Benefits Science LLC (“Benefits Science,” “We” or “Us”) is committed to respecting the privacy rights of visitors to the websites and portals operated by Benefits Science, including without limitation www.benefitsccience.com (the “Site”), the client portals set up for our health care organization clients (the “Portals”), all subdomains, all social media accounts (such as Linked In) held or operated by Benefits Science (collectively, the “Sites”), and all of the Benefits Science data analytics systems, applications, content and services (collectively, “Services”) made available or provided from the Sites. Each Portal is an Internet application that enables registered users to have secure web-based access to medical information, as provided by their employer/our health care organization client, and allows the registered user to use such medical information and personal information to run analytics reports, among other features and functionality. Benefits Science has adopted the privacy policies outlined below (this “Privacy Policy”), which serve as the basis for our use of personal information and protected health information in our business relationships through the Sites. This Privacy Policy is intended to comply with privacy laws applicable to Benefits Science and the operation of the Site, the Portal and the Services. However, this Privacy Policy does not replace or supersede any privacy obligations set forth in each Business Associate Agreement (“BAA”) signed by Benefits Science with respect to its health care clients.
WHAT TYPE OF INFORMATION DOES BENEFITS SCIENCE COLLECT?
We may collect three types of information from time to time about users: (1) “Personal Information” (such as name, company/employer, phone number, physical address, email address, IP address, session data for your log-in session, protected health information, and other account-related information); (2) “De-Identified Information” (such as non-identifiable statistical information on the Sites usage); and (3) “Aggregate Information” (such as information about how many users log on to the Sites on a daily basis):
Personal Information is collected online when users voluntarily submit non-public personal information by establishing an account, requesting information, sending or receiving electronic notices or other similar communications on the Sites. Only your IP address and/or user name would be collected automatically when you access the Sites or the Services for purposes of processing your login to your account in the Benefits Science Portal or enhancing your web site browsing via cookies or standard settings. Your Personal Information will be retained for fulfillment of the intended purposes for which such Personal Information is collected. We may obtain your protected health information, as a subset of Personal Information, from third parties in connection with the services We provide to our clients.
De-Identified Information is collected online information in which all personal and individually identifiable health information has been removed by Benefits Science. De-Identified Information is used in a collective manner for analyses and statistics in order to improve the Services. De-Identified Information does not personally identify a specific user.
Aggregate Information is non-identifiable (or anonymous) information about you, such as pages most frequently accessed by you. Aggregate Information is used in a collective manner, and no single person can be identified by that compiled information (for example, the number of people who logged into the Sites in a particular day). Aggregate Information does not personally identify a specific user.
We will establish minimum and maximum retention periods based upon the type of information collected (i.e., sensitivity), the intended purposes and as otherwise may be legally required.
Personal Information will NOT include any personal information posted or sent by or to you in any public forum (such as a comment box on a particular page or a social media account) on the Sites. Participation in such public forums requires the public release and dissemination of such information, and thus Benefits Science cannot commit to treating such information confidentially in the same manner that other personal information will be treated under this Privacy Policy. Participation in these features of the Sites is voluntary and thus your consent to certain terms is required before participation is allowed.
HOW DOES BENEFITS SCIENCE SECURE MY PERSONAL INFORMATION?
Benefits Science maintains commercially reasonable safeguards to ensure the security, integrity and privacy of the Personal Information provided by you. Such security safeguards are intended to be appropriate to the sensitivity of the Personal Information collected. To the extent that Benefits Science transfers any Personal Information to third parties, we will use commercially reasonable efforts to assure that such third parties to whom we may transfer any Personal Information have knowledge of our Privacy Policy and provide sufficient protection of such Personal Information. Benefits Science is committed to properly securing the Personal Information collected online. To help us accomplish this, we take the following steps:
We employ internal access controls to ensure that the only people who see your information are those with a need to do so to perform their official duties.
We train relevant personnel on our privacy and security measures and applicable legal requirements.
We physically secure the areas where we hold hard copies (if any) of the information that we collect online.
We regularly back up the information that we collect online to insure against loss.
We use technical controls to secure the information that we collect online as appropriate, including but not limited to: encryption, firewalls, and password protections.
We periodically test our security procedures to ensure personnel and technical compliance.
We disclose your Personal Information only to your employer and others to whom you have given consent, or as otherwise required or permitted by law.
We disclose the minimum amount of Personal Information as necessary for the particular purpose in compliance with applicable law.
The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), and certain privacy and security regulations promulgated by the U.S. Department of Health and Human Services to implement certain provisions of HIPAA and the Health Information Technology for Economic and Clinical Health Act, as modified by the Omnibus Final Rule (collectively the “HIPAA Requirements”), as well as other applicable federal and state privacy and security laws and regulations, regulate and limit the use and disclosure of protected health information (“PHI”). Benefits Science has established privacy practices with respect to any Personal Information, which contains protected health information in order to be compliant with applicable HIPAA Requirements, and, where legally required, enters into BAA agreements with health care organizations for which Benefits Science may store or process protected PHI.
Please note that Personal Information stored on the Sites will be collected, stored and processed in the United States of America.
DOES BENEFITS SCIENCE USE COOKIES TO COLLECT PERSONAL INFORMATION ON THE SITES?
The Sites may utilize a standard technology called a “cookie” to collect information about how the Sites are used. A “cookie” is a small text file placed on your hard drive by our web page server. These cookies do not collect Personal Information, only Aggregate Information.
Your browser is probably set to accept cookies. However, if you would prefer not to receive cookies, you can alter the configuration of your browser to refuse cookies. If you choose to have your browser refuse cookies, it is possible that some areas of our Sites or the Services will not function properly when you view them.
We do not combine Aggregate Information collected through cookies with other Personal Information to determine who you are or your e-mail or IP address. The Sites can access the Aggregate Information only from a cookie sent by the Sites. We cannot access other cookies sent by other websites or the information contained in those other websites. Additionally, we cannot learn your email or IP address through the use of a cookie.
You must specifically submit Personal Information to Benefits Science via the Services or the Sites. For example, in order to set up an account, you must voluntarily submit your name, your employer and email address to Benefits Science. We use cookies to track usage of the Sites and the Services and further customize your experience when you are visiting the Sites or using the Services. By tracking usage, we can best determine what features of the Sites and the Services best serve the users. Without cookies, the features would “forget” items that may be stored. The session information used by the Sites is deleted when your browser is closed.
When you visit the Sites, we automatically collect Aggregate Information about your visit. We can tell the type of computer, browser, and web service that you are using. We also know the date, time, and pages that you visit on the Sites and the geolocation of the device that you are using. Collecting this information helps us design the Sites and the Services to enhance your experience during access. We may use Aggregate Information for internal purposes, such as tracking demographic data and providing targeted content to make the Sites or the Services more useful to our visitors. The gathering of this Aggregate Information may be accomplished by the use of cookies.
In particular, Benefits Science may collect an IP Address from all visitors to the Sites. An IP Address is a number that is automatically assigned to your computer when you use the Internet. We use IP addresses to help diagnose problems with our server, administer our Sites, analyze trends, track users’ movement on the Sites, gather broad demographic information for aggregate use in order for us to improve the Sites, and deliver customized, personalized content. IP addresses, however, are not linked to Personal Information.
We may at times provide third parties with De-Identified Information or Aggregate Information about our users, as more fully set forth in this Privacy Policy. On those pages of the Sites not requiring your account login, you may decline to accept cookies sent by the Sites by selecting an option on your browser to reject cookies. However, some portions of the Sites may require account login or account registration in order to access those areas. In such case, we ask that you provide us with basic information on your account set-up page. Cookies enable our server to know that you are a registered user. Therefore, our registration system requires that you accept the cookies from the Sites. Other websites linked to the Sites also may send cookies; however we do not control such activities.
Benefits Science also may use a unique assigned number located with the Sites’ URL to determine each web site from which you navigated to get to the Sites. While this number may not be apparent to you, it does not contain your Personal Information.
HOW DOES BENEFITS SCIENCE USE PERSONAL INFORMATION?
Your privacy is important to us. We will use the Personal Information provided by you in accordance with good commercial practice and applicable law. If you provide us with your e-mail address (or have done so in the past), we will send notifications to you. When you set up your user account (and at any time thereafter), you view how Personal Information is shared from your account settings. Your email will be used for notifications only. Benefits Science does not share your public email address with others in its public forums.
We also may use information provided by you, for example, to provide notifications about certain features of our Sites or the Services to measure consumer interest in our various services, and to inform you about various products and services offered on the Sites. These offers may be based on information provided by you as well as information available from external sources. These e-mail offers will come exclusively from Benefits Science.
By providing information using the Sites or the Services, you warrant to Benefits Science that your Personal Information is reliable for its intended uses, accurate, complete and correct, and that you will promptly notify use if such Personal Information is no longer current or correct.
We also may use your Personal Information collected via the Sites in the performance of all Services in order to provide, maintain and improve our Services as well as to develop new products and services to be offered as part of the Services. For example, we may use Personal Information to analyze data, to improve our Services and to tune our outputs and reports based on a particular individual’s patterns of usage of our Services.
DOES BENEFITS SCIENCE SHARE YOUR PERSONAL INFORMATION WITH OTHERS?
As a general policy, Benefits Science does not share, sell or trade Personal information with third parties without permission from the user. However, we may provide your Personal Information to third parties directly involved in the operation, performance, support, hosting and/or maintenance of the Sites or the Services and each product or service offered on the Sites, including without limitation, our websites designers, hosts, service providers, technical consultants, and business partners. Any Personal Information, however, will be used by such organizations only to perform their functions and/or to provide services in support of the Sites or the Services, and as otherwise permitted by law or approved by you in accordance with this Privacy Policy. Aggregate Information or De-Identified Information may at times be shared with Benefits Science’s business partners and other third parties.
We reserve the right to assign or transfer your Personal Information to any successor in interest to our business associated with the Sites or the Services by merger, reorganization, sale of all or substantially all of our assets or equity interests or operation of law. We also may divulge Personal Information if such information is required for us to comply with any valid legal process, such as a subpoena, search warrant, statute or court order, or if we reasonably believe that you have commit unlawful acts or acts that may endanger the health or safety of another user or of the general public.
CAN I MAKE CORRECTIONS TO PERSONAL INFORMATION COLLECTED ONLINE?
Additionally, you may request to view the Personal Information collected about you through your use of the Sites operated by Benefits Science by accessing your user account on the Sites. If you prefer, you can send an e-mail to our Security Officer at the Contact Address below. If you send your request by email, we will likely send such Personal Information (or a summary thereof) to your email address on file for the account name in our database, or we will send the Personal Information to you in another secure manner. If at any time you wish to change, correct or update your Personal Information, or have it removed from our database, you may do so by accessing your user account on the Sites. You also may submit a change request to our Security Officer by sending an email to the Contact Address below.
WHO CAN I CONTACT AT BENEFITS SCIENCE IF I HAVE QUESTIONS ABOUT THIS PRIVACY POLICY OR ANY CHALLENGES AS TO COMPLIANCE?
We have designated our Security Officer, who can be contacted at the following address (“Contact Address”):
By Mail: Benefits Science LLC
295 Washington St., 8th Floor
Boston, MA 02108
By Telephone: (888) 767-2744
By Email: securityofficer@benefitsscience.com
Our Security Officer is accountable for Benefits Science’s compliance with this Privacy Policy and applicable federal and state privacy laws and regulations. If you have any challenge concerning our compliance with this Privacy Policy, or if you have any questions about Benefits Science’s purposes for the collection and retention of your Personal Information, then please contact our Security Officer at the Contact Address and provide a description of your concerns sufficient in detail to permit the Security Officer to investigate your concerns and contact you. It is our intent to make available to you through the Security Officer specific information about this Privacy Policy and our management of your Personal Information as may be required by applicable law.
Benefits Science uses a self-assessment approach to ensure compliance with this Privacy Policy and periodically verifies that this Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with applicable laws, including without limitation the safe harbor principles. We encourage you to raise any concerns using the contact information provided above.
DOES BENEFITS SCIENCE COLLECT PERSONAL INFORMATION FROM CHILDREN?
Benefits Science does not knowingly solicit data from children or knowingly market to children. Benefits Science is concerned about the safety of children and their use of the Internet. Therefore, in accordance with the U.S. Children’s Online Privacy Protection Act of 1998, we do not knowingly request or solicit personally identifiable information from anyone under the age of 13 without prior verifiable parental consent. In the event that we receive actual knowledge that we have collected such Personal Information without the required and verifiable parental consent, we will delete that information from our database as quickly as is reasonably practical.
WHAT ABOUT PRIVACY ON INTERNET WEBSITES LINKED TO THE SITES?
You should be aware that other Internet websites to which you hyperlink from the Sites may contain privacy statements that differ from our Privacy Policy. Benefits Science encourages you to read and understand such privacy policies and terms of use of any linked websites accessed by you. If you decide to access such linked websites and/or provide any personal information to such linked websites, you do so entirely at your own risk. Benefits Science is not responsible for such provisions, and expressly disclaims any and all liability related to such provisions.
WHAT ELSE SHOULD I KNOW ABOUT BENEFITS SCIENCE’S PRIVACY POLICY?
No transmission of data over the Internet is guaranteed to be completely secure. It may be possible for third parties not under the control of Benefits Science to intercept or access transmissions or private communications unlawfully. If you choose to visit the Sites or use the Services, your visit and any dispute over privacy is subject to this Privacy Policy, including but not limited to limitations of damages and application of the law of the State of Texas and the laws, regulations, ordinances and treaties of the United States of America.
WHAT IS THE EFFECTIVE DATE OF THIS PRIVACY POLICY AND HOW CAN CHANGES BE MADE?
This Privacy Policy was last modified on August 28 2018. This Privacy Policy has been adopted with the recognition that Internet technologies are rapidly evolving, and that underlying business models are still not established. Accordingly, these policies are subject to change at any time and Benefits Science expressly reserves the right to modify the terms of this Privacy Policy at any time and in our reasonable discretion, by posting a change notice to the home page of the Sites. Your continued use of the Sites or the Services following our posting of a change notice will constitute binding acceptance of this Privacy Policy and all changes thereto.