NOTICE OF PRIVACY POLICIES

EFFECTIVE DATE: OCTOBER 6, 2014

UPDATED ON: JUNE 23, 2015

PLEASE READ THIS NOTICE CAREFULLY: IT DESCRIBES HOW YOUR PERSONAL OR MEDICAL INFORMATION WILL BE PROTECTED AND USED BY ACCOLADE.

YOUR PRIVACY IS VERY IMPORTANT TO ACCOLADE. WE ARE COMMITTED TO MAINTAINING THE CONFIDENTIALITY AND PRIVACY OF ALL PERSONALLY IDENTIFIABLE INFORMATION AND HEALTH INFORMATION THAT WE RECEIVE, COLLECT, MAINTAIN AND USE, FROM ANY SOURCE AND IN ANY FORMAT, ABOUT YOU AND YOUR FAMILY. WE ARE REQUIRED BY LAW TO MAINTAIN THE PRIVACY AND SECURITY OF YOUR PERSONAL AND HEALTH INFORMATION AND TO ABIDE BY THE TERMS OF THIS NOTICE.

REMEMBER, ACCOLADE IS HERE TO SIMPLIFY HEALTHCARE AND YOUR HEALTH BENEFITS FOR YOU AND YOUR FAMILY. WE ARE HERE TO HELP YOU UNDERSTAND YOUR HEALTHCARE OPTIONS, TO FACILITATE YOUR USE OF THE HEALTHCARE SYSTEM AND TO SUPPORT YOU AS YOU MAKE YOUR HEALTHCARE DECISIONS. THE CONTENT WE PROVIDE YOU IS FOR INFORMATIONAL PURPOSES ONLY. ACCOLADE DOES NOT PROVIDE MEDICAL ADVICE, PROVIDE NURSING CARE, DIAGNOSE OR DELIVER TREATMENT. THOSE ARE ACTIVITIES FOR YOU TO UNDERTAKE WITH YOUR DOCTOR OR OTHER APPROPRIATELY TRAINED AND QUALIFIED HEALTH PROFESSIONAL.

WE DISCLOSE YOUR PERSONAL IDENTIFIABLE INFORMATION OR HEALTH INFORMATION ONLY TO YOU, TO SOMEONE YOU HAVE AUTHORIZED ACCOLADE TO SPEAK WITH ON YOUR BEHALF, OR TO PERSONS WHO ARE ENTITLED OR AUTHORIZED TO RECEIVE THIS INFORMATION UNDER STATE OR FEDERAL LAW, INCLUDING “HIPAA.” FOR EXAMPLE, WE CAN SHARE YOUR PERSONAL INFORMATION WITH PROFESSIONALS WHO ARE TREATING YOU OR FOR BILLING OR CLAIMS PURPOSES. WE MAY ALSO USE YOUR INFORMATION FOR ACCOLADE INTERNAL PURPOSES, SUCH AS FOR QUALITY CONTROL, COMPLIANCE REVIEW OR FOR TRAINING. WHENEVER WE DO DISCLOSE YOUR PERSONAL OR MEDICAL INFORMATION TO OTHERS, WE ONLY SHARE THE MINIMUM NECESSARY AMOUNT OF INFORMATION. OTHERWISE, WE WILL ONLY SHARE PERSONALLY IDENTIFIABLE INFORMATION OR HEALTH INFORMATION WITH YOUR PERMISSION.

FROM TIME TO TIME, ACCOLADE MAY CREATE AND DISTRIBUTE DE-IDENTIFIED HEALTH INFORMATION BY REMOVING ALL REFERENCES TO PERSONALLY IDENTIFIABLE INFORMATION. ANY DISTRIBUTION OF SUCH DE-IDENTIFIED INFORMATION IS ANONYMOUS.

FOR MORE INFORMATION ABOUT YOUR PRIVACY AND SECURITY RIGHTS UNDER HIPAA, PLEASE CONSULT:
www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html

WHEN IT COMES TO YOUR HEALTH INFORMATION, YOU HAVE CERTAIN RIGHTS:

YOU CAN ASK TO SEE OR GET AN ELECTRONIC OR PAPER COPY OF YOUR MEDICAL RECORD AND CERTAIN OTHER HEALTH INFORMATION WE HAVE ABOUT YOU. ASK US HOW TO DO THIS; WE WILL CHARGE A REASONABLE, COST-BASED FEE FOR THE COMPILATION.
YOU CAN ASK US TO LIMIT WHAT WE USE OR SHARE. (WE ARE NOT REQUIRED TO AGREE TO YOUR REQUEST UNDER CERTAIN CIRCUMSTANCES, WHICH WE WILL EXPLAIN IF ASKED).
YOU CAN ASK US TO CONTACT YOU IN A SPECIFIC WAY (FOR EXAMPLE, HOME OR OFFICE PHONE) OR IN A SPECIFIC LOCATION. AT PRESENT, ACCOLADE CONTACTS YOU BY TELEPHONE, TEXT MESSAGE OR THROUGH SECURE MESSAGING (USING EMAIL OR TEXT NOTICE, BASED ON HOW YOU SET YOUR PREFERENCES).
YOU CAN GET A LIST OF THOSE WITH WHOM WE’VE SHARED INFORMATION (FOR THE SIX YEARS PRIOR TO YOUR REQUEST); WE WILL CHARGE A REASONABLE, COST-BASED FEE FOR THE COMPILATION.
YOU CAN CHOOSE SOMEONE TO ACT FOR YOU AS YOUR PERSONAL REPRESENTATIVE.
YOU CAN FILE A COMPLAINT IF YOU FEEL YOUR RIGHTS ARE VIOLATED. YOU CAN CONTACT ACCOLADE’S PRIVACY OFFICER AT THE ADDRESS BELOW, OR FILE A COMPLAINT WITH THE US DEPARTMENT OF HEALTH AND HUMAN SERVICES, OFFICE FOR CIVIL RIGHTS, BY SENDING A LETTER TO 200 INDEPENDENCE AVENUE, S.W., WASHINGTON, D.C. 20201, CALLING 1-877-696-6775 OR VISITING www.hhs.gov/ocr/privacy/hipaa/complaints. WE WILL NOT RETALIATE AGAINST YOU FOR FILING A COMPLAINT.
YOU CAN GET A PAPER COPY OF THIS NOTICE ON REQUEST.
YOU HAVE THE RIGHT TO CORRECT ANY PERSONAL OR MEDICAL INFORMATION ABOUT YOU MAINTAINED OR COLLECTED BY ACCOLADE; JUST ASK US HOW TO DO THIS.

ACCOLADE HAS IMPLEMENTED REASONABLE AND APPROPRIATE PHYSICAL, TECHNICAL AND ADMINISTRATIVE MEASURES TO PROTECT YOUR PERSONALLY IDENTIFIABLE INFORMATION AND YOUR HEALTH INFORMATION STORED BY ACCOLADE.

ACCOLADE’S SECURE WEBSITE (“MYACCOLADE”) MAY USE “COOKIES” (WHICH ARE SMALL PIECES OF INFORMATION THAT SOME SITES STORE ON YOUR COMPUTER’S HARD DRIVE WHEN YOU VISIT THEM) OR “IP ADDRESSES” (WHICH IS A NUMBER THAT IS AUTOMATICALLY ASSIGNED TO YOUR COMPUTER WHEN YOU ACCESS THE INTERNET). WE MAY USE THESE TO UNDERSTAND THE SOURCES OF OUR SITE TRAFFIC, TO DETERMINE FOR WHAT PURPOSES PEOPLE ARE USING THE SITE, AND TO GENERATE CONTENT ON OUR SITE PAGES. ACCOLADE DOES NOT USE ANY INFORMATION WE GATHER TO TRACK YOUR ACTIVITY OUTSIDE OUR SITE.

YOUR USE OF MYACCOLADE IS VOLUNTARY. YOU UNDERSTAND THAT BY USING MYACCOLADE, YOU ARE AGREEING TO THE TERMS OF USE AND TO ACCOLADE’S PRIVACY POLICIES.

ACCOLADE MAY CHANGE OR UPDATE THIS NOTICE OF PRIVACY POLICIES IN RESPONSE TO FEEDBACK, OR TO REFLECT CHANGES WE MAKE IN HOW WE PROTECT YOUR PRIVATE INFORMATION, AND THE CHANGES WILL APPLY TO ALL INFORMATION WE HAVE ABOUT YOU. THE NEW NOTICE OF PRIVACY POLICIES WILL BE AVAILABLE ON REQUEST AND ON MYACCOLADE.

IF YOU HAVE ANY QUESTIONS OR COMMENTS REGARDING THIS NOTICE, OR IF YOU BELIEVE ACCOLADE HAS NOT COMPLIED WITH THIS NOTICE, PLEASE CONTACT:

ONLINE
Privacy@Accolade.com

MAIL
RICHARD ESKEW,
VP, PRIVACY OFFICER
ACCOLADE, INC.
660 WEST GERMANTOWN PIKE, SUITE 500
PLYMOUTH MEETING, PA. 19462