Privacy Policy - NeueHealth

Last Updated: August 14, 2024

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NeueHealth, Inc. (“NeueHealth”) understands the importance of your privacy and takes our responsibility to protect your information seriously. This Privacy Policy (the “Policy”) describes the types of information we collect from you through your access and use of any of the NeueHealth websites (including neuehealth.com, pmacare.com, associatesmd.com, centrumhealth.com), engage with our Consumer Care or NeueHealth businesses, when you interact with us, or otherwise communicate with us (collectively, the “Services”). This Policy also describes how we use and disclose this information, and certain rights and options you have regarding your information. Use of each of our websites and related services is also subject to the applicable Terms and Conditions.

By providing us with personal information or using the Services, you expressly consent to the information-handling practices described in this Policy. If you do not agree with this Policy, please do not use the Services or provide us with your information.

Patient Records

This Policy is in addition to, and does not replace, our Notice of Privacy Practices, which explains how our care businesses use and disclose patients’ protected health information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). To the extent of a conflict between the terms of this Policy and the Notice of Privacy Practices with respect to PHI, the Notice of Privacy Practices will control how our providers use and disclose your PHI. Please review the Notice of Privacy Practices that corresponds to the location where you are a patient for complete information on the use and release of PHI. Speak with your provider about any concerns you may have regarding your medical records.

Important Information About This Policy

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time, or to create additional policies, in order to accurately reflect changed circumstances or new legal requirements. As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information.

To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates. We also ask that, where we have an ongoing relationship with you and any of the data you have provided becomes no longer accurate, you keep us informed of this so we can amend our records accordingly.

Personal Information We May Collect or Receive About You

For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual.

The types of personal information we collect includes the following categories:

Contact information – first name, last name, email address (personal or business), mailing address (personal or business), billing address (personal or business), telephone number (personal or business), and employer and employment details.
Account information – if you register to use a patient portal, your username, account password, account number, and other information that we may request or that you may provide relating to your account.
Care-related information – if you are a patient receiving care, we may collect certain information in the course of providing our website that will be available via your patient portal, including a list of medical conditions that physicians have diagnosed, self-assessment data (such as information you self-report about how you feel and your demographic information), insurance data (such as your insurance carrier, insurance plan, member ID, group ID, health plan ID).
Transactional information – details about your, your employer’s, or your insurance carrier’s, transactions with us, including method of payment, payments received, payment details, transaction history, procedure and treatment information, and other health plan required information.
Financial information – if you are required to pay for our services, your bank account or payment card details and billing information (which is collected and processed by a third-party payment processor on our behalf).
Marketing information – details regarding informational and promotional materials you may have requested or received from us, our services in which you are interested, your receipt of promotional communications, and information on your marketing or communication preferences.
Portal content – details of any communications, questions, chats, texts, phone calls, video calls, or other inquiries you submit or engage in with a provider via any patient portal made available on the provider’s website. Note, we may collect transcripts of any video or phone engagements with a provider for the purposes of creating a record of that interaction as part of your medical record. Please review the Notice of Privacy Practices for the location where you are a patient to learn more about the rights you have with respect to your PHI.
Communication information – details of any communications or inquiries you submit to us, including technical or customer support requests, through email, calls, chatbots or similar software tools, or other features available in our website.
Job applicant information - If you are a job applicant, we may also collect information about you that you submit to us via through our websites. In addition to your contact information, we may collect your education and previous employment information, as well as any resumes, cover letters, or other relevant documents, in connection with your application.
Device and usage information – details regarding how and when you use our website, including the device used to connect to our website, your internet protocol (“IP”) address and device identifier (including ad ID), the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our website, and information about your interaction with our website.

We collect this information when you access, use, or navigate our website, fill in forms on our website, access the patient portal offered on our website, request information via our website, communicate with us or a provider (including by phone, email, chat, or otherwise), interact with any chatbot or similar features available on our website, visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.

Note, patient portals have features and functionalities that allow for you to interact and communicate with your provider. The collection of PHI and your rights with respect to such information is described in further detail in the Notice of Privacy Practices for the location where you are a patient.

Please note that we may aggregate or anonymize the foregoing types of data such that they are no longer capable of identifying you, in which case they are no longer considered “personal information” for the purposes of this Policy.

Automatically Collected Usage and Device Information

Like most website operators, we use various technologies to automatically collect the following types of information about you:

Cookies. Cookies are small text files that a website transfers to a visitor’s device for recordkeeping purposes. We use cookies to personalize visitors’ experiences on our websites, provide content that we believe may be of interest, track visitor trends and patterns, engage in marketing and advertising, and otherwise analyze our website traffic. NeueHealth employs cookies in order for its servers to recognize a return visitor as a unique user. The cookies placed by NeueHealth are readable only to NeueHealth, and cookies cannot access, read, or modify any other data on a computer. Web browsers may offer the option to refuse cookies. If a visitor refuses a NeueHealth cookie, NeueHealth does not gather any information on that visitor, but doing so will require you to re-enter certain information at each visit, or prevent us from customizing the website’s features according to your preferences. You may also delete a cookie manually from your hard drive. We may link the information we store in cookies to other personal information we collect or receive about you. For further information about cookies, including how to refuse cookies, please visit www.allaboutcookies.org. Please note that if cookies are disabled, you may not be able to enjoy certain features of our website.
Pixels, tags, and web beacons. Some NeueHealth websites may also use “pixels,” “tags,” or “web beacons.” These technologies are small pieces of code that run when a website page or email is loaded. They are used to monitor the behavior of the website visitor or email recipient—such as what icons were clicked or whether links in an email were opened—and gather analytics. For example, when a visitor arrives at the neuehealth.com homepage, a pixel may run and generate information based on the visit, and then this information is processed by us or our vendors. Pixels work in conjunction with cookies to let us know what portions of our website are of interest to you and to help us provide you with tailored information from our website. If you turn off cookies, pixels, tags, and web beacons may still detect certain information about your interaction with our website and disregard any cookie-prohibitive markers or signals. Please note that pixels, tags, and web beacons may transmit information regarding website visitors to third parties, who may then use that information for marketing, tracking, or other similar purposes. For example, many social media platforms make various pixels available to businesses to enable businesses to track advertisement conversions and the social media platform, in turn, may use this information to improve the success of its targeted advertisements. To disable cookies, pixels, or web beacons, and to otherwise limit the ability of third parties to target you with advertisements across various websites or platforms, please view the privacy and advertising settings for your social media account, email account, and device.
Log file information. Log file information is automatically collected from your browser or mobile device each time you access NeueHealth’s website and services. When you use our websites, our servers automatically record certain log file information. These server logs may include anonymous information such as your web request, device type, operating system type, IP address, mobile device identifier provided by your mobile device operating system, browser type, domain name, pages viewed, referring / exit pages and URLs, open and click engagement, as well as the language your system uses and the country and time zone where your device is located.
Analytics. Our websites may also use third-party analytics tools, such as Google Analytics. You can find more information about how data is collected and processed in connection with the Google Analytics service here. You can also read Google’s privacy policy here. Visit Google’s My Ad Center to learn more about how you can control the ads you see.

The information collected through these technologies may be combined with personal information. We may share information about your use of our websites with our analytics partners, who may combine it with other information that you previously provided to them.

Information from Other Sources

We may obtain both personal and non-personal information about you from affiliates, business partners, vendors, contractors, suppliers, and other third parties and add it to other information we have collected. For example, if you are a patient, we may receive information about you from your other healthcare providers. We, and the third parties we engage, may combine information we collect from you over time, and across our websites, with information obtained from other sources. This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.

Information from Social Media

If you interact with us on any social media platform: (i) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (ii) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts. Social media platforms operate independently from us and we are not responsible for the personal information that you choose to submit or link on any social media platform. We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.

How We Use Your Information

We (or the service providers acting on our behalf) use the personal information identified above for the following purposes:

Providing patients our Services, including access to care and their information via patient portals.
Sending patients and other users of our Services communications about their upcoming appointments, including via text message or email.
Facilitating the ability for providers to provide care to patients, including assisting those providers with creating medical records and administering patient care.
Negotiating, entering into, and managing our business relationship and agreements with our organizational partners and customers.
Making our website available to those patients, caregivers, and other users who are invited to use the website by their healthcare provider, health plan, pharmacy, or friend or family member.
Providing and optimizing your experience on our website and ensuring that our content is presented to you in the most effective manner.
Performing that portion of our Services that is intended to collect data that is used to assist with a patient’s medical or health care.
Communicating with you, including responding to your inquiries or questions regarding any issues you are experiencing.
Sending you promotional or informational communications and solicitations, tracking your marketing preferences, and for our internal marketing purposes.
Managing customer service issues, including issues relating to the performance of our Services and customer feedback.
Troubleshooting and resolving any technical issues with our websites or other software services.
Developing, updating, and improving our Services, customer service, and customer experience, and otherwise improving our knowledge and insights regarding users.
If you are a job applicant, to process your application, including set up interviews and communicate with you regarding your application.
Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with our websites or the use of our Services.
Enforcing our agreements with you or our organizational partners, complying with our legal or regulatory obligations, and defending or advancing legal claims.
Notifying you about changes to our Services or material changes to this Policy.
Providing you with surveys or otherwise soliciting feedback from you.
Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

For more information about your options relating to your personal information and your communication preferences, see “Your Choices About Collection and Use of Your Information” below.

Our Marketing Efforts

We may send you direct marketing communications from time to time including news, updates, offers, and other announcements relating to our business. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing communications from us, then you can always unsubscribe using the option provided in the communication you have received (e.g., in the footer of the email) or by contacting us using the information below.

Disclosure of Your Information

When the information we collect is aggregated, anonymized, or otherwise does not identify you, it is no longer considered “personal information.” We may use such information for any purpose or disclose it to third parties, to the extent permitted by applicable law.

In addition, we may disclose your information to the following types of persons:

Those of our affiliates and related entities who are healthcare providers, and with whom we partner to provide the Services or who may have services that are of interest to you.
Service providers we use to facilitate our business operations and administer our Services. These third parties have access to your personal information only to perform specific tasks on our behalf. For example, our service providers include (i) IT and system administration providers, (ii) our website developers and consultants, (iii) data storage providers, and (iv) vendors to facilitate payments and payment processing.
If you are using our Services as a patient, your healthcare provider or health plan and their personnel, staff, and third-party service providers.
If you authorize us to disclose information to those in your family or those in your long-term care facility, we may disclose your personal information to such caregivers. You can revoke your consent to this kind of disclosure at any time.
If you have been authorized by a patient to interact with us in the caregiving role, we will disclose your personal information to such patient, as well as their healthcare provider or health plan.
Marketing and advertising vendors that may assist with lead generation, hosting information relating to customers and business partners and potential customers or business partners, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
Analytics vendors in order to understand our website traffic and usage patterns, optimize our website, and identify potential new users.
Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
Our professional advisors, such as lawyers, accountants, and other similar advisors.
If you are a job applicant, our Human Resources vendors, service providers, personnel, and staff.
Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
Other parties for any purpose we disclose at the time you provide the information.

Protection of Personal Information

We use administrative, technical, and physical measures to protect your personal information from loss, theft, or unauthorized use, disclosure, or modification. Please be aware that no data transmission over the Internet is 100% secure. While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.

Your Choices About Collection and Use of Your Information

We respect your right to make choices about the ways we collect, use, and disclose your information, so we try to offer you meaningful choices regarding your personal information. Some choices you have regarding personal information include the following:

Marketing Emails – As required by applicable laws, you can opt-out of receiving promotional emails from us by clicking the “opt out,” “unsubscribe,” or similar link in any such promotional emails and following the instructions provided.
Cookies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same. Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Services.
Analytics – As discussed above, we use analytics tools in connection with the Services. If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use. You can find more information on how Google uses information it collects here.
Declining to Provide Information – You can choose not to provide us with information we may request through our Services, but that may result in you being unable to use certain features of our website, request information about our Services, or initiate other transactions with us.
Do Not Track Mechanisms – Please note that our website does not honor “Do Not Track” signals, and such signals will not impact the operation of the website.

In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.

Children’s Privacy

Our websites are general audience websites and are not directed at children under the age of 13. Accordingly, we do not knowingly collect personal information from children under age 13 through any of our websites. Should we discover that a child under age 13 provided us with personal information, we will use that information only to inform the child that we must have parental consent before receiving such information.

Direct Access to Other Sites

NeueHealth offers direct links to other websites that are independent of NeueHealth’s websites. Other websites may not follow the same privacy guidelines as NeueHealth. We are not responsible for and have no control over the content, acts, or privacy policies of the websites to which NeueHealth provides direct links. A link to a website does not constitute an endorsement of that website or the entity that controls the website.

Changes to This Privacy Policy

This Policy may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of the Services after any changes is deemed to be acceptance of those changes. Accordingly, we encourage you to check this Policy periodically for updates.

How to Contact Us

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

NeueHealth Group, Inc.
Email: compliance@neuehealth.com