To: Nova Pathfinder Health Plan Members,
Effective January 1, 2020

Nova Pathfinder Healthcare respects its members’ privacy. This Privacy Policy (“Policy”) will help you understand how we gather and utilize personal information from individuals who visit our website or use our online facilities and services, as well as what we will and will not do with the information we collect.

Our Policy was established and developed to assure individuals associated with Nova Pathfinder Healthcare of our dedication and fulfillment of our responsibility to not only meet, but also exceed, most current privacy requirements.

We reserve the right to make changes to this Policy at any time. If you want to remain up to date on the newest developments, we recommend that you visit this page on a regular basis.

If, at any time, Nova Pathfinder Healthcare chooses to use any personally identifiable information on file in a way that differs significantly from that indicated when this information was first obtained, the user or users will be immediately informed by email.

Users will have the choice to allow the usage of their information in this separate manner at that time. This Policy applies to Nova Pathfinder Healthcare and regulates the collection and use of data by us.

You are therefore agreeing to the data collecting methods outlined in this Policy by using the website Mynovahealthcare.org.

Please be aware that this Policy does not apply to the collecting and use of information by businesses that Nova Pathfinder Healthcare does not own or control, or by people who are not employed or managed by us.

If you visit a website that we reference or link to, please read its privacy statement before giving any information to the site. It is strongly advised and encouraged that you review the privacy policies and statements of each website you choose to use or visit to make better choices, and to understand the way websites gather, utilize, and disseminate information

Specifically, this Policy will inform you of the following:

1. What personally identifiable information is collected from you through our website;
2. Why we collect personally identifiable information and the legal basis for such collection;
3. How we use the collected information and with whom it may be shared;
4. What choices are available to you regarding the use of your data; and
5. The security procedures in place to protect the misuse of your information.

Information we collect

It is always your choice whether to provide us with personally identifiable information, but if you do not, we retain the right not to register you as a user or provide you with any products or services. This website collects a various information, including:
• Voluntarily provided information, such as your name, address, email address, billing and/or credit card information, and so forth, that may be used when you purchase products and/or services and to provide the services you have requested.

• Information automatically collected when visiting our website, that may include

cookies, third party tracking technologies and server logs

Moreover, Nova Pathfinder Healthcare may be required to collect non-personal anonymous demographic information such as age, gender, household income, political affiliation, race, and religion, as well as the type of browser you are using, IP address, or type of operating system, to provide and maintain superior quality service. Nova Pathfinder Healthcare may also consider it essential, from time to time, to monitor websites that our users visit to determine what kinds of services and goods are most popular among clients or the public.

Please be assured that we will only collect personal information that you voluntarily and freely give to us via surveys, completed membership forms, and emails. This site intends to use personal information solely for the purpose for which it was obtained, as well as any extra purposes expressly permitted by this policy.

Why we collect information and for how long

We are collecting your data for several reasons:

▪ To better understand your needs and provide you with the services you have requested;

▪ To fulfill our legitimate interest in improving our services and products;

▪ To send you promotional emails containing information we think you may like when we have your consent to do so;

▪ To contact you to fill out surveys or participate in other types of market research, when we have your consent to do so;

▪ To customize our website according to your online behavior and personal preference

We will keep data we gather from you for no longer than is required. The length of time we keep said information will be determined by the following criteria: the length of time your personal information remains relevant; the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations; any limitation periods within which claims may be made; and any retention periods prescribed by law or recommended by regulations.
Use of Information Collected

Nova Pathfinder Healthcare does not now, nor will it in the future, sell, rent, or lease any of its customer lists and/or names to any third parties. Nova Pathfinder Healthcare may collect and may make use of personal information to assist in the operation of our website and to ensure delivery of the services you need and request. We may consider it necessary to utilize personally identifiable information to keep you aware of additional potential products and/or services available to you from www.Mynovahealthcare.org at times.
Nova Pathfinder Healthcare may also contact you to complete surveys and/or research questionnaires about your opinion of existing or possible future services that may be provided. Nova Pathfinder Healthcare uses third-party social media tools such as Facebook, Twitter, LinkedIn, Instagram, and other interactive applications. These may gather your IP address and require the use of cookies to function correctly. These services are controlled by the providers’ privacy rules and are not under the authority of Nova Pathfinder Healthcare.

Disclosure of Information

Nova Pathfinder Healthcare may not use or disclose the information provided by you except under the following circumstances:

▪ as necessary to provide services or products you have ordered

▪ in other ways described in this Policy or to which you have otherwise consented

▪ in the aggregate with other information in such a way so that your identity cannot reasonably be determined

▪ as required by law, or in response to a subpoena or search warrant

▪ to outside auditors who have agreed to keep the information confidential

▪ as necessary to enforce the Terms of Service

▪ as necessary to maintain, safeguard and preserve all the rights and property of Nova Pathfinder Healthcare.

Non-Marketing Purposes

Nova Pathfinder Healthcare values your privacy. We will continue to contact you for non-marketing reasons (such as bug warnings, security breaches, account problems, and/or changes in Nova Pathfinder Healthcare products and services). In certain cases, we may publish a notice on our website, in newspapers, or in other public places.

Children Under The Age of 13

The Nova Pathfinder Healthcare website is not intended for minors under the age of thirteen, and no personally identifiable information is intentionally collected from them (13). If it is determined that such information was collected inadvertently on anyone under the age of thirteen (13), we will take the necessary steps to ensure that such information is deleted from our system’s database, or that verifiable parental consent is obtained for the use and storage of such information. Anyone under the age of thirteen (13) must seek and receive permission from a parent or adult to access this website.

Unsubscribe or Opt-Out

All users and visitors to our website have the option to opt out of getting emails or newsletters from us. To stop or unsubscribe from our website, please send an email to Mynovahealthcare.org with the subject “Unsubscribe.” If you want to unsubscribe or opt-out from any third-party websites, you must go to that particular website. We shall continue to follow this Policy regarding any previously acquired personal information.

Links to Other Websites

Our website contains links to affiliate and third-party websites. Nova Pathfinder Healthcare makes no claim to, and accepts no responsibility for, the privacy policies, practices, and/or processes of other websites. As a result, we urge all users and visitors to be cautious when leaving our website and to read the privacy policies of any website that collects personally identifiable information. This Privacy Policy Agreement only applies to information collected by our website.

Notice to European Union Users

Nova Pathfinder Healthcare’s operations are located primarily in the United States. If you provide information to us, the information will be transferred out of the European Union (EU) and sent to the United States. (The adequacy decision on the EU-US Privacy became operational on August 1, 2016. This framework protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes. It allows the free transfer of data to companies that are certified in the US under the Privacy Shield.) By providing personal information to us, you are consenting to its storage and use as described in this Policy.

Your Rights as a Data Subject

Under the regulations of the General Data Protection Regulation (“GDPR”) of the EU you have certain rights as a Data Subject. These rights are as follows:

▪ The right to be informed: this means we must inform you of how we intend to use your personal data and we do this through the terms of this Policy.

▪ The right of access: this means you have the right to request access to the data we hold about you and we must respond to those requests within one month. You can do this by sending an email to Lj@mynovahealthcare.org.

▪ The right to rectification: this means that if you believe some of the date, we hold is incorrect, you have the right to have it corrected. You can do this by logging into your account with us, or by sending us an email with your request.

▪ The right to erasure: this means you can request that the information we hold be deleted, and we will comply unless we have a compelling reason not to, in which case you will be informed of same. You can do this by sending an email to: Lj@mynovahealthcare.org.
▪ The right to restrict processing: this means you can change your communication preferences or opt-out of certain communications. You can do this by sending an email to: LJ@mynovahealthcare.org.

▪ The right of data portability: this means you can obtain and use the data we hold for your own purposes without explanation. If you wish to request a copy of your information, contact us at LJ@mynovahealthcare.org.

▪ The right to object: this means you can file a formal objection with us regarding our use of your information with regard to third parties, or its processing where our legal basis is our legitimate interest in it. To do this, please send an email to LJ@mynovahealthcare.org.

In addition to the rights listed above, please know that we will always make efforts to encrypt and anonymize your personal information wherever feasible. We also have procedures in place in the unlikely event that a data breach occurs, and we will notify you if your personal information is ever compromised.

For additional information on our security measures, please read the section below or visit our website at www.mynovahealthcare.org

Security

Nova Pathfinder Healthcare takes precautions to safeguard your personal information. When you submit sensitive information via the website, it is secured both online and offline. Wherever we gather sensitive information (for example, credit card information), it is encrypted and sent to us in a secure manner. You can check this by checking for a lock symbol in the address bar and “https” at the beginning of the webpage’s URL. While we utilize encryption to safeguard sensitive online information, we also protect your information offline. Access to personally identifiable information is restricted to workers who need it to perform a particular function (for example, invoicing or customer support). We keep the systems and servers where we hold personally identifiable information in a safe environment. All of this is done to avoid the loss, misuse, unauthorized access, disclosure, or alteration of the user’s personal information while it is in our control. The business also employs Secure Socket Layer (SSL) for authentication and private communications to increase customers’ trust and confidence in the internet and website usage by enabling easy and secure access to and transmission of credit card and personal information. Furthermore, Nova Pathfinder Healthcare is a TRUSTe licensee. VeriSign also secures the website.

Acceptance of Terms

By using this website, you agree to the terms and conditions outlined in the Privacy Policy Agreement. If you do not agree with our terms and conditions, please do not use our website any longer. Additionally, your continued use of our website after the publication of any updates or modifications to our terms and conditions constitutes your agreement and acceptance of such changes.

How to Contact Us

If you have any questions or issues about our website’s Privacy Policy Agreement, please contact us at the email, phone number, or postal address shown below.

Email: LJ@mynovahealthcare.org
Phone: (833) 444-6682 (NOVA)
Mailing Address: Nova Pathfinder Healthcare, 5739 Kanan Rd., Suite 336, Agoura, CA 91301

The data controller responsible for your personal information for the purposes of GDPR compliance is: LJ@mynovahealthcare.org

Nova Pathfinder Healthcare is experiencing a temporary service outage for new members in the state of Idaho. For questions or to get a quote contact member services at 833-444-6682.