PRIVACY POLICY

Please Read Carefully

This Online Privacy Policy describes the information Optum Labs, LLC and its affiliates, authorized service providers, and agents (collectively, the “Company” “us” or “we” or “our”) collect in connection with your use of the ProtectWell™ websites (collectively, the “Site”), mobile applications (the “App”), and all other ProtectWell-related services (the “Services”), how we use and share that information, and the privacy choices we offer.

California Residents: To learn more about our privacy practices under the California Consumer Protection Act of 2018 (CCPA), see our CCPA Notice.

You have downloaded the App and registered with ProtectWell for your personal use of the App and your use with one or more Sponsors and/or Projects who you may elect to “join” using the functionality of the App or the Site:

  • Sponsor. As described in the Terms of Service, you may elect to be associated with your employer, educational institution, or other specified sponsor (a “Sponsor”) in the App or Site if such potential Sponsor is a ProtectWell participating Sponsor. If you previously downloaded the App and registered with ProtectWell for your use with one particular Sponsor (whether your employer or school), you are continuing to use the Services with your previously associated Sponsor until such time as you (if permitted by your Sponsor) or your Sponsor chooses to disassociate such connection. After disassociation with a Sponsor you may continue to use the App with other Sponsors, Projects, and ProtectWell Participating Businesses selected by you.
  • Project. You may elect, from time to time, in the App or on the Site to participate in one or more research studies or other projects offered via the ProtectWell platform (each a “Project”). If you elect to participate in such a Project, you may be presented with supplemental terms and conditions and a supplemental privacy policy that will apply with respect to such Project and your involvement (the “Supplemental Terms”). Except to the extent expressly overridden in such Supplemental Terms, this Privacy Policy shall continue to apply. We may use the information that we collect about you to determine your eligibility to participate in a Project and to offer you the opportunity to participate.

This policy applies to information that we collect when:

  • you access the App, Site, or Services; and
  • you access the Site not through or logged into your ProtectWell account, including if you are accessing the Site without having registered with ProtectWell.

Use of this App is not a healthcare benefit and is not the provision of healthcare services.

Changes to this Online Privacy Policy

We may change this Online Privacy Policy from time to time. If we make changes, we will notify you by posting the updated policy on our Site and revising the “Last Updated” date below. We encourage you to review this Online Privacy Policy whenever you use the Services to stay informed about our information practices and ways you can help protect your privacy.

Confidentiality of Medical Information

If your Sponsor has subscribed for certain lab testing reporting services, then in using the App, Site, or Services, you may be directed to visit a healthcare provider for lab testing or take a home test provided by a testing laboratory (each a “Lab Test” and such provider or testing laboratory, a “Testing Lab”). Certain health information that you disclose to the Testing Lab may be protected health information or, for a provider at your educational institution’s facility, subject to educational privacy laws. Please review the provider’s HIPAA Notice of Privacy Practices or your Sponsor’s Annual Notification of Rights under the Family Educational Rights and Privacy Act (“FERPA”) to learn more about their privacy practices regarding your health information. However, once your health information, such as lab results and diagnosis, is disclosed to us, our Site, or our Services, that information will no longer be protected by HIPAA.

Use of App, Site, and Services

Your access to and use of the App, Site, and Services are subject to, and conditioned upon, certain terms and conditions as set forth in our Terms of Use, in which this Online Privacy Policy is hereby incorporated by reference.

Collection of Information

Information We Collect About You

We collect information about you when you use our App, Site, and Services, which may include:

  • Your Account Registration Information.
    • Your name;
    • your email address that you choose to be associated with your account (as opposed to an email address that we may collect with respect to a specific Sponsor as described below); and
    • your phone number.
  • Sponsor Registration Information. When you associate with a Sponsor in the App or on the Site, you may be required to enter certain information applicable to such Sponsor (“Sponsor Registration Information”) such as:
    • your work or school email address associated with such Sponsor;
    • your worksite or campus location; and
    • your employee or student ID (which identifies you to your Sponsor and which your Sponsor may have provided to you to enter into ProtectWell when associating with the Sponsor).

    Alternatively, we may collect some or all Sponsor Registration Information from the Sponsor and/or the Sponsor may directly update such Sponsor Registration Information with ProtectWell from time to time.

    If you choose to disassociate from Sponsor in ProtectWell, or Sponsor chooses to disassociate from you in ProtectWell, then you will no longer have access to Sponsor Registration Information. We may continue to provide Sponsor access to or delete such Sponsor Registration Information and historical Symptom Checker Responses (described below under “Sharing of Information”) collected during that period, in Sponsor’s discretion.

  • Symptom Check Responses and Status.
    • ongoing Symptom Check Responses, which may include whether you have reported testing positive or negative for COVID-19, and Symptom Check Response status information such as (but not limited to):
      • when you made such COVID-19 symptom self-attestations (or whether you have not);
      • self-reported initial date of symptoms and/or last date of exposure; and
      • whether you “resubmitted symptoms”
    • whether you are “cleared” by ProtectWell for purposes of returning to work based solely on your Symptom Check Responses and any Test Results (determined in part based on Center for Disease Control guidelines); and
    • if you are in a self-quarantine period at home under the ProtectWell protocols, then the remaining number of days in such quarantine period.
  • Lab Tests. In addition, if your Sponsor subscribes to integrated COVID-19 lab test scheduling and reporting functionality, and you take such a Lab Test, we may collect lab results and any corresponding diagnosis from you or (if you authorize) the Testing Lab.
  • Device Information. We may automatically collect certain information about the computer or devices (including mobile devices) that you use to access the Services. For example, we may collect and analyze information such as (a) operating system and the state or country from which you accessed the App, Site, or Services and, when you access the Site, IP address, browser type, and browser language; and (b) information related to the ways in which you interact with the App, Site, or Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the App, Site, or Services, the frequency of your use of the App, Site, or Services, error logs, and other similar information.We also may use third-party website analytics services in connection with the App, Site, or Services, including, for example, to register mouse clicks, mouse movements, scrolling activity and text that you type into the website or mobile application. These website analytics services only collect limited personal information, such as IP address. Such Personal Information may only be used by these vendors to perform analytics services for us. We use the information collected from these services to help make the website easier to use.

Use of Information

We use the information that we collect for the following purposes:

  • For the purposes for which you provided the information, including to share Symptom Check Response and related information with the Sponsor(s), Project(s), and ProtectWell Participating Business you choose to join and share such information as described below under Sharing of Information;
  • To provide, maintain, administer, improve, or expand the App, Site, or Services;
  • To contact you when necessary or requested in performing the Services;
  • To customize and tailor your experience of the App, Site, or Services;
  • To determine your eligibility to participate in a Project and to offer you the opportunity to participate in such a study;
  • To send you news and information about the App, Site, or Services, including Projects that may be of interest to you;
  • To track and analyze trends and usage in connection with the App, Site, or Services;
  • To better understand who uses the App, Site, or Services and how we can deliver a better user experience;
  • To use statistical information that we collect in any way permitted by law;
  • To prevent, detect, and investigate security breaches, fraud, and other potentially illegal or prohibited activities;
  • To enforce the legal terms that govern your use of the App, Site, or Services;
  • To generate aggregate or de-identified data (that is not personally identifiable) and use such aggregate or de-identified data as described below;
  • To administer and troubleshoot the App, Site, or Services; and
  • For any other purpose disclosed to you in connection with the App, Site, or Services.

We may use third-party service providers to process and store personal information. The ProtectWell platform production environment that is used to provide you the Services operates solely on our or our vendors’ servers located in the United States.

Aggregate or De-identified Data

We may generate or derive aggregate and/or anonymized, non-personally identifiable information from information collected by the App, Site, or Services or via other means so that the information is not intended to identify you. We may use and disclose such non-personally identifiable information:

  • to provide the Services, keep the Services secure and up to date, and improve the Services; and
  • for research and use for health and wellness, including to develop therapies, diagnostics, and other products and services for health and wellness, and for infectious disease planning and response;

in each case, in accordance with applicable laws and regulations.

Sharing of Information

We may share personal information about you as follows:

  • Shared with Sponsors. We may share the following information with your Sponsor to support your and your Sponsor’s decision-making, including regarding ready-to-work or return-to-school status:
    • Your name;
    • Your email address;
    • Sponsor Registration Information applicable to such Sponsor;
    • Your ongoing COVID-19 symptom check responses, including whether you have reported testing positive or negative for COVID-19 (“Symptom Check Responses”);
    • Symptom Check Response status information such as but not limited to:

      • when you made such COVID-19 symptom self-attestations (or whether you have not);
      • self-reported initial date of symptoms and/or last date of exposure; and
      • whether you resubmitted symptoms from a previous Symptom Check Response
    • whether you are “cleared” by ProtectWell for purposes of returning to work based solely on your Symptom Check Responses and any Test Results (determined in part based on Center for Disease Control guidelines); and
    • if you are in a self-quarantine period at home under the ProtectWell protocols, then the remaining number of days in such quarantine period.
    • If you elect to disassociate from a Sponsor in ProtectWell using the functionality in the App, or if your Sponsor elects to disassociate from you in ProtectWell, then we will cease providing any newly collected information collected from you to the Sponsor after the date of such disassociation, but we may continue to provide the Sponsor historical information described above collected prior to such disassociation.

    • Shared with Sponsors Subscribing to Lab Testing Reporting. If your Sponsor subscribes for integrated COVID-19 testing scheduling and reporting, then:
      • To take a Lab Test scheduled and reported via the ProtectWell platform, you will be required to consent to our disclosing the Lab Test results to your Sponsor. With such authorization from you, we may disclose the results of such Lab Test to your Sponsor to aid your and your Sponsor’s decision-making, including regarding ready-to-work or return-to-school status; and
      • We may share with your Sponsor whether you have failed to schedule or take such Lab Test or to authorize us to disclose the results to the Sponsor.
    • Shared in Connection with Projects.
      • With your authorization, we may share information about your Symptom Check Responses and Test Results with our affiliates to determine your eligibility to participate in a Project and to offer you the opportunity to participate in such a study;
      • Should you elect to participate in a Project, then related to such Project we may share the information described in any supplemental privacy policy or terms and conditions that you agree to in connection with joining such Project;
    • Shared with ProtectWell Participating Businesses. When and if made available in the Service, we may enable you to, solely in your discretion:
      • Visually show the “ProtectWell Cleared” screen on your App to a participating ProtectWell business or person who requests evidence of your Symptom Checker Response status (a “ProtectWell Participating Business”); and/or
      • otherwise electronically transfer your current Symptom Check Response and related Symptom Check status information, including, if any, recent Lab Test results to such ProtectWell Participating Business.
    • With third-party service providers to provide, maintain, and improve the App, Site, or Services, including service providers who access information about you to perform services on our behalf;
    • In connection with, or during the negotiation of, any merger, sale of company stock or assets, financing, acquisition, divestiture or dissolution of all or a portion of our business (but only under non-disclosure and confidentiality agreements and protections);
    • If we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; to enforce applicable user agreements or policies; to protect the security or integrity of the App, Site, or Services; and to protect us, our users or the public from harm or illegal activities;
    • We may also share your personal information in other ways with your consent; and
    • We may also share aggregated and/or anonymized, non-personally identifiable information with third parties as described above under Aggregate or Anonymous Data.

    Security

    We take reasonable measures, including administrative, technical, and physical safeguards, to help protect personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. 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, Company cannot ensure or warrant the security of any information you transmit to us or from our App, Site, Services, or other online products or services, and you do so at your own risk.

    Your Privacy Choices

    How You Can Access and Update Your Information

    You may update or correct information about yourself at any time or by emailing us at protectwellsupport@uhg.com.

    Cookies

    Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies; however, the App, Site, or Services may not function properly if you do so.

    Links to Other Websites

    The App, Site, or Services may contain links to other websites and those websites may not follow the same privacy practices as Company. We are not responsible for the privacy practices of third-party websites. We encourage you to read the privacy policies of such third parties to learn more about their privacy practices.

    Children

    Company does not knowingly collect or maintain personally identifiable information from persons under 13 years of age unless your Sponsor is a K-12 school and we have obtained the consent of such school or school district (or parent, as applicable). If you are under 13 years of age, then please do not use the App, Site, or Services, unless your school or school district asks you to. If Company learns that personally identifiable information of persons under 13 years of age has been collected without consent of the student’s school or school district, then Company will take the appropriate steps to delete this information. To make such a request, please contact us at protectwellsupport@uhg.com. Additional information about collection of student data in the K-12 context is provided to schools prior to such collection.

    Your California Privacy Rights

    If you are a California resident, please review the following additional privacy disclosures under the California Consumer Privacy Act of 2018 (CCPA).

    PI, We Collect and Disclose for Business Purposes

    In the preceding twelve (12) months, we may have collected the following PI about California residents:

    Category Examples Collected Categories of Third Parties to Which We Disclose PI for Business Purposes
    Identifiers A real name, postal address, Internet Protocol address, or email address. Yes Affiliates and Contracted Service Providers
    Personal information categories listed in the California Customer Records law A name, address, telephone number, or medical information. Some Personal Information included in this category may overlap with other categories. Yes Affiliates and Contracted Service Providers
    Biometric information Health data Yes Affiliates and Contracted Service Providers
    Internet and/or network activity Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. Yes Affiliates and Contracted Service Providers

    PI does not include:

    • De-identified or aggregated consumer information
    • Publicly available information from government records
    • 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
    • PI covered by other privacy laws, including: The Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994

    Categories of Sources of PI

    We obtain the categories of PI listed above from:

    • You or your authorized agent,
    • Service providers,
    • Our affiliates,
    • Publicly available information, or
    • Activity on our apps and websites

    The collections from these sources can occur online, in person, paper or other electronic means.

    Why We Collect PI
    We collect your PI for one or more of the following business purposes:

    • To communicate with you
    • To personalize services for you
    • To perform analytics and to improve our products
    • To protect someone’s health, safety, or welfare
    • To provide information to your Sponsor as described above
    • As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law

    In the preceding twelve (12) months, we have not sold any PI.
    Third parties are not allowed to use or disclose your PI other than as specified in our contract and as permitted by law.

    If we seek to use your PI for a materially different purpose than we previously disclosed in this notice, we will notify you and will not use your PI for this new purpose without your explicit consent.

    Your Rights

    1. You have the right to request that we disclose certain information to you about our collection and use of your PI over the preceding twelve (12) months prior to your request. Once we receive and confirm your verifiable consumer request, we will disclose to you:
      • What PI we collect about you
      • Where and from whom we collect PI about you
      • Our business purpose for collecting PI about you
      • The types of third parties with whom we share your PI
      • The specific pieces of PI we collect about you (however, we will not disclose your actual Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers)
      • The types of PI that we disclosed about you for a business purpose, and the categories of third parties to whom we disclosed your PI
    2. You have the right to be informed about the PI that we collect about you at or before we collect it. This is that notice.
    3. You have the right to request that we delete any PI about you that we have. Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why.
    4. You will not be discriminated against or penalized for exercising your CCPA rights to your PI. We will honor your rights, and unless permitted by the CCPA, we will not:
      • Deny you services,
      • Charge you different prices or rates for services,
      • Impose penalties, or
      • Provide you with a different level or quality of services.

    How to Exercise Your Rights

    • You can submit requests for information about your PI by calling us at 855-602-1006or emailing us at protectwellsupport@uhg.com.
    • You may be required to submit proof of your identity for these requests to be processed.
    • We will not be able to comply with your request if we are unable to confirm your identity.
    • You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.

    Timing

    • Our responses to any of your requests for the information described above will be limited to information that we have collected in the preceding twelve (12) months before our receipt of your verified request.
    • You will receive our response to your request within 45 days of your request, unless we provide you with notice that it will take more than 45 days to respond (in that case, we won’t take more than 90 days to respond).

    No Rights of Third Parties

    This Online Privacy Policy does not create rights enforceable by third parties.

    How to Contact Us

    Please contact us with any questions or concerns regarding this Online Privacy Policy at:

    UnitedHealth Group
    5995 Opus Parkway
    Minnetonka, MN 55343
    Attention: General Counsel, Optum Labs
    Email: protectwellsupport@uhg.com
    Phone: 855-602-1006

    Last updated on January 1, 2021.