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Privacy Policy

This Privacy Policy describes how MyA Health, Inc. and Reclaim ("Reclaim") protects your personal information when you use this Reclaim app ("App"). Reclaim is located at 45 Prospect Street, Cambridge, MA 02139. All references to you include your Authorized Individuals, if any. Your use of the App is subject to this Privacy Policy as well as our Terms of Use.


Please review this Privacy Policy and the Terms of Use carefully. If you do not agree with our practices, do not access or use any part of the App.

A. Summary of Data Practices

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B. Definitions

  • Activity Logs: Activity logs are Reclaim's records of when Personal Data is created, accessed, modified, deleted, released, or exported from and/or within the App.

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  • Aggregate Data: Aggregate Data is Claims Data that is: (1) grouped so it does not connect to you as an individual and (2) has names and other identifiers removed or altered. In other words, Aggregate Data is de-identified data and cannot be used to identify you as an individual.

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  • Authorized Individuals: An Authorized Individual is someone you authorize to access your Claims Data on your behalf.

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  • Authorized Individual-Representative: An Authorized Individual-Representative is an individual who has authority to create and manage a Reclaim account on behalf of a Dependent and may include a parent, guardian, or other legal representative.

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  • Dependent: A Dependent is a minor child or other individual over whom an Authorized Individual has legal authority.

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  • Personal Data: When you sign up for Reclaim and link your Data or your HSA/FSA, you provide and/or you authorize Reclaim to provide you with your medical, pharmacy and HSA/FSA transactions. Personal Data might include, but is not limited to the following:

    • Your name and contact information, such as your address, phone number, or email address

    • Your medical history, conditions, treatments, and medications

    • Your healthcare claims, health plan account numbers, bills, and insurance information

    • Demographic information, such as your age, gender, ethnicity, and occupation

    • Computer information, such as your IP address

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  • ​Personal Information: Personal Information means information about you that reasonably can be linked to you such as your name, health information, and other identifiers. Personal Information may also include but is not limited to your financial information or social security number.

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  • Reporting: Reclaim might report about business activities and users (you) to others, such as investors, auditors, potential business partners, or public communities. Reports will not include Personal Information without your specific permission or as permitted or required by law.

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  • App Providers: An App Provider is an entity that is hired to perform certain functions for Reclaim to support the development, maintenance, and implementation of Reclaim.  App Providers may include software or website designers and data storage providers.

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  • Plan Sponsor: A Plan Sponsor is an entity that provides you health coverage, such as your employer or your insurer.

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  • Security Measures: Security measures can include computer safeguards, secured files, and employee security training. In addition, Reclaim may be required by law to notify you about particular data breaches.

C.  What Information Does Reclaim Collect?

  1. Before you register for the App, Reclaim may collect your information in two ways: (1) if you contact Reclaim through the Internet and provide Reclaim with your contact information (e.g., name, mailing address, email address and other information); (2) Reclaim may obtain your contact information from a healthcare Plan Sponsor with which Reclaim partners. In either case, Reclaim will use such information for the sole purpose of informing you about the App and inviting you to register for the App.

  2. To use the App, you must complete the registration process, which includes accepting the Terms of Use. As part of the registration process, you may be asked to provide certain information, such as your name, mailing address, and email address. Further, to register, you must agree to the Reclaim Terms of Use which incorporates this Privacy Policy. 

  3. In general, Reclaim collects all information that you supply directly to the App. Further, Reclaim may collect information from other third party information providers that you expressly authorize to send information to your Reclaim account (e.g., your HSA/FSA bank).

  4. Reclaim passively collects information from you as you navigate through the App. Reclaim may track IP addresses, use industry standard tracking devices (e.g., session and persistent cookies, flash cookies, web beacons), and electronically gather information about the technology you use to access the App and the areas of the App you utilize. Reclaim passively collects this information for operational purposes such as evaluating, updating and improving the App.

D.  How Does Reclaim Use Your Information?

  1. Reclaim uses your information to provide the App as described on the web site and Terms of Use, as well as to enhance the performance of the App and/or create new services. Reclaim will not use Personal Information for product development or product enhancement without your express, written permission.

  2. Reclaim will not sell or rent your Personal Information without your written consent. Reclaim will not use or disclose your Personal Information, except as described in this Privacy Policy, the Terms of Use, or as permitted or required by law.

E.  Sharing Your Information With Third Parties

  1. Reclaim may make your Personal Information available to third parties participating in the App that are authorized by you or as necessary to complete transactions you authorize.

  2. Reclaim may disclose your Personal Information to Reclaim' App Providers that provide technical support or other services to Reclaim related to the App. All such App Providers are subject to confidentiality obligations and may only access and utilize your data for purposes of fulfilling their obligations to Reclaim.

  3. Reclaim may provide or sell Aggregate Data that is de-identified to a third parties. However, Aggregate Data will not include any of your Personal Information or be individually identifiable.

  4. If a third party acquires the assets of Reclaim related to the App and its products and services (whether by sale, merger, change of control, bankruptcy or otherwise), your Personal Information may be transferred to the new owner(s). In such case, your Personal Information would remain subject to the provisions of the Reclaim privacy policy that was in effect immediately prior to the transfer unless Reclaim provides you notice otherwise.

F. Choices You Have About How Reclaim Uses Your Information

  1. Managing Your Account. Generally, you may change how your information is used and disclosed through the account setting and account management features. You may access your Reclaim account at any time to review your Personal Data. For technical questions related to the Reclaim product, please access the messaging support link on the Reclaim App.

  2. Authorized Individuals.  You may grant access to your Reclaim account to one or more Authorized Individuals.  You may grant an Authorized Individual access to your Reclaim account by specifically authorizing Reclaim to permit access by such Authorized Individual to your Reclaim account.  When you grant access to an Authorized Individual, you may permit the Authorized Individual to: (a) have the same level of access to your Reclaim account as you have; or (b) have limited access to your Reclaim account, i.e., the Authorized Individual will be authorized to access and read a subset of your Personal Data ONLY that you specify.  Whether or not to grant an Authorized Individual access to your Reclaim account is your decision. You acknowledge and agree that: (a) you are solely responsible for verifying the identity of, and monitoring the use by, any Authorized Individual you select; (b) Reclaim has no responsibility or liability in connection with any access to, or use of, your account and information by any Authorized Individual or Authorized Individual-Representative; and (c) by logging in as an Authorized Individual, you represent and warrant that you have received permission from a user.

  3. Terminating Your Account. You may terminate your Reclaim account at any time by notifying us at support@reclaim.health. In addition, except with respect to an Authorized Individual-Representative who establishes an account on behalf of a Dependent, Reclaim will terminate your account within thirty (30) days of its receipt of a death certificate certifying your death.  With respect to an Authorized Individual-Representative, Reclaim will terminate all accounts associated with such Authorized Individual-Representative within thirty (30) days of its receipt of a death certificate certifying the death of such Authorized Individual-Representative unless a Dependent also has a living Authorized Individual-Representative associated with the account.  Otherwise, Reclaim will maintain and/or destroy all Personal Data and Personal Information associated with your account in accordance with its then current document retention and destruction policies.

G.  Data from Children Under the Age of 18

The App is not intended for use by children younger than 18 years old. Reclaim will not knowingly collect information from site visitors younger than 18 years. However, parents or guardians may elect to establish a Reclaim account for their children through the App as Authorized Individuals-Representative and, in doing so, expressly consent to Reclaim utilizing such information as set forth in this Privacy Policy and the Terms of Use.

 

An Authorized Individual-Representative may authorize and/or have access to a Reclaim records for a Dependent.  A Dependent's Reclaim records will be linked to an Authorized Individual-Representative's Reclaim account until the earlier of the date:  (i) the Dependent reaches the age of 12; (ii) the Authorized Individual-Representative is no longer the legal representative of the Dependent; or, (iii) Reclaim is notified by the Dependent or a court of law or agency with appropriate authority that the Dependent has been emancipated, attained legal custody of his or her own health information, or that a different Authorized Individual-Representative has been named. Each Authorized Individual-Representative agrees that a Dependent's Reclaim account also may be linked to the Reclaim account of another Authorized Individual-Representative, and each Authorized Individual-Representative will have the same rights to access and communicate through the Dependent's Reclaim account. 

H.  How Reclaim Protects Your Information

Reclaim uses both technical and procedural Security Measures to maintain the integrity and security of the Reclaim databases, including the use of firewalls. Reclaim encrypts all Personal Data during transmission. Within Reclaim, all Personal Information is encrypted at three levels: each individual has a unique encryption key; demographic information is encrypted; and healthcare data is separately encrypted.

 

The safety and security of your Personal Information also depends on you. Never share your password with anyone else. Notify Reclaim promptly if you believe your password has been breached. 

I.  Security Breach Notification Requirements

Pursuant to applicable law, Reclaim may be required to send you notice of security breaches or suspected security breaches that impact your Personal Information. In the unlikely event that Reclaim must provide you a notice of a security breach, Reclaim will send you security breach notices to the e-mail address or telephone number contained in your account information unless we are otherwise required by law. Please note: many e-mail systems have built in SPAM filters. If you have one in place, you should check with your system administrator or the available instructions to confirm that e-mails from Reclaim are not blocked by the filter (e.g., by confirming that the App domain name (reclaim.health) is a permitted domain name.

J.  Changes to this Privacy Policy

Reclaim reserves the right to change the Privacy Policy in its sole discretion. In such case, Reclaim will post the new Privacy Policy on the web site and the effective date of the new Privacy Policy will be clearly marked. If Reclaim updates this Privacy Policy, your continued use of the App (following the posting of the revised Privacy Policy) means that you accept and agree to the terms of the revised Privacy Policy. Remember, by using any part of the App, you accept and agree to our Privacy Policy and privacy practices.

K.  More information

If you have additional questions, please contact Reclaim any time. Or write to the company at:

MyA Health, Inc.

ATTN: Reclaim Privacy Matters

45 Prospect Street

Cambridge, MA 02139 (USA)

privacy@reclaim.health

Date last modified: April 10, 2020

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