiries, process and administer your application, provide you with services. |
| Characteristics of protected classifications under California or federal law. | Gender, marital status, age, health information. | To process and administer your plan and provide you with other requested services. |
| Commercial information. | Records of other financial products or services purchased. | For institutional risk control, or for resolving customer disputes or inquiries, to persons acting in a fiduciary or representative capacity on your behalf, to provide information to persons assessing our compliance with industry standards, and our attorneys, accountants and auditors, to protect the confidentiality or security of our records pertaining to you, the service or product, or to market other financial products or services. |
| Internet or other electronic network activity information. | Information regarding a consumer’s interaction with an internet website, application, or advertisement, browser information, web analytics, including IP address, time of visit, page(s) visited, cookies, pixel tags, and other similar technologies, Filtering IP Addresses and phone call area code information for fraud prevention and other associated purposes |
To operate the website more efficiently, maintain the security of your online session, improve our website design, protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability, and to protect the confidentiality or security of our records pertaining to you, the service, or product. |
| Audio, electronic, visual, thermal, olfactory, or similar information. | Customer service call recordings. | To protect against or prevent actual or potential fraud, unauthorized transactions, claims or other liability. |
How We Collect Personal Information
We collect the Personal Information in the chart above from the following categories or sources:
- From you and your transactions with us,
- From your employer, and/or
- From Plans Sponsors or advisors
Why We Collect Personal Information
We collect the Personal Information as described in the chart above to (a) comply with legal process; (b) respond to requests from public and government authorities; (c) enforce our terms and conditions; (d) protect our operations; (e) protect our rights, privacy, safety, or property; and (f) allow us to pursue available remedies or limit the damages that we may sustain.
We may combine the Personal Information we collect for the above purposes. We will not collect additional categories of Personal Information, nor use the Personal Information collected for additional purposes, without providing you with additional notice.
What Personal Information We Sell or Share
The CCPA defines “sale” very broadly to include sharing or disclosing of personal information with a third party. There are a number of circumstances where we are allowed to share personal information with third parties, which are not considered to be a sale. For example, we may share personal information with service providers who work on our behalf if the service provider agrees not to use your personal information for other purposes. We do not sell Personal Information for revenue-generating purposes.
We do not sell the personal information of minors under 16 years of age.
We may share the Personal Information with third parties, including but not limited to, third party service providers, law enforcement, and government agencies.
Your Rights
We may determine that the Personal Information related to your request is exempt from the CCPA. If your Personal Information is exempt, the CCPA does not require us to provide it to you or delete it, but we may provide information about the categories of Personal Information we collect, use, and disclose based on your relationship with us in response to your verifiable request. In the interest of good customer relations, your rights are outlined below:
- You have the right to request that we disclose what personal information we have collected about during the past
12 months. - You have the right to request that we delete personal information about you that we have collected about you. Note that the CCPA includes exemptions that provide that we do not have to delete data that is necessary to complete a transaction, detect security incidents, or for certain other internal purposes.
- We do not sell your personal information so there is no need to opt-out of the sale of such information.
- You have a right not to receive discriminatory treatment by us for exercising your privacy rights.
How to Submit a Data Privacy Request
To submit a request for access or deletion (to the extent we can do so), please email us at service@bluestarretirement.com. You can also submit a request by calling our dedicated toll-free number at 800.878.5220.
Verification of Your Identity
To process your request for access or deletion, we must be able to verify your identity to a reasonable degree of certainty. We will ask you to provide your contact information and an additional identifier based on your relationship with us. Before we process your request, we will match these data points with data points we currently maintain to verify your identity and your relationship with us.
Responding to Your Requests
Please note that because much of the data we have is exempt from the CCPA, we are not required to provide you with access to certain information under the CCPA.
You can designate an authorized agent to make a request to know or delete, on your behalf. When you use an authorized agent to submit a request for access or deletion, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.
Contact for More Information
For questions or concerns about our privacy policies and practices, please contact us at service@bluestarretirement.com or 800.878.5220