Welcome to HMSA’s Health Promotion & Preventive Services ("HPPS") Web Site (the "Site"). Please read carefully the following Web Site Privacy Statement ("Privacy Statement"), as well as the Web Site Terms and Conditions of Use (" Conditions of Use") , before using the Site. By entering and using the Site, you acknowledge that you have read and understood the Privacy Statement and Conditions of Use and that you agree to abide by them. If you do not agree to abide by the Privacy Statement and Conditions of Use , you may not enter, access, or otherwise use this Site.

The terms "you," "your," and "yourself" refer to the individual entering, accessing, or otherwise using the Site.

You acknowledge that you have read this Privacy Statement and that you accept the terms thereof. YOU AGREE TO READ THE PRIVACY STATEMENT CAREFULLY BEFORE USING THE SITE OR THE HPPS PROGRAM. If you do not agree to these terms, you may not access or otherwise use the Site or the HPPS program.

The HPPS program includes all the services accessible through the Site, including HealthPass, the Health Risk Assessment, Health Coaching, Health Education, and other health promotion and preventive services that may be added to the Site from time to time. The HPPS program is designed to help individuals identify their potential health risks and meet their lifestyle improvement goals. IT IS NOT INTENDED TO REPLACE A PHYSICAL EXAMINATION OR MEDICAL CARE BY A PHYSICIAN. This program is available to adults, age 18 years and older, and the use of this program by children under 18 years of age is prohibited. To participate in the HPPS program, you must complete the comprehensive health risk assessment questionnaire.

The Site is provided to you by Hawaii Medical Service Association ("HMSA"), its affiliated companies Hawaii Family Medical Centers ("HFMC") and Integrated Services Incorporated ("ISI"), and certain third party vendors (e.g., HealthMedia, Inc.) that will provide services in connection with the HPPS program. Collectively,HMSA, its affiliated companies, and third party vendors that will provide services in connection with the HPPS program are referred to in this Privacy Statement as "HPPS Entities." Please read this Privacy Statement to understand how the HPPS Entities will handle the privacy of health information you provide for the HPPS program through the online health risk assessment called "Succeed." To address privacy concerns you may have while visiting this Site, this Privacy Statement describes how the HPPS Entities may use information that you provide to this Site. The HPPS Entities may use and disclose the information that you provide through this Site only for purposes permitted or required by law, and as described in this Privacy Statement. If you do not wish us to use or disclose information that you provide through this Site as described in this Privacy Statement, you should disconnect from this Site.

HMSA has developed Conditions of Use describing your responsibilities when using this Site. Please refer to this document for additional information.

Individually Identifiable Health Information Provided By You Via the Site

Please note that this Privacy Statement applies only to how the HPPS Entities use and disclose individually identifiable health information that you provide when visiting this Site, and does not apply to personal information you might provide during an on-location visit while participating in HealthPass and the Succeed program. The collection of individually identifiable health information at this Site is for the purposes of your health risk assessment and screening. It is also to provide you with applicable health screening information, and for other purposes for which we are permitted by the HIPAA Privacy Rule to use or disclose the individually identifiable health information you provide (the "HIPAA Privacy Rule" is a federal regulation officially known as the "Standards for the Privacy of Individually Identifiable Health Information"). The individually identifiable health information you provide through this Site may be provided to the organization you identify as your employer in a report that aggregates the information, including the number of participants and health risks. All other information you provide through this Site, if reported, would be de-identified, aggregated with the information of other individuals, and reported as a combined group. The HPPS Entities may use and disclose your individually identifiable health information as outlined herein.

This Privacy Statement is distinct from HMSA's Notice of Privacy Practices for the HPPS program ("the HPPS Notice"), which describes how HMSA uses individually identifiable health information collected through the HPPS program - both online and offline - to provide services to you and to manage health care operations. HMSA publishes the HPPS Notice in accordance with the HIPAA Privacy Rule. Together, this Privacy Statement and the HPPS Notice describe how HMSA uses your individually identifiable health information and personal information collected through the HPPS program.

Please note that information you provide to HPPS in an offline setting - such as during an on-location health assessment conducted by our staff - is covered by the HPPS Notice, although it is not covered by this Privacy Statement.

Online Personal Information Collected About You Via the Site

When you communicate via the Site, personal information is collected about you only if you provide it to us. "Online personal information" is any information or data you provide through this Site that is individually identifiable, such as a name, address, or birth date. It also may include other information that we collect about you that is associated with your name or address, such as your email address. You may provide that information to us on our registration page. "Online personal information" may or may not be individually identifiable health information that is also protected by the Privacy Rule. Where online personal information also constitutes individually identifiable health information under the Privacy Rule, the provisions of this Privacy Rule also will govern HMSA's permitted uses and disclosures of the online personal information.

Portions of our Site may allow you to provide us with online personal information and email address in order to deliver requested materials to you, respond to your questions, and enable you to update information or allow us to provide any applicable program information.

Any online personal information that you provide via our Site is used exclusively for the purpose stated on the web page where you submit your personal information. The HPPS Entities will not sell, license, or disclose online personal information that you provide to us except as provided by this Privacy Statement (e.g., in a de-identified or aggregate form).

HPPS Entities' Use and Disclosure of Individually Identifiable Health Information and Online Personal Information

As permitted by the HIPAA Privacy Rule, individually identifiable health information that you provide through this Site or that is created or received about you may be used or disclosed by the HPPS Entities in connection with services provided to you for the HPPS program, and for other purposes that are permitted or required by law. Under the HIPAA Privacy Rule this information is called "protected health information." Protected health information is individually identifiable health information, including demographic information, collected from you or created or received by a health care provider, a health plan, or a health care clearinghouse and relates to: (i) your past, present or future physical or mental health or condition; (ii) the provision of health care to you; or (iii) the past, present or future payment for the provision of health care to you. We refer to protected health information and individually identifiable health information interchangeably in this Privacy Statement.

With respect to the HPPS program, the HPPS Entities shall handle your individually identifiable health information (including any online personal information that also constitutes individually identifiable health information) as follows:

1. The HPPS Entities shall not sell, transfer, or disclose individually identifiable health information without your prior authorization, except when permitted or required by law. As used in this Privacy Statement, "required by law" includes the permissive and mandatory requirements of state and federal regulations (such as the HIPAA Privacy Rule) that govern the use and disclosure of individually identifiable information.

a. Under the HIPAA Privacy Rule, the HPPS Entities are permitted to disclose individually identifiable health information to business associates who perform various functions or provide services on their behalf. To perform these functions or to provide services, business associates will receive, create, maintain, use, or disclose protected health information, but only after we require the business associates to agree in writing to contract terms designed to safeguard your information.

b. The HPPS Entities are also permitted to use and disclose individually identifiable health information to support the services provided through this Site, and to support their business functions. These services and functions may include:

i. providing personalized educational health information to you,

ii. tailoring your HPPS experience to meet your specific requirements by compiling and displaying content and information that we think you might be interested in,

iii. providing you with information about relevant health intervention programs.

2. The HPPS Entities will use individually identifiable health information obtained through this Site to generate aggregate data that may be disclosed to your employer, including health risk behaviors, biometric results and HPPS program performance.

3. The HPPS Entities may use or disclose individually identifiable health information obtained through this Site to assist business associates or other covered entities in their treatment, payment, or health care operation activities.

4. The HPPS Entities may use your individually identifiable health information (including online personal information) to create aggregate data for the purposes of tailoring the Site to meet customer needs and interests. Except as otherwise explained in this Privacy Statement, distribution and use of this aggregate data will be restricted to staff, management, agents, business associates of the HPPS Entities and others permitted by law who need aggregated statistical information about our users as a group, as well as the patterns of their Site usage. For example, our editors use this information to develop new features and content for the Site.

5. The HPPS Entities reserve the right to perform statistical analyses of user behavior on an aggregate basis in order to measure interest in, and use of the various areas of the Site, and to inform business associates, agents, or others permitted by law to receive such information.

6. The HPPS Entities may need to change this Privacy Statement from time to time in order to address new issues and to reflect changes on our Site. Please refer back to this Statement regularly, because your use of the Site signifies that you agree to be bound by this Privacy Statement and the Conditions of Use  as amended from time to time.

7. In the unlikely event that the HPPS Entities are acquired, merge with another entity or sells portions of its assets, our data bases (which may contain your protected health information and online personal information) may be among the transferred assets.

8. The Site contains links to web sites of third parties with which the HPPS Entities have not contracted to provide services in connection with the HPPS program (and such third parties - which are referred to below as "other third-parties" - do not fall within the definition of "HPPS Entities"). These links are provided solely as a convenience to you and not necessarily as an endorsement or recommendation by the HPPS Entities of the content on such other third-party web sites, or as an indication of any affiliation, sponsorship, or endorsement of or by such other third-party web sites.

a. These other third-party sites may have their own privacy policies or no policy at all. The HPPS Privacy Statement and the HPPS Conditions of Use  do not apply to the sites of such other third parties.

b. Other than sites within the HPPS Entities family of companies, the HPPS Entities are not responsible for and lack control over the content of other third-party sites whose links are included herein. The HPPS Entities do not make any representations regarding the privacy practices of, or the content or accuracy of materials on, other third-party web sites. Your use of other third-party web sites is subject to the terms of use for such sites. If you decide to access other third-party web sites that are linked to this Site, you do so at your own risk.

c. Although the HPPS Entities endeavors to warn users when they click on a link to other third-party websites that they are leaving this Site, we do not guarantee that you will receive such an alert. It is your responsibility to determine when you have left this Site.

d. Only some of the web sites associated with the HPPS Entities endeavor to warn users when they click on a link to a HPPS Entity-related web site or to other third-party sites. The HPPS Entities do not guarantee that you will receive such an alert.

e. The HPPS Entities require any entity that receives personal information collected on this Site to agree to adhere to this Privacy Statement and the HPPS Notice, to the extent that data are covered by the federal Privacy Rule.

9. Although parents are free to seek information available on the Site concerning the health of their children, no person under 18 years old is permitted to use the Site. The HPPS Entities do not direct this Site to children under the age of 18 years, or knowingly collect information from children under 18. Adults should not assist minors in accessing the Site. When users enter personal information on our Site, the user is representing to us that he/she is an adult, 18 years or older. We would be pleased to work with parent and guardians to delete from our records personal information a child may improperly disclose. Please contact us at healthpass@isi-hawaii.com.

10. We have physical and electronic safeguards designed to protect personal information about you. The HPPS Entities Privacy Policy bars access to your information except to those employees who need it in order to perform their jobs. Currently this Site may use Secure Socket Layer ("SSL") or other encryption or comparable technology to enhance data privacy and help prevent loss, misuse or alteration of the information under our control. We intend to continue to use this or comparable technology in the future. This encryption technology, however, does not absolutely guarantee or safeguard the total privacy of user information that has been voluntarily disclosed to the Site.

11. Security measures are in place to help protect against the loss, misuse, or alteration of your information under The HPPS Entities’ control. These measures include:

a. Authorized access to this Site. The HPPS Entities will register and assign you an access ID code to enter the Site.

b. Cookies: In order to log in and access the Site, you will need to turn cookies on in your web browser. This Site uses a cookie to identify you and help you obtain access to your confidential account and health information. This cookie is used only by this Site, and does not share information with any entity outside of the HPPS Entities, their affiliated companies and third party vendors. It also ensures that your session remains secure by maintaining an identifier unique to your session and automatically logging you off after a period of inactivity. The session cookie self-terminates after a set expiration time or when you close your browser.

If you have any questions or want additional information about this Privacy Statement please contact complianceofficer@isi-hawaii.com.

We hope this Privacy Statement answers your questions about HPPS and privacy. It is in addition to, and is not intended to replace, Conditions of Use.

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