Accolade Mobile Privacy Policy

Last updated: May 2017

This “Privacy Policy” describes how your personal information may be collected and used by Accolade, Inc. and its affiliates (“Accolade”) related to your use of the Mobile app, and/or any other Accolade owned websites which are linked from the Mobile app (the “Accolade Mobile App”).  This Privacy Policy is intended to be read in conjunction with the Terms of Use for the Accolade Mobile App.  By clicking “Accept” below, and using the Accolade Mobile App, you are expressly agreeing that you have read and understood this Privacy Policy.  Please read this Privacy Policy carefully.

Revisions to These Terms

This Privacy Policy was last updated as of the date indicated above. Accolade may revise this Privacy Policy at any time.  Accolade will indicate that a change has been made to this Privacy Policy on your next use of the Accolade Mobile App.  Any revision and/or addition to this Privacy Policy shall become effective and binding on you when you continue to use the Accolade Mobile App on or after posting of such revision and/or addition.

No Medical or Legal Advice

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. No material contained within or provided through the Accolade Mobile App should be construed as medical advice and/or treatment.  Accolade does not practice medicine and no physician or nurse to patient relationship is created as a result of your use of the Accolade Mobile App.  You should seek the care of your healthcare professional.

IF YOU ARE EXPERIENCING A HEALTH EMERGENCY, CALL 911 OR YOUR HEALTHCARE PROFESSIONAL IMMEDIATELY.

Nothing contained or provided through the Accolade Mobile App is intended or should be construed as legal advice or guidance.  No attorney-client relationship is created between you and Accolade or its personnel.  If you have any questions about any law, rule or regulation, or seek legal advice regarding your healthcare, you should contact your own legal counsel.

What Types of Information Do We Collect

We are delighted to bring you the Accolade Mobile App, which permits you and your families the opportunity to receive the same great Accolade service that we provide to hundreds and thousands of families through our Accolade Health Assistants® in the form of a mobile app.  The Accolade Mobile App will allow you to communicate with your personal Accolade Health Assistant® and to access certain information about your health benefits and claims. This Privacy Policy is designed to advise you of how we will access, transmit, and store your information as part of your use of the Accolade Mobile App, how we protect such information, how your information may be used or disclosed, and what rights you have to access your information.  Unless otherwise specified, this Privacy Policy does not describe how Accolade may handle your information in offline settings, which may be addressed in the Notice of Privacy Practices of your health plan.

In order to provide you with access to the Accolade Mobile App, there is certain personal and protected health information that the Accolade Mobile App will securely access and transmit.  Much of this information is similar to the information that our health assistants access for you today, and includes certain personal and health related information, such as:

  • general personal and demographic information (e.g., name, sex, date of birth, address, dependents)
  • health plan benefits and eligibility information
  • health and claims information
  • certain personal device information (such as physical location, IP address, battery usage, data or application usage, and accelerometer data)
  • other personal or protected health information that you may provide to Accolade via the Accolade Mobile App

collectively, “Your Personal Information.”

Beyond Your Personal Information, Accolade may collect certain other information from you when you are using the Accolade Mobile App; for example:

  • operating system version
  • device type
  • access or duration of use times
  • server logs
  • cookies
  • pixel tags or beacons and other tracking tools
  • app navigation and general analytics

collectively, “General Usage Information.”

How We Acquire or Access Your Personal and General Information

When your register to use the Accolade Mobile App, you will be asked to provide certain personal information, including name, date of birth, address, social security or other identifying code, in order for us to verify your identity and to associate your mobile account with our client record for you.

Once you are registered, and agree to use the Accolade Mobile App, you are permitting Accolade to transmit and receive Your Personal Information via the Accolade Mobile App.  The Accolade Mobile App provides functionality for you to view certain of Your Personal Information that Accolade already maintains as part of its role as a service provider to your employer and/or a health plan carrier through which you have purchased a health plan or other benefits, and for you to submit certain of Your Personal Information to Accolade to help you understand your healthcare options, facilitate your use of the healthcare system and support you as you make your healthcare decisions. The content we provide you is for informational purposes only. Accolade does not provide medical advice, provide nursing care, diagnose or deliver treatment. Those are activities for you to undertake with your doctor or other appropriately trained and qualified health professional.

When you use the Accolade Mobile App, some information may be automatically collected. For example, your mobile device operating system, device identifier (e.g., a number that is automatically assigned to your device used to access the Accolade Mobile App, and allows us to identify your device), access times, operating system type, device type, access times, duration of use, platform, new and repeat information, time stamp and language, and other similar information commonly used to track usage of applications on mobile devices may be logged automatically.

How We Use Your Personal Information

Generally speaking, we access and use Your Personal Information only as may be necessary to provide Accolade Mobile App to you, and to support the other services that Accolade provides to you. We may use Your Personal Information for the following purposes:

  • to authenticate you and/or your personal device for purposes of application security and to help prevent fraud and data loss
  • to permit you to view certain of Your Personal Information that Accolade already maintains as part of its role as a service provider to your employer and/or a health plan carrier through which you have purchased a health plan or other benefits
  • for you to submit certain of Your Personal Information to Accolade to help you understand your healthcare options, facilitate your use of the healthcare system and support you as you make your healthcare decisions
  • to deliver certain products and services to you that Accolade provides or that you have agreed to receive from Accolade’s partners
  • to send you marketing and promotional communications that make you aware of your eligibility for certain benefits, or to provide information about products and services that may be of interest to you

We also may share Your Personal Information with professionals who are treating you or for billing or claims purposes.

We may also use your information for Accolade internal purposes, such as for quality control, compliance review or for training. Whenever we do disclose your personal or medical information to others, we only share the minimum necessary amount of information. Otherwise, we will only share personally identifiable information or health information with your permission.

Your Personal Information may or may not be individually identifiable health information that is also protected by the federal HIPAA privacy law and various state laws. Where Your Personal Information also constitutes individually identifiable health information under the HIPAA, Your Personal Information will be handled in accordance with HIPAA and other applicable laws, and will govern Accolade’s permitted uses and disclosures of Your Personal Information. From time to time, Accolade may create and distribute de-identified health information by removing all references to personally identifiable information. Any distribution of such de-identified information is anonymous.

Special Note: Even if you decide not to use the Accolade Mobile App, Accolade will have access to certain of the above-referenced information in its role as a service provider to your employer and/or a health plan carrier through which you have purchased a health plan or other benefits.  As an employee or member of a health plan of an Accolade customer, you have already consented to Accolade’s access to and use of such information for these purposes.  This will not change whether or not you use the Accolade Mobile App.  If you have purchased a health plan from one of Accolade’s health plan customers, or receive benefits through a group health insurance plan administered by your employer, please refer to the “Notices of Privacy Practices” available to you through such heath plan carrier (e.g., a Blue Cross Blue Shield company) or your employer with respect to how your personal information may be used and disclosed in connection with your health benefits.

How We Use General Usage Information?

We may use your General Usage Information in the following manner:

  • operate and improve the Accolade Mobile App and associated services;
  • to monitor and track your access to and usage of the Accolade Mobile App, and understand and analyze information related to the number and type of visitors that browse and use the Accolade Mobile App;
  • respond to your comments and questions and provide customer and support service;
  • link or combine with other information we get from third parties, to help understand your needs and provide you with better information and services via the Accolade Mobile App;
  • personalize and customize the content, marketing, and other information provided to you in relation to our services through the Accolade Mobile App;
  • contact you to provide responses to your inquiries or to provide you with additional information about our products and services;
  • send you notices about and/or register you for events; and
  • 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.

By using the Accolade Mobile App, you are opting in to receive such information from Accolade, including by direct message via the Accolade Mobile App or separately by email.

Third Party-Disclosure

Your Personal Information will not be sold, 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 HIPAA and state privacy laws.

Under HIPAA, and other state privacy laws, Accolade may be permitted to disclose individually identifiable health information to business associates of Accolade or its customers who perform various functions or provide services on their behalf.  To perform these functions or to provide services, business associates will receive, create, maintain, use, or disclose individually identifiable health information that has been provided to or made available to the business associate by Accolade, but only after we require the business associates to agree in writing to contract terms designed to safeguard your information or, in the case of your Employer’s or health plan carrier’s business associates, reasonable assurance that they will safeguard Your Personal Information.

In addition to the above, we may share General Usage Information collected from you, as described above, with our third party partners to enable us to analyze and use such information in the manner set forth in this Privacy Policy.  We also may provide certain information to our partners who assist us in operating the Accolade Mobile App, conducting our business, or serving our clients, so long as those parties agree to keep this information confidential and comply with applicable law.  We do not sell your information to third parties for marketing purposes independent from the marketing performed by or on behalf of Accolade, your employer or your health plan carrier, and we restrict such third parties’ usage of your information consistent with this Privacy Policy.

In addition to the above, you acknowledge that we may be required to disclose your information to (i) comply with laws or to respond to lawful requests and legal process, (ii) to investigate, prevent, or take action regarding illegal or suspected illegal activities, (iii) to protect the rights and property of Accolade, and others to enforce our agreements, and this Privacy Policy and Terms of Use, (iv) in an emergency to protect person or property, (v) as may be needed on a confidential basis to support a corporate transaction (including a merger, acquisition, divestiture, financing, or sale of assets or lines of business, or (vi) on an aggregated basis for any purpose in which your specific personal information is blinded, masked or otherwise not identifiable.

How We Protect Your Information?

The security, integrity, and confidentiality of your information are extremely important to us.  We have implemented technical, administrative and physical security measures that are designed to protect your information from unauthorized access, disclosure, use and modification. We comply with applicable law and follow industry standard practices to protect and secure and maintain the integrity and availability of your information.

Such protections include strong encryption of Your Personal Information when in-transit across public networks.  The Accolade Mobile App Site and our internal networks supporting the Accolade Mobile App are scanned regularly for malware and other viruses.  Accolade monitors the Accolade Mobile App for any security incidents that could compromise your information.

Notwithstanding the foregoing, you acknowledge that no security safeguards or method of transmission over the Internet are completely secure.  Accolade assesses its security procedures regularly and will make updates and enhancements in order to better protect your information.  We ask that your take similar appropriate measures to protect their information, including by securing your access credentials (e.g., user name and password), not permitting your mobile device to be used by others, and by exiting from the Accolade Mobile App after each use to ensure no information is available after you end a session on the Accolade Mobile App.  Accolade will not be liable for any losses or damages arising from your failure to comply with these Terms.

If you believe that your access information has been compromised or become aware of any other security incident involving the Accolade Mobile App or your account, you agree to immediately notify Accolade.

Third Party Information / Links

Whether via your Accolade Health Assistant® or through the Accolade Mobile App, Accolade may provide links to other third-party websites that are not under our control. Accolade is not responsible for the content found on any third-party sites. We provide these links for your convenience and for information purposes only.

Following links to or from any other sites or pages shall be at your own risk and Accolade accepts no responsibility or liability, to the extent permitted by any law, for any losses or penalties whatsoever that may be incurred as a result of any linking to any location on any linked sites or pages.

Advertising

Accolade does not permit third parties, other than your employer or health plan carrier, to advertise on the Accolade Mobile App.

However, Accolade may serve online ads to you on other web sites based on your usage of the Accolade Mobile App or other information that we receive about you. Accolade does not direct interest-based advertising to children as defined under the Children’s Online Privacy Protection Act, or where Accolade has actual knowledge that a user is under 13 years of age.

Not Intended For Persons Under Age 18

The Accolade Mobile App is not intended for use by persons under the age 18.  Parents and other guardians or custodians may be granted access, subject to applicable law and appropriate verification, of information concerning their minor children.  Adults should not assist minors in accessing the Accolade Mobile App. When visitors enter personal information into the Accolade Mobile App, the user is representing that he/she is an adult over 18 years old.

If registration is required for any services on the Accolade Mobile App, and a user submits information through such a registration process that indicates that such user is a child, the child’s parent or guardian will be alerted to the child’s registration and will be provided instructions on how the parent or guardian can delete the child’s registration, if so desired.

When It Comes To Your Health Information, You Have Certain Rights

To the extent Accolade has such information, you can ask to see or get an electronic or paper copy of your medical record and certain other health information we have about you. Ask us how to do this; we may charge a reasonable, cost-based fee for the compilation as permitted by applicable law.

You can ask us to limit what health information we use or share. (Important Note: We are not required to agree to your request under certain circumstances, which we will explain if asked, including if your request is unreasonable or if we are not entitled to accept such request as in when we are a service provider to your health plan).

You can ask us to contact you in a specific way (for example, home or office phone) or in a specific location. For example, if you would prefer that we only contact you through the Accolade Mobile App, we will note that in your record.  (Important Note: We are not required to agree to your request under certain circumstances, which we will explain if asked, including if your request is unreasonable or if we are not entitled to accept such request as in when we are a service provider to your health plan).

You can get a list of those with whom we’ve shared information (for the six years prior to your request); we will charge a reasonable, cost-based fee for the compilation as permitted by applicable law.

You can choose someone to act for you as your personal representative.  We may ask you to designate such person in writing using a form of our choice.

You can file a complaint if you feel your rights are violated. You can contact Accolade’s Privacy Officer at the address below, or file a complaint with the US Department of Health and Human Services, Office for Civil Rights, by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775 or visiting www.hhs.gov/ocr/privacy/hipaa/complaints. We will not retaliate against you for filing a complaint.

You can get a paper copy of this notice on request.

You have the right to correct any personal or medical information about you maintained or collected by Accolade; just ask us how to do this.

Contact Us

If you have any questions, comments or concerns about the Accolade Mobile App or these Terms, please contact us as follows:

FOR GENERAL INQUIRIES:
Legal@Accolade.com

FOR PRIVACY INQUIRIES:
Privacy@Accolade.com

FOR SECURITY CONCERNS:
Security@Accolade.com

MAIL:
LEGAL DEPARTMENT
ACCOLADE, INC.
660 WEST GERMANTOWN PIKE, SUITE 500
PLYMOUTH MEETING, PA. 19462

MAIL:
CHIEF PRIVACY OFFICER
ACCOLADE, INC.
660 WEST GERMANTOWN PIKE, SUITE 500
PLYMOUTH MEETING, PA. 19462

MAIL:
CHIEF INFORMATION SECURITY OFFICER
ACCOLADE, INC.
ONE CONVENTION PLACE 701 PIKE STREET, SUITE 700
SEATTLE, WA 98101

While the Accolade mobile App provides for secure electronic messaging, email that you send to Accolade through the above email addresses, like most, if not all, non-encrypted Internet e-mail communications, may be accessed or intercepted and viewed by other Internet users, without your knowledge and permission, while in transit to us. We do not control the transmission of information to these email addresses through the Internet.

For that reason, to protect your privacy, please do not use email to communicate information to us that you consider confidential. If you wish, you may contact your Accolade Health Assistant through the Accolade Mobile App securely or use the telephone numbers that appears on your ID card.

Your Acceptance

You can accept this Privacy Policy by selecting “I ACCEPT”.  You understand that this will mean that you have read and understood this Privacy.