Internet Privacy Statement

Introduction

TriWest Healthcare Alliance Corp. (“TriWest”) is committed to protecting the privacy of our providers and beneficiaries. This Internet Privacy Statement (“Policy”) describes how TriWest strives to employ practices that ensure personal information collected when you visit our website is used conscientiously and appropriately, how we use your information, and the choices you have regarding its use, review and correction.

By using the TriWest Provider Portal, TriWest.com, or any digital services offered through either (“The Services”), you consent to the collection and use of the information you voluntarily provide to us as outlined in this Privacy Statement. This Policy does not apply to information that is otherwise protected by HIPAA or any other applicable legal protection.

This Policy applies to the Services and other features, content or applications offered from time to time by TriWest in connection with the Services. The Services are hosted in the United States.

This Policy covers how TriWest collects, uses, maintains, retains, protects, and shares information, including PII that you provide to us and information we collect automatically related to your use of the websites and Services.

This Policy does not apply to information collected by us offline or the practices of companies that TriWest does not own or control, to content or information not generated by TriWest, any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Services, or to acts of people that TriWest does not employ or manage.

PII means individually identifiable information that TriWest owns, controls, or maintains and that is from or about an individual, including, but not limited to (a) first and last name; (b) home or other physical address; (c) email address or other online information, such as a user name and password; (d) telephone number; (e) government-issued identification or other number; (f) date of birth; and (g) any information that is combined with any of (a) through (f).

We may change this Privacy Statement from time to time and without notice. If we change our Privacy Statement, we will publish the revised Privacy Statement on this page.

Information Collection and Use

TriWest collects information that personally identifies you (“Personal Information”) in some circumstances, for example when you apply for the Services, or our beneficiaries provide your information to us to contact you about your participation in TriWest programs. The types of Personal Information we collect include name, contact details, identification information, organization, title, information submitted in forms, payment details and enquiry/complaint details. We also may collect information about your interactions and transactions with us, including monitoring and recording any contact we have with you by telephone, email or online for purposes including security, dispute resolution and training. We collect Personal Information directly from you as well as from third parties including public sources, our network subcontractors, information service providers and the parties with whom we exchange information as described here.“Other Information” is any information we collect that is not Personal Information. We may combine Personal Information with Other Information, in which case we will treat the combined information as Personal Information.

Read the Veterans Health Administration Notice of Privacy Practices.

We collect, use and disclose your Personal Information to provide, administer, and improve our network and services, maintain and update our records, manage our relationship with you and our beneficiaries and deal with your enquiries and concerns. We may also collect, use and disclose your Personal Information in connection with suspected fraud, misconduct and unlawful activity.

If you are a participating provider, your Personal Information is used to give you access to our provider portal, to contact you with important information related to your participation, to improve and promote the smooth and efficient administration of the Services. We may contact you via email, postal mail, or in limited circumstances via fax. Under no circumstances will TriWest make any Personal Information about an individual user available publicly in this manner.

Your email address is used to only send you information that you have requested. TriWest allows you to elect to receive, or not receive, certain information. TriWest adheres strictly to permission-based email policy. Except as mentioned above, TriWest will not send you unsolicited email information, commercial offers or advertisements. TriWest will not sell, rent, or loan our contact lists (including provider data) to any outside firms not involved in the provision of TriWest services. All emails that TriWest sends to a list will have an option to unsubscribe. Unsubscribe requests are normally fulfilled within minutes and no further communications will be sent to users who have stated that they do not wish to receive the specified information.

We collect information in the aggregate form through the use of cookies and internet protocol (“IP”) addresses, such as demographic information and browsing patterns, including the internet service provider from which you access the internet, your domain name, the IP address of the computer you are using, the name of the page that referred you to us, the date and times you enter and exit the Services, the pages you visit before and after visiting the Services, the web pages, video content and advertisements you view and links you click on within the Services, unique identifiers, including mobile device identification numbers that can identify the physical location of such devices in accordance with applicable law, and information collected through web beacons and other technologies. Such information does not identify any individual and will not be linked to any PII. We collect such information using a variety of mechanisms, including the following:

• Web log data. When you visit TriWest Websites or use any of the Services, we automatically receive and record certain information from your computer (or other device) and your browser. To obtain such information, we may use web logs or applications that recognize your computer (or other device) and gather information about its online activity.
• Cookies. We also use cookies on the Services. Cookies are small files that are stored on your computer or other device by your web browser. A cookie allows the Services to recognize whether you have visited before and may store user preferences and other information. If you are concerned about having cookies on your computer or other device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer or other device. However, if you choose to block or delete cookies, certain features of the Services may not operate correctly.
• Web beacons. The Services or the emails that you receive from TriWest may use an application known as a “web beacon” (also known as a “clear gif” or “pixel tag”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include Personal Information. For example, it may allow our email sender to determine whether a user has opened a particular email.
• Third-party online tracking and behavioral advertising. We also may partner with certain third parties to collect, analyze, and use some of the Personal and Other Information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Services or in email communications from us. This information may be used for a variety of purposes, including online behavioral advertising, as discussed below (see the section entitled “Third-Party Analytics and Targeted Advertising”).

We use such information to:

• monitor the usage of the Services,
• recognize you when you return to our Services,
• store information about your preferences,
• aid strategic development,
• manage our relationship with content providers, and
• audit usage of the Services.

We may share such information, in the aggregate form only, with our affiliates, partners, or other third parties.

We may not be able to do the things described above without your Personal Information. For example, we may not be able to communicate with you and deal with your enquiries.

Disclosure

TriWest will not use or disclose your Personal Information without your consent, except:

• as required by law or when we believe that such disclosure is necessary in connection with a judicial proceeding or to comply with a court order, law or regulation applicable to TriWest or the Services;
• as we reasonably determine to be necessary to protect our property or assert our legal rights;
• as we reasonably determine to be necessary to protect the property or safety of any other person; or
• as otherwise described in this Policy.

We may exchange your Personal Information with our related bodies corporate, your representatives and with our service providers that assist us with the Services, including, for example, our providers of professional, legal, consulting, marketing, communications and business development services. We may disclose personally identifiable information to such entities as needed for them to perform their specific tasks under our instructions, subject to this policy. TriWest also uses third-party service providers that perform services on our behalf, including web-hosting companies, email vendors, and analytics providers. These service providers may collect and/or use your Personal or Other Information to assist us in achieving the purposes discussed above. We may also share your Personal or Other Information with other third parties when necessary to fulfill your requests for services; to meet the terms of any agreement that you have with us or our partners; or to manage our business.

Third-party plugins. The Services integrate certain third-party plug-ins (such as a Facebook “like” button). Even if you do not click on these plug-ins, they may collect information about you, such as your IP address and the pages that you view. They also may set and/or access a cookie. These plugins are governed by the privacy policy of the company providing them.

Chat Functionality. TriWest uses the services of a third party to provide chat-based functionality for some Services. If directed to the services, you may be accessing a the systems of a third part, specifically Pypestream, to communicate with TriWest. Pypestream’s services may collect Personal Information or Other Information, and the usage and collection of information by Pypestream is governed by the Pypestream privacy policy at https://www.pypestream.com/privacy-policy/.

Third-Party Analytics and Targeted Advertising

Analytics. We partner with certain third parties to collect the Other Information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Services use Google Analytics, and Google Ads, among others to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics at https://support.google.com/analytics/answer/6004245, and by Google Ads at https://support.google.com/ads/answer/2662922.

Targeted Advertising. The Services also enables third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties may use the fact that you visited our Services to target online ads to you. In addition, our third-party advertising networks might use information about your use of our Services to help target advertisements based on your online activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website.

The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Although our Services currently do not respond to “do not track” browser headers, you can limit tracking by these third parties and by taking the steps discussed above.

Facebook Custom Audiences and Similar Programs. We may partner with Facebook and other social media partners to deliver advertisements to our users via the Facebook Custom Audiences program or similar third-party programs. In order to identify and reach our users on Facebook or another third-party service, we may share information such as an email address with Facebook or another third-party service. For more information about custom audience targeting and how to adjust your social media advertising preferences, please review the privacy policy of your social media provider.

Information Collected from Children

Content on this website is directed at individuals over the age of 18 and is not directed at children under the age of 13. We do not knowingly collect personally identifiable information from children under the age of 13. If you are under the age of 13, do not provide personally identifiable information of any kind.

Data Security and Retention

To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we employ physical, technical and administrative procedures to safeguard the Personal Information we collect online. However, we cannot ensure or warrant the security of any information you transmit to the Services or to us, and you transmit such information at your own risk.

The Services may contain links to third party websites. We have not reviewed these third party sites and do not control and are not responsible for any of these sites, their content or their privacy policies. Thus, we do not endorse or make any representations about them, or any information, software or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third party sites listed on the Services, you do so at your own risk.

We retain information for as long as reasonably necessary to deliver the Services to you, to fulfill the purposes described in this Policy, or as required by law. To request the deletion of your Personal Information, please see the section “Contacting TriWest about Privacy” below.

Communications from the Site

Special Updates and Newsletters

We send all new users a welcoming email to verify their new account and confirm their password and username. Established users will occasionally receive information on TriWest-administered healthcare programs, and a newsletter. Out of respect for your privacy we present the option to not receive these types of communications. Customers can unsubscribe via the unsubscribe mechanism at the bottom of each email.

Service Announcements

On rare occasions it may be necessary to send out a strictly service related announcement via email. For instance, if the Services are temporarily suspended for maintenance we might send users an email. Generally, users may not opt-out of these communications, though they can deactivate their account.

Customer Service

We communicate with providers and beneficiaries on a regular basis to provide requested services and in regards to issues relating to their participation we reply via email or phone, in accordance with the their wishes.

The Services Usage Information

TriWest has business partners who help develop or service our websites. They may track and keep certain visitor information with the use of cookies, such as where you visit, information about your browser, your Internet protocol address, its capabilities, operating system, access date and time and identifying link.

The Services may contain links to third-party websites. If you follow a link to any of these websites, please note that these websites, and any services that may be accessible through them, have their own privacy policies. We are not responsible for the privacy practices of other websites. We encourage our users to be aware when they leave the Services and to read the privacy policies applicable to such third-party websites. This Policy applies solely to information collected in connection with the Services.

Security Technology

TriWest has made a substantial investment in technologies to protect our information assets. These technologies are deployed as part of sophisticated security architecture. All data resides in a tightly controlled, secure data center. These investments mean that information about the identity and preferences of individual members is strongly protected by TriWest against unauthorized access. We will maintain safeguards to protect the security of these servers and your Personal Information.

TriWest may process, store and back up its information with the assistance of those providers.

Policy Modifications

We regularly review our Privacy Statement to ensure that it provides an appropriate level of protection for your Personal Information and we may make changes to our Policy to keep it current with industry standards. We will post the date of the most recent revisions on this page. Check this page to make sure that you are current and up-to-date on our Policy. Keep in mind that your use of the Services means that you accept our Policy.

California Consumer Privacy Act of 2018

Information for California Residents. For information regarding the California Consumer Privacy Act of 2018 (CCPA), including the processes for submitting requests under the CCPA and how personal information is collected, used and shared by TriWest, please see the following links:

• TriWest's CCPA Supplemental Privacy Policy & Notice - English
• TriWest's CCPA Supplemental Privacy Policy & Notice - Spanish
• TriWest's Consumer Privacy Intake Form