- What Personal Information Do We Collect?
When you register for the Service, we collect certain personal information submitted to us by you, your PCP, and your health plan, including: your name, date of birth, and other data related to your personal identification; your health conditions and status, scheduled and completed health care services; medical orders given by your PCP or related medical providers; medical care plan requirements (“CPRs”), including your confirmations of understanding of CPRs, need for clarification of CPRs, and validation of completed CPRs. Additionally, at times, we may collect your feedback concerning your satisfaction with the Service and participating PCPs.
Some of the information that you, your health plan, or your PCP submit to wellPORTAL, such as, without limitation, information about your specific care plan, may constitute Protected Health Information (“PHI”) protected by the Health Information Portability and Accountability Act (“HIPAA”). For your own security and privacy, you should not submit to wellPORTAL any PHI that is not necessary for us to receive in order to provide the Service to you.
- How Do We Use the Personal Information We Collect?
We use the personal information we collect for the following purposes:
- To provide the Service to you. For example, we may use your personal information as follows:
- To help you schedule PCP appointments.
- To help coordinate your health care.
- To help facilitate access to health care services.
- To send you notifications and reminders of care plan requirements (CPRs) and then notify your PCP when you need clarifications of CPRs or report completed CPRs.
- To respond to your requests for customer service support from your PCP or your health plan.
- To provide information to your health plan. For example, we may use your personal information to report the completion of CPRs to facilitate your eligibility for enhanced benefits, financial incentives, and/or other rewards that may be available to you from your Health Plan.
- To improve the Service. In particular, we analyze the technical data we collect about the use of the Service to understand how users are using the Service and to improve it.
- To create aggregate-level data that we may publish in reports and marketing materials about the Service (“Aggregated Data”). Aggregated Data does not identify any individual user or user’s personal information. An example of Aggregated Data would be a finding that indicates, “85% of eligible wellPORTAL users completed a given CPR, such as a Colon Cancer Screening.
- When Do We Disclose Your Personal Information?
We do not disclose the personal information we collect about you to any third party without your permission, other than under the following circumstances (as allowed under HIPAA):
- To facilitate and support the operations of your PCP and your health plan, to support payments for health care services, and to facilitate health care treatment.
- When you submit requests to us for support and services from your PCP or health plan, including but not limited to PCP appointment scheduling, care coordination, care navigation, and general customer service support, we may disclose your personal information to your PCP, health plan, and other health care providers to fulfill your request.
- When you submit responses to care plan requirement notifications provided by the Service, wellPORTAL may use your responses to help clarify your understanding of care plan requirements and validate compliance with the same so that you may earn financial incentives from your health plan.
- When you submit responses to patient satisfaction surveys provided by wellPORTAL, we may use that data to assess the overall performance of wellPORTAL’s participating PCPs.
- When you submit information such as, without limitation, membership identification number, date of birth, log-in and/or password, wellPORTAL may use that data strictly for the purpose of authenticating your identity and granting you access to the Service.
- We may disclose personal information to wellPORTAL service providers and affiliated companies to the extent reasonably necessary to provide the Service to you. For example, if you request support from wellPORTAL for a technical problem with your use of the Service, your support call may be handled by a wellPORTAL-affiliated company that will have access to your information, as necessary, to help you. Any service providers or affiliates who receive personal information have agreed in writing to keep the information confidential and to use it only to provide services to wellPORTAL.
- We reserve the right to disclose your personal information if compelled to do so by court order or otherwise required by law; or if wellPORTAL believes in good faith that such disclosure is necessary to comply with law or with legal process served on wellPORTAL, to protect the rights or property of wellPORTAL, to act in urgent circumstances to protect the personal safety of Users or the public, or in the event of a medical emergency.
- Do Not Track Disclosure
wellPORTAL does not track users’ behavior across third party applications or web pages that users access before or after using the Service, and so does not respond to a “Do Not Track” signal. No third parties may track your behavior when using the Service.
- wellPORTAL Security Standards
wellPORTAL uses reasonable industry-standard security practices designed to protect your data from loss, misuse, unauthorized access or disclosure, alteration, or destruction. To the extent your personal information constitutes PHI protected under HIPAA, wellPORTAL protects PHI in accordance with the security standards required for business associates under HIPAA. Your information may be stored and processed in the United States or any other country where wellPORTAL, its subsidiaries, affiliates, or agents are located. In all instances, wellPORTAL uses HITRUST CSF-certified cloud hosting and security vendors to ensure the safety of personal information.
As part of the service, you may receive SMS (Text), push, or email messages or notifications regarding certain products, services, and complimentary goods.
- Updating Your Personal Information
You may update and correct your telephone number, email address, or any other personal information at any time through the Service or by contacting wellPORTAL by email at Clientservices@wellportal.com or by telephone at 702-533-4353.
- Complaints or Inquiries
If you have any complaints or inquiries about our Services, including how we handle your Personal Information, you may contact our Privacy Officer:
P.O. Box 98071
Las Vegas, NV 89193
- Unsubscribing from the Service or from Marketing Messages
You may deregister from the Service anytime by contacting wellPORTAL by email at Clientservices@wellportal.com or by telephone at 702-533-4353.
13. Effective Date