Introduction
HealthEdge Software, Inc. (“we”, “us”, “our” or “HealthEdge”) respects your privacy. This policy describes how we collect, use, disclose, and process personal information in connection with our websites and webpages (collectively “Website“) and other websites we own and operate that link to this Privacy Policy (including Wellframe, available at https://www.wellframe.com), and the related content, platform, services, products, and other functionality offered on or through our services (“Services”). It does not address our privacy practices relating to HealthEdge employees and other personnel.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. This policy may change from time to time (see Changes to Our Privacy Policy).
HIPAA Covered Information
In certain situations, we function as a service provider for our business customers (e.g., health plans) pursuant to the Health Insurance Portability and Accountability Act (“HIPAA”). In the course of providing services for our business customers, we may collect your personal information on their behalf pursuant to our contracts with them, including HIPAA business associate agreements. This Privacy Policy does not apply to our collection and processing of this data. We recommend referring to the privacy notice, including the HIPAA Notice of Privacy Practices, of the entity with which you have a relationship (e.g., your health plan) for information on how they engage service providers, like us, to collect and process such data on their behalf.
Children Under the Age of 16
Our Website is not intended for children under 16 years of age. No one under age 16 may provide any information to the Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website. If we learn we have collected or received personal information from a child under 16, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected].
What is Personal Information
When we use the term “personal information” in this Privacy Policy, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or any other data or information that constitutes “personal data”, “personal information,” or “personally identifiable information” under applicable privacy laws.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Website, including information:
- Such as first and last name, postal address (in whole or in part), personal or business email address, telephone number, employer, role, any other identifier by which you may be contacted online or offline;
- Provided in custom messages sent through forms, in chat messages, to one of our email addresses, or via phone. This also includes contact information provided on our Website. We use this information to investigate and respond to your inquiries, to communicate with you, to enhance the services we offer to our users and to manage and grow our organization;
- Information that is about you but generally does not identify you individually, such as cookies, pixels, tags, beacons, scripts, or other tracking technology (“Tracking Technologies”) placed by us (or our partners) on our Website or by our partners on third-party websites; and/or
- Information you provide us as a job applicant, such as employment history, education, background, resume, CV, cover letter, professional references, or social media accounts like LinkedIn.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties, for example, our business partners.
Information You Provide to Us
The information we collect on or through our Website may include:
- Information that you provide by filling in forms on our Website. This includes information provided at the time of requesting further information. We may also ask you for information when you report a problem with our Website.
- Information you provide while communicating with our Website chat bot. We may use this information to communicate with you and answer any questions you may have about HealthEdge or our solutions.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your search queries on the Website.
Information We Collect Through Automatic Data Collection Technologies
We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our Website, read our emails, or otherwise engage with us. We typically collect this information through Tracking Technologies and we may use third-party partners or technologies to collect this information. Information we collect automatically about you may be combined with other personal information we collect directly from you or receive from other sources.
The Tracking Technologies we use for this automatic data collection may include:
- Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies through the cookie consent banner made available on our Website or by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies that are necessary for parts of our website to function when you direct your browser to our Website.
- Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit HealthEdge, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
We, and our third-party partners, use Tracking Technologies to automatically collect usage and device information, such as:
- Information about the way you access and use our services, for example, the site from which you came and the site to which you are going when you leave our services, how frequently you access the Website, whether you open emails or click the links contained in emails, whether you access the services from multiple devices, and other actions you take on the Sites.
- Information about how you use the Website, such as the pages you visit, the links you click, the ads you view and click on, videos you watch, and other similar actions. We may also use third-party tools to collect information you provide to us or information about how you use the Website and may record your mouse movements, scrolling, clicks and keystroke activity on the Website and other browsing, search or purchasing behavior. These tools may also record information you enter when you interact with our Website or engage in chat features through our Website.
- Information about the computer, tablet, smartphone or other device you use, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other such information. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices.
- Information about your location, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate or infer a device’s location by analyzing other information, like an IP address.
- Analytics information. We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the services and to understand more about the demographics of our users. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its opt-out options at https://tools.google.com/dlpage/gaoptout.
All of the information collected automatically through these tools allows us to improve your customer experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Website, and to improve the effectiveness of our Website, offers, advertising, communications and customer service. We also use this information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including targeted content and advertising; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our services.
If you would prefer not to accept cookies, you can manage your preferences through the cookie consent banner on our website and most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies; however, doing so may negatively impact your experience using the services, as some features and services may not work properly. You may also set your e-mail options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our e-mail and performed certain functions with it.
We and our third-party partners may also use cookies and tracking technologies for advertising purposes. For more information about tracking technologies, please see Third-Party Use of Cookies and Other Tracking Technologies below.
Below are some links to external resources you may find helpful regarding how different browsers handle Tracking Technologies. These resources are completely external to HealthEdge and HealthEdge makes no guarantees or warranties as to their content. If your browser is not listed below, you should consult the documentation that your browser’s provider makes available.
We may link or combine the personal data we collect about you and the information we collect automatically. This helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to deliver a better, more personalized experience.
- Speed up your searches.
- Recognize you when you return to our Website.
Third-Party Use of Cookies and Other Tracking Technologies
We may participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third-party services, to collect information about your use of our online services over time so that they may play or display ads on our Services, on other websites or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through tracking technologies, such as cookies, web beacons, embedded scripts, location-identifying technologies, and similar technology, which recognize the device you are using and collect information, including click stream information, browser type, time and date you visited the Sites, AdID, precise geolocation and other information. We may share a common account identifier (such as a hashed email address or user ID) with our third-party advertising partners to help identify you across devices. We and our third-party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research. We may also use services provided by third parties (such as social media platforms) to serve targeted ads to you and others on such platforms. We may do this by providing a hashed version of your email address or other information to the platform provider.
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android). You may also manage your preferences through the cookie consent banner on our Website, and may be able to opt-out of some — but not all — interest-based advertising served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.
Disclosure of Your Information
We may also share, transmit, disclose, grant access to, make available, and provide personal information with and to third parties, as follows:
- Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, chat technology, analytics services, employment application-related services, payment processing services, and administrative services.
- Business Partners: From time to time, we may share personal data with our business partners or we may allow our business partners to collect your personal information. Our business partners will use your information for their own business and commercial purposes, including to send you any information about their products or services that we believe will be of interest to you.
- Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency, bankruptcy or receivership.
- Legal Obligations and Rights: We may disclose personal information to third parties, such as legal advisors and law enforcement:
- in connection with the establishment, exercise, or defense of legal claims;
- to comply with laws or to respond to lawful requests and legal process;
- to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
- to detect, suppress, or prevent fraud;
- to protect the health and safety of us and others; or
- as otherwise required by applicable law.
- With Your Consent: We may disclose personal information about an individual to certain other third parties or publicly with their consent or direction. For example, with an individual’s consent or direction we may post their testimonial on our Sites or service-related publications.
Data Retention
We will usually store the personal information we collect about you for no longer than necessary to fulfil the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal data for longer periods of time, until set retention periods and deadlines expire, for instance where we are required to do so in accordance with legal, tax and accounting requirements set by a legislature, regulator or other government authority.
To determine the appropriate duration of the retention of personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of personal data and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Email Communications Preferences. You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in such communications. You may not opt-out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Services, technical and security notices).
- Modifying or Deleting Your Information. If you have any questions about reviewing, modifying, or deleting your information, you can contact us directly at [email protected]. We may not be able to modify or delete your information in all circumstances.
Additional California Consumer Privacy Rights (CCPA) Disclosures and Rights
The following personal data elements we collect may be classified as “sensitive” under the CCPA (“sensitive information”):
- Social security, driver’s license, state identification card, or passport number;
- Account log-in in combination with password or credentials allowing access to an account;
- Precise Geolocation
- Racial or Ethnic Origin
- Religious or Philosophical Beliefs
- Contents of a Consumer’s Mail, Email, or Text Messages (unless the company is the intended recipient of the communication)
- Biometric information for the purpose of unique identification;
- Health Information; and
- Information concerning sex life or sexual orientation.
We use this sensitive information for the purposes set forth in the Information We Collect About You and How We Collect It section of our Privacy Policy. Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to limit, or withdraw your consent for, our processing of sensitive information (as described in more detail below).
CCPA “Sale” or “Share” Notice – In the previous 12 months, we may have sold or shared the following categories of information (as each term is defined in the CCPA), to our third-party business partners:
- Identifiers
- Contact information
- Internet or other electronic network activity information
- Professional or employment-related information
The categories of third parties to whom we may sell or share the personal data include:
- Business and Marketing Partners (if applicable)
- Online Advertising Networks and Analytics Providers
- Social Networks
Your California Privacy Rights
If you are a resident of California you have the following rights under the California Consumer Privacy Act (“CCPA”):
- THE RIGHT TO NON-DISCRIMINATION for exercising your CCPA rights;
- THE RIGHT TO KNOW about the personal information a business collects about you and how it is used and shared;
- THE RIGHT TO DELETE personal information we collect from you (with some exceptions); and
- THE RIGHT TO OPT-OUT OF SALES of your personal information for monetary or other valuable consideration.
- The Right to Opt Out of the SHARING of your personal information for cross-context behavioral advertising purposes (targeted advertising).
To submit a request, please see the sections below for more information. When you submit a request, we may need additional information about you in order to sufficiently verify your request. Depending on the request, verification may require your legal name, email address, zip code, company, or phone number. If a third party is making the request on your behalf we will require proof that the third party is authorized to act on your behalf, in compliance with the CCPA. By sharing this information with us, you consent to us contacting you to fulfill your request.
The Right to Non-Discrimination
We understand privacy is important and we will not discriminate against you for exercising any of your CCPA rights.
The Right to Know & The Right to Delete
To exercise the rights to know and delete, you can contact us at [email protected] or write to us at the address in the Contact Us section. Please note that in certain instances we may not be able to fulfill your request. This may be for reasons including not having information about you, not being able to verify your request, or because we have to maintain your information to meet legal requirements. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.
The Right to Opt-Out of Sale of Sharing for Targeted Advertising
For California residents, we may share your information with our business partners, which may qualify as a “sale” under California law. A sale of information under the CCPA is broader than how you might commonly understand the term. Under the CCPA, “sale” includes the traditional exchange of money but it also includes any sort of benefit we may receive in exchange for your personal information. This means a CCPA sale may include instances where we co-host a webinar with a business partner and share the attendee list between hosting entities. We also share your personal information with AdTech providers. As a result, we provide the right to opt-out to comply with the CCPA and its definition of “sale” of personal information. In addition, we “share” your personal information with third parties for cross-context behavioral advertising purposes (targeted advertising). The third parties to whom we sell or share personal information may use such information for their own purposes in accordance with their own privacy policies.
To exercise any of these rights please contact us at [email protected]. To appeal a decision regarding a consumer rights request contact us at [email protected].
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at:
HealthEdge, Attn: Privacy Officer, 30 Corporate Drive, Burlington, MA 01803 or [email protected]
Last Updated: 2/21/2024