PRIVACY NOTICE

How Information May Be Shared

Any information that may be shared about you is subject to the minimum data needed rule (and other HIPAA regulations) related to the Services provided, as noted below:

• Social Recognitions – Some Services allow for recognizing: personal and/or team standing among all participants of an activity or program; achievements; winners of competitions; recipients of awards and/or rewards. The information shared varies with the Sponsor of Services access, applicable recognition and information that is needed for the recognition, for example: name, points earned, steps/exercise time, volunteer time, awards or rewards received.
• Third-Party Wellness Providers – If you are eligible for access and/or participate in a service, program or activity from a third-party Wellness provider (“Third-Party Wellness Provider”) that is available to you through HPN Services, we may disclose the personal data needed such as your name, contact and other relevant information, with the Third-Party Wellness Providers to enable you to access, sign-up for and/or permit them to contact you to offer the related service(s) in support of your health and wellness goals and to provide those services. Third-Party Wellness Providers have their own terms and privacy policies which are separate from those of HPN and HPN Services.
• Sponsors – At the request of an employer, health plan or other Sponsor of your access to Services and related services through Third-Party Wellness Providers, HPN may disclose relevant personal data for the purpose of administering your benefits and/or health plan operations – e.g., providing services, support, payment, incentives and other functions.
• Operations – HPN only shares personal data with its third-party service providers that perform operational services on behalf of HPN Services (e.g., web hosting, payment services, data storage, analysis). Any third party with which we share personal data must agree to safeguard it in substantially the same manner as described herein and in accordance with all applicable laws.
• Aggregate Data – HPN may aggregate information collected though the Services and remove identifiers so that the information neither identifies nor can be used to identify an individual who uses the Services (“Aggregated Data”). Because it cannot be used to identify any specific individual, Aggregated Data is not considered “personal data.” Aggregate data may be shared in reports, articles and other ways for customers, communications other operational purposes.
• Your Requests – You may use options available through Services that allow you to share your health information with your doctor or others contingent on your consent for us to make the disclosure.
• Other Legal Disclosures – subject to applicable Federal and state laws:
  1. We may disclose personal information to Emergency Medical Personnel in the event of a medical emergency, or to a coroner, medical examiner or funeral director.
  2. We may disclose personal information to the appropriate public health and/or other legal authorities, as required by law and to the extent necessary to avert serious and imminent threat to your health or safety or the health or safety of others.
  3. We may share personal information with the Department of Health and Human Services to verify compliance with federal privacy law.
  4. We may share health information about you in response to a court or administrative order, or in response to a subpoena.
• Consent – By use of HPN Services described in this Privacy Notice, you consent that HPN may disclose your personal information in the ways listed above.

Please note that each Sponsor and third-party source of support on Services has its own terms of use and privacy policy. If you provide personal data to any of those entities, or consent to our sharing personal data with them, that data is governed by their privacy statements.