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Transcarent Privacy Notice

Effective: July 20, 2022

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Transcarent is the first comprehensive health and care experience company that makes it easy to get the high-quality, affordable health and care that everyone deserves. We do that by directly connecting consumers with high-quality care, transparent information, and trusted guidance on their terms – in as little as 60 seconds, 24/7, from the palm of their hand.

This Privacy Notice explains how we collect, use, and share information from users of our mobile applications, digital tools, other platform services, and related websites (including our website at www.transcarent.com) (the “Site”) (collectively, the “Services”). Please see our Terms of Service for more details.

Table of Contents

  1. Our Relationship With You

  2. Protected Health Information

  3. Personal Information

    1. Categories of Personal Information We Collect

    2. How We Use the Information We Collect

    3. When We Share the Information We Collect

  4. Your Privacy Rights

  5. Other Important Information

  6. Changes to Our Privacy Notice

  7. Contact Information

Our Relationship With You

Our members are employees (and often their spouses or domestic partners and dependents) with coverage under group health plans. Anybody can visit our Site and learn about us and our Services, but you will only be able to activate a membership, or log in, if your health plan is our client.

Your access to the Services through Transcarent is solely determined by your group health or welfare plan, which can: restrict, suspend, or terminate your access to or ability to use the Services.

Protected Health Information

When you use the Services as a participant in a group health or welfare plan sponsored or administrated by a Transcarent client, we collect protected health information (“PHI”) about you that is governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). We will receive this information either directly from your health plan, or on behalf of your health plan from you or the health care providers that provide health care services to you. For example, when we help you access care at centers of excellence or when we help you coordinate care between your health care providers.

These are some examples of the types of protected health information we may collect from or on behalf of your health plan:

  • your medical history, conditions, diagnoses, treatments, medications, lab results;

  • Your medications; primary care physicians, health care providers;

  • your medical claims, health plan account number, and insurance information;

  • your weight, activity logs, other health statistics collected from medical devices and smartphones;

  • information provided by your family members relating to your health;

  • demographic information (such as your age and gender); and

  • your biometric information such as voice recording or image.

These are some examples of how we may use or share your protected health information to provide our service to you, to the extent your group health or welfare plan allows:

  • for personalization – we need to know about you to provide care coordination services and to make tailored recommendations;

  • we take steps to avoid your de-identified health information from being re-identified, for example, when used in data analytics;

  • to request a new or refill prescription for you, we may need to share your information with a pharmacy.

Our collection and use of such protected health information is treated differently than the personal information (PI) that we may receive when you visit our Site without signing-in to your account. Your health plan’s HIPAA Notice of Privacy Practices—and the contractual agreement we have with your plan, known as a business associate agreement—and laws and regulations govern our collection and use of such information. Please read the Notice of Privacy Practices of your health plan to understand how your PHI can be used and disclosed.

Personal Information

Transcarent may collect, use, or share information we receive directly from you, automatically collected when you use our Services or visit our Site, and collected by Transcarent from third parties.

The following subsections apply only to your personal information (“PI”), which comes from our Site without log-in, and not to protected health information.

Categories of Personal Information We Collect

In the past twelve (12) months, Transcarent may have collected any of the following categories of personal information (PI) about you:

Categories of Information

Examples 

Source

Context 

∙ Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

∙ First and last name

∙ E-mail address

∙ Phone number

∙ Postal code

∙ Employment (employer and job title)

∙ You

∙ When you use the “Contact Us” link on the Site

∙ If you send us an inquiry using another method

∙ If you sign-up for notifications or updates

∙ When you contact our customer support team (but not as an account holder)

∙ Site visit and usage information

∙ IP address

∙ Type of device/operating system/browser type

∙ Page requests

∙ Average time spent on our website

∙ Dates and times of visit

∙ Third Parties

∙ We use this information to monitor and improve our website.

∙ We use this information to improve your experience, such as by serving a version of our site appropriate for your screen dimensions.

∙ Web analytics

∙ Web page interactions

∙ Referring webpage/source through which you access the Services

∙ Statistics associated with the interaction between device or browser and the Services

∙ Third Parties

∙ We use this information to monitor and improve our website.

∙ Email analytics

∙ Email open

∙ Third Parties

∙ When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.

∙ Geolocation data

∙ Approximate geographic location inferred from an IP address

∙ Third Parties

∙ We use this information to get a general understanding of how many people visit our sites from which cities or regions.

∙ We may use this information to provide information that is relevant for you. 

Information We Automatically Collect When You Use Our Services.

We and third-party partners collect information (PI) using cookies, pixel tags, or similar technologies when you use our Services or visit our Site. Our third-party partners, such as analytics and advertising partners, may use these technologies to collect information (PI) about your online activities over time and across different services.

  • Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

  • Pixel tags, also known as “clear GIFs”, “tracer tags”, or “web beacons”, are technologies that allow us and our third-party partners to understand which pages or content you view. These pixel tags are used to help us optimize and tailor our Site for you and other web visitors.

  • Your web browser’s “Help” file has information on how to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

Analytics Information. We may use analytics services such as Google Analytics and Mixpanelto collect and process certain analytics data. These services may also collect information (PI) about your use of other websites, apps, and online resources. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the searches you conduct, and the dates and times of your visits. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

How We Respond to Do Not Track (DNT) Settings. Some web browsers incorporate a “Do Not Track” (“DNT”) or similar feature. At the present time, we do not respond to DNT signals.

How We Use the Information We Collect

We will use your information (PI) to respond to inquiries you send to us, to fulfill your request to sign you up to our newsletter, and also:

  • To provide, maintain, improve, and enhance our Services;

  • To understand and analyze how you use our Services and develop new products, services, features, and functionality;

  • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;

  • For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and

  • For other purposes for which we provide specific notice at the time the information is collected.

In addition, we may use information that has been anonymized or aggregated, without limitation.

When We Share the Information We Collect

In the past twelve (12) months, Transcarent may have shared the information (PI) we have about you with the following recipients:

Categories of recipients

Reason for sharing

Categories of Information Shared

Vendors and Service Providers.

We may share any information we receive with vendors and service providers—including our analytics partners described in the section above titled “Analytics Information”—retained in connection with the provision of our Services. Information is shared to the extent necessary to perform the vendors’ or service providers’ respective functions.

∙ Identifiers

∙ Protected classification characteristics under California or federal law (such as gender or race)

∙ Commercial information

∙ Internet or similar network activity

∙ Geolocation data (such as IP address data)

∙ Professional or employment-related information

∙ Inferences drawn from other personal information

Corporate Affiliates.

To support us in providing, integrating, promoting, and improving the Services, we may share personal information within our corporate family of companies that are related by common ownership or control.

∙ Identifiers

∙ Protected classification characteristics under California or federal law (such as gender or race)

∙ Commercial information

∙ Internet or similar network activity

∙ Geolocation data (such as IP address data)

∙ Professional or employment-related information

∙ Inferences drawn from other personal information

In addition, we may share information we have about you that is described in any of the categories listed above in “Categories of Information We Collect” in the following situations:

  • As required by law and similar disclosures: We may access, preserve, and disclose your information if we believe doing so is required to: (a) comply with applicable laws or law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. We will respond to a law enforcement request or legal process following guidance from HHS, which prohibits disclosure in all but the narrowest circumstances.

  • Merger, sale, or other asset transfers: We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our assets.

  • With your consent: We may disclose your information with your permission.


Security

We make reasonable efforts to protect your personal information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, no electronic transmission or storage of information can be entirely secure; no one can guarantee the absolute security or privacy of your information.

Retention of information

We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Notice, to make our products and services available to you, or as instructed by you, unless a longer retention period is required or permitted by law.

Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age. Although certain health care services for children provided by independent health care practitioners may be accessed using our Services, no part of our Services is directed to children. If you learn that a child has provided us with personal information in violation of our policy, then please alert us at [email protected].

Update Your Information or Ask a Question

You have the right to request that we update your information to correct information that is outdated or incorrect. See Your Privacy Rights, below. Please note that most of the information that we have is protected health information, regulated by HIPAA, and you may be required to request your desired amendment through your health plan; we will let you know if that is the case.

Your Privacy Rights

Transcarent has website visitors from around the world and members from throughout the United States that use our Services to improve their health and care experiences. Regardless of where you are located, we respect your ability to know, delete, correct, and export your information and have extended those rights globally. We will not discriminate against you for exercising your privacy rights.

Information About Your Rights

The following applies to residents of California as well as all visitors to our site.

Upon your request, and subject to applicable legal exceptions, we will:

  • provide access to and/or a copy of certain information we hold about you

  • update information that is outdated or incorrect

  • delete certain information that we have about you

  • disclose the categories of information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your information; and the categories of third parties we share or disclose your information. For your convenience, we have already included that information in this Privacy Notice.

  • disclose information on the financial incentives that we offer to you, if any.

Residents of certain states, such as Nevada and California, have the right to opt out of the sale of personal information. As of the date of this privacy notice, we do not sell your personal information, as defined under applicable law, such as the California Consumer Privacy Act (CCPA). If that changes in the future, we will update this privacy notice.

Exercising Your Privacy Rights 

To request to exercise your privacy rights described above, please submit your request to [email protected] with the subject line “Exercising my privacy rights”.

Only you or an authorized agent may make a request related to your personal information. We may ask additional questions to verify that a request is coming from you or an authorized agent; we do this to protect your data privacy. To do that, we need you to:

  1. provide information that allows us to reasonably verify that you are the person about whom we collected personal information or an authorized representative. For example by letting us know your name and zip code; and

  2. describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

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. If we follow-up with you to ask for more identifying details, please know this is to protect your data privacy. We will use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Making a verifiable consumer request does not require you to create an account with us.

Because Transcarent collects both personal information (PI) and protected health information (PHI), it can be hard to understand which rights apply to your data in what context. If you have any questions about how any of the information applies to you and your data with Transcarent, please contact us at [email protected].

Other Important Information

Third Parties

Our Services may contain links to other websites, products, or services that we neither own nor operate. These links are provided solely as a convenience to you and are not a referral or endorsement of the content of such third parties or the entity, item, or service.

Transcarent is not responsible for the content of any linked third-party website. We make no representations regarding the content or accuracy of any materials on such third-party website, which is developed and provided by or on behalf of that third party. You should take precautions when downloading files from all websites to protect your computer from viruses and other destructive programs. If you decide to access any third-party websites, you do so at your own risk.

We are also not responsible for the privacy practices of these third parties. Our privacy policy does not apply to third party websites. Just as you are reading our privacy policy so, too, should you read third party website privacy policies before providing them any information. Contact the site administrator, webmaster, or privacy contact person of that website if you have any concerns regarding such links or content.

International Visitors

Our Services are hosted in the United States and intended for users located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, if you choose to use the Services outside the United States, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

Changes to Our Privacy Notice

We will update this Privacy Notice to make sure it accurately reflects our data collection and use practices, changes to our privacy policies, or as applicable laws require. We will comply with applicable legal requirements regarding providing you with notice and/or consent when we make such changes, depending on the type of change made. We also provide information about how our Privacy Notice has changed over time below.

Previous Notice

Major changes made to the Notice

July 15, 2021

In this update, we: 

∙ Redesigned the Privacy Notice to make it easier to read and understand. 

∙ Added additional details to answer questions we anticipate you may have.

∙ Replaced the prior California privacy rights section with a new Your Privacy Right section, which expand the same rights previously described to all site visitors rather than restricting to California residents.

We welcome any questions, concerns, or feedback you may have about the updates to this Notice. 

Contact Information

If you have any questions, comments, or concerns about our processing activities, please email us at [email protected] or write to us at Transcarent, Inc., 4700 S. Syracuse Street, Suite 900, Denver, CO 80237, Attention: Privacy Inquiries.