The HRA VEBA Plan (such plan and the plan provider or its governing board or body, and any trust or other entity through which the plan is funded, and all service providers to the Plan, being referred to herein collectively as the “Plan,” “your HRA Plan,” “we,” or “our”) takes your privacy seriously. Because we value our relationships with participating employers and participants, we do not sell your information. We will only share your information in compliance with the law and for the purposes of providing services that you have engaged us to perform on your behalf, such as providing you with enrollment, eligibility, contribution, and claims reimbursement services, as applicable, and as otherwise permitted or required by law.

To help you understand how we protect your privacy, this Privacy Policy outlines our information-sharing practices, including when we collect and use information about you, and the measures we take to protect the confidentiality of that information.

Your Confidential Information

Your Confidential Information includes, but is not limited to:

• Protected Health Information is defined as individually identifiable health information that is held or transmitted by the Plan in performance of its legal and contractual obligations with participating employers and plan participants. This type of information includes information in electronic, paper and oral form.

• Nonpublic Personal Financial Information is defined as including confidential information of a financial nature that is shared by a current or prior participant or participating employer with us in the course of our providing benefits or services relating to the administration of the Plan. This type of information is not otherwise available to the public and includes, but is not limited to, the following: account balances, direct deposit information, claims and reimbursement history, participant and employer account information, participant benefit coverage information, employer plan design information, and any other data of a participating employer or participant that is financial in nature.

You do not have to provide us any Confidential Information in order to visit our Website (as defined in the Website’s Terms of Use Agreement). We may request Confidential Information from you at our site in order to deliver requested materials to you and deliver benefits-related or plan-related services. We do not sell your Confidential Information to others under any circumstances.

We collect only that amount of Confidential Information which you choose to provide to us. By using our Website, you agree to the uses of your Confidential Information described in this notice and in the Website’s Terms of Use Agreement. If at any time this policy changes, those changes will be posted on this page of our Website, so that you are aware of our intent to better protect your privacy.

Confidentiality Practices

Generally, we support the concept of non-disclosure of your Confidential Information. We also hold our Business Associates and our affiliates to similar confidentiality standards. Your Confidential Information must be used and disclosed in a manner consistent with applicable laws and regulations, contractual obligations, and the policies and procedures of the Plan.

Protected Health Information and Nonpublic Personal Financial Information may be used and disclosed solely for the Plan’s and our service providers’ business activities and health care operations related to the administration of the Plan.

Information We Collect

We know how important your privacy is to you and we appreciate you trusting us to handle your Confidential Information responsibly and with integrity. The information we collect is limited to the data elements on the prescribed paper forms you use or entries you may make through our Website portals. In the course of conducting our business, we may share information you provide to us strictly on an as-needed basis or as otherwise required by law. In certain situations, and in no event contrary to applicable public policy, we may share information about you to: (1) our Plan service providers who are Business Associates to the Plan in order to provide a Plan benefit or service to you; (2) a third party if reasonably necessary to enable them to perform services for us or you, such as claims appeals or the detection of fraud or material representations; (3) governmental authorities only to the extent that we are required to disclose any such Confidential Information pursuant to the legal process we receive from such governmental authority; or (4) as otherwise disclosed to you in the Plan’s Privacy Notice contained in your Plan Summary and also on our Website.

Online Tracking

Click Streams

We may capture click streams to help us learn what parts of our Website are most popular and among which audiences. We may also use them to help us optimize our user interface, to analyze site usage statistically, to improve content, and to customize our Website's content and layout. In short, we use this information to allow us to tailor our Website and to meet your needs better. We analyze click stream data to track trends and behaviors, not individuals. We are interested in our audience size, return visit rate, and similar data on an aggregate basis. We also capture date and time information of visits, pages visited, and the time you spend with us.

Cookies

Cookies are pieces of information that a website transfers to your computer's hard drive for record-keeping purposes. They can make the site more useful by storing information about your preferences at our Website. It is almost standard for any interactive website to use cookies. Cookies do not identify a user, but they do identify a user's computer. Most browsers are set up to accept cookies. If you prefer, you can set your browser to refuse cookies, but some online services on our Website will not function without them.

We do not use cookies to track or report on activity when you are not on our Website or to provide such information to other parties for their own marketing use. We do not use cookies to collect personal information such as your e-mail address, and we do not combine information collected through cookies with your Confidential Information. We make no attempt to look at or examine other cookies or information that may be stored on your computer.

Information We Share

We do not use, disclose, sell or transfer any Confidential Information without consent unless required or permitted by law or regulation. In cases of permitted disclosure, we will disclose information in compliance with applicable laws and regulations, and we will require the recipient to protect the information and use it only for the purpose provided.

Information Security

We restrict access to your Confidential Information to our service providers who need to know such information in order to provide you with the Plan benefits and Plan-related services. We maintain physical, electronic, and procedural safeguards that comply with U.S. federal and state regulations to guard your Confidential Information.

The Plan takes caution in emailing you Confidential Information by encrypting such emails. By contrast, be aware that e-mail messages sent in clear text over the public internet can be observed by an unintended third party. Non-encrypted internet e-mail communications may be accessed and viewed by other internet users without your knowledge and permission while in transit to us. In an effort to better protect your information, please do not use unsecured electronic mail to communicate information to us or request information from us that you consider to be Confidential and/or proprietary. If you wish, you may use our secure website portals or you may contact us via telephone at the phone number provided elsewhere in this Website.

Correcting or Removing Your Personal Information

If you would like to correct the Confidential Information you have provided to us, or to request that we remove your information from our records, please contact the customer care center at 1-888-659-8828 with the correction or removal request.

Children’s Online Privacy Protection Act (COPPA)

We do not knowingly collect online information from children under the age of 13. Our services are intended for adults who are participants or acting on behalf of participating employers and service providers under the Plan. If we are notified that we have collected personal information in violation of the Children’s Online Privacy Protection Act (COPPA), the Plan will take immediate measures to mitigate such violation in accordance with the law.

Links to Other Sites

We may provide links to other websites not owned or controlled by us that we think might be useful or of interest to you. We are not, however, responsible for the privacy practices used by other website owners or the content or accuracy contained on those other Websites. Links to other websites do not constitute or imply endorsement by us of those websites, any products or services described on those websites or any other material contained in them. Please contact those websites directly for their individual privacy policies.

Changes to Our Privacy Policy

We reserve the right to make changes to our Privacy Policy at any time. Such changes will be posted on this page. We encourage you to review the Website and the Privacy Policy periodically for any updates or changes. Your continued access or use of this Website shall be deemed your acceptance of all terms and conditions contained in this Privacy Policy and the Terms of Use Agreement also located on this Website.

Last modified on February 22, 2016