Privacy policy

At XPO H2O, we value the trust you have placed in us and intend to continue to earn your trust each day. Protecting the privacy of your personal information is a major priority throughout all of our business practices and procedures. Our commitment to protecting your privacy is reflected in this Privacy Policy, which describes our policies in using, gathering, communicating, and protecting information about you. Our procedures and policies protecting and safeguarding your personal information are maintained both while you are insured under a policy we administer and for any time thereafter.

Personal Information We Collect

We receive information from you on applications for professional services and related forms. We also receive information from outside sources, including eligibility listings from employers. This information may include, among other things, your name, address, social security number, phone number, marital status (including domestic partnerships), your dependents, financial information, and (as applicable) your academic enrollment status or employment details.

We receive information from you and others regarding premium payments. This information may include, among other things, credit card numbers, bank account numbers, and other material relating to premium payments you make.

In connection with your use of our Website, we may collect the following information:

  • The domain name or Internet Protocol (IP) address, but not the email address of visitors to our Website.
  • The e-mail addresses of users who communicate with us via email.
  • Aggregate information on what pages on our Website users access or visit.
  • Information volunteered by the user, such as site registration and email update requests.

We retain personal information only so long as required by our business practices or by applicable law.

Personal Information We Disclose

We do not disclose any nonpublic information about you to anyone, except as authorized or as permitted or required by law. We do not sell or otherwise disclose your personal information to anyone for purposes unrelated to our products and services.

We use the personally identifying information you voluntarily provide to register you as a user of the Website or to complete transactions with us at your request. We will not use your information for any purpose that you have not expressly authorized. Your information is not sold, rented, or shared with other entities or organizations for commercial purposes or in ways different than what is disclosed in this Privacy Policy.

From time to time, we may disclose information to fulfill certain legal and regulatory requirements or if we believe, in good faith, that such disclosure is legally required or necessary to protect others’ rights or to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity. We may also provide information to a court, government agency, or other third parties when subpoenaed or as otherwise required by law. Further, in the event Acquisition Procurement Sourcing, LLC is subject to a merger or acquisition, we may provide information to the new owners of the business. Disclosure may also be required for company audits or to investigate a complaint or security threat.

Our Policies and Procedures with Respect to Confidentiality and Security of Personal Information

We restrict access to information about you to those employees and third parties who need to know that information in order to provide the benefits and services pertinent to your insurance policy. All personal information exchanged with third parties is restricted by confidentiality agreements. We maintain physical, electronic, and procedural safeguards that comply with federal and state regulations to protect information about you from disclosure. If, at any time in the future, it is necessary to disclose any of your personal information in a manner that is inconsistent with this Policy, we will give you advance notice of the proposed change so that you will have the opportunity to consent or refuse consent to such disclosure.

We will apply the policies discussed above in the event we propose to disclose your information to a third party. If we propose to disclose your information to a third party that is acting as our agent or on our behalf, we will ensure that the third party has agreed to assure adequate protection of your information.

Choice/Opting Out

You may choose to restrict our use of your information. You may exercise your choice to “opt-out” of providing personal information in many ways. When selecting to use certain services or features of our Website, you can choose whether to share personal information with respect to the particular service or feature. If you receive communications from us that you do not want to receive, you can opt-out from receiving these communications, by requesting that we remove your user account from our database.

You may also opt-out entirely from providing personal information to us by not creating an account on our Website or not completing transactions with us online through the Website. You may also choose at a later date to have your name removed from our database.

However, certain sections of our Website do require registration in order to use these sections and services. If you choose not to register or provide certain information, these sections will not be available for your use.

We will not use your information for any purpose other than for those purposes you have authorized. Further, we will not use your information for a purpose that is incompatible with the purpose for which it was originally authorized by you.


Your user account containing your information is password protected. Only those who log on with your password can access your account. Any transactions requiring you to enter personal identifying information is submitted via a secure, encrypted page. We have taken appropriate security measures to protect your personal information from loss, misuse and unauthorized access, disclosure, alteration, and destruction. However, please remember that you play a valuable part in security as well. Your password to access your account should never be shared with anyone. After you have finished using the Website, you should log off and exit your browser so no unauthorized persons can use our Website with your name and account information. Furthermore, if you provide any information to parties who operate websites that are linked to or from our Website, different rules may apply to their collection, use, or disclosure of your personal information. We encourage you to review the privacy policies of such other sites before revealing any sensitive or personal information. Despite precautions taken by you or by us, “perfect security” does not exist on the Internet. We cannot ensure or warrant the ultimate security of any information you transmit.

We make every effort to ensure that the information on the Website, as well as your account information which you have provided to us, is reliable for the use you intend, and that it is accurate, complete, and current. To assist us in ensuring that your information is relevant on an ongoing basis for its intended purposes, we encourage you to update your information on the Website as frequently as may be necessary.

Access our Websites through Mobile Devices

If you access our websites on a mobile device, we may also collect the related unique device identifier and mobile device IP address, as well as information about that that device’s operating system, mobile carrier, and location information.

When you provide us your mobile device phone number as your contact phone number, you consent to the use of your mobile device phone number for the purposes identified in this Privacy Policy. If you choose to receive notifications from us on your mobile device (e.g., text notifications), you also consent to the use of your mobile phone number for that purpose.


Cookies are pieces of information that a web site transfers to a user’s computer for purposes of storing information regarding user’s preferences. Just as many major web sites use cookies as a standard practice to provide useful information to a user, Acquisition Procurement Sourcing, LLC uses cookies to deliver web site content specific to your identified interests and to guide you through your session on the Website. By themselves, cookies do not personally identify users, although they do identify a user’s computer. A user can opt not to take advantage of the cookie benefits by setting his or her browser to refuse cookies.

Your Access to Your Personal Information

You may request a copy of our records of personal information relating to you and may ask us to correct the information contained in those records. Note that we may not be able to correct inaccuracies in information provided to us by others.

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