PRIVACY POLICY V.2023.002 Information Collection and Use
References in this document to “GATEWAY FIRST BENEFITS APP” refer to the owners of GATEWAY FIRST BENEFITS APP Licensed Products, their affiliates, officers, directors, employees, agents, and representatives (collectively, “GATEWAY FIRST BENEFITS APP”).
1) Information Gathered by GATEWAY FIRST BENEFITS APP
GATEWAY FIRST BENEFITS APP collects and uses information from ourUsers at several different points on our website and the Licensed Products and that information is subject to this Privacy Policy. While GATEWAY FIRST BENEFITS APP collects certain information on this site, including personally identifiable information to make the site and our services more secure, error-free, relevant and effective, we will not sell, share, or rent to others the information that we collect for our own use in a manner contrary to this Privacy Policy.Personally identifiable information means sensitive personal information ofUsers, including but not limited to social security numbers, account numbers,Protected Health Information within the meaning of 45 C.F.R. § 160.103 (“PHI”),financial data, date of birth, passwords, but excludes User names and email addresses and electronic communications between Users and GATEWAY FIRST BENEFITS APP. GATEWAY FIRST BENEFITS APP receives PHI and other information protected from disclosure under applicable laws only upon receiving written assurances from GATEWAY FIRST BENEFITS APP’s Customers that such information is being provided to GATEWAY FIRST BENEFITS APP pursuant to a valid written authorization permitting the disclosure of such information to GATEWAY FIRST BENEFITS APP. As a recipient of such information, GATEWAY FIRST BENEFITS APP complies with all applicable Health Insurance Portability and Accountability Act of 1996 (HIPAA)privacy and security rules (as amended by the Health Information Technology forEconomic and Clinical Health Act (“HITECH”)) and applicable state laws. GATEWAY FIRST BENEFITS APP never discloses any PHI of any User to anyone in a manner that violates any applicable privacy rules of HIPAA as amended by HITECH. Any disclosures to aUser’s Health Plan will be in strict compliance with the limitations imposed on disclosures of PHI to group health plans under the HIPAA privacy rule. GATEWAY FIRST BENEFITS APP may share certain de-identified information with customers or business partners, or with Users of our services, either in individual or aggregate form. Such information will not allow for the personal identification of any individual (i.e., it will be “patient de-identified”).The very nature of the services GATEWAY FIRST BENEFITS APP provides allows other organizations and individuals to use GATEWAY FIRST BENEFITS APP’s site to collect information (other than PHI), through one or more of GATEWAY FIRST BENEFITS APP’S Licensed Products. PHI within the meaning of45 C.F.R. § 160.103 (“PHI”) and information that is otherwise protected from disclosure under applicable laws is never disclosed to outside parties, except as may be allowed by the Health Insurance Portability and Accountability Act of1996 (HIPAA) privacy and security rules (as amended by the Health InformationTechnology for Economic and Clinical Health Act (“HITECH”)) and/or applicablestate laws or pursuant to valid legal process such as a search warrant, subpoena or court order. However, other information provided to GATEWAY FIRST BENEFITS APP may be shared with other organizations and individuals in accordance with this Privacy Policy. Users must understand that GATEWAY FIRST BENEFITS APP controls only our own use of information that we collect; other entities who collect information through our Licensed Products may have their own different policies regarding the information they collect through our Licensed Products. ConcernedUsers should check with their organization to learn its privacy policy.
2) Access to Health Data GATEWAY FIRST BENEFITS APP will not use any information gained from the use of the User’s personal health information for any advertising or similar services. GATEWAY FIRST BENEFITS APP will not disclose any information gained from the use of the User’s personal health information to any third parties. GATEWAY FIRST BENEFITS APP will not sell any information gained from the use of the User’s personal health information to any third parties, such as advertising platforms, data brokers, information resellers, or research institutions. GATEWAY FIRST BENEFITS APP will not use any information gained from the use of the User’s personal health information for applications, services, or features designed to collect or combine user data for human subjects research, or any other similar research overseen by an Institutional Review Board or Ethics Committee unless prior written consent is given. GATEWAY FIRST BENEFITS APP will not use any-information gained from the use of the User’s personal health information forany purpose or in any manner involving Protected Health Information, as defined by the Health Insurance Portability and Accountability Act of 1996 and itsimplementing regulations (“HIPAA”) unless prior written consent is given. GATEWAY FIRST BENEFITS APP will only be allowed access to the User’s daily step count information oncethe User has given the app permission. GATEWAY FIRST BENEFITS APP will only access theUsers’ daily step count information for the purpose of calculating anddetermining if Users have met their goals. Users may revoke GATEWAY FIRST BENEFITS APP’S permission to access their step count data at any time.
3) Collection Of Information By Third-PartiesSome of our site(s) and service(s) contain links to othersites whose information practices may be different than ours. Visitors shouldconsult the other sites’ privacy policies as we have no control over informationthat is submitted to, or collected by, these third parties (see the sectionbelow entitled “Links”).
Although we take appropriate measures to safeguard against unauthorizeddisclosures of personally identifiable information, we cannot assure you thatpersonally identifiable information that we collect will never be disclosed ina manner that is inconsistent with this privacy policy if you click on a linkto an outside website to GATEWAY FIRST BENEFITS APP’s site.
Additionally, despite all of GATEWAY FIRST BENEFITS APP’s best efforts, there is always arisk that third parties may unlawfully intercept transmissions of information(see “Disclaimer” at the end of this Notice). This reality is true of allInternet use. As a result, we cannot 100% ensure the security of any information transmitted to GATEWAY FIRST BENEFITS APP via the Internet.
4) Information Gathered During Registration
In order to use GATEWAY FIRST BENEFITS APP’s website, Users may be asked to first complete a log-in registration form. During registration Userswho register may be required to give their contact information (such as name,ID number, etc.). GATEWAY FIRST BENEFITS APP uses the information collected from Users during the registration process to provide secured access to the LicensedProduct. Users may have their IP addresses (unique network identifying numbers)recorded in order to prevent fraud or misuse.
5) Log FilesWe use IP addresses to analyze trends, administer the site, track Users’ movement, prevent unauthorized tampering with our services, andgather broad demographic information on aggregate usage patterns. IP addresses are not generally linked to personally identifiable information, although theymay be recorded in transaction log files to aid in security auditing. Log files include IP address, domain name, pages visited, access times, browser type,referring pages, and other information that is contained within a normal webpage request.
6) External Website Links from www.gatewayfirst.medefy.com
GATEWAY FIRST BENEFITS APP’s web site contains links to other sites.Please be aware that GATEWAY FIRST BENEFITS APP is not responsible for the privacy practices of such other sites. We encourage Users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This Privacy Policy applies solely to information collected through GATEWAY FIRST BENEFITS APP’s own website, https://www.gatewayfirst.medefy.com
7) Security
GATEWAY FIRST BENEFITS APP takes special care to protect Users’ information. When Users submit sensitive personally identifiable information via our website, this information is protected both online and off-line.When our order form asks Users to enter sensitive information, that information is encrypted and is protected with the best encryption software in the industry– – currently, Secure Sockets Layer (SSL), authenticated with a digital certificate. Users will see an indication that the page the User is visiting is deemed secure when a lock-shaped icon appears on a secure page (such as our order form) at the bottom of popular Web browsers; this icon will appear“locked” (as opposed to an “unlocked” icon that appears when you access non-secure pages).
We compartmentalize and quarantine our employee data and billing data, and keepthem separate from one another which thereby increases protection. Onlyemployees who need the information to perform a specific authorized task (forexample, billing or customer service) are granted access topersonally-identifiable information. All employees are kept up-to-date on oursecurity and privacy practices. Every quarter, as well as any time new policiesare added, our employees are notified and reminded of the importance that GATEWAY FIRST BENEFITS APP places on privacy, and what they can do to continue to ensure that ourcustomers’ information remains protected. Finally, our servers (within whichpersonally identifiable information, including PHI, is stored) are kept in asecure, monitored facility.
If a Customer or User has any questions about the security of our online services and our website, the Customer or User can contact tech support atsupport@medefy.com.
8) Site and Billing Announcements
We may also periodically send site and billing announcements to our Customers. Customers will be unable to un-subscribe from these announcements, as they contain important information concerning our service or the User’s account. We must be able to communicate with the User to provide requested services and in regards to issues relating to their account via e-mail or the web. These announcements will be limited in content to information concerning our services, or the User’s account, and they will not contain any promotional or marketing material.
9) NewsletterBoth current and prospective Users may sign up to receive our monthly newsletter. At the time at which Users subscribe for the service, and included in every month’s newsletter, is a link to an automated “unsubscribe”system. We will not sell or release our newsletter mailing list to any other party for any reason.
10) Correcting / Updating Personal Information
If a User’s personally-identifiable information changes(such as their zip code), or if a User no longer desires to use our service, wewill utilize an updating system to incorporate and act upon the User’s personal data provided to us. This can be performed at our User Account editor page, orby notifying our customer support personnel at support@medefy.com.
11) Customers’ Data and E-mail Lists
In the course of providing services, GATEWAY FIRST BENEFITS APP may receive data from customers, or to be sent to its customers, including but notlimited to questions, response data, and e-mail lists for invitations. GATEWAY FIRST BENEFITS APP will not use specific questions or e-mail addresses for purposes other than for providing service to the customer. Specifically, we do not use or sell e-mail addresses to which invitations have been sent using GATEWAY FIRST BENEFITS APP’s e-mail invitation system. Please note, however, that GATEWAY FIRST BENEFITS APP does use aggregate information regarding questions, responses, and e-mails to learn about and improve how our service works. For example, we may measure the response rates to e-mail invitations, or how the position of a question on a page affects its response rate, but we will not use specific questions, responses, or e-mail addresses without your permission.
12) Exceptions
Nothing in this Privacy Policy or the User Agreement may be construed as stopping or inhibiting GATEWAY FIRST BENEFITS APP’s cooperation with law enforcement, investigative agencies or court orders. Furthermore, nothing in this Privacy Policy shall restrain GATEWAY FIRST BENEFITS APP from investigating and prosecuting any Users of our site who attempt to defraud or damage us, or who violate our User Agreements. Therefore, GATEWAY FIRST BENEFITS APP may share otherwise protected data with law enforcement or investigative agencies, or as directed by court order. Also, when necessary to diagnose and repair technical problems, GATEWAY FIRST BENEFITS APP may examine or change any data, computer code, or other information. Such examinations and changes will be restricted to technical personnel with a need to know.
13) Notification of Changes
If we decide to change our Privacy Policy, we will post those changes on our site so that our Users are always aware of what information we collect, how we use it, and under what circumstances – if any –that we disclose it. If at any point we decide to use personally-identifiable information in a manner different from that stated at the time it was collected, we will notify Users pursuant to applicable regulations and HIPAA.Based upon information contained in this e-mail notice, Users will then have a choice to opt out of the changes, if they disagree with how we propose to use their information in this different manner. We will honor Users’ choices, and will agree to use Users’ personally identifiable information in accordance with the Privacy Policy under which the information was originally collected, at theUser’s election.
14) Disclaimer
While GATEWAY FIRST BENEFITS APP agrees to maintain certain security measures to protect User information, GATEWAY FIRST BENEFITS APP cannot be responsible for the release of User information caused by hacking or another User’s tampering with the GATEWAY FIRST BENEFITS APP website. Users assume the risk that any information that they have submitted, however secure, may be illegally misappropriated by others. GATEWAY FIRST BENEFITS APP agrees to fully cooperate with law enforcement to protect and retrieve any information that may be illegally misappropriated by others.
15) Questions or Complaints
Any questions or complaints about GATEWAY FIRST BENEFITS APP’s use of information subject to this Privacy Policy, or about this Privacy Policy in general, should be directed to support@medefy.com.