This Privacy Policy is effective as of June 15, 2024..
Zelis Healthcare, LLC, its affiliates and subsidiaries, (“Zelis,” “We,” “Us,” or “Our”) have created this privacy policy (this “Privacy Policy”) because We know that You care about how the information You provide to Us is used and shared. This Privacy Policy relates to the information collection and use practices of Zelis in connection with its products and services, including but not limited to the Sapphire Transparency Platform, SmartShopper application, and associated services and call center (collectively, the “Products and Services”), which are made available to You through a variety of platforms, including, but not limited to, www.smartshopper.com (the “Website”), and Our mobile app, which is accessible through tablets, cell phones, and other devices (the “App”). The Products and Services, Website, and the App are collectively referred to as the “Platform.” This Privacy Policy is subject to our terms of use (“Terms of Use”) which are incorporated herein by reference.
DESCRIPTION OF USERS AND ACCEPTANCE OF TERMS
For convenience, the words “User,” “You,” and “Your” as used in this Privacy Policy refer to all users of the Platform, including, without limitation, anyone that accesses or visits the Platform (including those that view only publicly-available content), and individuals who have signed up to use Our Products and Services. By (i) visiting our Platform, or (ii) by signing up, accessing, and/or using the Platform, You agree to the terms of this Privacy Policy and the accompanying Terms of Use.
CHANGES TO THIS PRIVACY POLICY
Please note that this Privacy Policy may change from time to time. Zelis will post any changes on this page. We encourage You to check back and review this Privacy Policy periodically for any updates or modifications. Unless another method is provided to you, Your continued use of the Platform will be deemed Your having read, acknowledged, and acceptable of the information contained in the updated Privacy Policy.
If You have any additional questions or concerns about this Privacy Policy, please contact Us at:
Zelis
Attn: General Counsel
340 Mount Kemble Avenue Suite 200
Morristown, New Jersey 07960
Email address : legal@zelis.com
WHAT INFORMATION DO WE COLLECT/RECEIVE
In the course of operating the Platform, Zelis will collect (and/or receive) the following types of information:
1. Personal Information
For the purposes of this Privacy Policy, “Personal Information” is information that (i) You voluntarily provide to Us or is obtained by Us through Your Use of the Platform, and (ii) that personally identifies You. Personal Information includes, but is not limited to, Your name, email address, fax number, IP address, mailing address, business address, phone number, billing and payment information, Your health insurance plan (“Health Plan”) member identification number, and other data that can be used to personally identify or contact You.
If You decide to utilize any of the Products and Services, including, for example performing a search of Healthcare Providers (defined below) in Your Health Plan’s network and where available, scheduling an appointment with a physician, healthcare facility, psychologist, long-term care facility, hospitals, surgery center, and other providers of healthcare services (“Healthcare Provider”) through the Platform, Your Personal Information may also contain sensitive personal information, including any confidential health information (such as Your reason for scheduling the provider appointment) that You voluntarily provide.
HIPAA: Please note that in order for the Platform to function, the Platform must utilize: (1) information submitted by You, including but not limited to health information and Your Personal Information; and (2) and information, including health related information from your Health Plan (collectively the “Platform Information”). The Platform Information meets the definition of Protected Health Information (“PHI”) as that term is defined under the Health Insurance Portability and Accountability Act of 1996, and the Health Information Technology for Economic and Clinical Health Act (“HITECH”) and the regulations promulgated thereunder, in effect or as amended (collectively, “HIPAA”). Zelis is not a “Covered Entity” as that term is defined under HIPAA, however, Your Health Plan is a Covered Entity. Although Zelis is not a Covered Entity, we are a Business Associate of Your Health Plan. To the extent that Zelis has received your Platform Information from a Covered Entity, in its capacity as a Business Associate, the terms of the applicable Business Associate Agreement between Zelis and your Health Plan shall govern Zelis’ use and disclosure of such Platform Information. Zelis may engage third party subcontractors (“Third Party”) to provide Services, including but not limited to process and store your Platform Information. To the extent Zelis engages such Third Parties, Zelis shall use commercially reasonable efforts to ensure that any such Third Party to whom it provides PHI agrees to the materially similar restrictions and conditions that apply to Zelis with respect to such PHI. Your Health Plan should be particularly aware of its obligations of confidentiality with respect to your PHI, including, without limitation, its obligations under United States federal and state laws, in particular HIPAA. If You wish to restrict the uses of Your PHI, amend, or receive an accounting of the disclosures of your PHI, you must contact Your Health Plan. Zelis does not have, and does not assume, any responsibility for the confidentiality of communications between You and Your Health Plan, other than those expressly stated in this Privacy Policy, or any responsibility for a violation of HIPAA by Your Health Plan. When You use the Platform, you may automatically receive administrative emails from Us. You cannot opt-out of receiving administrative emails sent by Us.
Your Platform Account: This information may include, for example, Consistent with the above, Zelis may obtain, collect, retain, store or otherwise maintain Your Personal Information from the following sources:
You can decline to provide Your Personal Information to Us by not engaging in the activities described above, such as by not registering or creating a Platform Account on the Platform or by not using the Products and Services. If You decline to submit Personal Information, Zelis may not be able to or may choose not to provide to You some or all of its Products and Services. Accordingly, You can determine to a large extent what Personal Information You wish to provide to Us. If You do not want Your Health Plan to provide Personal Information to Zelis, You must make a request to Your Health Plan.
2. Other Information
In addition to the Personal Information, We may collect and/or receive additional Information (collectively, the “Other Information”). Such Other Information may include:
a. From Your Activity. Zelis also collects personally identifiable server-log information relating to its Users. This information may include, but is not limited to, (i) Your Platform Account activity, including storage usage, number of log-ins, data displayed or selected, including User interface elements, links, etc; (ii) Your web or mobile application request, Internet Protocol address (“IP address”), the location of Your computer (through the IP address), browser type, browser language, browser programming language, computer or mobile device type, the date and time of Your request, date and time of access, and one or more cookies that may uniquely identify Your browser and referrer Uniform Resource Locator (“URL”)..
b. From Cookies and Tracking Technologies. We and Our third-party partners and providers may use cookies and other tracking technologies to automatically collect certain types of usage information when You visit or interact with the Platform. You may choose not to allow some types of cookies. When You visit the Platform, We send to Your computer and/or Your mobile device (such as a smartphone), one or more cookies and other tracking technologies, which are small files containing a string of characters. A cookie among other things, uniquely identifies Your browser or Your mobile device, as applicable, and allows Zelis to “remember” Your mobile device and/or Your activities on the Platform. We use cookies to improve the quality of the Products and Services. Most browsers and mobile devices are initially set up to accept cookies but You can reset Your browser or the settings on Your mobile device to reject all cookies. Some browsers also can be set to indicate when a cookie is being sent. Please note that some features of Our Platform may not function properly, if Your computer or mobile device is set to reject all cookies. A tracking technology is a mechanism allowing the website to monitor and measure User behavior and interest for multiple purposes.
HOW WE USE AND SHARE THE INFORMATION
Zelis only uses Platform Information for the purposes and in the manner described in this Privacy Policy. Specifically, You explicitly consent to Zelis use of Platform Information for:
You also authorize Us to use and/or share Platform Information as described below:
We may share Platform Information with employees, contractors and agents of Zelis who need to know such Platform Information for performing their duties with respect to the purposes set forth in this section. These individuals and/ or entities are bound by confidentiality obligations similar to those set forth herein.
We may disclose Your Registration Information to certain third parties in connection with the various programs, tools and services that are provided through the Platform.
We may employ third parties to perform services on Our behalf. Examples may include services to improve Our Platform, storing data, marketing, tracking technologies, advertising, compliance and promotional efforts and to facilitate transactions. These third parties will have access to Your Information only as necessary to perform their services, and they may not use Your Information for any other purpose.
We may share some or all of Your Information with any of Our parent companies, subsidiaries, joint ventures, or other companies under common control with Us.
As We develop Our businesses, We might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
We may disclose Your Information, including Personal Information, to government authorities, and to other third parties when compelled to do so by government authorities, at Our discretion, or otherwise as required by law, including but not limited to in response to court orders and subpoenas. We also may disclose Your Information when We have reason to believe that someone is or may be causing injury to or interference with Our rights or property, other Users of the Platform, or anyone else that could be harmed by such activities.
Aggregated Non-Personal Information
We may disclose Aggregated Non-Personal Information to third parties, including third-party content providers, paid advertisers and licensees of the Products and Services without prior notice to You. For the purposes of this Privacy Policy, “Aggregated Non-Personal Information” is information about some or all of the Users of the Products and Services, but unlike Personal Information, does not reflect or reference an individually identifiable User. Aggregated Non- Personal Information may be formed from Platform Information, but any of the Personal Information used to form the Aggregated Non-Personal Information has been processed to no longer reflect or reference an individually identifiable User.
EXTERNAL LINKS
This Privacy Policy only applies to the Platform and the Products and Services made available through the Platform. This Privacy Policy does not apply to any other websites or mobile applications, including those that may link to or from any part of the Platform or those from which You may be able to download or launch the Platform. (collectively, the “External Sites”). Zelis does not endorse and is not responsible for the maintenance or content of any linked External Sites. These External Sites may have their own privacy policies and terms of use, which We encourage You to read. You should contact these External Sites directly if You have any questions about their use of Your information. Zelis is not responsible for any use of Your information, including Your Personal Information, when You use or visit such third party websites, mobile applications and services.
INFORMATION SECURITY
We take reasonable and appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of Your Information, including Personal Information stored or maintained on Our servers and other systems. These measures include internal reviews of Zelis’ data collection, storage and processing practices and security measures, as well as physical security measures to guard against unauthorized access to servers and systems where Zelis stores personal data.
However, no method of transmission over the internet or method of electronic storage is 100% secure. Therefore, We cannot guaranty the security of Your Information, including Personal Information.
DATA INTEGRITY
Zelis processes Personal Information only for the purposes for which it was collected and in accordance with this Privacy Policy. Zelis though, must depend on You and Our other Users to provide, accurate, complete and current Personal Information and to update or correct their Personal Information whenever necessary. Zelis does not and cannot monitor or pre-screen the Personal Information that You provide for accuracy and completeness but takes reasonable steps to ensure that We accurately process and maintain the Personal Information that You provide.
ACCESSING AND UPDATING PERSONAL INFORMATION
Information You Provide When Registering For a Platform Account
You may change or update the e-mail address and password that You provided when You registered for Your Platform Account via the “settings” or “account settings” section of such account. You may terminate Your Platform Account by sending an e-mail with Your account termination request to legal@zelis.com .
Information You Store or Access When Using the Platform
When You use the Platform, We make good faith efforts to provide You with access to Your Personal Information. You may organize or delete or change certain of the information that is entered or uploaded into Your Platform Account via the section of Your account where the information is located. Where applicable, We ask individual Users to identify themselves and the information requested to be accessed, corrected or removed before processing such requests, and We may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes), or for which access is not otherwise required. In any case, where We provide information access and correction, We provide this service free of charge, except if doing so would require a disproportionate effort. If You have any questions or want more information about accessing or updating Your Personal Information, please contact Zelis by e-mail to legal@zelis.com.
All deletions, changes or updates that You make to Your Personal Information and account termination requests will take effect after We receive and process Your e-mail termination request. Except for deleted information that was stored exclusively on Your mobile device, residual copies of the deleted information, may remain in perpetuity in backup systems.
Deleting the App from Your mobile device will not terminate Your Platform Account but will delete any information that You stored through the App by means of taking a photograph with Your mobile device (“Stored Photographic Information”). Terminating Platform Account will not delete Stored Photographic Information unless You also delete the App from Your mobile device.
Please note though that according to the Terms of Use, Your Submissions to the Platform should not include any “personally identifiable information (other than the name of the Healthcare Providers being reviewed).” This Privacy Policy does not apply to any Personal Information that You may nevertheless include in Your Submissions and You may not be able to change or update any such Personal Information included in Your Submissions.
CHILDREN
We do not knowingly collect Personal Information from children under the age of 13 through the Platform. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce Our Privacy Policy by instructing their children to never provide Personal Information through any website without their permission. If You have reason to believe that a child under the age of 13 has provided Personal Information to Us, please contact Us, and We will endeavor to delete that information from Our databases.
ENFORCEMENT
Please direct any questions or concerns regarding this Privacy Policy or Zelis’ treatment of Personal Information by contacting Us at the following address
Zelis
Attn: General Counsel
340 Mount Kemble Avenue Suite 200
Morristown, New Jersey 07960
Email address legal@zelis.com
When Zelis receives formal written complaints at this address, its policy is to contact the complaining User regarding his or her concerns. Zelis will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Information that cannot be resolved between an individual and Zelis.
IMPORTANT NOTICE TO NON-U.S. RESIDENTS
The Platform is operated in the United States. If You are located outside of the United States, please be aware that any information You provide to Us will be transferred to the United States. By providing Us with any information through the Platform, You consent to this transfer and Our use of such information in accordance with this Privacy Policy
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