Privacy Policy and Personal Data Transfer to U.S. Consent

This Website Privacy Policy (“Privacy Policy”) describes the commitment by Bupa Insurance Company and its subsidiaries, affiliates, and related group of companies (collectively “Bupa” or “Company” or “our”) to your privacy and explains our website privacy practices, so you can make an informed decision about your use of this Site and the information that you choose to provide to us. Please read this Privacy Policy carefully to understand how we collect, share, and protect information about you on and through our Site.

This Privacy Policy is incorporated into and is part of the Terms and Conditions of Use [** insert link to Terms and Conditions of Use **] of each of the web sites owned and operated by Bupa, including but not limited to: www.bupalatinamerica.com and www.bupasalud.com (collectively and each separately, the "Site"). The Terms and Conditions of Use, including but not limited to, limitations of liability, disclaimers, choice of law and venue terms, apply to this Privacy Policy.

By accessing and using the Site, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy.

Introduction

In order to deliver personalized and relevant information to you through this Site, Bupa collects certain information from you. Bupa is committed to protecting your privacy. The purpose of this Privacy Policy is to describe our privacy practices regarding that information.

We may collect personal information about you from you, your employer or other sources. Bupa only uses and discloses such information about you as permitted by the Privacy Rule established under the Health Insurance Portability and Accountability Act of 1996 (HIPAA), and all other applicable laws and regulations, and any separate agreement with you.

A Special Note About Children

Bupa is committed to protecting the privacy of children. This Site is not designed or intended to attract children 13 years and under in accordance with the Children’s Online Privacy Protection Act. We collect information about children under the age of 13 only from the child’s parent or legal guardian. We do not collect any personal information directly from any person if we know such person is a child under the age of 13. BY ACCESSING THIS SITE, YOU REPRESENT THAT YOU ARE 13 YEARS OF AGE OR OLDER. If you believe we have collected personal information from a child under the age of 13, please Contact Us at privacyoffice@bupalatinamerica.com.

Information About You That We Collect

You, your employer or third party vendors providing services on behalf of you may furnish us information about you, such as your name, date of birth, health plan ID number, and zip code, and, in certain circumstances, your medical history and other health information, and your health plan. Third party vendors may furnish information to us related to your health, such as medical and pharmacy claims, health risk assessment information or other administrative data, in order for us to provide the services of this Site to you. If you can make payments at our Site you can provide your bank account information and your credit or debit card information, as applicable. This information is processed by our third party payment processor. We also may collect information directly from you through your use of the Site, including, but not limited to: demographic information (such as your name, address, date of birth, email and IP address) and information related to your health (such as your height, weight, medication history or experience with certain conditions or treatments), or other information.

As with many other websites, the Web servers used to operate the Site may collect certain data pertaining to you and the equipment and communications method that you use to access the Internet and the Site. We also may collect other identifying information from or about you in connection with your use of the Site. For example, we may collect and store the content of, and data regarding, any correspondence you may have with us or our representatives, regardless of the subject matter or the mode of communication by which such correspondence is made.

We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/).

We may use your online activity to show you ads for Company or our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. These ads do not appear on our Site, but are displayed at third party sites such as Facebook and Google. Interest-based ads are ads presented to you from these other sites based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our site or third-party sites not owned by Company. We belong to ad networks that may use your browsing history across participating websites to show you interest-based advertisements on those websites. Our Site does not recognize if your browser sends a “do not track” signal or similar mechanism to indicate you do not wish to be tracked or receive interest-based ads. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org).

How We Use Information about You

We use information about you that you provide through the Site, or that we otherwise collect, to provide services and information to you and to run our Company operations. For example, we may use information about you to notify you of opportunities, products, services or other business reasons. If you create an online account you can view claims information and policy information using the Site. We may also use the information that you provide us with to send you information, electronically, by mail, telephone or other means, Bupa also may use information about you to provide services to you or to ensure that software, hardware and other systems are working correctly and securely.

Bupa may combine information about you with information about others who use the Site and remove all personal identifiers from the resulting combined information to create “de-identified information.” We use de-identified information in the development of products and services to meet the continuing needs of our clients, and to analyze and improve the content, features, materials, and opportunities that we may make available on the Site.

If you contact us for support or assistance, we may use information about you or your computer that you provide for purposes such as verifying whether your computer meets the minimum requirements needed to use the Site and our various services.

Data collected by our Web servers or otherwise through use of the Site may be used by us. For instance, the Company may use the data to facilitate Site operation and system administration, to generate aggregated, non-identifiable statistical information, to monitor and analyze Site traffic and usage patterns, and to improve the content and content delivery with regard to the Site and the content, materials, opportunities, and services that we describe or make available on the Site. This data may reveal such things as the Internet Protocol address assigned to your computer, specific pages that you accessed on the Site or immediately prior to visiting the Site, and the length of time you spend at the Site, but without combining these data with other sources of information, they do not readily or personally identify you. For security reasons and to confirm the integrity of our data, however, we may combine components of these data with other sources of information that may identify you.

How We Share or Disclose Information About You

We may share information about you, including your health and medical information, with your health care providers and authorized representatives to provide the services of this Site and for other purposes permitted by HIPAA and other applicable laws. We may decide from time to time to utilize a number of trusted business partners in delivering the content available on or through this Site to you. To the extent necessary for purposes of operating the Site, communicating with you, or fulfilling your requests for our services, we may share information about you with these business partners. When we use other companies to provide services to us, we require them to protect the confidentiality of any personal information they receive from us or collect on our behalf and to use such information only for the limited purpose of providing the services on our behalf.

In certain limited circumstances, we may disclose information about you, including your health information, if we become subject to a subpoena, search warrant or court order, or if we are otherwise legally required to disclose such information. Bupa may, for instance, disclose information about you as necessary to establish or exercise our legal rights, to enforce the Terms and Conditions of Use, to assert and defend against legal claims, in connection with a corporate transaction resulting in a transfer of the assets or line of business relating to such data, to protect, secure or amend our data, systems, products or services, and to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities. Bupa also may disclose such information in special cases, such as in response to a potential threat to the physical safety or well-being of you or others or to protect property.

Our Use of “Cookies”

“Cookies” are small files of data that reside on your computer and allow us to recognize you as a Bupa client if you return to the Site using the same computer and browser. We send a “session cookie” to your computer if and when you log in to your Bupa account. These cookies allow us to recognize you if you visit multiple pages in the Site during the same session, so that you don’t need to re-enter your password multiple times. Once you log out or close your browser, these session cookies expire and no longer have any effect.

We also use longer-lasting cookies to display your user name on our sign-in form. Our cookie files are encoded so that any information stored in them may only be interpreted by the servers on the Site.

Web browsers and other software allow you to erase cookies from your computer’s hard drive, to block or reject all cookies, or to receive a warning before a cookie is stored. If you choose to reject cookies, you may not be allowed access to the Site or it may not operate efficiently or the way it was intended.

Bupa Provides the Site in a Secure Environment

We use commercially reasonable methods to keep information about you that we collect or store on or through the Site safe from unauthorized access. Because Bupa respects your privacy and values your trust, the only persons to whom we give access to information about you are those who use it to provide services to you or conduct other activities described in this Privacy Policy.

Bupa maintains physical, electronic, and procedural safeguards designed to comply with applicable standards to help guard information about you and to assist us in preventing unauthorized access to that information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. We cannot and do not guarantee that communications to or from the Site, or that data transmitted or stored on or through the Site, are or will be totally secure from loss, misuse or unauthorized access by third parties.

Consent To Data Processing Of Personal Data In United States

In order to provide our products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the European Economic Area and (EEA), including to the United States. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as within the EEA to the extent feasible under applicable law. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

You Have Options

When corresponding with Bupa or our representatives, or when making a request for information or otherwise interacting with Bupa through the Site, you choose what information to supply, what questions to pose, and what comments to make, whether you wish to receive further information, and how we should provide such information. Please take care to share only information that you believe is appropriate.

There may be opportunities on the Site for you to opt-in or opt-out of certain uses and disclosures of information specific to particular tools or sections of the Site. There also may be opportunities for you to designate how you would like your e-mail address to be used or not used by Bupa for purposes related to the services provided through the Site. Please take care to evaluate these options where they are available.

If you wish to remove information about you from the Site, please contact Bupa at the following address:

Bupa Latin America
Attn: Privacy Officer
17901 Old Cutler Road, Suite 400
Palmetto Bay, Florida 33157 USA
privacyoffice@bupalatinamerica.com

Please be aware that it may not be technologically possible to remove each and every data record from our servers.

Independent Recourse

If you have any questions or concerns regarding the privacy of your information, please contact Bupa at the above address. Bupa is committed to maintaining the privacy and security of your information consistent with all applicable legal requirements and the terms of this Policy and will review all legitimate concerns.

Changes to the Privacy Policy

From time to time, we may change this Privacy Policy and our privacy practices because of changes in relevant and applicable legal or regulatory requirements, in our business practices, or in our attempts to better serve your needs and those of our clients. When we do so, we will post a revised Privacy Policy on the Site and a new effective date below. Any such change will be effective immediately upon posting on the Site. You are responsible for checking the Privacy Policy for such changes.

Linked Sites

For your convenience, this Site may contain links to websites that are not operated by or affiliated with Bupa, including without limitation Facebook, Twitter, Hi5, Sonico, and Youtube. These third party websites are not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy or security practices of those sites or of any companies that we do not own or control. Any information you disclose once you access these other web sites is not subject to this Privacy Policy. We encourage you to seek out and read the privacy policy of each website that you visit to understand how information about you is collected, used, and protected.

Questions

If you have any questions regarding this Privacy Policy, please contact Bupa at the above address.

If you become aware of any breach of Site security, this Privacy Policy, or the Terms and Conditions of Use, please notify us immediately.

Acknowledgement

BY ACCESSING OR USING THE SITE, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND CONSENT TO OUR PRIVACY PRACTICES AND TO THE USES AND DISCLOSURES OF INFORMATION THAT WE COLLECT ABOUT YOU AND YOU AGREE TO BE BOUND BY THE TERMS AND CONDITIONS OF USE APPLICABLE TO YOU.

Effective Date

This Privacy Notice is effective as of December, 2015.