Effective Date: 18th November 2021
- Use of Information
- Disclosure of Information
- Security Practices
- Managing and Updating Information: Your Rights
We will not sell your information to third parties, including data brokers or marketers, without obtaining a separate consent from you to do so. Unless you provide consent, we do not allow third parties to advertise to Users on the Website.
Information We Collect from Third Parties
Information that is Automatically Collected
We may use automated means to collect information about you, your computer or other device that you used to access the Website, and your use of the Website. These automated means include common technologies such as cookies or similar technologies. These technologies help us to administer the Services, track Users’ interactions with the Services, gather demographic information about our user base as a whole, and otherwise provide you with relevant content. We may collect information from and about the devices you use to access the Services. This could include information such as Internet Protocol (“IP”) addresses, the type of browser and device you use, the region and language settings on your device, and identifiers associated with your devices. Where you have given consent, your devices, depending on their settings, may also transmit location information to us, to enable you to receive more relevant information from third party service providers and vendors acting on our behalf where you have agreed to receive such information.
We may also automatically collect, review and store information about your interactions with the Services, such as page response times, page interaction information (such as scrolling, clicks, and mouse-overs), technical data (including crash reports), and the web page you visited before coming to our website or go to after our website.
Cookies and Tokens
Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Website may use session cookies to better understand how you interact with our services, to monitor aggregate usage by Users and to improve our services. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our Website.
Cookies, tokens and similar technologies (collectively, "Tracking Technologies") may be used for administering the Website, including without limitation, for authentication, to remember Users’ settings, to customize the content and layout of the Website for Users, to contact you about the Website, and to improve our internal operations, the content of our Website and our services. Users may be able to control the use of, or reject or disable, some Tracking Technologies at the individual browser level. If you reject or disable Tracking Technologies, you may still use our Website, but your ability to use some features or areas of the Website may be limited. We may use Tracking Technologies to identify your device and keep track of your Internet session with our Website. Using these Tracking Technologies, we may automatically end your session on our Website after a period of inactivity (as determined by us in our sole discretion). We may also use Tracking Technologies that allow us to recognize your device when you return to the Website within a certain period of time (as determined by us in our sole discretion) and automatically log you back into your account with us. UNLESS YOU AFFIRMATIVELY LOG OUT of your account PRIOR TO YOUR SESSION ENDING (whether by you or by us), YOU MAY BE AUTOMATICALLY LOGGED BACK IN THE NEXT TIME YOU OR ANY USER OF YOUR DEVICE VISITS OUR SITE within the period of time determined by us. If you do not wish to be automatically logged back in when you (or someone using your device) next initiate a session with our Website (using the same device that is being used for your current session), you should log out of your account (i) prior to ending your session, or (ii) if you will be inactive on our Website for more than a few minutes.
In conjunction with the gathering of data through cookies and in order to determine errors, Web servers may log records such as your device type, operating system type, device advertising identifier, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The Web server logs also may record the address of the Web page that referred you to our Website, the IP address (and associated city and state or province for the IP address) of the device you use to connect to the Internet, and data about your interaction with our Website, such as which pages you visit.
We may use third-party web analytics services on our Website, such as those of Google Analytics. Service providers use the sort of technology described in this “Information that is Automatically Collected” section to help us analyze how Users use the Website, including by noting the third-party Web site from which Users arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Website. To prevent Google Analytics from using your information for analytics, you may visit the Google Analytics opt out page.
Additional Technologies on Optum.com.ie and Other Websites
Use of Information
Use and Storage of Information to Provide You with the Website and Related Services
Optum, and any third party vendors acting on Optum’s behalf, may use and store your information to perform activities associated with providing you with the Website and Services such as: (i) resolving disputes and/or troubleshooting problems; (ii) verifying your compliance with your obligations in our Terms of Service or other Optum policies; (iii) improving the quality of the Website, (iv) fulfilling any request you make; (v) communicating with you; (vi) connecting you with and providing you with information about services, providers of services, rewards, resources or programs to which you may have access; (vii) providing you with Website content, including, without limitation, generating recommendations (such as recommended Website activities), and processing your preferences and requests; (ix) analyzing, customizing, and personalizing the Website, including through the delivery of tailored content and communications; (x) otherwise as directed by you or provided for herein. Except where prohibited by law, and only to the extent permitted by Optum’s agreements with applicable Optum Partners, we may also use your information in connection with any other services we make available to you.
Optum’s legal basis to process your information includes processing that is necessary for Optum’s legitimate interests, including those described above, to carry out the functions necessary to provide you with the Website and the Services. It is also based on your consent, which may subsequently be withdrawn at any time by contacting us at email@example.com without affecting the lawfulness of processing based on consent before its withdrawal.
Additional Information Regarding Use of Information for Communications
Optum, Optum Partners, and any third-party vendors acting on Optum's behalf, may also use your information to communicate with you (including, without limitation, via email and/or mobile push notifications) about the Website and/or our products and Services (and related features and functionality) or those of any Optum Partner that is providing services to you. Our communications to you will include, without limitation, contacting you at the email address(es) that you use to register for our Website to communicate with you regarding the Website and actions that you take in connection with the Website and/or the Services.
Your Choices Regarding Our Communications with You
Creation and Use of Combined Data, De-Identified Data, and Aggregated Data
As permitted by law and by Optum’s agreements with applicable Optum Partners, Optum, and any third party vendors acting on Optum’s behalf, may aggregate and/or de-identify your information (meaning you are no longer identifiable from it), and/or with your consent combine your information with other information maintained or available to Optum, and use or disclose such information as follows:
- We may disclose de-identified data, in anonymized form, for academic and statistical purposes.
- We may use aggregated or combined data to communicate with you about the Website and/or our products and services and disclose such aggregated or combined data to Optum Partners in connection with providing the Website.
We may also use and disclose de-identified data, de-identified aggregated data, and/or de-identified combined data for any business purpose, which may include, without limitation, improving our products and services, conducting analytics such as evaluating our Website and developing additional benefits, programs, and services, and disclosing to Optum Partners for analytics purposes.
Retention of Data
Your information will be retained only for so long as reasonably necessary for the purposes set out above, in accordance with applicable laws. This is subject to our retention of information where necessary (a) in connection with any legal proceedings (including prospective legal proceedings), obtaining legal advice or otherwise establishing exercising or defending legal rights; and (b) for medical purposes undertaken by a health professional or any person who in the circumstances is subject to an equivalent duty of confidentiality.
Disclosure of Information
We may share your information in the following circumstances:
Disclosures to Service Providers and Optum Partners
Optum, and third party vendors acting on our behalf, may disclose your information to Optum Partners, third party service providers, or vendors acting on our behalf for the purpose of providing the Website and related services to you or other Users, including, without limitation, registering you to use the Website (e.g., authenticating your identity), logging you into the Website, providing you with information you have requested through the Website or related services, providing customer service, and connecting you with resources and other services. Third party service providers or vendors acting on our behalf are authorized to use your information only in connection with providing these services to us or as required by law.
Additional Disclosures with Your Consent
Safety, Security and Compliance with Law
Subsidiaries and Affiliated Companies
Sale, Merger or Similar Transaction
Uses and Disclosures as Required or Permitted by Law, Including Research, Health Care Operations, and Public Health
To the extent not prohibited by law or precluded by Optum’s agreements with the applicable Optum Partner, Optum, and any third party vendors acting on Optum’s behalf, may use and disclose your information: (a) as required or permitted by law; (b) for Research purposes; (c) for purposes of Health Care Operations of the applicable Optum Partner; and (d) for Public Health, as each is defined and in accordance with HIPAA, or other applicable laws including the General Data Protection Regulation (GDPR).
We Do Not Control the Privacy Policies of Third Parties
The security of your information is important to us. We follow security standards to protect the information submitted to us, both during transmission and once we receive it. These safeguards vary based on the sensitivity of the information that we collect, process and store and the current state of technology. For example, we restrict access to information to those Optum employees or third-party vendors who needs access to such information in order to provide the Services. We maintain appropriate physical, electronic and procedural safeguards to protect your information, including firewalls, individual passwords and encryption and authentication technology, and take all other necessary and adequate administrative, organizational, technical, personnel and physical measures to safeguard the same against unauthorized or unlawful processing and use, accidental loss or destruction or damage, theft, disclosure or modification and to ensure its integrity. Please note that Optum uses encryption software that may be subject to export control regulations.
No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. When disclosing any information via an open network, such as the Internet or email, you should consider that it is potentially accessible to others. If you have any questions about security on our Website, you can contact us at firstname.lastname@example.org.
Be Sure to Log Off When Using Public or Third-Party Computers
As described above, we use Tracking Technologies that automatically log you back into your account with us unless you affirmatively log out of your account prior to your session ending (whether you end your session or we end your session, for example if our Website has "timed out" – i.e. we have ended your session automatically after a period of inactivity as determined by us in our sole discretion). If you log into the Website using a public computer or device, or a computer or device of that belongs to or is shared with another person, you should affirmatively log out of your account. Otherwise, the next user of that computer or device may be able to access your account and your information in your account if your session has not ended.
Transfer of Information
Managing and Updating Information: Your Rights
Users are entitled, in accordance with applicable law, to object to or request restriction of processing of their personal data, and to request access to, rectification, erasure and portability of their own information. Requests should be submitted by contacting us at email@example.com. We will respond to your request within a reasonable timeframe under the circumstances of your request, and in any case in accordance with legal requirements.
As well as using the contact details above, you may update and/or delete certain information by logging into the Website and updating your account. Please remember, however, if we have already disclosed some of this information to third parties, we cannot access that information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. Certain information may be necessary in order for us to provide the Website and the Services; therefore, if you delete such necessary information you will not be able to use the Website or receive the Services.
The Website is not directed to children under the age of 13 and children under the age of 16 years of age are not eligible to use our Website. Protecting the privacy of children is very important to us. We do not collect information from people we actually know are under 16 years of age, and no part of our Website is designed to attract people under 16 years of age. If we later learn that an individual has provided us with their information and they are under 16 years of age, we will take steps to remove that User's information from our databases and to prevent the User from utilizing the Website.
To contact the Company:
Optum Health Solutions (UK) Limited
5 Merchant Square
London W2 1AS
Attention: Deanna DiCarlantonio,
Data Protection Officer
To contact the Company’s EU Representative:
Optum Services (Ireland) Limited
Block C, One Spencer Dock, Dublin 1, Dublin, Ireland
Attention: Deanna DiCarlantonio,
Data Protection Officer