Last Revised: April 17, 2019
1 ELIGIBILITY REQUIREMENTS
Wishbone does not knowingly collect or solicit Personal Information from anyone under the age of 13 or knowingly allow such persons to register for an account for the Program. If we learn that we have collected Personal Information from anyone under the age of 13, we will delete that information.
2 INFORMATION WE COLLECT
Information collected from you will vary depending on how you access or use the Program and what information you choose to provide to us. You may use portions of the Website without registering for an account or submitting any personally identifiable information (collectively, “Personal Information”). When we ask you to provide Personal Information, you can choose not to provide us with Personal Information, but that will prevent you from obtaining an account or using our Program or may prevent you from obtaining requested information, products or services.
2.1 Information We Collect From You
When you register for an account or otherwise use the Program, we may collect information you provide via forms or other online methods including your:
- HCSC plan beneficiary number
- User Name
- Email address
- Date of Birth
- Zip Code
- Telephone and mobile numbers
If you win a prize in any of our sweepstakes or games with a value of $600 or more, we are required by law to obtain your social security number for tax reporting purposes. We will delete your social security number after we have sent you the required tax form.
Telephone calls with Wishbone may be recorded or monitored.
2.2 Information We Receive From HCSC
HCSC will provide us with the following information about you:
- Demographic information
- Eligibility data
- Claims data
- Clinical information (disease states)
This information will be used only for the purposes described in Section 3 below.
2.3 Login Through Social Media
We may allow you to login to the Program using third party services (including social network Websites such as Facebook, Google Plus or Twitter) (“Social Media“). If you login to the Program through Social Media, we access and collect information about your use of the Social Media service and information you provide to such Social Media service. To the extent you and the Social Media service allow, we may access your information that is publicly available to other users of the Social Media service and all information you have provided to the Social Media service, such as login e-mail and other content information, friends lists, network statistics and updates regarding your Social Media account.
2.4 Automated Collection of Information
Other information we may automatically collect include:
- Geolocation data
- Check ins
- Claims data
- Calendar access
- Access to health kit data (activity, sleep, nutrition)
- App activity (views, purchases, questions within the App)
- Searches you have made through our Program
- Portions of the Website or App you’ve visited
- How long you spent on a portion of our Website or App
- Sections or content in the Program on which you click
- The number of times you visit a page of our Website or App
- When emails are opened or links are clicked
We may also use web beacons to access our cookies. A web beacon is an electronic file on a Web page that allows us to count users who have visited that page and to recognize users by accessing our cookies. Further, a web beacon can be used in HTML-formatted email to determine responses to our communications and measure their effectiveness. You can avoid web beacons by turning off HTML display and displaying only the text portion of your email. You can learn more about cookies and non-cookie tracking technologies, including how to opt out of accepting cookies, by visiting the Network Advertising Initiative.
Wishbone does not track users across websites or applications operated by third parties (“Third Party Websites”), and therefore does not use or respond to “do not track” (“DNT”) signals in your web browser. However, some Third Party Websites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such Websites, certain Website browsers allow you to set the DNT signal on your browser so that third parties (particularly advertisers) know you do not want to be tracked.
We may participate in behavioral-based advertising. This means that a third party may place a cookie on your browser, or use a web beacon, to collect information about your use of our Website so that they can provide advertising about products and services tailored to your interest. That advertising may appear either on our Website, or on other Websites.If you would like to opt-out from having the behavioral-based advertising companies with whom we have a relationship use your information for advertising purposes you can do so by visiting the Network Advertising Initiativeor Digital Advertising Alliance.
3 HOW WE USE YOUR INFORMATION
3.1 To Provide the Program
We use the information that we collect from you to provide you with the Program, support and enhance your use of the Program, allow you to select applicable products or services, to provide you with information about products and services that may be of interest to you, to monitor which features of the Program are used most and to allow us to determine which features we need to focus on improving. We will also use your Personal Information to deliver prizes you may win through our sweepstakes or games.
We use member eligibility data provided by HCSC to determine your eligibility to register for the Program.
Upon registration with the Program, a user profile is developed to further customize your experience and provide you with content, services or products that may be relevant to you.
We will also use demographic information, claims data and clinical data provided by HCSC to personalize your experience in the Program such as customizing the offers and advertising you receive.
From time to time you may be given the option of receiving periodic informational and promotional mail, e-mail or text messages from Wishbone. You choose whether or not to receive such correspondence when you provide this information or by changing your preferences within your registration profile at any time.
We use non-personal information collected from you and all other users of the Program in the aggregate, so that we can improve the Program and for business and administrative purposes.
3.2 Diagnose Problems
Wishbone uses your Internet Protocol (IP) address and other information about your computing devices to help diagnose problems with our computer server, and to administer the Program. Your IP address is also used to gather broad demographic data. It is not stored or linked to your personal profile information, such as name or contact information.
3.3 Program-related Announcements
We will send you strictly Program-related announcements on rare occasions when it is necessary to do so. For instance, if our Program is temporarily suspended for maintenance, we might send you an email.
Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.
3.4 Customer Service
4 OUR DISCLOSURE OF YOUR INFORMATION
4.1 Fulfilment of Prizes and Purchased Goods and Services
We will use your Personal Information to deliver prizes you may win through our sweepstakes or games.
We also will share the minimum necessary information needed for fulfillment with health-related vendors that make deals available to you (“Deal Vendors”) after you have made a purchase. In order to determine fulfillment, we will share certain limited information with Deal Vendors, such as your name, address, phone and e-mail for products and unique bar code for services. We will not share any individually identifiable health information or any aggregated or de-identified data with Deal Vendors.
4.2 Third Party Service Providers
4.3 Aggregated Data
We may aggregate your Personal Information with information of other users and/or de-identify your Personal Information in a manner that such information can no longer be used to identify you, and may also collect and create aggregated usage and log data collected from users of the Program that does not contain Personal Information (collectively, the “Anonymized Data”). We may use and share Anonymized Data for any business purposes, including sharing it with our business partners, affiliates and service providers.
4.4 Law Enforcement
Wishbone cooperates with government and law enforcement officials, agencies and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials, agencies or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal processes (including but not limited to subpoenas), to protect the property and rights of Wishbone or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical or legally actionable activity.
4.5 Business Transfers
5 ACCESSING AND UPDATING YOUR PERSONAL INFORMATION AND PREFERENCES
If your Personal Information changes, or if you no longer desire our Program, or if you wish to update your preferences to receive email or other communications from us, you may correct, delete inaccuracies, or amend your Personal Information and preferences by logging into your account and making the change on our user information page or by contacting us at email@example.com. We will use reasonable efforts to respond to your request within 30 days.
6 RETENTION OF PERSONAL INFORMATION
We use reasonable measures to protect your account information against unauthorized access or release. However, we cannot guarantee the security of our database, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet, and any information you transmit to Wishbone you do at your own risk. We recommend that you use unique numbers, letters and special characters in your password and not disclose your password to anyone. If you do share your password or Personal Information with others, you are responsible for all actions taken in the name of your account. If your password has been compromised for any reason, you should immediately notify Wishbone at firstname.lastname@example.org change your password.
In addition, we have procedures that limit Wishbone’ employees and contractors’ access to Personal Information. Only those employees and contractors with a business reason to know have access to such information. We educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, mandatory training programs, and internal policies on data privacy and corporate integrity. We take appropriate disciplinary measures to enforce employee privacy responsibilities.
When you enter especially sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). We will not store your complete credit card information on our servers, but will only use an incomplete identifier (e.g., last four digits of your credit card number) to identify your account. Any complete credit card information you choose to store in connection with your account will be stored by our third party payment processing service providers.
8 INDIVIDUAL CALIFORNIA RESIDENTS
California residents may choose to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes or choose to opt out of such disclosure. Our policy is not to disclose personal information collected online to a third party for directing marketing without your approval. To make a request or to opt out at any time, please contact us email@example.com the other contact information provided below.It is important to note that this opt-out does not prohibit disclosures made for non-marketing purposes.
9 THIRD PARTY LINKS
We may provide links to Third Party Websites, such as credit bureaus, service providers or merchants or Social Media. If you follow links to websites or applications not affiliated or controlled by Wishbone, you should review their privacy and security policies and other terms and conditions. Wishbone does not guarantee and is not responsible for the privacy or security of these websites or applications, including the accuracy, completeness, or reliability of their information.
11 USERS OUTSIDE THE UNITED STATES
12 CONTACT US
Wishbone Club, LLC
Attention: Privacy Officer
300 E Randolph Street
Chicago, IL -60601
or at privacy@Wishbone.com