HIPAA AND YOUR PROTECTED HEALTH INFORMATION
Your health information is protected by the Health Insurance Portability and Accountability Act (HIPAA), one of the strongest federal privacy laws in the country. We treat all information you provide as a Member of Transcarent, or a patient of our affiliated medical group, as Protected Health Information ("PHI") governed by HIPAA. We receive your PHI from your health plan, from you, from our telehealth clinics, or from the health care providers that treat you. Neither this Policy nor our Consumer Health Data Privacy Notice governs how we handle your PHI; HIPAA will govern how we handle your PHI.
When you use our Services as a Transcarent Member, your health information is protected by HIPAA, your health plan's Notice of Privacy Practices, and our business associate agreement with your health plan. If you use our AI Care Assistant, the technology partners that help power it are contractually bound by HIPAA and may only use your information to support our services on your behalf. Please read your health plan’s Notice of Privacy Practices for more detail on how your PHI is protected.
If you are a patient of one of our affiliated telehealth clinics, their Notice of Privacy Practices describes how we collect, use, maintain and share PHI, as well as your related rights. To review those policies, click here for The Transcarent Clinic and here for Accolade Care. We may use our AI Care Assistant to support your clinician in starting your visit or to help explain your care plan to you. Any technology partners involved are contractually bound by HIPAA and may only use your information to support your care.
CATEGORIES OF PERSONAL INFORMATION WE COLLECT
We collect personal information from three sources: directly from you, automatically when you visit our Sites, and from other sources. The table below describes the types of personal information we may have collected in the past twelve (12) months.
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Information Category
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Examples
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Sources and Context
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Identifiers
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- Internet Protocol address
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You, such as when you:
- Use the “Contact Us” link on the Sites
- Send us an inquiry using another method
- Sign-up for notifications or updates
- Contact our customer support team (but not as a Member)
From third party data aggregators that provide us with your contact information.
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Internet or Other Electronic Network Activity
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- Type of device, operating system, and browser
- Average time spent on our website
- Information on web page interactions
- Referring webpage or source through which you access the Services
- Statistics associated with the interaction between device or browser and the Services
- Information on whether an email was opened or clicked on
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Our service providers and third parties that deploy cookies and similar tracking technologies on our Sites.
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Non-Precise Geolocation Data
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- Approximate geographic location inferred from an IP address
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Our service providers and third parties that deploy cookies and similar tracking technologies on our Sites.
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Professional or Employment-related Information
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You, such as when you:
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Sensitive Information
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- Health information (that is not PHI subject to HIPAA)
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You, such as when you do the following but are not logged into an account:
- Share information when posting reviews or providing feedback
- Request general information about our Services
- Complete a quiz or pre-visit questionnaire to our direct-to-consumer telehealth clinic.
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HOW WE USE THE PERSONAL INFORMATION WE COLLECT
We use your personal information to respond to your questions, communicate with you, and for the following purposes:
- To understand how you use or navigate around our Sites, monitor and improve our Sites, improve your experiences interacting with us, tailor our content to you, and create new products, services, features, and functions.
- When we send you emails, we may track whether you open them to learn how to improve our communications
- To communicate with you, give you information you ask for, respond to your comments and questions, and provide support.
- To follow the law, enforce our Terms of Service or other legal rights, or as required by laws, regulations, or government requests.
- To contact prospective clients with general or personalized messages that may be of specific interest to them. We may also use AI tools to analyze and improve our communications with prospective clients.
- To create deidentified and anonymized datasets for internal and external uses.
- For other reasons we tell you about when we collect the information.
We only use sensitive personal information for limited internal purposes, such as: (i) providing services you would reasonably expect; (ii) detecting and responding to security incidents; (iii) ensuring physical safety; (iv) short-term, transient use, including non-personalized advertising; (v) internal business operations; and (vi) maintaining the quality or safety of our services. We do not use sensitive personal information to profile you.
Note about Voice/Text Messaging: We 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.
Note about Use of AI: Our sales and client success teams may use AI-powered tools from service providers to improve the quality of our communications with potential and current clients, such as for emails, calendar invitations, and meetings.
WHEN WE DISCLOSE THE PERSONAL INFORMATION WE COLLECT
In the past twelve months, we may have shared personal information with the following types of recipients:
- Vendors and Service Providers: We share information with vendors and service providers who help us operate our business, including analytics partners, technology providers, and marketing services. These partners receive only the information they need to perform their work on our behalf.
- Corporate Affiliates: We may share personal information within the Transcarent family of companies to provide, integrate, and improve our Services.
- As required by law and similar disclosures: We may access, keep, and share your information if we believe it is necessary to: (a) follow the law or respond to law enforcement requests and legal processes, like a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.
- Merger, Sale, or Other Asset Transfers: If Transcarent is involved in a merger, acquisition, or sale of assets, your information may be shared with advisors, potential business partners, or other parties involved in the transaction.
- With your consent: We may disclose your information with your permission.
We do not sell your personal information for money, and we never will. Some state privacy laws use broad definitions of “sale” and “sharing” that may include certain analytics cookies we use to understand how our websites perform. Under those definitions, our use of analytics cookies involving Identifiers, Internet and Other Electronic Activity Information, and Non-Precise Geolocation Information may qualify. You can opt out of these cookies at any time using our cookie preference settings.
COOKIES AND PIXELS
We and our partners use cookies, pixel tags, and similar technologies to improve your experience when you use our Services or visit our Sites. Our analytics and advertising partners may also use these technologies to understand how our websites are used. Some advertising may be personalized based on topics we think may interest you.
- Cookies: Cookies are small text files containing a string of letters and numbers. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie stays after you close your browser and may be used on future visits to our Services.
- Pixel tags: Also known as “clear GIFs”, “tracer tags”, or “web beacons”, these technologies help us and our partners understand which pages or content you view. Pixel tags help us improve and customize our Site for you and other visitors.
- Browser settings: Your web browser’s “Help” file has information on how to change your cookie settings. Note that deleting or not accepting cookies may affect your experience with Services that do not require logging in.
Analytics Information: We use analytics services, such as Google Analytics, to understand how visitors use our Sites and to improve them. These tools automatically collect information about your interactions, such as the pages you view and the dates and times of your visits. You can learn about Google’s practices at https://www.google.com/policies/privacy/partners, and opt out of Google Analytics by visiting https://tools.google.com/dlpage/gaoptout.
Behavioral and Targeted Advertising Information: On certain of our marketing websites and on third-party websites, we may personalize content and advertising based on topics we think may interest you. This is sometimes called “behavioral advertising.” We may also measure the effectiveness of our advertising and communications, including whether you open or interact with our emails. You can manage your advertising and cookie preferences at any time through our cookie settings.
Setting your Preferences: We use OneTrust for cookie consent management. When you visit our Services, including our Sites, you can set your cookie preferences using a consent banner. You can change your choices later by clearing your cookies in your browser settings and updating your choice in the consent banner, or by using “Manage Cookie Preferences” to choose certain types of cookies. Note that Required Cookies cannot be turned off, and if you decide to opt-out of Functional Cookies, some features of our Sites may not work properly.
SECURITY
We protect your personal information using industry-standard physical and electronic safeguards, including encryption, access controls, and regular security assessments. While no system is completely immune to risk, we work continuously to keep your information safe.
RETENTION OF PERSONAL INFORMATION
We keep your information only as long as needed to fulfill the purposes described in this Policy, provide our Services, or comply with legal requirements.
CHILDREN’S PRIVACY
We do not knowingly collect, maintain, use, sell, or share personal information (including sensitive personal information) from children under 16 years of age. If you learn that a child has given us personal information in violation of our policy, then please let us know at Privacy@Transcarent.com.
YOUR PRIVACY RIGHTS
The rights in this section apply to your personal information, not your Protected Health Information (which is governed by HIPAA). Most of the information we hold is PHI, so depending on your relationship with us, you may need to make requests through your health plan or our telehealth clinics. We know this can be confusing, so if you have questions about which rights apply to you, please contact us at Privacy@Transcarent.com.
Depending on where you live, you may have the following rights with respect to your personal information:
- Right to Know and Access: You can request to see what personal information we have about you and how we use and share it. For your convenience, we 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 Correct: You have the right to request that we correct inaccurate personal information we maintain about you.
- Right to Request Deletion: You have the right to ask us to delete your personal information, with some exceptions.
- Right to Opt Out of Sale or Sharing for Targeted Advertising: You can opt out of the “sale” or “sharing” of your personal information for targeted advertising under applicable state privacy laws. If your browser or device is configured to send a Global Privacy Control (GPC) signal, we will honor it automatically.
- If you are a resident of Oregon or Minnesota, you also have the right to request a list of third parties to whom we disclose personal information.
To opt out of sale or sharing for targeted advertising, use our cookie consent banner to disable Targeting Cookies and other non-essential tracking technologies. You can update your preferences at any time by clearing your cookies and revisiting the consent banner, or by selecting “Manage Cookie Preferences.” You will need to complete this step on each website, browser, and device you use. We also honor Global Privacy Control (GPC) signals as required by applicable privacy laws. If your browser or device sends a GPC signal, we will process your opt-out automatically.
To exercise your other privacy rights, visit our Data Subject Rights Portal here or call us toll-free at (888) 914-9661 (PIN# 494 202). We will never treat you differently for exercising your privacy rights.
To protect your privacy, we may ask you to verify your identity before processing your request. We will need you to:
- provide information that helps us verify your identity, such as your name and zip code; and
- describe your request with enough detail so we can understand, evaluate, and respond to it.
Depending on where you live, you may authorize an agent to submit a privacy request on your behalf. Your agent must have your written permission, verify their identity, and follow the same steps described above.
Right to Appeal: If we deny a privacy request, you can appeal by submitting a new request using the same methods described above. Please include any additional information that may help us reconsider.
ADDITIONAL NOTICE FOR WASHINGTON AND NEVADA RESIDENTS
Residents of Washington and Nevada may have additional rights related to their consumer health data. Please review our Consumer Health Data Privacy Notice.
OTHER IMPORTANT INFORMATION
Third Parties: Our Services may contain links to websites, products, or services we do not own or operate. These links are provided for convenience and do not imply endorsement. We are not responsible for the privacy practices of third-party websites, and this Policy does not apply to them. We encourage you to review the privacy policies of any third-party sites before sharing your information.
International Visitors: Our Sites are hosted in the United States and intended for U.S. visitors. If you access our Sites from outside the United States, your information may be transferred to and processed in the United States or other countries where our service providers operate. By using our Sites, you consent to this transfer.
CHANGES TO OUR PRIVACY POLICY
We may update this Policy to reflect changes in our practices or as required by law. When we make material changes, we will notify you by posting a notice on our Services or sending you an email.
CONTACT INFORMATION
If you have any questions about this Policy or how we handle your information, please email us at Privacy@Transcarent.com.
