Privacy Notice

Collection of Personal Information

Sometimes we collect Personal Information automatically when an individual interacts with our Services and sometimes we collect Personal Information directly from an individual. At times, we may collect Personal Information about an individual from other sources and third parties.

Personal Information Collected from Site Visitors and Account Holders

The Personal Information we collect and have collected over the last 12 months depends on your interactions with us, and may include:

• Identifiers, including first and last name, email address, mailing address, employer, job title, company name, phone number and communication preferences.
• Inquiry Information, including information provided in custom messages sent through the forms or contact information provided on our Site and through our Services.
• Professional or Account-related Information, including name, company name, employer, job title, email address, username and password, profile information, Edifecs CORE-related information, Edifecs Compliance-related information, Edifecs CommerceDesk-related information, Edifecs ServiceDesk-related information, and any other account information you provide to us.
• Survey Information, including feedback you share with us in connection with surveys we may send you from time to time, and any related testimonials or other content you choose to share with us.
• Commercial Information, such as products or services purchased and other purchasing histories or tendencies, including your subscriber ID, account contact information and transaction-related information.
• Event Information, including registration information, attendee badge information, and contact information.
• Audio, Visual or Other Sensory Information, such as your image when recorded or captured in surveillance camera footage, pictures taken in the workplace, or voice recordings from customer service phone calls between you and Edifecs.

Personal Information Automatically Collected

As is true of most digital platforms, the Personal Information we and our third-party providers collect and have collected over the last 12 months depends upon your interactions with us, and may include:

• Internet and other electronic-related information, such as Personal Information from an individual’s device, browsing actions and site usage patterns automatically collected when visiting or interacting with our Site, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser ID, the URL entered and the referring page/campaign, the date/time of visit, the time spent on our Site and any errors that may occur during the visit to our Site) and analytics data (such as the electronic path taken to our Site, through our Site and when exiting our Site, as well as usage and activity on our Site)
• Geolocation data, such as non-precise geolocation information derived from your IP address.
• Inferences, drawn from any of the information we collect to determine your preferences.

Cookies and other Tracking Technologies

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixel tags, clear gifs, e-tags, flash cookies, log files, embedded scripts, location-identifying technologies, logging technologies or other local storage provided by your browser or associated application (collectively, “cookies”) to automatically collect this Personal Information. These technologies (i.e., cookies) collect information about your use of the Sites and other websites and applications, including your Internet Protocol address, browser type, browser language, pages viewed, links clicked, conversion information, information entered into forms, the date and time of your visit, mobile network information, and time spent on pages or in apps. These cookies may also uniquely identify your browser. We use this information to understand how people interact with our website, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests, and better understand your online activity. For example, our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”), to collect and view reports about the traffic on our Site. More information about the use of Google Analytics for these analytical and non-advertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here.

Most browsers are initially set up to accept cookies. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. If you want to learn more about how to opt-out of receiving targeted advertisements based on your interest, you can visit the NAI's Consumer Opt Out page, which will allow you to opt-out of seeing advertisements set by participating NAI members.

Google Analytics. We use Google Analytics on our website to track usage data and help improve your experience. You can find more information on how Google uses data at https://www.google.com/policies/privacy/partners.

HubSpot. We use HubSpot traffic analytics tool on our website (www.edifecs.com) to track usage data and help improve your experience. You can find more information on how HubSpot uses data at https://legal.hubspot.com/privacy-policy.

Responding to "Do Not Track" Signals. Some browsers incorporate a "Do Not Track" feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. Not all browsers offer a DNT option and DNT signals are not yet uniform. Our Sites are thus not currently set up to respond to these signals. For more information on Do Not Track signals, please visit https://allaboutdnt.com/.

Global Privacy Control (GPC) allows individuals to automatically signal their privacy preferences to websites and other online services through their browser or through an extension. If we receive a GPC signal to opt-out of website tracking, we will honor such requests made on our website (https://www.edifecs.com). We will process a GPC signal in a 'frictionless' manner, meaning we will not require any additional confirmation from you, change your user experience, or display any pop-up notifications upon receiving the signal. Please note that we may not be readily able to associate an opt-out preference signal with other personal information such as your email address. If you configure this setting on your browser, certain features on our Site may not work and you will receive less targeted advertising. You will also need to turn the setting on for each browser that you use.

Opting Out of Cross-Context Behavioral Advertising or Targeted Advertising

We allow third-parties to provide analytics and advertising services and serve advertisements on our behalf across the Internet and in mobile applications. Our advertising partners may collect information about your activities on our Sites on your current device and combine it with information about your activities on other websites, mobile apps, and devices. They may also collect IP address, browser or operating system type and version, and demographic or inferred-interest information, as well as personal information if you have submitted such information to us through the Sites. They collect such information using server logs, cookies, web beacons, tags, pixels, mobile advertising IDs (such as Facebook cookies or Google's Advertising ID), cross-device linking, and similar technologies. For example, our advertising partners may use the fact that you visited our website to target advertising to you on other websites and mobile apps on your current device or on other devices you use. They may match your browsers or devices if you log into the same online service on multiple devices or if your devices share similar attributes that support an inference that they are used by the same person or household. This means that information about your activity on websites or apps on your current browser or device may be combined and used with information collected from your other browsers or devices. These third parties partners use this information for our and their own advertising, analytics, attribution, and reporting purposes. To learn more about interest-based advertising, tracking technologies, and how to opt out, please visit https://www.aboutads.info/choices. You can disable the sharing of your personal information for cross-contextual behavioral advertising or targeted advertising through online cookies and tracking technology by adjusting your cookie preferences using our cookie banner. When you visit our Sites, the cookie banner provides options to manage or reject non-essential cookies and tracking technologies associated with advertising and analytics. You may also manage your preferences by accessing the 'Cookie Settings' link available on our cookie banner or our website footer. Please note that disabling these cookies may affect your personalized experience and limit certain functionalities.

Personal Information from Third Parties

We may also obtain Personal Information from third parties. We may combine this information with other Personal Information we have about you for the reasons described below.

We may receive the same categories of Personal Information as described above from the following third parties:

• Your Employer: If you use our Services on behalf of your employer, we may receive information from your employer or another employee such as your name and contact information.
• Social Media: When you interact with our Services through various social media networks, such as when you “Like” us, follow us, or share our content on Google, Facebook, Twitter, or other social networks, we may receive some information about you that you permit the applicable social network to share with third parties. The data we receive depends on your privacy settings with the social network. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services.
• Service Providers: Service providers that perform services solely on our behalf, such as survey and marketing providers, collect Personal Information and often share some or all of this information with us.
• Information Providers: We may, from time to time, obtain information from third-party information providers to correct or supplement Personal Information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with you.
• Publicly Available Sources: We may collect Personal Information about you that we do not otherwise have, such as contact information, employment-related information, and interest-in-services information, from publicly available sources. We may combine this information with the information we collect from you directly. We may use this information to contact you, to send advertising or promotional materials or to personalize our Services and to better understand the demographics of the individuals with whom we interact.

Uses of Personal Information

We use Personal Information (including the identifiers, inquiry information, professional or account-related information, survey information, commercial information, event information, internet and other electronic-related information, geolocation data, and inferences described above) for the following business and commercial purposes:

• Fulfill the purpose for which the information was provided, such as to perform our contractual obligations or to deliver Services you have requested;
• Manage our organization and its day-to-day operations;
• Communicate with individuals, including via email, text message, social media and/or telephone calls;
• Ask individuals to complete surveys about us, our Services, and organizations we partner with;
• Market our Services to individuals, including through email, direct mail, phone and text message;
• Administer, improve and personalize our Services, including by recognizing individuals and remembering their information when they return to our Site;
• Facilitate client benefits and services, including customer support through our command center services;
• Identify and analyze how individuals use our Site and Services;
• Conduct research and analytics on our client base and our Services;
• Improve and customize our Services to address the needs and interests of our client base and other individuals we interact with;
• Test, enhance, update and monitor the Services, and diagnose or fix technology problems;
• Help maintain the safety, security and integrity of our property and Services, technology assets and business;
• Defend, protect and enforce our rights or applicable contracts and agreements; - Prevent, investigate or provide notice of fraud or unlawful or criminal activity; and
• Comply with legal obligations.

We may provide additional privacy disclosures if the Personal Information at issue and/our expected use case falls outside the scope of this Privacy Notice.

Disclosure of Personal Information

We may disclose your Personal Information in the following ways and to the following categories of third parties:

• Cotiviti family of companies: We may disclose information with Cotiviti's parent companies, subsidiaries, joint ventures, or other affiliated companies under common control (collectively the "Cotiviti family of companies")
• Your Employer: If you engage in our Services through your employer, we disclose Personal Information to your employer such as your name and contact information.
• Survey Providers: We share Personal Information with third parties who assist us in delivering our survey offerings and processing the responses.
• Marketing Providers: We coordinate and share Personal Information with our marketing providers in order to communicate with individuals about the Services we make available.
• Customer Service and Communication Providers: We share Personal Information with third parties who assist us in providing our customer services and facilitating our communications with individuals that submit inquiries.
• Other Service Providers: In addition to the third parties identified above, we engage other third-party service providers that perform business or operational services for us or on our behalf, such as website hosting, infrastructure provisioning, IT services, analytics services, and administrative services.
• Other Business as Needed to Provide Services: We may share Personal Information with third parties that an individual engages with through our Services or as needed to fulfill a request.
• Business Transaction or Reorganization: We may take part in or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose Personal Information to a third party during negotiation of, in connection with or as an asset in such a corporate business transaction. Personal Information may also be disclosed in the event of insolvency, bankruptcy or receivership.
• Legal Obligations and Rights: We may disclose Personal Information to third parties, such as legal advisors and law enforcement:
  • in connection with the establishment, exercise, or defense of legal claims;
  • to comply with laws or to respond to lawful requests and legal process;
  • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
  • to detect, suppress, or prevent fraud;
  • to protect the health and safety of us and others; or
  • as otherwise required by applicable law.
• Otherwise with Consent or Direction: We may disclose Personal Information about an individual to certain other third parties or publicly with the individual’s consent or direction. For example, with an individual’s consent or direction we may post his or her testimonial on our Site or other Services.
• Other Reasons. We may disclose personal information for other reasons we may describe to you, including if you consent to the disclosure or direct us to disclose your information.

Edifecs does not sell Personal Information to third parties in the traditional sense, but we do use cookies and other tracking technologies, which may constitute a “share” or “sale” of Personal Information under certain U.S. state consumer privacy laws. In the past 12 months, we have disclosed the following categories of Personal Information with our targeted advertising service providers and partners: Identifiers, Geolocation data, and Internet and other electronic-related information. For more information, see the Cookies and other Tracking Technologies section of our privacy policy above.

Marketing Opt-Out

If you would like to opt out of receiving promotional or marketing e-mail from us, you may use the “unsubscribe” mechanism included in each marketing message. Note that your option not to receive promotional and marketing e-mail shall not preclude us from corresponding with you, by e-mail or otherwise, regarding your existing relationship with us. Your opt-out request will also not apply to correspondence that has already been initiated.

Security of your Personal Information

We follow generally accepted industry standards to protect the personal information submitted to us and have implemented reasonable technical, organization, administrative and physical measures to protect personal information. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security and encourage you to use websites and share information with caution.

Retention of Personal Information

We may retain Personal Information as reasonably required to provide our products and services, operate our business, and comply with our legal obligations. In determining when your Personal Information is retained or disposed, we may consider the nature and sensitivity of your Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information, and applicable legal requirements.

Children's Personal Information

Our Site and our other Services are not directed to, and we do not intend to, or knowingly, collect or solicit Personal Information from children under the age of 18. Individuals under the age of 18 should not use our Site or other Services, or otherwise provide us with any Personal Information either directly or by other means. If we learn that any Personal Information we collect has been provided by a child under the age of 18, we will take reasonable measures to promptly delete that Personal Information from our records. If you become aware of any data we may have collected from children under age 18, please contact us at PrivacyOffice@cotiviti.com.

Links to Third-Party Websites or Services

Our Site and Services may include links to third-party websites, plug-ins and applications. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to, and we are not responsible for, any Personal Information practices of third-party websites and online services or the practices of other third parties. External links are provided for convenience only and access to these links is at your own risk. To learn about the Personal Information practices of third parties, please visit their respective privacy notices.

International Privacy Disclaimer

Because privacy laws are not the same in all countries, our non-U.S. operations may adopt additional measures depending on local legal requirements. Information obtained from our website generally is processed and stored in the United States in accordance with this Policy, which may not be as comprehensive as required in the European Union or other nations.

Confidentiality and Non-Disclosure Agreements

Nothing in this Privacy Policy shall detract from the rights and obligations of the parties to any non-disclosure or similar agreement that Edifecs or any of the Edifecs family of companies have entered into with any customer or other third-party.

Updates to This Privacy Notice

The Edifecs Privacy Policy is subject to change at any time, and we encourage you to review this policy regularly for any changes. A current policy is available for review on our website at www.edifecs.com.

Contact Us

If you have questions or comments regarding our Privacy Policy, or any issue relating to how we collect, use or disclose personal information, or if you would like us to update information we have about you or your preferences, please contact us as indicated below.

Email us at: PrivacyOffice@cotiviti.com

Write to us at:

(770) 379 2800

For Issues regarding Information Security
Email us at: InfoSec@cotiviti.com

Write to us at:

(770) 379 2800