ActiveHealth’s Web & Mobile Privacy Statement

Welcome to ActiveHealth’s web and mobile experience. This ActiveHealth Web & Mobile Privacy Statement (the “Privacy Statement”) describes our practices in connection with information we collect through software applications (including mobile applications) and websites that we operate and that contain a link to this Privacy Statement (an “Application” or, together, the “Applications”). This Privacy Statement is designed to transparently describe our privacy practices, in a format that is easy to navigate, read, and understand. We are committed to treating your information with care and respect and managing our Applications in a manner which is compliant with law.

As you navigate our Applications and communicate with ActiveHealth (sometimes referred to as “we” “us” or “our”) via the Applications, we may ask you to disclose certain information so that we can provide you with the highest quality information and services. In order for you to make an informed decision about whether to disclose your information to us via the Applications, we are providing you with the following information about how we collect and use your information.

Any use of this site constitutes your agreement to this Web & Mobile Privacy Statement.

Collecting and Using Personal Information

When you visit and navigate our Applications and when you communicate with us via our Applications, we will not collect personal information about you unless you provide us that information voluntarily. Any non-public personal information that you may provide via our Applications may be used to verify you identity so that we can be sure that all of our communications with you are secure and confidential, and respond to inquiries or requests from you. (In some cases, and in all cases where required by law or regulation, you will be able to update the information that you provide to us either by sending us an e-mail or, where you have established personal profiles with us, by updating your profile online. Please refer to the specific pages where data is collected for more information.) Except in connection with the sale, transfer, merger, consolidation or other transaction involving all or a part of our company, ActiveHealth will not sell, license, transmit or disclose this information outside of ActiveHealth and its affiliated companies unless (a) expressly authorized by you, (b) necessary to enable ActiveHealth contractors or agents to perform certain functions for us, or (c) required or permitted by law. In all cases, we will disclose the information consistent with applicable laws and regulations and we will require the recipient to protect the information and use it only for the purpose it was provided. By "personal information," we mean data that is unique to an individual, such as a name, address, Social Security number, or telephone number. From time to time, we may request personal information from you at our Applications in order to deliver products, services or requested materials to you or respond to your questions.

Our Applications are not directed to and will not knowingly collect personally-identifiable information from minors under the age of thirteen (13) without their parents’ consent.

ActiveHealth does not serve advertising on our Applications. We do not engage online advertising service providers to serve ads on other sites, based on web pages you may have visited or your search engine activity. For this reason, it is not necessary for us to respond to “Do Not Track” signals.

What Type of Information is Contained in our Applications?

Our Applications contain information about your health that your health plan collects and maintains in connection with providing your health benefits. This information primarily consists of claims for reimbursement submitted by your health care providers. You can also add information to our Applications about your own health conditions and medical treatment. We encourage you to add your own information as this makes our Applications a more valuable tool for you. In addition, you may be able to use our Applications to communicate with ActiveHealth coaches to discuss your health conditions and goals.

Our Applications do not contain all of the information about your health. Among other things, they do not include information relating to sensitive medical conditions such as HIV/AIDS, treatment for sexually transmitted diseases, certain mental health care, drug or alcohol abuse, or family planning. It is important that you and your health care providers understand this limitation of our Applications and not use our Applications as the sole source of information about your health conditions or medical treatment.

How May The Health Information Contained Within Our Applications Be Used By ActiveHealth?

Our Applications serve as both a repository of your health information as well as a tool to inform you and your physicians about opportunities to improve your health. As new data is received, it is scanned in order to identify potential ways in which your health care may be improved. In addition, the claims data present in our Applications, as well as any information you provide on your own, may be utilized by ActiveHealth in connection with any other ActiveHealth programs or services that may be provided to you through your health plan. Such programs or services may include disease management services and/or health advocacy services.

How Does ActiveHealth Use and Disclose the Information in its Applications?

The information in our Applications is considered ""protected health information"" and its use and disclosure is restricted under the Health Insurance Portability and Accountability Act ("HIPAA"). As a result, ActiveHealth may use and disclose personal information in the course of running our health business or for purposes of payment or treatment including, but not limited to: conducting operational activities such as quality assessment and improvement; licensing; accreditation by independent organizations; performance measurement and outcomes assessment; health services research; disease management, case management and care coordination; data and information systems management; customer service; to facilitate the sale, transfer, merger or consolidation of all or a part of ActiveHealth Management or Aetna with another entity, to facilitate payment for your covered services; to conduct utilization and medical necessity reviews; responding to complaints, appeals and requests for external review; and disclosing information to doctors, dentists, pharmacies, hospitals and other health care providers who take care of you. We may disclose personal information to other covered entities or business associates of those entities for treatment, payment and certain health care operations purposes.

We also may disclose personal information in support of your employer’s administration of your benefits plan, as well as to researchers for research purposes (provided measures are taken to protect your privacy), business partners who provide services to us (provided they assure us they will protect the information), health care industry regulators (for example, state insurance departments), federal, state and local law enforcement officials, in legal proceedings and to address matters of the public welfare and public interest as required or permitted by law (for example, national security, threats to public health and safety, and child abuse). We may disclose health information about you to others involved in your health care such as a relative, a friend, the subscriber of your health benefits plan or another person that you identify, provided the information is directly relevant to that person’s involvement in your care or the payment for that care.

In all situations other than those described above, ActiveHealth will ask for your written authorization before using or disclosing personal information about you. If you have given us an authorization, you may revoke it at any time, if we have not already acted on it.

May I Change or Delete Information in the Applications?

You may change or delete any information in our Applications that you have provided.

You may not, on your own, change or delete any information that is included in our Applications from other sources. If you believe any information in our Applications is inaccurate or incomplete, you may contact the member services toll-free number contained within our Applications.

May a Minor Create a Record in the Applications?

A minor does not have access to our Applications. However, a parent or legal guardian has access to our Applications for his or her minor children. The parent, and not the minor, controls access to our Applications. As indicated above, certain information about sensitive health care services provided to minors is excluded from our Applications to ensure compliance with state medical privacy laws.

How Can I Discontinue Use of the Applications?

You may discontinue the use of our Applications at any time by calling member services toll-free number contained within our Applications. If you have authorized health care providers to access your website, this access will be automatically terminated once we receive your notice of discontinuance.

If you discontinue use of our Applications, ActiveHealth will save all of the information in our Applications for a period required by applicable law. You may request a copy of this information during the period when it is retained by ActiveHealth.

Your E-Mail

We welcome your comments or questions about our Applications and have provided e-mail boxes for that purpose. We will share your comments and questions with our customer service representatives and those employees most capable of addressing your questions and concerns.

Please note that your e-mail, like most, if not all, non-encrypted Internet e-mail communications, may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to us. For that reason, to protect your privacy, please do not use e-mail to communicate information to us that you consider confidential. If you wish, you may contact us instead via non-cellular telephone at the numbers provided at various locations on our Applications.

Collecting and using non-personally identifiable information

You should also be aware that when you visit our Applications, we collect certain non-personally-identifiable and aggregate information about you. This data helps us to analyze and improve the usefulness of the information we provide via our Applications. In order for you to make an informed decision about whether to use and navigate our Applications, we are providing you with the following information about how we collect and use non-personally identifiable and aggregate information. By “non-personally-identifiable information, we mean information that does not identify you personally, but provides us with anonymous "usage data," such as the number of unique visitors we receive, what pages are visited most often and the navigation preferences and characteristics of our visitors.

• Web browser information. Web browsers collect and store information about the type of device and operating system you are using to access our Applications, as well as your device’s MAC address for facilitating network communications. Accessing this information helps us to establish a secure and consistent connection to you during your visits to our Applications.


• "Cookie" technology. A "cookie" is an element of data that a website can send to your browser when you link to that website. It is not a computer program and has no ability to read data residing on your computer or instruct it to perform any step or function. By assigning a unique data element to each visitor, the website is able to recognize repeat users, track usage patterns and better serve you when you return to that site. The cookie does not extract other personal information about you, such as your name or address.


• Client-side page tagging. This technology uses code on each web page to write certain information about the page and the visitor to a log when a page is rendered to you by your web browser. "Tagging" does result in a JavaScript program running in your browser, but it is limited to providing information about the page that you are requesting and the configuration of your browser. It will not read any of your data files, nor execute any additional programs. It does not extract any personal information about you, such as your name or email address. You can prevent tagging by disabling JavaScript in your browser, but that may prevent you from using all of our Application's functions.


• Tracking pixels or beacons. These techniques use electronic files to track your navigation of our Applications, your completion of transactions and other browsing behavior.


• IP Address: When you subscribe to an Internet Service Provider (ISP), your computing device is assigned an IP Address. We track and store this address to help us manage security and monitor usage volume and patterns.

Linking to Other Sites

From time to time, our Applications may provide links to other websites, not owned or controlled by ActiveHealth, that we think might be useful or of interest to you. We cannot, however, be responsible for the privacy practices used by other website owners or the content or accuracy of those other websites. Links to various non-ActiveHealth websites do not constitute or imply endorsement by ActiveHealth of these websites, any products or services described on these sites, or of any other material contained in them.

Security

ActiveHealth has adopted and adheres to stringent security standards designed to protect non-public personal information on our Applications against accidental or unauthorized access or disclosure. Among the safeguards that ActiveHealth has developed for this site are administrative, physical and technical barriers that together protect our Applications and our other internal systems from unauthorized access or use. We periodically subject our site to simulated intrusion tests and have developed comprehensive disaster recovery plans.

You also play an important role in ensuring the security of our Applications. As part of our Applications’ registration process, you choose a password for accessing our Applications. You should not share your password with anyone. You should understand that if another person has your password they will be able to obtain access to our Applications as if they were you.

Changes to This Statement

ActiveHealth may change this Privacy Statement from time to time. We encourage you to periodically reread this Privacy Statement to see if there have been any changes that may affect you. This Privacy Statement is not intended to and does not create any contractual or other legal rights in or on behalf of any party.