Privacy Notice - Website
(Updated: August 23, 2024; Effective: September 1, 2024)
If you live in California, please visit our California Privacy Statement, which supplements this Privacy Policy.
If you live in Colorado, Washington, Oregon, or any other state with applicable data privacy laws, please visit our Consumer Health Data Privacy Policy, which supplements this Privacy Policy.
1. Introduction
2. What information does Accolade collect through the site?
3. How do we use your information?
4. Who has access to your information?
5. How do we protect your information?
6. How long do we keep your information?
7. Does the site use cookies?
8. What are the privacy policies of third-party websites to which the site links?
9. Where does data storage and processing occur?
10. State data privacy laws exemptions
11. Additional terms for EU visitors
12. Does the site use other third-party tools, such as Google AdSense?
13. Session replay technology
14. Electronic mail from Accolade
15. Do not track
16. Not intended for children under 13
17. Changes to this privacy notice
18. Contacting us
1. Introduction
Your privacy is very important to Accolade, Inc., and its affiliates, including Accolade 2ndMD LLC (“Accolade Expert MD” or 2nd.MD”) (collectively, “Accolade”). This “Privacy Notice” has been compiled to assist you in understanding the ways in which we, Accolade, collect personal information from you as you use the www.accolade.com or www.2nd.MD websites (the “Site(s)”). Please read this Privacy Notice carefully to get a clear understanding of how we collect, use, protect or otherwise handle your personally identifiable information. Please note that the Accolade.com and 2nd.MD Digital Tools have a separate privacy notice, which can be found here: Privacy Notice – Digital Tools. Once you have activated and logged into your account, the terms of the Privacy Notice – Digital Tools will control. This Privacy Notice – Website is intended to be read in conjunction with the Terms of Use for the Site. By using the Site, you are agreeing to the Terms of Use and this Privacy Notice – Website. If you are a member of Accolade services, including Accolade Expert MD or 2nd.MD, please remember that 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, is based on the best available information, and may not be relied upon when alternative and more relevant information (such as, for example, information provided directly by your healthcare provider) would be more relevant or accurate. No material contained within or provided through the Accolade and 2nd.MD Sites should be construed as medical advice and/or treatment. Accolade shall have no responsibility or liability for out-of-pocket costs you may incur for actual care provided or medical procedures performed by your healthcare provider(s), and you are responsible for understanding and evaluating such costs, including any costs known as “surprise billing” or costs incurred as a result of balanced billing, notwithstanding information provided by Accolade based on best available information. Accolade does not provide medical advice, provide nursing care, diagnose, or deliver treatment and no physician- or nurse-to patient-relationship is created as a result of your use of the Accolade and 2nd.MD Sites. Those are activities for you to undertake with your doctor or other appropriately trained and qualified health professional. IF YOU THINK YOU HAVE A MEDICAL EMERGENCY, YOU SHOULD CALL YOUR DOCTOR OR 911 IMMEDIATELY. Accolade may provide, from time to time, various digital services to its customers and members, including the Accolade Portal (including the web service known as MyAccolade), Accolade Digital Tools, Accolade Mobile App, 2nd.MD Portal, and 2ndMD Mobile App. Such digital services have their own terms and conditions and privacy notices, and your use of such services is subject to those terms and conditions and privacy notices. Those digital services are just one more way you can connect with your Accolade Health Assistant® representative to support you and your family in your healthcare journey. This Privacy Notice applies only to your use of the Site, and was last updated as of the “Last Updated” date at the top of the policy. Accolade may revise this Privacy Notice at any time and such revision will be posted here and accessible at the following link: 2nd.MD/privacy/general. Any revision and/or addition to this Privacy Notice shall become effective and binding on you when you continue to use the Site on or after the effective date of such revision and/or addition.
2. What Information Does Accolade Collect Through the Site?
Accolade collects certain types of information from you, whether you provide it directly or it is automatically gathered as you use our Site.
| Information We Collect | Information You Choose to Provide |
|---|---|
| Description | When communicating with Accolade in general, you may be asked to provide your first and last name, postal address, email address, or other contact information; or when inquiring about an open job posting, you may desire to upload your resume or connect with us using various third-party tools, such as LinkedIn or Indeed (we are not responsible for third party use of your information); or when registering for an event or a webinar, Accolade or its third party partners may ask you to provide personal information for the purpose of registering you for such event or webinar and providing access to the event. As further detailed below, we may also collect certain non-personally identifiable information about how you use the Site. |
| Information We Collect | Information Collected Via Your Use of Our Site |
| Description | We may collect information from you when you are using the Site in a number of different ways; for example: we may collect and track your IP address; Depending on your settings, we may use cookies, web beacons, pixels, technologies to record user sessions, and other tracking tools to monitor and track your access to and usage of the Site and for the purpose of certain remarketing activities (e.g., we display Accolade branded ads to you after you visit our Site and as you browse elsewhere on the Internet); |
| Information We Collect | Information We Collect Automatically |
| Description | We may now or in the future use tools, including third-party analytical software, to collect automatically certain data about the computer or other device you use to reach our Site such as: (i) device properties including, but not limited to, unique or other device identifiers; (ii) device operating system and firmware; (iii) IP address (i.e., a number that is automatically assigned to your device or computer used to access the Site, and allows us to identify your device or computer) and Internet service provider; (iv) mobile phone carrier; (v) geographical data such as country or region; and (vi) other similar data. Accordingly, when you visit our Site, some information may be automatically collected. Such information may also include Site access times, browser type and settings, device type, domain name, access times, duration of visit, referring URL, platform, new and repeat information, time stamp and language, and referring website addresses all of which may be logged automatically. We may also collect information about your usage and activity on our Sites. |
3. How Do We Use Your Information?
In general, we do not and will not share your personally identifiable information except as set forth in this Privacy Notice. We do not sell, transfer, and/or share your personally identifiable information with third parties for their own marketing purposes.
We use the information we collect from you when you browse the Site in the following manner:
| Category Name | Personal Identifiers |
|---|---|
| Categories of Your Personal Information | Identification information, message content, application usage data (e.g., features/pages accessed by a member), location data (GPS) |
| Use of Information | To operate and improve the Site and associated services |
| Category Name | Usage Information |
| Categories of Your Personal Information | Identification information, message content, application usage data (e.g., features/pages accessed by a member), location data (GPS) |
| Use of Information | To understand and analyze information related to the number and type of visitors that browse and use the Site |
| Category Name | Member Support |
| Categories of Your Personal Information | Name, phone number, mailing address, email address |
| Use of Information | To respond to your comments and questions and provide customer services |
| Category Name | Candidate Employee Support |
| Categories of Your Personal Information | Name, mailing address, email, phone number, employment application information |
| Use of Information | To permit you to apply for a job at Accolade, connect with third parties that we use to process job application information, and receive more information about open positions at Accolade |
| Category Name | Event Registration Information |
| Categories of Your Personal Information | Name, mailing address, email address, phone number, demographic information |
| Use of Information | To register for various events and webinars |
| Category Name | Member Communications |
| Categories of Your Personal Information | Name, mailing address, email address, phone number |
| Use of Information | To communicate with you about new contests, promotions and rewards, upcoming events, and other news about products and services offered by Accolade and our selected partners |
| Category Name | Member Outreach |
| Categories of Your Personal Information | Name, mailing address, email address, phone number |
| Use of Information | To conduct outreach and engagement communications to make you aware of Accolade services |
| Category Name | Internal Business Purposes |
| Categories of Your Personal Information | Name, mailing address, email address, phone number, demographic information |
| Use of Information | To link or combine with other personal information we get from third parties, to help understand your needs and provide you with better information on the Site |
| Category Name | Device Information and Identifiers |
| Categories of Your Personal Information | IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers. |
| Use of Information | For Accolade, internal purposes, such as providing the services, including registration and member support. Fixing and improving the services. Personalizing content and your experience. |
| Category Name | Research, survey, or sweepstakes information (including personal identifiers and user generated content) |
| Categories of Your Personal Information | Collected if you participate in a survey or sweepstakes; includes information needed for you to participate (such as contact information), and to fulfill your prize. |
| Use of Information | For Accolade, internal purposes, such as providing the services, including registration and member support. Fixing and improving the services. Personalizing content and your experience. |
If you provide Accolade with your contact information to receive marketing materials, you are opting-in to receive information from Accolade, including by email. You can opt-out anytime from the types of uses of your information, and receiving these communications, as further described below.
4. Who Has Access to Your Information?
| Access to Information | No Sale of Personal Information |
|---|---|
| Description | Your personal information will not be sold. It will not be licensed or disclose to unaffiliated third-parties, except in connection with the sale, transfer, merger, consolidation, or other transaction involving all or part of our company, or as may be permitted under applicable law. |
| Access to Information | Third-Party Sharing |
| Description | We may share information collected from you with our third-party partners to enable us to analyze and use such information to provide you with our services as described in this Privacy Notice. |
| Access to Information | Required Disclosure |
| Description | In addition to the above, we may be required to disclose your information to (i) comply with laws or to respond to lawful requests and legal process (including to respond to requests from public or government authorities, including public or government authorities outside your country of residence), (ii) to investigate, prevent, or take action regarding illegal or suspected illegal activities, (iii) to protect the rights and property of Accolade, and others to enforce our agreements, and this Privacy Notice and the Terms of Use, including to protect the security or integrity of the Site or our information systems, (iv) in an emergency to protect person or property, (v) as may be needed on a confidential basis to support a corporate transaction (including a merger, acquisition, divestiture, financing, or sale of assets or lines of business), or (vi) on an aggregated basis for any purpose in which your specific personal information is blinded, masked or otherwise not identifiable. |
5. How Do We Protect Your Information?
We follow industry standard practices to protect, secure and maintain the integrity and availability of your information. The Site and our internal networks supporting the Site are scanned regularly for malware and other viruses. Notwithstanding the foregoing, you acknowledge that no security safeguards or method of transmission over the Internet are completely secure.
The Site is not intended to collect, maintain or transmit your information to the privacy and security standards used in healthcare or banking where sensitive medical, health, or financial information may be transmitted. The Site is not protected according to HIPAA/HITECH, PCI or other such standards. DO NOT USE THE SITE OR COMMUNICATION TOOLS TO SEND US SENSITIVE PERSONAL OR PROTECTED HEALTH INFORMATION (e.g., do not send us your health information, benefit or ID card number, health claims information, social security number, financial account number, passcodes, etc.). For this reason, Accolade does not secure the transmission of your information submitted through the Communication Tools (as defined above), including using the addresses and numbers provided in the “Get in Touch” section of the Site.
6. How Long Do We Keep Your Information?
We store your information for as long as necessary to serve the business purposes for which it was collected and in conformance with applicable data protection laws. When determining how long we keep your information, we consider factors such as, but not limited to, the type and sensitivity of the data, the risk of unauthorized use, the purposes for processing, and the legal or business needs. Due to our data protection measures, residual copies of your information may temporarily remain in our backup systems before being automatically deleted or rendered inaccessible.
7. Does the Site Use Cookies?
Yes, the Site uses “cookies” and other web tracking tools. We may store information about you using the cookies on our site. A cookie also called web cookie, Internet cookie, browser cookie, or simply cookie) is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. We use cookies to improve your site experience, to assess content usage, to distinguish you from other users of our site and to support the marketing of our services. For example, cookies help determine what kind of content we will serve to the user – a use case might be, if a user is browsing a particular set of page content themes, we might serve that theme in the form of advertising as we’ve identified them as an interested party of that theme.
Most internet browsers automatically accept cookies, but you can set your browser to refuse them or to alert you when they are being sent. If, after your initial visit to the Site, you decide to change your cookie selection, you can do so by visiting www.accolade.com and selecting “Manage Cookies.”
Further, if you want to delete any cookies that are already on your computer, please refer to the file management software to locate the file or directory that stores cookies under the following file names. Other information on deleting or controlling cookies is available at www.allaboutcookies.org. Please note that by deleting our cookies or disabling future cookies you may not be able to access certain areas or features of our site.
8. What Are the Privacy Policies of Third-Party Websites to Which the Site Links?
Occasionally, at our discretion, we may link to third party sites or content on the Site. These third-party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability for the content and activities of these linked sites.
Nonetheless, we seek to protect the integrity of our Site and welcome any feedback about these third-party sites. We urge you to review the privacy policies posted on these third-party websites at the time you first visit such sites.
9. Where Does Data Storage and Processing Occur?
The Site collects information and processes and stores that information in databases located in the United States. If you are visiting the Site from a country outside the United States, you should be aware that you may transfer personally identifiable information about yourself to the United States, and that the data protection laws of the United States may not be as comprehensive as those in your own country. By visiting the Site and submitting any personally identifiable information you consent to the transfer of such personally identifiable information to the United States.
10. State Data Privacy Law Exemptions
Accolade and its affiliates are exempt from the Connecticut Data Privacy Act (“CTDPA”), Utah Consumer Privacy Act (UCPA) and Virginia Consumer Data Protection Act (“VCDPA”), and other similar state data privacy laws, with the below stated exemptions, which grant residents specific rights concerning their personal information.
These state laws generally apply to for-profit and business-to-business companies that interact, or process personal data of these states on a relatively larger scale. However, these laws DO NOT apply to covered entities or business associates under the Health Insurance Portability and Accountability Act (“HIPAA”) and the Health Information Technology for Economic and Clinical Health Act. Accolade and its affiliates are covered entities and/or business associates and are not subject to CTDPA, UCPA, VCDPA or any other state data privacy laws with similar exemptions.
11. Additional Terms for EU Visitors
This website is intended only for users located in the United States. To the extent that you are accessing this website from a location within the European Union, the following information shall apply to the collection and processing of your Personal Information.
The data controller for this Site is Accolade, Inc. Accolade processes Personal Information it collects through the Site for Accolade’s legitimate business purposes, for example to fulfill any requests you may make in connection with your submission of personally identifiable information, to monitor and improve the quality of the Site, and to protect and defend our rights, property or safety or that of our clients and other users of the Site. You may have the right to access and/or obtain a copy of your Personal Information, correct inaccuracies in your Personal Information, request the erasure of your Personal Information and restrict the processing of your Personal Information. For more information about how you can access, rectify, and erase your Personal Information or make any other requests relating to your Personal Information or to contact Accolade, please see the “Contact Us” section of this Privacy Notice below. In addition, you have the right to lodge a complaint with a supervisory data protection authority, contact information is available at https://edpb.europa.eu/about-edpb/board/members_en.
12. Does the Site Use Other Third Party Tools, such as Google AdSense?
Accolade has enabled Google AdSense on the Site. Google AdSense is an advertising service provided by Google. Accolade uses the “DoubleClick” Cookie, which tracks use of www.accolade.com, 2nd.MD, and user behavior concerning ads, products, and the services we offer. You may decide to disable all the DoubleClick Cookies by clicking on: https://www.google.com/settings/ads/onweb/optout?hl=en.
Google’s advertising requirements can be summed up by Google’s Advertising Principles: https://support.google.com/adwordspolicy/answer/1316548?hl=en
Google provides a breakdown of the information relevant to the collection and processing of data by Google AdSense:
Personal Data collected: Cookie and Usage Data Place of processing: USA
You can find the AdSense Privacy Policy at https://policies.google.com/technologies/ads
13. Session Replay Technology
You acknowledge that Accolade uses session replay technologies, such as those provided by Quantum Metric and FullStory, that employ software code to record users’ interactions with the Services in a manner that allows us to watch and analyze visual reconstructions of those user sessions. The replays may include users’ clicks, mobile app touches, mouse movements, scrolls, and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about FullStory at https://www.fullstory.com/legal/privacy-policy and you can opt-out of session recording by FullStory at https://www.fullstory.com/optout/. You can learn more about Quantum Metric, including opt out options, at https://www.quantummetric.com/legal/privacy-policy/.
14. Electronic Mail from Accolade
When you provide your email to Accolade by using the Communication Tools (as defined above), you can select to opt-in to receive email from Accolade. If you opt-in to the receipt of this electronic mail, we will:
not use false or misleading subjects or email addresses;
identify the message as an advertisement in some reasonable way;
include the physical address of our business or site headquarters;
monitor third party email marketing services for compliance, if one is used;
honor opt-out/unsubscribe requests quickly; and
allow users to unsubscribe by using the link at the bottom of each email
You can unsubscribe from promotional emails at any time by: (1) following the unsubscribe instructions in our emails; or (2) emailing us at [email protected]. You may update your email preferences anytime as well. Please note that even if you unsubscribe from promotional email messages, we may still need to contact you with important transactional information related to your account and your use of the Service. For example, even if you have unsubscribed from our email messages, we will still send you emails relating directly to a profile created through the Service confirming registration.
15. Do Not Track
We may not recognize or respond to every type of “do not track” signal or other mechanisms that provide consumers the ability to exercise choice regarding the collection of personally identifiable information about an individual consumer’s online activities over time and across third party websites or online services, but we give you certain choices about how we collect personally identifiable information as described in this Privacy Notice. Many Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Site including certain opt-out cookies.
We encourage you to review the privacy policies of our third-party advertisers and analytics service providers to learn about your choices and about the information they collect from you. In addition, the Network Advertising Initiative offers information about some of the Internet advertising companies we may use, including how to opt-out of interest based advertising they deliver. To opt-out of Google Analytics web tracking you can download Google Analytics Opt-out Browser Add-on.
For all the details, including how to turn on Do Not Track, visit www.donottrack.us.
16. Not Intended for Children Under 13
The Site is not intended for use by persons under the age of 18 and Accolade does not specifically market to children under 13.
17. Changes to this Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Privacy Notice, we will notify you by email or through a notice on our website homepage.
18. Contacting Us
If there are any questions regarding this Privacy Notice you may contact us using the information below.
Accolade, Inc. 660 West Germantown Pike, Suite 500 Plymouth Meeting, PA 19462 Attn: Chief Privacy Officer [email protected]