This Privacy Statement describes American Financial Systems,
Inc. (d.b.a. Deferral.com) and its affiliates (collectively,
“Deferral.com”) agreement with each user of the Deferral.com Online Platform
(the "Website") to treat certain information on a private basis.
Deferral.com reserves the right to revise its privacy statement from time to
time, but will publish such changes on the Website before doing so. You should
check the Website on a regular basis for updates and changes.
This Statement has been compiled to better serve those
concerned with how their 'Personally Identifiable Information' (PII) is being
used online. PII, as described in US privacy law and information security, is
information that can be used on its own or with other information to identify,
contact, or locate a single person, or to identify an individual in context.
collect, use, protect or otherwise handle your Personally Identifiable
Information in accordance with our Website.
By using the Website, you agree to this Privacy Statement.
If you do not agree with any term in this Privacy Statement, please do not use
The Website is used to host and operate an online record
keeping system (the "System") for certain types of supplemental
benefits, most of which are not qualified plans under ERISA (often called
"nonqualified plans"). While many nonqualified plans do not hold
assets for their participants, some plan sponsors elect to use life insurance,
mutual funds, securities and other assets to pay or deliver plan benefits.
Our System stores data for plans and for assets that
employers may elect to hold or provide in connection with their plans, including
information about the plan sponsor and personal information about the plan's
participants. For plans that allow online enrollment or that allow for
participants to make investment allocations or other elections, our System will
track this information, as well.
Plan sponsors own the records (including participant data of
their employees) maintained in the database in our System for their plans.
Deferral.com owns the database architecture, structure, design and technology,
along with other technology used for the Website. We do not sell individual
nonpublic personal information for targeted advertising or other similar uses,
and we use password access restrictions for nonpublic information in our
databases. If you believe any of your nonpublic information is in error, please
contact your plan administrator to arrange for any necessary corrections or
Information Collection and Usage
If you are a participant in a Plan for which data is stored
on our Website, we collect nonpublic information from you, your employer, your
plan sponsor (along with its brokers, advisers and, if applicable, insurers)
and plan administrator to enable such parties to manage your benefit plan, to
collect and provide information pertaining to your participation, transactions
and/or choices relating to your plan account, and to manage assets (if any)
your plan sponsor chooses to hold or provide to pay or deliver benefits under
Information collected from you (or others on your behalf,
such as your plan administrator) will include your name, address, date of
birth, social security number, benefit plan account information and, depending
on the type of benefit plan, information pertaining to your compensation,
retirement benefits, assets that may be used to fund, deliver or measure
benefit payments, and your transactions pertaining to the plan (such as
Your personal information is contained behind secured
networks and is only accessible by a limited number of persons who have special
access rights to such systems, and are required to keep the information
confidential. In addition, all sensitive information you supply is encrypted
via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user
places an order, enters, submits, or accesses their information to maintain the
safety of their personal information.
We use vulnerability scanning. We never ask for credit card
numbers. We use regular Malware Scanning.
Use of 'cookies'
Cookies are small files that a site or its service provider
transfers to your computer's hard drive through your Web browser (if you allow)
that enables the site's or service provider's systems to recognize your browser
help us remember and process your activity. They are also used to help us
understand your preferences based on previous or current site activity, which
us compile aggregate data about site traffic and site interaction so that we
and save user's preferences for future visits.
You can choose to have your computer warn you each time a
cookie is being sent, or you can choose to turn off all cookies. You do this
through your browser settings. Since each browser is a little different, look
at your browser's Help Menu to learn the correct way to modify your cookies. If
you turn cookies off it will turn off some of the features of the site.
We do not sell, trade or disclose nonpublic personal
information to nonaffiliated third parties, except to the extent reasonably
required to perform services on the Website, to allow any successor to our
business to continue performance of services on the Website (for example, if
Deferral.com's business were to be sold), as required by law or to the extent
that such information already is publicly available from sources other than
Deferral.com. For example, we disclose personal information for purposes of
managing (or permitting your plan administrator, sponsor and other appropriate
parties to manage) your benefit plan and related transactions, assets and
services in accordance with applicable law. Also, nonpublic information with
regard to your plan is reported to your plan sponsor, employer and
administrator, and some of this information may be used for federal, state or
local income tax reporting purposes. We do not include or offer third-party
products or services on our website.
Many benefit plans require the support and services of
financial intermediaries (such as security and insurance brokers), insurance
companies, consultants and other service providers in the ordinary course of
plan management and plan transaction activity. These unaffiliated third parties
may need access to your nonpublic information to enable them to perform
services or provide or manage assets that relate to your plan. The privacy
policies of your employer, plan sponsor, plan administrator and any financial
intermediary, insurer or other service provider used in connection with your
plan (for example, a securities broker and/or insurer) also will govern how
your personal information may be used and disclosed. Further information
regarding these policies may be obtained from your plan administrator.
Applicability and Geographic Restrictions
Deferral.com’s services are applicable only to United States
companies and participants, as it follows the rules enacted by the entities
regulating our business, including but not limited to the United States
Department of Labor (DOL), Internal Revenue Service (IRS), Financial Industry
Regulatory Authority (FINRA) and others. Deferral.com also follows the
regulatory requirements established by US Privacy laws with respect to 'Personally
As a result, and given the scope and nature of our business,
this Website is intended to be used only by participants, administrators and
plan sponsors located within the United States. Therefore, use of the Website
from locations outside of the United States is not expected, with specific restrictions
established for EU citizens residing or operating abroad. In order to ensure
compliance with such restrictions, the Website utilizes filtering mechanisms
intended to disallow access to the platform from locations that implement
regulations beyond the scope of those provided by Deferral.com. If you are part
of one of the aforementioned parties intending to use our site from outside the
United States, please refrain from using the Website and contact your plan
Google's advertising requirements can be summed up by
Google's Advertising Principles. They are put in place to provide a positive
experience for users.
We have not enabled Google AdSense on our site but we may do
so in the future.
California Online Privacy Protection Act
CalOPPA is the first state law in the nation to require
reach stretches well beyond California to require any person or company in the
United States (and conceivably the world) that operates websites collecting
Personally Identifiable Information from California consumers to post a
collected and those individuals or companies with whom it is being shared. -
See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf
According to CalOPPA, we agree to the following:
Users can visit our site anonymously. Anonymous
users cannot perform transactions, only view public contents.
a link to it on our home page or as a minimum, on the first significant page
after entering our website.
'Privacy' and can easily be found on the page specified above.
You can change your personal information by
logging in to your account.
It's also important to note that we do
not allow third-party behavioral tracking
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from
children under the age of 13 years old, the Children's Online Privacy
Protection Act (COPPA) puts parents in control. The Federal Trade Commission,
United States' consumer protection agency, enforces the COPPA Rule, which
spells out what operators of websites and online services must do to protect
children's privacy and safety online.
We do not specifically market to children under the age of
13 years old.
Fair Information Practices
The Fair Information Practices Principles form the backbone
of privacy law in the United States and the concepts they include have played a
significant role in the development of data protection laws around the globe.
Understanding the Fair Information Practice Principles and how they should be
implemented is critical to comply with the various privacy laws that protect
Should a data breach
occur, we will notify your plan sponsor/administrator via email upon discovery
and following a reasonable forensic processing time.
We also agree to the Individual Redress Principle which
requires that individuals have the right to legally pursue enforceable rights
against data collectors and processors who fail to adhere to the law. This
principle requires not only that individuals have enforceable rights against
data users, but also that individuals have recourse to courts or government
agencies to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial
email, establishes requirements for commercial messages, gives recipients the
right to have emails stopped from being sent to them, and spells out tough
penalties for violations.
We collect your
email address in order to Process orders and to send information and
updates pertaining to orders and transactions. Deferral.com does not send
marketing materials and/or allow third parties to email participants.
To be in accordance
with CANSPAM, we agree to Not use false or misleading subjects or email
If at any time you would like to unsubscribe from
receiving future emails, you can email us at
email@example.com and we will
promptly remove you from ALL
If there are any
404 Wyman St. Suite 100
Waltham, MA 02451
This policy was most recently updated on May 25, 2018.