Privacy Policy

Effective Date: June 10, 2024

Introduction

Advanta Health Solutions, Inc. (“Advanta,” “we” or “us” or “our”) provides health and wellness incentive programs (“Programs”) on behalf of insurers and employers (collectively, “Sponsors”) that want to encourage their members or employees to participate in regular exercise and healthy activities. Our Programs are available through mobile applications, software, websites, and application programming interfaces (“APIs”) (collectively, “Applications”) including www.advantahealth.com, and our ActiveFit and Activefit+ applications.

This Privacy Policy sets out key information regarding how we use the personal information we collect when individuals (“you” or “your”) enroll in a Program, use our Applications, or interact with us in other ways.

PLEASE READ THIS PRIVACY POLICY CAREFULLY. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT USE OUR APPLICATIONS.

If you enroll in a Program, this Privacy Policy is incorporated by reference into your Participation Agreement. This Privacy Policy may change over time, so please reread it from time to time. Changes will be posted at this URL and will be effective when posted. Your continued use of our Applications following the posting of any change will signal your acceptance of the revised Privacy Policy.

Contact Information

Advanta Health Solutions, Inc.
550 Broad Street, Suite 804
Newark, NJ 07102
[email protected]

WHAT THIS PRIVACY POLICY COVERS

Personal Information:

Directly Identifiable: Name, postal or e-mail address, date of birth, gender, insurance information, gym membership number, and bank account information.
Indirectly Identifiable: Device IP address, mobile device identifier, geolocation data, and internet activity data.
Associated Information: Interests, job, fitness facility, personal characteristics, and exercise activities/preferences.

Exclusions:

Collection by third parties: Our Applications use features and services provided by third parties and may contain links to websites or social media that are not operated or controlled by Advanta. We are not responsible for the personal information practices or content provided by these third parties. We encourage you to review the privacy policies of these third parties. (See “Use of Third-Party Services” and “Links to Third-Party Sites.”)
Anonymized Information: Information that has been modified in a substantial way so that it no longer can reasonably be used to identify or be linked to an identifiable individual.
Collection for business to business purposes: Except where legally protected under applicable privacy laws, information we obtain about the employees, agents, or representatives of our Sponsors, service providers, suppliers, and business partners.

SOURCES AND TYPES OF PERSONAL INFORMATION WE COLLECT

Based on how you interact with us and the Program features in which you enroll, we may collect your personal information in the following ways.

From the Sponsor of your Program: We obtain your name, address, relevant insurance information, and date of birth to establish your eligibility to participate in the Program and to verify your identify when you enroll.
From you, when you enroll in a Program: When select your fitness options, set up an account, or make changes in your account information, we ask for your name, email address, postal address, phone number, gender, date of birth, and bank account information (to deposit the incentive payments you earn). You also create an individual password to logon to the mobile app or online portal for your Program. If you select to earn incentives by working out at your gym or other health facility, we ask for the name and address of the facility and your membership number.
From your communications with us: We collect your name, contact information, and other information you provide when your e-mail, text, telephone, or message us through social media, submit online forms, or participate in our surveys or promotions.
From you, when you use the Application and report your fitness activities: We record the date, time and type of fitness activity so that it counts toward earning incentives.
From your device connection: We collect device information on our Diagnostics screen under Settings, including (as applicable) your IP address, device ID number, model, and manufacturer, version of your operating system, version of our application you are running, available memory and permissions provided to the application. This device information is stored in our server logs and used for device identification.
From your mobile device with your permission: We can access and collect the following data only if you choose to enable the necessary permissions using either your app settings (Android) or mobile device settings (Apple). You can change those permissions at any time.
- Fitness data, such as your step counts, calories burned, distance and duration of exercise from an app such as Apple Health or Google Fit;
- Specific geolocation data used to confirm that you exercised at your previously identified health facility;
- Photos to confirm that you completed your exercise at home; and
- Device information that enables use of your device’s Bluetooth, SMS messages, storage, and other features.
From cookies and other internet tracking technologies: to save your access credentials and visit preferences, collect online activity data and usage metrics (see “Cookies and Online Data Collection” below).
From third parties: We may collect your information from our third-party business partners who deliver content, features, or services as part of your experience with us. See “Use of Third-Party Services.”

HOW WE USE YOUR PERSONAL INFORMATION

We use your personal information to:

Determine eligibility to participate in your Program, process your enrollment,and open and administer your Program account;
Authenticate your identity when you logon to use the Applications;
Maintain records of your exercise and other incentive-qualifying activities, determine when you qualify to receive an incentive award, and process your incentive payments;
Inform your Sponsor about individual and overall participation in the Program and the incentives awarded;
Communicate with you about your questions, account updates, and use of the Applications, troubleshoot problems, and request feedback;
Inform you about upgrades and improvements, new products and services, upcoming events, and other information may be of interest to you;
Deliver content that we believe may be of interest to you based on data about your usage of the Applications and your location;
Analyze the technical performance and functioning of our Applications;
Monitor and analyze usage and trends, evaluate and compare participation in our Applications, enhance our Service offerings, and develop new Applications;
Develop and analyze aggregated data for research and performance evaluation purposes;
Protect the security of our Applications, enforce our Participation Agreement and other legal agreements, and comply with applicable laws.

YOUR PERSONAL INFORMATION SHARED WITH THIRD PARTIES

We do not sell personal information. We share your personal information with third parties as described below.

Your Sponsor—Personal information relating to your Program participation and incentives you earn is shared with the Program Sponsor (employer or insurance company) and with third-party administrators and service providers as directed by the Sponsor.
Administrative service providers—Third parties who process information on our behalf may have access to your personal information, but may use it only on our behalf for the purposes set forth in this Privacy Policy. For example, these third parties may provide payment processing services for incentive payments, data hosting services, contact management, technology services, fraud detection and security services, e-mail marketing services, and customer support.
Mobile app suppliers—Advanta utilizes third-party applications, plug-ins, APIs and other features to provide mobile app functionality. Some of these features are necessary for the app to operate. Others you may choose to activate including, for example, beacons to detect and record that you have entered your fitness facility and to recognize geofences and beacons at your defined fitness facilities; and services to deliver messages and notifications to your phone. Because these third-party services may collect your personal information, we recommend that you review their privacy policies before activating the features they provide.
Optional Third-Party Marketing Communications—We may offer you the option to receive information from third parties about their products, services, and offerings. You may opt-in to receive this information by voluntarily clicking on a link or by making a specific request to share your information with the third party. We will share your information with the third party only if you opt-in and we may receive compensation from the third party. We or the third party will always provide the opportunity to withdraw your consent. If you notify us at [email protected], we will stop providing future access to your information to the third party. You should contact the third party directly to stop receiving additional materials based on information provided before your consent was withdrawn.
Law enforcement, regulators, advisors—We may share your information based on a good faith belief that it is required to comply with the law, or in the interest of protecting or exercising our or others’ legal rights. (For example, to resolve disputes, for fraud and security protection, and to comply with legal process.)
Business transaction parties—We may share or transfer your personal information in connection with a prospective or completed sale, merger, transfer, or other reorganization of all or parts of our business subject to appropriate confidentiality protections.
Others—We may share personal information for other lawful purposes consistent with the purposes set out in this Privacy Policy or where you have granted us permission.

YOUR RIGHTS AND CHOICES

Access and Correction: You have the right to access your personal information and request corrections to any inaccuracies. To exercise these rights, contact us at [email protected].
Data Portability: You may request a copy of your personal data in a commonly used, machine-readable format. Contact us for details.
Objection and Restriction: You have the right to object to or request restrictions on the processing of your personal information. Contact us to submit your request.

HOW WE PROTECT YOUR PERSONAL INFORMATION

We implement a variety of organizational and technical safeguards to protect your personal information from unauthorized access, use, or disclosure. These measures include encryption, access controls, network security protocols, and regular security assessments. While we strive to protect your personal information, we cannot guarantee absolute security. We also recommend reviewing the privacy policies of third-party services integrated with our Applications for additional protection measures they may have in place.

HOW LONG WE KEEP YOUR PERSONAL INFORMATION

We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including for the duration of your participation in the Program and as required to comply with legal obligations, resolve disputes, and enforce our agreements. Anonymized data, which cannot be linked back to you, may be retained for research, analysis, and evaluation purposes. This Privacy Policy remains applicable to your personal information even after your relationship with us ends.

USE OF THIRD-PARTY SERVICES

Our Applications connect with third-party applications, plug-ins, APIs, and other features to provide some of the functionality used to operate our services. They may collect your IP address or device identifier and other internet browsing data, and may set a cookie to enable their features to function and track your usage. We also use tools provided by Firebase, a Google subsidiary. We use the Firebase Messaging component to deliver messages and notifications to your phone within the Application, Firebase Analytics provides data on mobile application usage and user engagement, and Crashlytics provides real-time analytics related to crashes occurring with information like application version, device type, and operating system which helps us target issue resolution.

Advanta is not responsible for privacy practices of these third-party services. This Privacy Policy applies solely to information under our control. These third parties post privacy policies on their individual websites and we recommend that you review their privacy policies to learn about how they collect and process personal information.

COOKIES AND ONLINE DATA COLLECTION

We use cookies and similar technologies to enhance features, track usage, and provide personalized content. Cookies are small data files stored on your device that help us recognize repeat visitors, understand user behavior, and improve our Applications. You can control the use of cookies through your browser or device settings or by using third-party utilities. Disabling cookies may limit the functionality and performance of our Applications. Types of cookies we use include:

Essential Cookies: Necessary for the operation of our Applications.
Performance Cookies: Collect information about how you use our Applications.
Functionality Cookies: Remember choices you make and provide personalized features.
Targeting Cookies: Deliver relevant ads and track ad performance.

HOW YOU CAN RESTRICT ONLINE DATA COLLECTION

You have several options to manage and restrict the collection of your data online:

Browser/Device Settings: Adjust settings to control cookies and tracking technologies.
Avoid Data-Collecting Features: Opt out of features that collect extensive data when possible.
Direct Communication: Contact third-party data collectors to inquire about data practices and request data restriction.
Independent Software Utilities: Use tools like ad blockers or privacy extensions to limit tracking.

EMAIL AND TEXT MESSAGES

We communicate with you through emails and, with your permission, text push notifications to provide updates, service notifications, and promotional content. You can unsubscribe from promotional emails using the unsubscribe link provided in the emails or by contacting us at [email protected]. Please note that unsubscribing from promotional messages does not affect your ability to receive service-related notifications necessary for your participation in the Programs.

If you choose to share your Program participation or other activities on social media, your posts will be subject to the privacy practices of those platforms. We encourage you to review the privacy settings of the social media platforms you use to understand how your information may be shared and how you can control data sharing and connection options. We are not responsible for the privacy practices or content of these platforms.

LINKS TO THIRD-PARTY SITES

Our Applications may contain links to third-party websites for your convenience and information. These websites operate independently from us and have their own privacy policies. We strongly encourage you to review the privacy policies of any third-party sites you visit. We are not responsible for the content, accuracy, or privacy practices of these third-party sites.

PRIVACY RIGHTS OF CALIFORNIA RESIDENTS

California residents have rights under the California Consumer Privacy Act to request information about the categories and types of their personal information a business has collected and shared and, in some circumstances, to request deletion of their personal information. Advanta is a service provider to the Sponsors of the Programs we offer. We do not sell personal information or permit third parties to use it for their own commercial purposes, unless you give us permission to do so. Please contact your Sponsor directly to make a request to exercise your rights under the California Consumer Privacy Act. At your Sponsor’s request, we will assist in responding to such request.

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us, once per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year. To obtain this information from us, please email [email protected] with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Not all information is covered by the “Shine the Light” requirements and only information on covered sharing (if any) will be included in our response.

HOW WE USE YOUR LOCATION AND BACKGROUND LOCATION

Location and Background Location Data:

Collection: We collect your location data through your device’s GPS, Wi-Fi, and other location-based services when you use our Applications. This includes both foreground and background location data to ensure continuous functionality of our services.

Use: This data helps us:

Track and Record Fitness Activities: Accurately monitor and log your fitness activities, such as walking, running, or cycling, to ensure proper tracking and rewards.
Provide Personalized Content and Recommendations: Offer tailored content, recommendations, and fitness goals based on your location and activity patterns.
Verify Participation in Location-Based Fitness Programs: Confirm your participation in specific fitness programs or events that require location verification for eligibility.
Enhance User Experience: Improve the user experience by offering location-specific features and services, such as local fitness challenges, and nearby fitness facilities.

Background Location: We collect background location data to maintain continuous tracking of your fitness activities, even when the app is not actively in use. This allows for accurate and uninterrupted activity monitoring, ensuring you receive the appropriate rewards and incentives based on your participation and location.

Sharing: Location data is shared with Sponsors to:

Confirm eligibility for incentives and rewards based on your location and activity participation.
Provide aggregated, anonymized data for program improvement and research purposes.

We do not sell your location data to third parties. However, it may be shared with service providers who assist in delivering location-based features and functionalities within our Applications.

Opt-Out: You can disable location services through your device settings at any time. However, please note that doing so may limit the functionality of our Applications, including the ability to accurately track fitness activities, provide personalized content, and verify participation in location-based programs. If you choose to opt-out, certain features and services may not be available or may operate with reduced functionality.

If you are located in the UK or the European Union, you have the following rights under the General Data Protection Regulation (GDPR):

Right to Access: You have the right to request access to the personal data we hold about you.
Right to Rectification: You have the right to request that we correct any inaccuracies in your personal data.
Right to Erasure: You have the right to request the deletion of your personal data, subject to certain conditions.
Right to Restrict Processing: You have the right to request that we restrict the processing of your personal data under certain circumstances.
Right to Data Portability: You have the right to request that we provide your personal data in a structured, commonly used, and machine-readable format and to transmit that data to another data controller.
Right to Object: You have the right to object to the processing of your personal data under certain conditions.
Right to Withdraw Consent: If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time.
Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority if you believe that our processing of your personal data violates GDPR.

To exercise these rights, please contact us at [email protected]. We will respond to your request within the timeframe required by the GDPR.

USING THE APPLICATIONS OUTSIDE THE UNITED STATES

We operate under U.S. laws, and our Applications are designed to comply with these laws. If you are accessing our Applications from outside the United States, please be aware that your personal information may be transferred to, stored, and processed in the United States. The data protection laws in the United States may differ from those in your country of residence. By using our Applications, you consent to the transfer, storage, and processing of your information in the United States in accordance with this Privacy Policy. We take steps to ensure that your data is treated securely and in accordance with this Privacy Policy, regardless of where it is processed.

MINORS

We do not intentionally provide services to minors (anyone under the later of age 18 or the age of maturity under applicable state law); nor do we collect information from minors. If it is discovered that a minor has provided us with personal information, we will remove the information from our records. If you are a parent or guardian of a minor and are aware that minor’s personal information, please contact us to allow us to take necessary action.

CHANGES TO THIS PRIVACY POLICY

We may make changes to this Privacy Policy at any time. Your continued use of the Applications after a change to this Privacy Policy constitutes your consent to be bound by the revised Privacy Policy. We encourage you to periodically review this page for the latest information on our privacy practices.

You can keep your information accurate, complete, and up-to-date by accessing your account through the website portal or your mobile app. At any time you may use the “My Account,” “Payment Account,” “Change Status” and “My Clubs” functions to update information or modify permissions you have previously given us.

You can request to discontinue use of our Applications by contacting us. See “How to Contact Us,” below. After you discontinue using our Applications, you will not be able to access your account information or sign in.

HOW TO CONTACT US

For questions about our Privacy Policy:
Advanta Health Solutions, Inc.
550 Broad Street, Suite 804
Newark, NJ 07102
[email protected]