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TriWest Privacy Policy

Introduction

TriWest Healthcare Alliance Corp. ("TriWest", "our", "us" or "we") is committed to protecting the privacy of our providers, beneficiaries and those who use or access our websites. This Privacy Policy (the "Policy") describes TriWest's privacy policies and defines the use, disclosure and maintenance of personal information collected from you when you visit or interact with our website(s) or receive services from us. Additionally, this Policy indicates the choices and options you have regarding your personal information, the specific state laws that govern the personal information collected and the rights available to residents of such states. The TriWest Websites and the services we provide are hosted in the United States.

Consent

You may have access to and use of TriWest-controlled websites including TriWest.com, HealthyHomefront.com and/or the TriWest Veteran Portal (the "TriWest Websites") and certain services that are offered through them (the "Services"). If you use the TriWest Websites or the Services, you agree to the collection, use, disclosure and maintenance of the personal information you voluntarily provide to us as described in this Policy. We may change this Policy from time to time and, if we make changes to it, we will publish the revised Policy on this page. You may additionally have access to and use of the Availity Provider Website, however, this website is not controlled by TriWest and is subject to the terms of use and privacy policies of Availity, LLC.

Applicability and Scope

This Policy applies to the Services and other features, content or applications offered from time to time by TriWest in connection with the Services and describes how TriWest collects, uses, discloses, and maintains information, including personally identifiable information ("PII") and protected health information ("PHI"), that you provide to us and information we collect automatically related to your use of the TriWest Websites and Services. When collecting, using, disclosing or processing information, TriWest does so exclusively on the behalf of government agencies, including the VA and DoD, as a contracted service provider of third party administrator services.

This Policy does not apply to:

  • information collected by us offline;
  • the practices of companies that TriWest does not own, govern, or control;
  • content or information not generated or created by TriWest;
  • any information or data provided by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Services; and/or
  • acts of people that TriWest does not employ, supervise, control or manage.

Personal Information, Sources and Use

TriWest collects information that personally identifies you ("Personal Information" or "Personal Data") under certain circumstances, for example when you visit the TriWest Websites, apply or use the Services, or when you provide your information to us so that we may contact you about the benefits and services provided by TriWest under certain contracts with the U.S. Department of Veterans Affairs ("VA") and the U.S. Department of Defense ("DoD"). We also may collect Personal 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 and health care providers, information service providers and the parties with whom we share information as described in this Policy. "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.

Additionally, TriWest may collect PII, which means individually identifiable information that is from or about an individual, including, but not limited to:

  • Contact information (such as name, address, email address and telephone number);
  • Demographic information (such as age, date of birth, gender, marital status, ZIP code, and household composition); and
  • Social Security number.

TriWest does not collect payments from Veterans under VA's Community Care Network contract. TriWest may collect fees or premiums related to the DoD's 5th Generation TRICARE Managed Care Support Contract under certain circumstances, but credit card and other payment-related data will not be stored on databases or systems owned by TriWest

For information on how VA handles and protects your information, please read VA Notice of Privacy Practices.

For information on how DoD handles and protects your information, please read Military Health System Notice of Privacy Practices. You can also request a copy of the Notice of Privacy Practices from a military hospital or clinic (also referred to as "military treatment facilities" or "MTFs").

Categories of Personal Information Collected by TriWest in the Preceding 12 Months

The categories of Personal Information that TriWest may have collected within the last twelve (12) months are listed below:

  • Identifiers, including first and last name, alias, home address, physical address or postal (mailing) address, telephone numbers, email address, username, and password (in combination with security questions and answers), IP addresses, device IDs, driver's license number, government-issued identification, Social Security number, student, military or passport number, health insurance identification number and other similar identifiers;
  • Personal Information including marital status, sex, age, date of birth, gender, gender identity, race, religion, ancestry, national origin, physical disability, sexual orientation, medical condition, medical information, health care information, insurance information, genetic information and military status and other medical information;
  • Biometric information or data, including finger prints or an image of a face;
  • Commercial information, including, but not limited to, an account, account number, credit card or debit card numbers; and transaction information, payment and invoicing information, products or services purchased or rendered, purchasing or consuming histories and other financial data;
  • Internet/Network Activity Information, including browsing history, browsing patterns, search history and a visitor's interactions with and uses of any of the TriWest Websites and related applications and platforms, and including the internet service provider enabling access to the internet, domain name, the IP address of the computer used, the name of the page that referred a visitor to TriWest, the date and times a visitor entered and exited any of the TriWest Websites, the pages a consumer visited before and after visiting or accessing the TriWest Websites, the web pages, video content and advertisements viewed and links clicked within the TriWest Websites, and information or data collected through web log data, cookies, web beacons and third-party analytics and targeted advertising as described and set forth in this Policy;
  • Geolocation Data, such as device location;
  • Audio, electronic and visual or other similar information, such as video recordings and phone calls;
  • Professional or employment-related information, including current employer name, job title, work history, prior employers and all data included in resumes submitted to TriWest;
  • Education information, including the name of college or university attended and graduation date; and
  • Inferences, made or drawn from any of the Personal Information identified above, including individual's characteristics and preferences.

Categories of Sources of Personal Information Collected by TriWest and Shared with Third Parties

  1. General Sources

    The categories of sources of Personal Information that may have been collected by TriWest and that TriWest may share with third parties includes information obtained directly from you or your authorized Agent, for example, if you (or your authorized Agent) contact TriWest and provide information to TriWest or register or apply for any Services, information obtained from your device or browser and information from your activity or interactions on the TriWest Websites and related platforms and applications. We may also collect information from vendors, service providers, health care providers, and subcontractors, including our providers of professional, legal, consulting, marketing, communications, financial, business development, analytic services, marketing vendors and advertising networks. Information may be collected from publically available sources, records and databases information (including from social media). We may collect information from your employer, including professional or employment-related information and information from your college, university, or other educational institutions. Additionally, we may gather information from federal, state, local governments, including government departments and agencies like VA and DoD and information made available pursuant to applicable laws.

  2. Information Collected from Your Use of TriWest Websites

    We collect information in the aggregate through the use of cookies and internet protocol ("IP") addresses, which includes, but is not limited to, demographic information and browsing patterns, 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 TriWest Websites, the pages you visit before and after vising the TriWest Websites, the web pages, video content and advertisements you view and links you click on while using the TriWest Websites, 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 Personal Information.

Categories of Third Parties with Whom TriWest Shares or Discloses Personal Information

TriWest may share and disclose Personal Information and Other Information we collect about you with our affiliates and subsidiaries (if any) and certain vendors, service providers, healthcare providers, and subcontractors including providers of professional, legal, consulting, marketing, communications, financial, business development, and analytics services. We may also share Personal Information with VA and DoD representatives and with other third party companies that we collaborate with or hire to perform certain services on our behalf, when necessary to provide you with requested Services and as necessary to fulfill our obligations as a third party administrator of certain contracts with VA and DoD. For instance, we may hire companies to host or provide hosting services in connection with TriWest Websites and related computers, platforms and software applications. We may also disclose Personal Information to your authorized Agent (with your consent). Additionally, we may share your Personal Information with local, state and federal governmental and law enforcement authorities, other entities as required in connection with civil, administrative and/or criminal legal actions and lawsuits and other entities in the event of any change in control, merger or acquisition.

Business Purposes for Which Personal Information is Collected

TriWest collects, shares, processes and discloses Personal Information pursuant to one or more of the "Business Purposes" set forth below. A "Business Purpose" is defined as "the use of personal information for the business's or a service provider's operational purposes, or other notified purposes, provided that the use of personal information shall be reasonably necessary and proportional to achieve the operational purpose for which the personal information was collected or processed or for another operational purpose that is compatible with the context in which the personal information was collected." The sharing, processing or disclosure of Personal Information will not be deemed a "sale", if such information was used in connection with one or more business purpose(s) and such business purpose(s) are exceptions to the prohibition against selling, disclosing, processing or sharing Personal Information.

TriWest's General Business Purpose(s) for the Collection of Personal Information – To Assist in the Provision of Health Care Services to Veterans/Beneficiaries in Accordance with the Regulations and Contracts Established by VA and DoD

TriWest is a third party administrator for VA and Managed Care Support Contractor for DoD. We use your Personal Information or Personal Data as necessary to fulfill and comply with our duties under contracts with VA for the Community Care Network ("CCN"), DoD for the 5th Generation TRICARE Managed Care Support Contract ("T-5") and other contracts awarded to TriWest as established by VA and DoD from time to time. TriWest Services include, but are not limited to, creating and establishing credentialed community providers that partner with VA and DoD to provide health care to Veterans/Beneficiaries in their local communities in accordance with VA's and DoD's contractual requirements, policies and applicable federal regulations (the "General Business Purpose").

TriWest's Specific Business Purposes for the Collection of Personal Information

In the last twelve (12) months, TriWest may have collected, used, shared, processed and disclosed Personal Information or Personal Data for the below specific Business Purposes (the "Specific Business Purpose(s)"), which include, but are not limited to, the following:

  • To assist Veterans, Beneficiaries and consumers with the provision of health care services in accordance with the contracts , procedures, directives, policies, rules and regulations established by VA and DoD;
  • To provide a product or service specifically requested by a consumer, Veteran, Beneficiary or the parent or guardian of a child;
  • To perform a contract to which the consumer, Veteran or Beneficiary is a party, or to take steps at the request of the consumer, Veteran or Beneficiary prior to entering into a contract or to complete a transaction for which the Personal Information was collected, or reasonably anticipated by the consumer within the context of a business' ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer;
  • To protect the vital interests, health, safety, property, or welfare of the consumer, Veteran, Beneficiary or another individual;
  • To perform business operations as needed in connection with TriWest's duties as a third party administrator or contractor to VA for the CCN contract and to, DoD for the T-5 contract and other contracts awarded to TriWest by VA and DoD from time to time and to respond to inquiries from VA and DoD;
  • To process or review an application or other documentation related to health care services for a Veteran, Beneficiary or consumer;
  • To respond to or reply to a particular inquiry or email, or to communicate about an account or a transaction and/or to provide customer service (e.g., to resolve disputes, problems with an account/profile or the services rendered);
  • To provide information that TriWest believes may be useful or necessary, including, but not limited to, a welcoming email, user name and password, verification emails, special updates and/or newsletters, services announcements, to provide information about TriWest Websites, applications, Services, and information from VA and DoD and/or changes to our policies or procedures;
  • To perform internal operations that are reasonably aligned with the expectations of the Veteran, Beneficiary and consumer based on the consumer's existing relationship with the controller or to otherwise use the consumer's Personal Information, internally, in a lawful manner that is compatible with the context in which the consumer provided the information;
  • To provide, administer, develop, modify, improve, assess, manage, evaluate, and/or enhance TriWest's products, Services and/or the TriWest Websites, including, but not limited to, its computer network, platforms and/or applications, and to conduct internal research, institutional risk assessments, risk modeling and statistical analysis to improve, repair or develop products and services, or technology and to and to develop and perform business or data analytics;
  • To identify and repair technical errors that impair existing or intended functionality, to debug computer networks, related software, platforms, the TriWest computer network infrastructure and the TriWest Websites and/or repair errors that impair existing intended functionality;
  • To detect, investigate, mitigate and prevent security incidents and other activities that may violate TriWest's policies, pose safety issues or concerns or be fraudulent or illegal, to protect against malicious, deceptive, fraudulent, or illegal activity and/or prosecute those responsible for that activity;
  • To document and maintain records of communications, interactions and transactions between TriWest and/or Veteran beneficiaries, consumers and/or service providers;
  • To investigate, exercise, prepare for, or defend actual or anticipated legal claims, to protect the rights of TriWest, its affiliates, subsidiaries, employees and related third parties, and to take necessary, reasonable and appropriate legal action to: (1) enforce TriWest rights; and (2) protect TriWest's property, assets and employees;
  • To comply with a legal obligation, to comply with federal, state, or local laws, rules or regulations, or to comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summon by federal, state, local or other governmental authorities, or to cooperate with law enforcement agencies concerning conduct or activity that the controller or processor reasonably and in good faith believes may violate federal, state or other governmental authorities;
  • To exercise free speech, ensure the right of another consumer to exercise that consumer's right of free speech, or to exercise another right provided by law;
  • To provide accurate and timely information to our credentialed vendors, service providers and subcontractors that partner with VA and DoD to provide health care to Veterans and TRICARE Beneficiaries in their local communities;
  • To engage in pubic or peer-reviewed scientific, historical, or statistical research that adheres to all other applicable ethics and privacy laws, when the business' deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent;
  • To allow or permit use of the TriWest Websites and our online technologies and/or to personalize the TriWest Websites and certain applications;
  • To provide certain surveys and/or promotions or to provide certain marketing and advertising, with your permission;
  • To commence, participate in, investigate or complete a merger, acquisition and/or reorganization;
  • To receive, review, evaluate and process employment applications; and
  • As otherwise set forth in this Policy as updated by TriWest from time to time.

TriWest's Duties in Connection with Your Personal Information

TriWest will not use, share or disclose your Personal Information (or Personal Data) without your consent, except to fulfill or comply with one or more of the business purposes set forth above and to comply with the business purposes described in this Policy, including to fulfill our obligations as a third party administrator of certain contracts with VA and DoD contracts. We retain information for as long as reasonably necessary to deliver the Services to you and as required by applicable law.

Third-Party Service Providers, Third-Party Websites and Third-Party Links

TriWest uses third-party service providers to perform or develop the Services on our behalf, as necessary to fulfill your request for Services, to meet the terms of any agreement that you have with us or our partners, and to manage our business, including web-hosting companies, email vendors, and analytics providers that maintain or host the TriWest Websites. Our service providers may collect and/or use your Personal Information or Other Information to assist us in achieving the purposes discussed above and 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 and the TriWest Websites may contain links to third-party websites. If you follow a link to any of these third-party 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 such other third party websites. We encourage you, our users, visitors, Veterans and Beneficiaries to read the privacy policies applicable to such third-parties websites. 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, and to improve and promote the efficient administration of the Services.

Technologies Used to Collect Personal Information

We collect Personal Information using a variety of technologies in order to monitor the usage of the TriWest Websites and Services, recognize you when you return to the TriWest Websites or use our Services, store information about your preferences, aid strategic development, manage our relationship with content providers, and to audit usage of the TriWest Websites and the Services. We may share such collected information, in the aggregate form only, with our affiliates, partners or other third parties. The mechanisms and technologies we use to collect Personal Information include all of the following:

  1. 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.
  2. Cookies. We also use cookies on the TriWest Websites and in connection with the Services provided. Cookies are small files that are stored on your computer or other device by your web browser. A cookie allows the TriWest Websites 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 and determine 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 TriWest Websites and the Services may not operate correctly.
  3. Web Beacons. The TriWest Websites and 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.
  4. Third-Party Online Tracking. We may also partner with certain third parties to collect, analyze, and use some of the Personal Information and Other Information described in this Policy. For example, we may allow third parties to set cookies or use web beacons on the TriWest Websites and in connection with the Services provided, or in email communications from us.
  5. Third-Party Plugins. The Services integrate certain third-party plugins. 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 plug-ins are governed by the privacy policies of the companies providing them.
  6. 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 the systems of a third party, 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.

Third-Party Analytics

  1. Analytics

    TriWest partners 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.

    Google Analytics is a web analysis service provided by Google that collects and tracks information such as how often users visits websites, what pages they visit and what other sites they used prior to visiting the TriWest Websites. TriWest uses Google Analytics to better understand how visitors, Veterans and Beneficiaries use the TriWest Websites to improve the browsing experience for our users. Google's ability to use and share information collected by Google Analytics about your visits to the TriWest Websites is set forth in the Google Analytics Terms of Use and the Google Privacy Policy, which may be reviewed as indicated below:

    For more information about Google Analytics, including the option to opt-out, please review the Google Analytics terms and conditions.

    1. Opting Out of Cookies by Google Analytics. You may opt out of the use of cookies by Google Analytics.
    2. Opting Out of Cookies by Google Ads. You may opt out of the use of cookies by Google Ads.

For information about the Google Privacy Policy please review Google's privacy terms and conditions.

Information Collected from Children

The TriWest Websites are general audience websites and are not intended for or directed to minors under the age of 18. We do not knowingly collect Personal Information of minors under the age of 18. If you are 17 years old or under, do not provide Personal Information about you of any kind to TriWest.

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 guarantee or warrant the security of any information you send to the Services or to us, and you send such information at your own risk.

The Services may contain links to third party websites. We have not reviewed these third party sites; do not control, supervise or manage them; and are not responsible for any third party sites, their content, information or their privacy policies. Additionally, we do not endorse, recommend or make any representations or warranties about them, or any of the information, software, products, services or materials found or offered there, or any results that may be obtained from using them. If you decide to access any of the third party sites listed within the TriWest Websites or in connection with the Services, you do so at your own risk.

Communications from TriWest

  1. Permission-Based Email Policy

    Your email address is used to only send you information that you have requested from TriWest. TriWest allows you to elect to receive ("opt-in"), or not receive ("opt out"), certain information. TriWest uses and adheres strictly to a permission-based email policy. Except as set forth below and as needed to fulfill our obligations as a third party administrator of certain contracts with VA and DoD, TriWest will not: (i) send you unsolicited email information, commercial offers or advertisements; or (ii) sell, rent, or loan our contact lists (including provider data) to any outside firms or third parties not involved in the provision of 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 exercised their option to unsubscribe from the specified information.

  2. Special Updates and Newsletters

    Upon registering with one or more TriWest secure site(s), new users, Veterans and Beneficiaries may receive a welcome email to verify their new account and confirm their password and username. Established users may occasionally receive information about services that are available and/or a newsletter. Out of respect for your privacy, we have given you the option to not receive these types of communications. You can unsubscribe using the unsubscribe mechanism at the bottom of each email.

  3. 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.

  4. Customer Service

    We communicate with providers and beneficiaries on a regular basis to provide requested Services and to address issues relating to the provision of health care services under contracts with VA and DoD. We reply via email or phone, in accordance with communication preferences. 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 available to the public.

  5. 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 and 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 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.

  6. Policy Modifications

    We regularly review our Policy 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 TriWest Websites and the Services means that you accept our Policy.

Effective Date: March 22, 2024.

Updated: 5/5/2024 7:50:09 PM