Notification of Changes
Provider Web Sites and other pages on the CLA Web site include links to third party Web sites. These sites are governed by their own privacy statements, and CLA is not responsible for their operations, including but not limited to their information practices. Users submitting information to or through these third party Web sites should review the privacy statement of these sites before providing them with personally identifiable information.
A Special Note About Children
Children are not eligible to use CLA except through their parent’s membership and we ask that minors do not submit any personal information to us.
B. Information We Collect
Information About You From Third Parties
In order to protect all our customers against potential fraud, we verify with third parties some of the information you provide. In the course of such verification, we receive personally identifiable information about you from such services. In particular, if you use a credit card or debit card with CLA, we will use card authorization and fraud screening services to verify that your card information and address matches the information that you supplied to CLA, and that the card has not been reported as lost or stolen.
Web Site Traffic Information
Because of the way that World Wide Web communication standards work, when you arrive at or leave the CLA Web site, we automatically receive the Web address of the site that you came from or are going to. We also collect information on which pages of our Web site you visit while you are on the CLA site, the type of browser you use and the times you access our Web site. We use this information to try to understand our customers’ preferences better and to manage the load on our servers, so as to improve our service and your experience with CLA. We do not track the Web sites that you visit before or after you leave the CLA site. If you object to this tracking please visit us from a fresh browser window and exit our site (after logging off if applicable) by closing your browser.
Our Use of “Cookies”
“Cookies” are small files of data that reside on your computer and allow us to recognize you as a CLA member or provider if you return to the CLA site using the same computer and browser. We send a “session cookie” to your computer if and when you log in to your CLA account by entering your User ID and Password. These cookies allow us to recognize you if you visit multiple pages in our 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.
Customer Service Correspondence
If you send us correspondence, including e-mails and faxes, we may retain such information in the records of your account. We will also retain customer service correspondence and other correspondence from CLA to you. We retain these records in order to measure and improve our customer service, and to investigate problems. We may, over time, delete these records if permitted by law.
Questionnaires, Surveys and Profile Data
From time to time, we may offer optional questionnaires and surveys to our users for such purposes as collecting demographic information or assessing users’ interests and needs. The use of the information collected will be explained in detail in the survey itself. If we collect personally identifiable information from our users in these questionnaires and surveys, the users will be given notice of how the information will be used prior to their participation in the survey or questionnaire.
C. Our Use and Disclosure of Information
We collect, store and process your personal information on servers located in the United States. We use the information we collect about you in order to (1) provide our services and process your transactions, (2) provide customer service, (3) determine your eligibility to receive offers for special features or products, such as new services offered by Providers in your area, and (4) improve our products and services.
We authorize access to individually identifiable information about our users only to those employees who require it to fulfill their job responsibilities.
Disclosure to Third Parties
CLA will not sell or rent any of your personally identifiable information to third parties. CLA will not share any of your personally identifiable information with third parties except in the limited circumstances described below. These third parties are limited by law or by contract from using the information for secondary purposes beyond the purposes for which the information is shared.
- We share information with companies that help us process payments. See “Information About You From Third Parties” in Section B above. We may disclose the information we collect from you to companies that market CLA-related products and services on our behalf. Additionally, if you go into a negative balance and owe us money, we may share information with processing companies including collection agencies.
- We disclose information that we in good faith believe is appropriate to cooperate in investigations of fraud or other illegal activity, or to conduct investigations of violations of our Terms of Membership and Membership Agreement. For example, this means that if we find a fraudulent activity that requires investigation, we can give contact information (but not bank account or credit card information) to law enforcement on behalf of victims who request it.
- We disclose information in response to a subpoena, warrant, court order, levy, attachment, order of a court-appointed receiver or other comparable legal process, including subpoenas from private parties in a civil action.
- When a Member or Provider signs up for a co-branded version of CLA through links from a co-branded partner’s website, CLA will share with the co-branded partner that user’s name, e-mail address and physical address in order to provide enhanced integration between CLA services and the services of our co-branded partner. If you do not want your information shared with CLA’s co-branded partner, you should sign up with CLA directly and not through a link from our partner’s website.
- We disclose information to your agent or legal representative (such as the holder of a power of attorney that you grant, or a guardian appointed for you).
- We share aggregated statistical data with our business partners or for public relations. For example, we may disclose that a specific percentage of our users live in California. However, this aggregated information is not tied to personally identifiable information.
- We share your information with our parent, subsidiaries, affiliates and joint ventures to help coordinate the services we provide to you, enforce our terms and conditions, and promote trust and safety.
Our Contacts with Cardholders and Providers
We communicate with Cardholders and Providers on a regular basis via e-mail to provide requested services, and we also communicate by phone to properly service your account, resolve customer complaints or investigate suspicious transactions. We use your e-mail address to confirm your opening of an account, to send you notice of payments that are processed by you, to send information about important changes to our products and services, and to send notices and other disclosures required by law. Generally, users cannot opt out of these communications, but they will be primarily informational in nature rather than promotional.
We also use your e-mail address to send you other types of communications that you can control, including the CLA periodical newsletter, health tips, customer surveys and notice of special promotions. You can choose whether to receive some, all or none of these communications when you complete the registration process, or at any time thereafter, by logging in to your account on the CLA Web site and changing your preferences in your profile. You can also change your choices at any time through the same procedure.
In connection with independent audits of our financial statements and operations, the auditors may seek to contact a sample of our customers to confirm that our records are accurate. However, these auditors cannot use personally identifiable information for any secondary purposes.
Internet Address Information
We use IP addresses, browser types and access times to analyze trends, administer the site, improve site performance and gather broad demographic information for aggregate use.
CLA does not tolerate spam – even by Providers in the CLA network. We strictly enforce our Anti-Spam Policy! To report CLA-related spam to CLA, please contact us.
When you sign up for a CLA account, you may become eligible to participate in a referral program if one is currently active. If you choose to do so, your first and last name may be listed in communications with the person whom you refer. In addition the amount of bonus you have earned or will earn may be indicated.
D. Information Security
CLA is committed to handling your customer information with high standards of information security. No credit card or bank account information is stored on any CLA computers. We maintain physical, electronic and procedural safeguards that comply with federal regulations to guard your nonpublic personal information. We test our security systems regularly.
The security of your CLA account also relies on your protection of your CLA password. You may not share your CLA password with anyone. If you do share your CLA password with a third party for any reason, including because the third party has promised to provide you additional services such as account aggregation, the third party will have access to your account and your personal information, and you may be responsible for actions taken using your password. If you believe someone else has obtained access to your password, please change it immediately by logging in to your account and changing your Profile settings, and also contact us right away.
CLA will never ask you to send your password or other sensitive information to us in an e-mail, though we may ask you to enter this type of information on the CLA website, which will always have a URL beginning with https://www.CLAHealthcare.com/ in your browser’s address.
Any e-mail or other communication requesting your password, asking you to provide sensitive account information via email, or linking to a website with a URL that does not begin with https://www.clahealthcare.com/ should be treated as unauthorized and suspicious and should be reported to CLA immediately by forwarding the email to CardholderServices@CLAHealthcare.com with any information that you think might be helpful.
E. Accessing and Changing Your Information
You can review the personal information you provided us and make any desired changes to such information, or to the settings for your CLA account, at any time by logging in to your account on the CLA Web site and changing your preferences in your Profile page. You can also renew or close your account through the CLA Web site. If you close your CLA account, we will mark your account in our database as “Closed,” but will keep your account information in our database for a period of time. This is necessary for several reasons including customer service analysis to improve our service, the possibility of communications with you to tie up any loose ends, or invite you back to CLA at some point in the future. However, if you close your account, your personally identifiable information will not be used by us for any other purposes, nor sold or shared with third parties, except as necessary to prevent fraud and assist law enforcement, or as required by law.
F. Contacting Us