Effective Date: January 2019
The information we collect about you includes information about your health such as your medical history, age, health conditions you have, and laboratory test results (Protected Health Information or PHI). It also includes personal information such as your name, phone number, and home address (Personally Identifiable Information or PII). Please read the complete definitions of PHI and PII in the Terms and Definitions section at the end of this document.
If you have questions, email us at firstname.lastname@example.org or call us at (602) 904-6108.
When you use Solera products and services, we may collect and use or share your PHI and PII, but only to the extent minimally necessary and in line with our Notice of Privacy Practices. You accept that we may collect this PHI and PII from you directly, or from third parties that share your PHI or PII with Solera. It is fully your choice whether to give PHI and PII through Solera products and services. If you choose not to give PHI or PII we need, you may not be able to use some features of Solera products and services.
We may collect and use technical data (data from your device hardware or software) and related information (“Technical Information”), including but not limited to:
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 PHI or PII. Solera may use Technical Information in any way it believes is proper and lawful.
Solera products and services exist to simplify your healthcare experience and help our business partners (health plans, direct service providers, and community partners) find qualifying participants. Solera’s exclusive software platform connects a nationwide network of community organizations and digital solutions for chronic disease prevention programs (including the Centers for Disease Controls’ National Diabetes Prevention Program) with technology that manages service referrals, reimbursements and payments, collects data, and simplifies enrollment while supporting greater participant engagement and choice.
To support this, we need to ensure that each user who gives Information, clearly allows it to be used or shared. For this reason, we need a license from you to use or share your Information, whether we get it directly from you or, if applicable, from third parties you name.
At all times, we will only use or share your PHI and PII to the extent minimally necessary for the intended use or disclosure. The Solera minimum necessary policy follows the current industry standard that PHI and PII shouldn’t be used or shared when it is not necessary to satisfy a certain purpose or carry out a function. Read the full definition of “minimum necessary” in the Terms and Definitions section at the end of this document.
When we have your consent, you accept that we may collect this PHI from you directly or from third parties that you may allow to share PHI with Solera. We may ask you or allowed third parties to give PHI about you that will allow us to enhance how we serve your needs and your use of Solera products and services. It is fully your choice whether you give PHI through Solera products and services. If you choose not to give the PHI we need, you may not be able to use some parts of Solera products and services.
You also give Solera a lasting, non-exclusive, transferable, sub-licensable, royalty-free license to use your Information and other data we collect to develop, create, and extract statistics and other information, and to use this information and de-identified data known as “blind data”.
We may not be able to carry out a request to change PHI and PII if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may use your PHI and PII to contact you about our own and third-party products and services that may interest you. The technologies we use for this automatic data collection may include:
Some web browsers (including Safari, Internet Explorer, Firefox, and Chrome) include a “Do Not Track” (“DNT”) or similar feature that signals to digital services that a visitor does not want to have any online activity tracked. This can block the digital service from collecting certain Information about the browser’s user. Not all browsers offer a DNT choice, and there isn’t a standard yet for DNT signals. For these reasons, we, and many other digital service operators, don’t respond to DNT signals.
We have applied reasonable and suitable administrative, technical, and physical safeguards designed to protect your Information from illegal access, use or sharing. All Information you provide to us is stored with an approved cloud services provider. These safeguards include, without limitation, encrypting all PHI and PII.
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 products and services, you are responsible for keeping this information private. It is in your best interest to not share your user name or password with anyone.
Please keep in mind that whenever you willingly share Information on message boards or other public forums and features, or through email or group messaging, that Information can be collected and used by others who you may or may not have given consent. By posting Information online that is publicly accessible, you may receive unwanted messages from other parties or reveal your location. We are not responsible for the security or privacy of any Information you choose to send outside the scope of Solera products and services.
Solera neither designed nor intended its products and services to be accessed by children under the age of 13. No one under age 13 may provide any information to or through Solera products and services. If you are under age 13, do not give any information through Solera products and services. We do not intentionally collect Information directly from children under the age of 13 for Solera products or services.
We also do not collect any PHI from anyone under 18 unless clearly authorized under Federal and equivalent State law. No one under age 18 may give any health-related information through Solera products and services unless Solera confirms that sharing would follow applicable Federal or State laws.
If we learn we have collected or received PII or PHI from a child under age 13, we will delete that Information and take other appropriate measures. If you believe that we may have collected any Information, including PII or PHI directly from a child under age 13, please contact our Privacy Officer immediately at email@example.com or (602) 904-6108.
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 policies with respect to your PHI and PII. For more information about your rights under HIPAA, see www.hhs.gov/ocr/privacy/.