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. Please read our privacy policy carefully to get a clear understanding of how we 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 our services.


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.

Data Ownership

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 clarifications.

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 your plan.

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 investment allocations).

Information Protection

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 and capture and remember certain information. For instance, we use cookies to 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 enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. We use cookies to understand 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.

Information Disclosure

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 Identifiable Information'.

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 sponsor.


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 commercial websites and online services to post a privacy policy. The law's 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 conspicuous privacy policy on its website stating exactly the information being 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.

·         Once this privacy policy is created, we will add a link to it on our home page or as a minimum, on the first significant page after entering our website.

·         Our Privacy Policy link includes the word 'Privacy' and can easily be found on the page specified above.

·         You will be notified of any Privacy Policy changes on our Privacy Policy Page.

·         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 personal information.

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.


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 addresses.

If at any time you would like to unsubscribe from receiving future emails, you can email us at

info@deferral.com and we will promptly remove you from ALL correspondence.

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below:

404 Wyman St. Suite 100
Waltham, MA 02451

This policy was most recently updated on May 25, 2018.


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