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ACCOLADE PRIVACY POLICY

(Updated: December 18, 2023; Effective: January 1, 2024) 

Your privacy is very important to Accolade. This “Privacy Notice" has been
compiled to assist you in understanding the ways in which we, Accolade, Inc. and
its affiliates (“Accolade"), collect personal information from you as you use
the www.accolade.com website (the “Site"). Please read this Privacy Notice
carefully to get a clear understanding of how we collect, use, protect or
otherwise handle your personally identifiable information. 

This Privacy Notice is intended to be read in conjunction with the Terms of
Use for the Site. By using the Site, you are agreeing to the Terms of Use and
this Privacy Notice. 

If you are a member of Accolade services, please remember that Accolade is here
to simplify healthcare and your health benefits for you and your family. We are
here to help you understand your healthcare options, to facilitate your use of
the healthcare system and to support you as you make your healthcare decisions.
The content we provide you is for informational purposes only, is based on the
best available information, and may not be relied upon when alternative and more
relevant information (such as, for example, information provided directly by
your health care provider) would be more relevant or accurate. No material
contained within or provided through the Accolade Site should be construed as
medical advice and/or treatment. Accolade shall have no responsibility or
liability for out-of-pocket costs you may incur for actual care provided or
medical procedures performed by your healthcare provider(s), and you are
responsible for understanding and evaluating such costs, including any costs
known as “surprise billing" or costs incurred as a result of balanced billing,
notwithstanding information provided by Accolade based on best available
information. Accolade does not provide medical advice, provide nursing care,
diagnose or deliver treatment and no physician- or nurse-to patient-relationship
is created as a result of your use of the Accolade Site. Those are activities
for you to undertake with your doctor or other appropriately trained and
qualified health professional. IF YOU THINK YOU HAVE A MEDICAL EMERGENCY, YOU
SHOULD CALL YOUR DOCTOR OR 911 IMMEDIATELY. 

Accolade may provide, from time to time, various digital services to its
customers and members, including the Accolade Portal (including the web service
known as MyAccolade), Accolade Digital Tools, and the Accolade Mobile App. Such
digital services have their own terms and conditions and privacy notices, and
your use of such services is subject to those terms and conditions and privacy
notices. Those digital services are just one more way you can connect with your
Accolade Health Assistant® representative to support you and your family in your
healthcare journey. 

This Privacy Notice applies only to your use of the Site, and was last updated
as of the date noted above. Accolade may revise this Privacy Notice at any time
and such revision will be posted here and accessible at the following
link: https://www.accolade.com/privacy-policy. Any revision and/or addition to
this Privacy Notice shall become effective and binding on you when you continue
to use the Site on or after the effective date of such revision and/or
addition. 


WHAT INFORMATION DOES ACCOLADE COLLECT THROUGH THE SITE? 

Information You Choose to Provide. 

 * when communicating with Accolade in general, you may be asked to provide your
   first and last name, postal address, email address, or other contact
   information; or 

 * when inquiring about an open job posting, you may desire to upload your
   resume or connect with us using various third party tools, such as LinkedIn
   or Indeed (we are not responsible for third party use of your information);
   or 

 * when registering for an event or a webinar, Accolade or its third party
   partners may ask you to provide personal information for the purpose of
   registering you for such event or webinar and providing access to the event. 

As further detailed below, we may also collect certain non-personally
identifiable information about how you use the Site.  

We do not collect and ask that you not provide us with any medical, health,
financial or other sensitive personal information through the Site. 

 

Information Collected Via Your Use of our Site 

We may collect information from you when you are using the Site in a number of
different ways; for example: 

 * we may collect and track your IP address; 

 * depending on your settings, we may use cookies, web beacons, pixels,
   technologies to record user sessions, and other tracking tools to monitor and
   track your access to and usage of the Site and for the purpose of certain
   remarketing activities (e.g., we display Accolade branded ads to you after
   you visit our Site and as you browse elsewhere on the Internet); 

 

Information We Collect Automatically. 

We may now or in the future use tools, including third-party analytical
software, to collect automatically certain data about the computer or other
device you use to reach our Site such as: (i) device properties including, but
not limited to, unique or other device identifiers; (ii) device operating system
and firmware; (iii) IP address (i.e., a number that is automatically assigned to
your device or computer used to access the Site, and allows us to identify your
device or computer) and Internet service provider; (iv) mobile phone carrier;
(v) geographical data such as country or region; and (vi) other similar data.

Accordingly, when you visit our Site, some information may be automatically
collected. Such information may also include Site access times, browser type and
settings, device type, domain name, access times, duration of visit, referring
URL, platform, new and repeat information, time stamp and language, and
referring website addresses all of which may be logged automatically. We may
also collect information about your usage and activity on our Sites. 

This information may be collected via several technologies, including cookies,
web beacons, pixels, clear GIFs and other means. All of this information belongs
to us, and we use it to improve effectiveness, content, layout and/or operation
of our Site. You can remove certain cookies by following the directions in your
Internet browser’s “help" file. If you disable cookies, certain pixels and any
screen recording technologies will be disabled and your ability to use areas of
the Site may be limited. Additionally, Accolade provides a mechanism to remove
certain cookies, as discussed below.  


HOW DO WE USE YOUR INFORMATION? 

In general, we do not and will not share your personally identifiable
information except as set forth in this Privacy Notice. We do not sell,
transfer, and/or share your personally identifiable information with third
parties for their own marketing purposes. 

We use the information we collect from you when you browse the Site in the
following manner: 

Category NameCategories of Your Personal InformationUse of InformationPersonal
IdentifiersIdentification information, message content, application usage data
(e.g., features/pages accessed by a member), location data (GPS). To operate and
improve the Site and associated services. Usage InformationIdentification
information, message content, application usage data (e.g., features/pages
accessed by a member), location data (GPS). To understand and analyze
information related to the number and type of visitors that browse and use the
Site. Member SupportName, phone number, mailing address, email address. To
respond to your comments and questions and provide customer services. Candidate
Employee SupportName, mailing address, email, phone number, employment
application information To permit you to apply for a job at Accolade, connect
with third parties that we use to process job application information, and
receive more information about open positions at Accolade. Event Registration
InformationName, mailing address, email address, phone number, demographic
information To register for various events and webinars. Member
communicationsName, mailing address, email address, phone number To communicate
with you about new contests, promotions and rewards, upcoming events, and other
news about products and services offered by Accolade and our selected
partners. Member outreachName, mailing address, email address, phone number To
conduct outreach and engagement communications to make you aware of Accolade
services. Internal Business PurposesName, mailing address, email address, phone
number, demographic information To link or combine with other personal
information we get from third-parties, to help understand your needs and provide
you with better information on the Site. Device Information and IdentifiersIP
address; browser type and language; operating system; platform type; device
type; software and hardware attributes; and unique device, advertising, and app
identifiers.  For Accolade, internal purposes, such as providing the services,
including registration and member support Fixing and improving the
services. Personalizing content and your experience.  Research, survey, or
sweepstakes information (including personal identifiers and user generated
content)Collected if you participate in a survey or sweepstakes; includes
information needed for you to participate (such as contact information), and to
fulfill your prize. For Accolade, internal purposes, such as providing the
services,  including registration and member support Fixing and improving the
services. Personalizing content and your experience. 

If you provide Accolade with your contact information to receive marketing
materials, you are opting-in to receive information from Accolade, including by
email. You can opt-out anytime from the types of uses of your information, and
receiving these communications, as further described below. 


WHO HAS ACCESS TO YOUR INFORMATION? 

YOUR PERSONAL INFORMATION WILL NOT BE SOLD. Nor will Your Personal Information
be licensed or disclosed to unaffiliated third-parties, except in connection
with the sale, transfer, merger, consolidation or other transaction involving
all or part of our company or as may be permitted under applicable law. 

In addition to the above, we may share the information collected from you, as
described above, with our third party partners to enable us to analyze and use
such information to provide you with our services and in the manner set forth in
this Privacy Notice. We may share your information with third-parties who assist
Accolade with its outreach and engagement communications to make you aware of
certain of Accolade’s services. We also allow our website hosting partners and
other parties who assist us in operating our website, conducting our business,
or serving our users, to access and process your information so long as those
parties agree to keep this information confidential. We do not sell your
information to third parties for marketing purposes, and we restrict such third
parties’ usage of your information consistent with this Privacy Notice. 

In addition to the above, we may be required to disclose your information to (i)
comply with laws or to respond to lawful requests and legal process (including
to respond to requests from public or government authorities, including public
or government authorities outside your country of residence), (ii) to
investigate, prevent, or take action regarding illegal or suspected illegal
activities, (iii) to protect the rights and property of Accolade, and others to
enforce our agreements, and this Privacy Notice and the Terms of Use, including
to protect the security or integrity of the Site or our information systems,
(iv) in an emergency to protect person or property, (v) as may be needed on a
confidential basis to support a corporate transaction (including a merger,
acquisition, divestiture, financing, or sale of assets or lines of business), or
(vi) on an aggregated basis for any purpose in which your specific personal
information is blinded, masked or otherwise not identifiable. 


HOW DO WE PROTECT YOUR INFORMATION? 

We follow industry standard practices to protect, secure and maintain the
integrity and availability of your information. The Site and our internal
networks supporting the Site are scanned regularly for malware and other
viruses. Notwithstanding the foregoing, you acknowledge that no security
safeguards or method of transmission over the Internet are completely secure. 

The Site is not intended to collect, maintain or transmit your information to
the privacy and security standards used in healthcare or banking where sensitive
medical, health, or financial information may be transmitted. The Site is not
protected according to HIPAA/HITECH, PCI or other such standards. DO NOT USE THE
SITE OR COMMUNICATION TOOLS TO SEND US SENSITIVE PERSONAL OR PROTECTED HEALTH
INFORMATION (e.g., do not send us your health information, benefit or ID card
number, health claims information, social security number, financial account
number, passcodes, etc.). For this reason, Accolade does not secure the
transmission of your information submitted through the Communication Tools (as
defined above), including using the addresses and numbers provided in the “Get
in Touch" section of the Site. 


HOW LONG DO WE KEEP YOUR INFORMATION? 

We store your information for as long as necessary to serve the business
purposes for which it was collected and in conformance with applicable data
protection laws. 


DOES THE SITE USE COOKIES? 

Yes, the Site uses “cookies" and other web tracking tools. We may store
information about you using the cookies on our site. A cookie also called web
cookie, Internet cookie, browser cookie, or simply cookie) is a small piece of
data sent from a website and stored on the user’s computer by the user’s web
browser while the user is browsing. We use cookies to improve your site
experience, to assess content usage, to distinguish you from other users of our
site and to support the marketing of our services. For example, cookies help
determine what kind of content we will serve to the user – a use case might be,
if a user is browsing a particular set of page content themes, we might serve
that theme in the form of advertising as we’ve identified them as an interested
party of that theme. 

We want to be completely transparent about the cookies we use and to make their
control as easy as possible for you. When you first enter our Sites, you will be
asked to accept or reject cookies. If, after your initial visit to the Site, you
decide to change your cookie selection, you can do so by visiting
www.accolade.com  and selecting “Manage Cookies.”  

Further, if you want to delete any cookies that are already on your computer,
please refer to the file management software to locate the file or directory
that stores cookies under the following file names. Other information on
deleting or controlling cookies is available at allaboutcookies.org. Please note
that by deleting our cookies or disabling future cookies you may not be able to
access certain areas or features of our site.  


WHAT ARE THE PRIVACY POLICIES OF THIRD-PARTY WEBSITES TO WHICH THE SITE LINKS? 

Occasionally, at our discretion, we may link to third party sites or content on
the Site. These third-party sites have separate and independent privacy
policies. We, therefore, have no responsibility or liability for the content and
activities of these linked sites. Nonetheless, we seek to protect the integrity
of our Site and welcome any feedback about these third party sites. We urge you
to review the privacy policies posted on these third-party websites at the time
you first visit such sites. 


WHERE DOES DATA STORAGE AND PROCESSING OCCUR? 

The Site collects information and processes and stores that information in
databases located in the United States. If you are visiting the Site from a
country outside the United States, you should be aware that you may transfer
personally identifiable information about yourself to the United States, and
that the data protection laws of the United States may not be as comprehensive
as those in your own country. By visiting the Site and submitting any personally
identifiable information you consent to the transfer of such personally
identifiable information to the United States.   

 


CALIFORNIA RESIDENTS 

The California Consumer Privacy Act of 2018, as amended by the California
Privacy Rights Act (“CPRA”, collectively “CCPA”), and other California privacy
laws provides California residents (i.e., consumers) with specific rights
regarding personal information. This section of the Privacy Notice describes
those CCPA rights and how to exercise those rights.  

This section does not apply to publicly available information or to protected
health information that is collected and governed by the privacy, security, and
breach notification rules issued by the federal Department of Health and Human
Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations,
established pursuant to the Health Insurance Portability and Availability Act of
1996 (“HIPAA").  

 

Access to Specific Information and Data Portability Rights 

California residents have the right to request that Accolade disclose certain
information to you about Accolade’s collection and use of your personal
information over the past twelve (12) months. Once Accolade receives and
confirms a verifiable consumer request from you, Accolade will disclose to you,
to the extent permitted by law: 

 * The categories of personal information Accolade collected about you. 

 * The categories of sources for your personal information Accolade collected
   about you. 

 * Accolade’s business or commercial purpose for collecting your personal
   information. 

 * The categories of third parties with whom Accolade shares your personal
   information. 

 * If we disclosed your personal information for a business purpose, the
   personal information categories that each category of recipient obtained. 

 

You shall have the right to request that the information described above be
provided to you in a portable and readily useable format, to the extent
technically feasible (“data portability").  

Accolade does not sell your personal information.  

 

Deletion and/or Correction Request Rights 

You have the right to request that Accolade delete and/or correct certain of
your personal information that Accolade collected from and/or related to you and
retained, subject to certain exceptions. Because of the relationship between
Accolade and your employer and/or your health plan carrier, Accolade cannot
delete or correct/change your personal information provided by your employer,
your health care provider and/or other entities that support your health
benefits plan.  

To the extent that Accolade can delete or correct your personal information,
once Accolade receives and confirms your verifiable consumer request, Accolade
will delete and/or correct (and direct our service providers to delete) your
personal information, unless an exception applies.  

We may deny your deletion request if retaining the information is necessary for
us or our service providers to: 

 * Complete the transaction for which we collected your personal information,
   provide a good or service that you requested, take actions reasonably
   anticipated within the context of our ongoing business relationship with you,
   your employer, or your health plan carrier. 

 * Detect security incidents, protect against malicious, deceptive, fraudulent,
   or illegal activity, or prosecute those responsible for such activities. 

 * Debug products to identify and repair errors that impair existing intended
   functionality. 

 * Exercise free speech, ensure the right of another consumer to exercise their
   free speech rights, or exercise another right provided for by law. 

 * Comply with the California Electronic Communications Privacy Act (Cal. Penal
   Code § 1546 seq.). 

 * Engage in public or peer-reviewed scientific, historical, or statistical
   research in the public interest that adheres to all other applicable ethics
   and privacy laws, when the information's deletion may likely render
   impossible or seriously impair the research's achievement, if you previously
   provided informed consent. 

 * Enable solely internal uses that are reasonably aligned with consumer
   expectations based on your relationship with us. 

 * Comply with a legal obligation. 

 * Make other internal and lawful uses of that information that are compatible
   with the context in which you provided it. 

 

Additionally, Accolade may deny your deletion and/or correction request if the
information sought to be deleted is protected health information disclosed to us
as part of your participation in an employer-sponsored group health plan and/or
your health plan carrier through which you have purchased a health plan or other
benefits.  

We may deny your correction request if, after considering the totality of the
circumstances, we determine that the information is more likely accurate than
not.  

 

Limit the Use of My Sensitive Personal Information 

Under the CCPA, California residents have the right to limit the use of their
sensitive personal information (“SPI”) to only those purposes that are necessary
for the business to provide products or services to the consumer.  Accolade does
not use any of your SPI for any purposes other than to provide the services to
you.    

 

Exercising Your Access, Data Portability, and Deletion Rights 

To exercise the access, data portability, and deletion rights described above,
please submit a verifiable consumer request to Accolade by either:  

 * Visiting the Data Subjects Rights Portal located here; or 

 * Calling the following toll-free number at 1 (888) 914-9661, and using PIN#
   494 202 to identify that you are calling with respect to Accolade. 

 

We ask that you not provide us with any medical or protected health information
through the above communications.  

Only you or a person registered with the California Secretary of State that you
authorize to act on your behalf, may make a verifiable consumer request related
to your personal information. You may also make a verifiable consumer request on
behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability
twice within a 12-month period. The verifiable consumer request must: 

 * Provide sufficient information that allows Accolade to reasonably verify you
   are the person about whom Accolade collected personal information or an
   authorized representative. 

 * Describe your request with sufficient detail that allows Accolade to properly
   understand, evaluate, and respond to it. 

 

Accolade cannot respond to your request or provide you with your personal
information if Accolade cannot verify your identity or authority to make the
request and confirm the personal information relates to you. Making a verifiable
consumer request does not require you to create an account with us. We will only
use personal information provided in a verifiable consumer request to verify the
requestor's identity or authority to make the request. Any disclosures provided
pursuant to the CCPA will only cover the 12-month period preceding the receipt
of the verifiable consumer request. 

Accolade will respond to a verifiable consumer request within 45 days of its
receipt, or notify you that Accolade requires more time to respond and the
reason for the extended response time. Accolade will deliver its written
response by mail or electronically, at your option. 

To the extent that your verifiable consumer request is excessive, repetitive, or
manifestly unfounded, Accolade may charge a reasonable fee to respond to such
request. 

Accolade will not discriminate against you for exercising any of your CCPA
rights. Unless permitted by the CCPA, Accolade will not: 

 * Deny you goods or services. 

 * Charge you different prices or rates for goods or services, including through
   granting discounts or other benefits, or imposing penalties. 

 * Provide you a different level or quality of goods or services. 

 * Suggest that you may receive a different price or rate for goods or services
   or a different level or quality of goods or services. 

 


COLORADO RESIDENTS 

The Colorado Privacy Act (“CPA”) and other Colorado privacy laws provide
Colorado residents (I.e., consumers) with specific rights regarding personal
information. This section of the Privacy Notice describes those CPA rights and
how to exercise those rights. This section does not apply to publicly available
information or to protected health information that is collected and governed by
the privacy, security, and breach notification rules issued by the federal
Department of Health and Human Services, Parts 160 and 164 of Title 45 of the
Code of Federal Regulations, established pursuant to the Health Insurance
Portability and Availability Act of 1996 (“HIPAA”). 

 

Access to Specific Information and Data Portability Rights 

Colorado residents have the right to request that Accolade disclose certain
information to you about Accolade’s collection and use of your personal
information over the past twelve (12) months. Once Accolade receives and
confirms a verifiable consumer request from you, Accolade will disclose to you,
to the extent permitted by law: 

 * The categories of personal information Accolade collected about you. 

 * The categories of sources for your personal information Accolade collected
   about you. 

 * Accolade’s business or commercial purpose for collecting your personal
   information. 

 * The categories of third parties with whom Accolade shares your personal
   information. 

 * If we disclosed your personal information for a business purpose, the
   personal information categories that each category of recipient obtained. 

 * You shall have the right to request that the information described above be
   provided to you in a portable and readily usable format, to the extent
   technically feasible (“data portability”). 

 

Accolade does not sell your personal information.  

 

Deletion and/or Correction Request Rights 

You have the right to request that Accolade delete and/or correct certain of
your personal information that Accolade collected from and/or related to you and
retained, subject to certain exceptions. Because of the relationship between
Accolade and your employer and/or your health plan carrier, Accolade cannot
delete or correct/change your personal information provided by your employer,
your healthcare provider and/or other entities that support your health benefits
plan. 

To the extent that Accolade can delete or correct your personal information,
once Accolade receives and confirms your verifiable consumer request, Accolade
will delete and/or correct (and direct our service providers to delete) your
personal information, unless an exception applies. We may deny your deletion
request if retaining the information is necessary for us or our service
providers to: 

 * complete the transaction for which we collected your personal information,
   provide a good or service that you requested, take actions reasonably
   anticipated within the context of our ongoing business relationship with you,
   your employer, or your health plan carrier 

 * detect security incidents, protect against malicious, deceptive, fraudulent,
   or illegal activity, or prosecute those responsible for such activities 

 * debug products to identify and repair errors that impair existing intended
   functionality 

 * exercise free speech, ensure the right of another consumer to exercise their
   free speech rights, or exercise another right provided for by law 

 * engage in public or peer-reviewed scientific, historical, or statistical
   research in the public interest that adheres to all other applicable ethics
   and privacy laws, when the information's deletion may likely render
   impossible or seriously impair the research's achievement, if you previously
   provided informed consent 

 * enable solely internal uses that are reasonably aligned with consumer
   expectations based on your relationship with us 

 * comply with a legal obligation 

 * make other internal and lawful uses of that information that are compatible
   with the context in which you provided it 

 * Additionally, Accolade may deny your deletion and/or correction request if
   the information sought to be deleted is protected health information
   disclosed to us as part of your participation in an employer-sponsored group
   health plan and/or your health plan carrier through which you have purchased
   a health plan or other benefits. 

We may deny your correction request if, after considering the totality of the
circumstances, we determine that the information is more likely accurate than
not. 

 

Exercising Your Access, Data Portability, and Deletion Rights 

To exercise the access, data portability, and deletion rights described above,
please submit a verifiable consumer request to Accolade by either: 

 * visiting the Data Subjects Rights Portal located here; or 

 * calling the following toll-free number at 1 (888) 914-9661, and using PIN#
   494 202 to identify that you are calling with respect to Accolade. 

 

We ask that you not provide us with any medical or protected health information
through the above communications. 

 

Only you or a person registered with the Colorado Secretary of State that you
authorize to act on your behalf, may make a verifiable consumer request related
to your personal information. You may also make a verifiable consumer request on
behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability
twice within a 12 month period. The verifiable consumer request must: 

 * provide sufficient information that allows Accolade to reasonably verify you
   are the person about whom Accolade collected personal information or an
   authorized representative 

 * describe your request with sufficient detail that allows Accolade to properly
   understand, evaluate, and respond to it 

 

Accolade cannot respond to your request or provide you with your personal
information if Accolade cannot verify your identity or authority to make the
request and confirm the personal information relates to you. Making a verifiable
consumer request does not require you to create an account with us. We will only
use personal information provided in a verifiable consumer request to verify the
requestor's identity or authority to make the request. Any disclosures provided
pursuant to the CPA will only cover the 12-month period preceding the receipt of
the verifiable consumer request. 

Accolade will respond to a verifiable consumer request within 45 days of its
receipt, or notify you that Accolade requires more time to respond and the
reason for the extended response time. Accolade will deliver its written
response by mail or electronically, at your option. To the extent that your
verifiable consumer request is excessive, repetitive, or manifestly unfounded,
Accolade may charge a reasonable fee to respond to such request. 

Accolade will not discriminate against you for exercising any of your CPA
rights. Unless permitted by the CPA, Accolade will not: 

 * deny you goods or services 

 * charge you different prices or rates for goods or services, including through
   granting discounts or other benefits, or imposing penalties 

 * provide you a different level or quality of goods or services 

 * suggest that you may receive a different price or rate for goods or services
   or a different level or quality of goods or services 

 

Right to Appeal

You have the right to appeal any declination to respond or failure to take
action regarding your request to exercise your rights. To exercise your right to
appeal, please submit a verifiable appeal request to Accolade by either: 

 * visiting the Data Subjects Rights Portal located here; or 

 * calling the following toll-free number at 1 (888) 914-9661, and using PIN#
   494 202 to identify that you are calling with respect to Accolade. 

 

We ask that you not provide us with any medical or protected health information
through the above communications.  

 


CONNECTICUT, UTAH & VIRGINIA RESIDENTS 

Accolade and its affiliates are exempt from the Connecticut Data Privacy Act
(“CTDPA”), Utah Consumer Privacy Act (UCPA) and Virginia Consumer Data
Protection Act (“VCDPA”). 

These laws and other state privacy laws provide residents (i.e., consumers) of
these states with specific rights regarding personal information. These laws
apply to for-profit and business-to-business companies that interact, or process
personal data of residents of these states on a relatively larger scale. 
However, these laws DO NOT apply to covered entities or business associates
under the Health Insurance Portability and Accountability Act (“HIPAA”) and the
Health Information Technology for Economic and Clinical Health Act.  Accolade
and its affiliates are covered entities and/or business associates and are not
subject to CTDPA, UCPA or VCDPA.   


ADDITIONAL TERMS FOR EU VISITORS 

This website is intended only for users located in the United States. To the
extent that you are accessing this website from a location within the European
Union, the following information shall apply to the collection and processing of
your Personal Information. 

The data controller for this Site is Accolade, Inc. Accolade processes Personal
Information it collects through the Site for Accolade’s legitimate business
purposes, for example to fulfill any requests you may make in connection with
your submission of personally identifiable information, to monitor and improve
the quality of the Site, and to protect and defend our rights, property or
safety or that of our clients and other users of the Site. You may have the
right to access and/or obtain a copy of your Personal Information, correct
inaccuracies in your Personal Information, request the erasure of your Personal
Information and restrict the processing of your Personal Information. For more
information about how you can access, rectify and erase your Personal
Information or make any other requests relating to your Personal Information or
to contact Accolade, please see the “Contact Us" section of this Privacy Notice
below. In addition, you have the right to lodge a complaint with a supervisory
data protection authority, contact information is available
at https://edpb.europa.eu/about-edpb/board/members_en. 


DOES THE SITE USE OTHER THIRD PARTY TOOLS, SUCH AS GOOGLE ADSENSE? 

Accolade has enabled Google AdSense on the Site. Google AdSense is an
advertising service provided by Google. Accolade uses the “Doubleclick" Cookie,
which tracks use of www.accolade.com and user behavior concerning ads, products
and the services we offer. You may decide to disable all the Doubleclick Cookies
by clicking on:  https://adssettings.google.com/authenticated. 

Google’s advertising requirements can be summed up by Google’s Advertising
Principles: https://support.google.com/adwordspolicy/answer/1316548?hl=en 

Google provides a breakdown of the information relevant to the collection and
processing of data by Google AdSense: 

 * Personal Data collected: Cookie and Usage Data. 

 * Place of processing: USA. 

 

You can find the AdSense Privacy Policy
at https://www.google.com/policies/technologies/ads/. 

 

SESSION REPLAY TECHNOLOGY  

 

You acknowledge that Accolade uses session replay technologies, such as those
provided by Quantum Metric and FullStory, that employ software code to record
users’ interactions with the Services in a manner that allows us to watch and
analyze visual reconstructions of those user sessions. The replays may include
users’ clicks, mobile app touches, mouse movements, scrolls, and keystrokes/key
touches during those sessions. These replays help us diagnose usability problems
and identify areas for improvement. You can learn more about FullStory at
https://www.fullstory.com/legal/privacy-policy and you can opt-out of session
recording by FullStory at https://www.fullstory.com/optout/.  You can learn more
about Quantum Metric, including opt out options, at
https://www.quantummetric.com/legal/privacy-policy/.  


ELECTRONIC MAIL FROM ACCOLADE 

When you provide your email to Accolade by using the Communication Tools (as
defined above), you can select to opt-in to receive email from Accolade. If you
opt-in to the receipt of this electronic mail, we will: 

 * not use false or misleading subjects or email addresses; 

 * identify the message as an advertisement in some reasonable way; 

 * include the physical address of our business or site headquarters; 

 * monitor third-party email marketing services for compliance, if one is used; 

 * honor opt-out/unsubscribe requests quickly; and 

 * allow users to unsubscribe by using the link at the bottom of each email. 

You can unsubscribe from promotional emails at any time by: (1) following the
unsubscribe instructions in our emails; or (2) emailing us
at member.support@accolade.com. You may update your email preferences anytime as
well. Please note that even if you unsubscribe from promotional email messages,
we may still need to contact you with important transactional information
related to your account and your use of the Service. For example, even if you
have unsubscribed from our email messages, we will still send you emails
relating directly to a profile created through the Service confirming
registration.  


DO NOT TRACK 

We may not recognize or respond to every type of “do not track" signal or other
mechanisms that provide consumers the ability to exercise choice regarding the
collection of personally identifiable information about an individual consumer’s
online activities over time and across third-party websites or online services,
but we give you certain choices about how we collect personally identifiable
information as described in this Privacy Notice. Many Web browsers are set to
accept cookies by default. If you prefer, you can usually choose to set your
browser to remove cookies and to reject cookies. If you choose to remove cookies
or reject cookies, this could affect certain features or services of our Site
including certain opt-out cookies. 

We encourage you to review the privacy policies of our third party advertisers
and analytics service providers to learn about your choices about information
they collect from you. In addition, the Network Advertising Initiative offers
information about some of the Internet advertising companies we may use,
including how to opt-out of interest based advertising they deliver. To opt-out
of Google Analytics web tracking you can download Google Analytics Opt-out
Browser Add-on. 

For all the details, including how to turn on Do Not Track,
visit www.donottrack.us.  


NOT INTENDED FOR CHILDREN UNDER 13 

The Site is not intended for use by persons under the age of 18 and Accolade
does not specifically market to children under 13. 


CHANGES TO THIS PRIVACY NOTICE 

We reserve the right to amend this Privacy Notice at our discretion and at any
time. When we make changes to this Privacy Notice, we will notify you by email
or through a notice on our website homepage. 


CONTACTING US 

If there are any questions regarding this Privacy Notice you may contact us
using the information below. 

Accolade, Inc.  660 West Germantown Pike, Suite 500 Plymouth Meeting, PA 19462 
Attn: Chief Privacy Officer  privacy@accolade.com 

 

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When you visit our website, we store cookies on your browser to collect
information and use other technologies to record sessions and improve our sites
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your device, and is mostly used to make the site work as you expect it to and to
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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 functioning of our website (such as
prompting the cookie banner and remembering your settings, to log into your
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work. These cookies do not store any personally identifiable information.

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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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These cookies may be set through our site by our advertising partners. They may
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relevant adverts on other sites.    They do not store directly personal
information, but are based on uniquely identifying your browser and internet
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