Online and Mobile Communication Privacy Notice
Effective date: 5/7/18
First Choice and First Choice VIP Care Plus (“First Choice”) are committed to maintaining the privacy and security of the personal information of its plan members (“Members”), mobile application and/or portal users (“Users”) and website visitors (“Visitors”).
In this Privacy Notice, we refer to Members, Users, and Visitors together as "Participants.” We appreciate that medical information is particularly sensitive.
This Online and Mobile Communication Privacy Notice details the information gathering and dissemination practices of First Choice with respect to its:
(i) corporate website (www.amerihealthcaritas.com) and the websites of its affiliated health plans and companies as listed on the AmeriHealth Caritas Family of Companies’ page on its corporate website,
(ii) the First Choice member portals (the “First Choice Member Portals”),
(iii) First Choice’s mobile applications for its affiliated health plans and companies (“First Choice Apps or First Choice Applications”) and
(iv) any of First Choice’s text messaging features offered to Users, collectively the “First Choice Online and Mobile Communication Services.”
For a summary of First Choice’s privacy obligations as a health plan under the Health Insurance Portability and Accountability Act (“HIPAA”), please see our HIPAA Notice of Privacy Practices for the particular health plan or company found on the applicable First Choice Website, First Choice Member Portal, or First Choice Application.
1. Acceptance of Privacy Notice
By using First Choice Online and Mobile Communication Services, you agree to accept the terms and conditions set forth in this Privacy Notice. If you do not agree to the terms and conditions of this Privacy Notice, please do not use the First Choice Online and Mobile Communication Services. Your continued use of First Choice Online and Mobile Communication Services following the posting of any changes or updates to these terms and conditions will mean that you accept those changes.
2. Collection of Personal Information from the First Choice Online and Mobile Communication Services
Through the First Choice Online and Mobile Communication Services, First Choice and/or its third party business partners may collect and/or track:
(1) the home server domain names, e-mail addresses, type of computer or mobile device used, IP address, files downloaded, search engine used, operating system employed, mobile device telephone number, and type of web browser of online or mobile Participants;
(2) the e-mail addresses of a Participant who communicates with First Choice via e-mail;
(3) information knowingly provided by a Participant in online forms, registration forms, surveys, e-mail, text messages, contest entries, and other online or mobile avenues (including demographic and personal profile information); and
(4) aggregate and user-specific information on which web pages or application features the Participant accesses.
To better serve Participants to the First Choice Websites and the Member Portals, First Choice may use "cookies" to enhance a visitor's browsing experience. Cookies are simple text files stored by a user's browser that provide a way to distinguish among Participants. The cookies placed on a Participant's computer by using an First Choice Website or a Member Portal do not contain personally identifiable information. A Participant can refuse a cookie or delete the cookies file from his or her computer at any time by using any one of a number of widely available methods.
When a Participant performs a search within an First Choice Online and Mobile Communication Service, First Choice may record information identifying the Participant or linking the Participant to the search performed. First Choice may also record limited information for every search request and may then use that information to solve any technical problems with the applicable First Choice Online and Mobile Communication Service and to calculate overall usage statistics.
First Choice may collect certain information about Participants that is either in aggregate form or not personally identifiable, such as aggregate information about First Choice Online and Mobile Communication Services usage, and First Choice may share such de-identified information with third parties.
3. Collection of Other Personal Information from the First Choice Apps and/or Member Portals
Through the First Choice Apps or First Choice Member Portals, First Choice may collect personal information provided by a Member, such as medication information supplied through the “Medicine Cabinet” feature, personal information contained in questions submitted through the “Contact Us” feature, health information or medical history information supplied via text message or demographic information supplied when you change your “Profile and Settings."
4. Use of Personal Information Collected
Personal information collected by First Choice may be used by First Choice for many purposes, including: editorial and feedback; statistical analysis of Participants' usage; product development; content improvement; and/or customization of the content and layout of the First Choice Online and Mobile Communication Services.
Aggregate information on Participants' home servers may be used for internal purposes or provided to third parties. Individually identifiable information, such as names, postal and e-mail addresses, phone numbers, and other personal information that Participants voluntarily provide to First Choice, may be added to First Choice databases and/or used for future calls and mailings regarding First Choice Online and Mobile Communication Services updates, new products and services, upcoming events, and for other purposes in accordance with state and federal law.
5. Disclosure of Personal Information to Third Parties
- Members / Users. For Members and/or Users using the First Choice Online and Mobile Communication Services, First Choice will only use and disclose personal information as permitted by applicable laws, and as described in our HIPAA Notice of Privacy Practices for the particular health plan or company found on the applicable First Choice Website, First Choice Member Portal, or First Choice Application.
- Visitors. For Visitors to an First Choice Website who have not identified themselves as Members, First Choice will not sell, rent, license, or trade your personal information with third parties for their own direct marketing use unless we receive your express consent to do so. Unless you give us permission to do so, First Choice will not share the personal information of Visitors other than as specified in this Privacy Notice. First Choice may share your personal information under confidentiality agreements with other companies that work with, or on behalf of, First Choice to provide products and services, such as a vendor that helps us collect information on how you use the First Choice Websites. These companies may use your personal information to assist First Choice in its operations. However, these companies do not have any independent right to share this information. We may provide information about Visitors to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
6. Link Disclaimer
First Choice may occasionally provide links to other entities' websites for convenience to the Participants in locating health-related information, services, and products. When you link to other websites, please remember that you are leaving First Choice website, and these other websites are maintained by organizations that First Choice does not control.
7. Security Measures
First Choice has implemented numerous security features to prevent the unauthorized release of, or access to, personal information, including the measures it has adopted in running its health plans and other lines of business pursuant to HIPAA security requirements. For example, all First Choice employees are required to certify their understanding that personal information is considered confidential, that it is important to safeguard personal information, and that First Choice will take appropriate action against any employee who fails to adhere to our privacy standards.
Please be advised, however, that the confidentiality of any communication or material transmitted to or from First Choice through an First Choice Online and Mobile Communication Service, e-mail or text cannot be guaranteed. Accordingly, First Choice is not responsible for the security of information transmitted through the Internet. For more private communications, including communications pertaining to medical or health information, Participants who have health coverage through or administered by First Choice can contact First Choice at the phone number listed on their member identification card.
8. Opt-Out Right
Visitors who are not Members may opt out of having their personal information retained by First Choice by contacting First Choice through regular mail, telephone, or via secure e-mail as provided in Section 14 below. This opt-out right does not apply to collection or public traffic information such as the type of web browser that you use to access an First Choice Website, your geolocation, or your operating system.
9. Access to and Ability to Correct Personal Information
Upon request by regular mail or phone, First Choice will provide to any Visitor a summary of any personal information retained by First Choice regarding the Visitor. Visitors may modify, correct, change or update personal information First Choice has collected through an First Choice Online and Mobile Communication Service by contacting First Choice by regular mail, telephone, or via secure e-mail as provided in Section 14 below.
The rights of Members to access and correct their personal information maintained by First Choice is governed by our HIPAA Notice of Privacy Practices for the particular health plan or company found on the applicable First Choice Website, First Choice Portal or First Choice Application.
10. Collection of Personal Information from Children
First Choice understands the importance of protecting children's privacy in the interactive online world. The First Choice Online and Mobile Communication Services, including the First Choice Websites, First Choice Member Portals and the First Choice Apps, are not designed for, or intentionally targeted at, children under 13 years of age.
It is not our policy to intentionally collect information about anyone under the age of 13. No one under the age of 13 should submit any personal information to First Choice through an First Choice Website, an First Choice Member Portal and/or an First Choice App.
11. Response to “Do Not Track” Signals
Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, the First Choice Online and Mobile Communication Services does not process or respond to “Do Not Track” signals.
12. Your Role in Protecting Your Privacy
13. Privacy Notice Changes
This First Choice Online and Mobile Privacy Notice may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on the notice at the top of this Privacy Notice so that it will be easier for you to know when there has been a change.
If we make any change to this Privacy Notice regarding use or disclosure of personal information, we will provide appropriate advance notice through the First Choice Online and Mobile Communication Services. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.
If you have any questions or concerns about this Privacy Notice or about First Choice’s handling of your personal information, please contact us by mail at P.O. Box 40849, Charleston, SC 29423, Attn: Privacy Office, by telephone at 1-888-276-2020 or via e-mail through our secure e-mail submission form.