ClearHealthCosts (also referred to as “CHC,” “we,” “our,” “us”) is in the business of providing pricing services (the “Service”) and other reliable information regarding health care costs from medical service providers. We partner with newsrooms to do deep-dive investigations into consumer benefits projects that reveal health costs in various communities. Our stated mission is to bring transparency to the health-care marketplace.
1. What Information Do We Gather?
When you visit our Website and Portal (“Site”), we collect only the information and personal data you have agreed to provide to us that is necessary to identify your needs and to provide you with better service. Through your use of the Site or registration as a new user, we may request personal data including, but not limited to:
- Name and company
- Contact information including email address and cell phone number
- Demographic information including postal code, product preferences and interests
- Internet Protocol (“IP”) Address and other persistent identifiers
- Other information relevant to customer surveys and offers
- If you become a registered user or if you conduct transactions through this Site, we will collect information about the interactions you have while on the Site and other potential activities on the Site. This information may include, without limitation, areas of the Site that you visit, transaction type, content that you view, download or submit,.
Some of this personal data, including name, company and contact information, will only be collected if you voluntarily provide it during the user registration process. We may also track information such as the domain name and the name of the web page from which you entered our Site, and how much time you spend on each of our pages. We may collect information that is combined with other web visitors’ information, such as how many times visitors click on each web page and the methods by which our Site was found.
We may collect IP addresses and website usage information from you when you visit our Site via the use of “cookies.” An IP address is a number that is assigned to your computer when you are using your browser on the Internet. A cookie is a small file that is stored on the hard drive of your computer ready for future access when you return to our Site. We use cookies to deliver web content specific to you and to keep track of your online activity. Cookies cannot pass viruses, harm your computer or pass on private information such as an email address without the computer user’s intervention. Cookies contain session identification numbers that allow our systems to recall previous sessions for authentication efforts and assemble information from our gathered data. You can configure your computer’s browser to alert you when a site is attempting to send you a cookie and allow you to accept or refuse the cookie.
You should visit the “Help” section of your browser for how to manage your cookie settings, or follow the links below:
- Internet Explorer:
https://support.microsoft.com/en-us/help/260971/description-of-cookies - Mozilla Firefox:
https://support.mozilla.com/en-US/kb/Cookies - Google Chrome:
https://www.google.com/support/chrome/bin/answer.py?hl=en&answer=95647 - Safari:
https://support.apple.com/kb/PH5042 - Opera:
https://help.opera.com/en/latest/web-preferences/#cookies
Further information on how to prevent cookies from being stored on your device can be found on http://www.allaboutcookies.org under the ‘manage cookies’ section. Alternatively, you can access further information by going to the help menu within your internet browser. To opt out of being tracked by Google Analytics across all websites visit http://tools.google.com/dlpage/gaoptout.
We use cookies to give you the best experience on our Site. If you continue without changing your cookie settings, we assume that you consent to our use of cookies on this device. You can change your cookie settings at any time but if you do, you may lose some functionality on our Site.
2. What Do We Do With the Personal Information We Collect?
You will be asked to provide personal data in certain fields on this Site that allow you to be able to use our Services. The personal data we collect is used only for the purpose we state at the time of collection or for purposes contained below. For example, our uses may include, but are not limited to, the following:
- To process transactions. ClearHealthCosts uses personal data such as name, physical address, telephone number, email address, and company/institution to engage in interactions with you, including contacting you about your transactions with the site.
- To process payments. We use financial/credit card and payment information to process your order and may need to share some of this information with delivery services, credit card clearing houses, and other third parties to complete the transaction.
- To provide support or other services. ClearHealthCosts may use your personal data to provide you with support or other services that you have ordered or requested. ClearHealthCosts may also use your personal information to respond directly to your requests for information.
- To provide information based on your needs and respond to your requests. ClearHealthCosts may use your personal data to provide you with notices of new product releases and service developments.
- To provide online forums and social networks. Some services available on our Site may permit you to participate in interactive discussions, post comments, opportunities, or other content to a Forum, or otherwise engage in networking activities. Some of these services may be moderated; all may be accessed for technical reasons (for example, for improvements or fixes). ClearHealthCosts does not control the content that users post to the Forums or social networks. You should carefully consider whether you wish to submit personal information to these forums or social networks and tailor any content you submit appropriately and in accordance with the relevant terms of use. You should also review any additional terms and conditions that may govern your use of these services, including terms related to sharing your personal information and receiving communications.
- To administer products. ClearHealthCosts may contact you if you purchase products to confirm certain information about your order (for example, that you did not experience problems in the download process). We may also use this information to confirm compliance with licensing and other terms of use.
- To select content, improve quality, and facilitate use of the websites. ClearHealthCosts may use your personal data, including the information gathered as a result of site navigation and electronic protocols and cookies (including third-party cookies), to help create and personalize website content, improve website quality, track marketing campaign responsiveness, evaluate page response rates, conduct usability testing, and facilitate your use of the websites (for example, to facilitate navigation and the login process, avoid duplicate data entry, enhance security, keep track of shopping cart additions, and preserve order information between sessions). You have a right to opt out of the use of cookies under the California Consumer Privacy Act (“CCPA”) and and the California Privacy Rights Act (“CPRA”).
- To serve personalized advertising to you. We don’t share your personal data with advertisers without your consent. We may allow advertisers to choose the characteristics of users who will see their advertisements, and we may use any of the non-personally-identifiable data attributes we have collected to select the appropriate audience for those advertisements. When you click on or otherwise interact with an advertisement, there is a possibility that the advertiser may place a cookie in your browser and that your attributes meet the criteria the advertiser selected.
- To assess usage of ClearHealthCosts products and services. We may track your usage of our products
- To update you on relevant ClearHealthCosts benefits, programs, and opportunities. We may communicate with you regarding relevant ClearHealthCosts benefits, programs, and opportunities available to you.
- To engage with third parties. We may share your personal data with third parties in connection with services that these individuals or entities perform for or with us. These third parties are restricted from using this data in any way other than to provide services for us or for the collaboration in which they and ClearHealthCosts are contractually engaged (for example, hosting a ClearHealthCosts database or engaging in data processing on our behalf, or mailing you information that you requested). We carefully select these third parties, and they are obligated to keep your data secure. From time to time, we may also share your information with third parties whom we think might provide content, products, or services of interest to you.
- To protect ClearHealthCosts content and services. We may use your personal data to prevent potentially illegal activities and to enforce our terms and conditions. We also use a variety of technological systems to detect and address anomalous activity and to screen content to prevent abuse, such as spam. These efforts may, on occasion, result in a temporary or permanent suspension or termination of some functions for some users. By using our Site, you acknowledge and agree that we may access, retain and disclose the personal data we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention, or disclosure is reasonably necessary to: (a) comply with legal process (e.g. a subpoena or court order) or law; (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; (d) respond to your requests for customer service; and/or (e) protect the rights, property or personal safety of ClearHealthCosts, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, compliance with applicable law, and spam/malware prevention, and similar purposes.
- To get feedback or input from you. In order to deliver products and services of most interest to our customers, from time to time, we may ask members, customers, volunteers, and website visitors to provide us input and feedback (for example through surveys, usability studies, focus groups).
- To protect ClearHealthCosts information assets as well as your own personal data. Our policies protect the confidentiality, integrity, and availability of ClearHealthCosts information assets by following a risk management approach based on policies, standards, guidelines, and procedures to meet security objectives while supporting business and operational goals.
- To assist in Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of ClearHealthCosts’ assets are sold or transferred to a third-party, customer personal data (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
To the extent that we collect certain demographic information about you, we may use this information in our market research, but we will do so only after we “anonymize” or “pseudonymize” the data, i.e., remove information that would confirm your identity. We will only use your name upon receipt of your consent. We will not use your personal data, however, to send commercial or marketing messages to you unless we have a legal basis for doing so, such as your consent or a contract with us for which, in either case, you will have the ability to opt out of by sending an email to info@clearhealthcosts.com
This Site does not collect personal data when you browse the Site and request pages from our servers unless you voluntarily and knowingly provide such information to us. This means that we will not know your name, your email address, or any other personal data just because you browse the Site unless you:
- access the Site from a link in an email that we have sent to you;
- have created a profile and you either log-in to your account or choose to be remembered via your cookie or your web-enabled mobile device.
In these cases we will know who you are based on the information you previously supplied to us. When you request a page from our Site, our servers log the information provided in the HTTPS request header including the IP number, the time of the request, the URL of your request and other information that is provided in the HTTPS header. We collect the HTTP request header information in order to make our Site function correctly and to provide you with the functionality that you expect to see. We also use this information to personalize content presented to you, and to better understand how visitors use our Site and how we can better tune it, its contents, and functionality to meet your needs. We only use your personally identifiable information for those activities listed at the time you submit your information to us. For example, if you provide us with an email to inform you of special events, then that is what we will use your email address to do. If we would like to use your personally identifiable information for an unrelated activity, we will first request your consent to do so.
3. Who Can Use the Information We Collect and How?
We may provide your personal data to third parties, or third parties may collect personal data from you on our behalf if we have contracted with that third party to provide some part of the information or service that you have requested. Other than those who act on our behalf and except as explained in this Policy, personal data you provide at this Site will not be transferred to unrelated third parties, unless we have a legal basis to do so. However, please note that personal data provided to this Site is subject to disclosure pursuant to judicial or other government subpoenas, warrants or orders. We will only provide this information after approximately two weeks following receipt of a valid subpoena or other legal process in a civil case.
4. How Do We Protect the Personal Information We Collect?
Security of Personal Data
We are committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements. We take our security obligations seriously and so should you. While we are responsible for maintaining the security of this Site, you must also access and use this Site in a manner that is responsible and secure. We adhere to internationally recognized security standards as well as our information security management system policies relating to client confidential data. In addition, we have implemented a series of policies, procedures, and training to address data protection, confidentiality, and security, and we update and review the appropriateness of these measures on a regular basis.
Disclosure and Sale of Personal Data
In the preceding twelve (12) months, ClearHealthCosts has disclosed to our news partners the following categories of personal information for a business purpose: Names, emails, health care experiences, costs and related information about health care transactions while for the purposes of investigative journalism.
In the preceding twelve (12) months, ClearHealthCosts has not sold personal information.
Storage and Transfer of Personal Data
The personal data we collect may be stored and processed in your region, in the United States or in any other country where we, our affiliates, or contractors maintain facilities, including outside the European Union. We take steps to ensure that the data we collect under this Privacy Policy is processed pursuant to the terms thereof and the requirements of applicable law wherever the data is located.
We also collaborate with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your personal data within ClearHealthCosts or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured, and transferred according to applicable law.
If you would like to know more about our data transfer practices, please contact info@clearhealthcosts.com.
Retention of Personal Data
We retain personal data for as long as necessary to provide the services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g., statute of limitations). If your personal data is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.
5. What Are Your Rights Regarding Your Personal Data?
We respect your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with our Products and Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features, Sites, Products, or Services.
Access to personal data: In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law.
Portability: If you reside within the European Union, you have the right to ask for a copy of your personal data and/or ask for it to be ported to another provider of your choice. Please note that such a request could be limited to the only personal data you provided us with or that we hold at that given time and subject to any relevant legal requirements and exemptions, including identity verification procedures.
Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via email, postal mail or telephone about our products, services and events that may be of interest to you, including newsletters.
E-mail communications you receive from us will generally provide an unsubscribe link allowing you to opt out of receiving future email or to change your contact preferences. E-mail communications may also include a link to directly update and manage your marketing preferences. If you have an online account with ClearHealthCosts, You can also change your contact preferences by emailing us at info@clearhealthcosts.com. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts.
6. How Do You Opt Out of Personal Information Sharing with Our Business Partners?
We may use third party analytics vendors to evaluate and provide us with information about the use of our Services and viewing of our content. Some of the information you see on our Sites may be customized based on automated predictions about your interests, which predictions are generated from your visits over time and across different websites, using tools such as Google Analytics. This information allows us to create content of greater interest to you and can also be used to serve ads based on your past visits to our Sites. Note that you can opt out of a third-party vendor’s use of cookies, including use by Google, by visiting the Network Advertising Initiative opt-out page (http://www.networkadvertising.org/choices/).
For more information about how targeted Network Advertising works, please visit: http://www.youradchoices.com/ or http://www.networkadvertising.org/understanding-online- advertising.
You may opt out of third party targeted advertising or analytics in two ways: 1) By directly notifying a Network Advertising service provider via its opt-out tools (Please see above), or 2) using your browser’s Do Not Track (DNT) settings to indicate that you do not wish to receive targeted advertising based on your overall internet usage. For more information about DNT and how it works, please visit the Future of Privacy Forum’s website: http://www.allaboutdnt.com/.
We will make a good faith reasonable effort to honor your DNT browser settings for opting out of receiving targeted third party advertising based on your overall Internet usage. Please note that various browsers frequently update technology or change their settings and business practices without advance notice, and we may not have the latest information on how to honor your preferences. If you exercise either opt-out option – the cookie opt-out or the browser opt-out – you will continue to receive advertising, but such advertising may not relate to your specific interests, previous purchases, or search history.
However, you cannot opt out of our contextual analytics and advertising, which is based on your usage of only our Services. We will continue to serve you contextual advertising. We will also continue to monitor your usage and search or transaction history to provide us with analytics on how well our Services, features, and activities are functioning and used. We will also share this information in an aggregated or anonymized form (meaning that no one individual person can be identified) within ClearHealthCosts.
You can also opt out of our marketing emails at any time by emailing us at info@clearhealthcosts.com or by sending us a post card to “OPT OUT”, ClearHealthCosts, P.O. Box 8124, Pelham, N.Y. 10803.
7. How Do You Correct and Update Your Personal Data?
We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact info@clearhealthcosts.com.
You can change or correct your personal data at any time. Just send an email with your old information and your corrections to info@clearhealthcosts.com with “Correction” in the subject line.
8. What is Our Privacy Policy If You Are an Underage Child?
We understand the importance of protecting the privacy of all individuals, especially the very young. Our services are intended for United States audiences over the age of 18. Our Site and its Services are not directed to children, and you may not use our Services if you are under the age of 13. You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf). You must be at least 16 years of age to use the Site Forums. Subscribing to our Services is restricted to adults who are either 18 years of age or older or as otherwise legally defined by the country of your residency.
9. What Happens When You Link to a Third-Party Web Site?
If you click on a link and go to another site, you will be subject to that website’s privacy policy. We encourage you to read the posted privacy policy statement at any website before submitting any personal data at all.
10. What Happens When We Update Our Privacy Policy?
We may on occasion update our Privacy Policy. Your acceptance of any minor changes to this Privacy Policy is indicated by your continued use of our Services. If we make any material changes to our Privacy Policy, we will post a notice about the change at a prominent location on our Site. We encourage you to periodically review our Site and this Privacy Policy for any changes.
11. What Happens If We Sell Our Business?
While we do not anticipate it, every business nowadays should plan for the possibility that it might sell certain or all of its assets to another company or individual, or that it might buy certain assets of another company or individual. If all or part of the company is sold, merged or otherwise transferred to another entity, the personal information you have provided to us may be transferred as part of that transaction. However, we will take steps to ensure that your personal information is used in a manner consistent with the provisions of our Policy.
12. Your European Union Privacy Rights
Under the General Data Protection Regulation (Regulation EU 2016/679) (also known as GDPR), if you are an individual protected by the GDPR you may have certain rights as a data subject. To request information about or avail yourself of those rights, please send an email to info@clearhealthcosts.com with “GDPR Request” in the subject line. In the email please describe, with specificity, the GDPR right you are requesting assistance with. Please note additional information may be requested prior to initiation of a request and that COMPANY reserves the right to charge a fee with respect to certain requests. Upon COMPANY’s completion of its review you will be notified if your request has been granted, denied, or exemptions apply.
13. Your California Privacy Rights
We have adopted the following disclosures to comply with the California Consumer Privacy Act of 2018, as amended, and implementing regulations (“CCPA”), the California Privacy Rights Act (“CPRA”), effective January 1, 2023, and other California privacy laws. Any terms defined in the CCPA/CPRA, other California privacy laws, or in our Privacy Policy have the same meaning when used in this notice.
This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) and the California Privacy Rights Act (“CPRA”) as a supplement to other privacy policies or notices issued by ClearHealthCosts. In the event of a conflict between any other ClearHealthCosts policy, statement, or notice and this Notice, this Notice will prevail as to California Consumers and their rights under the CCPA and CPRA.
In accordance with the CCPA’s and CPRA’s requirements, this Notice describes our collection, use, disclosure, and “Sale” or “Sharing” of California Consumers’ “Personal Information” or “PI” as defined by the CCPA and CPRA, as well as the rights California Consumers have under the CCPA and CPRA. Terms defined in the CCPA and CPRA that are used in this Notice have the same meanings as in the CCPA and CPRA.
Information We Collect and How We Use and Share It
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”).
The following is a description of our data collection practices, including the personal data we may collect, the source of that information, the purposes for which we collect information (in addition to as otherwise set forth herein), and whether we disclose that information to external parties.
We may use any and all of the information for any purposes described in this Privacy Notice. We may not collect additional categories of personal information or use personal information collected for additional purposes that are incompatible with the disclosed purposes for which the personal information was collected, without providing consumers with notice. Our collection, use, retention, and sharing of a consumer’s personal information shall be necessary and proportionate to achieve the purposes for which such information is collected or processed, or for another disclosed purpose that is compatible with the context in which the personal information was collected, and not further processed in a manner that is incompatible with those purposes.
We may share the personal information and sensitive personal information described below subject to your right to opt out as provided by the CCPA and CPRA. ClearHealthCosts shares your information with our partners. We also may maintain the data with a third party.
Retention
We may not retain a consumer’s personal information or sensitive personal information for each disclosed purpose for which the personal information was collected for longer than is reasonably necessary for that disclosed purpose.
If we are acting as a third party that controls the collection of personal information about a consumer on its premises, including in a vehicle, then we shall, at or before the point of collection, inform consumers as to the categories of information to be collected and the purposes for which the categories of personal information are used, and whether such personal information is sold, in a clear and conspicuous manner at such location.
PERSONAL IDENTIFIERS
- We collect your name, address, possibly Policy Numbers , phone number, and email address when you create an account with us or it is provided to us through your uploading an EOB. We use this information to provide our Services, and to respond to your requests.
- We collect a unique numerical identifier, assigned to you by a first-party cookie, automatically when you use our Services in order to identify you, provide our services, prevent fraud, and provide you with targeted information and offers.
- We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our mobile application, and measure the effectiveness of online services, applications, and tools.
- We collect your Device ID automatically when you use our Services. We use this information to monitor your use and the effectiveness of our Services, and to identify you.
PERSONAL DATA PROTECTED AGAINST SECURITY BREACHES (CAL. CIV. CODE § 1798.80(E))
- We may collect your name, phone number or email address when you create an account with us or when provided to us. We use this information to provide our Services and to respond to your requests.
- We may collect banking information in order to provide the Services.
- We collect health insurance or other financial services information directly from you or from records provided to us. We use this information to provide you with the Service.
PROTECTED CLASSIFIED INFORMATION
- We collect information about your age and date of birth when you create an account with us or when your information is provided to us. We use this information to provide you with the Service and to better calibrate our assessment tool.
COMMERCIAL INFORMATION
- When you engage with us, we create records of your interactions with us and the Services provided. We use this information to measure the effectiveness of our Services and use this information to better calibrate our assessment tool.
INTERNET OR OTHER SIMILAR NETWORK ACTIVITY
- We may collect information about your browsing history, search history, and information regarding your interaction with our Site.
GEOLOCATION
- As described above, we collect your IP address automatically when you use our Site. We can often determine your general location based on the IP address.
AUDIO/VIDEO DATA
- If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We do not collect your image or any thermal, olfactory, or similar information.
PROFESSIONAL OR EMPLOYMENT RELATED INFORMATION
- Not applicable
EDUCATION INFORMATION
- Not applicable
BIOMETRICS
- Not applicable
INFERENCES DRAWN FROM OTHER PERSONAL DATA
- Not applicable.
SENSITIVE PERSONAL INFORMATION
- We may collect sensitive personal information such as a social security, driver’s license, state identification card, or passport number if you provide it to use through the use of our Services, although our request forms do not require it.
- We may also collect login, financial account, debit card, or credit card numbers in combination with any required security or access code, or credentials allowing access to an account for payment for our plan that provides health care costs for a fee.
- Your racial, ethnic origin, religious or philosophical beliefs, or union membership may be collected by us if you submit such information in the ClearHealthCosts Price Check submission form.
- We may also collect other biometric or genetic data that you may submit through an Explanation of Benefits or other field provided for to access ClearHealthCosts price checking information but this information is not required.
- We may also collect personal information concerning your health such as through an Explanation of Benefits submitted through the ClearHealthCosts price checking tool.
- Other sensitive personal information may be collected by ClearHealthCosts via a submission of an Explanation of Benefits, or the open text field for the price-checking tool, but it is not required that personal information be submitted to use the tool or to obtain a quote.
When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. The CCPA and CPRA prohibit third parties who purchase the personal information we hold from reselling it unless you have received explicit notice and an opportunity to opt out of further sales.
Either we or our Service Providers also may use your information for the following Business Purposes (as defined in the CCPA and CPRA) on a day-to-day basis:
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Debugging to identify and repair errors that impair existing intended functionality.
- Short-term, transient use, provided that the personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
- Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
- Undertaking internal research for technological development and demonstration.
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.
Does ClearHealthCosts “Sell” or “Share” Your Personal Information?
We may sell personal information by renting, disclosing, releasing, transfering, making available or otherwise communicating your personal information to a third party for monetary or other valuable consideration. We may disclose Personal Information to third parties, such as our news partners, in such a way that may be considered a sale of Personal Information under CCPA and CPRA.
We also may share your personal information with a third party or disclose it to a service provider or contractor for a business purpose. Sharing within the meaning of the CCPA and CPRA means to share, rent, release, disclose, disseminate, make available, transfer, or otherwise communicate orally, in writing, or by electronic or other means, your personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration. This includes transactions that ClearHealthCosts has with a third party for cross-context behavioral advertising for the benefits of ClearHealthCosts in which no money is exchanged.
For the purposes of defining what it means to “share,” the term “cross-context behavioral advertising” means the targeting of advertising to a consumer based on the consumer’s personal information obtained from the consumer’s activity across businesses, distinctly-branded websites, applications, or services, other than the business distinctly branded website, application, or service with which the consumer intentionally interacts.
If we do sell or share your personal information, ClearHealthCosts shall enter into an agreement with such third party, service provider or contractor that: (1) specifies that the personal information is sold or disclosed by the ClearHealthCosts only for limited and specified purposes; (2) obligates the third party, service provider, or contractor to comply with applicable obligations under the CPRA and obligate those persons to provide the same level of privacy protection as required by the CPRA; (3) grants ClearHealthCosts the rights to take reasonable and appropriate steps to help ensure that the third party, service provider, or contractor uses the personal information transferred in a manner consistent with the ClearHealthCosts’ obligations under the CPRA; (4) requires the third party, service provider, or contractor to notify the business if it makes a determination that it can no longer meet its obligations under the CPRA; and (5) grants ClearHealthCosts the right, upon notice, including under (4), to take reasonable and appropriate steps to stop and remediate unauthorized use of personal information.
Under the right to delete provisions of the CPRA, ClearHealthCosts will enter into an agreement with a third party that (1) the service provider or contractor shall cooperate with the business in responding to a verifiable consumer request (2) that at the direction of ClearHealthCosts, shall delete, or enable ClearHealthCosts to delete, and shall notify any of its own service providers or contractors to delete, personal information about the consumer collected, used, processed, or retained by the service provider or the contractor.
Additionally the service provider or contractor (1) shall notify any service providers, contractors or third parties who may have accessed personal information (requested for deletion) from or through the service provider or contractor, unless the information was accessed at the direction of ClearHealthCosts, to delete the consumer’s personal information, unless doing so proves impossible or involves disproportionate effort. A service provider or contractor shall not be required to comply with a deletion request submitted by the consumer directly to the service provider or contractor to the extent that the service provider or contractor has collected, used, processed, or retained the consumer’s personal information in its role as service provider or contractor to ClearHealthCosts.
How to Exercise Your Rights Under the CCPA
Under the CCPA and CPRA you have the right to find out about the personal information that we have collected and how that information has been used or disclosed. You also have the right to request that we delete or correct your personal information or opt out of the sale or sharing of your personal information, to the degree you allow it to be sold or shared. If you wish to exercise any of the rights listed below, or if you would like additional information, please contact us at info@clearhealthcosts.com. .[1]
1. The Right to Access and Know About Personal Information Collected, Disclosed, Sold or Shared
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties to whom we disclose that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we disclosed your personal information for a business purpose, identifying the personal information categories that each category of recipient obtained.
For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
However, ClearHealthCosts is deemed to be compliant with the above requirements of disclosure if:
(1) ClearHealthCosts collects the same categories of information about all consumers,
(2) from the same sources;
(3) has the same reasons for collecting, selling and sharing each of ClearHealthCosts’ consumers’ information;
(4) and discloses those categories of information to the same categories of third parties,
Under the CPRA, if (1)-(4) apply there is no benefit to the consumer if ClearHealthCosts is required to separately provide this information to the consumer, when you can look at this Privacy Policy to learn this information. However, ClearHealthCosts always has the responsibility to provide the “specific pieces” of information it has collected about you.
2. The Right to Request Deletion of Your Personal Information by COMPANY and Third Parties
Subject to certain exceptions, you have the right to request that we delete any of all of your personal information that we collected from you and retained over the past 12 months. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers or contractors or customers to delete) your personal information from our records, unless an exception applies. Additionally, upon receiving a verifiable consumer request, we will notify all third parties with whom ClearHealthCosts has shared such personal information to delete the consumer’s personal information, unless doing so is proven to be impossible or involves disproportionate effort. You may request that only a portion of your information be deleted.
We may deny all or part of your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a service that you requested, take actions reasonably anticipated based on our ongoing business relationship with you, or otherwise perform our agreement with you
- Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
- Debug products to identify and repair errors that impair existing intended functionality
- Exercise free speech or ensure the right of another consumer to exercise their right of free speech or other right provided for by law
- Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’s deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent
- To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information
- Comply with law or a legal obligation
ClearHealthCosts may maintain a confidential record of deletion requests solely for the purpose of preventing the personal information of a consumer who has submitted a deletion request from being sold, for compliance with other laws, or for other purposes solely to the extent permissible under the CPRA.
3. The Right to Opt Out of the Sale or Sharing of Your Personal Information
“DO NOT SELL OR SHARE MY INFORMATION”
The CCPA and CPRA provides you with the right to opt out and stop businesses from selling or sharing your personal information. This right applies to all California consumers ages 16 or older and may be exercised at any time.
The right to opt out of sharing personal information includes sharing with a third paty even when there is no exchange of consideration between the parties. This can include the right to opt out of ClearHealthCosts using technologies like cookies and pixels to track you across other websites, apps, or services that then share that information with ad networks to deliver targeted advertisements to you.
If you are 16 years of age or older, you have the right to direct us to not sell or share your personal information at any time (the “right to opt out”). Our websites and products are not intended for minors. We do not sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization to sell or share (the “right to opt in”) from either the consumer who is at least 13 but not yet 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt in to personal information sales may opt out of future sales at any time.
How to exercise this right:
- By contacting ClearHealthCosts at the number 914-552-9876; or
- By sending an email to info@clearhealthcosts.com, providing details of your request
While there is not yet a consensus, data practices of third-party cookies and tracking technologies associated with our websites and mobile app may constitute a “Sale” or “Sharing” of your personal information as defined by the CCPA and CPRA. You can exercise control over browser-based cookies by adjusting the settings on your browser, and mobile devices may offer ad limitation choices. In addition, third-party tools may enable you to search for and opt out of some of these trackers, such as the Ghostery browser plug-in available at www.ghostery.com. You can learn more about your choices regarding certain kinds of online interest-based advertising in our privacy policy. We do not represent that these third-party tools, programs or statements are complete or accurate, clearing cookies or changing settings may affect your choices and you may have to opt out separately via each browser and other device you use.
Some browsers have signals that may be characterized as do not track signals, but we do not understand them to operate in that manner or to represent a “do not sell” request by you; accordingly, currently we do not view these signals as a do not sell request. We understand that various parties are developing do not sell signals and we may recognize certain such signals if we conclude such a program is appropriate.
We do not knowingly sell the personal information of Consumers. All consumers, regardless of age, may opt out of our promotional emails by clicking the ‘unsubscribe’ link on each of our brand emails. You can also click on the “Do not share my personal info” button in our footer menu.
4. The Right to Non-Discrimination
We will not discriminate against you for exercising any of your CCPA or CPRA rights, and will not engage in the following behaviors:
- Denying you goods or services
- Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
- Providing you a different level or quality of goods or services
- Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
- Retaliating against an employee, applicant for employment, or independent contractor as defined under the CPRA, for exercising their rights under the CPRA
When you exercise these rights and submit a request to us, we will verify your identity by asking for information about your relationship with ClearHealthCosts, such as email address on file.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
Under the General Data Protection Regulation (Regulation EU 2016/679) (also known as GDPR), if you are an individual protected by the GDPR you may have certain rights as a data subject. To request information about or avail yourself of those rights, please send an email to info@clearhealthcosts.com with “GDPR Request” in the subject line. In the email please describe, with specificity, the GDPR right you are requesting assistance with. Please note additional information may be requested prior to initiation of a request and that COMPANY reserves the right to charge a fee with respect to certain requests. Upon COMPANY’s completion of its review you will be notified if your request has been granted, denied, or exemptions apply.
· Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services
· Retaliating against an employee, applicant for employment, or independent contractor as defined under the CPRA, for exercising their rights under the CPRA
When you exercise these rights and submit a request to us, we will verify your identity by asking for information about your relationship with ClearHealthCosts, such as email address on file.
You shall have the right to request that ClearHealthCosts maintains inaccurate personal information about you as correct such as inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information. If ClearHealthCosts collects your personal information ClearHealthCosts shall disclose, pursuant to the CPRA, section 1798.130, your right to request correction of inaccurate personal information.
If ClearHealthCosts receives a verifiable consumer request to correct inaccurate personal information, ClearHealthCosts shall use commercially reasonable efforts to correct the inaccurate personal information, as directed by you pursuant to section 1798.130 and applicable regulations. ClearHealthCosts shall also ask third parties and service providers information has been shared or sold with to correct or delete your personal information upon request.
6. The Right to Limit Use and Disclosure of Sensitive Personal Information
Sensitive personal information is defined as personal information that reveals the following:
- Your social security, driver’s license, state identification card, or passport number
- Your login, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing acesss to an account
- Your precise geolocation
- Your racial or ethnic origin, religious or philosophical beliefs, or union membership
- The contents of your mail, email, and text messages unless ClearHealthCosts is the intended recipient of the communication
- Your genetic data
- Biometric information for the purpose of uniquely identifying you
- Personal information collected and analyzed concerning your health
- Personal information collected and analyzed concerning your sex life or sexual orientation
However, information that is publicly available shall not be considered sensitive personal information or personal information.
5. The Right to Correct Inaccurate Personal Information
You shall have the right, at any time, if ClearHealthCosts collects sensitive personal information about you, to limit ClearHealthCosts’ use and disclosure of your sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests such goods or services, to perform following services:
- To ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for security and integrity
- To debug to identify and repair errors that impair existing intended functionality
- For short-term, transient use, including but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with ClearHealthCosts, provided that your personal information is not disclosed to another party and is not used to build a profile about you or otherwise alter the consumer’s experience outside the current interaction with the business.
- To perform services on behalf of the business, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytic services, providing storage, or providing similar services on behalf of the business or
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured for, or controlled by ClearHealthCosts, and to improve, upgrade, or enhance the service or device that is owned, manufactured for or controlled by ClearHealthCosts
- Information that is collected or processed without the purpose of inferring characteristics about a consumer, is not subject to the right to limit use and disclosure, and shall be treated as personal information for purposes of the CPRA.
Notice of Financial Incentive, if an incentive is offered
The CCPA and CPRA allows businesses to offer consumers financial incentives for sharing personal information. For example, a business can offer a rewards program or provide a premium service to consumers as compensation for their personal information. Where ClearHealthCosts offers these programs, your participation is optional. If you choose to participate, your participation will be subject to any applicable terms, and you may withdraw at any time.
However, we may charge a different price or rate, or offer a different level or quality of goods or services, to the extent that doing so is reasonably related to the value of the applicable data. ClearHealthCosts may also offer loyalty, rewards, premium features, discounts, or club card programs consistent with the CPRA.
From time to time, we may offer coupons or other price reductions for our products and services in exchange for your enrollment in email updates, newsletter delivery, contests, or similar services we provide to communicate with you. To provide these services, we may utilize the identifiers you have provided to us and may use the details from your commercial relationship with us (from your commercial information). To receive these financial incentives (or opt in), you may be asked to provide personal information through an online form, contest submission, or via social media.
To opt out of the financial incentives, please review our Privacy Policy and use the contact information found in that policy to submit a request to us. If you opt out we will not reduce the value of any financial incentives you previously received from us.
We do not assign a monetary value to the data that we collect and strive to only use that information to further our business in accordance with our Privacy Policy; to the extent that we are required to assign a monetary value to your personal information that is equal to the value of the discount or financial incentive that we have provided to you.
Authorized Agents
You may authorize a natural person or a business entity registered with the California Secretary of State to act on your behalf to make a request to know or to delete your personal information.
To do so, you must (i) verify your identity to ClearHealthCosts and provide that authorized agent written permission to make such a request or (ii) provide the authorized agent with power of attorney pursuant to the California Probate Code sections 4000 to 4465.
The authorized agent must include those authorizations in the verifiable consumer request.
Security Procedures
ClearHealthCosts shall implement reasonable security procedures and practices appropriate to the nature of the personal information collected about a consumer to protect the personal information from unauthorized or illegal access, destruction, use, modification, or disclosure.
Timeframe for Disclosure
If a consumer requests disclosure of required information, a consumer’s right to request required information beyond a 12-month period, and a business’s obligation to provide such information, shall only apply to personal information collected on or after January 1, 2022.
Children 16 and Under
We do not knowingly collect, solicit, or share personal information from children under the age of 16. If we have knowledge that a child under 16 has submitted personal information in violation of this Policy, we will delete that information as soon as possible. If you believe we may have obtained information in violation of this Policy, please email us at info@clearhealthcosts.com or call us at 914-552-9876.
Questions About The CPRA?
If you have questions or concerns regarding this statement, you should first contact us via email at info@clearhealthcosts.com.
Changes to this Privacy Policy
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes. If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.
California Shine the Light Law
If you are a California resident and have an established business relationship with us and want to receive information about how to exercise your third party disclosure choices, you must send a request to the following address with a preference on how our response to your request should be sent (email or postal mail). You may contact us in two ways. Send an email to info@clearhealthcosts.com.
Alternatively, you may contact us at:
ClearHealthCosts
P.O. Box 8124
Pelham, N.Y. 10803
Attn: Your California Privacy Rights
c/o Privacy Administrator
For requests sent via email, you must put the statement “Your California Privacy Rights” in the subject field of your email. All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or post card and clearly stated on the actual request. For all requests, please include your name, street address, city, state, and zip code. (Your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping.) We will not accept requests via the telephone or by facsimile. We are not responsible for responding to notices that are not labeled or not sent properly, or do not have complete information.
If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to info@clearhealthcosts.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
14. What If You Have Questions?
If you have questions or concerns regarding this statement, you should first contact us via email at info@clearhealthcosts.com.