NeoCare Solutions℠ Privacy Policy

Aetna INC is concerned about privacy issues and wants you to be familiar with how we collect, use and disclose information. This Privacy Policy describes our practices in connection with information that we collect through the NeoCare Solutions℠ website (including any successor website(s) thereto, the (“Site”). By accessing or using the Site, or providing information to us in connection with the Site, you agree to the terms and conditions of this Privacy Policy.

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third party, including, without limitation, any healthcare providers, any health benefits plan sponsor or administrator and, if applicable, any app marketplace or hardware provider, such as Apple, Inc. or Google Inc.

We may change this Privacy Policy at any time. Please take a look at the “LAST UPDATED” legend at the top of this page to see when this Privacy Policy was last revised. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available through the Site.Your use of the Site or the submission of any information in connection with the Site following such changes means that you accept the revised Privacy Policy.

Jurisdictional Issues

The Site is controlled by us from the United States; accordingly, this Policy, and our collection, use and disclosure of your Personal Information and Health Information, is governed by U.S. law, and not by the laws of any country, territory or jurisdiction other than the United States. We do not represent or warrant that the Site, or any functionality or feature thereof, is appropriate or available for use in any particular jurisdiction. Those who choose to access or use the App do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. By using the App and submitting any Personal Information or Health Information, users from outside the United States acknowledge that the Site is subject to U.S. law and consent to the transfer of Personal Information and Health Information to the United States, which may provide a different level of data security than in their country of residence, and waive any claims that may arise under their own national laws.

Personal Information

There are two categories of personally identifiable information that we may collect from you or from people whom you ask to upload data in connection with the Site, or that, in certain instances, we may receive from your health benefits plan sponsor or administrator.

First, there is Health Information, which relates specifically to the care or treatment of your child, and which is subdivided into Protected Health Information and Additional Health Information, as fully defined below.

Second, there is Personal Information, which is a broader category that includes Health Information as well as other personally identifiable information that is not related to the care or treatment of your child.

Personal Information We May Collect

“Personal Information” is information that identifies you or your child as an individual. We and our service providers may collect Personal Information from you including, but not limited to, the following examples:

IF YOU SUBMIT ANY PERSONAL INFORMATION OR HEALTH INFORMATION RELATING TO ANYONE ELSE OTHER THAN YOURSELF TO THE SITE, YOU REPRESENT THAT YOU HAVE THE NECESSARY AUTHORITY TO DO SO.

Protected Health Information, Additional Health Information and Other Information, as defined below, may be collected in connection with the Site in addition to Personal Information. The definition, collection, use and disclosure of such information are addressed separately below under the headings “HEALTH INFORMATION” and “OTHER INFORMATION”.

How We May Use Personal Information (Other Than Health Information)

We and our third-party service providers may use such Personal Information:

How Personal Information (Other Than Health Information) May Be Disclosed

Your Personal Information may be disclosed:

If we combine any Personal Information with any information such that the combined information meets the definition of Protected Health Information or Additional Health Information, as set forth below, then the combined information will be treated by us as Protected Health Information or Additional Health Information, as applicable, as long as it is so combined.

Health Information

There are two categories of Health Information that we and our service providers may collect through the Site: Protected Health Information and Additional Health Information.

“Protected Health Information” is individually identifiable health information that is created or received by a covered entity (for example, a health care provider or health plan) and which relates to the past, present or future physical or mental health or condition of an individual, the provision of health care to an individual, or the past, present or future payment for the provision of health care to an individual. Protected Health Information is further defined by the federal Health Insurance Portability and Accountability Act of 1996 (HIPAA) and is subject to the protections of HIPAA. We and our service providers may collect Protected Health Information in connection with the Site.

“Additional Health Information” is information that does not fall within the category of Protected Health Information above (typically because it was not created or received by a provider or health plan), but that is the combination of Personal Information with information related to past, present or future physical or mental health or conditions, the provision of health care to an individual, or the past, present or future payment for the provision of health care to an individual. We and our service providers may collect Additional Health Information in connection with the Site.

How We May Use Protected Health Information and Additional Health Information

We and our third-party service providers may use Protected Health Information and Additional Health Information:

How Protected Health Information and Additional Health Information May Be Disclosed

Your Protected Health Information and Additional Health Information may be disclosed:

Other Information

Other Information We May Collect

“Other Information” is any information that does not reveal your specific identity, such as:

How We Collect Other Information

We and our third-party service providers may collect Other Information in a variety of ways, including:

How We Use and Disclose Other Information

Please note that we may use and disclose Other Information for any purpose, except to the extent we determine that we are required to do otherwise under applicable law. If we so determine that we are required to treat any Other Information as Personal Information under applicable law, then, in addition to the uses listed in the “How We Collect Other Information” section above, we may use and disclose such Other Information for all the purposes for which we may use and disclose Personal Information.

In some instances, we may combine Other Information with Personal Information and/or Health Information (such as combining your zip code with your name, or with your name together with a medical condition). If we combine any Other Information with Personal Information and/or Health Information, then the combined information will be treated by us as Personal Information or Health Information, as applicable, as long as it is so combined.

Third Parties

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including our third-party service providers (including cloud service providers such as Amazon Web Services LLC), any healthcare providers, Insurers and, if applicable, Apple Inc., and any other third party operating any software application or website to which the Site contain a link. The inclusion of a link on the Site does not imply endorsement of the linked software application or website by us or by our affiliates.

Security

We seek to use, within Aetna INC, reasonable physical, technical and administrative measures to protect Personal Information and Health Information under our control. Unfortunately, no data transmission over the Internet or data storage system is guaranteed to be 100% secure. Please also be aware that we may use third-party cloud service providers (such as Amazon Web Services LLC) that provide hosting, data storage and other services pursuant to standard terms and conditions that are generally non-negotiable; these service providers inform us that they apply security measures they consider adequate for the protection of information within their system.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

Choices and Access

Your choices regarding our use of your Personal Information, Protected Health Information and Additional Health Information

You may opt-out from certain uses of Personal Information, Protected Health Information and Additional Health Information as set forth below.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you do opt-out of receiving educational-related e-mails from us, we may still send administrative messages to you; you cannot opt-out from receiving administrative messages. Please also note that if you opt-out as described above, we will not be able to remove your Health Information from the databases of plan sponsors or administrators with which we have already shared such Health Information (i.e., to which we have already provided such Health Information as of the date that we implement your opt-out request).

Use of Site by Minors

The Site is not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide Personal Information through the Site.

Behavioral Advertising

We do not serve advertising on the Site. However, we do engage online advertising service providers to serve ads on other sites, based on web pages you may have visited on your search engine activity. Currently, the Site does not respond to “Do Not Track” signals from browsers.

Use of Google Analytics

The Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). This analytical tool uses cookies and similar technologies to help analyze how users use the Site. The information generated about Site usage, including user IP address, is transmitted to Google. This information is then used to evaluate use of the Site, compile statistical reports on Site activity, and provide other services relating to Site activity and internet usage. Google offers the ability to opt out from tracking through Google Analytics cookies; for more information, visit http://tools.google.com/dlpage/gaoptout.

Your California Privacy Rights

California Civil Code Section 1798.83 permits customers of Aetna INC who are California residents to request certain information regarding its disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please write to us at:

c/o: NeoCare Solutions℠ Team

1333 Broadway Avenue

3rd Floor

New York, NY 10018

Contacting Us

If you have any questions about this Privacy Policy, please contact us by e-mail at support@neocaresolutions.com.

Please note that e-mail communications are not always secure; so please do not include or Health Information, credit card information or other sensitive information in your e-mail messages to us.