Solera Health, Inc.’s Privacy Policy

 Effective Date: February 2016

This Privacy Policy applies to all visitors to, and users of, Solera Health, Inc.’s (“Solera,” “our,” “us,” or “we”) website www.SoleraNetwork.com (“Website”) and related services (collectively, “Solera’s Products and Services”).

Solera respects the privacy of all visitors and users of Solera’s Products and Services and is committed to protecting privacy through our compliance with this Privacy Policy.  We understand that Personal Information and Protected Health Information (both, defined below) are private, and we are dedicated to maintaining the accessibility, confidentiality and integrity of all such information.  Users, subject to review and acceptance of this Privacy Policy, will have the option, using a user name and password subject to certain security criteria, to access and use Solera’s Products and Services.

Your Consent To This Privacy Policy

5.3.1. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our Privacy Policy, your choice is not to use Solera’s Products and Services By using our website, you agree to our Privacy Policy and our Terms of Use.

We may change this Privacy Policy and our Terms of Use from time to time, and while we will do our best to notify you of any changes it is your responsibility to review this Privacy Policy and the Terms of Use periodically.  Your continued use of Solera’s Products and Services after we make changes is deemed to be an acceptance of those changes, so please check our Privacy Policy periodically for updates.  When we do change the Privacy Policy or Terms of Use, we will also update the “Effective” date on the relevant document and may notify you or post a message via our Website.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of Solera’s Products and Services.  This Privacy Policy describes the types of information we may collect from you or that you may provide, and our practices for collecting, using, maintaining, protecting and disclosing that information.  At all times, we will only use or disclose your Personal Information and Protected Health Information (both, defined below) to the extent minimally necessary for the intended use or disclosure.

The Privacy Policy applies to information we collect:

Personal Information

As used in this Privacy Policy, “Personal Information” means any information that may be used to identify an individual, such as your first and last name, age, gender, postal address, e-mail address, telephone number, other contact information, certain health information, or other personally identifiable information under an applicable law such as the Health Insurance Portability and Accountability Act (“HIPAA”) or an equivalent State law governing the use or disclosure of health information.  When you use Solera’s Products and Services, we may collect, use or disclose your Personal Information but only to the extent minimally necessary and consistent with our Notice of Privacy Practices.  If you so authorize, you acknowledge that we may collect this Personal Information from you directly or from third parties that you authorize to share Personal Information with Solera.  It is entirely your choice whether or not to provide Personal Information through Solera’s Products and Services.  If you choose not to provide requested Personal Information, you may not be able to use certain features of Solera’s Products and Services.

Protected Health Information

As used in this Privacy Policy, “Protected Health Information” means Personal Information in conjunction with information related to physical or mental health, such as medical history, family history, medical diagnosis, health background, current health status, age, gender, sexual behavior and sexual orientation, demographic information (including race, ethnicity, marital status, salary, education, political, religious, and trade union information) and information related to the diagnosis and treatment of health conditions, over-the-counter and prescription medications, laboratory test results, payments for treatment and health insurance information or other personally identifiable information under an applicable law such as HIPAA or an equivalent State law governing the use or disclosure of Protected Health Information and as defined by HIPAA.  When you use Solera’s Products and Services, we may collect, use or disclose Protected Health Information but only to the extent minimally necessary and consistent with our Notice of Privacy Practices.

Upon obtaining your express authorization, you acknowledge that we may collect this Personal Information from you directly or from third parties that you may authorize to share Personal Information with Solera.  We may ask you or authorized third parties to provide Protected Health Information about you that will enable us to enhance our ability to serve your needs and/or your use of Solera’s Products and Services.  It is entirely your choice whether or not to provide Protected Health Information through Solera’s Products and Services.  If you choose not to provide requested Protected Health Information, you may not be able to use certain features of Solera’s Products and Services.

Accessing and Correcting Your Personal and/or Protected Health Information

You can review and, subject to applicable laws, change your Personal Information by accessing Solera’s Products and Services via your secure user name and password.

You may also send us an e-mail at myprivacy@soleranetwork.com or call us at (602) 443-5260 to request access to, correct or delete any Protected Health Information, subject to applicable laws.

We may not be able to accommodate a request to change Personal or Protected Health Information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Technical Information

We may collect and use technical data and related information, including but not limited to technical information about your device (e.g., manufacturer, service provider, IP address, operating system, browser type, mobile number) system and application software, peripherals and your interactions with Solera’s Products and Services including automatically recording the dates and times of visits to Solera’s Products and Services, traffic data, and your search queries (“Technical Information”).  Technical Information is gathered periodically to facilitate the provision of software updates, product support, product enhancements and other services to you (if any) related to Solera’s Products and Services, to estimate our audience size and usage patterns, store information about your preferences (allowing us to customize our products and services according to your individual interests), speed up your searches, and recognize you when you return to our Website and/or use Solera’s Products and Services.  We may also automatically receive and record information on our server logs from your browser or mobile device, which could include your IP address, cookie information, browser information and the pages you visit/request.  Solera does not consider nor intend Technical Information to constitute Personal or Protected Health Information.  Solera may use the Technical Information in any manner it deems appropriate and lawful.

Choices About How We May Use Or Disclose Your Information

We strive to provide you with choices regarding your Personal and/or Protected Health Information.  We have created mechanisms to provide you with the following control over your Information.  You can set your browser to refuse all or some browser cookies (described below) or to alert you when cookies are being sent.  If you disable or refuse cookies, please note that some parts of Solera’s Products and Services may then be inaccessible or not function properly.

We may use your Information to contact you about our own and third-parties’ products and services that may be of interest to you.  The technologies we use for this automatic data collection may include:

How We May Use or Disclose Your Information

Except as described in this Privacy Policy or in our Terms of Use, Personal Information, Protected Health Information, Technical Information, Location-Based Information and Behavior Tracking Information (collectively, “Information”) that you provide or that we collect from third parties, will be kept confidential and used or disclosed only to the extent minimally necessary to support Solera’s Products and Services.  Solera’s Products and Services exist to streamline the patient consumer healthcare experience and help our partners – health plans, providers and community partners – identify qualifying regulatory benefits.  Solera’s proprietary SaaS platform connects a nationwide network of community organizations and digital solutions for chronic disease prevention programs (including the CDC National Diabetes Prevention Program) with technology that manages service referrals, reimbursement and payment, aggregates data, and simplifies enrollment and supporting increased consumer engagement and choice.  In order to provide for these types of exchanges, we need to ensure that each user that contributes Information expressly permits the uses or disclosures we envision.  For this reason, we need a license from you to use or disclose Information, whether collected directly from you or, if applicable, third parties that you identify.  You hereby grant Solera a non-exclusive, transferable, sub-licensable, royalty free license to use Information in order to enable, provide and make improvements to Solera’s Products and Services.  The license is non-exclusive (meaning you are free to license the Information to anyone else in addition to us), fully-paid and royalty-free (meaning that we are not required to pay you for our use of the Information), sub-licensable (so that we are able to use affiliates and subcontractors), transferable (meaning that we may transfer it to a third party should we restructure our business), irrevocable (meaning that you may not revoke or rescind such license for any reason once the Information is uploaded) and worldwide (because the Internet is, and Solera’s Products and Services may be, global in reach).

You also grant Solera a perpetual, non-exclusive, transferable, sub-licensable, royalty free license to use such Information and other data we collect in order to collect, develop, create, extract or otherwise generate statistics and other information and to otherwise compile, synthesize and analyze such Information and de-identified data (“Blind Data”).  Notwithstanding anything to the contrary in this Privacy Policy, to the extent Solera collects or generates Blind Data, such Blind Data will be owned solely by Solera and may be used for any lawful business purpose without a duty of accounting to you, provided that such data is not personally identifiable and does not identify the source of such data.

We may use or disclose your Information only to the extent minimally necessary:

How We Secure Your Information

We have implemented reasonable and appropriate administrative, technical, and physical safeguards designed to protect the Information from unauthorized access, use or disclosure.  All Information you provide to us is stored with an authorized cloud services provider.  These safeguards include, without limitation, encrypting all Personal Information and Protected Health Information.

The safety and security of your Information also depends upon you.  Where we have given you (or where you have selected) a user name and password to access Solera’s Products and Services, you are responsible for keeping this information confidential.  It is in your best interest that you not share your user name or password with anyone.

Please keep in mind that whenever you voluntarily disclose Information on message boards or other public forums or features or through e-mail or group messaging, that Information can be collected and used by others to whom you may or may not have given consent.  In short, by posting Information online that is publicly accessible (i.e. within message boards and the like), you may receive unsolicited messages from other parties in return or make others aware of your location.  We are not responsible for the security or privacy of any Information you choose to submit outside the scope of Solera’s Products and Services.

Third-Party Products, Services and Technologies

We may provide links to third-party websites within Solera’s Products and Services.  Such links may appear as a specific domain name or URL.  Please be aware that other websites and services, including the websites of third parties that you connect with through Solera’s Products and Services, may collect personally identifiable information about you.  This Privacy Policy does not cover the information practices of those third-party websites, services or applications and cannot control and is not responsible for the information collection practices of any such websites, services or applications.  We encourage you to carefully review the terms of use, privacy policies, and any other legal notifications on such websites before using or providing information through such websites, services or applications.

International Transfers

Information collected from you may be stored and processed in the United States or any other country in which Solera or its affiliates, subsidiaries, agents or contractors maintain facilities.  If you are accessing Solera’s Products or Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your data to the United States and processing globally.  By providing your Information you consent to any transfer and processing in accordance with this Privacy Policy.

HIPAA

Physicians or other health care providers, to the extent they are “Covered Entities” under HIPAA (as such term is defined in HIPAA), likely have their own privacy and security obligations with respect to your Personal Information and Protected Health Information.  For more information regarding your rights under HIPAA, see www.hhs.gov/ocr/privacy/.

Do Not Track Policy

Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to digital services that a visitor does not want to have his/her online activity tracked.  If a digital service that responds to a particular DNT signal receives the DNT signal, the browser can block the digital service from collecting certain Personal Information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform.  For this reason, we and many other digital service operators do not respond to DNT signals.

Children’s Privacy Policy

Solera’s Products and Services are not designed or intended to be accessed by children under the age of 13.  No one under age 13 may provide any information to or through Solera’s Products and Services.  If you are under age 13, do not provide any information on or through Solera’s Products and Services, including, but not limited to, your name, address, telephone number, e-mail address, user name, health information or other.  We do not intentionally collect Personal Information directly from children under the age of 13 through Solera’s Products or Services.  We also do not collect any Protected Health Information from anyone under 18 unless expressly authorized under Federal and equivalent State law.  No one under age 18 may provide any health-related information to or through Solera’s Products and Services unless Solera confirms that such disclosure would comply with applicable Federal or State laws.

If we learn we have collected or received Personal or Protected Health Information from a child under age 13 without verification or parental consent, we will delete that information and take other appropriate measures.  If you believe that we may have collected any information, including Personal or Protected Health Information, directly from a child under age 13, please contact us immediately at myprivacy@soleranetwork.com or (602) 443-5260.

Changes to Our Privacy Policy

It is our policy to post any changes that we make to our Privacy Policy on this page and on our home page.  If we make material changes to how we treat our users’ Personal or Protected Health Information, we will notify you by e-mail to the primary e-mail address you have provided and/or through a notice on the home page of our Website.  The date our 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 e-mail address for you, and for periodically visiting our Website and this Privacy Policy for changes.  For any questions or comments regarding this Privacy Policy, please contact us at myprivacy@soleranetwork.com or call us at (602) 443-5260.