Online and Mobile Communication Privacy Notice
Effective date: 5/7/18
Keystone First, Keystone First CHC, and Keystone First VIP Choice ("Keystone First") are committed to maintaining the privacy and security of the personal information of its plan members ("Members"), mobile application and/or portal users ("Users") and website visitors ("Visitors").
In this Privacy Notice, we refer to Members, Users and Visitors together as "Participants." We appreciate that medical information is particularly sensitive. This Online and Mobile Communication Privacy Notice details the information gathering and dissemination practices of Keystone First with respect to its:
(i) corporate website (www.amerihealthcaritas.com) and the websites of its affiliated health plans and companies as listed on the AmeriHealth Caritas Family of Companies' page on its corporate website (www.amerihealthcaritas.com/corporate/companies.aspx),
(ii) the Keystone First member portals (the "Keystone First Member Portals"),
(iii) Keystone First's mobile applications for its affiliated health plans and companies ("Keystone First Apps or Keystone First Applications") and
(iv) any of Keystone First's text messaging features offered to Users, collectively the "Keystone First Online and Mobile Communication Services."
For a summary of Keystone First's privacy obligations as a health plan under the Health Insurance Portability and Accountability Act ("HIPAA"), please see our HIPAA Notice of Privacy Practices for the particular health plan or company found on the applicable Keystone First Website, Keystone First Member Portal or Keystone First Application.
1. Acceptance of Privacy Notice
By using Keystone First Online and Mobile Communication Services, you agree to accept the terms and conditions set forth in this Privacy Notice. If you do not agree to the terms and conditions of this Privacy Notice, please do not use the Keystone First Online and Mobile Communication Services. Your continued use of Keystone First Online and Mobile Communication Services following the posting of any changes or updates to these terms and conditions will mean that you accept those changes.
2. Collection of Personal Information from the Keystone First Online and Mobile Communication Services
Through the Keystone First Online and Mobile Communication Services, Keystone First and/or its Third Party business partners may collect and/or track:
(1) the home server domain names, e-mail addresses, type of computer or mobile device used, IP address, files downloaded, search engine used, operating system employed, mobile device telephone number, and type of web browser of online or mobile Participants;
(2) the e-mail addresses of a Participant who communicates with Keystone First via e-mail; (3) information knowingly provided by a Participant in online forms, registration forms, surveys, e-mail, text messages, contest entries, and other online or mobile avenues (including demographic and personal profile information); and (4) aggregate and user-specific information on which web pages or application features the Participant accesses.
To better serve Participants to the Keystone First Websites and the Member Portals, Keystone First may use "cookies" to enhance a visitor's browsing experience. Cookies are simple text files stored by a user's browser that provide a way to distinguish among Participants. The cookies placed on a Participant's computer by using a Keystone First Website or a Member Portal do not contain personally identifiable information. A Participant can refuse a cookie or delete the cookies file from his or her computer at any time by using any one of a number of widely available methods.
When a Participant performs a search within a Keystone First Online and Mobile Communication Service, Keystone First may record information identifying the Participant or linking the Participant to the search performed. Keystone First may also record limited information for every search request and may then use that information to solve any technical problems with the applicable Keystone First Online and Mobile Communication Service and to calculate overall usage statistics.
Keystone First may collect certain information about Participants that is either in aggregate form or not personally identifiable, such as aggregate information about Keystone First Online and Mobile Communication Services usage, and Keystone First may share such de-identified information with third parties.
3. Collection of Other Personal Information from the Keystone First Apps and/or Member Portals
Through the Keystone First Apps or Keystone First Member Portals, Keystone First may collect personal information provided by a Member, such as medication information supplied through the "Medicine Cabinet" feature, personal information contained in questions submitted through the "Contact Us" feature, health information or medical history information supplied via text message or demographic information supplied when you change your "Profile and Settings."
4. Use of Personal Information Collected
Personal information collected by Keystone First may be used by Keystone First for many purposes, including: editorial and feedback; statistical analysis of Participants' usage; product development; content improvement; and/or customization of the content and layout of the Keystone First Online and Mobile Communication Services. Aggregate information on Participants' home servers may be used for internal purposes or provided to third parties.
Individually identifiable information, such as names, postal and e-mail addresses, phone numbers, and other personal information that Participants voluntarily provide to Keystone First, may be added to Keystone First's databases and/or used for future calls and mailings regarding Keystone First Online and Mobile Communication Services updates, new products and services, upcoming events, and for other purposes in accordance with state and federal law.
5. Disclosure of Personal Information to Third Parties
- Members / Users. For Members and/or Users using the Keystone First Online and Mobile Communication Services, Keystone First will only use and disclose personal information as permitted by applicable laws, and as described in our HIPAA Notice of Privacy Practices for the particular health plan or company found on the applicable Keystone First Website, Keystone First Member Portal or Keystone First Application.
- Visitors. For Visitors to an Keystone First Website who have not identified themselves as Members, Keystone First will not sell, rent, license, or trade your personal information with third parties for their own direct marketing use unless we receive your express consent to do so. Unless you give us permission to do so, Keystone First will not share the personal information of Visitors other than as specified in this Privacy Notice. Keystone First may share your personal information under confidentiality agreements with other companies that work with, or on behalf of, Keystone First to provide products and services, such as a vendor that helps us collect information on how you use the Keystone First Websites. These companies may use your personal information to assist Keystone First in its operations. However, these companies do not have any independent right to share this information. We may provide information about Visitors to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
6. Link Disclaimer
Keystone First may occasionally provide links to other entities' websites for convenience to the Participants in locating health-related information, services, and products. When you link to other websites, please remember that you are leaving Keystone First's website, and these other websites are maintained by organizations that Keystone First does not control.
7. Security Measures
Keystone First has implemented numerous security features to prevent the unauthorized release of, or access to, personal information, including the measures it has adopted in running its health plans and other lines of business pursuant to HIPAA security requirements. For example, all Keystone First employees are required to certify their understanding that personal information is considered confidential, that it is important to safeguard personal information, and that Keystone First will take appropriate action against any employee who fails to adhere to our privacy standards.
Please be advised, however, that the confidentiality of any communication or material transmitted to or from Keystone First through a Keystone First Online and Mobile Communication Service, e-mail or text cannot be guaranteed. Accordingly, Keystone First is not responsible for the security of information transmitted through the Internet. For more private communications, including communications pertaining to medical or health information, Participants who have health coverage through or administered by Keystone First can contact Keystone First at the phone number listed on their member identification card.
8. Opt-Out Right
Visitors who are not Members may opt out of having their personal information retained by Keystone First by contacting Keystone First through regular mail or telephone at the addresses provided in Section 14 below. This opt-out right does not apply to collection or public traffic information such as the type of web browser that you use to access a Keystone First Website, your geolocation, or your operating system.
9. Access to and Ability to Correct Personal Information
Upon request by regular mail or phone, Keystone First will provide to any Visitor a summary of any personal information retained by Keystone First regarding the Visitor. Visitors may modify, correct, change or update personal information Keystone First has collected through a Keystone First Online and Mobile Communication Service by contacting Keystone First by regular mail or telephone at the addresses provided in Section 14 below.
The rights of Members to access and correct their personal information maintained by Keystone First is governed by our HIPAA Notice of Privacy Practices for the particular health plan or company found on the applicable ACH Website, Keystone First Portal or Keystone First Application.
10. Collection of Personal Information from Children
Keystone First understands the importance of protecting children's privacy in the interactive online world. The Keystone First Online and Mobile Communication Services, including the Keystone First Websites, Keystone First Member Portals and the Keystone First Apps, are not designed for, or intentionally targeted at, children under 13 years of age.
It is not our policy to intentionally collect information about anyone under the age of 13. No one under the age of 13 should submit any personal information to Keystone First through a Keystone First Website, an Keystone First Member Portal and/or an Keystone First App.
11. Response to "Do Not Track" Signals
Some Internet browsers include the ability to transmit "Do Not Track" signals. Since uniform standards for "Do Not Track" signals have not yet been adopted, the Keystone First Online and Mobile Communication Services does not process or respond to "Do Not Track" signals.
12. Your Role in Protecting Your Privacy
13. Privacy Notice Changes
This Keystone First Online and Mobile Privacy Notice may be revised from time to time as we add new features and services, as laws change, and as industry privacy and security best practices evolve. We display an effective date on the notice at the top of this Privacy Notice so that it will be easier for you to know when there has been a change.
If we make any change to this Privacy Notice regarding use or disclosure of personal information, we will provide appropriate advance notice through the Keystone First Online and Mobile Communication Services. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.
If you have any questions or concerns about this Privacy Notice or about Keystone First's handling of your personal information, please contact us by mail at 200 Stevens Drive Philadelphia, PA 19113, Attn: Privacy Office, by telephone at 1-800-450-1166 or via e-mail through our secure e-mail submission form.