Effective as of January 1, 2021
- 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.
(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).
- 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.
(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.
- 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.
- 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.
- 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.
- 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 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.
- HOW TO CONTACT US