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 We Value Your Privacy This legal notice applies to the entire contents of this Website and to any correspondence between HealthierCompany LLC trading as HealthierCompany, its associated companies and approved agents ("us" or "we") and you. This Privacy Policy applies to information collected through the website HealthierCompany (the "Website") and information collected through other channels, and covers the following: What personally identifiable information is collected by HealthierCompany LLC or by any third party through our Website; How HealthierCompany LLC uses this information; With whom HealthierCompany LLC may disclose this information; What choices are available to you as a user of the Website with respect to collection, use and distribution of the information; What types of security procedures are in place to protect the confidentiality and integrity of information under our control; and How you can correct any inaccuracies in the information. Please read these terms carefully before using this Website or submitting your personal data to us. Using this Website or otherwise submitting your personal data to us or agreeing to submit your personal data to us indicates that you accept the terms of this Privacy Policy. Policy Please read the following Policy to understand how we use and protect the information that you provide to us. By registering with us, by completing any of our assessment tools or by submitting your personal data in any other way, you consent to the collection, use and transfer of your information under the terms of this Privacy Policy. However, if at any time you have any queries or concerns about our use of your personal information, please contact us. Sensitive personal data: we wish to draw your attention to the fact that as part of our collection of data, you will be asked to supply some sensitive personal data. Personal Identifiable Information (Personal Information) Personally Identifiable Information (or Personal Information) is information that we collect about you that can be used to identify or contact you, as well as other personal data, including, but not limited to, your assessment results and medical history. While some of the Personal Information provided by you or collected by us in this website may be health information, HealthierCompany LLC is not subject to the Privacy and Security Rules applicable to a “covered entity,” as defined at 45 C.F.R. § 160.103, under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). HealthierCompany LLC may, however, be subject to some of the HIPAA rules and regulations as a “business associate” of a covered entity and will comply with such rules and regulations under those circumstances. Even though HealthierCompany LLC is not subject to the HIPAA Privacy and Security Rules, it is our policy to maintain the privacy and security of your Personal Information in accordance with industry best practices; many of which are consistent with the principles underlying HIPAA. Information Collection and Use The collection of information on the website includes, but is not limited to, the following stages: anonymous information, subscription and registration, and health risk assessment. Anonymous information. First, we collect anonymous, aggregate information (such as domain name or IP address) from all visitors to the website. This type of information is never linked to any personally identifiable information and is only used for internal purposes to help us improve your user experience, including to generate statistical reports about the use of our website. Cookies Cookies are small computer files that we transfer to your computer’s hard drive that allow us to know how often someone visits a website and the activities they conduct while on that website. Your internet browser software can be set to reject all cookies. Most browsers offer instructions on how to reset the browser to reject cookies. If you reject our cookie, certain functions and conveniences of our website may not work properly but you do not have to accept our cookie in order to productively use our website. Web Usage Data With or without cookies, our Website keeps track of usage data, such as the source address that the page request is coming from (i.e. your IP address and/or domain name), date and time of the page request, the referring website (if any) and other parameters in the URL (e.g. search criteria). We use this data to better understand website usage so we know what areas of our Website users prefer. This information is stored in log files and is used for aggregated and statistical reporting. Subscription and Registration Second, we require the submission of a working e-mail address for you to register to use the website or receive notices about the Website. Registration for HealthierCompany LLC's services does not require you to submit any other personal identifiers such as name, address, telephone number, or social security number. We use the Personal information that you provide through registration to deliver relevant content and respond to questions from you and/or inform you of material changes to this Privacy Policy. We may also use this information to send you email with special promotions or newsletters with content that we think may be of interest to you. If you wish to unsubscribe from our communications to you and do not wish us to contact you in future, please let us know at any time by contacting us via the 'Contact Us' page of the Website and we will comply with your request.You may also elect to voluntarily submit additional Personal Information, for example your name, or photo, in order to enhance your profile on the website. Submission of these personal identifiers is strictly voluntary. Health Risk Assessment HealthierCompany LLC will collect other information, some of which may be Personal Information, which you voluntarily provide to us when you choose to register for and use some of HealthierCompany LLC's services, such as health risk assessment. This may include, but is not limited to, specific information regarding medical conditions, lifestyle, diet, exercise habits, drug and alcohol usage, workplace matters, demographic information (such as gender, age, ethnicity, country of birth, country of residence) and other relevant Personal Information relating to your wellness. We may also collect information you provide voluntarily through responses to surveys and questionnaires. Surveys On a regular basis HealthierCompany LLC may request information from you via surveys. Participation in these surveys is completely voluntary and it is your choice whether or not to disclose your information. The requested information typically includes contact information (such as name and address) and demographic information (such as gender and age). Personal information is not shared with third parties unless we give you prior notice and you are given the opportunity to opt-out of such information sharing programs. Public Forums HealthierCompany LLC may feature public forums, such as web chats and blogs, where users can share information or where users can post questions for other community members to answer. You should be aware that any information shared in a bulletin board, online discussion, or other public forum is public information and may be seen, disclosed to or collected by third parties that do not adhere to nor are subject to our Privacy Policy. You should think carefully before disclosing any Personal Information in any public forum. Use of your information We may use your personal information for the following purposes: accounting, billing and audit, credit or other payment card verification, security, administrative and legal purposes, systems testing, maintenance and product development, customer relations, in carrying out obligations under contracts entered into between you and us and to help us in any future dealings with you. Disclosure of Your Personal Information Unless we receive your permission, HealthierCompany LLC will not sell, rent, or share Personal Information to or with any third party not affiliated with or owned by HealthierCompany LLC, with the following exceptions: Third Party Wellness Providers: HealthierCompany LLC may disclose your Personal Information to third parties who provide disease management, health management, behavioral coaching, or similar wellness-related services (“Third Party Wellness Providers”), subject to any contractual restrictions or conditions between HealthierCompany LLC and such Third Party Wellness Providers. These Third Party Wellness Providers are separate and distinct entities completely independent from HealthierCompany LLC. These Third Party Wellness Providers may contact you to market their services to you. If you agree to accept the services offered by the Third Party Wellness Provider, such agreement is solely between you and the Third Party Wellness Providers. HealthierCompany LLC is not responsible for the privacy practices of the Third Party Wellness Providers. Provision of Service: HealthierCompany LLC may disclose your Personal Information with third parties to provide you with a product or service that you have requested from us. Agents and Contractors: In order to provide you with the services on the website, we may disclose your information to our agents, contractors, or service providers who perform services on our behalf, such as incentive fulfillment, web hosting, or data storage. These third parties may also collect information on our behalf. HealthierCompany LLC will ensure that any agent, contractor, or service provider to whom we share information agrees to the same restrictions and conditions that apply through this Privacy Policy to HealthierCompany LLC with respect to such information. Covered Entities: HealthierCompany LLC may disclose your personal information to a “covered entity,” as defined at 45 C.F.R. § 160.103, under HIPAA, if necessary to comply with a business associate agreement, as defined at 45 C.F.R. § 160.103, entered into by HealthierCompany LLC with a covered entity. Use and Disclosure of Aggregate Information: We may store information that we collect through log files to create a profile of our users. Log files record internet protocol (IP) addresses, browser types, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the website, track a customer’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to personally identifiable information. A profile is stored information detailing how individual customers use the website. HealthierCompany LLC may provide to third parties, including to our corporate sponsors, non-personal information about you in a profile that does not allow you to be identified or contacted and that is combined with the non-personal information of other users (“Aggregate Information”). For example, we might inform third parties regarding the number of users of our website and the services they utilize while on our website. Depending on the circumstances of each instance, we may or may not charge third parties for this Aggregate Information. We also may not limit the third parties’ use of the Aggregate Information, except that we do require third parties to whom we disclose Aggregate Information to agree that they will not attempt to make this information personally identifiable by combining it with other databases or otherwise. Sharing Information with Corporation Customers In many instances, our services are made available to end-users (like you) through the websites of our corporate customers (e.g. employers, health plans and consultants). Unless we receive your permission, we do not share with our corporate customers any of your Personal Information that we may collect. However, we may share Aggregate Information (as described above) with such corporate customers. Such information is never disclosed in a level of detail sufficient to permit the identification of any particular individual.HealthierCompany LLC cannot and does not control the collection and usage of Personal Information by our corporate customers through mechanisms that are not within our control or supervision. We can offer no assurance that the privacy practices of such corporate customers will be similar to ours. To the extent that you are accessing the website through an employee or health plan beneficiary portal or other third party website, we strongly encourage you to review and understand the privacy policies of such organizations prior to providing information to us or them that you consider to be sensitive or personal in nature. Additional Uses of Your Personal Information Administrative Notices HealthierCompany LLC reserves the right to send you specific administrative notices about your registration or subscription or to contact you if required by law. You may not opt-out of these kinds of communications. Emails and Newsletters: During program registration and at various times as you use the Website, you may have the option of receiving emails or newsletters directly from HealthierCompany LLC or third parties who are participating in research, marketing surveys, and similar activities. You may elect to opt-in or opt-out of these communications by placing a check mark beside a statement that expresses a preference for receiving these communications or participating in these activities. In order to provide you with enhanced functionality and services, we may seek your permission to share your Personal Information with contractors and/or Third Party websites. You are not obligated to opt-in to such programs. Additional information about our other services and products will be sent to you only if you have expressly chosen to receive such information. If you do not wish to receive website newsletters or additional information you may remove yourself from communication lists easily by following instructions within the newsletters. Third Party Products and Services: We may also enter into arrangements with our partners and other vendors where we agree to promote third-party products and services directly (e.g. through targeted mailings, telephone calls or other communications) to our users without sharing your Personal Information. You have the option of remove yourself from these lists easily by following the instructions that will accompany any such communications. Links This Website contains links to other websites, including links to sponsors and partners (including our corporate customers). HealthierCompany LLC is not responsible for the privacy practices or content of these other websites. We encourage you to be aware when you leave our Website and to read the privacy statements of each and every Website that collects personally identifiable information. This Privacy Policy applies solely to information collected by our website. Third party contact details As part of our assessment process we may request or you may volunteer contact details of a third party for confirmation of your information. It is your responsibility to inform any third party, whose contact details and personal information you provide to us, that you have disclosed this information. You should obtain the prior consent of any such third party before disclosing their personal information. If we have contacted you as a result of your details being disclosed to us by a participant in the assessment process, we confirm that we will use your personal details and any information that you subsequently submit to us in accordance with this Privacy Policy. User submissions Users of our Website are prohibited from posting or transmitting to or from this Website any unlawful, threatening, libelous, defamatory, obscene, pornographic or other material that would violate any law. Retention and storage of your information We generally keep your personal details indefinitely for the purposes that we have mentioned. However, in certain circumstances we may destroy or delete any of your personal information that we hold. Please note that our policies on privacy will be overridden where we are required or permitted to disclose personal information under law or the terms of any court order. Checking your details You are entitled to see the information that we hold about you. You may ask us to make any necessary changes to ensure that your information is accurate and kept up-to-date. If you wish to verify the details you have submitted to us, you may do so by contacting us using the contact details at the end of this notice. Changes to our privacy policy We may update the privacy policy from time to time. When we make a material change to the Privacy Policy a notice will be posted on our Website together with the updated privacy policy. Security HealthierCompany LLC maintains administrative, physical, and technical safeguards to reasonably and appropriately protect the confidentiality, availability, and integrity of your Personal Information. For example, we maintain data in secure locations with access limited to authorized personnel and all of our employees are kept up-to-date on our security practices. While we encrypt sensitive data, such as Personal Information, using SSL or VPN whenever it is transmitted over the Internet, we cannot completely ensure the privacy of e-mail communications to and from our website because they are not encrypted and, therefore, not secure. Given the nature of the Internet and the fact that network security measures are not infallible, we cannot guarantee the security of your information. We maintain notification procedures as part of our information security policy, to be used in the event we become aware of a material data security breach. If we are required to provide notice to you of a data security breach, the notice will be provided in electronic form at the email address you have provided to HealthierCompany LLC. Compliance with our security policies is periodically audited by our technical staff and we continually assess the adequacy of, and where appropriate improve, our security controls and procedures. HealthierCompany LLC employees and our third party service providers must abide by this policy and those who violate it are subject to corrective action, up to and including termination of employment or other legal action as permitted by law. When registering for access to a secure area of the Website, we will ask you to select a username and password. We recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited email. Also, remember to sign out of the registered website and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence when accessing your computer. If you have any questions about the security at our website, you can send a message to customer support at support@healthiercompany.com. HealthierCompany LLC is committed to complying with the privacy principles of the Safe Harbor (see http://export.gov/safeharbor). Correcting, Updating, and Deleting Personal Information Users are able to self administer key privacy settings via the website in order to keep their Personal Information private. You can always contact us in order to delete any of your Personal Information from our systems or if your Personal Information on the website is incorrect. We will make the requested correction or deletion within two (2) business days. You should be aware that, if our website was made available to you by a corporate customer that is sponsoring your usage of the website, your eligibility to receive promotional benefits from such parties, if any such benefits are offered, may be adversely affected by your election to remove your Personal Information from our systems. You must contact the sponsoring organization directly for further information. Notification of Changes If we decide to change our Privacy Policy, we will post the changes on this page with an updated effective date, and we may post a notice on the website’s main page and other pages to alert you about the change. If the privacy policy changes materially so that we are going to use your personally identifiable information in a manner different from that stated at the time of collection, we will notify you by either sending you an email or by posting a notice on the website’s main page. However, if you deleted and deactivated your account, then you will not be contacted. Contact Information If you have any questions or concerns about this Privacy Policy, please feel free to contact us.support@healthiercompany.com Unsubscribe If you wish to unsubscribe from our communications to you and do not wish us to contact you in future, please let us know at any time by contacting us via the 'Contact Us' page of the Website and we will comply with your request.
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