CLAIMSECURE PRIVACY NOTICE

EFFECTIVE DATE: November 30, 2020

The ClaimSecure and the ValueHealth programs (hereinafter referred to as the “ClaimSecure and ValueHealth Programs”) is offered by ClaimSecure Inc. and provides health benefit plan management and administration services to clients and to benefit plan members.

At ClaimSecure Inc. (“ClaimSecure”, “we” or “us”) we value the trust that our customers place in us to appropriately use and protect personal information. This Privacy Notice informs visitors and regular users of the ClaimSecure eProfileTM and ValueHealth Programs offered via the claimsecure.com, valueHealth.ca and valeur-sante.ca websites (collectively referred to as the “ClaimSecure Websites”) about the purposes for which ClaimSecure may collect, use, and share personal information, and how it is protected. We want you to be clear how we use personal information and the ways in which we protect this information. By using the ClaimSecure Websites, you accept the privacy practices presented in this Privacy Notice. We encourage you to read this Privacy Notice in full to understand our privacy practices before using the ClaimSecure Websites or submitting any personal information.

Scope

This Privacy Notice applies only to the ClaimSecure eProfileTM and ValueHealth Programs offered via the ClaimSecure Websites. ClaimSecure and its affiliates and subsidiaries may have separate websites, sub-domains, and services through other web, mobile, or cloud platforms that are not subject to this Privacy Notice. Additionally, ClaimSecure business partners, ad networks, and other third parties have their own websites and services with separate privacy practices. We encourage you to read the privacy notices of all websites, portals, and applications that you visit to understand their privacy practices.

Throughout this Privacy Notice, we use the term “personal information”, which is any information accessed, collected, or used by ClaimSecure that identifies an individual, or can reasonably be used to identify an individual, directly or indirectly. This may include, for example, your contact information, your account information and your health information. “Personal information” is equivalent to similar terms used in different regulations, such as “personally identifiable information (PII)” and “personal data.” This Privacy Notice does not cover information that is de-identified and/or aggregated and cannot be associated with an identifiable individual, since this information is not considered to be personal information.

Personal Information We Collect

When you use the ClaimSecure Websites, we may collect personal information about you. The personal information we may collect with your prior consent, where required by law, includes but is not limited to:

  • Your Complete Name and Initials
  • Your Email Address
  • Your Password Management Information and Security Questions and Answers
  • Your Date of Birth
  • Your Contact Information Including Full Billing Address
  • Your Direct Deposit bank account details and Credit Card Information including card holder name, expiration date and CVV, CVC2 or CID number (code verification value code)
  • Your Benefit Plan Sponsor
  • Information about your health that you choose to share with us, which may include information about your health conditions, medication purchases or underlying diagnosis
  • Your Marketing preference such as text message or email notification and frequency
  • Information about you that you share or make visible on the Internet. We may combine such information with information we already have about you.You do not have to provide us with this information if you do not want to; however, that may limit your ability to use certain functions or to request certain services or information.
  • We may collect non-personal information and it may be aggregated with other information. If we combine your non-personal information with personal information, the combined information will be treated as personal information.

Tracking Technologies We Use

We use various technologies to collect personal information about visitors to our ClaimSecure Websites. These technologies include the following:

  • Web server logs
    • As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data.
  • Cookies
    • We and our subsidiaries, business partners, marketing partners, affiliates, or other service providers may utilize cookies. Cookies uniquely identify your device or user account associated with the ClaimSecure Websites. You can control the use of cookies by adjusting your browser preferences at any time. If you reject cookies, you may still use the ClaimSecure Websites but your ability to use some features or areas of the ClaimSecure Websites may be limited.
    • Geo-location
    • When you enable a location-based service, we may collect information about your location, for example, as part of the “Find my Pharmacy” tool which is available to anyone accessing the ClaimSecure Websites. The “Find my Pharmacy” tool allows you to enter an address into the tool to obtain the list of pharmacies within a set distance of the address you have entered. In order to provide you with this service, the information you have entered is passed on to Google via the “Find my Pharmacy” tool we then embed a map that Google builds into our ClaimSecure Websites which shows the list of nearby pharmacies.
    • Provided that employers or brokers have received the consent from their employees or clients, the ClaimSecure Websites also make available a “Network Mapping” tool. The “Network Mapping” tool is intended to be used by brokers, sponsors and employers to determine the proximity of each of their plan members to a network pharmacy. Once the Network Mapping template is uploaded, the address information is sent to Google mapping service to provide geographic coordinates to determine the closest network pharmacy. A “Results File” is created once the upload is completed and denotes each address “in-network” if it is within a set distance to a network pharmacy or “out-of-network” if it is not. The “Results File” is created during the same session as a result of uploading the Network mapping template, and the user must remain in the session to retrieve the “Results File”. Neither file is retained by ClaimSecure nor google once the user exits the session.
    • We use various features to determine location, such as IP address, GPS signals, and sensor data from your device that may provide information on nearby Wi-Fi access points and cell towers. You may opt out of geo-location collection by changing the setting of your browser or device.
  • Other Tracking Technologies
    • The ClaimSecure Websites use Google Analytics, a Google Inc. (“Google”) provided web analysis service. To learn more about how Google Analytics collects and processes data, please visit Google’s website "How Google uses data when you use our partners' sites or apps" located at www.google.com/policies/privacy/partners/
    • We also use HTML5 (or any similar technology) to collect and store content information and preferences. Our third-party partners, who provide certain features on this ClaimSecure Websites or who display advertising, use HTML5 (or any similar technology) to collect and store information. Various browsers may offer their own management tools for removing HTML5 (or any similar technology).
    • These methodologies are used for the following purposes:
  • To register or sign in to the ClaimSecure eProfileTM and ValueHealth Programs or ClaimSecure Websites
  • To personalize your user service or provide you with customized site-content based on your preferences
  • To analyze trends
  • To provide you with customer and troubleshooting support
  • To provide you with marketing notices, newsletter, or communications via email, fax, mail, mobile badge notifications, or text message

We may receive reports based on the use of tracking technologies on an individual and aggregated basis.

How We Respond to “Do Not Track” Signals

Some web browsers have a “Do Not Track” feature. This feature allows you to tell websites you visit that you do not want to have your online activity tracked over time and across websites. These features are not yet uniform across browsers. The ClaimSecure Websites are not currently set up to respond to those signals.

Recording of Telephone Calls

ClaimSecure records telephone calls for quality assurance, training and conflict resolution purposes. Recorded telephone calls will involve the collection of an individual’s personal information, and ClaimSecure will use, disclose, protect and retain such personal information in accordance with this privacy policy.

How We Use the Personal Information Collected

Generally, personal information that is provided to ClaimSecure is used to determine eligibility under various benefit plans, to adjudicate and process claims, to administer health benefit plans, and to meet regulatory or contractual requirements. Personal information also includes records and data relating to the claims experience and history of benefit plan members.

In addition, we may use the personal information we collect for purposes such as:

  • To register your profile in the ClaimSecure eProfileTM and ValueHealth Programs
  • To personalize your user service or provide you with customized site-content based on your preferences
  • To provide you with customer and troubleshooting support
  • To provide you with marketing notices, newsletters, or communications via email, fax, mail, mobile badge notifications, or text message according to your preference
  • Provided that you have opted in and subject to your right to withdraw your consent to receive commercial electronic messages, to offer you the opportunity to voluntarily participate in surveys and to communicate and market existing and new products and services that may be of interest to you, including treatment alternatives, health-related benefits, and products and services offered by third parties
  • To present you with customized information and advertisements for promotions, drug product specific programs, financial savings opportunities and health educational events in which you may want to voluntarily participate, all based on information you voluntarily provide to us (e.g., through creating your eProfileTM)
  • To provide loyalty programs, promotions and other non-pharmacy related activities
  • To manage the ClaimSecure eProfileTM and ValueHealth Programs
  • Claim Submission
    • ClaimSecure will process health benefit claims that are submitted by benefit plan members, or by healthcare providers on behalf of benefit plan members and eligible dependents.
    • By utilizing the ClaimSecure/ValueHealth pay-direct card to authorize an electronic claim submission by a healthcare provider; by contacting ClaimSecure to obtain information regarding a benefit plan or a benefit plan claim; by accessing the ClaimSecure Websites; or by otherwise submitting a benefit claim to ClaimSecure, the claimant and benefit plan member authorize ClaimSecure, healthcare professionals (including but not limited to, pharmacists, dentists, physicians), insurance companies, administrators of government benefits or other benefit programs and other service providers working with ClaimSecure to exchange, utilize, and retain any necessary information regarding the claim, the claimant, the health benefit plan, and the benefit plan member for purposes of administering the health benefit plan or providing services that they have been contracted to provide.
  • Claims Audit
    • Conduct audits of claims submitted for purposes including, but not limited to, preventing and detecting fraud, waste and abuse. "Abuse" means practices, services or actions that, although not fraud, are inconsistent with sound medical, professional or business practice which result in unnecessary costs to the employee or eligible dependent, benefit plan or otherwise, and payments for services that are not medically necessary or which fail to meet the standard for healthcare. “Fraud” means an intentional act of deception, misrepresentation or concealment in order to gain something of value, including, for example, submitting claims for services not rendered, submitting claims for services at a higher rate than the actual provider costs, deliberately misrepresenting services, resulting in improper or overpayments to providers or benefit members. "Waste" means an overutilization of healthcare services that, although not fraud and not the result of criminal action, might directly or indirectly result in unnecessary costs to the benefit plan, including, for example, waste arising from billing and payment errors. By accessing the ClaimSecure Websites, or by otherwise submitting a benefit claim to ClaimSecure, the claimant and benefit plan member authorize ClaimSecure, and persons acting for ClaimSecure, to disclose this claim, or any personal information contained in this claim, to the benefit plan sponsor/employer for the purposes of reporting fraud, waste and abuse or any other type of suspicious claims. As well, ClaimSecure, or persons acting on its behalf, may be required or permitted by law to disclose this claim, and the information contained in this claim, to others without knowledge or the consent of the individual to whom the information relates.
  • Surveys
    • If you participate in surveys, we will request certain personal information from you. Participation in these surveys is completely voluntary and you have a choice whether to disclose this information. We may use a third-party service provider to conduct these surveys. We will not share the personal information you provide through a survey with other third parties unless we give you prior notice and choice.
    • We may also use the information collected for the following purposes:
  • Advertising
    • We may partner with a third party to manage our advertising. Our third-party partner may use cookies and other technologies to gather information about your activities to provide you advertising based upon your browsing activities and interests.

How We Share Personal Information Collected

  • We may share personal information with other ClaimSecure business units when permitted by law. Additionally, we may share your personal information with third parties only in the ways described in this Privacy Notice.
  • We may provide your personal information to third parties that provide services to help us with our business activities such as Moneris, Apple Wallet or Google Pay for processing payments or digital wallet services. These companies are authorized to use personal information about you only as necessary to provide these services to us.
  • Limited personal information may be disclosed to business partners whose products or services you indicate you wish to use. This may include value added products and services offered through the ClaimSecure Websites, Pharmacy-related services and discounts, Insurance services and health & wellness & lifestyle products o services and is done in an effort to assist you in engaging with those partners.
  • Some of our pages may utilize framing techniques, which allows us to display content to/from our partners while preserving the look and feel of our ClaimSecure Websites. If you choose to interact or share additional personal information via these frames, please be aware you are providing personal information to these third parties and not directly to ClaimSecure, and your personal information is subject to the privacy practices of these third parties.ClaimSecure may also need to share information with companies, organizations, or individuals outside of ClaimSecure if we have a good faith belief that access, use, preservation, or disclosure of that information is reasonably necessary to:
  • Meet applicable laws, regulations, legal processes, or enforceable governmental requests
  • Enforce applicable terms of service or terms of use, including investigation of potential violations
  • Detect, prevent, or otherwise address fraud, waste, abuse, or security or technical issues
  • Protect against harm to the rights, property or safety of our users, ClaimSecure, or the public as required or permitted by law
  • Engage in a merger, acquisition, reorganization, or sale of all or a portion of ClaimSecure assets.

Your Choice

Where appropriate or legally required, we will describe how your information we collect through the ClaimSecure Websites will be used, and will provide choices about whether to allow us to engage in that use. To exercise your choice, you may contact us to correct, update, amend, or request deletion of your personal information through the address listed in the Contact Information section below.

Where permitted in our legitimate interest, or with your prior consent and in accordance with the Canadian Anti-Spam legislation (“CASL”), we will use your name and email address to send our newsletter to you. You may choose to stop receiving our newsletter or marketing emails by updating your preferences directly in your account or by following the unsubscribe instructions included in these emails or contacting us using the contact information listed below in this Privacy Notice.

Your Rights

You can contact us directly any time at the address listed in the Privacy Office: privacy@ClaimSecure.com Contact Information section below to update your personal information or make another type of request regarding the information you know or believe the ClaimSecure eProfileTM and ValueHealth Program holds about you. Here are some rights that you may have according to where you are located:

  • Access
    • Subject to applicable law, you have the right to receive information about, and review in person, or obtain copies of, the personal information we maintain about you. We may charge you a reasonable fee as allowed by law to obtain this information.
  • Amendment or Deletion
    • Subject to applicable law, you have the right to request that we amend or delete your personal information.
  • Disclosure Accounting
    • Subject to applicable law, you have the right to request and receive a list of certain disclosures made of your personal information. If you request this list more than once in a 12-month period, we may charge you a reasonable fee as allowed by law to respond to any additional request.
  • Use/Disclosure Restriction or Objection
    • Subject to applicable law, you have the right to request we restrict our use or disclosure of your personal information for certain purposes. You also have the right to object to the processing of your personal information. We may not be required to agree to a requested restriction or objection. We will agree to restrict use, or disclosure of, your personal information provided the law allows it and we determine the restriction does not impact our ability to operate our business, provide diagnostic services, and comply with the law. Subject to applicable law, even when we agree to a restriction request, we may still disclose your personal information in a medical emergency and use or disclose your personal information for public health, safety and other similar public benefit purposes permitted or required by law.
  • Withdraw Consent
    • Subject to applicable law, you may withdraw your consent to our processing of your personal information. Note: withdrawal does not invalidate the consent-based processing that occurred prior to withdrawal.
  • Automated Decision Making
    • Subject to applicable law, if at any time the ClaimSecure Websites use automated decision making to process personal information, you have the right to object to the use of your personal information.
  • Data Portability
    • Subject to applicable law, you have the right to receive your personal information in a structured, commonly used, and machine-readable format.

These rights may be limited in some circumstances by local law requirements.

The ClaimSecure eProfileTM and ValueHealth Programs shall provide you with a response to any such request(s) without undue delay and in any event within 30 days of receipt of the request. That period may be extended by 30 days where necessary, taking into account the complexity and number of request(s). ClaimSecure shall inform you of any such extension within 30 days of receipt of the request, together with the reason(s) for the delay. If you make the request by electronic-form means, the information shall be provided by electronic means where possible, unless otherwise requested by you in written documentation.

You can also exercise the rights listed above at any time by going to the contact information at the bottom of this notice.

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection or privacy regulator.

Retention

We will retain your personal information to meet our contractual obligations to you and for as long as your account is active, is reasonably useful for commercial purposes, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Children’s Privacy

The ClaimSecure Websites are not intended for any user under the age of 18 and we do not knowingly collect personal information from children under the age of 18, unless such information is submitted by the broker, the plan administrator, the plan sponsor, or the child’s legal guardian. We request children under the age of 18 not submit any personal information through the ClaimSecure Websites.

How We Protect Your Information

The ClaimSecure eProfileTM and ValueHealth Programs have implemented programs to address the privacy and security requirements of protecting health information.

The ClaimSecure eProfileTM and ValueHealth Programs have also established appropriate physical, technical, and administrative safeguards to protect the personal information we collect from or about our users. We restrict access to personal information to ClaimSecure and its affiliates and their respective employees, contractors, and agents who need to know the information to process it for us, and who are subject to confidentiality obligations.

Any sensitive personal information (e.g., credit card number) will be transmitted in an encrypted form using SSL encryption. Notwithstanding our security safeguards, it is impossible to guarantee 100% security in all circumstances. If you have any questions about security or have reason to believe your interaction with us is no longer secure (for example, you feel the security of any account you might have with us has been compromised), you must immediately notify us of the problem by contacting ClaimSecure at 905-501-7898 or by sending an email to privacyofficer@ClaimSecure.com

Cross-Border Transfer of Personal Information

ClaimSecure does not transfer personal health information outside of Canada. When you use the ClaimSecure Websites, your personal information (not including any personal health information) may be transferred to another country where we or our service providers (such as Apple wallet or Google Analytics) operate, including the United States. These countries may have different data protection standards and privacy laws from your country of residence, but we will transfer and protect your personal information lawfully and in accordance to this Privacy Notice. We will have proper contracts or legal mechanisms in place (such as data protection agreements, Standard Contractual Clauses, EU-U.S. Privacy Shield, etc.) prior to transferring personal information to another country.

Changes to this Privacy Notice

We may periodically update this Privacy Notice to describe new features, products, or services we offer and how it may affect our use of personal information about you and your controls. Since we may change this Privacy Notice, we recommend you check the current version available from time to time. If we make changes to this notice, we will update the “Effective Date” at the beginning of this notice.

Privacy Office Contact Information

If you have questions or concerns about this Privacy Notice, our information handling practices, or any other aspect of privacy and security of your personal information, please contact us at: privacy@ClaimSecure.com

You may also call us at 1-888-513-4464

Or write to us at:

ClaimSecure Inc.

Privacy Officer

1 City Centre Drive, Suite 620

Mississauga, Ontario

L5B 1M2

For more information on your privacy rights, you may also contact the Federal Privacy Commissioner at:

Office of the Privacy Commissioner of Canada

112 Kent Street Place de Ville Tower B, 3rd Floor

Ottawa, Ontario

K1A 1H3

Or your provincial office of the Information and Privacy Commissioner for more information.

© 2019 CLAIMSECURE INC. ALL RIGHTS RESERVED.