Last Revised: July 28, 2017
188 King St., #502,
San Francisco, CA 94107
3. A Note About Children. We do not intentionally gather Personal Data from visitors who are under the age of 13. If a child under 13 submits Personal Data to Lively and we learn that the Personal Data is the information of a child under 13, we will attempt to delete the information as soon as possible. If you believe that we might have any Personal Data from a child under 13, please contact us at firstname.lastname@example.org.
(a) Information You Provide to Us.
- We may collect the following data, which may include Personal Data, from you when you create an account to log in to our network (“Account”):
- Physical Address
- Mailing Address
- Social Security Number
- Employer Identification Number (EIN)
- Date of Birth
- Email Address
- Phone Number
- Health plan information
- Beneficiary Information
- Dependent information
- Receipts for medical expenses, which may contain PHI
- Existing Health Savings Account information (for rollover purposes)
- HSA-related investment account information
- Personal bank account information
- If you use our Services on your mobile device, including through our Application, we may collect your phone number and the unique device id number.
- If you tell us where you are (e.g., by allowing your mobile device to send us your location), we may store and use that information to provide you with location-based information and advertising. If you want to deactivate this feature, you can deactivate GPS on your mobile device.
- Our Site may let you store preferences like how your content is displayed, your location, safe search settings, and favorite widgets. We may associate these choices with your ID, browser or the mobile device, and you can edit these preferences at any time.
- When connecting to our Services via a service provider that uniquely identifies your mobile device, we may receive this identification and use it to offer extended services and/or functionality.
- Certain Services, such as two-factor authentication, may require our collection of your phone number. We may associate that phone number to your mobile device identification information.
- We retain information on your behalf, such as files and messages that you store using your Account.
- If you provide us with feedback or contact us via e-mail, we will collect your name and e-mail address, as well as any other content included in the e-mail, in order to send you a reply.
- When you post messages on the message boards of our Site, the information contained in your posting will be stored on our servers and other users will be able to see it.
- When you participate in one of our surveys, we may collect additional profile information.
- We also collect other types of Personal Data that you provide to us voluntarily, such as your operating system and version, product registration number, and other requested information if you contact us via e-mail regarding support for the Services.
- We may also collect Personal Data at other points in our Site that state that Personal Data is being collected.
(b) Information Collected via Technology.
- Information Collected by Our Servers. To make our Site and Services more useful to you, our servers (which may be hosted by a third party service provider) collect information from you, including your browser type, operating system, Internet Protocol (“IP”) address (a number that is automatically assigned to your computer when you use the Internet, which may vary from session to session), domain name, and/or a date/time stamp for your visit.
- Pixel Tag In addition, we use “Pixel Tags” (also referred to as clear Gifs, Web beacons, or Web bugs). Pixel Tags are tiny graphic images with a unique identifier, similar in function to Cookies, that are used to track online movements of Web users. In contrast to Cookies, which are stored on a user’s computer hard drive, Pixel Tags are embedded invisibly in Web pages. Pixel Tags also allow us to send e-mail messages in a format users can read, and they tell us whether e-mails have been opened to ensure that we are sending only messages that are of interest to our users. We may use this information to reduce or eliminate messages sent to a user. We do not tie the information gathered by Pixel Tags to our users’ Personal Data.
- How We Respond to Do Not Track Signals. We do not currently respond to “do not track” signals or other mechanisms that might enable Users to opt out of tracking on our Site.
- Mobile Services. We may also collect non-Personal Data from your mobile device. This information is generally used to help us deliver the most relevant information to you. Examples of information that may be collected and used include your geographic location, how you use the Site and Services, and information about the type of device you use. This information is sent to us as aggregated information and is not traceable to any individual and cannot be used to identify an individual.
(c) Information Collected from Third Party Companies. We may receive Personal and/or Anonymous Data about you from companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our Site. These third party companies may supply us with Personal Data. We may add this information to the information we have already collected from you via our Site in order to improve the Services we provide.
(d) Information Collected from Employers, Payroll Companies or Health Plans. If your Account was established by your employer or your health plan, they may have requested that we set up a communication channel whereby you can log into Lively’s portal (known as single sign on) or access your Account information through their site without entering your user name and password again. Your employer or health plan also may have contracted with another vendor that provides additional services, such as personal health care costs management, that allows you to log into Lively’s portal or access your Account through that vendor’s website, also without entering your Lively username and password. When you use those websites to sign into Lively’s portal or access your Account, you are authorizing Lively’s system to pass on certain information, such as your account balances, to those systems.
(e) Location When you use our Site and Services, we may collect and process location information. If you do not want this information collected by us, you can disable location services on your phone.
6. Use of Your Personal Data
- General Use. We use and retain your Personal Data in order to provide products and services and may, from time to time, provide such information to nonaffiliated third party service providers to perform services for or functions on behalf of us, to effect, administer, or enforce transactions authorized by you; for example,
(a) To verify your identity, open and administer your Accounts and provide other financial services under the USA PATRIOT Act;
(b) To open and administer your Accounts and provide other financial services;
(c) To make payments to medical service providers;
(d) To provide you any health insurance information, if applicable;
(e) To help us protect you and us from financial loss;
(f) To prepare account statements; and
(g) To prepare annual tax reporting information, if applicable.
- In addition, we will collect and store the following:
(a) Names and other identifying information of the dependents that are covered by your Account;
(b) Names and other identifying information of people authorized by you to use your Account
(c) Names and other identifying information of people authorized by you to access your Account; and
(d) Transactions with us such as your Account balance, fees, payments, withdrawals, deposits/contributions and the identity of persons to whom you make payments, including health care providers.
(a) User Testimonials and Feedback. We often receive testimonials and comments from users who have had positive experiences with our Services. We occasionally publish such content. When we publish this content, we may identify our users by their first and last name and may also indicate their home city. We obtain the user’s consent prior to posting his or her name along with the testimonial. We may post user feedback on the Site from time to time. We will share your feedback with your first name and last initial only. If we choose to post your first and last name along with your feedback, we will obtain your consent prior to posting you name with your feedback. If you make any comments on a blog or forum associated with your Site, you should be aware that any Personal Data you submit there can be read, collected, or used by other users of these forums, and could be used to send you unsolicited messages. We are not responsible for the personally identifiable information you choose to submit in these blogs and forums.
(b) Creation of Anonymous Data. We may create Anonymous Data records from Personal Data by excluding information (such as your name) that makes the data personally identifiable to you. We use this Anonymous Data to analyze request and usage patterns so that we may enhance the content of our Services and improve Site navigation. We reserve the right to use Anonymous Data and aggregated and other de-identified information for any purpose and disclose Anonymous Data to third parties in our sole discretion.
(a) Third Parties Designated by You. When you use the Services, the Personal Data you provide will be shared with third parties that you or your employer designate to receive such information. Depending on the type of access you or your employer grant to such third parties, they may also be permitted to edit the information you have provided to us and to designate others to access and edit such information. You may change your settings at any time as to who has access to your information by contacting us at email@example.com. We will use commercially reasonable efforts to honor your requests.
(b) Employers. We will share your Personal Data with your employer solely for the purpose of providing the Services.
(c) Third Party Service Providers. We may share your Personal Data with third party service providers, including reputable reference sources or reporting agencies, to: provide you with the Services that we offer you through our Site; to conduct quality assurance testing; to facilitate creation of accounts; to provide technical support; for risk management and to maximize the accuracy of your information; and/or to provide other services to Lively. These third party service providers are required not to use your Personal Data other than to provide the services requested by Lively.
(f) Disclosure to Third Party Companies. We may enter into agreements with companies that provide our Services by way of a co-branded or private-labeled website or companies that offer their products and/or services on our website (“Third Party Companies”). A Third Party Company may want access to Personal Data that we collect from its customers. As a result, we may disclose your Personal Data to a Third Party Lively; however, we will not disclose your Personal Data to any Third Party Lively for the Third Party Lively’s own direct marketing purposes. The privacy policies of these Third Party Companies may apply to the use and disclosure of your Personal Data that we collect and disclose to such Third Party Companies. Because we do not control the privacy practices of Third Party Companies, you should read and understand their privacy policies.
10. Your Choices Regarding Information. You have several choices regarding the use of information on our Service:
(b) Cookies. If you decide at any time that you no longer wish to accept Cookies from our Service for any of the purposes described above, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the websites you visit. Consult your browser’s technical information. If you do not accept Cookies, however, you may not be able to use all portions of the Service or all functionality of the Service. If you have any questions about how to disable or modify Cookies, please let us know at the contact information provided below.
(c) Changing or Deleting Your Personal Data. Users may make changes to their Personal Data through their Accounts. For Personal Data that cannot be changed via your Account, you may contact us at firstname.lastname@example.org to request the change. We will use commercially reasonable efforts to honor your requests. We will never delete your Personal Data unless you contact us and ask us to do so. If you completely delete all of your Personal Data, then your Account may become deactivated. We may retain an archived copy of your records as required by law or for legitimate business purposes.
(d) Security of Personal Data and Bank Account Information. We have developed policies and procedures to keep your Personal Data confidential and secure. We restrict access to those employees and other persons who must use that information to provide services on our behalf. We maintain physical, electronic and procedural safeguards, in compliance with applicable laws, regulations and industry standards, to protect the confidentiality of the Personal Data we obtain.
We require our service providers to maintain the same level of confidentiality and security that we do. We continually update and improve our security standards and procedures to help protect against anyone gaining unauthorized access to your Personal Data and to prevent fraud.