Collective Health Corporate Website Privacy Policy

Updated: January 4, 2021

Introduction

Thank you for visiting Collective Health! Collective Health, its subsidiaries and affiliates, care about protecting your privacy. This Corporate Website Privacy Policy describes how we collect, use, and disclose personal information through www.collectivehealth.com (our “corporate website”).

This Policy does not apply to our member or employer facing digital products, including but not limited to, the welcome portal, the member portal, the employer portal, mobile applications, and other digital services (our “Digital Platform”). The Digital Platform services are covered by a separate Digital Platform Privacy Policy.

We may provide you access to third-party sites or applications through our services. This Policy does not apply to these third-party sites and we are not responsible for their independent privacy policies or practices. As you visit these sites, we encourage you to review their privacy policies.

Before using our corporate website, please carefully read Collective Health’s Health’s Terms of Service and this Policy. By accessing our corporate website, you agree to the Terms of Service and all provisions of this Policy.

1. Personal Information We Collect

When you interact with us through our corporate website, we may collect Personal Information about you. When we use the term “Personal Information” we mean any information that relates to you, identifies you personally, or could be used to identify you, such as your full name, address, email, or your telephone number. Below are the four categories of Personal Information that we collect about you and have collected about you in the past 12 months.

1.1 Information you provide to us

When interacting with our corporate website, you may choose to provide us with Personal Information, such as:

• Contact Information. You may choose to provide us with business contact information, such as name, e-mail, and company name to receive more information about our products and services.
• Job Applicant Information. When applying for a job through our corporate website, you may choose to provide us with Personal Information, such as your name, e-mail, phone, resume, cover letter, and links to personal profiles and websites containing Personal Information.
• Health Risk Assessment Information. We may create sites for members and the general public to assess risks related to specific diseases or conditions, such as COVID-19. If you choose to participate, you may provide us with information about your past, present, or future health conditions or treatment. Where this information is collected, we will not ask you to provide any identifying personal information and we will make no attempt to identify or link individuals based on information that is automatically collected.

You are not required to provide this information to use our corporate website; however, you may not be able to use certain features without providing the requested personal information.

1.2 Information we receive in the course of business

We may receive or deduce information about you, including Personal Information, in the ordinary course of our business. For example, this includes Personal Information you may provide when attending a conference or event or in other business interactions with Collective Health.

1.3 Information we collect from third parties

To the extent permitted by applicable law, we may receive Personal Information about you from publicly available sources, third-party service providers, and/or partners and combine it with information we have about you to provide a more personalized experience.

1.4 Information automatically collected

When you use our corporate website, we automatically collect information about the services you use and how you use them. This information is necessary to provide and improve the functionalities of our corporate website and services, and to comply with legal obligations.

• Device and Connection Information. We automatically collect certain information when you access or use our corporate website. This information includes your browser type, device information and settings, operating system information, IP address, access dates and times, and any links you clicked to navigate to our websites. Collecting this information allows us to customize your experience and content when using our websites.
• Tracking Technologies. We use cookies, web beacons, pixels, and other tracking technologies for remembering your settings and preferences and analyzing your clicks and movements on our sites in order to improve your experience with our corporate website. You can control the use of cookies through your browser.
• Usage Information. We collect information about your interactions with our corporate website, such as the content you view, the links you click, and the searches you conduct. We may also collect information about how you arrived at our corporate website, including hostnames and keywords searched.
• Geo-location. When accessing our corporate website, we may collect information about your approximate location through your IP address or your precise location through GPS, if authorized by you, to offer you an improved experience. You may control or disable the availability of GPS location services in your device or browser settings.
• Do Not Track. In conformity with the California Online Privacy Protection Act (“CalOPPA”) Do Not Track law, our corporate website currently does not respond to a “Do Not Track” signal in the HTTP header from your browser or mobile application due to lack of standardization regarding how that signal should be interpreted. In the meantime, you may use technical means to prevent some of the tracking, if any. See the technical means discussed in the section “Your Advertising Choices.”

2. How We Use the Personal Information We Collect

Your Personal Information is used for the following purposes:

2.1 Provide and improve our corporate websites

We may use your Personal Information to deliver and improve your experience with our corporate website, such as:

• Enable you to sign up to receive information about our products and services;
• Enable you to apply for jobs through our corporate website;
• Provide you with website content;
• Personalize your experience with our website; and
• Conduct research and analysis to improve our website.

2.2 Provide you with information you requested

We may use information collected through our websites and third-parties to communicate with you about our products and services. You will always have the option to opt out of these communications.

2.3 Comply with legal requirements and provide a safe environment

We use certain information collected through your use of our websites for the purposes of protecting your data and our platform, and for complying with legal obligations, such as:

• Prevent and detect harmful activity including security incidents, spam, fraud, and abuse;
• Investigate suspected security incidents;
• Comply with legal obligations;
• Enforce this Policy, our Terms of Service, and any other terms you have agreed to; and
• Resolve any disputes and enforce our agreements with third parties.

2.4 Provide, measure, and improve our advertising and marketing

We may use your Personal Information for legitimate business purposes, including providing you with information about our products and services that may be of interest to you, such as:

• Sending promotional messages and marketing communications that may interest you. You will always have the option to unsubscribe from these communications.
• Providing, personalizing, measuring, and improving our advertising, including advertising through external websites and social media platforms.

If, in the future, we use your Personal Information in any way that is not described in this Policy, we will disclose this to you.

3. Sharing Your Information

We may share the Personal Information provided by you or collected by us through the use of our corporate website to service providers for legitimate business purposes. We have not and will not sell your Personal Information to third parties without your consent. Additionally, consistent with the California Shine the Light Law and other applicable laws, we will not share or sell your data to third parties for such third parties’ direct marketing purposes without your consent.

3.1 Sharing with Third-Party Service Providers

Collective Health uses third-party service providers to help us provide and improve our corporate websites and services. We may share the Personal Information you provide to us or that we collect from you through our corporate website to these third-party service providers. When we do so, we will only provide the information necessary for the third-party to perform its agreed upon services and require that they use such information for no other purpose than to provide the services to us.

3.2 Sharing with Company Affiliates

We may share the Personal Information you provided to us or that was collected by us with our affiliated companies or subsidiaries for purposes of providing services to you. Consistent with the California Shine the Light Law and other applicable laws, we will never share or sell your Personal Information to affiliated companies or subsidiaries for direct marketing purposes without your explicit consent.

3.3 Sharing for Business Transactions

If Collective Health is involved in any merger, acquisition, sale of assets, bankruptcy, or insolvency event, we may sell or transfer some or all of our assets, including some or all of your Personal Information in connection with such transaction. We will notify you before your personal information becomes subject to a different privacy policy.

3.4 Sharing for Legal and Compliance Purposes

We may share Personal Information collected through the use of our corporate website to respond to valid legal processes (e.g., a court order or subpoena). We may also share your information to comply with applicable laws, to protect the safety of any person, to address fraud, security, or technical issues, or to enforce this Policy, Terms of Service, and any other terms or conditions you have agreed to with us.

4. Your California Privacy Rights

This section applies only to California residents and provides additional details about the Personal Information we collect about California consumers and the rights afforded to them under the California Consumer Privacy Act of 2018 (the “CCPA”).

For more details about the Personal Information we have collected over the last 12 months, including the categories of sources, please see Section 1 – ‘Personal Information We Collect’ above. We collect this information for the business and commercial purposes described in Section 2 – ‘How We Use the Personal Information’ above. We share this information with the categories of third parties described in Section 3 – ‘How We Share Your Personal Information’ above. We do not sell the Personal Information we collect and we will not sell your Personal Information without your consent.

4.1 Your Rights Under the CCPA

If you are a California resident, you have rights in relation to your Personal Information; however, your rights are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of Personal Information or the security of our systems. Additionally, we will only be able to act on your requests if we can verify your identity against the Personal Information we have collected about you. Below are the specific rights provided to you by the CCPA:

• Right to Know. You have the right to request, in writing, (a) the categories of Personal Information we have collected about you, (b) the business or commercial purposes for the collection, (c) the categories of third parties with which we have shared your Personal Information, and (d) the specific pieces of Personal Information we have collected about you.
• Right to Delete. You have the right to request that we delete any Personal Information we have collected from you or maintain about you, subject to certain exceptions.
• Right to Non-Discrimination. You have the right not to be discriminated against for exercising any of the rights described in this section. We will not discriminate against you for exercising any of the rights described in this section.

4.2 Exercising Your Rights

You may exercise your rights described in this section by sending an e-mail to privacy@collectivehealth.com. To verify your identity, we may request additional information from you, which we will only use to verify your identity, and for security or fraud-prevention purposes.

5. Your Advertising Choices

Your behavior patterns and interactions with our corporate website may be used by us or by third-party advertisers to surface relevant content to you. To do so, our advertising service providers either place or recognize a unique cookie on your browser. They may also use other techniques such as pixel tags to determine the content you view and surface relevant advertisements on their websites. If you would like more information about these practices and to learn about your choices, please visit the Digital Advertising Alliance or the Network Advertising Initiative. Your behavior patterns and interactions with any of our health risk assessment websites will not be used by Collective Health or by third-party advertisers to surface relevant content to you.

You may control interest-based advertising as explained below. Please note that opting out of receiving interest-based advertising does not result in blocking all advertisements served to you. You will continue receiving advertisements; these advertisements will be generic or based on the content of a webpage that you are visiting, instead of being targeted to your specific interests.

• To Control Advertising on Websites. If you want to limit the amount of interest-based advertising you receive through websites, you may opt-out of certain forms of tracking. Please note that you will continue receiving advertising on third-party sites, but this advertising will not be based on your activities on our site. You can opt-out of certain forms of tracking by visiting Digital Advertising Alliance WebChoices or the Network Advertising Initiative Opt Out.
• To Control Advertising on Mobile Applications. If you want to limit the amount of interest-based advertising you receive through mobile applications, you may opt-out of certain forms of tracking. You can learn more about ad choices for mobile devices by visiting the Digital Advertising Alliance AppChoices Digital Advertising Alliance AppChoices and downloading the AppChoices mobile application.
  To immediately end all targeting on a mobile device, you can also limit ad tracking in the device settings. For instructions on how to limit ad tracking on your mobile device, please visit Apple Support or Android Support.
• To Control Information Collected and Used by Google Analytics. We use Google Analytics to analyze our corporate website traffic and interactions. For more information on how Google uses this information, please refer to How Google Uses Data When You Use Our Partners’ Sites or Apps. Information collected by the Google Analytics cookie is transmitted to and stored by Google in accordance with its privacy practices. To opt out of Google Analytics, please visit Google Analytics Opt Out.

6. Information Security

Although we are serious about protecting the security of your Personal Information and have taken steps to protect your Personal Information from loss, misuse, unauthorized access, disclosure, or destruction, no security measures are completely secure and we do not and cannot guarantee the security of your information. If you have reason to believe that your information has been lost, stolen, or otherwise compromised from our sites, please contact us immediately via trust@collectivehealth.com.

7. Changes to this Corporate Website Privacy Policy

Collective Health may change this Policy as needed to accurately reflect our information collection, use, and sharing practices. If we make changes to this Policy, the revised policy will be posted on this site with the last effective date. The effective date of the Policy is the date indicated at the top of the Policy. Your continued use of the corporate website after the effective date signifies your acceptance of the revised Policy. It is therefore important that you review this Policy regularly to ensure you are updated on any changes.

8. Children

Our corporate website is directed toward adults and are not designed for, intended to attract, or directed toward children under the age of 16. If you are under the age of 16, you must obtain the authorization of a responsible adult (parent or legal guardian) before using or accessing our corporate website. If we become aware that we have collected any Personal Information from children under 16, we will promptly remove such information from our databases. If you learn that your child has used our corporate website to provide us with their personal information without your consent, please e-mail us at privacy@collectivehealth.com.

9. Contact Us

If you have any questions or comments about this Policy, please e-mail us at privacy@collectivehealth.com or send us a letter at:

Collective Health
Attn: Privacy Officer
85 Bluxome St.
San Francisco, CA 94107