Effective __________, 2024

Your privacy is important to us. To better protect your privacy and for you to understand how we collect, use and disclose personal information via our website, we provide this “Privacy Policy” explaining our online information practices. This notice applies to all information collected from this website. This policy does not apply to information collected through other means such as by telephone, in person or via a mobile application, although that information may be protected by other privacy policies.

Our use and disclosure of your information may be subject to the requirements of the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPPA”). Any information you submit to us that constitutes Protected Health Information, as defined by HIPAA, is subject to HIPAA and applicable law. “Protected Health Information” (or “PHI”) refers to individually identifiable health information about your past, present or future physical or mental health or condition, the provision of health care to you or the past, present or future payment for such care. Please note that any PHI collected will be used and disclosed only in accordance with our HIPAA Privacy Practices Notice. To read more about our privacy practices regarding health and medical information under HIPAA, visit our HIPAA Privacy Practices Notice.

Consent

By using this website, you consent to the collection and use of your information in the manner described in this Privacy Policy. IF YOU DO NOT AGREE WITH THESE TERMS, DO NOT USE THIS WEBSITE.

Minors

We abide by the United States Children’s Online Privacy Protection Act (COPPA), Texas Securing Children Online through Parental Empowerment (SCOPE) Act, and other applicable law. Use of this site is intended for persons eighteen (18) years or older. Minors under the age of 18 are not permitted to register on this site, or use any functionality for which registration is required. No personal information is knowingly collected from any person under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at _______________. We will delete such information from our files within a reasonable time.

Collection of Personally Identifiable Information

You may generally use this website without disclosing personally identifiable information. However, use of certain features and functions of the website may require you to submit personally identifiable information to us. We may collect any information you voluntarily share with us via the website. This information also may be collected by a third-party vendor, supplier or contractor on our behalf. We require any such service providers to maintain confidentiality of such information. This information may include: contact information and date of birth; demographic information, such as your age, gender, ethnicity and occupation; or healthcare claims, health plan account numbers, and insurance information.

We do not collect or maintain credit or payment card data.

Use and Disclosure of Information

We will use your information to provide the services for the purpose for which you provide it or as otherwise may be disclosed at the point of collection. We may also use the information you provided us to:

• contact you from time to time to provide you with important information and required notices;
• communicate with you;
• process requests for services requested by you;
• administer surveys;
• personalize your experience;
• perform analytics and to improve our products;
• facilitate software updates;
• comply with law or regulations;
• to keep a record of our transactions and communications; and
• perform other necessary and useful tasks related to services provided to you.

We may provide aggregated data obtained on the website that is de-identified to third-parties. However, any aggregated data obtained on the website will not include any of your personally identifiable information, including PHI, or be individually identifiable.

We may also use or disclose your personal information to resolve disputes, enforce our website Terms of Use or any other agreement.

We may share information in response to a court order, subpoena, search warrant, request from the Texas Department of Insurance or other regulatory agency with jurisdiction over the matter inquired about, or as required by law or regulation.

We may share information with third-party vendors with whom we have contracted to perform services on our behalf and which we require to maintain confidentiality of such information.

If we are sold or disposed of, whether by merger, reorganization, sale of assets or otherwise, or in the event of insolvency, bankruptcy, or receivership, any and all personally identifiable information, including your account information may be one of the assets sold or merged in connection with that transaction. Information about you may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support, or funding. In such transaction, personal information will be subject to the promises made in any pre-existing Privacy Policy in effect when the information was obtained.

Additional Collection, Disclosure and Use for Portal Websites

If you are currently a Member, Provider, Employer, or Broker doing business with us, you may choose to register for one of our “Portal Websites” if applicable. A web “portal” is a website that allows two-way interaction and can collect information from the visitor or provide information to the visitor. For the purposes of this policy, the following definitions shall apply:

We collect PHI or other sensitive information to track those users registering for portal access. This information is used to permit continued access to the Portal Website and shall be collected and disclosed in accordance with this Privacy Policy.

After registration, a user may choose to provide personal information via the Portal Website. By supplying us with PHI or other information, users of the Portal Website have consented to allowing us to use that PHI in accordance with HIPAA standards.

Access to Personally Identifiable Information

Upon written request and verification of your identity, we will provide you with your personal information in our possession as well as the personal information, if any, that we have disclosed to third-parties. Requests for such information should be sent to the contact information below. You may also update, correct or delete your personal information in our possession by contacting us using the contact information below or by updating your personal information by logging into your account.

You may have access to your Individual Health Record (IHR) via this website or Portal Websites. If applicable, you may be able to grant others, such as family members or authorized individuals, access to your IHR. The IHR is an electronic health data application that helps users collect, manage, and share health information, health history, and current health status. IHR users may utilize the IHR platform to import their health information from several sources, including but not limited to their healthcare providers, health plans, and medical devices. If applicable, Sendero Health Plans, Inc. or third-parties with which it contracts to provide services may use your IHR Data and/or Information to operate and manage the IHR platform, software, website, and portal. If applicable, your healthcare or medical provider may have access to your IHR to help manage your care.

Collection of Information via Cookies and Tracking Tools

This website utilizes various technologies, including cookies, tokens, tags, web logs, web beacons, scripts, web server logs, or statistical identifiers to capture information to enable features of this website or improve performance of this website. Cookies are small text files that may be placed on your computer when you visit a website. Cookies may include “single-session cookies” (which generally record information during only a single visit to a website and then are erased) or “persistent cookies” (which are generally stored on a computer unless or until they are deleted or set to expire). First-party cookies are placed by us. Third-party cookies may be placed by a third-party. Web beacons or pixel tag are tools that we may send to you to help us determine whether a page has been viewed. A pixel tag is a type of web beacon embedded in an image on the website. Our website may have pixel tags from vendors. Statistical identifiers or device recognition tools are tools used to inform us of the content you use and view on the website without the use of cookies.

These various tools may be placed on web browsers to serve ads based on past visits to this website or collect non-personal information about your use of this website, such as tracking the internet browser most commonly used to access the website or the pages that are most popular. We may use tracking technologies that allow us to recognize your device when you return to our website within a period of time, as determined by us, and to support automatic login. These tools cannot give access to your computer or any information stored on your computer. These tools may be created and managed by parties outside of our control. When utilizing these applications, we are subject to the usage terms of any third-party service provider furnishing the cookie or tracking tool.

Use of Information Collected via Cookies and Tracking Tools

These tools may be used for analytics, retargeting, remarketing, and online behavioral advertising as set forth below. When utilizing these applications, we are subject to the usage terms of any third-party service provider furnishing the cookie or tracking tool. All data collected will be used in accordance with this Privacy Policy and the privacy policies of any third-party service provider as identified below. Please read all third-party privacy policies before using this website.

This website may use advertising and remarketing technology to advertise on third-party websites (including Google and social media websites such as Meta, X, and Instagram). Third-party vendors, will place cookies on web browsers to serve advertisements based on past visits to this website.

Website and Information Security

We maintain reasonable administrative, technical and physical safeguards designed to protect the information that you provide on this website. For example, it is our policy to protect the confidentiality of Social Security numbers ("SSNs") that we receive or collect in the course of business through various means, including physical, technical, and administrative safeguards that are designed to protect against unauthorized access. However, no security system is impenetrable and we cannot guarantee the security of our website, nor can we guarantee that the information you supply will not be intercepted while being transmitted to use over the Internet. We are not liable for the illegal acts of third-parties such as criminal hackers.

Changes to Privacy Policy

We reserve the right to modify or amend this Privacy Policy at any time. All changes will be effective immediately upon posting to this website and may be made without notice to you. You agree to review this Privacy Policy frequently so that you will be familiar with these terms. You further agree that each time you use this website that you are, by such use, consenting to the terms of this Privacy Policy that are applicable at your time of use.

Contact Information

Any questions you have about the information we collect via our website and your privacy can be directed to us by mail or email using the contact information on the Contact page of this website.