Clover Health Privacy Policy

Effective Date: December 10, 2019

This Online Privacy Statement (“Privacy Statement”) describes the information we collect about you, how we use that information, and how we protect your privacy when you use a website, mobile application, or other interactive feature (each, a “Service, and collectively, “Services”) that we control or operate, and which links to this Privacy Statement.  Services include, but are not limited to:

  • www.cloverhealth.com, or other Clover Health-branded websites
  • Interactive email or text messaging features, when you provide your email address or cell phone number to us, or consent to our use of your email address or cell phone number

By using the Services, you consent to the data practices described in this Online Privacy Statement. 

Types of information we collect

When you interact with the Services, we may collect your Personal Information. “Personal Information” means any information that can be used to identify, contact or locate you, such as your name, address, email address, telephone number, occupation and medical information. 

In addition, we may automatically collect information about your device and your use of the Services (“Usage Information”). This information can include your IP address, browser type, device ID, domain names, access times, and pages visited.  Usage Information is not Personal Information unless we link it to Personal Information.

Please note:  Our HIPAA Notice of Privacy Practices describes our privacy practices for your Medical Information/HIPAA Protected Health Information.  It does not apply to the Personal Information or Usage Information that we collect from you through the Services.  We include a link to our HIPAA Notice of Privacy Practices on webpages where we collect information from you is treated as “Medical Information” or “HIPAA Protected Health Information”.

How we use Personal Information and Usage Information

We collect and use Personal Information and Usage Information to:

  • Operate and personalize the Services
  • Notify you of new Service features, health services or plan benefits
  • Provide you with customer service and technical support
  • Evaluate and improve our Services
  • Create an online account for you
  • Verify your identity and authenticate access to your account
  • Bill and collect payment for any applicable fees or charges
  • Inform you about other products or services available from Clover Health and our affiliates or business partners
  • Contact you via surveys to conduct research about your opinion of our current services and potential new services that may be offered
  • Send you important administrative announcements about Clover Health, your account, or updates to our policies
  • Take action that helps us to maintain the security of our Services and the privacy of your Personal Information, to obey laws and to help prevent fraud and abuse
  • Update any hardware, software or other tools that we provide in conjunction with the Services
  • Take actions to enforce our agreements and policies

We may also collect and use Personal Information or Usage Information for any other purpose disclosed to you at the time of collection.

Subject to applicable law, we reserve the right to aggregate or de-identify your Personal Information for all legal purposes.  Aggregated or de-identified data is not treated as Personal Information if it does not, and cannot be reasonably used to, identify you.

Cookies and other data collection technologies

We use various technologies to help us manage the operations of the Services, remember your preferences, and track usage behavior so that we can tailor information to make your visits more enjoyable and meaningful.

Our data collection technologies include:

  • Cookies: A cookie is a text file that is placed on your hard disk by a webpage server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. You can find more information about cookies at Statement.allaboutcookies.org.
  • Web beacons and GIFs: Certain pages on the Services contain web beacons (also known as web bugs, pixel tags and clear GIFs), which we use to monitor how users use the Services.
  • Local Storage and Local Shared Objects: We use local shared objects and local storage to enhance user experience. Local storage is similar to browser cookies but can store data more complex than simple text. By itself, local storage cannot do anything to or with the data stored on your device. Like cookies, local storage can only access personal data that you have provided to the Services. Various browsers may offer their own management tools for removing HTML5.

We have third-party service providers that use different tracking technologies to predict or determine a likely association or relationship between two or more devices such as smartphones, tablets, desktop computers, etc.  We may use analytics from these service providers to help us serve online content about the Service across the internet on websites and social media platform. We do not permit any third parties to serve advertisements in our Services.

You may have the ability to accept or decline cookies and manage your local storage through your web browser. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to experience certain features of the Services.

Bear in mind, that third parties may use cookies, web beacons, and other technologies to collect information about you when you visit our website or mobile applications, including your IP address, web browser, pages viewed, time spent on pages, links clicked, and conversion information. We are not responsible for third party tracking technologies, and we encourage you to check the privacy policies of these third parties to learn more about their privacy practices.

Some web browsers incorporate a "do-not-track" ("DNT") or similar feature that signals to websites that a visitor does not want to have his/her online activity tracked. If a website receives a DNT signal, the browser can block that website from collecting certain information about the browser's user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, we (along with many other website operators) do not currently respond to DNT signals. For more information about DNT signals, visit Statement.allaboutdnt.com.

When we share Personal Information

We consider all information we collect from you to be confidential.  We do not sell, rent or lease your Personal Information to third parties. We may disclose your Personal Information to third parties, as follows:

  • Service providers.  We use third party service providers to assist us in delivering our Services to you, including internet service hosting, technical integration, marketing, analytics, customer service and fraud detection providers. These service providers are obligated by contract to use your Personal Information only on our behalf and at our direction.
  • With your authorized representatives.  While you may choose to share your Clover Health account credentials with someone, we have no way of verifying whether or not that person is really you, or whether they are authorized to access your Personal Information.  You should only grant access to your Clover Health account with individuals you trust.
  • With our affiliates.  We may share data with companies within our corporate family in order to coordinate our Services.
  • Corporate changes.  We may sell or otherwise transfer some or all of our assets to a third party in connection with a merger, consolidation, corporate reorganization, acquisition, reorganization or sale of equity or assets, or in the event of a bankruptcy. In such event, your Personal Information may be transferred to that third party.
  • For legal purposes.  We also may share your Personal Information that we collect, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support internal functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, order, governmental request, or other legal or regulatory process. We also may share Personal Information as required to pursue available remedies or limit damages we may sustain.
  • California Privacy Act Notice. UNDER CALIFORNIA CIVIL CODE SECTIONS 1798.83-1798.83, CALIFORNIA RESIDENTS ARE ENTITLED TO ASK US, ONCE PER YEAR, FOR A NOTICE IDENTIFYING THE CATEGORIES OF INFORMATION WHICH WE SHARE WITH OUR AFFILIATES AND/OR THIRD PARTIES FOR MARKETING PURPOSES, AND PROVIDING CONTACT INFORMATION FOR THESE AFFILIATES AND/OR THIRD PARTIES. REQUESTS WILL APPLY TO INFORMATION PROVIDED DURING THE PREVIOUS CALENDAR YEAR (FOR EXAMPLE, IF YOUR REQUEST INFORMATION IN 2019, YOU WILL RECEIVE INFORMATION REGARDING 2018).
  • IF YOU ARE A CALIFORNIA RESIDENT AND WOULD LIKE A COPY OF THIS NOTICE, PLEASE SUBMIT A WRITTEN REQUEST, SUBJECT HEADING: “CALIFORNIA CIVIL CODE COPY OF NOTICE REQUEST)” TO THE ADDRESS PROVIDED BELOW UNDER “HOW TO CONTACT US”.

Requesting access, modification or deletion of Personal Information

You may email us at privacy@cloverhealth.com with your request to access, modify or delete your Personal Information. We will respond to your request within a reasonable time. 

Data security

The security of Personal Information is important to us. We employ reasonable security measures designed to safeguard the Personal Information under our control from unauthorized access, use, and disclosure. Despite these measures, we cannot guarantee or warrant the confidentiality or security of your Personal Information. We encourage you to take appropriate steps to protect your Personal Information, such as using a complex password.

Email and text messages

Email and SMS text messaging are interactive communications technologies that we may use to deliver our Services.  There are some locations on our Services where we provide for secured email or text communications.  Otherwise, email and SMS text messaging technologies are generally sent over an unsecured network, which means that someone else could read, delete or alter them without your permission or knowledge. If you choose to send or request information over unencrypted email or SMS text message, you agree that you understand and accept this risk.

Retention of your information

We will retain Personal Information for as long as your account is active or as needed to provide you with Services, or as otherwise necessary to help us improve our products and services, comply with our legal and contractual obligations, resolve disputes, and enforce our agreements with you.

Note to international users

The Services are hosted in the United States and subject to U.S. law. If you are accessing the Services from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the law of your jurisdiction. By accessing and using the Services, you consent to the transfer to and processing of your Personal Information in the United States.

Protection of children's privacy

The Services are not designed for, intended to attract, or directed toward children under the age of thirteen. Consistent with the requirement of the Children's Online Privacy and Protection Act, if we learn that we have received any information directly from a child under age 13 without first receiving his or her parent's verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services and subsequently, we will delete that information or otherwise make it permanently inaccessible.

Changes to this Privacy Statement

The effective date of this Privacy Statement is set forth at the top of this page. We may occasionally update this Privacy Statement to reflect company and customer feedback. We encourage you to periodically review this Privacy Statement to be informed of how we are protecting your information. We will endeavor to provide you with advanced notice of any material changes to the Privacy Statement. By continuing to use the Services after such changes take effect, you agree to be bound by the modified Privacy Statement.  If any such changes materially alter your rights, we will notify you of these changes, either by posting notice on the Services or by sending you an email to the email address we have on file for you.  We will not make changes that have a retroactive effect unless we are legally required to do so.

How to contact us

We welcome your comments and questions regarding this Privacy Statement or our data practices. You can contact us at:

Clover Health
Attention: Privacy Team
P.O. Box 471
Jersey City, NJ 07303
Phone: 1-888-778-1478 (TTY 711)
Email:
privacy@cloverhealth.com