1. Introduction

Dinsmore Steele, LLC (“Dinsmore Steele,” “we,” “us,” or “our”) is committed to protecting the privacy and security of your information. This Privacy Policy describes how we collect, use, share, and protect information obtained through www.dinsmoresteele.com and our related services.

By using our site or services, you consent to the data practices described in this policy. If you do not agree, please discontinue use.

2. Information We Collect

2.1 Information You Provide

When you submit a Request for Proposal (RFP) or otherwise interact with our services, we may collect:

Business contact information (name, title, company, email, phone, address);
Company information (size, industry, number of employees);
Employee information necessary to obtain benefits or payroll proposals, which may include names, dates of birth, and compensation data;
Health-related information for benefits enrollment purposes, which may constitute Protected Health Information (PHI) under HIPAA;
Financial information such as payroll totals, banking information, or budget data (note: payment processing is performed by third-party processors and we do not store full payment account details).

2.2 Information Collected Automatically

When you visit our site, we may automatically collect:

IP address and approximate geographic location;
Browser type and version;
Pages visited, time spent, and referring URLs;
Device and operating system information;
Cookie and tracking data (see Section 5).

3. How We Use Your Information

We use the information we collect to:

Facilitate your Request for Proposal and connect you with appropriate Vendors;
Communicate with you about proposals, services, and updates;
Improve our website and service offerings;
Conduct research and analytics on service usage;
Comply with legal obligations, including data breach notification laws;
Protect the rights, safety, and property of Dinsmore Steele, our users, and the public.

We do not sell, rent, or lease your personal information to third parties.

4. How We Share Your Information

4.1 With Vendors

Your information is shared with Vendors solely for the purpose of obtaining proposals on your behalf. By submitting an RFP, you authorize Dinsmore Steele to share your information with Vendors who may be able to fulfill your requested services.

4.2 With Service Providers

We may share information with trusted service providers who assist us in operating our website, conducting analytics, or delivering services. These providers are contractually prohibited from using your information for any other purpose and are required to maintain its confidentiality.

4.3 As Required by Law

We may disclose your information without prior notice if required to do so by law, court order, or in good faith belief that such disclosure is necessary to comply with legal process, protect our rights or property, or address an emergency involving personal safety.

5. HIPAA and Sensitive Health Information

To the extent that Dinsmore Steele receives or transmits Protected Health Information (PHI) in connection with employee benefits services, we comply with applicable HIPAA requirements. Where required, we will execute a Business Associate Agreement (BAA) with Clients and ensure that Vendors we engage are also subject to appropriate HIPAA obligations.

PHI is handled with heightened care and is not used for marketing or any purpose beyond the benefits services you have requested.

6. Cookies and Tracking Technologies

Our site uses cookies and similar technologies to enhance your experience. Cookies are small text files stored on your device. We use:

Essential cookies: Required for the site to function properly;
Analytics cookies: Help us understand how visitors use our site (e.g., Google Analytics);
Preference cookies: Remember your settings and choices.

You may adjust your browser settings to refuse cookies. Note that doing so may limit your ability to use certain features of our site. We do not currently respond to “Do Not Track” signals, but we do not engage in cross-site behavioral advertising.

7. Data Retention

We retain your personal information for as long as necessary to fulfill the purposes for which it was collected, to comply with our legal obligations, resolve disputes, and enforce our agreements. Generally:

Business contact and proposal information is retained for up to 7 years;
Health and benefits-related information is retained in accordance with HIPAA requirements (minimum 6 years from creation or last effective date);
Website analytics data is retained for up to 26 months.

Upon expiration of the applicable retention period, we securely delete or anonymize your information.

8. Data Security

We implement reasonable administrative, technical, and physical safeguards designed to protect your information from unauthorized access, use, disclosure, alteration, or destruction. However, no method of data transmission or storage is 100% secure, and we cannot guarantee absolute security.

In the event of a data breach affecting your personal information, we will notify you as required by applicable law, including the laws of New York, California, and other applicable states.

9. California Residents — Your CCPA Rights

If you are a California resident, the California Consumer Privacy Act (CCPA) grants you the following rights:

Right to Know: You may request disclosure of the categories and specific pieces of personal information we have collected about you, the purposes for collection, and the categories of third parties with whom we share it;
Right to Delete: You may request deletion of personal information we have collected, subject to certain exceptions;
Right to Opt-Out of Sale: We do not sell personal information. You do not need to opt out;
Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights.

To exercise your rights, contact us at info@dinsmoresteele.com. We will respond within 45 days as required by law. You may also designate an authorized agent to make requests on your behalf.

10. Children’s Privacy

Our site and services are not directed to individuals under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have inadvertently collected such information, we will delete it promptly. Individuals under 18 may only use our site with the permission of a parent or legal guardian.

11. Opt-Out and Unsubscribe

You may opt out of receiving marketing communications from Dinsmore Steele at any time by:

Clicking the “Unsubscribe” link in any email we send;
Emailing us at info@dinsmoresteele.com with your request.

Please note that opting out of marketing communications does not affect our ability to send you transactional or service-related communications necessary to fulfill your requests.

12. Third-Party Websites

Our site may contain links to third-party websites. This Privacy Policy does not apply to those sites. We encourage you to review the privacy policies of any third-party sites you visit, as we have no control over their data practices.

13. International Users

Our services are operated from the United States. If you access our site from outside the U.S., your information will be transferred to and processed in the U.S. By using our services, you consent to this transfer.

14. Changes to This Policy

We may update this Privacy Policy periodically to reflect changes in our practices or applicable law. We will post the revised policy on this page with an updated effective date. We encourage you to review this page regularly.

15. Contact Us

If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at:

Dinsmore Steele, LLC

Email: info@dinsmoresteele.com