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HRAgo® Privacy Policy

PRIVACY POLICY

Effective as of January 1, 2021

 

This privacy policy (the “Privacy Policy”) applies to the HRAGo® mobile application (the “App”), owned and operated by Empire Innovation Group, LLC (d/b/a “OneBridge Benefits”) (“OneBridge,” “we,” “us,” or “our”) solely for the purpose proving you with a mobile device interface with one or more of your employer’s benefit plans. We have created this Privacy Policy to tell you what information the App collects, how we use that information, and who we will share that information with, if at all. This Privacy Policy does not address the privacy practices of any third parties that we do not own, control, or are affiliated with. By visiting and/or using our App, you are agreeing to the terms of this Privacy Policy. We encourage you to read the Privacy Policy, and to use the information it contains to help you make informed decisions.

  1. INFORMATION WE COLLECT OR RECEIVE

In the course of operating the App, we will collect and/or receive the following types of information. You authorize us to collect and/or receive such information.

(a) Personal and Protected Health Information. We only receive or collect information that identifies you personally if you choose to provide such personally identifiable information to us via email, the app, our participant portal, or other means. When you sign up to become a user or contact us, you will be required to provide us with personal information about yourself (collectively, the “Personal Information”). Such Personal Information may include your name, e-mail address, physical address, and phone number. If you use the app to file claims for health benefits under your employer’s benefit plan, you will likely provide us with information that may be considered protected health information, which we will collect and use to process your claim and to retain records of your claim and reimbursement for your future reference. We do not collect any Personal Information or Protected Health Information from you when you use the App unless you provide us with the Personal Information voluntarily.

(b) Direct Deposit Information. If you elect to receive payment for your health benefits by direct deposit, you will be required to provide us with your banking information, including, without limitation, bank account numbers, account details, ACH information, and similar data (collectively, “Direct Deposit Information”). Such Direct Deposit Information will be collected, stored, and used by your benefit plan provider and any applicable banking custodian to make reimbursements of plan benefits by direct deposit and maybe subject to additional terms and conditions, privacy policies, and terms of use of these third parties. You may change or remove your Direct Deposit Information at any time.

(c) Third-Party Analytics. We and the third-party technology providers with which we work use third-party analytics services (e.g., Google Analytics) to evaluate your use of the App, compile reports on activity, analyze performance metrics, and collect and evaluate other information relating to the App and mobile and Internet usage. None of these reports, analyses, or information identifies you personally. You consent to the processing of data about you by these analytics providers in the manner and for the purposes set out in this Privacy Policy. 

(d) Other Information. In addition to the Personal Information and Direct Deposit Information, we may automatically collect or receive additional information regarding you and your use of the App; your interactions with us; and information regarding your computer and mobile devices used to access the App (collectively, the “Other Information”). Such Other Information may include:

(i) From You. Additional information about yourself that you voluntarily provide to us, such as your gender and your product and service preferences.

(ii) From Your Activity. We may collect or receive information regarding:

(a) IP address, which may consist of a static or dynamic IP address and will sometimes point to a specific identifiable computer or mobile device;

(c) date and time; and

(c) details regarding your activity on the App, such as search queries and other performance and usage data.

(iii) About Your Mobile Device. We may collect or receive information regarding:

(A) type of mobile device;

(B) operating system and version (e.g., iOS, Android, or Windows); and

(C) network type (Wi-Fi, 3G, 4G, LTE, 5G).

  1. HOW INFORMATION IS USED AND SHARED

(a) You authorize us to use the Personal Information, Direct Deposit Information, and the Other Information (collectively, the “Information”) to:

(i) provide and improve our App;

(ii) provide our services; and

(iii) to monitor and improve the security of our App.

(b) We engage third-party companies and individuals to perform functions on our behalf. Examples may include providing technical assistance, and customer service. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.

(d) In an ongoing effort to better understand our users, the App, and our products and services, we may analyze certain Information in anonymized and aggregate form to operate, maintain, manage, and improve the App and/or such products and services. This aggregate information does not identify you personally. We may also disclose aggregated user statistics that do not identify you personally to describe the App and these products and services to current and prospective business partners and investors and to other third parties for other lawful purposes.

(e) 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 but only for the same purposes described in this Privacy Policy.

(f) 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.

(g) To the extent permitted by law, we may also disclose the Information:

(i) when required by law, court order, or other government or law enforcement authority or regulatory agency; or

(ii) whenever we believe that disclosing such Information is necessary or advisable, for example, to protect the rights, property, or safety of us or others, including you.

  1. ACCESSING AND MODIFYING INFORMATION AND COMMUNICATION PREFERENCES

If you have provided us any Personal Information, you may access, remove, review, and/or make changes to the same as described in your employer’s benefit plan materials. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our databases. You cannot opt out of receiving transactional e-mails related to the App (e.g., confirming account changes).

We may also deliver notifications to your mobile device (e.g., push notifications). You can disable these notifications by deleting the relevant service or by changing the settings on your mobile device.

  1. HOW WE PROTECT YOUR INFORMATION

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases or the databases of the third parties with which we may share such Information, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. In particular, e-mail sent to us may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

  1. IMPORTANT NOTICES TO NON-U.S. RESIDENTS

The App and its servers are operated in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the App, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere.

  1. APP STORES; EXTERNAL WEBSITES

Your app store (e.g., iTunes or Google Play) may collect certain information that does not identify you personally in connection with your use of the App, such as usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

The App may contain links to third-party websites. We have no control over the privacy practices or the content of these websites. As such, we are not responsible for the content or the privacy policies of those third-party websites. You should check the applicable third-party privacy policy and terms of use when visiting any other websites.

  1. CHILDREN

The App is not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not use the App. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records.

  1. CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Any such changes will be posted on the App. By accessing the App after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis.

  1. HOW TO CONTACT US

If you have questions about this Privacy Policy, please call the customer care center number listed in your benefit plan materials or mail us at the following address: OneBridge Benefits, 170 Franklin Street, Suite 700, Buffalo, NY 14202.