Last modified: June 8, 2021 Introduction Triple-S Management Corporation, Triple-S Salud, Inc., Triple-S Advantage, Inc., Triple-S Propiedad, Inc. and Triple-S Vida, Inc. (jointly “Triple-S”, the “Company” or “We”) respect your privacy and are committed to safeguarding the personal information that is received from you when you interact with any of the Company’s mobile applications, websites and online services. In some cases, the information we collect about you is subject to the requirements of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and/or the Gramm Leach Bliley Act (“GLBA”), as amended. If you are a Triple-S member and register to use the online member portal services, that information is subject to HIPAA and/or the GLBA. In those circumstances, Triple-S Salud, Inc.’s and Triple-S Advantage Inc.’s HIPAA Notice of Privacy Practices and Triple-S Vida, Inc.’s and Triple-S Propiedad, Inc.’s GLBA Notice of Privacy Practices, shall apply (jointly “Notice of Privacy Practices”). This Website Privacy Notice describes the types of information we may collect from you or that you may provide when you visit our websites [management.grupotriples.com; salud.grupotriples.com; advantage.grupotriples.com; sssvital.com; propiedad.grupotriples.com; vida.grupotriples.com], (our “Websites”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. If you have questions about which policy applies in a certain situation, please contact Triple-S’s Corporate Compliance & Ethics Director at moc.r1732180477psss@1732180477racyn1732180477nej1732180477 or 787-749-4949. This policy applies to information we collect: On this Website. In electronic messages between you and this Website. When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy. It does not apply to information collected by: Us offline; or Any third party through any application or content – e.g. advertising – that may link to or be accessible from or on the Websites. Please read this privacy notice carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using our Websites, or by clicking to accept the terms of our Website Privacy Notice and Notice of Privacy Practices when this option is made available to you, you accept and agree to their terms. This Website Privacy Notice and/or the Company’s Notice of Privacy Practices may change from time to time (see Amendments and Updates). Your continued use of Triple-S’s Websites or renewed acceptance of the Website Privacy Notice and Notice of Privacy Practices following the posting of the revised terms is deemed to be acceptance of those changes, so please check the Website Privacy Notice and/or Notice of Privacy Practices periodically for updates. Children Under the Age of 13 Our Websites are not intended for children under thirteen (13) years of age. No one under age thirteen (13) may provide any personal information to or on Triple-S’s Websites. We do not knowingly collect personal information from children under thirteen (13) years of age. If you are under thirteen (13), do not use or provide any personal information on our Websites or through any of its features, register, use any of the interactive or public comment features of our Websites, or provide any information about yourself to us, including your name, address, telephone number, email address or request applications for coverage. If we learn we have collected or received personal information from a child under thirteen (13) without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under thirteen (13), please contact Triple-S’s Corporate Compliance & Ethics Director at moc.r1732180477psss@1732180477racyn1732180477nej1732180477 or 787-749-4949. Information We Collect About You and How We Collect It We collect several types of information from and about users of our Websites, including information: By which you may be personally identified, such as name, last name, e-mail address, telephone number, date of birth [or any other identifier by which you may be contacted online or offline] (“personal information”); and/or About your internet connection, the equipment you use to access our Websites, and usage details. We collect this information: Directly from you when you provide it to us. Automatically as you navigate through the sites. Information collected automatically may include usage details, IP addresses, home server, session identification, browser, operating systems and information collected through cookies, web beacons, and other tracking technologies. Information You Provide to Us The information we collect on or through our Websites may include: Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our services, posting material, or requesting further services. Records and copies of your email address(es) if you contact us. Your responses to surveys or request for feedback that we might ask you to complete for research purposes. Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order or making a payment on any of your Triple-S insurance policies through our Website. Your search queries on the Website. The only personal information Company obtains about individual visitors to its Websites is that which is supplied voluntarily by visitors. In cases when Company may need additional personal information to provide visitors with customized content or to inform them about new features or services, visitors are explicitly asked for that information. Social Media Disclaimer You also may provide information to be published or displayed (hereinafter, “posted”) on Triple-S’s social media pages by means of the links to the Company’s social media accounts published on each of its Websites (“user contributions”). Your user contributions are posted on and transmitted to others at your own risk. Although we may limit public access to said pages, you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. Lastly, all users of social media applications must comply with their terms of service. As such, Triple-S makes no representation as to the accuracy, truthfulness or completeness of information contained in such user contributions and disclaims any liability in relation to any user contributions posted to the Company’s social media accounts. Information We Collect Through Automatic Data Collection Technologies As you navigate through and interact with our Websites, we may use proprietary or third-party automatic data collection technologies, such as Google Analytics, to collect certain information about your equipment, browsing actions, and patterns, including: Details of your visits to our Websites, including traffic data and other communication data and the resources that you access and use on the Website. Information about your computer and internet connection, including your IP address, operating system, and browser type. Triple-S does not use these technologies to collect information about your online activities over time and across third-party websites or other online services (i.e. behavioral tracking). The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to: Estimate our audience size and usage patterns. Store information about your preferences, allowing us to customize our Website according to your individual interests. Speed up your searches. Recognize you when you return to our Website. The technologies we use for this automatic data collection may include: Cookies (or browser cookies). “Cookies” are small text files that a website transfers to a website visitor’s hard disk or browser for added functionality, or for tracking website usage. Our Websites use cookies during your on-line session to deliver content specific to your interests. Our cookies enable Triple-S to relate your use of the Websites to information that you have specifically and knowingly provided through our Websites. You may refuse to accept browser cookies by activating the appropriate setting(s) on your browser. However, if you select this setting you may be unable to access certain parts of our Websites. Unless you have adjusted your browser setting(s) so that it will refuse cookies, our system will issue cookies when you direct your browser to our Websites. Flash Cookies. Certain features of our Websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information. Web Beacons. Pages of our Websites and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). How We Use Your Information We use information that we collect about you or that you provide to us, including any personal information: To present our Websites and their contents to you. To provide you with information, products, or services that you request from us or have authorized. To fulfill any other purpose for which you provide it. User IDs and Passwords to provide you with access to your account(s) with the Company. To provide you with notices about your account/subscription, including expiration and renewal notices. To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. To notify you about changes to our Websites or any products or services we offer or provide though it. To allow you to participate in interactive features on our Websites. For internal research purposes about our users’ preferences and/or to improve our products, services, and site designs. To raise and respond to issues and inquiries of all types. In any other way we may describe when you provide the information. For any other purpose with your consent. Users may also request to unsubscribe or opt-out of Triple-S marketing or advertising emails by utilizing the “unsubscribe” option. For more information, see Choices About How We Use and Disclose Your Information. Any protected health information or non-public financial information submitted by members through the Company’s online portal member services will be handled in accordance to its HIPAA Notice of Privacy Practices and GLBA Notice of Privacy Practices, as applicable. As a result, users’ opt-out and/or access rights may limited. External Links At times, our Websites may contain links to other Internet websites. We encourage all of our partners, contributors and third parties to implement policies and practices that respect the privacy of our users. However, Triple-S is not responsible for the privacy practices or the content of such websites. This Website Privacy Notice only addresses the use and disclosure of information we collect from you. To the extent that you disclose your personal information to other parties, whether they are linked from the Company Websites, different rules may apply to their use or disclosure of the personal information you disclose to them. Because Company does not control the privacy notices of third parties, you are subject to the privacy customs and practices of that third party. We encourage you to ask questions before you disclose your personal information to others. Disclosure of Your Information We may disclose aggregated information about our users and information that does not identify any individual, without restriction. We may disclose personal information that we collect or you provide as described in this privacy policy: To our subsidiaries and affiliates. To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Triple-S’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Triple-S about our Website users is among the assets transferred. To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information. To fulfill the purpose for which you provide it. For any other purpose disclosed by us when you provide the information. With your consent. EXCEPT AS DISCLOSED IN THIS WEBSITE PRIVACY NOTICE, TRIPLE-S DOES NOT SELL, LEND, RENT OR OTHERWISE DISCLOSE ANY PERSONAL INFORMATION TO ANY THIRD PARTIES. Disclosures Required by Law We may also disclose your personal information: To comply with any court order, law, or legal process, including to respond to any government or regulatory request. To enforce or apply our terms of use and other agreements, including for billing and collection purposes. If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Triple-S, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection. Choices About How We Use and Disclose Your Information We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly. Accessing and Correcting Your Information You can review and change your personal information by logging into the corresponding Website and visiting your account profile page. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your User Contributions from the Company’s social media pages, copies of your User Contributions may remain viewable in cached and archived pages or may have been copied or stored by other Website users. Proper access and use of information provided through the Websites is governed by our terms of use. Job Applicants As part of any recruitment process, Triple-S collects and processes personal data relating to job applicants. Triple-S is committed to being transparent about how the Company collects and uses that data and its commitment to safeguard that information as described in its Job Applicant Privacy Notice. Data Security We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions will be encrypted using SSL technology or pursuant to industry standards to prevent the unauthorized disclosure or exposure of personally identifiable information. The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Triple-S does not make calls or sends email requests asking for personal account or credit card information. If you receive a call or an email message that appears to come from Triple-S and asks you to provide your email ID, password, Social Security number or other personal information, do not respond or reply to it. Amendments and Updates It is our practice to post any changes we make to our Website Privacy Notice on this page with a notice that it has been updated on each of the Websites’ home pages. If we make material changes to how we treat our users’ personal information, we will notify you by email to the primary email address specified in your account, through a notice on the Websites’ home pages and/or require your renewed acceptance by clicking to accept the terms of our Website Privacy Notice and Notice of Privacy Practices. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Websites and this privacy notice to check for any changes. Nothing in this Website Privacy Notice is intended to, and does not, create any contractual or other legal rights in or on behalf of any party. Contact Information To ask questions or comment about this privacy notice and our privacy practices, please contact Triple-S’s Corporate Compliance & Ethics Director at moc.r1732180477psss@1732180477racyn1732180477nej1732180477 or 787-749-4949.
