February 24, 2020
Flipt provides pharmacy benefit manager services in a unique and proprietary manner, and Flipt may grant you access to use the Services once you register as an account user (“User”). A “User” is a person who registers a User account (“Account”) through a portal available through the Sites, which also enables Users to access their Account to use the Services. Users may also access the Services on behalf of their covered dependents (“Covered Dependents”).
Our Commitment to Privacy
What is Personal Information?
“Personal Information” includes any information which can be used to identify a person including name, date of birth, mailing address, social media profiles and other third party platform account identifiers, home phone number, mobile phone number, e-mail address, credit card information, and Social Security number.
How Your Personal is Collected?
We collect certain Personal Information when you sign up for your Account, such as your name, address, e-mail address, phone number or mobile phone number, billing information, and other information that we deem relevant and important in order to provide the Services to you.
When you access the Sites via a mobile device, we may receive information about your location (based on your IP address) and your mobile device, including various unique identifiers associated with your device, hardware type, and the version of your operating system. We may use this information to provide you the Services and related content based on your location.
You may provide us with Personal Information on the checkout page of the Sites when ordering and paying for products or receiving rewards from your employer, where applicable. We use your Personal Information, as applicable to process your prescription drug information and claims in accordance your health plan’s contract with us and the prescription benefits provided under your health plan, and to transfer funds as you may direct us from time-to-time. We may request additional Personal Information as needed from time-to-time to provide the Services to you or to provide additional Services that you may elect.
Communicating With Us
In order to provide you with the Services, we may communicate with you through email or through text messaging to your mobile device. You acknowledge that electronic communications are not completely secure and that there may be some risks that your personal or prescription-related information may be seen or obtained by a third party.
You may review and adjust your communication preferences by logging into your Account. We may adjust the categories of communication preferences available to you through the Sites from time to time. These adjustments may, in certain instances, affect which communications you receive and the communication channels by which you receive them. Please note that if you opt-out of certain methods of communication, we may not be able to fully provide the Services or to provide certain Services at all.
How Your Personal Information is Used and Disclosed
In addition to using your personal information to provide the Services, we may use your Personal Information, in compliance with applicable law:
- to enhance or improve User experiences or our Services;
- to send emails about our Services or to respond to inquiries;
- to send emails, texts, and updates about Flipt and the Services and your related health plan or prescription information;
- to perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our Services;
- to enforce our rights and resolve disputes;
- for business purposes in a de-identified and aggregated form; and
Covered Dependent Personal Information
The Services may include features through which a User (the “Primary Account Holder”) may be permitted to view the Personal Information or manage the benefits on behalf of Covered Dependents, including minors. Adult dependents may similarly become registered Users with the ability to access their own Personal Information. An adult Covered Dependent may grant or restrict access to the Primary Account Holder to view the granting person’s Personal Information. The Primary Account Holder has permission to view the Personal Information of minor Covered Dependents until such Covered Dependents reach the age of majority or otherwise qualify as emancipated minors under applicable law and provide Flipt with evidence of such emancipated status.
The availability of the Personal Information of the Primary Account Holder and other Covered Dependents may depend on the Primary Account Holder’s or Covered Dependents’ preferences, plan/program preferences, available website functionality, and applicable law.
Third Party Access to Your Information
Release of Your Information for Legal Purposes
At times, we may be legally compelled to release your information in response to a request from a government agency or in connection with a lawsuit or other legal action.
Other Disclosures of Your Personal Information
Health-Related Personal Information
To the extent you submit Personal Information that constitutes Protected Health Information (“PHI”), use and disclosure of such PHI may be governed by the Health Insurance Portability and Accountability Act (“HIPAA”) and your health plan’s Notice of Privacy Practices, which you may obtain from your health Plan. In order for Flipt to provide the full Services to you, you may be asked to sign a HIPAA Authorization Form which may be presented to you upon Account registration or thereafter.
If you have any questions about which policies apply to information you submit to us, please contact us at firstname.lastname@example.org.
How We Collect Your Non-Personal Information
IP Addresses and Log File Data
Whenever you use the Services, we may collect non-personal information from you, such as your IP address, referring URL, operating system, cookie information, and Internet Service Provider. You may be able to opt-out of certain third-party associations of such non-identifying information by following third party customization and/or opt-out options.
Cookies, Web Beacons, Browser Local Storage, and Similar Technologies
How We Use Your Non-Personal Information
Aggregate and De-identified Data
We sometimes create and analyze or aggregate de-identified information from information you provide. Aggregated or de-identified data helps us understand trends and User needs so that we can better consider new products and services, and optimize existing products and services. Aggregate data is summary level data, which does not contain Personal Information. De-identified data is generally data that does not identify an individual and with respect to which there is no reasonable basis to believe that the information can be used to identify an individual.
How We May Disclose Your Non-Personal Information
We may disclose non-personal information to our affiliated companies, third parties who provide services to us, other parties that you have authorized, and for any lawful or legitimate business purposes.
Other Policies Pertaining to Privacy
Communications with You
Our communications to you may include messages sent through the use of landline phone, cellular phone, and text messages (including SMS and MMS). We may use an automatic telephone dialing system (or “auto-dialer”), which may employ artificial or pre-recorded voice or “robotexts.” By submitting your Personal Information, including your phone number, email address, or other contact information, you are providing your express written consent to receive communications from us at the email address and telephone numbers you provide to us, including via text messages for which you may incur charges from your cell phone or wireless provider. You also represent and warrant that you are at least 18; you have not registered on a national or statewide Do Not Call list; you are the account holder for the email addresses and phone numbers you provide, or you have authorization from the account holder to give this consent; and the email addresses and phone numbers you provided are accurate, and you will let us know if you release them to another person or individual.
How often we send you text communications will vary based on the Services you request and how we provide such Services. Agreeing to text communications is not a condition of purchasing any property, goods or services from us. However, without the ability to communicate with you via text message, we will not be able to provide some of the Services to you. You may opt-out of receiving such text communications by removing your phone number from your Account or by contacting Flipt by email at email@example.com, but opting-out may impair our ability to provide, and your ability to use, the Services.
Flipt has put into place security measures in an effort to protect Personal Information from loss, misuse or alteration while it is under our control. We use technical, contractual, administrative and physical measures in an effort to protect against unauthorized access to your Account and Personal Information. Only select Flipt staff have access to the Personal Information you provide. However, we make no representations as to the security or privacy of your Personal Information outside of the specific industry-standard mechanisms we have undertaken in good faith. Additionally, we have absolutely no control over the security of other third party sites you might visit, interact with, or do business with.
Breach of Personal Information
Depending on where you live or the type of information that is compromised, you may have a legal right to receive notice of a security breach in writing. To the extent required by applicable law, Flipt may report the breach of information to governmental authorities or other third parties.
If you believe there has been any breach of security of our sites, please email us at firstname.lastname@example.org
Your California Online Privacy Rights
Flipt is concerned about the safety and privacy of children online. Because of this, we will make all efforts to comply with the Children’s Online Privacy Protection Act of 1998 (COPPA). We do not and will not knowingly contact or collect Personal Information from children under 13. Further, our Services are neither intended for nor designed to attract Users under the age of 18. Notwithstanding the foregoing, depending upon the functionality available in the Services, you, a partner, guardian, or similar legally authorized person (“Authorized Person”) may register a minor under their supervision for access to our Services. Upon turning 18, we will cease providing access to Services to the Authorized Person related to a minor that reaches the age of majority.
Retention of Information