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Concordia Plan Services Privacy Policies

Privacy Policy for the Website and CPS Portals

PLEASE READ THIS PRIVACY POLICY CAREFULLY BEFORE USING THE WEBSITE OR THE CPS PORTALS. DO NOT USE THE WEBSITE OR THE CPS PORTALS UNLESS YOU AGREE TO THIS PRIVACY POLICY.

This Privacy Policy describes the types of information CPS may collect about you, your dependent(s) (in the case of a member), and the employees and agents authorized to Use the Website or the CPS Portals on your behalf (in the case of an employer). It also describes how we may use and disclose this information. By Using the Website or the CPS Portals, you agree that you have read the Privacy Policy, understand it, and agree to be bound by it and any revisions CPS may publish.

A. Effective Date
This Privacy Policy is effective as of August 7, 2018.

B. Definitions For purposes of this Privacy Policy:
  1. "CPS," "our," "us," or "we" means Concordia Plan Services.
  2. "CPS Portals" means the CPS Member Portal and the CPS Employer Portal offered by CPS for purposes of benefits administration, both of which are accessible through the Website.
  3. "Use" or "Using" means accessing, processing, viewing, displaying, and downloading from the Website or the CPS Portals.
  4. “Website” means the Concordia Plan Services website, including but not limited to www.concordiaplans.com.

C. Information We Collect
  1. Personal Information. To conduct our business and operate the Website and the CPS Portals, we may collect personal information about members, members’ dependents, employers, and the employees and agents authorized to Use the Website or the CPS Portals on their behalf, from applications or other forms, health plans and providers, members’ employers, and our partners (collectively, “Personal Information”). This information usually identifies the member, the member’s employer, and/or the employer’s authorized employee or agent as the source, and may include such data points as name, address, telephone number(s), email address, Social Security or employee identification number, account numbers, and benefits information and related health information. In some circumstances (for example, when registering for either of the CPS Portals), a member, employer, or their authorized employee or agent may provide us with additional personal information.
  2. Usage Information. When a user navigates the Website or the CPS Portals, we may collect additional information from the user that may not by itself reasonably identify the user as the source (collectively, “Usage Information”). Usage Information may include information regarding the user's computer, IP address, internet browser used, location from which the user visited the Website or the CPS Portals, type of computer operating system used to access the Website or the CPS Portals, domain name of the website from which the user linked to the Website or the CPS Portals, and/or the areas of the Website or the CPS Portals visited and the actions performed on the Website or the CPS Portals. We will take reasonable measures to ensure that the Usage Information we collect is not personally identifiable and may not later be easily used to identify the user, except in the case of fraud checks or as otherwise required by applicable law.
  3. Cookies and Other Tracking Technologies. We utilize cookies to facilitate user navigation of the Website and the CPS Portals. A cookie is a small data file that is transferred from the Website or the CPS Portals to the user's browser, which enables the Website and the CPS Portal sites to remember and customize subsequent visits. The user can instruct his or her browser to block the acceptance of cookies or to provide a warning prompt before cookies are accepted. If the user rejects cookies, the functionality of the Website or the CPS Portals may be diminished or the Website or CPS Portals may not function at all. The use of cookies by any third-party sites accessed through a link from the Website or the CPS Portals is not covered by this Privacy Policy. In addition to cookies, the Website or the CPS Portals may use other tracking technologies, including but not limited to Marketo, Qualtrics, and Hotjar, to collect information automatically as a user browses the Website, the CPS Portals, and the web.

D. How We Use and Disclose Information About You
  1. General Uses and Disclosures. We may use and disclose Personal Information and Usage Information for a variety of business-related purposes, including, but not limited to, contacting the user in response to inquiries; analyzing user browsing and usage activities and patterns in order to understand user preferences with respect to the Website and the CPS Portals; and managing our everyday business needs.
  2. Plan Administration. In addition to the General Uses and Disclosures described above, CPS may tabulate Personal Information or Usage Information for statistical purposes, and may provide the tabulated data to third parties for plan administration purposes. The tabulated data will not personally identify the user, any member, or any member’s dependents.
  3. Third Parties. If and to the extent permitted or required by law, we may disclose Personal Information and Usage Information to third parties, such as service providers that help us manage our daily operations (for example, maintaining and hosting the Website or the CPS Portals), our benefit plan administrators as necessary (for example, to effectuate benefit elections), employers, and providers of other complementary services.
  4. Law Enforcement, Safety, and Legal Processes. We may disclose Personal Information or Usage Information to law enforcement or other government officials related to a criminal investigation or alleged criminal activity. We may also disclose this information if required or permitted to do so by law; for fraud protection and credit risk reduction purposes, or in the good-faith belief that such action is necessary to protect and defend the rights or property of CPS or the users of the Website or CPS Portal; to act under urgent circumstances to protect the safety of CPS, its employees, or members of the public; and to comply with a judicial proceeding, court order, subpoena, or legal process.
  5. Sale or Acquisition of Assets. If we become involved in a transaction involving the sale of our assets (such as a merger or acquisition), or if the Website or the CPS Portals are transferred to another company, we may disclose Personal Information and Usage Information to the other entity or entities involved. If we are not the surviving entity in that transaction, the surviving entity may use and disclose Personal Information and/or Usage Information pursuant to its own privacy policies and practices, which may differ from this Privacy Policy.

E. No Sale of Personal Information
We do not rent, sell, or lend mailing lists, telephone numbers, or email addresses to third parties outside CPS or The Lutheran Church—Missouri Synod. However, as described in paragraph D.3 above, we may disclose such information to service providers and benefit plan administrators as necessary.

F. Security of Personal Information
No information transmitted over or accessible through the Internet is or can be absolutely secure. While we will implement reasonable and appropriate safeguards to protect the confidentiality, integrity, and availability of Personal Information and Usage Information, we do not guarantee or warrant that it will be completely secure from misappropriation or misuse, or from a security event affecting computer hardware, software, or networks. We will notify you and/or your authorized employee or agent of known or suspected security incidents and/or privacy breaches involving Personal Information as required by applicable law. By providing an email address to us, the user agrees to receive any such notice electronically.

G. Other Provisions
1. California Privacy Rights. Under California law, California residents have the right to request that businesses tell them how their personal information has been shared, if at all, with third parties for the third parties’ direct marketing purposes. To make such a request, please contact us at the contact information listed below.
2. Do Not Track. Certain web browsers and other devices used to access the Website or the CPS Portals may permit the user to indicate a preference not to be "tracked" on line. At this time, the Website and the CPS Portals do not respond to "Do Not Track" signals.
3. Children Under 13. The Website and the CPS Portals are not intended for Use by children under the age of 13. We do not knowingly collect any Personal Information from children under the age of 13 through the Website or the CPS Portals. If you are aware of a child under the age of 13 using the Website or CPS Portal, please alert us at the contact information listed below.
4. Accessing and Correcting Your Personal Information. You have the right to access, update and correct factual inaccuracies in your Personal Information that we collect through the Website or the CPS Portals, subject to certain exceptions. To do so, you should log into your account or you may call us at 1-888-927-7526 or e-mail us at info@concordiaplans.org. To help protect your privacy and the security of your personally identifiable information, we will take reasonable steps to verify your identity before granting access.
5. Third Party Links. The Website and the CPS Portals may contain links to websites not affiliated with CPS. Use of an external website or any informational content found on an external website is subject to and governed by the terms and guidelines of that website. CPS does not endorse or make any representations or warranties concerning, and will not in any way be liable for, any informational content, products, services, software, or other materials available on an external website, even if one or more pages of the external website are framed within a page of the Website or the CPS Portals. CPS is not responsible for the privacy practices of any external website.
6. Updates to this Privacy Policy. We may periodically revise the Privacy Policy in our sole and absolute discretion to reflect changes in our business practices. If we revise the Privacy Policy, we will notify users by posting the updated Privacy Policy on the Website and the CPS Portals. Changes to the Privacy Policy will become effective and will apply to the information collected starting on the date we post the revised Privacy Policy on the Website and the CPS Portals. Continued use of the Website or the CPS Portals after any change has become effective will constitute acceptance of any change.
7. Governing Law. This Privacy Policy is governed by the laws of the State of Missouri, notwithstanding the choice of law provisions of the venue where any action is brought, where the violation occurred, where the user may be located, or any other jurisdiction.

H. Comments and Questions.
If you have a comment or question about the Privacy Policy, please contact us at:
Concordia Plan Services
1333 South Kirkwood Road
Saint Louis, Missouri 63122
info@concordiaplans.org
1-888-927-7526