netWell’s Privacy Policy
Uses and Disclosures of Your Information
netWell services are intended for use solely by and on behalf of individuals located in the United States.
Effective Date: April 1, 2021
We Care About Your Privacy
The privacy of your information is very important to the netWell membership. This Privacy Policy explains the information (as defined below) we collect, how we use and store it, and with whom we share it. This Privacy Policy explains your options and rights and we encourage you to read it carefully and to check back often to review any changes. netWell may update this Privacy Policy occasionally, and we encourage you to check the effective date of this Privacy Policy whenever you use the netWell membership to see if there have been any changes since your last visit. Your continued use of the netWell membership is your agreement to any of those changes.
1. This Privacy Policy applies solely to information collected by this web site. It will notify you of the following:
• What personally identifiable information is collected from you through the website, how it is used and with whom it may be shared.
• What choices are available to you regarding the use of your data.
• The security procedures in place to protect the misuse of your information.
• How you can correct any inaccuracies in the information.
• Information Collection, Use, and Sharing
2. The netWell memberships means this website and any other services provided by netWell, as may be selected by you or automatically delivered to you. “You” and “your” means the person or entity using the netWell membership and providing data in connection with the netWell membership, as an “Account Holder.” “netWell” “we”, “us” and “our” means netWell, its subsidiaries and affiliates.
3. By using any services, the netWell membership offers, you consent to our collection, use, and disclosure of your personal information, including health information (“your information”), as described in this Privacy Policy. Your use of the website is also subject to netWell’s Terms of Use. Any disputes related to this Privacy Policy will be governed by the applicable provisions of the Terms of Use, which are incorporated into this Privacy Policy by reference.
The Information We Collect and Create About You
1. Your Authorization: Except as outlined below, we will not use or disclose your information for any purpose unless you have signed a form authorizing the use or disclosure. You have the right to revoke that authorization in writing unless we have taken any action in reliance on the authorization.
• Information Received Pre-Enrollment: netWell may request and receive from you and your health care providers personal health information prior to your enrollment in netWell. We will use this information to determine whether you are eligible to enroll. We will protect the confidentiality of that information in the same manner as all other personal health information we maintain and, if you do not enroll, we will not use or disclose the information about you we obtained for any other purpose.
• Information Collected about Your Use of Services: netWell also automatically collects information from you related to your use and navigation of the netWell membership including this website. This information may be collected by us or our third-party service providers using website analytics tools or other technologies, like cookies, in order to collect information about your visit to and use of the netWell membership, including the netWell website pages you visit, links you click and other actions you take while using the netWell membership. We may also collect information that your browser automatically sends to the websites you visit, such as your IP address, browser type/language, and other information. All this navigation and usage information (together, “usage information”) helps us to improve your experience in using the netWell membership. Usage information is not considered your information under this Privacy Policy.
• Information Collected from Mobile Apps or Devices: If you choose to use a mobile device to access the netWell membership, when made available by netWell, we may collect information from your device, such as your geolocation data, which will enable some functions in accordance with your device settings (“mobile device information”). Mobile device information that does not identify you is not considered your information for the purposes of this Privacy Policy.
• Aggregated Information: We may also create aggregated, anonymized information that may include or be based on your information, usage information and mobile device information, along with the similar information of other users (“aggregated information”). Aggregated information does not identify you and is not considered your information under this Privacy Policy.
Use and Disclosure of Your Information
1. Disclosures for Treatment: We will make disclosures of your information as necessary for your treatment. For instance, a doctor or health facility involved in your care may request some of your information that we hold in order to make decisions about your care.
2. Uses and Disclosures for Sharing: We will make uses and disclosures of your information as necessary for sharing purposes. For instance, we may use information regarding your medical procedures and treatment to process and arrange for the sharing of eligible medical requests, to determine whether services are medically appropriate or to otherwise pre-authorize services as eligible for sharing under the Member Guide. netWell may also forward such information to another health plan that may also have an obligation to process medical requests on your behalf.
3. Uses and Disclosures for Health Care Operations: We will use and disclose your information as necessary for our health care operations which include peer review, business management, accreditation and licensing, utilization review and management, quality improvement and assurance, enrollment, voluntary disclosure of health conditions, compliance, auditing, and other functions related to your healthcare management. We may also disclose your information to another health care facility, health care professional, or health plan for such things as quality assurance and case management, but only if that facility, professional, or plan also has or had a patient relationship with you.
4. Family and Friends Involved in Your Care: With your approval, we may from time to time disclose your information to designated family, friends, and others who are involved in your care or in funding for your care in order to facilitate that person’s involvement in caring for you or funding for your care. If you are unavailable, incapacitated, or facing an emergency medical situation and we determine that a limited disclosure may be in your best interest, we may share limited personal health information with such individuals without your approval. We may also disclose limited personal health information to a public or private entity that is authorized to assist in disaster relief efforts for that entity to locate a family member or other persons that may be involved in some aspect of caring for you.
5. Business Associates: Certain aspects and components of our services are performed through contracts with outside persons or organizations who assist us with our health care operations, such as legal services, utilization management services, preferred provider organizations, pharmacy benefit managers, etc. (“business associates”). At times it may be necessary for us to provide some of your information to one or more of these business associates. In all cases, we require these business associates to appropriately safeguard the privacy of your information, and such business associates are required to protect the confidentiality of such health information according to those same regulations and may not make use of such information for any other purpose.
6. Communications with You: We may communicate with you regarding your Monthly Commitment Contribution, your Member Commitment Portion, medical requests or other things connected with your health. In the event you could be endangered if all or part of the information being sent to you is viewed by another person, you have the right to request, and we will accommodate reasonable requests by you to receive communications regarding your information from us by alternative means or at alternative locations. For instance, if you wish messages to not be left on voice mail or sent to a particular address, we will accommodate reasonable requests. You may request such confidential communication in writing and may send your request to netWell at the address listed in the For Further Information section at the end of this notice.
7. Other Health-Related Products or Services: We may, from time to time, use your information to determine whether you might be interested in or benefit from treatment alternatives or other health-related programs, products or services which may be available to you as a member. For example, we may use your information to identify whether you have a particular illness and advise you that a disease management program may be available to help you manage your illness better. We will not use your information to communicate with you about products or services that are not health-related without your written permission.
Use and Disclosure of Your Information as Required by Law or Regulation
We may also use and share your information as required by the following circumstances:
1. We may release your information if required by law to a government oversight agency conducting audits, investigations, or civil or criminal proceedings.
2. We may release your information as required by law or for public health activities, such as required reporting of disease, injury, birth or death, and for required public health investigations.
3. We may release your information to law enforcement officials as required by law to report wounds and injuries and crimes or if we believe you to be a victim of abuse, neglect, or domestic violence or if we suspect child abuse or neglect.
4. We may release your information if you are a member of the military as required by armed forces services; we may also release your information if necessary, for national security or intelligence activities.
5. We may release your information to workers’ compensation agencies if necessary, for your workers’ compensation benefit determination.
6. We may release your information to coroners and/or funeral directors consistent with law.
7. We may release your information if necessary, to arrange an organ or tissue donation from you or a transplant for you.
Operational Uses of Your Information
We may also use and share your information under the following circumstances:
1. We use your information in order to provide you with access to and use of the netWell membership. We also use it to service your account and to provide you with general information about netWell and the netWell membership. We use your information to answer your questions, to provide you with information you request, or to provide you with information about your account, registration or use of the netWell membership.
2. We may use or share your information to diagnose technical problems or to detect or prevent security issues.
3. We may use or share your information for our own internal business purposes including statistical, design or operational purposes, such as to measure traffic patterns and understand demographic trends among our users.
4. We may share your information with third parties that perform services on our behalf. We will require them to comply with this Privacy Policy.
5. While we do not currently use your email address to send you any periodic email or newsletter communications on topics generally relevant to our users, we reserve the right to do so in the future. In that event, we will provide you with an opportunity to opt-out and/or unsubscribe to such communications.
6. Any sharing of your information that is not expressly permitted by this Privacy Policy, or future revisions to this policy, may occur only with your consent and applicable law.
7. We may use, share and/or sell information that does not identify you for any purpose, including providing it to third parties for their own business or marketing purposes.
8. We do not sell your information to third parties.
Your Access
1. Access to Your Information: You may request a copy and/or inspect much of the personal health information that we retain on your behalf. All requests for access must be made in writing and signed by you or your representative. We may charge you a fee if you request a copy of the information. We will also charge for postage if you request a mailed copy and will charge for preparing a summary of the requested information if you request such summary. You may obtain an access request form by contacting netWell at the address listed in the For Further Information section at the end of this notice.
2. Amendments to Your Information: You may request in writing that personal health information that we maintain about you be amended or corrected. All amendment requests, in order to be considered by us, must be in writing, signed by you or your representative, and must state the reasons for the amendment/correction request. If an amendment or correction you request is made by us, we may also notify others who work with us and have copies of the uncorrected record if we believe that such notification is necessary. You may obtain an amendment request form by contacting netWell at the address listed in the For Further Information section at the end of this notice.
3. Accounting for Disclosures of Your Information: You may receive an accounting of certain disclosures made by us of your information. Requests must be made in writing and signed by you or your representative. Accounting request forms are available from netWell at the address listed in the For Further Information section at the end of this notice. The first accounting in any 365-day period is free. You will be charged a fee for each subsequent accounting you request within the same 365-day period.
4. Restrictions on Use and Disclosure of Your Information: You may request restrictions on some of our uses and disclosures of your information for treatment, sharing or health care operations by notifying us of your request for a restriction in writing. A restriction request form can be obtained from netWell at the address listed in the For Further Information section at the end of this notice. We will attempt to accommodate reasonable requests when appropriate and we retain the right to terminate an agreed-to restriction if we believe such termination is appropriate. In the event of a termination by us, we will notify you of such termination. You also may terminate, in writing or orally, any agreed restriction by providing such termination notice to netWell at the address listed in the For Further Information section at the end of this notice.
5. Complaints: If you believe your privacy has been violated, you can file a complaint with netWell at the address listed in the For Further Information section at the end of this notice. There will be no retaliation for filing a complaint.
Cookies and Other Technologies
We may use the following technologies to collect usage information:
1. “Cookies” are small text files inserted and stored by your web browser on your computer’s hard drive. They help us determine what parts of the website you visited, and also help us analyze and improve the design and technology of the netWell membership. Your browser may permit you to disable cookies; please refer to your browser settings for further information. However, if you disable cookies, you may not be able to use all the features and functions of netWell membership, and any settings or preferences you previously set that are controlled by the cookies may no longer be available.
2. We use navigational technology, including audit logs, which provides us with information on how you are using the website and other services offered by the netWell membership, like “cookies.” We may use widgets and plugins so that you can use the netWell membership more efficiently. If these interactive mini programs are made available to you on the netWell membership, you understand that they run on the website and collect your IP address, which page you are visiting on the website, and set a cookie to enable the widget to function properly. Your interactions with these widgets are governed by the Privacy Policy of the company providing them, and not by this Privacy Policy.
3. This description of technologies used is not comprehensive, as we will continually update our systems to provide you with the best possible online experience.
Rights Under State Law
1. You may have additional rights under the law of the state where you reside, including if you are a California resident. In addition to all your rights under other parts of this Privacy Policy, your state law may provide you with the right to:
• Request that we provide you with information about whether and to whom we have disclosed your information.
• Request to have a copy of the specific information collected about you during the twelve months before your request.
• Have your information deleted (with some exceptions).
• Request that your information not be sold to third parties.
• Not be discriminated against because you have exercised any of these rights.
Security
1. Member Enrollment Request: An enrollee must first complete the Member Enrollment Request. During the enrollment process a Member Enrollment Request is required to give certain information (such as name, email address, demographic information, medical information, etc.). This information is used to review your enrollment, allowing netWell the opportunity to ensure you and all enrollees meet the enrollment criteria per the Member Guide on our website.
2. Sharing of Information: We share aggregated demographic information with our subcontractors, where we have partnered with a third party to provide specific services. We will share names, or other contact information that is necessary for the third party to provide these services. These parties are not allowed to use personally identifiable information except for the purpose of providing these services. Please know this information sharing policy applies only to data which you provide during your general use of this website, and as a member of the Health Care Sharing Ministry. Personally, your information is treated as confidential in strict conformity with all regulations and shared only as necessary with third-party vendors providing essential services to the netWell membership and its members.
3. Links: This website may contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our members to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information.
4. Surveys: From time-to-time our site may request information via surveys. Participation in these surveys is completely voluntary and you may choose whether or not to participate and therefore disclose this information. Information requested may include contact information (such as name and mailing address), and demographic information (such as zip code and age level). Survey information will be used for purposes of monitoring or improving the use and satisfaction of this site.
Updating Your information
Our Privacy Policy may change from time to time and all updates will be posted on this page. If you feel that we are not abiding by this privacy policy, you should contact us by emailing us at member@netwell-com-1-ddf7dperhqcta6cn.eastus-01.azurewebsites.net. You may also update your information by emailing us by logging into your member portal at any time to update your information. If you request that we delete your information, you understand that it may not be possible to delete information from our backup systems. We will delete records in accordance with our general record retention policies and do not have any obligation or liability to you regarding your information that is deleted.
For More Information
You may make any of the above requests by contacting netWell with your request by emailing us at member@netwell-com-1-ddf7dperhqcta6cn.eastus-01.azurewebsites.net, mailing a written request to netWell at P. O. Box 35339, Canton, OH 44735 or call us at 1-866-netWell. You may make such requests no more than twice in any 365-day period. You understand that we may need to collect information from you to verify your identity in order to respond to your requests; we will respond within 45 days.
