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California Consumers

This California Consumers section supplements the Privacy Policy and applies only to California consumers.  

 

The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CPRA”, collectively “CCPA”), and other California privacy laws provides California residents (i.e., consumers) with specific rights regarding personal information. This section of the Privacy Notice describes those CCPA rights and how to exercise those rights.  

  

This section does not apply to publicly available information or to protected health information that is collected and governed by the privacy, security, and breach notification rules issued by the federal Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Availability Act of 1996 (“HIPAA").  

  

 

California Consumer Rights 

Description 

Access to Specific Information and Data Portability Rights 

California residents have the right to request that Accolade disclose certain information to you about Accolade’s collection and use of your personal information over the past twelve (12) months. Once Accolade receives and confirms a verifiable consumer request from you, Accolade will disclose to you, to the extent permitted by law:  

  • The categories of personal information Accolade collected about you.  
  • The categories of sources for your personal information Accolade collected about you.  
  • Accolade’s business or commercial purpose for collecting your personal information.  
  • The categories of third parties with whom Accolade shares your personal information.  
  • If we disclosed your personal information for a business purpose, the personal information categories that each category of recipient obtained.  

  

You shall have the right to request that the information described above be provided to you in a portable and readily useable format, to the extent technically feasible (“data portability").  

  

Accolade does not sell your personal information.  

Deletion and/or Correction Request Rights 

You have the right to request that Accolade delete and/or correct certain of your personal information that Accolade collected from and/or related to you and retained, subject to certain exceptions. Because of the relationship between Accolade and your employer and/or your health plan carrier, Accolade cannot delete or correct/change your personal information provided by your employer, your health care provider and/or other entities that support your health benefits plan.  

  

To the extent that Accolade can delete or correct your personal information, once Accolade receives and confirms your verifiable consumer request, Accolade will delete and/or correct (and direct our service providers to delete) your personal information, unless an exception applies.  

  

We may deny your deletion request if retaining the information is necessary for us or our service providers to:  

  • Complete the transaction for which we collected your personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, your employer, or your health plan carrier.  
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.  
  • Debug products to identify and repair errors that impair existing intended functionality.  
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.  
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).  
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.  
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.  
  • Comply with a legal obligation.  
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.  

 

Additionally, Accolade may deny your deletion and/or correction request if the information sought to be deleted is protected health information disclosed to us as part of your participation in an employer-sponsored group health plan and/or your health plan carrier through which you have purchased a health plan or other benefits.  

  

We may deny your correction request if, after considering the totality of the circumstances, we determine that the information is more likely accurate than not.  

Limit the Use of My Sensitive Personal Information 

Under the CCPA, California residents have the right to limit the use of their sensitive personal information (“SPI”) to only those purposes that are necessary for the business to provide products or services to the consumer.  Accolade does not use any of your SPI for any purposes other than to provide the services to you.    

Exercising Your Access, Data Portability, and Deletion Rights 

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to Accolade by either:  

  

  • Visiting the Data Subjects Rights Portal located here; or  
  • Calling the following toll-free number at 1 (888) 914-9661, and using PIN# 494 202 to identify that you are calling with respect to Accolade.  

 

  

We ask that you not provide us with any medical or protected health information through the above communications.  

  

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.  

  

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:  

  • Provide sufficient information that allows Accolade to reasonably verify you are the person about whom Accolade collected personal information or an authorized representative.  
  • Describe your request with sufficient detail that allows Accolade to properly understand, evaluate, and respond to it.  

 

Accolade cannot respond to your request or provide you with your personal information if Accolade cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. Any disclosures provided pursuant to the CCPA will only cover the 12-month period preceding the receipt of the verifiable consumer request.  

 

Accolade will respond to a verifiable consumer request within 45 days of its receipt, or notify you that Accolade requires more time to respond and the reason for the extended response time. Accolade will deliver its written response by mail or electronically, at your option.  

 

To the extent that your verifiable consumer request is excessive, repetitive, or manifestly unfounded, Accolade may charge a reasonable fee to respond to such request.  

 

Accolade will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, Accolade will not:  

  • Deny you goods or services.  
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.  
  • Provide you a different level or quality of goods or services.  
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.