Last Updated: February 2, 2023
We are pleased to announce that PlushCare, Inc., PlushCare of California, Inc., Accolade 2ndMD LLC, and Accolade, Inc. are now part of Accolade, Inc.
Please read this privacy notice carefully as it will help you understand what we do with the information that we collect.
Personal Information We Collect
PlushCare collects information that you provide, including but not limited to:
Personal and contact information, such as your name, address, telephone number, email address, birth date, gender, race, sexual orientation, gender identity, marital status, ethnicity, electronic signature, and federal or state issued identification
Payment information, such as credit card information, insurance information, and billing address
Employment information, such as job title, professional experience, education, performance history, salary, and compensation
Health information, such physical or psychological state of health (e.g., laboratory data), medical history, medical treatment or diagnosis, and health care provider information
Information you post, if you comment or otherwise provide information in a public space on the Sites
Other information you give us when you contact our customer service team or otherwise communicate with us and if you participate in a survey or sweepstakes; includes information needed for you to participate (such as contact information), and to fulfill your prize
Username and password that you may select in connection with establishing your Account
Content shared via
communications with us through your use of the Services such as when you engage in our telehealth services and/or interact with our in-app messaging services, which may include, chat messaging content any images and/or files, including any medical records uploaded by you.
We may use automated technology such as cookies and other tracking software to collect Personal Information from your computer system or mobile device. We may collect the following information:
Internet Protocol (IP) address or other device identifier
Browser type and version
Browsing information, such as pages you view and the links you click, and whether you access our website via a social media site
Time zone setting
Browser plug-in types and versions
Operating system and platform
Other portable device information
With your permission, we may also collect your precise location data. We may also collect the time spent visiting, usage patterns, and the domain name of the website from which you linked to the Sites
In connection with your appointment with a Provider and with your permission, we may also access certain device information, such as information about speakers, microphone, camera, WiFi information and other device information like Bluetooth signals
Information about the Services with which you have engaged
Details about our interactions with you and the agreements you have executed with us
Public information related to your practice, such as license information, disciplinary history, legal and regulatory proceedings, and other due diligence information
Notice on COVID-19 and data collection consent: PlushCare provides members with virtual medical care and mental healthcare, for conditions including but not limited to COVID-19. PlushCare collects personal data to support a patient’s ability to speak with a Board-certified doctor over video through the app and deliver care related to conditions including but not limited to COVID-19. For COVID-19 related purposes, qualified patients may be able to use PlushCare to: discuss symptoms with a doctor; receive a diagnosis; receive lab orders and results; receive a COVID-19 treatment prescription. PlushCare only uses the personal data it acquires for COVID-19 related purposes in conjunction with its app’s user-facing purpose.
How We Collect Your Personal Information
We may obtain Personal Information:
When you provide it directly (such as by registering for your Account). We might also collect information if you post a review or contact us
Automatically when you visit the Sites or use the Services (such as from cookies)
From your communications with us through your use of the Services such as when you engage in our telehealth services and/or interact with our in-app messaging services
From third parties (such as when you make payments to us using our payment processor)
From our affiliates, including the Providers (e.g., professional health care provider) about your participation in the Services
We may combine information from different sources. For example, we may combine information that we have collected offline with information we collect online, or we may combine information we get from a third party with information we already have.
Information Gathered from Cookies and Other Similar Technologies
Strictly Necessary Cookies
These cookies are essential in order to enable you to move around the Sites and use their features. Without these cookies, services you have requested, such as remembering your login details or submitted information, cannot be provided.
These cookies collect anonymous information on how people use the Sites. For example, we use Google Analytics cookies to help us understand how individuals arrive at the Sites, browse or use the Sites, and highlight areas where we can improve such as navigation and marketing campaigns. The data stored by these cookies never shows personal details from which your individual identity can be established.
These cookies remember choices you make such as the country from which you visit the Sites, language, and search parameters. These can then be used to provide you with an experience more appropriate to your selections and to make the visits more tailored and pleasant. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.
Targeting Cookies or Advertising Cookies
These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an ad as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third party advertising networks. They remember the websites you visit and that information is shared with other parties such as advertisers.
We may use different kinds of cookies including session ID cookies and persistent cookies. Session ID cookies are used to personalize your user experience, to determine ways to improve the Sites and the Services we offer. These cookies are deleted when you close your browser session. Persistent cookies are used to collect information such as IP addresses, browser type, Internet Service Provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks.
You can change your settings for cookies and similar technologies by clicking on the cookie consent box on the Sites. In addition, you can refuse or accept cookies from the Sites at any time by activating the settings on your browser. You are always free to decline our cookies if your browser permits, but some parts of the Sites may not work properly if you do. Check the “Help” menu of your browser to learn how to change your cookie preferences. To find out more about cookies, visit www.aboutcookies.org.
We may also use technologies similar to cookies, such as Google Analytics and FaceBook/Meta Analytics. We use Google Analytics to collect anonymized statistics in order to improve the Sites and the Services. We do not combine the information collected through the use of Google Analytics with Personal Information. You can selectively disable Google Analytics by installing the opt-out component provided by Google on your browser. You can refer to the following links for more information: Google Analytics and privacy and Google Analytics opt-out browser.
Do Not Track
Many web browsers allow for the use of a “Do Not Track” (“DNT”) function to inform websites that you do not want your online activities tracked. We endeavor to cooperate with DNT signals. When you choose to turn on the DNT setting in your browser, your browser sends a signal to websites, analytics companies, ad networks, plug in providers, and other web services you encounter while browsing to stop tracking your activity. DNT signals are not universal, and in special circumstances, PlushCare reserves the right to refrain from complying with signals, such as when the signal is indecipherable or incompatible with our processes. Similar to our note about cookies, if you choose to turn on your DNT setting within your browser, some of our Services may not function as a result.
How We Use Your Personal Information
PlushCare only uses your personal information to provide our services, personalize your experience, comply with security measures as well as the law, or to fulfill business obligations. We may also need to use your personal data to address your own requests for that data, or to comply with your rights.
Providing our Services
Operate our business (e.g., manage your Account, provide and personalize our Services, and process payments)
Provide customer support
Communicate with you, including about the Services and the related services offered by Providers that treat you (e.g., surveys and feedback)
Provide you with newsletters, articles, alerts, announcements, invitations, and other information about the Services
Manage our vendor and partner relationships
Personalizing your Experience
Better design the Sites to improve users’ experiences, both in terms of content and ease of use
Analyze your interactions with the Services and third parties’ online services so we can tailor our advertising in ways we think will interest you
To conduct outreach and engagement communications to make you aware of the Services
PlushCare’s advertising practices align with industry best practices for internet-based advertising. You may choose not to receive future promotional, advertising, or other Service-related notifications from us by opting out of such advertising on your settings. If you choose not to receive notifications, you may still use the Service but you may not receive, or may be unable to use, certain services that involve our interaction with you.
To communicate with you about new contests, promotions and rewards, upcoming events, and other news about products and services offered by PlushCare and our selected partners
PlushCare reserves the right to show you sponsored content, which may or may not look similar to non-sponsored content, although we will alert you to the nature of the content by adding a tag (such as “sponsored content” or “advertisement”). If you choose to comment, share or similarly engage with sponsored content, your action may be viewable by your connections on your feed as well as by the sponsor. The choice over whether to engage with sponsored content is yours.
PlushCare does not share your personal data with any third-party advertisers or ad networks except for in the instance of: (1) hashed IDs, device identifiers, or pseudonymous data (to the extent that they are personal data in some countries); (2) with your separate permission or (3) data already visible to any users of our Services (e.g., profile or public feed data).
Other Instances (Monitoring for Fraud, Complying with Lawful Requests for Data, and More)
Track and monitor end user interaction with the Services
Ensure the security and integrity of the Services
Protect our and others’ interests, rights, and property (e.g., to protect our copyrighted materials)
Comply with applicable legal requirements, such as tax and other government regulations and industry standards, contracts, and law enforcement requests
Use of Anonymous Information. We may use Anonymous Information (as defined below), or disclose it to third party service providers, to provide and improve the Service. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners, for purposes including, but not limited to, targeting advertisements. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about use of the Service.
Sharing of Your Personal Information
YOUR PERSONAL INFORMATION WILL NOT BE SOLD. Nor will Your Personal Information be licensed or disclosed to unaffiliated third-parties, except in connection with the sale, transfer, merger, consolidation or other transaction involving all or part of our company or as may be permitted under applicable law.
PlushCare also may share this Personal Information to outside contractors, advisors, auditors, vendors, consultants, or others engaged by PlushCare to assist in providing financial or operational activities on PlushCare’s behalf, including technical and processing services and analysis of the Sites’ performance. Additionally, we reserve the right to disclose to third parties non-personally identifiable information collected for any lawful purpose, including but not limited to, aggregate or de-identified data.
PlushCare may disclose your Personal Information to third parties when obligated or permitted to do so by law or if we have a good faith belief that such disclosure is necessary to comply with a current judicial proceeding, court order, or legal process served on PlushCare or to investigate, prevent, or resolve any suspected or actual unlawful activities, such as potential fraud, or a perceived irregularity in any audits of the accuracy of any documentation or information submitted to PlushCare by you or on your behalf, as deemed appropriate by PlushCare.
PlushCare may be required or permitted by law to share your Personal Information, without prior notice to you, to maintain, safeguard and/or preserve all the rights and/or property of PlushCare and perform under demanding conditions in an effort to safeguard the personal safety of users of the Sites and/or the general public, including but not limited to, reporting adverse reactions to certain items, product recalls, preventing disease, and for health research purposes. We may dispute such requests when we believe, in our discretion, they are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Finally, PlushCare may disclose or transfer information, including any Personal Information, to a successor entity (or potential buyer) in connection with a proposed or actual corporate merger, acquisition, consolidation, sale of assets, bankruptcy, or other corporate change. In addition, in the event PlushCare becomes the subject of an insolvency proceeding, whether voluntary or involuntary, PlushCare or its liquidator, administrator, receiver, or administrative receiver may sell, license, or otherwise dispose of such information in a transaction approved by the court.
Links to Other Websites
Retention of Personal Information
PlushCare has implemented commercially reasonable physical, technical, and administrative security measures designed to protect your Personal Information, including a secure firewall and use of security infrastructure. As an additional security measure, your Personal Information is also encrypted during transmission using SSL security, an industry standard secure technology. SSL encryption is indicated on your Web browser by the display of a lock or key on the browser status bar. Nonetheless, no such measure is ever 100% effective; therefore, we do not guarantee that your Personal Information will be secure from theft, loss, or unauthorized access or use, and we make no representation as to the reasonableness, efficacy, or appropriateness of the measures we use to safeguard such Personal Information. We encourage you to use caution when using the Internet. This includes not sharing your passwords.
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your Account has been compromised), please immediately notify us by contacting us at [email protected]
Depending on your jurisdiction, you may have certain rights regarding our collection, use, and sharing of your Personal Information. If you have any questions regarding these rights, please contact us at: [email protected] Please note that we may request additional information to respond to or fulfill any requests regarding your rights under applicable laws or regulations.
You can always opt out of any subscription for emails, involving any updates, information, postings, news, and/or press releases, by clicking “Unsubscribe” at the bottom of the email. We might still send you some important emails, like responding to you by email if you send us a request or comment.
Notice to California Residents
The California Consumer Privacy Act of 2018 (“CCPA”), 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.
Information Exempt from the CCPA
Note that certain information that is governed by other laws, such as the California Confidentiality of Medical Information Act (CMIA) or the Health Insurance Portability and Accountability Act of 1996, as implemented and amended (HIPAA), is not considered Personal Information with respect to the rights of California residents noted above. However, additional rights might be available under those laws and standards. For more information, please review our HIPAA Notice of Privacy Practices.
As a California resident, you have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that companies disclose certain information to you about their collection and use of your Personal Information over the past twelve (12) months. This right of access includes information about:
The categories of Personal Information we collected about you
The categories of sources for the Personal Information we collected about you
Our business or commercial purpose for collecting that Personal Information
The categories of third parties with whom we share that Personal Information
The categories of Personal Information that each recipient received
The specific pieces of Personal Information we collected about you
You shall have the right to request that the information described above be provided to you in a portable and readily usable format, to the extent technically feasible (“data portability”).
PlushCare does not sell your personal information.
Deletion and/or Correction Request Rights
You have the right, subject to certain exceptions defined in the CCPA and other applicable laws and regulations, to request that PlushCare delete and/or correct any of your Personal Information that it has collected from you and retained.
To the extent that PlushCare can delete or correct your Personal information, once PlushCare receives and confirms your verifiable consumer request, PlushCare 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 goodor 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, or otherwise perform ourServices.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity,or prosecute those responsible for suchactivities.
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, ifyou 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, PlushCare 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.
California consumers also have the right not to receive discriminatory treatment if they exercise the rights listed herein.
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. PlushCare does not use any of your SPI for any other purposes 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.
Accolade and its affiliates are exempt from the Virginia Consumer Data Protection Act (“VCDPA”).
The VCDPA and other Virginia privacy laws provide Virginia residents (i.e., consumers) with specific rights regarding personal information. The VCDPA applies to for-profit and business-to-business companies that interact with Virginia residents, or process personal data of Virginia residents on a relatively larger scale. However, VCDPA DOES NOT apply to covered entities or business associates under the Health Insurance Portability and Accountability Act (“HIPAA”) and the Health Information Technology for Economic and Clinical Health Act. Accolade and its affiliates (including Plushcare) are covered entities and/or business associates and are not subject to VCDPA.
Although PlushCare does not sell Personal Information, Nevada residents have the right to submit a verified request directing PlushCare not to sell their Personal Information. If you are a Nevada resident, and would like to submit such a request, please send your request to [email protected]
Additional Terms for EU Visitors
The Sites are intended only for users located in the United States. To the extent that you are accessing this website from a location within the European Union, the following information shall apply to the collection and processing of your Personal Information.
The data controller for this Site is PlushCare, Inc. PlushCare processes Personal Information it collects through the Site for PlushCare’s legitimate business purposes, for example to fulfill any requests you may make in connection with your submission of personally identifiable information, to monitor and improve the quality of the Site, and to protect and defend our rights, property or safety or that of our Members and other users of the Site. You may have the right to access and/or obtain a copy of your Personal Information, correct inaccuracies in your Personal Information, request the erasure of your Personal Information and restrict the processing of your Personal Information. For more information about how you can access, rectify and erase your Personal Information or make any other requests relating to your Personal Information or to contact PlushCare, please see the “Contact Us” section of this Privacy Notice below. In addition, you have the right to lodge a complaint with a supervisory data protection authority, contact information is available at https://edpb.europa.eu/about-edpb/board/members_en.
This Service is neither directed to nor structured to attract children under the age of 13 years. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 13 years of age. We will direct potential users under 13 years of age not to use the Service. If we determine that such information has been inadvertently collected on anyone under the age of 13, we will take the necessary steps to ensure that such information is deleted from our system’s database. If you are a parent or guardian and become aware that your child has provided us with information, please contact us using one of the methods specified below.
Email: [email protected]
Mailing Address: 101 Mission St Suite 800, San Francisco, CA 94105