Consumer Health Data Privacy Policy

Last Updated: November 18, 2024

Introduction

The company Columbia Medical IDTF, LLC owns and operates the website located at https://www.cmwellcare.com/. Your access to and use of the Platform, any part of it, or anything associated with it, including its content ("Content"), any products or services provided through the Platform or otherwise by Columbia Medical, are governed by our Privacy Policy. Capitalized terms not defined in this Privacy Policy or the Consumer Health Data Privacy Policy have the meanings assigned to them in Columbia Medical's Terms of Use ("Terms of Use").

This Consumer Health Data Privacy Policy ("Consumer Health Data Privacy Policy") applies to the extent required by applicable state law with respect to consumer health data ("Consumer Health Data") as defined by such laws. [cite: 4] For example, this Consumer Health Data Privacy Policy does not apply to protected health information ("PHI") subject to the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). Please refer to our Notice of Privacy Practices, which governs such information.

In addition to addressing state-specific regulations, Columbia Medical IDTF, LLC ensures compliance with federal laws, including HIPAA, to protect your sensitive health data. This policy supplements our general Privacy Policy. In the event of a conflict between our Privacy Policy and the Consumer Health Data Privacy Policy, the Consumer Health Data Privacy Policy applies to the extent it is consistent with applicable state law.

Consent and Data Portability

By using our Platform, you consent to the collection, use, and sharing of your Consumer Health Data as described in this Privacy Policy. We provide clear and accessible mechanisms for obtaining your consent where required by law. If you do not consent to these terms, please do not use our Platform or services.

We support data portability rights as required by applicable laws. You have the right to request and obtain a copy of your Consumer Health Data in a structured, commonly used, and machine-readable format. This allows you to transmit your data to another service provider seamlessly. For more information about exercising these rights, see the "Your Rights Regarding Consumer Health Data" section below.

Collection of Consumer Health Data

The Consumer Health Data we collect depends on how you interact with us, the services you use, and your choices. We collect Consumer Health Data about you from different sources and in various ways when you use our services, including Consumer Health Data you provide directly, Consumer Health Data collected automatically, Consumer Health Data obtained from third-party sources, and Consumer Health Data inferred or generated from other data.

Consumer Health Data You Provide

We collect Consumer Health Data that you may provide to us. For example:

Name and contact information, such as your name, email address, phone number, and billing or physical addresses.
Demographic information, such as your gender, racial or ethnic origin, date of birth, and zip code.
Payment information, such as your credit card number, financial account details, and other payment data.
Account profile information, such as a username or account number combined with a password, security or access code, or other credentials that grant access to your account; a redemption code; biographical details; links to your social media profiles; information about your interests and preferences; and any additional information you add to your account profile.
Marketing information, such as your preferences for receiving our marketing communications and details about your engagement with them.
Content, such as photographs, videos, documents, and other files you upload to our Service. This includes email messages and the content of other communications you send to us.
Government-issued identifiers, such as driver's license numbers, passport numbers, and social security numbers. We may collect images of such identification cards.
Biometric information, such as information that can identify you.
Health information, such as details about your physical and/or mental health status.
Sexual and reproductive health, such as information about your sexual life, reproductive health, and/or sexual orientation.

Consumer Health Data We Collect Automatically

When you use our services, we collect certain information through specific tracking technologies that may qualify as Consumer Health Data. For example:

Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (e.g., MAC address), device type, and your device's operating system, browser, and other software, including type, version, language, settings, and configuration. As described in the "Cookies, Mobile IDs, and Similar Technologies" section of our Privacy Policy, our websites and online services store and retrieve cookie identifiers, mobile IDs, and other data.
Location data. We may collect general location data when you use our apps or online services.
Usage data. We automatically log your activity on our websites, apps, and connected products, including the URL of the website from which you arrived, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website. In some cases, such usage data may be associated with browsing activity on health-related websites.

Consumer Health Data We Create, Infer, or Generate

We may create, infer, or generate Consumer Health Data from other data we collect, including by using automated methods to generate information about your likely preferences or other characteristics.

Consumer Health Data We Obtain from Third-Party Sources

We also obtain the types of Consumer Health Data described above from third parties. Such third-party sources may include, for example:

Corporate affiliates. We may receive your Consumer Health Data from our corporate affiliates.
Third-party partners. Third-party applications and services, including social networks, that you choose to connect with or interact with through our services.
Co-branding/marketing partners. Partners with whom we offer co-branded services or participate in joint marketing activities.
Service providers. Third parties that collect or provide data related to the work they perform on our behalf.
Publicly available sources. Public sources of Consumer Health Data, such as open government databases.

Consumer Health Data Usage

We use consumer health data for the purposes described in this Consumer Health Data Privacy Policy or otherwise disclosed to you. For example, we use consumer health data for the following purposes:

Purpose of Use	Categories of Consumer Health Data
Product and service delivery. To provide and deliver our Service and operate our business, including analyzing Service use, troubleshooting, facilitating your movement through the Service, confirming your location, billing, processing your payments, accounting, administering your account, securing our systems, detecting fraudulent or illegal activity, providing customer support, communicating with you about the Service, personalizing the Service, verifying your identity and complying with our legal obligations and enforcing our rights.	Contact information, demographic data, payment information, content and files, biometric information, identifiers and device information, location data, usage data, inferences, government ID, account access information, health data, information about sex life, reproductive health, or sexual orientation.
Product improvement, development, and research. To develop, test, or improve the Service and content, features and/or products or services offered via the Service. Additionally, to Identify or create new products or services. Lastly, to analyze traffic and user behavior or activity to and through Service.	Contact information, demographic data, payment information, content and files, biometric information, identifiers and device information, usage data, inferences, government ID, account access information, location data, genetic data, health data, information about sex life, reproductive health, or sexual orientation.
Aggregation, de-identification and/or anonymization. We may create aggregated, de-identified and/or anonymized data from your Consumer Health Data. We make Consumer Health Data into de-identified and/or anonymized data by removing information that makes the data identifiable to you and we will not attempt to re-identify such data other than if required by applicable law. We may use and disclose this aggregated, de-identified and/or anonymized data with third parties.	Contact information, demographic data, payment information, content and files, biometric information, identifiers and device information, location data, usage data, inferences, government ID, account access information, health data, information about sex life, reproductive health, or sexual orientation.
Marketing. To communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners.	Contact information, demographic data, payment information, content and files, biometric information, identifiers and device information, location data, usage data, sensor data, inferences, health data, information about sex life, reproductive health, or sexual orientation.

Retention of Consumer Health Data

We retain Consumer Health Data for as long as necessary to fulfill the purposes for which it was collected and to comply with legal, regulatory, or business requirements. Our retention periods vary depending on the type of data and how it is used.

Security of Consumer Health Data

We implement and maintain appropriate administrative, technical, and physical safeguards designed to protect the security, confidentiality, and integrity of your Consumer Health Data. These measures are designed to provide a level of security appropriate to the risks associated with processing your Consumer Health Data. However, no security measure is perfect, and we cannot guarantee the security of your Consumer Health Data.

Your Rights Regarding Consumer Health Data

You have certain rights regarding your Consumer Health Data as described in this section. These rights may vary based on your location and are subject to applicable laws.

Access and Correction

You have the right to access and correct your Consumer Health Data. If you wish to access or correct your Consumer Health Data, please contact us using the information provided below. We may ask you to verify your identity before fulfilling your request.

Deletion

You have the right to request the deletion of your Consumer Health Data under certain circumstances. Please note that we may retain certain data as required by law or for legitimate business purposes.

Objection to Processing

You have the right to object to the processing of your Consumer Health Data under certain circumstances. To exercise this right, please contact us using the information provided below.

Data Portability

You have the right to request and obtain a copy of your Consumer Health Data in a structured, commonly used, and machine-readable format. This allows you to transmit your data to another service provider. For more information about exercising these rights, please contact us using the information provided below.

Withdrawal of Consent

If you have provided consent for the collection, use, or sharing of your Consumer Health Data, you have the right to withdraw your consent at any time. Please note that withdrawing your consent does not affect the lawfulness of any processing based on your consent before its withdrawal.

How to Exercise Your Rights

To exercise your rights regarding your Consumer Health Data, please contact us using the contact information provided below. We will respond to your request in accordance with applicable laws.

Changes to This Policy

We may update this Consumer Health Data Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, and other factors. When we update this Consumer Health Data Privacy Policy, we will revise the "Last Updated" date at the top of this page. If we make material changes to this Consumer Health Data Privacy Policy, we will notify you by prominent posting on our website or through other appropriate communication channels.

Contact Us

If you have any questions or concerns about this Consumer Health Data Privacy Policy or our privacy practices, please contact us at:

Columbia Medical IDTF, LLC
123 Main Street
Anytown, USA 12345
Email: privacy@cmwellcare.com
Phone: (123) 456-7890