PeopleOne Health Privacy Policy

This Privacy Policy was Last Updated on and is Effective as of September 1, 2021.

PeopleOne – Privacy Policy

General Provisions

Our Commitment To Privacy

Thank you for visiting www.peopleonehealth.com (the “Website”) and/or accessing the PeopleOne™ mobile application (the “Application”), which are owned and operated by PeopleOne Health, Inc. d/b/a PeopleOne Health (“PeopleOne”, “we”, “us”, or “our”) or otherwise obtaining our Services.  PeopleOne is a provider of fully integrated health plans for organizations focusing on the employee experience.  Terms used herein and not otherwise defined shall have the meanings attributed to them in our Terms of Use, available here: portal.peopleonehealth.com/HealthyLiving/Article/1463, which Terms of Use are hereby incorporated by reference.

PeopleOne recognizes the importance of maintaining your privacy, and as a result, has established this Privacy Policy (“Privacy Policy”). This Privacy Policy is intended to help you understand the types of information we may collect from you or that you may provide when you visit the Website and when you download or access the Application, and/or when you use any Services or Functionality, and describes our practices for collecting, using, maintaining, protecting and disclosing such information. This Privacy Policy applies to information we (or our Service Providers on our behalf) collect on or through the Website and the Application or when performing or providing any Services (including Account Services), or otherwise provided to us by Organizations or their Authorized Users (including in connection with the establishment of Accounts), your Empower360 health care providers, or your insurers about you, as well as information we collect from you via emails from you to us, in text messages you send to us, and whenever you provide us with Personally Identifiable Information (either offline or online), and does not govern information collected from you in any other manner.

PLEASE CAREFULLY READ THIS PRIVACY POLICY BEFORE YOU START USING THE WEBSITE OR THE APPLICATION OR ANY SERVICES.  BY ACCESSING THE WEBSITE, DOWNLOADING OR USING THE APPLICATION, CAUSING INFORMATION OR DATA TO BE TRANSMITTED TO OR THROUGH THE WEBSITE OR THE APPLICATION, USING THE SERVICES, BY MANIFESTING YOUR ACCEPTANCE OF THESE TERMS PURSUANT TO A PURCHASE ORDER, OR BY CLICKING OR CHECKING THE “I ACCEPT” BUTTON OR CLICKBOX IF AND WHEN THIS OPTION IS MADE AVAILABLE TO YOU, YOU:

1. AGREE TO BE LEGALLY BOUND, WITHOUT LIMITATION OR QUALIFICATION, TO THIS PRIVACY POLICY AND OUR TERMS OF USE LOCATED AT PORTAL.PEOPLEONEHEALTH.COM/HEALTHYLIVING/ARTICLE/1463;
2. REPRESENT AND WARRANT THAT YOU ARE 18 YEARS OF AGE OR OLDER;
3. REPRESENT AND WARRANT THAT, IF YOU ARE ENTERING INTO THIS PRIVACY POLICY ON BEHALF OF AN ORGANIZATION (INCLUDING, WITHOUT LIMITATION, PURSUANT TO A SERVICE AGREEMENT), YOU ARE AUTHORIZED TO ACT ON BEHALF OF THE ORGANIZATION AND TO BIND THE ORGANIZATION TO THIS PRIVACY POLICY, AND YOU UNDERSTAND THAT “YOU” AND “YOUR” AS USED HEREIN REFER TO BOTH YOU INDIVIDUALLY AND TO THE ORGANIZATION UNLESS OTHERWISE INDICATED; AND
4. REPRESENT, WARRANT, AND COVENANT THAT YOU HAVE OBTAINED ADEQUATE CONSENT AND WRITTEN AUTHORIZATION FROM EACH INDIVIDUAL AND/OR ENTITY AS REQUIRED UNDER APPLICABLE LAW TO ENABLE YOU TO LEGALLY VIEW, ACCESS, USE, COLLECT, STORE, SUBMIT, UPLOAD, TRANSMIT, DISCLOSE, SHARE WITH, AND OTHERWISE PROVIDE TO US AND OUR SERVICE PROVIDERS ANY AND ALL INFORMATION, CONTENT, MATERIALS, FILES, AND/OR DATA THAT YOU HAVE OR WILL INPUT INTO THE WEBSITE AND/OR THE APPLICATION AND/OR THAT YOU CAUSE TO BE TRANSMITTED TO OR FROM OR SHARED THROUGH THE WEBSITE AND/OR THE APPLICATION OR WHICH YOU OTHERWISE PROVIDE TO US OR OUR SERVICE PROVIDERS IN CONNECTION WITH THE SERVICES INCLUDING, WITHOUT LIMITATION, YOUR OR YOUR EMPLOYEES’ PERSONALLY IDENTIFIABLE INFORMATION AND ANY USER-PROVIDED DATA.

IF YOU DO NOT AGREE TO ALL, OR ANY, OF THE PROVISIONS IN THIS PRIVACY POLICY PLEASE IMMEDIATELY EXIT AND MAKE NO FURTHER USE OF THE WEBSITE, THE APPLICATION, AND/OR THE SERVICES AND DELETE THE APPLICATION FROM YOUR DEVICES.

The Website and the Application Are Not Intended For Use By Individuals Under 18 Years of Age

We do not knowingly collect personal information, including Personally Identifiable Information, directly from anyone under 18.  If you are under 18, do not: (i) use or directly provide any information or User-Provided Data on the Website or the Application or otherwise provide us with Personally Identifiable Information or (ii) directly provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.  If we do inadvertently collect Personally Identifiable Information from individuals under the age of 18 and we become aware of same, we will delete this Personally Identifiable Information from our (and our Service Providers’) systems and servers.

Collection of Information

The Website, the Application and our Services are intended to be used by Organizations (including their Authorized Users) and their Employees participating or interested in participating in an Employee Wellness Plan or otherwise obtaining our Services.

• We collect or are provided with several types of information from and about users of our Website, Application, and Services, namely:
• Your Personally Identifiable Information and other information that you provide directly to us or our Service Providers via the Application or the Website, or that we receive from your Empower360 health care providers, or in connection with any Services or otherwise so that we or our Service Providers can (i) create and/or verify your Account and provide you access to the Account Services or other Services (as applicable); (ii) contact you to respond to your inquiries about the Website, the Application, and/or contact you regarding any related Services offered by PeopleOne and/or third parties including but not limited to, pricing, special promotions and discounts; (iii) communicate with you in connection with feedback or other messages you submit to us; (iv) interact with you and otherwise provide you with the Account Services or other Services (including, for example, health and wellness information tracking (such as number of steps per day, calorie intake, weight loss and the like), health and wellness coaching services, health service scheduling (such as biometric screening), company wellness and incentive program progress, and the ability to view, analyze, and interact with certain User-Provided Data and run Reports); (v) otherwise use such information for the reason why you or such Empower360 health care providers provided it; and (vi) provide your Organization with reports to determine if incentives have been earned.
• Website and/or Application usage details, IP addresses, mobile device information, location information, traffic information , and other information collected through cookies, web beacons, and other tracking technologies automatically as you navigate through the Website and/or the Application (See Tracking Technologies below) so that we can enhance your user experience;
• Information about your device used to access the Website or the Application, including the device’s unique identifier, IP address, operating system, browser type, mobile network information, and the mobile device’s telephone number so that we can enhance your user experience; and
• If you are an Employee, your Organization or insurer may provide us with your Employee Onboarding Information at or around the time your Organization enters into a Service Agreement with us or at or around the time of your employment with the Organization (whichever is later), which comprises your name, address, gender, date of birth, certain health information from your Organization’s insurer,  your employee ID number, and your social security number, and your insurer or Organization may provide us with updated health information from time to time so that we can set up your Account, personalize the Services, your Account and your experience using the Website and the Application or our Services, including, without limitation, any health and wellness coaching services.

Use and Sharing of Information

Except as provided in this Privacy Policy, or as otherwise permitted or required under law, we reasonably attempt to ensure that we do not intentionally disclose any Personally Identifiable Information we receive about you to any third party without having first received your permission (through your opting in or otherwise agreeing to the disclosure of such information).

Notwithstanding the foregoing, we will release information, which may include Personally Identifiable Information, as required by law to comply with any valid legal inquiry or process such as a search warrant, subpoena, statute or court order. We will also release specific information, which may include Personally Identifiable Information, in special cases, such as if there is an attempted breach of the security of the Website or the Application or a physical or property threat to you or others. We may also transfer user information, including Personally Identifiable Information, in connection with a corporate merger, consolidation, a sale of stock or assets, corporate division, or other fundamental corporate change.

We may also provide access to your Personally Identifiable Information and other User-Provided Data you submit to us to our Service Providers to assist us in providing the Website, the Application and/or any Services.  Similarly, these Service Providers may collect and provide us your Personally Identifiable Information and other User-Provided Data that they collect from you in assisting us in providing the Website, the Application and/or any Services.  Our Service Providers have access to your Personally Identifiable Information as needed to perform their functions but may  not use or disclose it for other purposes.

Additionally, we may use your Personally Identifiable Information to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes and/or if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PeopleOne and its affiliates or others.

On occasion, we may collect Personally Identifiable Information from you in connection with optional special offers or promotions. We will share such information with necessary third parties for the purpose of carrying out the special offer or promotion, or to inform you of additional special offers or promotions.  Your participation in the special offer or promotion constitutes your consent to such disclosure and use of such Personally Identifiable Information.

We also reserve the right to use your Personally Identifiable Information to send you communications regarding changes to this Privacy Policy or the Terms of Use.

We may, in our discretion, provide designated representatives of your Organization with Anonymized Data and other aggregate and de-identified data about usage of the Website, the Application, the Services or any Functionality (including usage, progress, and related information), as well as Non-Anonymized Data and other identifiable information such as name, birthdate, and social security number for the purpose of census management and any other reason or purpose explained in this Privacy Policy or our Terms of Use.  In addition, so that your Organization can fulfill any rewards or incentive obligations, and/or for reasons related to your wellness program, we may also provide the designated representatives: (i) your name and related incentive information (e.g., the number of SparkPoints or tokens that you have earned); and/or (ii) your name and status of completion of certain activities or tasks (for example, that you participated in biometric screening, that you met with a health coach or visited a primary care physician); and/or (iii) your name and that you met or did not meet certain health outcomes (only sharing yes/no against meeting outcomes, vs specific health outcome numbers/values).”We will NOT otherwise provide any of the Personally Identifiable Information we or our Service Providers collect from you or your Empower 360 health care providers to your Organization, except for the limited purposes set forth elsewhere in this Privacy Policy or in our Terms of Use (including, without limitation in the second paragraph of this section).

Your Personally Identifiable Information (including your name and health information) will be shared with your PeopleOne Coach so they can personalize their recommendations to help you better meet your goals. You can visit your “My Profile” section of the Website or Application to stop sharing with your coach.

If you are an Employee, we may provide your Personally Identifiable Information (including your name and health information) as instructed or expressly consented by you to a doctor’s office, hospital, insurer, or other healthcare provider of your choosing.   

Except as set forth in this section, without your express permission, we will not sell, lease, rent, or license your Personally Identifiable Information to third parties (including, without limitation, for direct marketing purposes).

Security of Information

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of Personally Identifiable Information, User-Provided Data, and other information collected pursuant to this Privacy Policy, we have put in place reasonable physical, technical, and administrative safeguards to secure such information, and we make good faith efforts to store such information in a secure operating environment.

You must also seek to protect against unauthorized access any Personally Identifiable Information that you use or transmit in connection with the Website and/or the Application or otherwise in connection with the Services.  You must keep your Log-In Information confidential and you must not disclose it to any other person or entity. PeopleOne will not be responsible to you or any third-party if you do not properly secure your Log-In Information or if you choose to share your Log-In Information with anyone else.  Please see the Terms of Use for additional provisions concerning Accounts and obligations concerning same.

In the event that we determine that there has been a security breach resulting in the unauthorized disclosure of Personally Identifiable Information to a third party, we will notify individuals whose Personally Identifiable Information has been so disclosed as required by law.

Unfortunately, no data transmission over the Internet can be guaranteed to be absolutely secure. As a result, while we strive to protect Personally Identifiable Information you submit to us, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.

Tracking Technologies

As you navigate through and interact with the Website and/or the Application, we may use automatic data collection technologies to collect certain information about your equipment or device, browsing actions, and patterns, including (i) details of your visits to our Website and/or the Application, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website and/or the Application, and (ii) information about your computer, your device and/or your internet connection, including your IP address, operating system, browser type, the device’s unique identifier and phone number, and mobile network information.

The information we collect helps us to improve our Website, the Application, and/or our Services and to deliver a better and more personalized service, including by enabling us to: (i) estimate our audience size and usage patterns, (ii) store information about your preferences, allowing us to customize our Website and Application according to your individual interests; and (iii) recognize you when you return to our Website and/or the Application.

The Website and/or the Application may use “cookies” and/or other technologies or files (collectively, “cookies”) to identify how visitors make use of the Website and/or the Application.  Through the use of cookies, we may automatically collect information when you visit the Website and/or the Application, namely, the time and date of your visit, the pages that you access, and the number of times you return to the Website and/or the Application. This information is used to help us improve and enhance our Services and/or the Website and/or the Application experience for all of our visitors. If you would prefer not to have such cookies stored on your computer or device, you may be able to modify your browser settings or your device settings to reject the cookies. However, by so rejecting the cookies, you may be unable to fully access the offerings on the Website and/or the Application.

We may also collect information through the use of clear gifs (also called web beacons and web bugs) in selected e-mail messages we send to you. These are tiny graphic files, not visible to the human eye, that are included in HTML-based e-mails and used to let us know which e-mails we send are opened. Clear gifs may also see or read cookies on your computer. When authorized by us, third parties specializing in monitoring aggregate statistical use of the Website and/or the Application with whom we contract, may use cookies, our web log files, web beacons, and other monitoring technologies to compile anonymous aggregate data.

Additionally, we may use IP address information to count and track aggregate visits to the Website and/or the Application, to help diagnose problems with our server, and to administer the Website and/or the Application. We do not link IP addresses to anything personally identifiable, so while a particular user’s session can be tracked, the user remains completely anonymous.

DO NOT TRACK Signals

Please note that PeopleOne does not currently respond to DO NOT TRACK requests sent from a user’s web browser, such as Internet Explorer, Chrome, and Safari.

Electronic Communications and Opting In and Opting Out

When you communicate with us electronically, via e-mail or otherwise, you consent to our use of the information you have provided, and you further consent to receive e-mail communication from us including, e-mail the primary purpose of which is sending articles and other content to help you with your program. A secondary purpose may be the commercial advertisement or promotion of a commercial product or service (a “commercial communication”).  If you would prefer not to receive commercial communications, you can opt out of/unsubscribe to our e-mail lists by clicking on the “opt out”/”unsubscribe” line at the bottom of the commercial communication that you receive from us.  You should be aware, however, that (i) it is not always possible to completely remove or modify information in our databases and servers, although we will always make reasonable efforts to do so upon your request, and (ii) we are unable to have your information removed from the records of any third party who has been provided with your information in accordance with this Privacy Policy.

Other Website and/or the Application and Links

The Website and/or the Application may include links to pages on third party websites, such as PeopleOne’s social media pages, that we think will be of interest to you and are not operated by PeopleOne.  These third party websites have separate data collection and privacy practices independent from ours, and PeopleOne is not responsible for the policies or activities of such other websites.  Please contact such third parties directly if you have questions about their privacy policies.

Reviewing, Correcting or Requesting that We Discontinue use of Your Personal Data

If you would like to review the current details of your Personally Identifiable Information or if you would like us to either change, or discontinue use of, your Personally Identifiable Information, please contact us at su*****@pe*************.com .

Changes to the Privacy Policy

We encourage you to review our Privacy Policy not just the first time you visit the Website and/or the Application but periodically afterwards since we may modify our Privacy Policy from time to time. The date of the last update of the Privacy Policy will always be posted at the top of this Privacy Policy and here: February 19, 2021.

If we make any substantive changes to our Privacy Policy in the future, we will incorporate those changes here and will summarize the changes below:

Your continued use of the Website and/or the Application after the changes are posted constitutes your agreement to the changes, both with regard to information we have previously collected from you and with regard to information we collect from you in the future. If you do not agree to the changes, please discontinue use of the Website, the Services, and/or the Application. 

Lastly, if PeopleOne is sold or merged with another company, your Personal Data and any other Personal Data submitted by you may be included as part of the sale. In this case, your Personal Data and the Personal Data submitted by you will be maintained in the same manner as described in the Privacy Policy unless you’re notified that the Privacy Policy has been changed.

Data Destruction

In the event we are advised that you are no longer an Employee of an Organization, or in the event your Organization’s Service Agreement is terminated for any reason or we terminate the Terms of Use as against you for any reason, we shall have no obligation (except to the extent required per applicable law) to continue to maintain your Personally Identifiable Information (or any other User-Provided Data) and we shall take all reasonable steps to dispose, or arrange for the disposal of, all of your Personally Identifiable Information promptly after the time in which your Personally Identifiable Information is no longer needed for a legitimate business purpose as set forth in our Terms of Use or this Privacy Policy.  You acknowledge and agree that, to the fullest extent permitted per applicable Laws, we shall in no event be liable to you for destroying, erasing, or otherwise deleting any of your Personally Identifiable Information or User-Provided Data in our (or our Service Providers’) possession, custody, or control.

PeopleOne’s Contact Information

If you have any questions or comments about this Privacy Policy, the Website, the Application, or your dealings with PeopleOne we encourage you to contact PeopleOne at su*****@pe*************.com .