(updated December 26, 2019)
Your privacy is very important to Accolade. This “Privacy Notice" has been compiled to assist you in understanding the ways in which we, Accolade, Inc. and its affiliates (“Accolade"), collect personal information from you as you use the www.accolade.com website (the “Site"). Please read this Privacy Notice carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personally identifiable information.
If you are a member of Accolade services, please remember that Accolade is here to simplify healthcare and your health benefits for you and your family. We are here to help you understand your healthcare options, to facilitate your use of the healthcare system and to support you as you make your healthcare decisions. The content we provide you is for informational purposes only, is based on the best available information, and may not be relied upon when alternative and more relevant information (such as, for example, information provided directly by your health care provider) would be more relevant or accurate. No material contained within or provided through the Accolade Site should be construed as medical advice and/or treatment. Accolade shall have no responsibility or liability for out-of-pocket costs you may incur for actual care provided or medical procedures performed by your healthcare provider(s), and you are responsible for understanding and evaluating such costs, including any costs known as “surprise billing" or costs incurred as a result of balanced billing, notwithstanding information provided by Accolade based on best available information. Accolade does not provide medical advice, provide nursing care, diagnose or deliver treatment and no physician- or nurse-to patient-relationship is created as a result of your use of the Accolade Site. Those are activities for you to undertake with your doctor or other appropriately trained and qualified health professional. IF YOU THINK YOU HAVE A MEDICAL EMERGENCY, YOU SHOULD CALL YOUR DOCTOR OR 911 IMMEDIATELY.
Accolade may provide, from time to time, various digital services to its customers and members, including the Accolade Portal (including the web service known as MyAccolade), Accolade Digital Tools, and the Accolade Mobile App. Such digital services have their own terms and conditions and privacy notices, and your use of such services is subject to those terms and conditions and privacy notices. Those digital services are just one more way you can connect with your Accolade Health Assistant® representative to support you and your family in your healthcare journey.
This Privacy Notice applies only to your use of the Site, and was last updated as of December 26, 2019. Accolade may revise this Privacy Notice at any time and such revision will be posted here and accessible at the following link: https://www.accolade.com/legal/policies/privacy/. Any revision and/or addition to this Privacy Notice shall become effective and binding on you when you continue to use the Site on or after the effective date of such revision and/or addition.
What Information Does Accolade Collect Through the Site?
Information You Choose to Provide.
- when communicating with Accolade in general, you may be asked to provide your first and last name, postal address, email address, or other contact information; or
- when inquiring about an open job posting, you may desire to upload your resume or connect with us using various third party tools, such as LinkedIn or Indeed (we are not responsible for third party use of your information); or
- when registering for an event or a webinar, Accolade or its third party partners may ask you to provide personal information for the purpose of registering you for such event or webinar and providing access to the event.
As further detailed below, we may also collect certain non-personally identifiable information about how you use the Site.
We do not collect and ask that you not provide us with any medical, health, financial or other sensitive personal information through the Site.
Information Collected Via Your Use of our Site
We may collect information from you when you are using the Site in a number of different ways; for example:
- we may collect and track your IP address;
Information We Collect Automatically.
We may now or in the future use tools, including third-party analytical software, to collect automatically certain data about the computer or other device you use to reach our Site such as: (i) device properties including, but not limited to, unique or other device identifiers; (ii) device operating system and firmware; (iii) IP address (i.e., a number that is automatically assigned to your device or computer used to access the Site, and allows us to identify your device or computer) and Internet service provider; (iv) mobile phone carrier; (v) geographical data such as country or region; and (vi) other similar data. Accordingly, when you visit our Site, some information may be automatically collected. Such information may also include Site access times, browser type and settings, device type, domain name, access times, duration of visit, referring URL, platform, new and repeat information, time stamp and language, and referring website addresses all of which may be logged automatically. We may also collect information about your usage and activity on our Sites.
This information may be collected via several technologies, including cookies, web beacons, clear GIFs and other means. All of this information belongs to us, and we use it to improve effectiveness, content, layout and/or operation of our Site. You can remove certain cookies by following the directions in your Internet browser’s “help" file. If you disable cookies, your ability to use areas of the Site may be limited. Additionally, Accolade provides a mechanism to remove certain cookies, as discussed below.
How We Use Your Information?
In general, we do not and will not share your personally identifiable information except as set forth in this Privacy Notice. We do not sell, transfer, and/or share your personally identifiable information with third parties for their own marketing purposes.
We use the information we collect from you when you browse the Site in the following manner:
|Category Name||Categories of Your Personal Information||Use of Information|
|Personal Identifiers||Identification information, message content, application usage data (e.g., features/pages accessed by a member), location data (GPS).||To operate and improve the Site and associated services.|
|Usage Information||Identification information, message content, application usage data (e.g., features/pages accessed by a member), location data (GPS).||To understand and analyze information related to the number and type of visitors that browse and use the Site.|
|Member Support||Name, phone number, mailing address, email address.||To respond to your comments and questions and provide customer services.|
|Candidate Employee Support||Name, mailing address, email, phone number, employment application information||To permit you to apply for a job at Accolade, connect with third parties that we use to process job application information, and receive more information about open positions at Accolade.|
|Event Registration Information||Name, mailing address, email address, phone number, demographic information||To register for various events and webinars.|
|Member communications||Name, mailing address, email address, phone number||To communicate with you about new contests, promotions and rewards, upcoming events, and other news about products and services offered by Accolade and our selected partners.|
|Member outreach||Name, mailing address, email address, phone number||To conduct outreach and engagement communications to make you aware of Accolade services.|
|Internal Business Purposes||Name, mailing address, email address, phone number, demographic information||To link or combine with other personal information we get from third-parties, to help understand your needs and provide you with better information on the Site.|
If you provide Accolade with your contact information to receive marketing materials, you are opting-in to receive information from Accolade, including by email. You can opt-out anytime from the types of uses of your information, and receiving these communications, as further described below.
Who Has Access to Your Information?
YOUR PERSONAL INFORMATION WILL NOT BE SOLD. Nor will Your Personal Information be licensed or disclosed to unaffiliated third-parties, except in connection with the sale, transfer, merger, consolidation or other transaction involving all or part of our company or as may be permitted under applicable law.
In addition to the above, we may share the information collected from you, as described above, with our third party partners to enable us to analyze and use such information to provide you with our services and in the manner set forth in this Privacy Notice. We may share your information with third-parties who assist Accolade with its outreach and engagement communications to make you aware of certain of Accolade’s services. We also allow our website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, to access and process your information so long as those parties agree to keep this information confidential. We do not sell your information to third parties for marketing purposes, and we restrict such third parties’ usage of your information consistent with this Privacy Notice.
How Do We Protect Your Information?
We follow industry standard practices to protect, secure and maintain the integrity and availability of your information. The Site and our internal networks supporting the Site are scanned regularly for malware and other viruses. Notwithstanding the foregoing, you acknowledge that no security safeguards or method of transmission over the Internet are completely secure.
The Site is not intended to collect, maintain or transmit your information to the privacy and security standards used in healthcare or banking where sensitive medical, health, or financial information may be transmitted. The Site is not protected according to HIPAA/HITECH, PCI or other such standards. DO NOT USE THE SITE OR COMMUNICATION TOOLS TO SEND US SENSITIVE PERSONAL OR PROTECTED HEALTH INFORMATION (e.g., do not send us your health information, benefit or ID card number, health claims information, social security number, financial account number, passcodes, etc.). For this reason, Accolade does not secure the transmission of your information submitted through the Communication Tools (as defined above), including using the addresses and numbers provided in the “Get in Touch" section of the Site.
How Long Do We Keep Your Information?
We store your information for as long as necessary to serve the business purposes for which it was collected and in conformance with applicable data protection laws.
We want to be completely transparent about the cookies we use and to make their control as easy as possible for you. When you first enter our Sites, you will be asked to accept or reject cookies. If, after your initial visit to the Site, you decide to change your cookie selection, you can do so by https://www.accolade.com/legal/policies/cookies.
Further, if you want to delete any cookies that are already on your computer, please refer to the file management software to locate the file or directory that stores cookies under the following file names. Other information on deleting or controlling cookies is available at www.allaboutcookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.
What Are the Privacy Policies of Third-Party Websites to Which the Site Links?
Occasionally, at our discretion, we may link to third party sites or content on the Site. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these third party sites. We urge you to review the privacy policies posted on these third-party websites at the time you first visit such sites.
Where Does Data Storage and Processing Occur?
The Site collects information and processes and stores that information in databases located in the United States. If you are visiting the Site from a country outside the United States, you should be aware that you may transfer personally identifiable information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Site and submitting any personally identifiable information you consent to the transfer of such personally identifiable information to the United States.
The California Consumer Privacy Act of 2018 (“CCPA") and other California privacy laws provides California residents (i.e., consumers) with specific rights regarding personal information. This section of the Privacy Notice describes those CCPA rights and how to exercise those rights.
This section does not apply to publicly available information or to protected health information that is collected and governed by the privacy, security, and breach notification rules issued by the federal Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Availability Act of 1996 (“HIPAA").
Access to Specific Information and Data Portability Rights
California residents have the right to request that Accolade disclose certain information to you about Accolade’s collection and use of your personal information over the past twelve (12) months. Once Accolade receives and confirms a verifiable consumer request from you, Accolade will disclose to you, to the extent permitted by law:
- The categories of personal information Accolade collected about you.
- The categories of sources for your personal information Accolade collected about you.
- Accolade’s business or commercial purpose for collecting your personal information.
- The categories of third parties with whom Accolade shares your personal information.
- If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.
You shall have the right to request that the information described above be provided to you in a portable and readily useable format, to the extent technically feasible (“data portability").
Accolade does not sell your personal information.
Deletion Request Rights
You have the right to request that Accolade delete certain of your personal information that Accolade collected from and/or related to you and retained, subject to certain exceptions. Because of the relationship between Accolade and your employer and/or your health plan carrier, Accolade cannot delete your personal information provided by your employer, your health care provider and/or other entities that support your health benefits plan.
To the extent that Accolade can delete your personal information, once Accolade receives and confirms your verifiable consumer request, Accolade will delete (and direct our service providers to delete) your personal information, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected your personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, your employer, or your health plan carrier.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Your Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Accolade by either:
- Visiting the Data Subjects Rights Portal located here; or
- Calling the following toll-free number at 1 (888) 914-9661, and using PIN# 494 202 to identify that you are calling with respect to Accolade.
We ask that you not provide us with any medical or protected health information through the above communications.
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows Accolade to reasonably verify you are the person about whom Accolade collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows Accolade to properly understand, evaluate, and respond to it.
Accolade cannot respond to your request or provide you with your personal information if Accolade cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. Any disclosures provided pursuant to the CCPA will only cover the 12-month period preceding the receipt of the verifiable consumer request.
Accolade will respond to a verifiable consumer request within 45 days of its receipt, or notify you that Accolade requires more time to respond and the reason for the extended response time. Accolade will deliver its written response by mail or electronically, at your option.
To the extent that your verifiable consumer request is excessive, repetitive, or manifestly unfounded, Accolade may charge a reasonable fee to respond to such request.
Accolade will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Accolade will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Additional Terms for EU Visitors
This website is intended only for users located in the United States. To the extent that you are accessing this website from a location within the European Union, the following information shall apply to the collection and processing of your Personal Information.
The data controller for this Site is Accolade, Inc. Accolade processes Personal Information it collects through the Site for Accolade’s legitimate business purposes, for example to fulfill any requests you may make in connection with your submission of personally identifiable information, to monitor and improve the quality of the Site, and to protect and defend our rights, property or safety or that of our clients and other users of the Site. You may have the right to access and/or obtain a copy of your Personal Information, correct inaccuracies in your Personal Information, request the erasure of your Personal Information and restrict the processing of your Personal Information. For more information about how you can access, rectify and erase your Personal Information or make any other requests relating to your Personal Information or to contact Accolade, please see the “Contact Us" section of this Privacy Notice below. In addition, you have the right to lodge a complaint with a supervisory data protection authority, contact information is available at https://edpb.europa.eu/about-edpb/board/members_en.
Does the Site Use Other Third Party Tools, such as Google AdSense?
Accolade has enabled Google AdSense on the Site. Google AdSense is an advertising service provided by Google. Accolade uses the “Doubleclick" Cookie, which tracks use of www.accolade.com and user behavior concerning ads, products and the services we offer. You may decide to disable all the Doubleclick Cookies by clicking on: www.google.com/settings/ads/onweb/optout?hl=en.
Google’s advertising requirements can be summed up by Google’s Advertising Principles: https://support.google.com/adwordspolicy/answer/1316548?hl=en
Google provides a breakdown of the information relevant to the collection and processing of data by Google AdSense:
- Personal Data collected: Cookie and Usage Data.
- Place of processing: USA.
Electronic Mail from Accolade
When you provide your email to Accolade by using the Communication Tools (as defined above), you can select to opt-in to receive email from Accolade. If you opt-in to the receipt of this electronic mail, we will:
- not use false or misleading subjects or email addresses;
- identify the message as an advertisement in some reasonable way;
- include the physical address of our business or site headquarters;
- monitor third-party email marketing services for compliance, if one is used;
- honor opt-out/unsubscribe requests quickly; and
- allow users to unsubscribe by using the link at the bottom of each email.
You can unsubscribe from promotional emails at any time by: (1) following the unsubscribe instructions in our emails; or (2) emailing us at [email protected] or [email protected] You may update your email preferences anytime as well. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account and your use of the Service. For example, even if you have unsubscribed from our email messages, we will still send you emails relating directly to a profile created through the Service confirming registration.
Do Not Track
We may not recognize or respond to every type of “do not track" signal or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third-party websites or online services, but we give you certain choices about how we collect personally identifiable information as described in this Privacy Notice. Many Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site including certain opt-out cookies.
We encourage you to review the privacy policies of our third party advertisers and analytics service providers to learn about your choices about information they collect from you. In addition, the Network Advertising Initiative offers information about some of the Internet advertising companies we may use, including how to opt-out of interest based advertising they deliver. To opt-out of Google Analytics web tracking you can download Google Analytics Opt-out Browser Add-on.
For all the details, including how to turn on Do Not Track, visit www.donottrack.us.
Not Intended for Children Under 13
The Site is not intended for use by persons under the age of 18 and Accolade does not specifically market to children under 13.
Changes to this Privacy Notice
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 notify you by email or through a notice on our website homepage.
If there are any questions regarding this Privacy Notice you may contact us using the information below.
660 West Germantown Pike, Suite 500 Plymouth Meeting, PA 19462
Attn: Chief Privacy Officer