Consumer Health Privacy Policy

Effective Date: March 31, 21024

LAST UPDATED March 31, 21024

Coordinated Care Corporation, together with its subsidiaries and affiliates (collectively, "Company" "us," "we," or "our") is committed to protecting the privacy of Consumer Health Data (i.e., health information relating to a reasonably identifiable consumer). This Consumer Health Privacy Notice describes how we process Consumer Health Data collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”); in-person interactions, events, and purchases; and other online and offline interactions.

Scope

This Consumer Health Data Privacy Policy applies only in limited circumstances when we may handle health information subject to the Washington My Health My Data Act (“Consumer Health Data”).  This Consumer Health Data Privacy Policy does not apply to most health data we handle, which is instead generally subject to the Health Insurance Portability and Accountability Act (“HIPAA”) as described in our main Privacy Policy.  This Consumer Health Data Privacy Policy also does not apply to data about our own employees, contractors, agents, or job applicants. 

Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us, you must obtain their consent (or have the legal authority without consent) to share their Consumer Health Data with us.

Changes

We may update this Consumer Health Privacy Notice from time to time. Any updated Consumer Health Privacy Notice will be effective when posted. Please check this Consumer Health Privacy Notice periodically for updates. If required by law, we will contact you directly to provide you with an updated Consumer Health Privacy Notice.

1. Sources of Consumer Health Data

We collect Consumer Health Data about you from the following sources:

  • Directly from you. We may collect Consumer Health Data you provide to us directly, such as when you contact us through our Digital Properties, interact with us in person, sign up for offers or newsletters, communicate with us, place or customize orders, or sign up for an account or other services.
  • Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information.
  • From third parties. We may collect Consumer Health Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies or other parties who interact with us.
  • From publicly available sources.  We may collect Consumer Health Data about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Consumer Health Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.

2. Types of Consumer Health Data We Collect

We may collect the following type of Consumer Health Data:

Inferences about health derived from other health or non-health data, such as action you take on our Digital Properties that may indicate an attempt to acquire health services or supplies.

3. How We Use Consumer Health Data

We may use Consumer Health Data for the following purposes:

  • To provide you products and services, such as making our Digital Properties, products and services available to you; registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you request; providing customer service; verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); hosting informational webinars; and providing similar services or otherwise facilitating your relationship with us.
  • For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records, such as accounting, document management and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
  • For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; improving our products or services; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
  • For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
  • In connection with a corporate transaction, such as if we acquire assets of another business, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

4. How We Disclose Consumer Health Data

We disclose the Consumer Health Data described above to third parties, including the categories of recipients described below:

  • Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
    • Centene Corporation
  • Law enforcement, government agencies, and other recipients
    for legal, security, or safety purposes,     such as when we share information to comply with law or legal requirements, to enforce or apply our Terms of Use/Terms of Service and other agreements or policies, and to protect our, our customers’, or third parties' safety, property, or rights.
  • Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
  • Business partners that we may use to perform the activities described in Section 5 (Cookies and Other Tracking Technologies) below.
  • Entities to which you have consented to the disclosure.

5. Cookies and Other Tracking Technologies

Our Digital Properties and authorized third parties use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Digital Properties, which may include Consumer Health Data. This section contains additional information
about:     

  • The types of tracking technologies we use and the purposes for which we use them
  • The types of information we collect using these technologies
  • How we disclose or make information available to others
  • Choices you may have regarding these technologies

A. Types of cookies and tracking technologies we use

We and the third parties that we authorize may use the following tracking technologies:

  • Cookies, which are a type of technology that install a small amount of information on a user's computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time.
  • Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms. In addition to the uses described below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
  • Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences on our Digital Properties

B. Purposes for using these technologies

We and authorized third parties use these technologies for purposes including:

  • Personalization, such as remembering language preferences and pages and products you have viewed in order to enhance and personalize your experience when you visit our Digital Properties;
  • Improving performance, such as maintaining and improving the performance of our Digital Properties; 
  • Analytics, such as analyzing how our websites are used. For example, we may use Google Analytics to help us improve the user experience.  Google Analytics may use cookies and other tracking technologies to perform their services.  To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners;  
  • Security, such as preventing fraud and malicious behavior

C. Information collected

These tracking technologies collect data about you and your device, such as your IP address, location cookie ID, device ID, operating system, browser used, browser history, search history, and information about how you interact with our Digital Properties (such as pages on our Digital Properties that you have viewed).

D. Disclosures of your information

We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Digital Properties, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Digital Properties. 

E. Your choices

You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Digital Properties’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of
all advertising, but rather only interest-based advertising from us or our agents or representatives.

6. Data Subject Rights

Washington consumers may have certain rights regarding your Consumer Health Data.  We will not discriminate
against you for exercising these rights:    

  • Right to Access. You may have the right to confirm whether we process your Consumer Health Data.
  • Right to Delete. You may have the right to request that we delete Consumer Health Data concerning you.
  • Right to Withdraw Consent. If you provided consent to process Consumer Health Data, you may have the right to withdraw such consent.
  • Right to Appeal. If we deny your rights request, you may have the right to appeal. We will inform you of our response.

You may exercise the rights available to you by emailing us at WACompliance@Centene.com.

7. Contact Information

If you have questions regarding this Consumer Health Privacy Notice, please contact us at:

WACOMPLIANCE@CENTENE.COM.