Transcarent Privacy Notice
Effective: January 2, 2024
Transcarent Privacy Policy
Effective Jan 2, 2024
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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
Protected Health Information
This Policy does not govern our privacy practices with respect to individually identifiable health information (also referred to as “Protected Health Information” or “PHI”). Transcarent treats all information you provide as a Member of Transcarent or a patient of our affiliated medical group as PHI 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, on behalf of your health plan from you, or the health care providers that provide health care services to you.
When you use our Services as a Member of Transcarent, 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.
The Notice of Privacy Practices describes how we collect, use, maintain and share that PHI, as well as your related rights, as a patient of our affiliated medical group.
Personal Information
Transcarent may collect, use, or share information we receive directly from you, automatically collected when you visit our Site, and collected by Transcarent from third parties.
This Policy only applies to our collection, use, or disclosure of your personal information, which comes from our Site without log-in.
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 |
|---|---|---|---|
Identifiers | ∙Real name ∙Alias ∙Postal address and code ∙Internet Protocol address ∙E-mail address ∙Phone number | ∙ 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 a Member) ∙ Transcarent may use an affiliated third-party vendor to help us manage some of our voice/text messaging communications with you. While we do supply this vendor with mobile telephone numbers of those we wish for them to contact, your mobile telephone number is only to be used to communicate with you on our behalf for marketing or transactional messaging. Originator opt in data will not be shared with any non affiliated third parties. |
Internet or other electronic network activity | ∙ Type of device/operating system/browser type ∙ Page requests ∙ Average time spent on our website ∙ Dates and times of visit ∙ Web page interactions ∙ Referring webpage/source through which you access the Services ∙ Statistics associated with the interaction between device or browser and the Services ∙ Email open | ∙ 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. ∙ 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. |
Professional or employment-related information | Employment (employer and job title) | ∙ You | ∙ When you register for a webinar |
We do not collect, use, or disclose Sensitive Personal Information from our Site, (as defined by the California Consumer Privacy Act, or CCPA), that is not PHI. Neither do we sell or share Sensitive Personal Information as those terms are used in the CCPA.
Cookies. We and third-party partners collect personal information 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 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 deleting or choosing not to accept cookies may impact your experience with non-logged-in Services.
Analytics Information
We may use analytics services to collect and process certain analytics data. These services may also collect personal information 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 content you view, and the dates and times of your visits. We use Google Analytics to gather statistics from our website and online services. Google Analytics uses a browser cookie for statistical analysis related to your browsing behavior on our website and online services. We also use other services of Google, like Tag Manager, to assist in search engine optimization and advertising effectively. 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. Learn more about Google’s privacy practices: https://policies.google.com/privacy
How We Respond to Do Not Track (DNT) Settings.
You may choose to turn on a “do not track” (DNT) setting in your browser or use a Global Privacy Control (GPC) setting. As there is not an industry or legal standard for recognizing or honoring web browser “Do Not Track” signals, we do not respond to them at this time.
Selling/ Sharing Personal Information
We do not “sell” your Personal Information for monetary value. But, we do use analytic cookies that some may consider to be a “sale.”
Transcarent uses OneTrust as our cookie consent tool. You will have the opportunity to customize your cookie preferences, via a consent banner, when you visit our website. You can change your choices later by either clearing your cookies through your browser settings and revising your choice in the consent banner or by using “Manage Cookie Preferences” to opt into certain types of cookies. Please note that Required Cookies cannot be disabled and if you decide to opt-out of Functional Cookies, certain functionality of our websites or your account may be impacted.
How We Use the Information We Collect
We will use your personal information to respond to inquiries you send to us, to fulfill your request to sign you up to our newsletter, and for other purposes such as:
To understand and analyze how you use our Site and develop new products, services, features, and functionality;
To communicate with you, provide information that you request, respond to comments and questions, and otherwise provide site visitor 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 ∙ 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 ∙ 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 Policy, 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, sell, or share personal information (including sensitive personal information) from children under 16 years of age. If you learn that a child has provided us with personal information in violation of our policy, then please alert us at privacy@transcarent.com.
Your Privacy Rights
Transcarent has website visitors from around the world. 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 or retaliate against you for exercising your privacy rights.
Your privacy rights only apply to your personal information. Most of the information that we have is protected health information, regulated by HIPAA, and you may be required to submit any privacy request through your health plan or as a medical records request; we will let you know if that is the case.
For your convenience, we already include the following information in this Policy.
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.
The categories of third parties with whom we share or disclose your information
Right to Know and Access Personal Information
You have the right to access and know what personal information we collect about you, and how we use and disclose such personal information.
Right to Correct Inaccurate Personal Information
You have the right to request that we correct inaccurate personal information we maintain about you.
Right to Request Deletion of your Personal Information
You have the right to request that we delete the personal information we have about you, subject to certain limitations. If we do not delete your personal information for reasons permitted under applicable law, we will let you know the reason why.
Right to Opt Out of Sale or Sharing of Personal Information
You have the right to opt out of sale or sharing of personal information. Information on how to do so is in the earlier section, titled Selling/Sharing Personal Information.
Right to Opt Out of Automated Decision-Making
We do not use personal information for automated decision-making purposes.
Right to Opt Out of Processing of Personal Information for Profiling or Targeted Advertising
We do not process personal information for targeted advertising purposes, profiling generally, or for profiling in furtherance of decisions that produce legal or similarly significant effects concerning a consumer as described by Colorado 4 CCR 904-3, Rule 9.03.
Right to Limit Processing of Sensitive Personal Information
We do not process sensitive personal information within the meaning of CCPA. You can learn how your PHI can be used and disclosed by reading the Notice of Privacy Practices of your health plan, (for Members), or reading the Notice of Privacy Practices (for patients of our affiliated medical group).
Exercising Your Privacy Rights
To request to exercise your privacy rights described above, please submit your request to Privacy@Transcarent.com with the subject line “Exercising my privacy rights”. You may also make a privacy request by calling our toll-free number (888) 388-9151.
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:
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
describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We can only respond to your request or provide you with personal information if we 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 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 Privacy@Transcarent.com.
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 Site is hosted in the United States and intended for users located within the United States. If you choose to visit our Site 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 visit the Site from 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, 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 |
|---|---|
January 2, 2024 | Non-major change: added information to Categories of Personal Information We Collect regarding opt-in data. |
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. | |
In this update, we: ∙ Align the categories of information collected and shared with defined terms in the California Consumer Privacy Act ∙ Explain new privacy rights in alignment with state laws ∙ Provide information for telehealth patients ∙ Removed some text to make the notice shorter and easier to understand 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 Privacy@Transcarent.com.