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TRANSCARENT PRIVACY NOTICE

Effective: January 2, 2024

Haga clic aquí para la versión en español.

Effective Jan 2, 2024

Transcarent is the first comprehensive health and care experience company that
makes it easy to get the high-quality, affordable health and care that everyone
deserves. We do that by directly connecting consumers with high-quality care,
transparent information, and trusted guidance on their terms – in as little as
60 seconds, 24/7, from the palm of their hand.

This Privacy Notice explains how we collect, use, and share information from
users of our mobile applications, digital tools, other platform services, and
related websites (including our website at www.transcarent.com) (the “Site”)
(collectively, the “Services”). Please see our Terms of Service for more
details.




TABLE OF CONTENTS

 1. Protected Health Information

 2. Personal Information
    
    1. Categories of Personal Information We Collect
    
    2. How We Use the Information We Collect
    
    3. When We Share the Information We Collect

 3. Your Privacy Rights

 4. Other Important Information

 5. Changes to Our Privacy Notice

 6. Contact Information




PROTECTED HEALTH INFORMATION

This Policy does not govern our privacy practices with respect to individually
identifiable health information (also referred to as “Protected Health
Information” or “PHI”). Transcarent treats all information you provide as a
Member of Transcarent or a patient of our affiliated medical group as PHI that
is governed by the Health Insurance Portability and Accountability Act of 1996
(“HIPAA”). We will receive this information either directly from your health
plan, on behalf of your health plan from you, or the health care providers that
provide health care services to you.  

When you use our Services as a Member of Transcarent, your health plan’s HIPAA
Notice of Privacy Practices—and the contractual agreement we have with your
plan, known as a business associate agreement—and laws and regulations govern
our collection and use of such information. Please read the Notice of Privacy
Practices of your health plan to understand how your PHI can be used and
disclosed. 

The Notice of Privacy Practices describes how we collect, use, maintain and
share that PHI, as well as your related rights, as a patient of our affiliated
medical group. 




PERSONAL INFORMATION

Transcarent may collect, use, or share information we receive directly from you,
automatically collected when you visit our Site, and collected by Transcarent
from third parties.  

This Policy only applies to our collection, use, or disclosure of your personal
information, which comes from our Site without log-in. 



CATEGORIES OF PERSONAL INFORMATION WE COLLECT

In the past twelve (12) months, Transcarent may have collected any of the
following categories of personal information (PI) about you:

Categories of Information

Examples 

Source

Context 

Identifiers

∙Real name 

∙Alias 

∙Postal address and code 

∙Internet Protocol address  

∙E-mail address 

∙Phone number 

∙ You

∙ When you use the “Contact Us” link on the Site

∙ If you send us an inquiry using another method

∙ If you sign-up for notifications or updates

∙ When you contact our customer support team (but not as a Member)

∙ Transcarent may use an affiliated third-party vendor to help us manage some of
our voice/text messaging communications with you. While we do supply this vendor
with mobile telephone numbers of those we wish for them to contact, your mobile
telephone number is only to be used to communicate with you on our behalf for
marketing or transactional messaging. Originator opt in data will not be shared
with any non affiliated third parties.

Internet or other electronic network activity 

∙ Type of device/operating system/browser type 

∙ Page requests 

∙ Average time spent on our website 

∙ Dates and times of visit 

∙ Web page interactions 

∙ Referring webpage/source through which you access the Services 

∙ Statistics associated with the interaction between device or browser and the
Services 

∙ Email open 

∙ Third Parties

∙ We use this information to monitor and improve our website.

∙ We use this information to improve your experience, such as by serving a
version of our site appropriate for your screen dimensions.

∙ When we send you emails, we may track whether you open them to learn how to
deliver a better customer experience and improve our Services.

Geolocation data

∙ Approximate geographic location inferred from an IP address

∙ Third Parties

∙ We use this information to get a general understanding of how many people
visit our sites from which cities or regions.

∙ We may use this information to provide information that is relevant for you. 

Professional or employment-related information 

Employment (employer and job title) 

∙ You

∙ When you register for a webinar



We do not collect, use, or disclose Sensitive Personal Information from our
Site, (as defined by the California Consumer Privacy Act, or CCPA), that is not
PHI. Neither do we sell or share Sensitive Personal Information as those terms
are used in the CCPA. 

Cookies. We and third-party partners collect personal information using cookies,
pixel tags, or similar technologies when you use our Services or visit our Site.
Our third-party partners, such as analytics and advertising partners, may use
these technologies to collect information about your online activities over time
and across different services.  

 * Cookies are small text files containing a string of alphanumeric characters.
   We may use both session cookies and persistent cookies. A session cookie
   disappears after you close your browser. A persistent cookie remains after
   you close your browser and may be used by your browser on subsequent visits
   to our Services. 

 * Pixel tags, also known as “clear GIFs”, “tracer tags”, or “web beacons”, are
   technologies that allow us and our third-party partners to understand which
   pages or content you view. These pixel tags are used to help us optimize and
   tailor our Site for you and other web visitors. 

 * Your web browser’s “Help” file has information on how to modify your cookie
   settings. Please note deleting or choosing not to accept cookies may impact
   your experience with non-logged-in Services. 

Analytics Information

We may use analytics services to collect and process certain analytics data.
These services may also collect personal information about your use of other
websites, apps, and online resources. To help us understand how you use our
Services and to help us improve them, we automatically receive information about
your interactions with our Services, like the content you view, and the dates
and times of your visits.  We use Google Analytics to gather statistics from our
website and online services. Google Analytics uses a browser cookie for
statistical analysis related to your browsing behavior on our website and online
services. We also use other services of Google, like Tag Manager, to assist in
search engine optimization and advertising effectively. You can learn about
Google’s practices by going to https://www.google.com/policies/privacy/partners
and opt out of them by downloading the Google Analytics opt-out browser add-on,
available at https://tools.google.com/dlpage/gaoptout. Learn more about Google’s
privacy practices: https://policies.google.com/privacy 

HOW WE RESPOND TO DO NOT TRACK (DNT) SETTINGS.

You may choose to turn on a “do not track” (DNT) setting in your browser or use
a Global Privacy Control (GPC) setting. As there is not an industry or legal
standard for recognizing or honoring web browser “Do Not Track” signals, we do
not respond to them at this time.  

SELLING/ SHARING PERSONAL INFORMATION 

We do not “sell” your Personal Information for monetary value. But, we do use
analytic cookies that some may consider to be a “sale.”  

Transcarent uses OneTrust as our cookie consent tool. You will have the
opportunity to customize your cookie preferences, via a consent banner, when you
visit our website. You can change your choices later by either clearing your
cookies through your browser settings and revising your choice in the consent
banner or by using “Manage Cookie Preferences” to opt into certain types of
cookies. Please note that Required Cookies cannot be disabled and if you decide
to opt-out of Functional Cookies, certain functionality of our websites or your
account may be impacted. 

HOW WE USE THE INFORMATION WE COLLECT

We will use your personal information to respond to inquiries you send to us, to
fulfill your request to sign you up to our newsletter, and for other purposes
such as:  

 * To understand and analyze how you use our Site and develop new products,
   services, features, and functionality; 

 * To communicate with you, provide information that you request, respond to
   comments and questions, and otherwise provide site visitor support; 

 * For compliance purposes, including enforcing our Terms of Service or other
   legal rights, or as may be required by applicable laws and regulations or
   requested by any judicial process or governmental agency; and 

 * For other purposes for which we provide specific notice at the time the
   information is collected. 

In addition, we may use information that has been anonymized or aggregated,
without limitation.  

WHEN WE SHARE THE INFORMATION WE COLLECT

In the past twelve (12) months, Transcarent may have shared the information (PI)
we have about you with the following recipients:

Categories of recipients

Reason for sharing

Categories of Information Shared

Vendors and Service Providers

We may share any information we receive with vendors and service
providers—including our analytics partners described in the section above titled
“Analytics Information”— retained in connection with the provision of our
Services. Information is shared to the extent necessary to perform the vendors’
or service providers’ respective functions. 

∙ Identifiers

∙ Internet or similar network activity

∙ Geolocation data (such as IP address data)

∙ Professional or employment-related information

∙ Inferences drawn from other personal information

Corporate Affiliates

To support us in providing, integrating, promoting, and improving the Services,
we may share personal information within our corporate family of companies that
are related by common ownership or control.

∙ Identifiers

∙ Internet or similar network activity

∙ Geolocation data (such as IP address data)

∙ Professional or employment-related information

∙ Inferences drawn from other personal information



In addition, we may share information we have about you that is described in any
of the categories listed above in “Categories of Information We Collect” in the
following situations:

 * As required by law and similar disclosures: We may access, preserve, and
   disclose your information if we believe doing so is required to: (a) comply
   with applicable laws or law enforcement requests and legal process, such as a
   court order or subpoena; (b) respond to your requests; or (c) protect your,
   our, or others’ rights, property, or safety. We will respond to a law
   enforcement request or legal process following guidance from HHS, which
   prohibits disclosure in all but the narrowest circumstances.  

 * Merger, sale, or other asset transfers: We may transfer your information to
   service providers, advisors, potential transactional partners, or other third
   parties in connection with the consideration, negotiation, or completion of a
   corporate transaction in which we are acquired by or merged with another
   company, or we sell, liquidate, or transfer all or a portion of our assets. 

 * With your consent: We may disclose your information with your permission.




Security

We make reasonable efforts to protect your personal information by using
physical and electronic safeguards designed to improve the security of the
information we maintain. However, no electronic transmission or storage of
information can be entirely secure; no one can guarantee the absolute security
or privacy of your information. 

Retention of information

We will retain your information for the period necessary to fulfill the purposes
outlined in this Policy, to make our products and services available to you, or
as instructed by you, unless a longer retention period is required or permitted
by law.  

Children’s Privacy

We do not knowingly collect, maintain, or use, sell, or share personal
information (including sensitive personal information) from children under 16
years of age. If you learn that a child has provided us with personal
information in violation of our policy, then please alert us at
privacy@transcarent.com.  


YOUR PRIVACY RIGHTS

Transcarent has website visitors from around the world. Regardless of where you
are located, we respect your ability to know, delete, correct, and export your
information and have extended those rights globally.  

We will not discriminate or retaliate against you for exercising your privacy
rights.  

Your privacy rights only apply to your personal information. Most of the
information that we have is protected health information, regulated by HIPAA,
and you may be required to submit any privacy request through your health plan
or as a medical records request; we will let you know if that is the case. 

For your convenience, we already include the following information in this
Policy. 

 * The categories of information we collect or disclose about you. 

 * The categories of sources of such information. 

 * The business or commercial purpose for collecting your information. 

 * The categories of third parties with whom we share or disclose your
   information 

Right to Know and Access Personal Information  

You have the right to access and know what personal information we collect about
you, and how we use and disclose such personal information. 

Right to Correct Inaccurate Personal Information 

You have the right to request that we correct inaccurate personal information we
maintain about you. 

Right to Request Deletion of your Personal Information 

You have the right to request that we delete the personal information we have
about you, subject to certain limitations. If we do not delete your personal
information for reasons permitted under applicable law, we will let you know the
reason why. 

Right to Opt Out of Sale or Sharing of Personal Information  

You have the right to opt out of sale or sharing of personal information.
Information on how to do so is in the earlier section, titled Selling/Sharing
Personal Information. 

Right to Opt Out of Automated Decision-Making  

We do not use personal information for automated decision-making purposes. 

Right to Opt Out of Processing of Personal Information for Profiling or Targeted
Advertising 

We do not process personal information for targeted advertising purposes,
profiling generally, or for profiling in furtherance of decisions that produce
legal or similarly significant effects concerning a consumer as described by
Colorado 4 CCR 904-3, Rule 9.03. 

Right to Limit Processing of Sensitive Personal Information 

We do not process sensitive personal information within the meaning of CCPA. You
can learn how your PHI can be used and disclosed by reading the Notice of
Privacy Practices of your health plan, (for Members), or reading the Notice of
Privacy Practices (for patients of our affiliated medical group). 



Exercising Your Privacy Rights 

To request to exercise your privacy rights described above, please submit your
request to Privacy@Transcarent.com with the subject line “Exercising my privacy
rights”. You may also make a privacy request by calling our toll-free number
(888) 388-9151. 

Only you or an authorized agent may make a request related to your personal
information. We may ask additional questions to verify that a request is coming
from you or an authorized agent; we do this to protect your data privacy. To do
that, we need you to:

 1. provide information that allows us to reasonably verify that you are the
    person about whom we collected personal information or an authorized
    representative. For example by letting us know your name and zip code; and

 2. describe your request with sufficient detail that allows us to properly
    understand, evaluate, and respond to it.

We can only respond to your request or provide you with personal information if
we verify your identity or authority to make the request and confirm the
personal information relates to you. If we follow-up with you to ask for more
identifying details, please know this is to protect your data privacy. We will
use personal information provided in a verifiable consumer request to verify the
requestor’s identity or authority to make the request. Making a verifiable
consumer request does not require you to create an account with us. 

Because Transcarent collects both personal information and protected health
information (PHI), it can be hard to understand which rights apply to your data
in what context. If you have any questions about how any of the information
applies to you and your data with Transcarent, please contact us at
Privacy@Transcarent.com.




OTHER IMPORTANT INFORMATION

Third Parties

Our Services may contain links to other websites, products, or services that we
neither own nor operate. These links are provided solely as a convenience to you
and are not a referral or endorsement of the content of such third parties or
the entity, item, or service.  

Transcarent is not responsible for the content of any linked third-party
website. We make no representations regarding the content or accuracy of any
materials on such third-party website, which is developed and provided by or on
behalf of that third party. You should take precautions when downloading files
from all websites to protect your computer from viruses and other destructive
programs. If you decide to access any third-party websites, you do so at your
own risk.  

We are also not responsible for the privacy practices of these third parties.
Our privacy policy does not apply to third party websites. Just as you are
reading our privacy policy so, too, should you read third party website privacy
policies before providing them any information. Contact the site administrator,
webmaster, or privacy contact person of that website if you have any concerns
regarding such links or content.  

International Visitors

Our Site is hosted in the United States and intended for users located within
the United States. If you choose to visit our Site from the European Union or
other regions of the world with laws governing data collection and use that may
differ from U.S. law, then please note that you are transferring your personal
information outside of those regions to the United States for storage and
processing. Also, if you choose to visit the Site from outside the United
States, we may transfer your data from the U.S. to other countries or regions in
connection with storage and processing of data, fulfilling your requests, and
operating the Services. By providing any information, including personal
information, you consent to such transfer, storage, and processing. 




CHANGES TO OUR PRIVACY NOTICE

We will update this Privacy Notice to make sure it accurately reflects our data
collection and use practices, changes to our privacy policies, or as applicable
laws require. We will comply with applicable legal requirements regarding
providing you with notice and/or consent when we make such changes, depending on
the type of change made. We also provide information about how our Privacy
Notice has changed over time below.

Previous Notice

Major changes made to the Notice

January 2, 2024

Non-major change: added information to Categories of Personal Information We
Collect regarding opt-in data.

July 15, 2021

In this update, we: 

∙ Redesigned the Privacy Notice to make it easier to read and understand. 

∙ Added additional details to answer questions we anticipate you may have.

∙ Replaced the prior California privacy rights section with a new Your Privacy
Right section, which expand the same rights previously described to all site
visitors rather than restricting to California residents.

We welcome any questions, concerns, or feedback you may have about the updates
to this Notice. 

July 20, 2022

In this update, we: 

∙ Align the categories of information collected and shared with defined terms in
the California Consumer Privacy Act 

∙ Explain new privacy rights in alignment with state laws 

∙ Provide information for telehealth patients 

∙ Removed some text to make the notice shorter and easier to understand 

We welcome any questions, concerns, or feedback you may have about the updates
to this Notice. 




CONTACT INFORMATION

If you have any questions, comments, or concerns about our processing
activities, please email us at Privacy@Transcarent.com. 


WHY TRANSCARENT?

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CARE EXPERIENCES

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 * Muscle and Joint Health

 * Weight Health

 * Pharmacy Care

 * Mental Health Care




RESOURCES

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Some U.S. state privacy laws offer their residents specific consumer privacy
rights, which we respect as described in our privacy policy. To opt-out of our
making available to third parties information relating to cookies and similar
technologies for advertising purposes, select "Opt-Out." To exercise other
rights you may have related to cookies, select "More Choices" or see this "Do
Not Sell My Personal Information" link.Privacy Policy
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DO NOT SELL OR SHARE MY PERSONAL DATA

When you visit our website, we store cookies on your browser to collect
information. The information collected might relate to you, your preferences or
your device, and is mostly used to provide a more personalized web experience.
However, you can choose not to allow certain types of cookies This may impact
your experience of the site and the services we are able to offer. Click on the
different category headings to find out more and change our default settings
according to your preference. You cannot opt-out of our First Party Strictly
Necessary Cookies as they are deployed in order to ensure the proper
functionality of our website (such as prompting the cookie banner and
remembering your settings, to log into your account, to redirect you when you
log out, etc.). For more information about the First and Third Party Cookies
used please follow this link.
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These cookies are necessary for the website to function and cannot be switched
off in our systems. They are usually only set in response to actions made by you
which amount to a request for services, such as setting your privacy
preferences, logging in or filling in forms. You can set your browser to block
or alert you about these cookies, but some parts of the site will not then work.
These cookies do not store any personally identifiable information.

TARGETING COOKIES

Targeting Cookies

These cookies may be set through our site by our advertising partners. They may
be used by those companies to build a profile of your interests and show you
relevant adverts on other sites. They do not store directly personal
information, but are based on uniquely identifying your browser and internet
device. If you do not allow these cookies, you will experience less targeted
advertising.

PERFORMANCE COOKIES

Performance Cookies

These cookies allow us to count visits and traffic sources so we can measure and
improve the performance of our site. They help us to know which pages are the
most and least popular and see how visitors move around the site. All
information these cookies collect is aggregated and therefore anonymous. If you
do not allow these cookies we will not know when you have visited our site, and
will not be able to monitor its performance.

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