As used in this Policy, terms such as "we," "us," "our," and "Company" refer to current and future affiliated entities, subsidiaries, agents, contractors, or vendors of Optum Perks LLC. Our Online Services operate on computer servers in the United States; therefore, any Information you provide will be transferred to and processed by a computer server located within the United States.
- What Information We Collect About You
- How We Use Your Information
- How We Share Your Information
- How to Manage Your Information
- Protecting Your Information
- Children Under 13
- Additional Rights for California Residents
- Social Media Disclaimer
- Social Security Number Protection Policy
- Changes to This Policy
- Contact Us
- California Consumer Privacy Act Notice
Our Policy does not apply to the practices of other companies or other websites or software applications that may be linked from or made available through our Online Services.
Some of our products and services are regulated by certain state and federal laws, including the Health Insurance Portability and Accountability Act ("HIPAA") and the Gramm-Leach-Bliley Act and may have specific privacy practices ("Product Privacy Notices") such as a HIPAA Notice of Privacy Practices or other specific privacy practices that we want you to be aware. When a Product Privacy Notice exists, the content of the Product Privacy Notice applies to your use of the product and service.
What Information We Collect About You
We may collect two basic types of information (collectively, “Information”) through the Online Services: (1) information you provide directly to us, and (2) information that is automatically provided to us or collected through your use of our Online Services.
When you use the Online Services, you may provide certain Information directly to us. For example, you may input a telephone number or email address into a webform or enter information into a chat functionality. We also may make certain information available to you on the Online Services that we collect from other sources. For example, we may pre-populate certain demographic information in an online form or make health or medical information viewable on the Online Services that you have provided to us on paper forms or maintained in other information systems.
We also may obtain Information that is automatically collected through the Online Services. The automatically collected Information may include demographic, de-identified, aggregated, or certain information from your device such as technical information about your device, web-browser information, and server log files collected by us or provided by you. See Cookies and Tracking for more information on automatically collected information.
You may limit the Information you provide or make available to us if you want to; however, that may limit your ability to access or use certain functions of the Online Services or to request certain services or information.
In addition to the Information identified above, our mobile applications also collect the following Information:
Information that Identifies You
- Health, medical, or therapy information
- Location data such as GPS, Wi-Fi, or carrier network location (see below for more details)
What You Do on Your Device
- Phone dialer
- Use of screen, e.g., what points are touched, frequency, etc.
- Patterns of app usage
Device or System Data
- Mobile Device Identifier, e.g., UDID, Android ID
- Technical information about your device and system and application software, e.g., type of phone, Operating System (OS), and IP address
We may obtain location data from your device to provide location-related services (e.g., driving directions or distance calculation, via the mobile application). You may withdraw consent to use precise, real-time, or network location data at any time by turning off the location-based feature on your mobile device or by not using any location-based features. If you withdraw your consent, functionality associated with precise, real-time, or network location (e.g., navigation) will no longer work.
How We Use Your Information
We may use your Information:
- To respond to an email, chat or other instant message or particular request from you.
- To communicate with you.
- To provide you with content, services, and functionality through our Online Services or other services that we may offer.
- To process an application for a product or service as requested by you.
- To authenticate you on any portion of our Online Services and with vendors acting on our behalf.
- To administer surveys and promotions.
- To personalize your experience on our Online Services.
- To provide you with informational or promotional offers, as permitted by law, that we believe may be useful to you, such as information about products or services provided by us or other businesses.
- To perform analytics and to improve our products, Online Services, and advertising.
- To facilitate the provision of software updates and product support.
- To improve products and other services related to the Online Services or to provide services or technologies to you.
- To comply with applicable laws, regulations, and legal process.
- To protect someone's health, safety, or welfare.
- To keep a record of our transactions and communications.
- As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law or for any other purpose with your consent.
We may use Information to contact you through any contact information you provide through our Online Services, including any email address, telephone number, cell phone number, or fax number. We may communicate, electronically or via telephone with you about your benefit plan, programs, products, or services that are or may be available to you in connection with your transactions with us including, but not limited to, Online Services updates, general wellness reminders or information, prescription reminders, appointment reminders, general health information, newsletters, and surveys. These electronic communications may contain protected health information. You acknowledge and accept that such communications may be sent unencrypted and there is some risk of disclosure or interception of the contents of these communications.
We may, when permitted, combine your Information with other information, whether online or offline, maintained or available to us from you or from other sources, such as from our vendors, and we may use and disclose combined data for the purpose described in this Section or for internal business purposes. We may, when permitted, use and disclose de-identified and aggregated data for any purpose, which may include, without limitation, disclosures to third parties for analytics purposes such as evaluating the Online Services and providing additional benefits, programs, and services.
How We Share Your Information
We will only share your Information with third parties as outlined in this Policy and as otherwise permitted by law or as permitted with your consent.
We may share Information if all or part of the Company is sold, merged, dissolved, acquired, or disbanded to any extent in a similar transaction, or in connection with steps that may need to be taken in anticipation of such events.
We may share Information in response to a court order, subpoena, search warrant, or to comply with law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting activities that are illegal, violate our rules, or may be harmful to other visitors.
We may also share Information within the Company, including among affiliates, or with our parent company, or subsidiaries.
We may also share Information with other third-party companies with which we have a business relationship or hire to perform services on our behalf. For example, we may hire a third-party company to help us send and manage email, and we might provide that third-party company with your email address and certain other Information for them to send you an email message on our behalf. Similarly, we may hire third-party companies to host or operate some of our Online Services and related computers and software applications.
How to Manage Your Information
Our Online Services may permit you to view your profile, if applicable, and access related Information about you and to request changes to such Information. Please remember, however, if we have already disclosed some of this Information to third parties, we may not have access to that disclosed information and may not be able to force the modification of any Information by the third parties to whom we have made those disclosures.
Communication Preference Management
Our Online Services may permit you to select how you would like to receive certain communications.
We may offer mobile applications that enable us to communicate with you through push notifications. Where mobile applications are offered, you may be able to manage push notifications in your mobile phone or tablet settings. You may also be able to control preview settings in your email applications.
If you need additional assistance in opting-out of a communication, please Contact Us for assistance. Please be aware that opt-outs may not apply to certain types of communications, such as account status, Online Service updates, or other communications.
Cookies and Tracking
The Company may use various technologies, including cookies, tokens, tags, web logs, web beacons, scripts, and web server logs to gather automatically collected information and may aggregate this information from visitors of our Online Services or to enable certain features of our Online Services. This information may include demographic data, technical information about the technology (e.g., phone, computer) you use to connect to the Online Services, web browser information, your IP address, and browsing behavior such as pages visited and how often they are visited (collectively, "Activity Information"). We may also use third-party analytics companies to provide these services.
Activity Information is captured using various technologies and may include cookies. "Cookies" are small text files that may be placed on your computer or mobile device when you visit an Online Service or click on a URL using your web browser. Cookies may include "single-session cookies" which generally record information during only a single visit to a website and then are erased, and "persistent" cookies which are generally stored on a computer or mobile device unless or until they are deleted or are set to expire. You may disable cookies and similar items by adjusting your browser preferences at any time; however, this may limit your ability to take advantage of all the features on our Online Services. In addition, you may also have additional means to manage the collection of Activity Information by:
- Managing the use of "flash" technologies, with the Flash management tools available at Adobe's website;
- Visiting Google Analytics to "Opt-Out" of certain data aggregation and analysis;
- Clicking on the "Opt-Out" link at the bottom of the home web page, if applicable; and/or
- Visiting Google to "Opt-Out" of display advertising or customize Google display network ads.
Please note that we do not currently respond to web browser "Do Not Track" signals that provide a method to opt out of the collection of Information about online activities over time and across third-party websites or online services because, among other reasons, there is no common definition of such signals and no industry-accepted standards for how such signals should be interpreted.
We gather Activity Information about you to improve the quality of our services, such as the best method and time to contact you. Without limiting the other ways in which we may use Information as described herein, we may otherwise use and disclose your Activity Information unless restricted by this Policy or by law. Some examples of the ways we use your Activity Information include:
- Customizing your experiences, including managing and recording your preferences;
- Authenticating your account information;
- Marketing, product development, and research purposes;
- Tracking resources and data accessed on the Online Services;
- Developing reports regarding Online Service usage, activity, and statistics;
- Assisting users experiencing problems with our services;
- Updating and servicing our Online Services;
- Enabling certain functions and tools on the Online Services; and
- Tracking paths of visitors to the Online Services and within the Online Services.
As described above, we may use tracking technologies that allow us to recognize your device when you return to our Online Services within a period of time, as determined by us, and to support automatic login to your Online Services. To maintain your privacy, you should affirmatively log out of your account prior to your session ending (whether you end your session or we end your session, for example if our Online Services has "timed out" - i.e., we have ended your session automatically after a period of inactivity as determined by us in our sole discretion). Unless you affirmatively log out of your account, you may be automatically logged back in the next time you or any user of your devices visits the Online Services.
Protecting Your Information
We maintain administrative, technical, and physical safeguards designed to protect the Information that you provide on our Online Services. These safeguards vary based on the sensitivity of the Information that is being collected, used, and stored. We cannot guarantee the security of our Online Services, nor can we guarantee the security of the Information you transmit to us over the Internet, including your use of email. We are not liable for the illegal acts of third parties such as criminal hackers.
It is your responsibility to safeguard the devices you use to access our Online Services (such as laptops, tablets and mobile devices), and to use appropriate security settings on those devices. If those devices are lost, stolen or misplaced, others may be able to access your account and your personal Information using those devices. You should affirmatively log out of your account (i) prior to ending your session, or (ii) if you will be inactive on the Online Services for more than a few minutes; otherwise, the next user of that computer or device, particularly a public one or one not owned by you, may be able to access your account and the Information in your account if your session has not ended.
You agree that we are not responsible for any harm that may result from someone accessing your account or personal Information on any computer or device where you do not, for any reason, take the necessary steps to log out of your account prior to ending a session on such device or computer.
We retain Information for as long as necessary for the purpose for which it is collected, subject to a longer period if the Information is relevant to a legal challenge.
Children Under 13
We will not intentionally collect any personal information (as that term is defined in the Children's Online Privacy Protection Act) from children under the age of 13 through our Online Services without receiving parental consent. If you think that we have collected such personal information from a child under the age of 13 through our Online Services, please Contact Us immediately.
Additional Rights for California Residents
California “Shine the Light” Privacy Rights
California law permits our customers who are California residents to request certain information regarding the disclosure of certain personal information to third parties for their direct marketing purposes.
If we have disclosed any personal information to third parties for direct marketing purposes, we will provide a list of the categories of personal information, along with the names and addresses of these third parties to you at your request. To make such a request, write us at the postal or email address found in the Contact Us section of this Policy.
This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the specified email or postal address. You should put "California Privacy Rights-Direct Marketing" in the email subject line and in the body of your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.
California Minors Under 18
If you are a California resident under the age of 18 and are a registered user of our Online Services, you may request that we remove from our Online Services any content you post to our Online Services that can be accessed by any other user (whether registered or not). Please note that any content that is removed from visibility on our Online Services may still remain on our servers and in our systems. To request removal of content under this provision, please write or email us at the postal or email address found in the Contact Us section of this Policy. When you write to us, please provide us with a description of the content and the location of the content on our Online Services, along with any other information that we may require to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Online Services by you.
Social Media Disclaimer
Are you using social media? So are we! We encourage you to read, share, follow us and provide commentary on Facebook®, Twitter®, Pinterest®, Instagram® and other social media sites ("Social Media Site"). Before you post on our pages or accounts, please make sure you read our social media disclaimer:
We are under no obligation to screen or monitor your posts or any other user content; however, we reserve the right to monitor participation to ensure that you stay on topic, are courteous and avoid making offensive comments. Your posts and user content must adhere to the following requirements and cannot:
- Contain any third-party material including logos, drawings, tattoos, photographs, pictures, sculptures, paintings and other images or works of art, phrases, trademarks, trade secrets, or other items without explicit, prior, written permission to use such materials
- Contain sexually explicit, graphic, gratuitous or unnecessarily violent content or defamatory or derogatory content against any ethnic, racial, gender, religious, sexual orientation, professional or age group, or contain any pornographic or nude material
- Contain any private information about yourself or any other individual, including without limitation, information related to the health of the individual, financial information about the individual, or any identification or account numbers related to the individual, with or without their permission or consent
- Contain any software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software, hardware, or telecommunications equipment
- Contain any advertising, promotional materials, "junk mail," "spam," "chain letters," "pyramid schemes," or promote illegal activity and/or illegal contests, sweepstakes, gambling, including any online casino, sports books, bingo, poker, or any other form of solicitation
We reserve the right to edit comments for content, remove off-topic contributions, delete offensive comments or remarks, block offensive contributors, and delete actual or suspected spam content from any Social Media Site. Please be aware that once you post something online, there is the potential for numerous individuals to read your words, even years from now. Therefore, we suggest that you exercise caution when posting on any Social Media Sites and that you not disclose Information like your location, medical record number, personal medical information, financial information, etc. We are not responsible for the content of any comments or responses posted by others to any Online Service or Social Media Site we manage or monitor. We do not control the placement of any marketing or advertising displayed on our pages by social media or third-party organizations.
Please remember that content posted on any of our social media profiles or platforms is for general informational purposes only and should not be considered medical advice and should not replace a consultation with your health care or financial professional. Always consult an appropriate health care or financial professional for your specific needs. If you are experiencing a medical emergency, call 9-1-1 or your local emergency number. Some treatments mentioned on social media formats may not be covered by your health plan. Please refer to your benefit plan documents for information about coverage.
We reserve the right to respond to any post or user content and may occasionally privately request your contact information to assist you offline, with your consent, by routing the matter to the appropriate persons or department for further handling. Any further questions about your account, claims or benefits or request for additional information can be addressed by visiting your member or patient website or calling the toll-free member phone number on your health plan or member ID.
All trademarks are the property of their respective owners.
Social Security Number Protection Policy
It is our policy to protect the confidentiality of Social Security numbers (“SSNs”) that we receive or collect in the course of business. We secure the confidentiality of SSNs through various means, including physical, technical, and administrative safeguards that are designed to protect against unauthorized access. It is our policy to limit access to SSNs to that which is lawful and to prohibit unlawful disclosure of SSNs.
Changes to This Policy
We may change this Policy at any time. If we do so, such change will appear on this page. We may also provide notice and choices to you, on the Online Services and in other appropriate locations, based on the scope and extent of changes. You may always visit this Policy to learn of any updates. Your continued access to or use of the Online Services constitutes your consent to these changes to this Policy.
Contact us regarding this Policy or related privacy practices. If you believe we or any company associated with us has misused your Information, please contact us immediately.
Please email or write to us at: email@example.com or Optum Perks LLC, PO Box 510658, Livonia, MI 48151-6658
June 30, 2021
California Consumer Privacy Act Notice
This privacy notice is for California Residents in compliance with the California Consumer Privacy Act of 2018 (CCPA). It explains what Personal Information (PI) we collect about you, where and from whom we obtain it, why we collect it, and your rights regarding it. This notice applies to any PI that we collect about you.
PI We Collect And Disclose For Business Purposes
In the preceding twelve (12) months, we may have collected the following PI about California residents and have disclosed it for business purposes described:
|Category||Examples||Collected||Categories of Third Parties We Disclose To For Business Purposes|
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, date of birth, or other similar identifiers.||Yes||Contracted Service Providers, Vendors|
|Personal information categories listed in the California Customer Records law||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||Yes||Contracted Service Providers, Vendors|
|Protected classification characteristics under California or federal law||Age (40 years or older), gender, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions)||Yes||Contracted Service Providers, Vendors|
|Commercial information||Records of personal property, products or services purchased, obtained, or considered (i.e., Optum Perks prescription drug claim data), or other purchasing or consuming histories or tendencies.||Yes||Contracted Service Providers, Vendors|
|Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|Internet and/or network activity||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||Yes||Contracted Service Providers, Vendors|
|Geolocation data||Physical location or movements||No|
|Sensory data||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|Professional or employment-related information||Current or past job history or performance evaluations.||No|
|Education information subject to the Family Educational Rights and Privacy Act||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||No|
|Inferences drawn from other personal information||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||No|
PI does not include:
- De-identified or aggregated consumer information
- Publicly available information from government records
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- PI covered by other privacy laws, including: The Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
Categories of Sources of PI
We obtain the categories of PI listed above from:
- You or your authorized agent,
- Service providers,
- Publicly available information,
- Organizations with which you are employed or affiliated, or
- Activity on our apps and websites.
The collections from these sources can occur online, in person, paper or other electronic means.
Why We Collect PI
We collect your PI for one or more of the following business purposes:
- To respond to an email or particular request from you
- To communicate with you
- To personalize services for you
- To process an application as requested by you
- To administer surveys and promotions
- To provide you with information that we believe may be useful to you, such as information about products or services provided by us or other businesses
- To perform analytics and to improve our products, websites, and advertising
- To comply with applicable laws, regulations, and legal processes
- To protect someone's health, safety, or welfare
- To protect our rights, the rights of affiliates or related third parties, or take appropriate legal action
- To keep a record of our transactions and communications
- To detect and protect against security incidents
- To debug to identify and repair errors
- As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law
In the preceding twelve (12) months, we have not sold any PI.
Third parties are not allowed to use or disclose your PI other than as specified in our contract and as permitted by law.
If we seek to use your PI for a materially different purpose than we previously disclosed in this notice, we will notify you and will not use your PI for this new purpose without your explicit consent.
- You have the right to request that we disclose certain information to you about our collection and use of your PI over the preceding twelve (12) months prior to your request. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- What PI we collect about you
- Where and from whom we collect PI about you
- Our business purpose for collecting PI about you
- The types of third parties with whom we share your PI
- The specific pieces of PI we collect about you (however, we will not disclose your actual Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers)
- The types of PI that we disclosed about you for a business purpose, and the categories of third parties to whom we disclosed your PI
- You have the right to be informed about the PI that we collect about you at or before we collect it. This is that notice.
- You have the right to request that we delete any PI about you that we have. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why.
- You will not be discriminated against or penalized for exercising your rights to your PI, and we will honor your rights by not:
- Denying you services,
- Charging you different prices or rates for services,
- Imposing penalties, or
- Providing you with a different level or quality of services.
How to Exercise Your Rights
- You can submit requests for information about your PI by calling us at 1-866-407-8901 or emailing us at firstname.lastname@example.org.
- You may be required to submit proof of your identity for these requests to be processed.
- We will not be able to comply with your request if we are unable to confirm your identity.
- You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.
- Our responses to any of your requests for the information described above will be limited to information that we have collected in the preceding twelve (12) months before our receipt of your verified request.
- You will receive our response to your request within 45 days of your request, unless we provide you with notice that it will take more than 45 days to respond (in that case, we won’t take more than 90 days to respond).
We will review this CCPA Notice annually and update it from time to time. Any changes will be posted on this page and will become effective as of the “Last Revised” date. We encourage you to review this Notice periodically to be sure you are aware of those changes.
Last Revised: December 1, 2020