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Privacy Policy

Overview

This Privacy Policy (the “Privacy Policy”) explains the Producer-Writers Guild of America Pension Plan’s and Writers’ Guild-Industry Health Fund’s (the “Pension Plan and Health Fund”, “we,” “us,” “our,” or other similar pronouns) information-gathering and dissemination practices for our website: www.wgaplans.org (the “Site”), our mobile application (the “App” and collectively with the Site, the “Services”). The Services allow you to review and upload contribution information, make payments, process applications, download your statements, store your medical ID card, access the summary plan descriptions of each of the Pension Plan and Health Fund’s respective Pension, Individual Account, and Health Plans (the “Summary Plan Descriptions”) and certain related personal information of yours to the extent and in the manner then currently offered by and through the Services.

The Pension Plan and Health Fund takes your privacy rights seriously and we have posted this Privacy Policy to let our users know what information we collect from you, why we collect it and what we do with it. The Pension Plan and Health Fund’s goal is to collect and use only that information that we think is necessary for our legitimate business interests, such as to better understand and serve you, to give you a better experience with the Services, and to allow you to access your personal information related to your benefits.

Here are a few general principles to keep in mind as you read through the Privacy Policy:

  • The Services are not intended for children under 13. 
  • This Policy does not apply to information that you may provide to us, or that we may obtain, other than through our Services, such as over the phone, by mail, or in person.
  • The terms of this Policy apply only to residents of the United States.  You may be accessing our Services from a computer or mobile phone device (through an iPhone or iPad application, for example) and this Privacy Policy governs your use of our Services regardless of the means of access. This Privacy Policy covers all collection, use and disclosure of personal information, whether through the Services or otherwise. If you are located outside of the United States, you should know that the information you provide to us is being transmitted to us and processed in the United States and will be protected subject to this Privacy Policy and United States laws, which may not be as protective as the laws in your country. Also, this Site places cookies and local shared objects on your computer or device which are further described below.  By using the Site, you agree to this.  

Acceptance of These Terms

By visiting the Services, you consent to the terms of this Privacy Policy as they may be amended from time to time. If you do not agree to the terms of this Privacy Policy or the Terms and Conditions for use of the Services, please do not provide us with any information and do not use the Pension Plan and Health Fund Services. All changes will go into effect on the date that they are posted in our Privacy Policy. Use of the Services following such changes constitutes your acceptance of the revised Policy then in effect. To the fullest extent permitted by applicable law, the new Privacy Policy will apply to all past and current users of the Services and will replace any prior Policies.

Does This Privacy Policy Apply To You?

This Policy covers the Pension Plan and Health Fund’s information collection and use practices for anyone who uses the Services. The Site, however, contains links to other websites, advertisers and other third parties. By clicking on any of these links, you are leaving the Site. The Pension Plan and Health Fund has no control over the information collected from or about you by any third party after you have left the Site. This Privacy Policy does not cover the data collection and use practices of any third party linked to the Pension Plan and Health Fund. The Pension Plan and Health Fund assumes no liability and is not responsible for any practices of such third party web sites, including their privacy practices or content. Additionally, a link provided on the Site does not constitute an endorsement of the content, viewpoint, accuracy, opinions, policies, products, services, or accessibility of that linked web site. Once you link to another website from the Site, you are subject to the terms and condition of that website, including, but not limited to, its Internet privacy policy.

What Information, Including Personally Identifiable Information, Does the Pension Plan and Health Fund Collect From And About You?

Our goal in collecting information from and about you is to provide you with the best experience possible while using the Services, including providing adequate security for your information and to allow you to get the most out of your experience with the Services.

In order to provide you with our services, the Pension Plan and Health Fund collects information from its community through two methods: passive collection of technical information and information you voluntarily provide to the Pension Plan and Health Fund, including personally identifiable information.

Passive Collection of Technical Information: As is the case with many online properties, our servers, and third parties which have contracted to provide services to us may collect “Non-Personally Identifiable Information” (“Non-PII”), automatically collect your IP address when you visit the Services, and we may associate that with your domain name or that of your internet access provider and the general geographic location from which you are connecting. Your IP address is used internally by the Pension Plan and Health Fund for security reasons, such as to prevent hacking attacks. We may also capture certain “clickstream data” pertaining to your usage of the Services.  Clickstream data includes, for example, device ID and other information about your computer or device, web browser and operating system and their settings, the pages and content you see or click on during your visit and when and for how long you do so, items you download, the next website or other online property you visit when you leave the Services, and any search terms you have entered on the Services or a referral service or website or other online property.

To better serve you we may deploy various tracking technologies on the Services to collect additional information about your visits to the Services. We use cookies. Cookies are simple text files stored on your web browser to provide a means of distinguishing among users of the Site. The use of cookies is a standard practice among Internet websites. To better serve you, we use “session cookies” for security purposes to identify you. Session cookies can be created automatically on the device you use to access the Site. These session cookies do not contain personal information and do not compromise your privacy or security. We may use the cookie feature to store a randomly generated identifying tag on the device you use to access the Site. A session cookie is erased during operation of your browser or when your browser is closed.

By using our Services, you consent to our use of these tracking technologies as described above.

Information You Provide

The Pension Plan and Health Fund does not require anyone to submit any personal information in order to utilize the general portions of the Services. However, if you wish to access your personal information associated with your benefits, you will be required to submit “Personally Identifiable Information” including certain personal data about you (“PII”) that will assist us in complying with verification requirements, including account information and other PII. This information is required for authentication purposes and to protect the security of your information.

If during your visit to the Services you send an electronic mail message to the Pension Plan and Health Fund, your electronic mail address and the contents of your message will be collected. The information collected is not limited to text characters and may include audio, video, and graphic information formats included in the message. Your electronic mail address and the information included in your message will be used to respond to you, to address issues you identify, or to forward your message to the appropriate department within the Pension Plan and Health Fund for appropriate action.

Please note that electronic mail does not provide a completely secure and confidential means of communication and may not be encrypted. It is possible that your electronic mail communication may be intercepted or viewed by another Internet user while in transit to the Pension Plan and Health Fund. Your electronic mail address is not collected for commercial purposes and the Pension Plan and Health Fund does not sell or otherwise distribute your electronic mail address for commercial purposes.

What Happens To My Information After the Pension Plan and Health Fund Collects It?

In general, in addition to the purposes listed above, the Pension Plan and Health Fund uses information collected from you passively or submitted by you to:

  • improve the performance of the Services, such as to determine the number of users logged in simultaneously;
  • for problem solving purposes, either to solve issues connected with the Services or that individual users may be having with the Services;
  • to administer the Services and your account with us;
  • to respond to your request, questions and concerns;
  • to verify customer information;
  • for internal research for technology development and demonstrations, and to develop, improve, upgrade and enhance new features and offerings for our customers;
  • for developing new features and offerings on the Services;
  • for analytical purposes;
  • to audit compliance and other practices;
  • to detect security incidents;
  • to protect against bad activity;
  • to bring claims against wrongdoers;
  • for quality and safety assurance measures;
  • for debugging software, systems and practices; and  
  • to protect your rights and property .

In addition, the Pension Plan and Health Fund will not sell, dispose, or otherwise transfer your personally identifiable information to third parties without your consent except as specifically set forth in this paragraph. When you choose to supply the Pension Plan and Health Fund with your electronic mail address, the Pension Plan and Health Fund compiles this information in a database with other Pension Plan and Health Fund community members’ information. Further, the Pension Plan and Health Fund retains your personal information associated with your benefits. The Pension Plan and Health Fund reserves the right to transfer this information to a successor, related entity or to a third party purchasing or succeeding to the Pension Plan and Health Fund’s assets.

Notwithstanding any other provision of this Policy to the contrary, we reserve the right to disclose PII and/or Non-PII to others as we believe appropriate (a) to comply with legal process; (b) to respond to governmental requests; (c) to enforce our Terms of Use; (d) to protect the rights, privacy, safety or property of the Pension Plan and Health Fund, you or others; and (e) to permit us to pursue available remedies or limit the damages that we may sustain.  We may disclose any information, including PII, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request. We may also exchange information, including PII, with other companies to address cyber security risks and/or data breaches.

Because Non-PII does not personally identify you, we may use such information for any purpose. In addition, we reserve the right to share such Non-PII with other third parties, for any purpose.

We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy unless a longer retention period is required or allowed by law.

Notification of Information Sharing

We work with third parties who provide services including but not limited to Services operation, payment processing and authorization, and other administrative services. We may share personal information with such third parties for the purpose of enabling these third parties to provide services to us. Such service providers may include client support specialists, webhosting companies, client data management and enhancement companies, payment processors, data analysis firms and email service providers. Such third parties may be provided with access to personal information needed to perform their functions, but may not use such information for any other purpose. Our employees and service providers may be located in foreign jurisdictions, and your personal information may be subject to the laws of those foreign jurisdictions and/or accessible to law enforcement and other authorities.

How Can You Review And Correct Information You Submitted To The Services Or Opt Out?

It is not optional to supply the Pension Plan and Health Fund with your email address. We use your email address to communicate to you of changes to your information and payments made for Dependent Premiums, Cobra payments and Same Sex Domestic Partner Tax payments.

Once you have chosen to access your personal information via the Services, you are able to opt out of this ability by calling the Website Support number at (818) 526-6500 or Toll free (855) 794-2932.

We will endeavor to comply with your request as soon as reasonably practicable and in accordance with applicable law. Please note that if you opt-out as described above, we will not be able to remove personal information about you from the databases of third parties with which we have already shared personal information as of the date that we implement your opt-out request. 

What Kinds of Security Procedures Are in Place to Protect the Loss, Misuse or Alteration of Information under the Pension Plan and Health Fund’s Control?

The Pension Plan and Health Fund protects your personal information associated with your benefits from access by a third party through the Services by maintaining multiple authentication fields. When registering an account on the Services, please be sure to choose an account password that is difficult for others to guess, preferably a password you do not use on any other website or account, and never reveal it to anyone else.  If you use a shared or public computer, DO NOT choose to have your login ID or password remembered and be sure to log out of your account completely every time you leave the computer.  Also, please verify that your web browser has a secure connection to the Services before entering any personal information and avoid including PII in e-mails to us. If you are locked out through this security mechanism, you can contact the Pension Plan and Health Fund via telephone at (818) 526-6500 or Toll free (855) 794-2932 to reset your log-in ID.

To further protect your information, the Pension Plan and Health Fund limits access to any personal information submitted by or associated with a user of the Services to only certain of its employees. When you opt-in to receive electronic mail messages from the Pension Plan and Health Fund, the Pension Plan and Health Fund retains your electronic mail address in an encrypted database that is also protected by Firewalls, Denial of Service and Intrusion Protection appliances. Additionally, the Pension Plan and Health Fund protects information associated with your benefits by keeping it in an encrypted database that is also protected by a Firewalls, Denial of Service and Intrusion Protection appliances. The Pension Plan and Health Fund daily monitors the intrusion detection systems.

Jurisdiction

The Services are controlled and operated by the Pension Plan and Health Fund from the United States. We do not intend to collect personal information from residents of any country other than the United States. The Pension Plan and Health Fund does not represent or warrant that the Services, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access the Services, do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. We may limit Service availability, in whole or in part, to any person, geographic area or jurisdiction we choose, at any time and in our sole discretion.

Use of the Services by Children Under the Age of 13.

The Services are a general audience website and mobile application and are intended to be used by adult and teenage participants interested in their pension and health plan benefits. It is not intended for children and the Pension Plan and Health Fund does not want to collect any personally identifiable information from users who are under the age of 13. The safety of children is very important to the Pension Plan and Health Fund, and the Pension Plan and Health Fund recommends that parents review this Privacy Policy and understand its terms, so that this Services is used only by persons age 13 and over.

California Consumer Privacy Act Notice.

The below summarizes our policies with respect to personal information that we process of the following users of the Site and any Services that we provide who are California residents (collectively, the “customers” or “you”). We adopt the policies set forth below to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and the CCPA’s implementing regulations and any terms defined in the CCPA (such as “personal information”) have the same meaning when used in this policy.

Categories of Personal Information: We have collected the following categories of personal information in the preceding 12 months:

  • Identifiers, such as name, address, telephone number, email address, and other contact information.
  • Protected classification characteristics under California or federal law, such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
  • Commercial information such as records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
  • Biometric information such as genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
  • Internet activity such as browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
  • Geolocation data.
  • Sensory data such as audio, electronic, visual, thermal, olfactory, or similar information.
  • Professional or employment-related information.
  • Non-public education information such as education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
  • Inferences drawn from other personal information such as synthetic profiles reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
  • Data submitted and collected through our website(s) visited by participants including data submitted by email.

Categories of Sources: We collect personal information directly from you, indirectly from you and from other sources, including from the Services, applications, forms, correspondence and other communications, as well as participants’ transactions with us and others.

Business and Commercial Purposes: We use and disclose the categories of personal information listed above for business purposes.  Such purposes include to operate, manage and maintain our business and to accomplish our business purposes and objectives.  For example, we use personal information to provide Services; fulfill your transactions; respond to your communications; conduct risk and security control and monitoring; detect and prevent fraud; perform accounting, audit and other internal functions; comply with law, legal process and internal policies; maintain records; and exercise rights and defend legal claims.

Categories of Third Parties: In the preceding 12 months, we have shared the categories of personal information listed above for business purposes with our service providers who assist in providing our services or operating our business. We do not sell personal information to third parties. 

Access and Data Portability Rights: You have the right to request that we disclose the following information to you with respect to the preceding 12 months:

  • the categories of personal information collected about you;
  • the categories of sources from which the personal information is collected;
  • the purposes for collecting or sharing personal information; and
  • the categories of third parties with which we share personal information for a business purpose;
  • the specific pieces of personal information we collected about you.

These access and data portability rights do not apply to (i) personal information collected about employees, job applicants, independent contractors or similar individuals and used only within the context of such a relationship (“employment-related personal information”) or (ii) personal information reflecting a written or verbal business-to-business communication (“B2B personal information”).

Deletion Request Rights:  You have the right to request that we delete the personal information (other than employment-related personal information or B2B personal information) we collected about you, subject to certain exceptions provided by the CCPA.  Once we receive and confirm your verifiable request, we will delete the requested personal information from our records, unless an exception provided by the CCPA applies.  For example, we may retain personal information as required or permitted by law, and may maintain a copy of your deletion request.

Exercising Your Access and Data Portability Rights:  To exercise the access and data portability rights described above, please submit a verifiable consumer request to us:

Compliance Manager
PWGA
2900 W. Alameda, Suite 1100
Burbank CA, 91505
Email: [email protected]
Phone:  818-846-1015 X.199

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. You may only make a verifiable participant request for access or data portability twice within a 12-month period. The verifiable participant request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. Please describe your request with sufficient detail for us to properly understand, evaluate and respond to it.

Requests from Authorized Agents:  If you would like an authorized agent to submit a CCPA request on your behalf or if you are an authorized agent of a participant and registered with the Secretary of State to conduct business in California, please send us an email at [email protected] for instructions and details on proof required for use of an authorized agent, including a copy of the written permission signed by the participant for the agent to act on the participant’s behalf in this manner.

Right of Non-Discrimination:  You have the right not to receive discriminatory treatment by us for exercising any of your CCPA rights.

Reasonable Access for Participants with Disabilities:  Persons with disabilities may contact us about obtaining this Privacy Policy in alternative format.

Contact Information: If you have any questions or comments about your rights in California, the ways in which we collect, use and disclose your personal information described here or your choices and rights regarding such practices, please do not hesitate to contact us at:

Compliance Manager
PWGA
2900 W. Alameda, Suite 1100
Burbank CA, 91505
Email: [email protected]
Phone:  818-846-1015 X.199

Use of the Services by European Data Subjects.

This Site is hosted in the United States and are governed by United States law. If you are located in the European Economic Area (EEA), United Kingdom (UK), or another country, the United States may not necessarily have data protection laws or other similar laws as comprehensive as those in your country.  For example, you may reside in a country that is subject to the General Data Protection Regulations (GDPR).  If you reside in a country subject to GDPR you may have the rights (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. While our Site is not necessarily subject to GDPR compliance, we are nonetheless issuing this Policy to explain the handling of the personal data of those who reside in one of the countries subject to the GDPR.  If you are using the Site or our services from outside the United States, please be aware that your Personal Information and/or Usage Information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. By using the Site or our services, you consent to your Personal Information and Usage Information being transferred to our servers.  If you have questions or comments about your privacy rights, you may reach out to us at the contact information below.

Modifications to This Privacy Policy.

The Pension Plan and Health Fund reserves the right, at our discretion, to change, modify, add or remove portions of this Privacy Policy at any time to comply with any applicable state or federal regulations, to utilize new technologies or to improve your experience with the Services, so please check back periodically to review our Privacy Policy. If the Pension Plan and Health Fund changes any portion of this Privacy Policy, the change will be posted in this document so that you will always know what information we gather, how we might use that information, and to whom we will disclose it. The Pension Plan and Health Fund will not change the use and dissemination practices related to information obtained under a prior version of this Privacy Policy without your prior consent. Please be sure to check this page periodically for changes.

Do Not Track Disclosure

Some web browsers may transmit “do-not-track” (DNT) signals to the websites with which the user communicates.  Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them.  We currently do not change our tracking practices (which are explained in more detail above) in response to DNT settings in your web browser.

Disclaimer

The information provided in this Privacy Policy should not be construed as giving business, legal, medical, or other advice, or warranting as fail proof, the security of information provided through the Services.

This Privacy Policy is effective as of February 23, 2022.