WEBSITE PRIVACY POLICY
This Website Privacy Policy describes Health Dialog Services Corporation's ("Health Dialog's" or "our") commitment to your privacy and explains our privacy practices, so you can make an informed decision about your use of this Site and the information that you choose to provide to us. Please read this Privacy Policy carefully to understand how we collect, share, and protect information about you.
This Privacy Policy is incorporated into and is part of the Terms and Conditions of Use of each of the web sites owned and operated by Health Dialog (collectively and each separately, the "Site"). The Terms and Conditions of Use include terms, such as governing choice of law and venue for dispute, that are important to this Privacy Policy.
By accessing and using the Site, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy.
Introduction
Health Dialog is committed to protecting your privacy. In order to deliver personalized and relevant information to you through this Site, we collect certain information. The purpose of this Privacy Policy is to describe our privacy practices regarding that information.
We may collect individually identifiable information about you from you, your health plan, your employer and other sources. Health Dialog only uses and discloses such information about you as permitted by the Privacy Rule established under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), any other applicable laws and regulations and our agreement with your health plan.
A Special Note About Children
Health Dialog is committed to protecting the privacy of children. This Site is not designed or intended to attract children under age 13. We do not collect any personal information from any person if we know such person is a child under the age of 13. BY ACCESSING THIS SITE, YOU REPRESENT THAT YOU ARE 13 YEARS OF AGE OR OLDER.
Information About You That We Collect
Your health plan, your employer or third party vendors providing services on behalf of your health plan may furnish us information about you, such as your name, date of birth, health plan ID number, and zip code, and, in certain circumstances, your health plan or its third party vendors may furnish information related to your health, such as medical and pharmacy claims, health risk assessment information or other administrative data, in order for us to provide the services of this Site to you. We also may collect information directly from you through your use of the Site, including, but not limited to: demographic information (such as your name, address, and date of birth) and information related to your health (such as your height, weight, medication history or experience with certain conditions or treatments).
As with many other websites, the Web servers used to operate the Site may collect certain data pertaining to you and the equipment and communications method that you use to access the Internet and the Site. We also may collect other identifying information from or about you in connection with your use of the Site. For example, we may collect and store the content of, and data regarding, any correspondence you may have with us or our representatives, regardless of the subject matter or the mode of communication by which such correspondence is made.
How We Use Information About You
We use information about you that you provide through the Site, or that we otherwise collect, to provide services to you on behalf of your health plan. For example, when you fill out a personal health assessment, we may use the information from the assessment to give you personalized feedback about your health. We may use information about you to notify you of opportunities available on or through the Site, to customize the Site content for you, to send you materials that you request from us, and for other legitimate and lawful business purposes. Health Dialog also may use information about you to provide services to your health plan.
Health Dialog may combine information about you with information about others who use the Site and remove all personal identifiers from the resulting combined information to create "de-identified information." We use de-identified information in the development of products and services to meet the continuing needs of our clients, and to analyze and improve the content, features, materials, and opportunities that we may make available on the Site.
If you contact us for support or assistance, we may use information about you or your computer that you provide for purposes such as verifying whether your computer meets the minimum requirements needed to use the Site and our various services.
Data collected by our Web servers or otherwise through use of the Site is used to facilitate Site operation and system administration, to generate aggregated, non-identifiable statistical information, to monitor and analyze Site traffic and usage patterns, and to improve the content and content delivery with regard to the Site and the content, materials, opportunities, and services that we describe or make available on the Site. These data may reveal such things as the Internet Protocol address assigned to your computer, specific pages that you accessed on the Site or immediately prior to visiting the Site, and the length of time you spend at the Site, but without combining these data with other sources of information, they do not readily or personally identify you. For security reasons and to confirm the integrity of our data, however, we may combine components of these data with other sources of information that may identify you. Unless otherwise described in this Privacy Policy or our Terms and Conditions of Use, such identifying information will be used solely for our internal business purposes.
How We Share or Disclose Information About You
We may share information about you with your health plan or your health care providers to provide the services of this Site and for other purposes permitted by HIPAA. Also, as permitted by HIPAA, we may share information about you with your health care provider in order to facilitate improved communication about and coordination of your health care services. We may decide from time to time to utilize a number of trusted business partners in delivering the content available on or through this Site to you. To the extent necessary for purposes of operating the Site, communicating with you, or fulfilling your requests for our services, we may share information about you with these business partners. When we use other companies to provide services to us, we require them to protect the confidentiality of any personal information they receive from us or collect on our behalf and to use such information only for the limited purpose of providing the services on our behalf.
In addition, Health Dialog may disclose to your employer the fact that you have registered with this Site, that you completed a personal health assessment or that you participated in or are enrolled in certain offers or programs made available by your health plan through this Site for various purposes. Those purposes may include, without limitation, your employer's use of such information in connection with implementation of a gift, award, incentive or other program or to analyze registration rates. Except as described above, Health Dialog will not share information about your health with your employer without your written or electronic authorization.
We may share reports containing de-identified data with your health plan, employer, or other third parties. De-identified data does not contain any information that could be used to contact or identify you.
In certain limited circumstances, we may disclose information about you, including protected health information, if we become subject to a subpoena, search warrant or court order, or if we are otherwise legally required to disclose such information. Health Dialog may disclose information about you as necessary to establish or exercise our legal rights, to enforce the Terms and Conditions of Use, to assert and defend against legal claims, in connection with a corporate transaction resulting in a transfer of the assets or line of business relating to such data, and to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities. Health Dialog also may disclose such information in special cases, such as in response to a potential threat to the physical safety or well-being of you or others or to protect property.
Our Use of "Cookies"
"Cookies" are small files of data that reside on your computer and allow us to recognize you as a Health Dialog client if you return to the Site using the same computer and browser. We send a "session cookie" to your computer if and when you log in to your Health Dialog account. These cookies allow us to recognize you if you visit multiple pages in the Site during the same session, so that you don't need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.
We also use longer-lasting cookies to display your user name on our sign-in form, so that you don't have to retype the e-mail address each time you log in to your Health Dialog account. Our cookie files are encoded so that any information stored in them may only be interpreted by the servers on the Site.
Web browsers and other software allow you to erase cookies from your computer's hard drive, to block or reject all cookies, or to receive a warning before a cookie is stored. If you choose to reject cookies, the Site may not operate efficiently for you.
Health Dialog Provides the Site in a Secure Environment
We use commercially reasonable methods to keep information about you that we collect or store on or through the Site safe from unauthorized access.
Health Dialog maintains reasonable physical, electronic, and procedural safeguards designed to comply with applicable federal standards to help guard information about you and to assist us in preventing unauthorized access to that information. Nevertheless, no set of security safeguards is guaranteed to be impenetrable. We cannot and do not guarantee that communications to or from the Site, or that data transmitted or stored on or through the Site, are or will be totally secure from loss, misuse or unauthorized access by third parties.
Health Dialog maintains identifiable information about you on this Site exclusively on servers located in the United States.
You Have Options
When corresponding with Health Dialog or our representatives, or when making a request for information or otherwise interacting with Health Dialog through the Site, you choose what information to supply, what questions to pose, and what comments to make, whether you wish to receive further information, and how we should provide such information. Please take care to share only information that you believe is appropriate.
There may be opportunities on the Site for you to opt-in or opt-out of certain uses and disclosures of information specific to particular tools or sections of the Site. There also may be opportunities for you to designate how you would like your e-mail address to be used or not used by Health Dialog for purposes related to the services provided through the Site. Please take care to evaluate these options where they are available.
If you wish to remove information about you from the Site, please contact Health Dialog's Privacy Officer at the following address:
Privacy Officer
Health Dialog Services Corporation
privacyofficer@healthdialog.com
Please be aware that it may not be technologically possible to remove each and every data record from our servers.
Changes to the Privacy Policy
From time to time, we may change this Privacy Policy and our privacy practices, because of changes in relevant and applicable legal or regulatory requirements, in our business practices, or in our attempts to better serve your needs and those of our other clients. When we do so, we will post a revised Privacy Policy on the Site and a new effective date below. Any such change will be effective immediately upon posting on the Site. You are responsible for checking the Privacy Policy for such changes.
Linked Sites
For your convenience, this Site may contain links to websites that are not operated by or affiliated with Health DialogThese third party websites are not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy or security practices of those sites or of any companies that we do not own or control. Any information you disclose once you access these other web sites is not subject to this Privacy Policy. We encourage you to seek out and read the privacy policy of each website that you visit to understand how information about you is collected, used, and protected.
Questions
If you have any questions regarding this Privacy Policy, please contact Health Dialog’s Privacy Officer at privacyofficer@healthdialog.com or:
Privacy Officer
Health Dialog Services Corporation
100 Summer Street, Suite 1400
Boston, MA 02110
If you become aware of any breach of Site security, this Privacy Policy, or the Terms and Conditions of Use, please notify us immediately. Health Dialog is committed to maintaining the privacy and security of your information consistent with all applicable legal requirements and the terms of this Privacy Policy and will review all legitimate concerns
Acknowledgement
BY ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND CONSENT TO OUR PRIVACY PRACTICES AND TO THE USES AND DISCLOSURES OF INFORMATION THAT WE COLLECT ABOUT YOU AND YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF USE APPLICABLE TO YOU.
Effective Date
This Privacy Policy is effective as of February 2, 2015