SPS Community Solutions Privacy Policy
Last update: May 2023

PRIVACY IS IMPORTANT TO US. PLEASE READ THIS PRIVACY POLICY BEFORE USING THE SPS COMMUNITY SOLUTIONS (“SPSCS”) WEBSITE OR SERVICES.

This Privacy Policy describes the types of information collected from our individual users when accessing or using the SPSCS website www.spscs.com and any software offered by SPSCS, including our referral management software and client portal (together, the “Website”) or additional services from the SPSCS team, as applicable (collectively, the “Services”). This Privacy Policy also explains how we may use and disclose such information. 

BY USING THE SERVICES, YOU ARE CONSENTING TO THE TERMS DESCRIBED IN THIS PRIVACY POLICY AND THE SPSCS TERMS AND CONDITIONS. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY OR THE TERMS AND CONDITIONS, DO NOT ACCESS OR USE THE SERVICES. We may revise and update this Privacy Policy, or the Terms and Conditions from time to time with or without notice. Your continued use of the Services means you accept those changes.

I. INFORMATION SPSCS COLLECTS AND HOW WE USE IT

This section describes the types of personal information we may collect about you. Such information is generally collected either (i) directly from your voluntary engagement with the Services (for example, by entering information into data fields on the Website or contact us via email, phone, or chat bot); (ii) automatically from you when you interact with the Services; or (iii) from your Managed Care Plan (“MCP”), Managed Long-Term Care health plan (“MLTC”), or Home Care Agency (“HCA”).

If you decline to provide certain information while using the Services, you may not be able to use or participate in some or all of the features offered through the Services.

The following categories of personal information we may collect about you includes:

• Contact and account information. In order to set up an account we may collect your name, signature, phone number, mailing address, and email address.

• Financial information. To prepare and/or process applications and recertifications, we may collect your banking information, including account type, account number, account balance, and transaction history, billing address, and other financial information.

• Health-related information. To provide the Services, we may collect your health information such as medical conditions, care, or health risk status.

• Social security number or government identification. We may collect identification information such as your social security number or state driver’s license in order to provide the Services.

• Insurance information. By providing the Services, we may collect your Medicare or Medicaid policy number or other health insurance information.

• Feedback information. To receive and respond to your customer service requests or comments on your experience with SPS, we may collect your name, phone number, address, email address, images, and any relevant history.

• Application or Recertification information. We may collect the above information as well as your signature, demographics such as date of birth, gender, occupation, income, and marital status to complete an application or recertification.

• Browser or Device Information: When you interact with our Website, we may automatically collect information about the computers, phones, and other devices you are using (e.g. IP address, browsing and search history, WiFi information, device attributes, operating system version, etc.).

• Website Usage: So that we may understand and improve on the user experience and functionality of the Website, we may collect information about how you interact with the Website such as mouse movements, clicks, keystrokes, the date of your visit, the time spent on pages of the Website, or other actions.

Personal information that is automatically collected may be obtained through cookies and similar technologies. Cookies are small files that are stored on your computer or mobile device through a user ID or other preferences. We use cookies to personalize your experience when you use the Services (e.g. auto-populating your log-in credentials or settings). You are free to set your browser or operating system settings to limit certain tracking or to decline cookies, but by doing so, you may not be able to use certain features through our Website or take full advantage of all our services. For more information about these technologies, please see our section on COOKIES, WEB BEACONS, AND OTHER WEB TECHNOLOGIES below.

B. INFORMATION SPSCS COLLECTS FROM THIRD PARTIES

We may supplement information about you from third parties such as healthcare professionals; data brokers; insurance companies; third party administrators; service providers; vendors; banking and other financial institutions; affiliates; business partners; customers, social media platforms; and government agencies or public records, so that we may provide the Services.

II. HOW SPSCS USES COLLECTED INFORMATION

SPSCS uses the information it collects for the following purposes:

• To provide you with the Services
• To provide you with updates regarding your application or recertification
• To address your inquiries and requests
• To contact and manage our relationship with you
• To manage your SPSCS account
• To ensure proper functionality of the Website and the Services
• To analyze usage trends and enhance or improve the Website and the Services
• To protect against fraud or other illegal activities
• For other purposes disclosed at the time you provide your information or otherwise with your consent SPSCS uses your information only for the purposes for which it was collected and in accordance with this Privacy Policy.

III. SECURITY AND RETENTION POLICY

SPSCS will retain your personal information for as long as is necessary to fulfill the purposes outlined above unless we are required to do otherwise by applicable law. This includes retaining your personal information to provide you with the Services you have requested and interact with you; maintain our business relationship with you; improve our business over time; or otherwise in accordance with our internal retention procedures. When we no longer need
the personal information we collect, we either deidentify the information or securely destroy the information.

SPSCS has put in place reasonable and appropriate security measures to protect the information collected via the Website and the Services. However, note that the confidentiality of information transmitted over the Internet cannot be guaranteed. Please exercise caution when transmitting information over the Internet and through the Website. SPSCS does not and cannot guarantee that unauthorized third parties will not gain access to your information. It is also very important that you do not share your username or password with anyone. You are responsible for all activity that occurs under your account. To the extent SPSCS stores certain information using its third-party hosting service provider Amazon Web Services and does not make any warranty regarding the privacy or security of any information stored by Amazon Web Services.

IV. COOKIES, WEB BEACONS, AND OTHER WEB TECHNOLOGIES

SPSCS utilizes automatic data collection to enhance the Website and the Services. The web technologies SPSCS may use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website or the Services. Unless you have adjusted your browser settings so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.

• Flash Cookies. Certain features of the Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Website.

• Web Beacons. The Website and SPSCS emails may contain small electronic files known as web beacons (also known as clear gifs, pixels, tags, and single-pixel gifs) that allow us to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

• Log Files: Log files are pieces of information that inform how users are accessing the Website. For example, each time you visit the Website, it may create a log file that someone visited the page. Log files can be used to create aggregate reports of Website activity.

• Do Not Track Mechanisms. Because there is no consensus on how companies should respond to web browser-based do-not track (“DNT”) mechanisms, our system will not recognize or respond to Do Not Track requests or headers at this time.

V. HOW PERSONAL INFORMATION MAY BE DISCLOSED

By using our Services, you consent to SPSCS’s disclosure of your personal information with our affiliate companies and any applicable MCP/MLTC or HCA on a confidential basis in order to provide the Services and without further consent from you.

In addition, SPSCS reserves the right to comply with the law and to release your information for the following reasons:

• Legal Matters. In response to subpoenas, regulatory or judicial processes, governmental requests and investigations, or as otherwise required by law.

• To Prevent Fraud or Illegal Activity. If we reasonably believe that there has been a violation of the Terms and Conditions or to protect the security of the Website, Services, and any SPSCS servers, network systems, and databases.

VI. THIRD-PARTY WEBSITES

The Website and Services may contain or suggest links to other websites or internet resources. When you click on one of those links, you are contacting another website or resource. SPSCS has no responsibility or liability for, or control over, those other websites or resource or their collection, use and disclosure of your information, and our Privacy Policy does not apply to personal information collected through these websites or resources. We suggest that you read the privacy policy and terms of use of each such website.

VII. CHILDREN'S PRIVACY

The Services are not intended for use by children under the age of 18. In accordance with the Children’s Online Privacy Protection Act of 1998, SPSCS does not knowingly request information from anyone under the age of 13 without parental consent.

VIII. CHANGES TO THIS PRIVACY POLICY

SPSCS may change this Privacy Policy from time to time. We encourage you to routinely check this page for any changes thereof. By continuing to access or use the Website or the Services you agree to accept any revised terms.

IX. CONTACT US

If you have any questions or concerns about this Privacy Policy or elect to Opt-Out from receiving communications from SPSCS, please contact us at privacy@spscs.com.

Please make sure to include your name, e-mail address, and phone number.