Privacy Policy

Privacy Policy

ShareWELL Health Share (the “Company,” “us,” or “we”) is committed to maintaining robust privacy protections for individuals and its members accessing the Company’s website(s) (each, a “Site”) or utilizing its services, whether online or otherwise (“Services”). This Privacy Policy is designed to inform users of how ShareWELL Health Share, its affiliates, subsidiaries, or related companies (“we,” “us,” or “our”) gather and use personal information collected on or through our Service.

For purposes of this Privacy Policy, the “Service” includes:
(1) the websites owned or operated by ShareWELL Health Share now, or in the future, including, but not limited to, www.sharewellhealth.org (collectively, the “Site”);
(2) ShareWELL Health Share’s subdomains and all related services and products provided in connection with the Site.

YOU SHOULD READ THIS PRIVACY POLICY CAREFULLY PRIOR TO ACCESSING THE SITE OR USING THE SERVICES.

10DLC Messaging Disclaimer

As part of our communication strategy, ShareWELL Health Share may send messages via 10DLC (10-digit long code) messaging systems. By providing your contact information and engaging with our Service, you consent to receive messages from ShareWELL Health Share, including updates, reminders, and promotional content, through 10DLC platforms. Standard message and data rates may apply. You may opt-out of receiving such communications by following the unsubscribe instructions provided in our messages or contacting us directly.

1. INTRODUCTION

By using the Service, you accept and hereby expressly consent to the terms of this Privacy Policy and to our use and processing of Personal Information (as defined hereunder) for the purposes set forth herein. “You” or “your” or similar terms refer to you as a user of our Service. By accepting our Privacy Policy during registration, or by using the Service, you expressly consent to our collection, use, disclosure, storage, and processing of your Personal Information (as defined below) in accordance with this Privacy Policy.

2. INFORMATION COVERED BY THIS PRIVACY POLICY

This Privacy Policy covers how ShareWELL Health Share treats your personally identifiable information that ShareWELL Health Share collects, receives, maintains, stores, or transmits, including, but not limited to, information you transmit or submit in connection with your use of, or interaction with, the Service (“Personal Information”). Your Personal Information includes, but is not limited to, information that individually identifies you or is information about you that can be traced back to you, your IP address, or your location. It may include, but is not limited to, your name, address, email address, phone number, other contact information, and any information you choose to share via the Service.

3. INFORMATION COLLECTED BY THE SERVICE

ShareWELL Health Share collects Personal Information that you choose to provide to us, including any Personal Information you provide in connection with your use of the Service, regardless of how you provide it. It is always your choice whether or not to provide us with your Personal Information. If you choose not to provide Personal Information, you may not be able to use certain features or functions of the Service. Whenever you use the Service, ShareWELL Health Share also receives and records information on our server logs from your browser, including your IP address, ShareWELL Health Share’s cookie information, the pages you request, and relates it to the Personal Information you provide.

Examples of how and why ShareWELL Health Share collects Personal Information include:

  • Registration – We collect your Personal Information as part of the registration process for our Service. For example, to process your registration or use of the Service, we may collect Personal Information such as your email, login, password, phone number, date of birth, your interest in the Service, and how you found the Service.

  • Self-Reported Personal Information – We collect Personal Information that you provide or enter during the course of using the Service or that you choose to provide to us through any devices that you use to collect information regarding your health and/or medical condition and related behaviors or that you have others provide on your behalf such as information or records relating to your medical or health history, health status and laboratory testing results, prescriptions, and other health-related information.

  • Health Care Payer or Company (Employer) – If you are receiving the Service through your health care payer or company, we may receive information as provided by your health care payer or company, or information provided by a third-party on the health care payer’s or company’s behalf.

  • Social Information – We collect information that you provide to us pertaining to the people with whom you consent to share your Personal Information (such as a family member or caregiver), as well as communications between you and such individuals.

  • User Content – We collect information that you submit through the Service, including messages, chats, reviews, photos, videos, images, folders, data, text, and other types of submissions that you provide in connection with the use of the Service.

  • Automatically Tracked Information – We may also use automated tracking methods such as cookies, flash cookies, web beacons, GPS data, and connected accelerometers to collect information regarding your behaviors relative to the Service, including, but not limited to, information related to your equipment, browsing actions and patterns, traffic and location data, the resources you access and use, and information about your internet connection including, but not limited to, your IP address, operating system, and browser type. We may also use these technologies to collect information regarding your interaction with our email messages such as whether you opened, clicked, or forwarded our email.

When you access our Service from a mobile device, we may collect unique identification numbers associated with your device (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We and our third-party partners may also use cookies and tracking technologies for advertising purposes.

  • Demographic Information – We may collect demographic information as you continue to use the Service such as your unique username and password, mailing address, age, gender, social security number, driver’s license number, geographic location, preferences, payment information (such as your payment card number, expiration date, and billing address), and any applicable insurance information.

  • Surveys and/or Assessments – From time to time, we may send you assessments and survey questions to help us understand your knowledge of the Service and to provide us with feedback on the Service. We collect any responses that you provide.

  • Augmenting – From time to time, we may use or augment your Personal Information with information obtained from third parties and sources other than the Service such as, without limitation, our partners, advertisers, or from ShareWELL Health Share and other providers. An example of such a third party includes analytics providers such as Google Analytics.

Cookies, Web Beacons, Research and Analytics, and Other Tracking Technologies

We use technology to automatically or passively store or collect certain information when you visit or interact with the Service. These technologies include “cookies” and “web beacons” (and subsequent technologies and methods later developed which perform a similar function), which are used to collect and store usage information regarding your use of the Service. We use this information for a variety of purposes, including, but not limited to, assessing the performance of, or enhancing your experience with, the Service.

  • Cookies – Cookies are small text files that we, or our third-party partners, place in visitors’ computer browsers or devices to store the visitor’s preferences. The use of cookies is standard on the Internet and allows us to tailor your visits to the Service to your individual preferences. Cookies may be session-based cookies that are removed after a user leaves a website or persistent cookies that are stored on a user’s computer permanently or until the expiration date. Users can delete cookies via their browser settings. Cookies themselves do not contain any Personal Information. Please note that if you delete or disable cookies from the Service, you may not be able to utilize the features of the Service to its fullest potential.

  • Flash cookies – Flash cookies are locally stored objects that may be incorporated in certain features of the Service to collect and store information about your preferences and navigation to, from, and on the Service. Flash cookies are not managed by the same browser settings as are used for browser cookies.

  • Web beacons – Web beacons (also known as clear gifs, pixel tags, and single-pixel gifs) are small pieces of code placed on a web page to monitor the behavior and collect data about the visitors viewing a web page that help ShareWELL Health Share manage online advertising and traffic.

  • Disabling Cookies

    You may set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. Please refer to your browser “Help” instructions to learn more about cookies and other technologies and how to manage their use. If you elect to refuse or delete cookies, you will need to repeat this process if you use another device or change browsers. The Network Advertising Initiative provides instructions and information on how to opt out of communications: http://www.networkadvertising.org/choices/. You can use your browser settings to decide whether to turn on and off cookies for our Service. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some of the Service may be inaccessible or not function properly.

California Do Not Track Disclosure

We currently do not support the Do Not Track browser setting or respond to Do Not Track signals. Do Not Track (or DNT) is a preference you can set in your browser to let the websites you visit know that you do not want them collecting certain information about you.

4. HOW WE USE AND DISCLOSE YOUR PERSONAL INFORMATION

In general, we will not rent or sell your Personal Information. Also, we will not share your Personal Information with other people or non-affiliated companies except in connection with providing the Service, when we otherwise have your permission, as permitted, or required by the Notice of Privacy Practice (the “NPP”), or as expressly permitted or required under this Privacy Policy, including under the following general circumstances.

Using Your Personal Information

We, or a third party on our behalf, use information we collect on the Service in a variety of ways in providing the Service and operating our organization, including, but not limited to, the following:

  • Providing you with the Service;
  • Providing you with services and information that you request;
  • Verifying your identity;
  • Personalizing your experience with the Service;
  • Processing payment card transactions;
  • Performing engagement and outreach activities and call monitoring;
  • Providing you with information about other goods and services we offer that are similar to those that you have already signed up for or inquired about;
  • Notifying you about changes to the Service, the Terms, and/or this Privacy Policy;
  • Operating, maintaining, and improving our Service and improving the content and functionality of the Service;
  • Administering the Service and for internal operations, including troubleshooting, data analysis, product and functionality development, patient experience, peer review, quality control and assurance, understanding and analyzing usage trends and user preferences, support, testing, research, statistical and survey purposes;
  • Responding to law enforcement requests as required by applicable law, investigating and defending ourselves against any claims or allegations, pursuing business development opportunities including, but not limited to, evaluating or conducting a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of ShareWELL Health Share’s assets;
  • Responding to user submissions, comments, and questions;
  • Creating de-identified datasets, to the extent permitted by applicable law;
  • Creating aggregated datasets, to the extent permitted by applicable law;
  • Protecting the personal safety of users of the Service and defending and protecting our rights, property, employees, customers, or patients;
  • Keeping our Service safe and secure;
  • Developing, displaying, and tracking content and advertising tailored to your interests on our Service and other sites, including providing our advertising to you when you visit other websites or applications;
  • Providing services as a business associate on behalf of, or to facilitate the services of, ShareWELL Health Share, including, but not limited to, disseminating the NPP, providing you with certain communications via email, text messages, or other means that contain PII, PHI, and/or PCI-DSS and sending you appointment reminders; and
  • Rendering any services, providing information, or for any other use permitted by applicable law, including for research purposes.

Disclosing Your Personal Information

Except as described in this Privacy Policy, we will not disclose Personal Information that we collect on the Service to third parties without your consent. However, we may disclose Personal Information that we collect on the Service to third parties, to the fullest extent permitted by law, for the following reasons:

  • We may disclose your Personal Information to ShareWELL Health Share or other providers for treatment, payment processing, or operational purposes;
  • We may disclose your Personal Information to your insurance company, health plan, employer, sponsor, or third-party administrator for purposes of billing and payment for our Service;
  • We may share your Personal Information with certain third parties to provide the Service to you on our behalf under confidentiality agreements, including, but not limited to, our third-party service providers such as website, application development, cloud hosting, maintenance, payment processors, and analytics service providers;
  • We may be required to disclose your Personal Information in response to a legal process, for example, in response to a court order or a subpoena to comply with its applicable legal and regulatory reporting requirements;
  • We may disclose your Personal Information in response to a law enforcement agency’s request, or where it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of the Terms, to verify or enforce compliance with applicable laws, or as otherwise required or permitted by law, and to take precautions against liability and to protect our property or other legal rights;
  • We may transfer your Personal Information to an entity or individual that acquires, buys, or merges with ShareWELL Health Share, or our other business units, including during the course of any due diligence process to explore such a transaction, or to explore and complete a divestiture, restructuring, reorganization, dissolution, bankruptcy, or change of control or ownership or sale of its assets (whether in whole or in part);
  • We may license, sell, or otherwise share de-identified, aggregated, or non-aggregated versions of your Personal Information with institutional clients, partners, investors, and contractors for any purposes related to our marketing, business, and/or research practices;
  • We may disclose your Personal Information in accordance with your prior written consent or authorization;
  • We may disclose Personal Information to our subsidiaries, affiliates, and related companies; and
  • We may disclose Personal Information to third-party advertisers to develop and display advertising tailored to your interests or location.

5. CONFIDENTIALITY AND SECURITY

We take reasonable steps to ensure that all Personal Information collected will remain secure and in its original form (i.e., free from any alteration). We have put in place appropriate physical, electronic, and administrative safeguards in compliance with federal and state law, including HIPAA, to help prevent unauthorized access, maintain data security, and correct use of the Personal Information we collect. We cannot, however, ensure or warrant the security of any Personal Information you transmit to us, and you do so at your own risk. Once we possess your transmission of information, we use commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or administrative safeguards.

The Service may contain links to Third-Party Offerings (as such term is defined in the Terms). Before using any Third-Party Offerings or related services, you must review and accept the terms of use and privacy policies for those sites and/or services. We are not responsible for the privacy policies and/or practices of any Third-Party Offerings, and we are not responsible or liable for the availability, reliability, content, functions, performance, accuracy, legality, appropriateness, services, materials, or any other aspect of such Third-Party Offerings. This Privacy Policy only governs information collected by our Service. When you access any Third-Party Offerings, you do so at your own risk, and you understand and agree that you are solely responsible for reading and understanding any terms of use and/or privacy policies that apply to such Third-Party Offerings. ShareWELL Health Share is not responsible for and will not be a party to any transactions between you and a third-party provider of products, information, or services. ShareWELL Health Share does not monitor such interactions to ensure the confidentiality of your Personal Information. Any separate charges, data records, or obligations you incur in your dealings with Third-Party Offerings are solely your responsibility.

6. ACCESSING AND CHANGING YOUR INFORMATION

You may review and request changes to your Personal Information or request additional information about our collection, use, and disclosure of such information by contacting us at info@sharewellhealth.org. We try to keep our records as accurate and complete as possible. You can help us maintain the accuracy of your information by promptly notifying us of any changes to your Personal Information. You may update, correct, or delete your profile information and preferences at any time by emailing Membersuccess@sharewellhealth.org. Any changes you make will be reflected in active user databases within a reasonable period of time; however, we may retain all information you submit for backups, archiving, prevention of fraud or abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so. We may not be able to modify or delete your information in all circumstances. In addition, you may request that we provide you with the information we hold about you; however, your rights to access your Personal Information are not absolute. We may deny you access when required and/or permitted by applicable laws or if disclosure would likely reveal personal information about a third party.

7. CHILDREN’S PRIVACY

Our Service is neither intended for nor designed to attract users who are under the age of 18. If you are under the age of 18, or we are not otherwise able to offer Service functionality to you because you are deemed a minor (for example, you are not an emancipated minor), do not use the Service. However, depending upon the Service functionality available to you, a parent, guardian, conservator, or custodian or similar legally authorized person (“Authorized Person”) may register for access to the Service and use it on your behalf. Upon turning 18, we will cease providing Service access to the Authorized Person and, depending on the Service functionality available to you, we may:

  • Permanently disable the Authorized Person’s account;
  • Require you to register for desired access to the Service;
  • Request that you indicate whether the Authorized Person may continue to act on your behalf;
  • Seek confirmation that you have taken over the account for access to the Service on behalf of the Authorized Person; and/or
  • Otherwise communicate with you and/or the Authorized Person in accordance with applicable law, your communication preferences, or otherwise.

Our Service is not directed to children under the age of 13, and we do not knowingly collect information from children under the age of 13 without obtaining parental consent. If you are under 13 years of age, then please do not use or access the Service at any time or in any manner. If we learn that a person under 13 years of age has used or accessed the Service or any information has been collected on the Service from persons under 13 years of age, then we will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under 13 years of age has obtained an account on or otherwise accessed the Service, then you may alert us at info@sharewellhealth.org and request that we delete your child’s information from our systems.

8. OPT-OUT

You may affirmatively opt out of receiving future emails from ShareWELL Health Share and may remove your name from our marketing mailing lists. The opt-out provisions do not apply to information collected by cookies or used internally to recognize you and/or facilitate your use of the Service or information we may retain to comply with legal requirements. Opting out will not prevent your access to the Service, and you will continue to receive administrative messages about the Service from us. If you no longer consent to us collecting, using, and sharing your Personal Information in accordance with this Privacy Policy, you may withdraw from the Service at any time by emailing admin@sharewellhealth.org.

9. CHANGES TO OUR PRIVACY POLICY

By using the Service, you agree to the current Privacy Policy, as well as our Terms into which this Privacy Policy is incorporated. ShareWELL Health Share reserves the right, in our sole discretion, to modify or amend this Privacy Policy at any time. Use of information we collect is subject to the Privacy Policy in effect at the time such information is used or disclosed. If we make any material changes to the ways in which Personal Information is collected, used, or transferred, as determined by ShareWELL Health Share, we will notify you of these changes by modification of this Privacy Policy, which will be available for your review through the Service, and the last revision date will be noted at the beginning or end of this Privacy Policy. You should review this Privacy Policy periodically so that you are up to date on our most current policies and practices. Your continued use of the Service after receiving notice signifies your acceptance of any such changes. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Service.

10. PROTECTED HEALTH INFORMATION

Some of the information that you provide to ShareWELL Health Share, or that is created through your use of the Service, may be considered “Protected Health Information” or “PHI” as defined in the Health Insurance Portability and Accountability Act (“HIPAA”). PHI is subject to ShareWELL Health Share’s Notice of Privacy Practices (the “NPP”). The NPP describes how ShareWELL Health Share uses and discloses your PHI and also describes your rights with respect to your PHI. To the extent that this Privacy Policy conflicts with the NPP, the NPP will prevail. In addition, to the extent a capitalized term is undefined in this Privacy Policy, it will have the same meaning as prescribed to it in our Terms of Service (the “Terms”). To the extent that this Privacy Policy conflicts with the Terms, this Privacy Policy will control. BY USING THE SERVICE, YOU ACKNOWLEDGE RECEIPT OF THE SHAREWELL HEALTH SHARE NPP.

In addition, your use of the Service may involve our receipt of PHI. PHI is Personal Information that relates to:

  • Your past, present, or future physical or mental health or condition;
  • The provision of health care to you; and
  • Your past, present, or future payment for the provision of health care, which is created, received, transmitted, or maintained by us.

This Privacy Policy describes how we protect your privacy as a visitor or general user of our Service. You have additional rights under federal and state law with respect to PHI. For more information on those rights, and how ShareWELL Health Share uses and discloses your PHI, refer to the NPP.

In addition to the permitted uses of Personal Information that are set forth in this Privacy Policy, we may use your Personal Information to:

  • Send you communications on behalf of ShareWELL Health Share and to facilitate the provision of health care services to you by ShareWELL Health Share;
  • Invite you to participate in IRB-approved research studies regarding the Service.

In addition to the permitted disclosures of Personal Information that are set forth in this Privacy Policy, and to the extent permitted by applicable law, we may, in our sole discretion and as we deem necessary or otherwise appropriate, disclose your Personal Information to an appropriate health care provider to address concerns regarding the safety and well-being of a user.

11. SPECIAL NOTICE TO RESIDENTS OF SPECIFIC STATES

This section describes the additional rights provided to residents of specific states in accordance with applicable privacy laws, including those of California, Colorado, Connecticut, Utah, and Virginia.

  • California Residents – Your rights under the California Consumer Privacy Act (CCPA) include the right to know, access, delete, or opt-out of certain data uses.
  • Colorado Residents – Your rights include access, portability, correction, and deletion of your Personal Information.
  • Connecticut Residents – Similar rights to those in California and Colorado apply, with specific details outlined above.
  • Utah Residents – Effective December 31, 2023, residents have rights regarding access, correction, and deletion.
  • Virginia Residents – Your rights under the Virginia Consumer Data Protection Act (VCDPA) include access, portability, correction, and deletion.

Details for exercising your rights, as well as contact information for appeals, can be found under the full section above or by emailing info@sharewellhealth.org.

12. USERS OUTSIDE THE UNITED STATES

The Service may only be used within certain jurisdictions within the United States as set forth in the Terms. Accordingly, this Privacy Policy, and our collection, use, and disclosure of your information, is governed by U.S. law, and by using the Service, you acknowledge that the Service will be governed by U.S. law. Using the Service from outside the United States is prohibited under our Terms and may subject you to termination of your use of the Service under such Terms. In no event will ShareWELL Health Share or any of its officers, directors, employees, consultants, subsidiaries, agents, and affiliated entities, including ShareWELL Health Share, be liable for any losses or damages arising from your use of the Service outside of the United States, and you waive any claims that may arise under the laws of your location outside the United States.

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ShareWELL is a nonprofit health care entity. ShareWELL members voluntarily share each other’s medical expenses in accordance with guidelines adopted by the members. ShareWELL is not insurance and is not regulated as insurance. ShareWELL members do not assume any legal obligation to share in the payment of any medical expense incurred by another ShareWELL member.