Thank
you for using the application(s) as provided by RxEOB.Com, LLC. (“RxEOB”) .
This privacy policy tells you how we use personal information collected in this
application. Please read this privacy policy before using the application or
submitting any personal information. By using the application, you are
accepting the practices described in this privacy policy. These practices may be changed or updated from time to
time. You are encouraged to review the privacy policy whenever you use the application
to make sure you understand how any personal information you provide will be
used. If you are a registered user, you have already agreed and are
additionally subject to either (1) the Terms of Use, or (2) any relevant client
service contract entered into between your pharmacy benefit provider and RxEOB,
each of which expressly incorporates this Privacy Policy.
NOTE:
the privacy practices set forth in this privacy policy are for the RxEOB application.
If you link to other websites within RxEOB application, please review the
privacy policies posted for those sites.
1. Collection
of Information
2. Tracking
Technologies
3. Distribution
of Information
4. Updating/Accessing/Amending/Correcting
Personal Information
5. Customer
Testimonials/Comments/Reviews
6. Commitment
to Data Security
7. Notification
of Changes
8. Your
Consent
9. California
Consumer Privacy Act Notice
9.a. CCPA
Consumer Request Form
10. Privacy
Contact Information
Collection
of Information
We
may collect personal information, like names, postal addresses, email
addresses, mobile phone numbers etc. that are volunteered by you if you are
required to register or by volunteering for messaging services. Upon this
registration you are given a unique RxEOB ID, and you are no longer anonymous
to us. Once you are registered you are granted access to features of the RxEOB application.
This information is used to fulfill your specific requests unless you authorize
us to use it in another manner, for example to report an issue or discrepancy
with our application or services.
Tracking
Technologies
Technologies
such as: cookies, tags, and scripts are used by RxEOB and our partners,
Pharmacy Benefit Sponsors, affiliates, for analytics. These technologies are
used in analyzing trends, administering the application, tracking users’
movements around the application, and to gather demographic information about
our user base as a whole. We may receive reports based on the use of these
technologies by these companies on an individual as well as aggregated basis.
We
use cookies to remember users’ settings. Users can control the use of cookies
at the individual browser level. If you reject cookies, you may still use our application,
but your ability to use some features or areas of our application may be
limited.
As
is true of most applications, we gather certain information automatically and
store it in log files. This information may include internet protocol
(IP) addresses, browser type, internet service provider (ISP), referring/exit
pages, operating system, type of device used, date/time stamp, and/or
clickstream data.
We
may combine this automatically collected log information with other information
we collect about you. We do this to improve the services we offer you, to
improve marketing, analytics, or application functionality.
RxEOB
does not display advertising on our application or allow advertising with other
applications. RxEOB does not share any tracking with third party advertisers,
nor do our applications respond to DNT browser signals.
Distribution
of Information
RxEOB
will only share personal information with your health plan, governmental
agencies, or other companies assisting us in fraud prevention or investigation.
We may do so when:
(1)
permitted or required by law such as to comply with a subpoena.
(2)
trying to protect against or prevent actual or potential fraud or unauthorized
transactions; or,
(3)
investigating fraud which has already taken place and when we believe in good
faith that disclosure is necessary to protect our rights, protect your safety
or the safety of others, or respond to a government request.
RxEOB
will not share any personal data with third parties for marketing purposes. If
we are involved in a merger, acquisition, or sale of all or a portion of our
assets, you will be notified via email and/or a prominent notice on our application
of any change in ownership or uses of your personal information, as well as any
choices you may have regarding your personal information. RxEOB will not
disclose any of your personal information except when we have your permission
or under special circumstances described in more detail below.
When
using RxEOB application and sharing personal information, you will be sharing
that information with RxEOB and/or your benefit sponsor. You can choose not to
allow the transfer of your personal information by not using that particular
service.
In
the event of a promotion sponsored by other companies or cosponsored with
RxEOB, you will still have the choice of sharing your information and will be
notified during the time of data collection and decide to share or not to share
your data.
Please
be aware that approved applications that have links on our application may
collect personal information about you. The information practices of applications
linked to RxEOB are not covered by this privacy policy, and you must check
those privacy policies to verify how they may use your personal information.
We
may, however, share aggregate statistical information regarding our customers,
traffic patterns, and application usage with our partners, each of whom is
bound by their own privacy policies and applicable laws. This information will
always be in aggregate and will not be individual and personal in nature. Your
RxEOB account can be deleted or deactivated but doing so will result in
termination of access. Please contact RxEOB for further instructions about
deleting or deactivating your RxEOB account. Residual information will remain
within our archive records.
We
will retain your information for as long as your account is active or as needed
to provide you with services and use your information as necessary to comply
with our legal obligations, resolve disputes, and enforce our agreements.
Updating/Accessing/Amending/Correcting
Personal Information
If
your personal information changes, or if you no longer desire our service, you
may correct, update, amend, delete/remove, or deactivate it by making the
change on our member information page, by emailing our Customer Support at
operations@rxeob.com, or by contacting us by telephone or postal mail at the
contact information listed below:
RxEOB.Com,
LLC
2810
N Parham Road, Suite 245,
Henrico,
Virginia, 23294
804-643-1540
We
will respond to your request within 30 days.
Customer
Testimonials/Comments/Reviews
We
post customer testimonials/comments/reviews on our application which may
contain personal information. We obtain customer’s consent to post their name
along with their testimonial via email prior to posting the testimonial. If you
wish to update or delete your testimonial, please contact us at
operations@rxeob.com.
Commitment
to Data Security
Your
personal information is kept secure. Only authorized employees, agents, and
contractors (who have agreed to keep information secure and confidential) have
access to this information. All emails and newsletters from this application
allow you to opt out of further mailings. Keeping your personal health-related
information private is vitally important to us. Knowing that you use certain
services or features may help us to offer you more relevant content; however as
with all personal information we do not make this available to any third
parties without your permission, except as required by law. Your RxEOB account
information is password-protected and encrypted with built in lockout features
to deter suspicious activity. Only you, your designated benefit enrollee, or
your benefit sponsor have access to this personal information. We strongly
recommend that you do not divulge your password to anyone. RxEOB will never ask
you for your password in an unsolicited phone call or in an unsolicited email.
Also remember to close the RxEOB application when not in use. This ensures that
others cannot access your personal information and correspondence.
Unfortunately,
no data transmission over the Internet can be guaranteed to be 100% secure. As
a result, while we strive to protect your personal information, RxEOB cannot
ensure or warrant the security of any information you transmit to us or from
our online products or services, and you do so at your own risk. Once we
receive your transmission, we will make reasonable efforts to ensure its
security on our systems.
Notification
of Changes
If
we decide to change our privacy policy, we will refer to those changes on our
Homepage prior to the change becoming effective, so our users are always aware
of what information we collect, how we use it, and under what circumstances, if
any, we disclose it. If at any point we decide to make any material changes or
use personal information in a manner different from that stated at the time it
was collected, we will notify users by way of an email prior to the change
becoming effective and wait for your consent. As mentioned before, users will
have the choice as to whether or not we use their information in a different
manner. We will use information in accordance with the privacy policy under
which the information was collected.
We
reserve the right to make changes to this policy. Any changes to this policy
will be posted.
Your
Consent
By
using our application, you consent to the collection and use of the information
as outlined above by RxEOB.
California
Consumer Privacy Act Notice
This
Privacy Notice for California Residents applies to individuals who live in the
State of California and whose data is subject to the California Consumer
Privacy Act of 2018 (CCPA). Below describes what information RxEOB collects
that is subject to the CCPA, your rights under the CCPA, and how you can
enforce those rights under the CCPA. Any terms defined in the CCPA have the
same meaning when used here.
Information
We Collect
We
collect information that identifies, relates to, describes, references, is
capable of being associated with, or could reasonably be linked, directly or
indirectly, with a particular consumer or device (“Personal
Information”).
Personal
Information does not include:
•
Publicly available information lawfully made available from government
records.
•
Deidentified or aggregated consumer information.
•
Information excluded from the CCPA’s scope, like:
o health or
medical information covered by the Health Insurance Portability and
Accountability Act of 1996 (HIPAA) and the California Confidentiality of
Medical Information Act (CMIA) or clinical trial data
o personal
information covered by certain sector-specific privacy laws, including the Fair
Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA) or California
Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection
Act of 1994
If
certain types of information are exempt from CCPA, and therefore this policy,
the RxEOB privacy policy will apply.
RxEOB
has collected the following categories of Personal Information from its users
within the last twelve (12) months:
|
Category
|
Examples
|
Collected?
|
|
A.
Identifiers.
|
A
real name, alias, postal address, unique personal identifier, online
identifier, Internet Protocol address, email address, account name, Social
Security number, driver's license number, passport number, or other similar
identifiers.
|
YES
|
|
B.
Personal information categories listed in the California Customer Records
statute (Cal. Civ. Code § 1798.80(e)).
|
Information
that is protected against security breaches such as: name, signature, Social
Security number, physical characteristics or description, address, telephone
number, passport number, driver's license or state identification card
number, insurance policy number, education, employment, employment history,
bank account number, credit card number, debit card number, or any other
financial information, medical information, or health insurance information.
Some
personal information included in this category may overlap with other
categories and may not be subject to all the rights under the CCPA.
|
YES
|
|
C.
Protected classification characteristics under California or federal law.
|
Age
(40 years or older), race, color, ancestry, national origin, citizenship,
religion or creed, marital status, medical condition, physical or mental
disability, sex (including gender, gender identity, gender expression,
pregnancy or childbirth and related medical conditions), sexual orientation,
veteran or military status, genetic information (including familial genetic
information).
|
NO
|
|
D.
Commercial information.
|
Records
of personal property, products or services purchased, obtained, or
considered, or other purchasing or consuming histories or tendencies.
|
NO
|
|
E.
Biometric information.
|
Genetic,
physiological, behavioral, and biological characteristics, or activity
patterns used to extract a template or other identifier or identifying
information, such as, fingerprints, faceprints, and voiceprints, iris or
retina scans, keystroke, gait, or other physical patterns, and sleep, health,
or exercise data.
|
NO
|
|
F.
Internet or other similar network activity.
|
Browsing
history, search history, information on a consumer's interaction with a,
application, or advertisement.
|
YES
|
|
G.
Geolocation data.
|
Physical
location or movements.
|
YES
|
|
H.
Sensory data.
|
Audio,
electronic, visual, thermal, olfactory, or similar information.
|
NO
|
|
I.
Professional or employment-related information.
|
Current
or past job history or performance evaluations.
|
NO
|
We
generally do not collect additional categories of personal information or use
the personal information we collected for significantly different or
meaningfully unrelated purposes without providing you with notice.
Where
We Obtain Personal Information
We
obtain the categories of personal information listed above from the following
categories of sources:
•
Directly from you or your devices. For example, from forms you complete on our
web application.
•
Indirectly from you. For example, from observing your actions on our application
or interactions with our advertisers.
•
Business partners. For example, pharmacy benefit managers or providers.
•
Publicly accessible sources. For example, National Provider Identifier.
Use
of Personal Information
We
may use, or disclose the personal information we collect for one or more of the
following business and commercial purposes:
•
Fulfilling or meeting the reason you provided the information. For example, if
you share personal information in order to be a registered user of RxEOB
applications, we will use that personal information for the credentialing
process.
•
Providing you with information, products, or services that you request from
RxEOB.
•
Providing you with text messages, email alerts, and other notices concerning
RxEOB’s services, or news that may be of interest to you.
•
Sending you text messages or push notifications.
•
Facilitating the connection of third-party services or applications, such as
social networks.
•
Facilitating transactions and payments.
•
De-identifying and aggregating information collected through our services and
using it for any lawful purpose.
•
Responding to trust and safety issues that may arise.
•
Carrying out our obligations and enforcing our rights arising from any
contracts or other terms entered into between you and RxEOB, including billing,
or as may be required by applicable laws and regulations or requested by any
judicial process or governmental agency.
•
Auditing related to a current interaction with you and concurrent transactions,
including, but not limited to, counting logons, clicks and impressions to
unique visitors, and auditing compliance with this specification and other
standards.
•
Personalizing your experience of our services, such as presenting tailored
content.
•
Undertaking activities to verify or maintain the quality or safety of our
services, and to improve, upgrade, or enhance our services.
•
For testing, research, analysis, and product development, including the
development of data models and algorithms, and for demonstration
purposes.
•
Detecting security incidents, protecting against malicious, deceptive,
fraudulent, or illegal activity, and prosecuting those responsible for that
activity.
•
Debugging to identify and repair errors that impair existing intended
functionality.
•
Short-term, transient use.
•
For other purposes for which we provide specific notice at the time the
information is collected.
•
To respond to law enforcement requests and as required by applicable law, court
order, or governmental regulations.
•
As described to you when collecting your personal information or as otherwise
set forth in the CCPA.
Sharing
Personal Information
RxEOB
may disclose your personal information to a third party for a business or
commercial purpose. When we disclose personal information for a business
purpose, we enter into a contract that describes the purpose and requires the
recipient to both keep that personal information confidential and not use it
for any purpose except performing the contract.
In
the preceding twelve (12) months, RxEOB has disclosed the following categories
of personal information for a business purpose:
Category
A: Identifiers
Category
B: California Customer Records
Category
F: Internet history
In
the preceding twelve (12) months, RxEOB has not disclosed personal information for
commercial purposes. However, for California residents, the California Consumer
Privacy Act (CCPA) defines “selling” personal information to include providing
it to a third party in exchange for money or valuable services.
Pursuant
to our Privacy Policy we share your information with the following categories
of third parties for a commercial purpose:
•
Integrated Third Parties: Third parties integrated into our services.
•
Third Parties as Legally Required: Third parties as required by law and similar
disclosures.
•
Third Parties in Merger/Acquisition: Third parties in connection with a merger,
sale, or asset transfer.
•
Third Parties with Consent: Other third parties for whom we have obtained your
permission to disclose your Personal Information.
For
avoidance of doubt, we do not sell health information subject to HIPAA without
your express authorization. If you give us such an authorization, you may
revoke it in writing at any time. Your revocation will not affect any use or
disclosure permitted by your authorization while it was in effect.
Your
Rights and Choices
The
CCPA provides California residents with specific rights regarding their personal
information. This section describes your CCPA rights and explains how to
exercise those rights.
|
Right
|
To Exercise This Right
|
Time Frame and Response from RxEOB
|
If We cannot complete your request
|
|
Access to specific information and the categories of
sources and purposes for collection, use, disclosure, and sale in the last 12
months, after verification of your identity.
|
Submit request and confirm your "verifiable
consumer request" via the contact information below.
|
We will evaluate and respond to your request
electronically or by mail (at your request) within 45 days. If we require
more time, we will inform you of the reason and extension period in writing.
|
We will explain the reasons we cannot comply with a
request in our response.
|
|
Deletion of information.
You have the right to request that RxEOB delete your
personal information, subject to certain exceptions and after verification of
your identity.
|
Submit request and confirm your "verifiable
consumer request" via the contact information below.
|
We will evaluate and respond to your request
electronically or by mail (at your request) within 45 days. If we require
more time, we will inform you of the reason and extension period in writing.
Once we confirm your verifiable consumer request, we
will delete (and direct our service providers to delete) your personal
information from our
records, unless an exception applies.
|
We will explain the reasons we cannot comply with a
request in our response.
The law does not require us to honor requests to
delete where it is necessary in certain circumstances for us or service
provider to maintain personal information. These include:
- Provide a good or service, perform our
contract or take action reasonably anticipated in the context of our ongoing
relationship with you.
- Detect and protect against malicious, deceptive,
fraudulent, or illegal activity, or prosecute those responsible for such
activities.
- Debug products to identify and repair errors that
impair existing intended functionality.
- Exercise and/or support free speech provided for
by law.
- Comply with the California Electronic
Communications Privacy Act (Cal. Penal Code § 1546 et seq.).
- Use internally for purposes aligned with
your expectations and our relationship.
- Comply with a legal obligation or make other
lawful use compatible with the context in which information was provided.
|
|
Opt out of the "sale" of personal
information in some circumstances. (Note: RxEOB does not sell personal
information)
|
Submit request and confirm your "verifiable
consumer request" via the contact information below.
|
We will evaluate and respond to your request
electronically or by mail (at your request) within 45 days. If we require
more time, we will inform you of the reason and extension period in writing.
|
We will explain the reasons we cannot comply with a
request in our response.
|
"Verifiable
Consumer Request”
To
exercise your rights to access or delete your personal information under the
CCPA, you must submit a “verifiable consumer request.” Only you, or a person
registered with the California Secretary of State that you authorize to act on
your behalf, may make a verifiable consumer request related to your personal
information. You may also make a verifiable consumer request on behalf of your
minor child.
A
verifiable consumer request must:
•
Provide sufficient information that allows us to reasonably verify whether you
are the person about whom we collected personal information or an authorized
representative.
•
Describe your request with sufficient detail that allows us to properly
understand, evaluate, and respond to it.
If
we cannot verify your identity or authority to make the request, we will not be
able to fulfill your request. The information provided for verification will
only be used for that purpose. If you would like to make a request, please Click Here and fill out the
form on the following page.
Authorizing
an Agent
To
authorize an agent to make a request to know or delete on your behalf, please
write to the contact address below in the Privacy Contact Information section.
To authorize an agent to make an opt-out request on your behalf, please send a
written authorization signed by you and the authorized agent to us via the
Contact Information section.
Processing
Fees
We
do not charge a fee to process or respond to your verifiable consumer request
unless it is excessive, repetitive, or manifestly unfounded. If we determine
that the request warrants a fee, we will tell you why we made that decision and
provide you with a cost estimate before completing your request.
Personal
Information Sales Opt-Out and Opt-In Rights
RxEOB
does not sell your personal information. If this should change in the
future, you will be notified and have the option to opt-in if you so desire by
the process as defined in such notification.
Non-Discrimination
We
will not discriminate against you for exercising any of your CCPA rights.
Unless permitted by the CCPA, we will not:
•
Deny you goods or services.
•
Charge you different prices or rates for goods or services, including through
granting discounts or other benefits, or imposing penalties.
•
Provide you with a different level or quality of goods or services.
•
Suggest that you may receive a different price or rate for goods or services or
a different level or quality of goods or services.
We
may offer you certain financial incentives such as discounted prices, rates, or
quality levels. Any permitted financial incentive we offer will reasonably
relate to your personal information’s value and contain written terms that
describe the program’s material aspects. Participation in a financial incentive
program requires your prior opt in consent, which you may revoke at any
time.
“Shine
the Light”
California’s
“Shine the Light” law (Civil Code Section § 1798.83) permits users of our application
that are California residents to request certain information regarding our
disclosure of personal information to third parties for their direct marketing
purposes. To make such a request, please send us an electronic message through
our application or write to us at our address listed below.
Changes
to Our Privacy Notice
We
reserve the right to amend this privacy notice at our discretion and at any
time. When we make changes to this privacy notice, we will post the updated
notice on the application and update the notice’s effective date. Your
continued use of our application following the posting of changes constitutes
your acceptance of such changes.
Privacy
Contact Information
If
you have any questions, concerns, or comments about our privacy policy you may
contact our designated Privacy Officer using the information below:
Robert
S. Oscar, Privacy Officer
secops@rxeob.com
804-643-1540
RxEOB
2810
N. Parham Road, Suite 245
Henrico,
VA 23294