Easy Copay

Privacy Statement

Welcome. We know that our most important asset is our relationship with you. We are committed to the privacy of your information, which is a top priority for us. Please be sure to review our Privacy Policy as defined in this EasyCopay Privacy Statement before you use our services or submit any information to us, since it informs you of how we use and respect information about you.

This Privacy Policy was last updated February 22, 2012.

EasyCopay.com and FSAok.com are websites owned by Finpago, Inc. DBA EasyCopay. In this Privacy Policy references to the EasyCopay Service, website and communications apply to both EasyCopay and FSAok.

References in this Privacy Statement to ‘you’ and ‘your’ refer to you and your family members who use the EasyCopay Service or for whom you use the EasyCopay Service.

PERMISSION

You agree to the terms of our Privacy Policy by using this site. Whenever you give us information you consent to the collection, use and disclosure of that information in accordance with this Privacy Policy. We use your information in order to process transactions for you, and to develop and deliver new products and services for you.

YOUR PRIVATE INFORMATION IS NOT FOR SALE

Your personal information is yours, and we work to keep it that way. We will not rent or sell your personal information to anyone at any time without first obtaining your express prior consent.

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WE COLLECT INFORMATION THAT YOU TELL US

We actively collect information from you so that we can identify you and provide services to you. We do this through specific questions, forms, and menus. Some of the information you submit may be Personally Identifiable Information (PII) such as your name, phone, address, e-mail address, and so on. We will always tell you what information is required and what is optional.

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WE COLLECT YOUR INFORMATION THAT OTHERS TELL US ON YOUR BEHALF

We retrieve your pharmacy transactions from our participating pharmacies, and may receive other health care information about you when you use EasyCopay Services and when you permit us to collect on your behalf. This information is considered Protected Health Information (PHI) and is protected under the Health Insurance Portability and Accountability act (HIPAA).

PII and PHI are sensitive information about you so always look for the “padlock” in the lower-right corner of your browser when any site, including EasyCopay.com, asks for any sensitive information. If your browser is secure, you can double-click on that padlock to confirm our identity.

We also actively collect information from organizations such as retailers, pharmacies, health care providers, organizations that handle prescription and healthcare claims, employers, health spending account administrators, financial institutions, payment processors, third-party payers such as health insurance carriers and other organizations that you explicitly authorize (together the "Information Providers"). We request and collect this information on your behalf so that we can provide services to you, including services and offers that may be provided to you based on that that information and PHI. When we request personal information about you we do so in accordance with this Privacy Policy and with the EasyCopay Terms and Conditions.

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INFORMATION FROM CHILDREN

No EasyCopay services are intended for use by children; accordingly we do not knowingly collect, online or offline, personally identifiable information from children under 13 years old.

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ANONYMOUS INFORMATION

Whenever you navigate almost any Internet site, certain anonymous information can be passively collected - that is, gathered without you expressly providing it - using technologies like log files, server logs, beacons, cookies, click stream data, and server logs. Your browser gives us some of this information, such as the URL of the web site you just came from and the Internet Protocol address (IP address) of the computer you are using. You may set your browser to work without cookies, but certain features of this site may not work without cookies.

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PROTECTION

We take reasonable steps to protect PII and PHI as you transmit it to our site. Once collected we use industry-standard safeguarding techniques to keep this information safe, and may employ additional, proprietary methods in the way that we encode and transmit your data to provide additional protection.
You should keep in mind that no Internet transmission is ever completely error-free or secure. In particular, email you send through this site or to us separately may not be secure. EasyCopay and EasyCopay.com will never ask you for credit card information by email. Never include credit card information in any email you send us.

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HOW WE USE THIS INFORMATION

The PII and PHI (collectively your Personal Information or “PI”) that we collect may be combined with other actively and passively collected information about you. We may provide such information to one or more third parties such as health care providers, information providers or other service providers that provide information or services to us or in connection with the services that we provide to you. We will do so, however, only if we have an agreement with those entities to protect the privacy of your Personal Information and limit its use to the specific purpose of providing services and other benefits to you in accordance with the EasyCopay Terms and Conditions as the same may be in effect from time-to-time.

We may use your Personal Information to select and deliver offers relevant to you and your interests, to deliver notices to you, to customize the site for you, to improve the site, or for other purposes that we deem reasonable and in accordance with our Privacy Policy and the EasyCopay Terms and Conditions. Certain tools are available from us through email and this site that allow you to store and transmit and otherwise use your Personal Information on or from servers maintained by EasyCopay and its service providers; we will use your Personal Information in a manner consistent with the stated intent or purpose of such tools (for example we may electronically transmit a claim that contains your Personal Information including information that we receive from health care providers to your health spending account benefits administrator for reimbursement from your FSA account).

EasyCopay may aggregate your information that we collect with information about other users of the EasyCopay service and disclose such data only in the aggregate and in a non-personally identifiable way for:

  1. Promotional and advertising purposes to prospective clients of EasyCopay and advertisers and other third parties for their marketing and promotional purposes (for example: the number of users in a particular region, the nature of the health expenses and purchases made by groups of our users or the number of users that clicked on a particular link on our website);
  2. To inform other users of the EasyCopay service how they may make the most out of the EasyCopay service, our offers to them and their health spending accounts; and
  3. Other business purposes that we deem reasonable, but only after informing you of our intent to do so.

Such "aggregated information" does not identify you individually.

Please note that if you click on an advertisement link on our website or in another communication such as email to you, you will be interacting with the website of an advertiser and not us, so such interactions and services are not covered by this Privacy Policy or the EasyCopay Terms and Conditions. If you choose to follow these links or use these separate products or services, disclose information to the providers, and/or grant them permission to collect information about you, then their use of your information is governed by their privacy policies and not by our Privacy Policy. You should evaluate the practices of external services providers before deciding to use their services. These third party websites likely will have different privacy policies than EasyCopay and EasyCopay is not responsible for their privacy practices. If you click on a link to a third party Web site, EasyCopay encourages you to check the privacy policy of that website before providing any personally identifiable information or making use of their services.

EasyCopay also reserves the right (and you authorize EasyCopay) to share or disclose your Personal Information that we have or may collect when EasyCopay determines, in its sole discretion, that the disclosure of such information is necessary to respond to law enforcement requests or where required by applicable laws, court orders, legal process or government regulations or to identify, contact, or bring legal action against you (A) if you are or may be violating our policies or the Terms and Conditions of Use; or (B) to prevent potentially prohibited or illegal activities. Further, we can use the information in connection with the sale, assignment or other transfer of the business of this site, in which case we will require such a buyer to agree to treat it in accordance with our Privacy Policy and use it for the same purposes.

We may contact your insurer, payer, financial institution, or other agent and share your PI to submit claims on behalf of you. We may also contact you about a claim related to our services.

We may use and disclose your PI as necessary for our Health Care Operations, such as management, education and training.

We may disclose your PI to a public health authority in the interest of preventing or controlling disease, injury or disability.

We may disclose your information for national security purposes, or for certain special investigations.

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YOUR EASYCOPAY ACCOUNT AND INFORMATION IS YOURS

You can ask us to delete your EasyCopay account and account information anytime. When you confirm your request that we delete your EasyCopay account, your information will be deleted permanently and promptly from our servers that operate this EasyCopay consumer website. Note that once such deletion is completed, access to your EasyCopay account will no longer be possible and we will cease collecting and transmitting your personal information on your behalf. That being said, please note that your information that has been depersonalized or aggregated with other data so that it is no longer associated with your personally identifying information may continue to exist and be used by EasyCopay indefinitely. Your personal information may also be stored indefinitely on backup media and servers, which are kept to ensure continued availability of the EasyCopay service in the case of system or network failures and for other business purposes not including the sale or rent of any such personal information. Also we may maintain a backup copy of your personal information to use in legal or regulatory processes as defined above in the section entitled "HOW WE USE THIS INFORMATION."

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RIGHTS WITH RESPECT TO YOUR INFORMATION

The following lists the various rights you have regarding your PII or PHI.

  1. To receive a written copy of this notice. To obtain a copy of this notice at any time, go to http://www.EasyCopay.com/ or contact EasyCopay at the address set forth at the bottom of this document.
  2. To access and copy your PHI/PII contained within our systems. To inspect or copy your PHI/PII, submit a written request to the address set forth at the bottom of this document. We will respond to your request in writing within 60 calendar days. A fee may be charged for the expense of fulfilling your request. We may deny your request to inspect and copy in certain limited circumstances, such as if we have reasonably determined that providing this information would endanger your life or safety.
  3. To request an amendment of PHI/PII. If you feel that your PHI/PII is incomplete or incorrect, you may request that we amend it for as long as we maintain the information. To request an amendment, submit a written request to the address set forth at the bottom of this document. Requests must identify: the information to amend, what corrections to make, and why the information needs to be amended. We will respond to your request in writing within 60 calendar days.
  4. To receive an accounting of disclosures of PHI/PII. You have the right to request an accounting of your PHI/PII disclosures for purposes other than payment, research, or health care operations. To obtain an accounting submit a written request, addressing the period in question (not to exceed beyond six years from the current date), to the address set forth at the bottom of this document. We will respond to your request in writing within 60 calendar days. We will provide an accounting per 12-month period free of charge, but you may be charged for the cost of any subsequent accountings.
  5. To request a restriction on certain uses and disclosures of PHI/PII. You have the right to request a restriction or limitation on our use or disclosure of your PHI/PII by submitting a written request to the address set forth at the bottom of this document. Requests must identify: the specific information you would like to limit, whether to limit use/disclosure or both, and to whom you want the limits to apply. We will respond to your request in writing within 60 calendar days. We have the right to terminate restriction if you agree orally or in writing, or if we inform you of the termination which becomes effective only with respect to your PHI/PII created or received after we inform you of the termination.

CONTACTING US

If you believe any of your personal information is inaccurate, please contact us using the information below and we will take appropriate steps to update or correct any inaccurate information. You can sign in to our website at http://www.EasyCopay.com or write Customer Service at:

EasyCopay
2 Walnut Grove Drive, Suite 110
Horsham, PA 19044

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COMPLAINTS

If you believe our privacy rights have been violated you can file a complaint with EasyCopay at the address above, or with the Secretary of the United States Department of Health and Human Services. All complaints must be submitted in writing. You will not be penalized in any way for filing a complaint.

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PRIVACY POLICY REVISIONS

We will notify you of any changes to this policy by posting the revised policy on the EasyCopay website. Please review it from time to time. If you disagree with the terms of the Privacy Policy that is in force at any time, you may stop using our service and request removal of your personally identifiable information by contacting us at the address above.

Thank you for your interest in EasyCopay. We look forward to serving you.

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