Last Update: March 27, 2024
This Privacy Policy provides information about how SHC Services, Inc. dba Supplemental Health Services (“SHC”) may collect, use, share and safeguard information relating to an individual person (“Personal Information”), and information about your rights and choices regarding our processing of your Personal Information. A reference to “SHC “we,” “us,” or “our” is a reference to SHC Services, Inc. and any relevant affiliate involved in the Personal Information processing activity.
This Privacy Policy applies to all visitors to our website (shccares.com, or the "site"), to online services provided by us or our affiliates that contain a link to this Privacy Policy, and to any form of communication between you and us (collectively referred to as the “Services”). Please read this Privacy Policy carefully. Use of the Services is subject to SHC’s Terms of Use, which is incorporated into this Privacy Policy by reference. By interacting with the Site or otherwise providing your Personal Information and other information through our Services, you agree that we may collect, use, share and/or transfer that information in accordance with the terms of this Privacy Policy, subject to your rights and our obligations under applicable law. If you do not agree to this Privacy Policy, please do not access or use the Site or otherwise provide us with your Personal Information.
This Policy does not apply to Personal Information relating to employees, job applicants, and contractors, who will be provided a separate Privacy Statement from SHC where required by law.
Information We Collect/Information We Collect Automatically
Information Provided by You
We collect Personal Information you choose to provide to us, such as your name, address, telephone number or email address, through registrations, applications, surveys, support or information requests, or other data capturing processes. This includes Personal Information you send to us when you contact SHC with your questions or comments through the “Contact” page on this website, or you provide Personal Information to us for another purpose. We may combine information we have about you with information obtained from public sources. Healthcare professionals may choose to provide us with information relating to their specialties, licensure, and professional status and affiliations.
If you submit any Personal Information relating to other people to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.
Information Collected from Website Use & Navigation
We collect information when you use and navigate the site or interact with our emails, such as the URL of the site you came from, the browser software you use, your Internet Protocol (IP) address, date/time of access, data transferred, pages visited, amount of time you spend on the sites, information about transactions conducted on the sites, and other “clickstream” data. This data is generated and collected automatically, as part of the standard operation of the sites.
To make the site work properly, we sometimes place small data files called cookies on your device. We use cookies, web beacons, tracking pixels, and other technologies to save your preferences, improve your site experience, and collect information when you use and navigate our sites or interact with emails from us. Tracking pixels are transparent graphic images, sometimes called web beacons or tracking beacons, that are placed on a web page or in an email to indicate that the page or email has been viewed. Pixels collect information about your browser or device and can also set cookies. If you access the site using a mobile device, the device ID or IP address may be recorded and used for purposes similar to those of cookies.
Our site uses Google Analytics, a web analytics service provided by Google, Inc. Google Analytics may collect information about your use of the site, including your IP address. Google uses cookies to provide information about visits to our site, including number of visitors, the websites from which visitors have navigated to our sites, and the pages on our sites to which visitors navigate. More information on Google Analytics can be found at the following link: www.google.com/policies/privacy/partners/
SHC also may contract with third party advertising networks that collect IP addresses and other information from pixel tags or web beacons on our site, in our emails, and on third party websites. These networks use cookies and other device and usage data in order to recognize individuals who have previously visited a particular website. This information is used to measure advertising effectiveness and provide advertisements about our products or services tailored to your interests.
Our site may use social media platform features, such as LinkedIn and the Facebook “like” button, the “Tweet” button and other sharing widgets. These features, which are either hosted by the respective social media network or hosted directly on our site, allow you to post information to your third-party social media profile page and share it with others in your network. When you click through social media features from particular websites (including our site), the social media network may receive information showing the websites you have visited. If you are logged in to your social media account, the social media network can link your visit to our site and other websites with your social media profile, and may deliver advertisements or promotions about our services tailored to your interests. Your interactions with social media features are governed by the privacy policies of the companies providing these features.
When you visit the site or interact with us in other ways, you can refuse to supply Personal Information. However, this may prevent you from engaging in certain site-related or other activities.
Use of Information
This section describes the purposes for which SHC uses the Personal Information we collect. Please note that there may be other uses, which we would describe to you when we collect the information.
To contract with you
We may use the information you provide us to help us fulfill a contract with, or provide services to, you or your organization, when you use our site under the applicable Terms of Use, and for other contractual purposes. We may also use this information to enforce our rights arising from such contracts.
Our internal business interests
We process your Personal Information to pursue our legitimate business interests, including to:
- understand you and your preferences to enhance your experience and enjoyment using our site;
- operate, maintain, and improve the content, design and navigation of our site;
- respond to comments and questions, provide requested services and information, and otherwise communicate with you;
- develop and deliver our services;
- comply with regulatory monitoring and reporting obligations;
- market our services to you, and/or send you information about our programs, offerings and company developments; and
- study website traffic patterns, detect and correct technical errors, and protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
To the extent permitted by applicable law, we may combine the various types of data we collect. We use this combined information to identify, update, expand, and analyze business opportunities and create tailored advertising. Such analysis may be conducted through third party services, using anonymous data and aggregate statistics generated by our information collection. We may use aggregate and/or de-identified data about visitors to our website for various business purposes, including development and improvement activities.
Consent
We may use your Personal Information when we have your consent to do so, where required or permitted under applicable law. If we are using your Personal Information on the basis of consent, you may withdraw your consent at any time (which will not affect the lawfulness of the processing before consent was withdrawn, or as otherwise agreed in writing) by contacting us at privacy@shccares.com.
For Legal, Safety or Security Reasons
We reserve the right to use your Personal Information (i) as required by law, court order, legal process or government or regulatory requirement; (ii) to respond to a request from public or government authorities; or (iii) to protect the safety, rights, or property of the public or SHC.
Sharing/Transferring Personal Information
In general, we may share and/or transfer your Personal Information to affiliates or service providers who assist us in the process of providing products or services to you, or otherwise perform functions on our behalf. Third party service providers may use Personal Information we provide to them only as instructed by SHC. We will not rent, sell or otherwise transfer your Personal Information to a third party for monetary consideration. We reserve the right to disclose Personal Information to third parties where we believe in good faith that disclosure is required to comply with our legal obligations under applicable laws, to cooperate with regulators or law enforcement authorities, to comply with a judicial proceeding or legal process, or to protect the safety, rights, or property of our customers, the public, or SHC. If we sell or transfer a business unit or asset to another company, we may share or transfer your Personal Information pursuant to the terms of the transaction. In addition, we may disclose information about you to a third party at your request, or if you consent to the disclosure. We may also disclose aggregate or de-identified data that is not personally identifiable to third parties for any purpose.
**All above exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Updates to Our Privacy Policy
SHC is continually improving and adding new functionality and features to our site. Because of these ongoing improvements, changes in the law and the changing nature of technology, our data practices will change from time to time. Accordingly, we reserve the right to update or modify this policy at any time and from time to time without prior notice. If and when our data practices change, SHC will post the revised policy on our site. Such changes to the Privacy Policy will become effective when posted. Your continued use of the site after any changes or revisions to this Privacy Policy will indicate your agreement with the terms of such revised Privacy Policy. We encourage you to check this page frequently to obtain the latest information on our privacy practices.
Children’s Privacy
We are committed to protecting the privacy of children and do not knowingly collect Personal Information from children under the age of 18. You should be aware that this website is not intended for, or designed to attract, children under the age of 18. No information should be submitted to SHC through this website by visitors who are less than 18 years of age.
Security
Please note that any information you send to SHC via email, in a sign-up form or via the Internet is not completely secure. We take reasonable steps to protect the Personal Information provided via our sites from loss, misuse and unauthorized access or disclosure, however, no Internet or e-mail transmission is ever fully secure or error free. Due to the nature of the Internet, there is a possibility that unsecured (unencrypted) email or Internet transmissions could be intercepted and read by third parties. SHC assumes no responsibility for interception of confidential information or Personal Information (including in a resume or CV or a sign-up form) that you send in an unsecured (unencrypted) email message or other Internet transmission to and from this website. Therefore, you should take special care in deciding what information you send to us via e-mail, in a sign-up form or via other Internet transmission. DO NOT SEND INFORMATION RELATING TO YOUR MEDICAL CONDITIONS OR THOSE OF ANOTHER PERSON, OR ANY OTHER SPECIFIC PERSONAL HEALTH INFORMATION, VIA OUR WEBSITE, AS SHC CANNOT BE RESPONSIBLE FOR PERSONAL HEALTH INFORMATION SENT THROUGH OUR WEBSITE. Please keep this in mind when disclosing any Personal Information to SHC via the Internet.
Data Retention and Access
We retain Personal Information or as long as needed or permitted in light of the purpose(s) for which it was obtained and as outlined in this Privacy Policy. The criteria used to determine our retention periods include: (i) the length of time we have an ongoing relationship with you; (ii) whether there is an applicable legal obligation; or (iii) whether retention is advisable to enforce our agreements, satisfy applicable statutes of limitations, resolve disputes, or manage litigation or regulatory investigations.
Links to Third Party Sites
This Privacy Policy applies only to websites owned or controlled by SHC. Our websites may contain links to other sites that are owned or controlled by third parties. Please be aware that we are not responsible for the privacy policies of such other sites or how these sites operate or treat your Personal Information. We encourage you to be aware of this when you leave our sites and to read the privacy policies and terms of use associated with each of these third party websites that collect personally identifiable information.
International Data Transfers and Processing
Any Personal Information you provide to SHC, and that SHC shares with affiliates, agents, vendors and service providers, may be stored and processed, transferred between and accessed from the United States and other countries, which may not guarantee the same level of protection of Personal Information as the country in which you reside. However, SHC will handle Personal Information in accordance with this Privacy Policy, and in compliance with applicable law.
Privacy Protection Policy for Social Security Numbers
The Company has established the following procedures to protect the confidentiality and security of Social Security numbers (SSNs) received by the Company. This policy applies to SSNs received for any employment-related purpose, including, but not limited to, pre-employment background screening; payroll, benefits, and human resources administration; and employment-related investigations. This policy complies with Connecticut ch. 743dd § 42-471.
Access to, and Use of, Information or Documents That Contain SSNs
Only authorized employees of the Company may access information and documents containing SSNs. Authorized employees may access information or documents containing SSNs only on a need-to-know basis and may use such information and documents only for the purpose for which access is permitted.
Disclosures of Information or Documents That Contain SSNs
The Company will disclose documents containing SSNs outside the Company only as permitted or required by law or court order. If the recipient of the document does not have a need to know the SSN, the SSN should be redacted before disclosure. If the recipient of the document does have a need to know the SSN, then the Company, whenever feasible, should obtain the recipient’s written agreement to provide adequate protections for the documents containing the SSN. SSNs may not be disclosed to a third-party without the prior approval of the Legal Department or of the Director of Human Resources.
Additional Safeguards for SSNs
SSNs and documents containing SSNs should receive the following additional protections:
- SSNs should not be publicly displayed, for example, by including them in electronic documents posted on internal web sites or in paper documents posted on employee bulletin boards;
- SSNs should not be printed on cards, such as insurance identification cards, that must be presented for an employee to obtain goods or services;
- SSNs generally should not be printed on paper documents that are mailed to an employee unless the document, by law, is required to include an SSN (such as a W-2 Form) or in certain other limited circumstances. Employees should consult with the Legal Department before including SSNs in a mailing;
- Employees authorized to access SSNs should take steps to prevent casual viewing of SSNs by unauthorized persons, such as activating a password-protected screen saver when leaving an assigned computer unattended;
- Employees authorized to access SSNs should not download SSNs or documents containing SSNs to any portable storage medium unless it is encrypted or remotely access files containing SSNs other than through an encrypted connection.
- SSNs should not be transmitted over the internet unless encrypted pursuant to the Company’s Information Security Policy.
Enforcement
Any employee who becomes aware of, or suspects, a violation of this policy should inform their SHC Representative immediately, so that the Company may conduct an investigation where appropriate. No employee may retaliate against an employee who reports a violation of this policy. Violation of this policy will result in disciplinary action up to and including termination of employment.
Supplemental Privacy Statement for Residents of California, USA:
This Supplemental Privacy Statement applies to residents of California, USA (“you” or “your”), and describes how we collect, use and share your Personal Information, and your rights with respect to your Personal Information. If you are a California job applicant or employee, please see our California Workforce Privacy Notice.
For purposes of this Statement, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018, as amended (“CCPA”) and similar personal data privacy laws in other US states as they may apply to SHC (“US Data Privacy Laws”), but does not include information exempted from the scope of such US Data Privacy Laws.
This Statement also does not apply to Personal Information relating to SHC employees, job applicants, and contractors, who will receive a separate privacy notice from SHC where required by law.
Personal Information collected from California residents
We collect information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked to a consumer or device (“Personal Information”).
The chart below summarizes how we collect, use and share Personal Information by reference to the categories specified in the CCPA, the sources from which we collect Personal Information, the business purposes for which Personal Information is collected and/or shared, and the categories of third parties with whom Personal Information is shared, describing our practices during the 12 months preceding the effective date of this Privacy Statement. We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice and/or obtaining your consent where required by law.
In the past 12 months, we shared or disclosed all of the categories of Personal Information listed below for the business purposes specified.
Category of Personal Information Collected | Sources of Personal Information | Business Purpose For Collecting/Sharing Personal Information | Shared/disclosed with third party categories (listed below)** |
---|---|---|---|
Identifiers (real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers) | · You or your agent · Affiliates | · Verify your identity, and create and maintain your account/profile · Provide customer service and communicate with you · Process and fulfill requests, transactions, shipments, & payments · Provide and improve our websites, and personalize your website experience · Advertise and market our products and services · Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity | 1, 2, 3 |
Personal Information categories (Cal. Civ. Code § 1798.80(e)) (name, signature, address, telephone number, insurance policy number, medical information, or health insurance information) | · You or your agent · Affiliates | Verify your identity, and create and maintain your account/profile · Provide customer service and communicate with you · Process and fulfill requests, transactions, shipments & payments · Provide and improve our website, and personalize your website experience · Advertise and market our products and services · Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity | 1, 2, 3 |
Protected classification characteristics under state or federal law (age (40 years or older), race, national origin, citizenship, religion, marital status, medical condition, disability, sex/gender, sexual orientation, veteran or military status, familial genetic information) | · You or your agent · Affiliates | · Verify your identity, and create and maintain your account/profile · Provide customer service and communicate with you · Process and fulfill requests, transactions, shipments & payments · Provide and improve our website, and personalize your website experience · Advertise and market our products and services · Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity | 1, 2, 3 |
Commercial Information (records of personal property, products or services purchased, considered, or other purchasing or consuming histories or tendencies) | You or your agent · Affiliates | · Verify your identity, and create and maintain your account/profile · Provide customer service and communicate with you · Process and fulfill requests, transactions, shipments & payments · Provide and improve our website, and personalize your website experience · Advertise and market our products and services · Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity | 1, 2, 3 |
Internet or other similar network activity (browsing history, search history, information on a consumer's interaction with a website, application, or advertisement) | Indirectly from your browser or device | · Verify your identity, and create and maintain your account/profile · Provide and improve our website, and personalize your website experience · Advertise and market our products and services · Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity | 1, 2 |
Geolocation data (physical location or movements) | Indirectly from your browser or device | · Verify your identity, and create and maintain your account/profile · Provide and improve our website, and personalize your website experience · Advertise and market our products and services · Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity | 1, 2 |
Sensory data (audio, electronic, visual, thermal, olfactory, or similar information) | You or your agent | · Verify your identity, and create and maintain your account/profile · Provide and improve our website, and personalize your website experience · Advertise and market our products and services · Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity | 1, 2 |
Professional or employment-related information (current or past job history or performance evaluations) | You or your agent | · Verify your identity · Provide customer service and communicate with you · Process and fulfill transactions and payments · Advertise and market our products and services · Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity | 1, 2, 3 |
Education information not covered by the Family Educational Rights and Privacy Act (current or past educational history) | N/A | N/A | N/A |
Inferences drawn from other Personal Information (profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes) | You or your agent | · Verify your identity, and create and maintain your account/profile · Provide and improve our website, and personalize your website experience · Advertise and market our products and services · Detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity | 1, 2 |
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