This Privacy Policy (“Notice”) is provided by Complementary Healthcare Plans, Inc. d/b/a The CHP Group (“The CHP Group,” “we,” “us,” or “our”).
This Notice only applies to information collected through www.chpgroup.com and chpactiveandhealthy.com (collectively, “our websites”). This Notice does not apply to information that we collect offline.
Protecting Your Privacy
The CHP Group is committed to protecting your privacy and maintaining the confidentiality of your information. This Notice answers some common questions about how we handle your information.
This Notice only applies to users of our websites listed above. This Notice does not apply to an employer plan sponsor or group policyholder, or plan participants or beneficiaries. For information on how we safeguard Protected Health Information, as defined by HIPAA, please contact us using the information below.
Information We Collect
We collect two basic types of information about you when you use our websites: personally identifiable information and non-personally identifiable information.
Personally Identifiable Information. Personally identifiable information is any information that can directly identify you, such as your name, e-mail address, telephone number, postal address, social security numbers, and payment card information.
We collect personally identifiable information when you provide us with information about you, including when you submit questions or comments to us or purchase a product or service from us (such as the Active and Healthy Program), when you participate on social media with The CHP Group or use other features of our websites, or in any other instance where a user submits personally identifiable information to us.
Non-Personally Identifiable Information. Non-personally identifiable information is information that does not personally identify you, but it may include tracking and usage information about your location, demographics, and use of our websites.
Generally, we collect and store the following types of non-personally identifiable information: (1) Device information about your computer, mobile device, or other device that you use to access our websites (this information may include IP address, geolocation information, unique device identifiers, browser type, browser language, and other transactional information); and (2) Usage information about your use of our websites (this information includes a reading history of the pages you view, “traffic data” such as time of access, date of access, software crash reports, session identification number, access times, and referring website addresses, your search terms and search results, other information regarding your use of our websites, and aggregate data regarding the use of our websites).
Use of Cookies and Other Tracking Technologies. Like many websites, we use “cookies,” which are small text files that are stored on your computer or equipment when you visit certain online pages that record your preferences and actions. We use cookies to monitor traffic, improve our websites, and make it easier to use and more relevant. Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of our websites may not work or may not work as designed. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org.
Our websites also use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies or other tracking technologies to help us analyze how users interact with and use our websites, compile reports on our websites’ activity, and provide other services related to our websites’ activity and usage. The technologies used by Google may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. Our websites do not use Google Analytics to gather any personally identifiable information. The information generated by Google Analytics will be transmitted to and stored by Google and will be subject to Google’s privacy policies.
Your browser or device may include “Do Not Track” functionality. The CHP Group’s information collection and disclosure practices, and the choices that we provide to users, will continue to operate as described in this Notice, whether or not a Do Not Track signal is received.
This Notice also does not apply to information collected by companies or organizations to which we may link or who may link to us. We are not responsible for the actions and privacy policies of third party websites. If you have any concerns or questions about another company or organization’s privacy practices, you should review their privacy policy or contact them prior to using their website or products or services.
Children’s Information. Our websites contain general audience content and services. We do not knowingly accept or collect any personal information from children under the age of 13 and we will delete any personal information collected that we later determine to be from a child under the age of 13. If you are under the age of 13, please exit our websites, and do not provide us with any personal information. If you are a parent or guardian of a child under the age of 13, and believe he or she has disclosed personal information to us without your knowledge and consent, please contact us at privacy@chpgroup.com.
How We Use Your Information
We may use personally identifiable information and non-personally identifiable information about you collected through our websites for several reasons, including:
- To help us personalize and continually improve your experience on our websites, including optimizing and improving our websites and operations;
- To assist us in providing products, services, or features that you request or utilize;
- To help design and improve our products, services or features;
- To offer products and services that may be of interest to you, including third-parties’ products or services;
- To provide you with requested content or communicate about our or a third party’s products or services;
- To detect, investigate, and prevent activities that may violate our policies or be illegal;
- To perform statistical, demographic, and marketing analyses of users of our websites; and
- To conduct other business activities related to The CHP Group or its customers.
We may use the information from one portion of our websites on other portions of our websites, and we may combine information gathered from multiple portions of our websites into a single record. We also may use or combine information that we collect through our websites with information that we collect offline or we collect or receive from third-party sources.
How We Share Information
In the course of doing business we may share your personally identifiable information with others as described below.
Third-Party Agents and Service Providers. We have third-party agents, affiliates and service providers that perform functions on our behalf, including, but not limited to: hosting, content syndication, content management, technical integration, marketing, analytics, customer service, and conducting business activities related to The CHP Group and our websites. The CHP Group uses a third party service provider to process all purchases made through our websites.
These entities may have access to personally identifiable information if needed to perform their functions. If such access is required, the third parties will be required to agree to maintain the confidentiality and security of that personally identifiable information.
Law Enforcement, Legal Process, and Emergency Situations. We may also use or disclose personally identifiable information if required to do so by law or on the good-faith belief that such action is necessary to (a) conform to applicable law or comply with legal process served on us or our websites; (b) protect and defend our rights or property, our websites or our users, or (c) act to protect the personal safety of us, users of our websites or the public. This may include disclosing your personally identifiable information in response to a subpoena, to prevent fraud, to comply with inquiries from government agencies or other regulators, or for other legal purposes.
Assignment. We may change our ownership or corporate organization while providing our websites. We may also sell certain assets associated with our websites. In such event, we may transfer some or all of your information to an entity acquiring all or part of our assets or to another entity with which we have merged. Under such circumstances, we would request the acquiring party to follow the practices described in this Notice. Nevertheless, we cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Notice.
Active and Healthy Program. When you enroll in the Active and Healthy Program you will be required to submit certain information, such as your name and email address. In some cases, you may need to provide additional information, such as your health plan identification number or a purchase number. We may combine information that we receive offline or through other sources with information you provide through enrollment in the Active and Healthy Program. We may share information about your enrollment in the Active and Healthy Program as described above, with your health plan, other service providers, and banks or mutual fund companies. Among other entities, we may share your information, when you enroll in the Active and Healthy Program, with Absolute Recreation Management (“ARM”) to perform certain services, such as website hosting, on our behalf. ARM or other service providers may contact you or otherwise use or share your information to provide services or information related to the Active and Healthy Program. When you provide information to ARM, ARM’s privacy practices will apply.
Your California Privacy Rights. California law permits users of our websites who are California residents to request certain information regarding our disclosure of their personally identifiable information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to privacy@chpgroup.com specifying that you seek your “California Customer Choice Notice.” Please allow thirty days for a response.
Non-Personally Identifiable Information. We may disclose your non-personally identifiable information in any other manner that we deem appropriate. Among other things, we may disclose non-personally identifiable information to third parties to help us determine how people use parts of our websites and how we can improve our websites.
We Protect Information We Collect About You
Ensuring the security of your personally identifiable information is important to us. We implement reasonable and appropriate security measures to help safeguard your personally identifiable information.
Accuracy and Retention of Personally Identifiable Information
We strive for accurate records. Please tell us if you receive any incorrect materials from us or believe any of your personally identifiable information held by us is inaccurate. We will make appropriate changes to any personally identifiable information we determine to be inaccurate unless we believe doing so would violate any laws or legal requirements. You may be required to provide us with personally identifiable information to verify your identity prior to accessing any records containing information about you. We maintain personally identifiable information as long as necessary for the purpose for which it was collected or for which it is to be further processed.
Notice to Non-US Users
Our websites are published in the United States and directed to individuals located in United States. Our policies are directed at compliance with the laws of the United States. If you are located outside the United States, you should be aware that your personally identifiable information will be transferred to the United States, the laws of which may be deemed by your country to have inadequate data protection. If you use our websites, you consent to the use of such information as provided in this Notice and to the transfer of that information to and storage of that information in the United States. If you are uncertain whether this Notice conflicts with the applicable local privacy laws where you are located, you should not submit your personally identifiable information to us.
More Information
You may write to us if you have questions about this Privacy Policy or our privacy practices.
Contact our Privacy Officer by e-mail at privacy@chpgroup.com or by mail at
The CHP Group
PO BOX 278
Beaverton, OR 97008-0278
We may change our privacy practices at times. Your continued use of our website following the posting of changes to this Notice will mean you accept the changes. If we make changes to this Notice that materially and adversely affect the way we use the personally identifiable information we previously collected about you, we will provide you with notice of the changes and seek your consent for such use. We also will give you a revised notice when required by law.
Revised 10/2017