This Privacy Policy applies to the Healthmine member platform, including our websites, mobile applications, and text message (SMS) communications (together, the “Service”). It does not replace Healthmine’s internal HIPAA Privacy and Security policies, and it does not replace the Notice of Privacy Practices issued by your health plan, employer, or other sponsor (“Sponsor”). Where your Protected Health Information (PHI) is involved, HIPAA and Healthmine’s Business Associate Agreement with your Sponsor control. If this Privacy Policy and the Healthmine Terms of Use conflict on a privacy matter, this Privacy Policy controls. If either conflicts with the Healthmine Notice of Nondiscrimination, that Notice controls as to nondiscrimination, language assistance, and auxiliary aids and services.

This Privacy Policy is incorporated by reference into the Healthmine Terms of Use. The terms “Healthmine”, “we”, and “us” include Healthmine Services, Inc. and our affiliates and subsidiaries. This Privacy Policy explains how Healthmine may: collect, use, and disclose information we obtain through the “Service.” By using the Service or providing your information to us or to our affiliates you consent to the collection, use, and disclosure of your information in accordance with this Privacy Policy and the Healthmine Terms of Use.

As part of providing the Service, Healthmine transmits, processes, and maintains data for health plans and health plan sponsors that use this Service. Such information will be held subject to the requirements specified by them and in accordance with our contracts with them and applicable law. This Privacy Policy does not reflect the privacy practices of the health plans and health plan sponsors, and we are not responsible for their privacy policies or practices. Healthmine does not review, comment upon, or monitor health plans or health plan sponsors’ privacy policies or their compliance with their respective privacy policies, nor do we review health plans or health plan sponsors’ instructions with respect to our processing of information to determine whether such instructions are in compliance or conflict with the terms of their published privacy policies.

“Personal Information” can be used to identify, contact or locate you.

“Personal Information” means information that alone or when in combination with other information may be used to identify, contact, or locate you, such as: name, address, email address, or phone number. Personal Information also includes health-related information. Personal Information does not include information that has been made anonymous so that a third party cannot identify a person.

We collect Personal Information:

We also collect information, such as anonymous usage statistics, by using cookies, server logs and other similar technology as you use the Service.

Registration and Account Information. You must have an account to use the Service. To create an account, you may need to provide Personal Information, such as your name, date of birth, group number, member number, email address, and a password. You may also provide other optional information, such as your address so we can send you rewards.

Your Use of the Service. We collect information you provide through the Service. For example, when you submit information in a health risk survey or community discussions or otherwise interact with other users, the Service will collect the information you provide in such submissions, including any Personal Information.

From Employers and Health Plans. Health plans and health plan sponsors may provide information, including Personal Information, to the Service about their members and personnel. When providing the Service, we maintain Personal Information collected or provided by health plans and health plan sponsors using the Service according to their instructions. It is the health plans and health plan sponsors’ responsibility to ensure that the information they submit to the Service is collected and used in compliance with applicable law, including, for example, by providing the appropriate level of notice to individuals.

Payments. Healthmine does not charge members to participate in the Service; your Sponsor pays for it. If your program ever includes an optional paid feature, payment would be handled by a third-party payment processor. Healthmine does not collect or store payment card or bank account numbers, though we may receive summary information about a transaction that does not include those numbers.

Customer support. We may collect Personal Information through your communications with our customer-support team.

Location information from your mobile device. We may collect and store general location information, such as city or postal code, if your device settings are enabled to send it to us. We do not collect precise geolocation. Collection of this information may improve the delivery of the Service.

Cookies, Automatic Data Collection, and Related Technologies. Like many other online services, the Service collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics. When we associate such information with Personal Information, we will treat the combination as Personal Information.

When you use the Service, we, and our third-party partners, such as analytics providers, use “cookies” and other similar technologies to collect information about how the Service is used. Our partners also may collect information about your online activities over time and on other websites or apps. When they provide such services, they are governed by their own privacy policies. You may be able to change browser settings to block and delete cookies when you access the Service through a web browser. However, if you do that, the Service may not work properly.

By using the Service, you are authorizing us to gather, analyze, and retain data related to the provision of the Service. This authorization does not extend to your Protected Health Information, which Healthmine uses, discloses, and retains only as permitted by HIPAA and by our agreement with your Sponsor, regardless of anything you agree to on this page.

We use Personal Information to:

We may use de-identified and aggregated information, which cannot reasonably be used to identify you, for our business purposes. We do not use Personal Information or Protected Health Information for marketing without your written authorization where one is required by law.

Internal and service-related usage. We use information, including Personal Information, for internal and service-related purposes and may provide it to third parties to allow us to facilitate the Service. We may use and retain any data we collect to provide and improve any of our services.

Communications. We may send email to the email address you provide to us or push notifications to your mobile device if they are enabled on your device to verify your account and for informational and operational purposes, such as account management, customer service, or system maintenance.

Health and Program Communications. Healthmine does not display third-party paid advertising on the Service. We may use information, including Personal Information, to send you communications about y our Sponsor's programs, the healtha ctions available to you, and your rewards, including push notifications, as permitted by HIPAA and our agreement with your Sponsor.

Aggregate data. We may use anonymous data collected through the Service and use it for any purpose.

We may share your Personal Information:

We do not rent, sell, or share Personal or mobile contact information with third parties or affiliates for marketing or promotional purposes. Information may be shared with subcontractors in support/delivery of services, such as customer service. Text messaging opt-in data and consent are never shared with any third party or affiliate, for any purpose.
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We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of the Service. For example, we partner with organizations that can provide educational information about health conditions, and we may provide information, including Personal Information to them, so they can provide you with relevant information. When we provide protected health information to such vendors, we require that they sign a business associate agreement limiting their use and disclosure of such information. We also may need to provide information, including Personal Information, to facilitate reward fulfillment.

Displaying to Other Users. The content you provide to the Service may be displayed on the Service. For example, other users of the Service may be able to see some information about you when you post to public areas of the Service by using the community and sharing features. We are not responsible for the privacy practices of the other users who will view and use the posted information.

Disclosing to Your Sponsor. Healthmine performs the Service on behalf of your Sponsor and acts as its Business Associate. Information you provide through the Service, including Personal Information and Protected Health Information, may be provided to or accessed by authorized personnel of the Sponsor connected to your account. We do this only as permitted by HIPAA and by our Business Associate Agreement with that Sponsor, and only for purposes such as treatment, payment, health care operations, quality measurement and reporting, and care management. Once information is with your Sponsor, the Sponsor’s own Notice of Privacy Practices governs how it is used, and we are not responsible for the Sponsor’s privacy practices.

Marketing. We do not rent, sell, or share Personal Information about you with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission. Healthmine does not display third-party paid advertising on the Service and does not enable third parties to deliver advertising to you through the Service.

Legal and Similar Disclosures. We may access, preserve, and disclose collected information, if we believe doing so is required or appropriate to comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; or protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, or transition of Service to another provider, your information may be transferred as part of such a transaction, only as permitted by HIPAA, applicable law, and our agreements with Sponsors. Any party receiving Protected Health Information in such a transaction remains subject to the same obligations that apply to Healthmine.

With Your Permission. We may also disclose your Personal Information with your permission.

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us.

We may provide our services to employers and health plans subject to HIPAA, and when we process “protected health information” as defined by HIPAA on behalf of employers and health plans, we are acting as a “business associate” to employers and health plans as regulated by HIPAA. Therefore, we must adopt and maintain appropriate physical, technical, administrative, and organizational procedures to safeguard and secure the protected health information we process. We also may not access, use, or disclose the protected health information except as permitted by health plans and health plan sponsors, you, and/or applicable law. We strive to protect the privacy of the Personal Information the Service processes, and to avoid inadvertent disclosure.

By using the Service or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Service. If a breach of unsecured Protected Health Information affecting your information occurs, we will notify affected individuals in accordance with the HIPAA Breach Notification Rule (45 C.F.R. §§ 164.400 to 164.414) and applicable state law. For other security incidents, we will notify you as required by applicable law, which may include posting a notice on the Service or sending you an email. You may have a legal right to receive this notice in writing. To receive free written notice of a security breach (or to withdraw your consent from receiving electronic notice), please notify us at ITSupport@Healthmine.com.

Text Messaging (SMS). If you opt in, you agree to receive SMS messages from Healthmine Services, Inc. on behalf of your health plan or other Sponsor. Messages may include health action and screening reminders, appointment prompts, and rewards notifications. Message frequency varies. Message and data rates may apply. For help, reply HELP. You can opt out at any time by replying STOP. Consent is not a condition of purchase and is not required to receive any benefit from your health plan. Your mobile number, opt-in record, and consent are never shared with any third party or affiliate for any purpose. Text messages are not a secure channel and may include limited personal information; please do not reply with sensitive health information. Opting out of text messages does not affect your health plan benefits or your participation in the Service.

Members under 18 participate only through a parent or legal guardian, who registers and manages the account on the member’s behalf. A member under 18 may not create an account independently.

Where your Sponsor covers members under the age of 18, a parent or legal guardian may register on the member’s behalf. During registration the guardian must confirm that they have legal responsibility for the member and that they hold documentation of that authority. Information about a minor member is collected from and through the registering guardian, and is used and disclosed only as described in this Privacy Policy and as permitted by HIPAA and our agreement with your Sponsor. No part of the Service is directed to children, and we do not knowingly permit a child to create an account for themselves. If you believe a minor has created an account without a parent or legal guardian, contact us at ITSupport@Healthmine.com. We will promptly investigate and take appropriate action, which may include deleting the information or transferring the account to a verified parent or legal guardian.

By using the Service, you will transfer data to the United States.

If you are visiting from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information you consent to any transfer and processing in accordance with this Privacy Policy.

We respect your control over your personal information. If you would like to update or correct any information that you have provided to us through your use of the Service or otherwise, or if you have suggestions for improving this Privacy Policy, please send an email to ITSupport@Healthmine.com.

Your Access and Other Data Subject Rights

Please note that we may ask you to verify your identify before taking further action on your request, for security purposes. In addition, if you have authorized a delegate i.e., through power of attorney, official documentation of such arrangement must also be provided as official record of authorization.

You may:

The Healthmine Site may periodically provide links to websites operated by third parties (“Linked Websites”). Please be advised that if you click on any such Linked Website, you will leave the Healthmine Service and be subject to the privacy policy of the Linked Website. Healthmine’s privacy policy does not control the activities of any Linked Website and we cannot control the activities of any Linked Website. Linked Websites may independently collect or request or information about you and have their own privacy policies. You should review those policies before following those links.

California Civil Code Section 1798.83, also known as the California “Shine The Light” law, permits California residents who are users of the Healthmine Service to request from us once a year, free of charge, information about the Personal Information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. If applicable, this information would include a list of the categories of Personal Information that was shared and the names and addresses of all third parties with which we shared information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to ITSupport@Healthmine.com.

Other State Privacy Rights. If you are a resident of California, Colorado, Connecticut, Texas, Utah, Virginia, or another state with a comprehensive privacy law, you may have additional rights regarding personal information that is not Protected Health Information, including the rights to access, correct, and delete personal information, to obtain a portable copy, to opt out of targeted advertising, sale, or profiling, and to limit the use of sensitive personal information. Healthmine does not sell personal information and does not share it for cross-context behavioral advertising. To exercise these rights, contact us at ITSupport@Healthmine.com. We will not discriminate against you for exercising your privacy rights. Information governed by HIPAA is generally exempt from these state laws; for that information, the rights described above and in your Sponsor’s Notice of Privacy Practices apply instead.

Posting of Revised Privacy Policy. We will post any adjustments to the Privacy Policy on this web page, and the revised version will be effective when it is posted. If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.

New Uses of Personal Information. From time to time, we may desire to use Personal Information for uses not previously disclosed in our Privacy Policy. If our practices change regarding previously collected Personal Information in a way that would be materially less restrictive than stated in the version of this Privacy Policy in effect at the time we collected the information, we will make reasonable efforts to provide notice and obtain consent to any such uses as may be required by law.