Privacy Policy

Please Read Carefully

 

This Online Privacy Policy describes the information Savvysherpa, LLC (d/b/a UnitedHealth Group Research and Development) and its affiliates, authorized service providers and agents (collectively, the “Company”, “us” or “we” or “our”) in connection with your use of the ProtectWell™ App and its associated websites, mobile applications, and all other related services (the “Services”), how we use and share that information, and the privacy choices we offer.  This policy applies to information we collect when you access or use our websites, mobile applications (including but not limited to, ProtectWell), or the Services (collectively, the “Site”), when you use our Services or when you otherwise interact with us in connection with Protectwell.

Your use of the Site and the ProtectWell App are sponsored by your employer as an occupational health service.  This is not a healthcare benefit. Any information disclosed to us in connection with the Site and the ProtectWell App is not protected health information, as defined under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) at 45 C.F.R. Parts 160 & 164.

 

Changes to this Online Privacy Policy

We may change this Online Privacy Policy from time to time.  If we make changes, we will notify you by posting the updated policy on our Site and revising the “Last Updated” date below.  We encourage you to review this Online Privacy Policy whenever you use the Services to stay informed about our information practices and about ways you can help protect your privacy.

 

Confidentiality of Medical Information

Certain health information that you disclose to your provider may be protected health information. Please review your provider’s HIPAA Notice of Privacy Practices to learn more about their privacy practices regarding your health information. If your health information is disclosed to us, our Site, or our Services, that information will no longer be protected by HIPAA.

 

Use of Services

Your access to and use of our Services are subject to certain terms and conditions, which are set forth in our Terms of Use.

 

Collection of Information

Information We Collect About You

We may collect the following information from you, your employer, or your provider:

        name

       email address

       mailing address

       worksite location

       phone number

       symptom checker responses

       lab results

       diagnosis

 

Information We Collect from Your Use of the Services

We collect information about you when you use our Site, including, but not limited to the following:

       Device Information.  We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services.  For example, we may collect and analyze information such as (a) IP addresses, unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information.  As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting this information.

       Cookies and Other Electronic Technologies.  We may use the tools outlined below in order to better understand users.  As we adopt additional technologies, we may also gather additional information through other methods.

o   Cookies: “Cookies” are small computer files transferred to your computing device that contain information such as user ID, user preferences, lists of pages visited and activities conducted while using the Services.  We may use Cookies to help us improve or tailor the Services by tracking your navigation habits, storing your authentication status so you do not have to re-enter your credentials each time you use the Services, customizing your experience with the Services, and for analytics and fraud prevention. 

Other Cookies used by our business partners may collect information when you use the Services, such as the IP address, mobile device ID, operating system, browser, web page interactions, the geographic location of your internet service provider, and demographic information.  These Cookies help Company learn more about our users’ demographics and internet behaviors. 

For more information on cookies, visit http://www.allaboutcookies.org.

o   Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files imbedded in a web page or email that may be used to collect anonymous information about your use of our Services, and the emails or newsletters that we send you.  The information collected by Web Beacons allows us to analyze how many people are using the Services or opening our emails, and for what purpose.

o   Website Analytics: We may use third-party website analytics services in connection with the Services, including, for example, to register mouse clicks, mouse movements, scrolling activity and text that you type into the website or mobile application.  These website analytics services generally do not collect personal information unless you voluntarily provide it and generally do not track your browsing habits across websites which do not use their services.  We use the information collected from these services to help make the website easier to use.

o   Mobile Device Identifiers: Mobile device identifiers are data stored on your mobile device that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it.  Mobile device identifiers enable collection of personal information (such as media access control, address and location) and traffic data.  Mobile device identifiers help Company learn more about our users’ demographics and internet behaviors.

 

Information from Third Parties

We may obtain additional information about you from third parties such as marketers, partners, researchers, and others.  We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

 

Aggregate or De-identified Data

 

We may aggregate and/or de-identify information collected by the Services or via other means so that the information is not intended to identify you.  Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Online Privacy Policy, and we may disclose it to others without limitation for any purpose, in accordance with applicable laws and regulations.

Use of Information

We use the information that we collect for the following purposes:

·       For the purposes for which you provided the information;

·       To provide, maintain, administer, improve, or expand the Services, perform business analyses, research, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we or our partners offer;

·       To contact you when necessary or requested;

·       To customize and tailor your experience of the Services;

·       To send mobile notifications (you may opt-out of this service)

·       To send emails and other communications that display content that we think will interest you and according to your preferences;

·       To send you news and information about our Services;

·       To track and analyze trends and usage in connection with our Services;

·       To better understand who uses the Services and how we can deliver a better user experience;

·       To combine information received from third parties with the information that we have from or about you and use the combined information for any of the purposes described in this Online Privacy Policy;

·       To use statistical information that we collect in any way permitted by law;

·       To prevent, detect, and investigate security breaches, fraud, and other potentially illegal or prohibited activities;

·       To enforce the legal terms that govern your use of the Services;

·       To protect our rights or property;

·       To administer and troubleshoot the Services; and

·       For any other purpose disclosed to you in connection with our Services. 

We may use third-party service providers to process and store personal information in the United States and other countries.

Sharing of Information

We may share personal information about you as follows:

·       With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf;

·       With our affiliates and partners so that they may use such information for the purposes described in this Online Privacy Policy;

·       In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture or dissolution of all or a portion of our business (but only under non-disclosure and confidentiality agreements and protections);

·       If we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; to enforce applicable user agreements or policies; to protect the security or integrity of our Services; and to protect us, our users or the public from harm or illegal activities; and

·       We may share information about your COVID-19 symptom check responses and results and COVID-19 testing status and results with your employer in order support you and your employer’s decision-making regarding its workforce and ready-to-work status thereof.

·       We may also share your personal information in other ways with your consent.

·       We may also share aggregated and/or anonymized, non-personally identifiable information with third parties.

 

Security

We take reasonable measures, including administrative, technical, and physical safeguards, to help protect personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction.  Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure.  As a result, while we strive to protect your personal information, Company cannot ensure or warrant the security of any information you transmit to us or from our online products or services, and you do so at your own risk. 

Your Privacy Choices

How You Can Access and Update Your Information

You may update or correct information about yourself at any time or by emailing us at protectwell@uhg.com.    

Cookies

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject cookies; however, our Services may not function properly if you do so.

 

Options for Opting out of Cookies and Mobile Device Identifiers

 

If you are interested in more information about interest-based advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs.

Please note that even after opting out of interest-based advertising, you may still see Company’s advertisements that are not interest-based (i.e., not targeted toward you).  Also, opting out does not mean that Company is no longer using its tracking tools—Company still may collect information about your use of the Services even after you have opted out of interest-based advertisements and may still serve advertisements to you via the Services based on information it collects via the Services.

How Company Responds to Browser “Do Not Track” Signals

 

We are committed to providing you with meaningful choices about the information collected on our Site for third-party purposes, and that is why we provide above the Network Advertising Initiative’s “Consumer Opt-out” link, Digital Advertising Alliance’s Consumer Opt-Out Link, and TRUSTe’s Advertising Choices page.  However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations and solutions.  For more information about DNT signals, visit http://allaboutdnt.com.

 

Links to Other Websites

 

Our Services may contain links to other websites and those websites may not follow the same privacy practices as Company.  We are not responsible for the privacy practices of third party websites.  We encourage you to read the privacy policies of such third parties to learn more about their privacy practices.

 

Children

 

Company does not knowingly collect or maintain personally identifiable information from persons under 13 years of age without verifiable parental consent, and no part of the Services are directed at persons under 13.  If you are under 13 years of age, then please do not use the Services.  If Company learns that personally identifiable information of persons less than 13 years of age has been collected without verifiable parental consent, then Company will take the appropriate steps to delete this information.  To make such a request, please contact us at protectwell@uhg.com.

Your California Privacy Rights

 

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.  If you are a California resident and would like to request this information, please submit your request in an email to protectwell@uhg.com.

 

No Rights of Third Parties

 

This Online Privacy Policy does not create rights enforceable by third parties.

 

How to Contact Us

Please contact us with any questions or concerns regarding this Online Privacy Policy at:

UnitedHealth Group

5995 Opus Parkway

Minnetonka, MN 55343

Attention: General Counsel, Research and Development

Email: protectwell@uhg.com

Last updated on May 15, 2020.