This is the privacy notice of the Affiliated Insurance Companies of The Cigna Group, which the notice calls “Cigna, we, our and us”. It says it applies to the company’s United States operations and to all personal information Cigna collects about the reader. The notice describes “we” as including, but not limited to, named insurers: Cigna Health and Life Insurance Company and listed state Cigna HealthCare entities for individual and family medical and dental plans, CHLIC, Connecticut General Life Insurance Company or their affiliates for group plans, and CHLIC, Life Insurance Company of North America or New York Life Group Insurance Company of NY for accidental injury, critical illness and hospital care plans. It adds that the last two insurers are not affiliates of The Cigna Group.
Supporting quotations
Privacy Notice of The Affiliated Insurance Companies of The Cigna Group (referred to in this notice as “Cigna, we, our and us”). This privacy notice applies to our United States operations.
This notice applies to all personal information we collect about you.
For purposes of this Notice, “we” or “us” refers to The Affiliated Insurance Companies of “The Cigna Group” which includes but is not limited to the following:
LINA and NYLGICNY are not affiliates of The Cigna Group.
Qualifications & exceptions
The notice applies to United States operations only.
“we” is described as including but not limited to the listed insurers, so the list is not exhaustive.
Which insurer applies depends on the product, such as individual, group or accidental injury, critical illness and hospital care plans.
Not stated here
The notice does not say whether LINA and NYLGICNY, which it says are not affiliates of The Cigna Group, are bound by its statements as insurers of those plans.
The listing of legal entities by state that the notice refers to is not part of the supplied text.
contrast (model-proposed): Right to review your personal information by written request — contrast: The notice says it applies to all personal information Cigna collects about the reader, but the right to review is described only for information collected to provide insurance products and services, so the two scopes differ.
Legal Rights & Agreement Rules · Context
Why the notice exists and Cigna’s general commitment
Cigna says it values the reader’s trust and is committed to acting responsibly when it collects, uses and protects personal information. It explains that financial companies, including insurers, choose how they share personal information, and that federal and state laws require it to tell the reader how it collects, shares and protects that information. The commitment is general; the specific protection measures appear in the security section.
Supporting quotations
We value your trust. We are committed to acting responsibly when we collect, use and protect your personal information.
Federal and state laws say that we must tell you how we collect, share and protect your personal information.
Qualifications & exceptions
The responsible-handling commitment is stated in general terms; specific measures are in the security section.
The notice names “federal and state laws” without identifying them in this passage.
Not stated here
The specific federal and state laws behind the notice requirement are not identified in this passage.
Data Access & Collection · Company practice
Types of personal information Cigna may collect
Cigna says the types of information it collects, uses and shares depend on the product or service the reader has, and that it may include name, telephone number, occupation, Social Security number, address, date of birth, financial and health history, and insurance claims information.
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The types of information we collect, use and share depend on the product or service you have from us. It may include your:
Name
Telephone number
Occupation
Social Security number
Address
Date of birth
Financial and health history
Insurance claims information
Qualifications & exceptions
The types depend on the product or service the reader has from Cigna.
The list is introduced with “may include”, so it is not stated to be exhaustive or to apply to every reader.
Not stated here
This section does not describe where Cigna gets the information from.
Sharing & Disclosure · Permission or license
Sharing all personal information for everyday business purposes
Cigna says it may share all of the personal information about the reader that it collects with affiliates and with nonaffiliated companies for its everyday business purposes. It defines nonaffiliated companies as those not under common ownership with Cigna, such as its service providers.
Supporting quotations
We may share all of the personal information about you that we collect with affiliates and nonaffiliated companies (companies that are not under common ownership with us, such as our service providers) for our everyday business purposes. For example, we may use your personal information and share it with others to:
Federal laws don’t allow you to limit the sharing of personal information as described above.
Qualifications & exceptions
The wording is “may”, a permission rather than a statement that sharing always happens.
The scope is “all of the personal information about you that we collect”, with no category limits.
Recipients include affiliates and nonaffiliated companies such as service providers.
A later paragraph says federal laws do not allow the reader to limit sharing as described above.
Not stated here
The notice does not define “everyday business purposes” beyond the examples that follow.
The notice does not name the affiliates or nonaffiliated recipients.
Use & Processing · Permission or license
Examples of everyday purposes for using and sharing information
As examples of everyday business purposes, Cigna says it may use personal information and share it with others to help run its business, process transactions, maintain accounts, administer benefit plans, report to credit bureaus, support or improve its programs or services including care management and wellness programs, offer other products and services, respond to court orders and legal or regulatory investigations or exams, do research for it, help prevent fraud, money laundering, terrorism and other crimes by verifying what it knows about the reader, and audit its business.
Supporting quotations
For example, we may use your personal information and share it with others to:
Help us run our business
Process your transactions
Maintain your account(s)
Administer your benefit plan
Report to credit bureaus
Support or improve our programs or services, including our care management and wellness programs
Offer you our other products and services
Respond to court orders and legal or regulatory investigations or exams
Do research for us
Help us prevent fraud, money laundering, terrorism and other crimes by verifying what we know about you
Audit our business
Qualifications & exceptions
The purposes are introduced with “for example”, so the list is not stated to be exhaustive.
The wording is “may”.
Offering other products and services is listed as an everyday business purpose.
Not stated here
The notice does not say what information goes to credit bureaus or researchers, or who the recipients are.
Sharing & Disclosure · Permission or license
Information shared if Cigna sells or merges its business
Among its everyday business purposes, Cigna lists using and sharing personal information to sell all or any part of its business or merge with another company.
Supporting quotations
Sell all or any part of our business or merge with another company
Qualifications & exceptions
Listed as an example everyday business purpose with “may”, so it is a permission.
Not stated here
The notice does not say what protections or choices apply to information in such a transfer.
Sharing & Disclosure · Permission or license
Other recipients of personal information
Cigna says it may also share the reader’s personal information with medical health care professionals, insurers including reinsurers, successor insurers or claim administrators who administer the reader’s benefit plan, and companies that help it recover overpayments, pay claims or do coverage reviews.
Supporting quotations
We may also share your personal information with:
Medical health care professionals
Insurers, including reinsurers
Successor insurers or claim administrators who administer your benefit plan
Companies that help us recover overpayments, pay claims or do coverage reviews
Qualifications & exceptions
The wording is “may also share”, a permission.
The recipients are described by category, not by name.
Not stated here
The notice does not say what information goes to each recipient category.
Sharing & Disclosure · Permission or license
Sharing for marketing and joint marketing
Cigna says it may share information with its agents and service providers to offer its products and services to the reader. It may also share personal information with other financial companies for joint marketing, which it defines as a formal agreement between nonaffiliated financial companies that jointly endorse, sponsor or market financial products or services to the reader.
Supporting quotations
We may share information with our agents and service providers to offer our products and services to you.
We may share your personal information with other financial companies for the purpose of joint marketing.
Joint marketing is when there is a formal agreement between nonaffiliated financial companies that jointly endorse, sponsor or market financial products or services to you.
Qualifications & exceptions
The wording is “may”.
Joint marketing, as defined, requires a formal agreement between nonaffiliated financial companies.
Joint marketing sharing is with other financial companies.
Not stated here
The notice does not name the joint marketing partners or say which categories of information are shared for marketing.
Sharing & Disclosure · Restriction or exception
Former customers and the limit on stopping this sharing
Cigna says it may share personal information about former customers in the way described above, and states that federal laws do not allow the reader to limit the sharing described above. Separately, the notice says the reader may have additional rights under state or other applicable laws.
Supporting quotations
We may also share personal information about former customers in the way described above.
Federal laws don’t allow you to limit the sharing of personal information as described above.
You may have additional rights under state or other applicable laws.
Qualifications & exceptions
This paragraph sits under the marketing heading after both sharing subsections, so “above” can be read to reach everyday and marketing sharing.
The additional state or other law rights are stated as “may have”.
Not stated here
The notice does not identify which state or other laws could give additional rights.
The supplied text describes no way to opt out of the sharing described above.
Cross-references
contrast (model-proposed): Additional rights under other laws and protection from pretext interviews — contrast: One paragraph says federal laws do not allow the reader to limit the sharing described above; another says the reader may have additional rights under state or other applicable laws. The notice does not say which state or other rights, if any, would let a reader limit sharing, so the two statements pull in different directions without being resolved.
qualifies (model-proposed): Sharing all personal information for everyday business purposes — qualifies: The statement that federal laws do not allow the reader to limit the sharing described above qualifies the broad permission to share all personal information for everyday business purposes: the reader is told the notice offers no way to limit it.
Security & Safeguards · Company commitment
How Cigna says it protects personal information
To protect personal information from unauthorized access and use, Cigna says it uses reasonable security measures, including secured files, user authentication, encryption, firewall technology and detection software; reviews the data security practices of companies it shares personal information with; and grants access to personal information to people who must use it to do their jobs.
Supporting quotations
To protect personal information from unauthorized access and use, we:
Use reasonable security measures, including secured files, user authentication, encryption, firewall technology and detection software
Review the data security practices of companies we share your personal information with
Grant access to personal information to people who must use it to do their jobs
Qualifications & exceptions
The standard is “reasonable security measures”, which the notice does not define.
The measures are introduced with “including”, so they are not stated to be the only ones.
Reviewing the security practices of recipients is stated as a practice, not as a requirement that recipients meet a standard.
Not stated here
This section does not say what happens if personal information is compromised or what standard recipients must meet.
Account & Service Control · User right or choice
Right to review your personal information by written request
Generally, the reader has the right to review the personal information Cigna collects to provide insurance products and services, by asking in writing and sending the letter to the address given in the notice. The notice asks the reader to include their full name, address, telephone number and policy number in the letter. Two limits apply to what is provided: health information may be given through the reader’s health care provider, and Cigna says it will not send anything it collected in connection with a claim or legal proceeding.
Supporting quotations
Generally, you have the right to review the personal information we collect to provide you with insurance products and services if you:
Ask us in writing
Send the letter to the address below
When you write to us, please include your full name, address, telephone number and policy number in your letter.
If the information you ask for includes health information, we may provide the information to you through your health care provider.
we won’t send you anything that we’ve collected in connection with a claim or legal proceeding
This notice applies to all personal information we collect about you.
Qualifications & exceptions
The right is stated as “generally”.
It covers personal information collected to provide insurance products and services, while the notice elsewhere says it applies to all personal information Cigna collects.
The request must be in writing and sent to the address in the notice.
Health information may be provided through a health care provider, and information collected in connection with a claim or legal proceeding will not be sent.
Not stated here
The notice states no response deadline or fee for review requests.
The notice does not say whether information collected for other purposes can be reviewed.
Account & Service Control · Restriction or exception
Limits on what Cigna will send in response to a review request
If the information a reader asks for includes health information, Cigna says it may provide it through the reader’s health care provider. Citing its legal sensitivity, Cigna says it will not send anything it collected in connection with a claim or legal proceeding.
Supporting quotations
If the information you ask for includes health information, we may provide the information to you through your health care provider. Due to its legal sensitivity, we won’t send you anything that we’ve collected in connection with a claim or legal proceeding.
Qualifications & exceptions
Providing health information through a health care provider is stated as “may”, a choice for Cigna.
The refusal to send claim or legal proceeding material is stated as a flat “won’t”, with legal sensitivity given as the reason.
Not stated here
“In connection with a claim or legal proceeding” is not defined, so the notice does not show how much of a reader’s file this excludes.
Cross-references
narrows (model-proposed): Right to review your personal information by written request — exception_to: The review right is stated generally, and this paragraph carves out limits: health information may be provided through a health care provider, and information collected in connection with a claim or legal proceeding will not be sent.
Account & Service Control · User right or choice
Asking Cigna to correct personal information
If the reader believes information Cigna has is incorrect, they can write and explain why. If Cigna agrees, it corrects its records and notifies anyone the reader specifically designates who may have received the information in the past two years, any insurance support organization that may have received it from Cigna in the past seven years, and any insurance support organization that furnished it to Cigna. If Cigna disagrees, the reader may send a statement of what they think is correct and why they disagree. If information is amended, Cigna says it will include the amendments when it gives the reader’s personal information to anyone outside Cigna, including those organizations and designated persons.
Supporting quotations
If you believe the personal information we have is incorrect, please write to us and explain why you believe it is incorrect. If we agree with you, we will correct our records and notify (1) any person you specifically designate that may have received the personal information within the past two years, (2) any insurance support organization that may have received the personal information from us in the past seven years, and (3) any insurance support organization that furnished the personal information to us. If we disagree with you, you may send us a statement setting forth what you think is the correct information and why you disagree with us. If information is amended, we will include amendments when we give your personal information to anyone outside of Cigna, including insurance support organizations that may have received the personal information from us or furnished the personal information to us, and any person you specifically designated.
Qualifications & exceptions
Correction and the notifications happen only if Cigna agrees with the reader.
The notification windows are two years for designated persons and seven years for insurance support organizations that received the information from Cigna; organizations that furnished it to Cigna are not tied to a window.
The reader’s statement of disagreement is something they may send; the passage is the only place it is described.
Not stated here
The notice does not state a response deadline.
The notice does not say what Cigna does with a statement of disagreement beyond receiving it.
“Insurance support organization” is not defined.
The notice does not say whether the identifying details requested for review requests also apply to correction requests.
Legal Rights & Agreement Rules · User right or choice
Additional rights under other laws and protection from pretext interviews
The notice says the reader may have additional rights under state or other applicable laws. It also says the reader has the right, with very narrow exceptions, not to be subjected to pretext interviews.
Supporting quotations
You may have additional rights under state or other applicable laws. Further, you have the right, with very narrow exceptions, not to be subjected to pretext interviews.
Qualifications & exceptions
Additional rights under other laws are stated as “may have”.
The protection from pretext interviews has “very narrow exceptions”.
Not stated here
The notice does not identify which state or other laws apply.
“Pretext interviews” and the narrow exceptions are not defined or listed.
Account & Service Control · Procedure
How to contact Cigna’s privacy office
For the review right, the notice repeats that the reader generally can review information collected to provide insurance products and services by writing to Cigna Corporation, US Privacy Office, PO Box 188014, Chattanooga, TN 37422. For questions, the reader can contact customer service at the number on their ID card, or email privacy needs to PrivacyOffice@Cigna.com.
Supporting quotations
Generally, you have the right to review the personal information we collect to provide you with insurance products and services if you write to us at:
Cigna Corporation
US Privacy Office
PO Box 188014
Chattanooga, TN 37422
For questions, contact customer service at the number on your ID card.
Email privacy needs to PrivacyOffice@Cigna.com.
Qualifications & exceptions
The mailing address is the one used for the written review requests described earlier.
The customer service number is the one on the reader’s ID card.
Not stated here
The notice does not say whether an email counts as the written request needed for review or correction.
The notice gives no customer service number for readers without an ID card.
Legal Rights & Agreement Rules · Context
Which insurers sit behind each plan type
The closing paragraph links plan types to insurers. Individual and family medical and dental plans are insured by Cigna Health and Life Insurance Company and by Cigna HealthCare of Arizona, Illinois, Georgia, North Carolina, South Carolina and Texas. Group health insurance and health benefit plans are insured or administered by CHLIC, Connecticut General Life Insurance Company, or their affiliates. Accidental injury, critical illness and hospital care plans are distributed through operating subsidiaries of The Cigna Group Corporation, administered by CHLIC, and insured by CHLIC, Life Insurance Company of North America or New York Life Group Insurance Company of NY. The paragraph also says the Cigna Healthcare name, logo and marks are owned by The Cigna Group Intellectual Property, Inc.
Supporting quotations
Individual and family medical and dental insurance plans are insured by Cigna Health and Life Insurance Company (CHLIC), Cigna HealthCare of Arizona, Inc., Cigna HealthCare of Illinois, Inc., Cigna HealthCare of Georgia, Inc., Cigna HealthCare of North Carolina, Inc., Cigna HealthCare of South Carolina, Inc., and Cigna HealthCare of Texas, Inc.
Group health insurance and health benefit plans are insured or administered by CHLIC, Connecticut General Life Insurance Company (CGLIC), or their affiliates
Accidental Injury, Critical Illness, and Hospital Care plans or insurance policies are distributed exclusively by or through operating subsidiaries of The Cigna Group Corporation, are administered by Cigna Health and Life Insurance Company, and are insured by either (i) Cigna Health and Life Insurance Company (Bloomfield, CT); (ii) Life Insurance Company of North America (“LINA”) (Philadelphia, PA); or (iii) New York Life Group Insurance Company of NY (“NYLGICNY”) (New York, NY), formerly known as Cigna Life Insurance Company of New York.
The Cigna Healthcare name, logo, and other Cigna Healthcare marks are owned by The Cigna Group Intellectual Property, Inc.
Qualifications & exceptions
The entity list is introduced as including but not limited to the entities named.
Group plans are described as insured or administered, so the role can differ by plan.
The state entities named apply to individual and family medical and dental plans.
Not stated here
The listing of legal entities by state for group HMO, dental HMO and other products is referred to but not supplied.
The notice does not say which insurer applies to a particular reader.