VCOSH Privacy Policy

VCOSH Healthful Rewards Platform ("VCOSH") is offered by UEFMS. UEFMS provides web and mobile delivery of traditional health, wellness, and other services designed to allow you to manage all of your health information in one place. VCOSH allows users to redeem healthy activities for travel, entertainment, and other incentives. The VCOSH platform and services may be offered through your employer, health plan, or other program sponsor, always on a voluntary basis. UEFMS is a Kingdom of Saudi Arabia based corporation, organized under the laws of Kingdom of Saudi Arabia.

UEFMS values your trust, and protecting your information is our highest priority. UEFMS is committed to your privacy. This Privacy Policy explains what information UEFMS and its affiliates (collectively, “UEFMS” or “We”) collect, how information is collected, how we use that information, what information is shared with whom, and how UEFMS protects your information when you use our products and services (“Services”).

By participating in VCOSH, UEFMS may collect the following about you:

• Personal Information. This is information that directly or indirectly identifies you, such as your name, email address, or other identifying information about you.
• Protected Health Information (“PHI”). In some situations, incentives are offered by a program sponsor for your participation in a health plan or wellness program. Some limited information may be considered PHI. PHI is your Personal Information related to healthcare that is protected under the Saudi Health Information Exchange Policies (“SHIEP”). SHIEP and other laws closely regulate how UEFMS may handle, protect, and share your PHI. The VCOSH program does not collect any medical or diagnosis information about you. For more information visit Saudi Health Information Exchange Policies - Policy .
• Only if you choose so and accept, VCOSH will collect and read your contacts' information to enable you to find your friends that are already part of the VCOSH community or to allow you to invite those who aren’t. Your contacts list will only be accessed temporarily and it won’t be stored on our servers.
• Other Information. Other Information is information that, by itself, does not individually identify you such as browser type, operating system, technical data, and usage. We may link together different types of Other Information or link Other Information to Personal Information.

We collect information in the following ways:

• Information You Give Us Upon Registration. Many of our Services require you to sign up for a VCOSH Account. When you do, we’ll ask for Personal Information like your name, email address, telephone number or credit card. If you want to take full advantage of the sharing features we offer, we might also ask you to create a publicly visible VCOSH Profile, which may include your name and photo.
• Information from Your Employer, Health Plan, or Program Sponsor. When you are eligible to participate in a sponsor’s program, your employer, health plan, or program sponsor may send us information that we can use to verify your eligibility and a unique identification number, among other things. We use this information to provide services to you on behalf of your health plan, employer, or program sponsor.
• Information We Get from Your Use of Services. We may collect information about the Services that you use and how you use them. This information includes:
• Information You Provide. We may collect information provided by you while using our Services.
• Computer, Tablet, or Mobile Telephone information. We may collect device-specific information such as your hardware model, operating system version, unique device identifiers, device sensors and mobile network information including phone number. UEFMS may associate your device identifiers or phone number with your VCOSH Account. We will comply with the usage/license restrictions and requirements applicable to the device from which the information comes.
• Cookies and Anonymous Identifiers. We use various technologies to collect and store information when you visit a VCOSH, and this may include sending one or more cookies or anonymous identifiers to your device, pursuant to our Cookie Policy. We also use cookies and anonymous identifiers when you interact with Services we offer to our partners, such as UEFMS features that may appear on other sites.

• To Provide Services to You. We use the information that we collect about you to provide, maintain, protect, and improve the Services that UEFMS provides to you.
• To Provide Enterprise Programs to You. We use the information that we collect about you to provide Services on behalf of a health plan, employer, or program sponsor to you.
• Analytics. We use analytics tools and other third-party technologies, such as Google Analytics, to collect non-Personal Information in the form of various usage and user metrics when you use our site. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device, and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and demographics, and other similar information.
• To Improve Our Services. We use de- identified, anonymous information that we collect about you for statistical and analysis purposes to improve our products and services, and to provide population statistical analysis and well-being trend information.

We take your privacy seriously. We do not sell your Personal Information to third parties and all information disclosed is the minimum amount necessary to fulfill the legitimate business purpose. We do not sell anyone’s sensitive data to data miners or data brokers. We do not share Personal Information with organizations and individuals outside of UEFMS except in the following circumstances:

• With Your Consent. We may share your Personal Information with companies, organizations, or individuals outside of UEFMS when we have your consent to do so.
• As Part of a Sponsored Program. We may share your information according to the direction of your health plan, employer, or program sponsor and any privacy policy and/or contractual requirements that they may ask us to comply with. This may include sharing limited information to your health plan, employer, or program sponsor. We will not share your PHI with your employer for employment-related purposes. We may only share the information needed for your employer to deliver the sponsored program. For example, we may share completion status of a wellness plan requirement but not the actual results of the required action or activity.
• Third-Party Service Providers. We may disclose your information to our business associates who perform various functions on our behalf, but UEFMS requires these third parties to agree in writing to safeguard your information appropriately and in accordance with the law.
• For Legal Reasons. We may disclose any information about you when, in our opinion, such disclosure is necessary to prevent fraud or to comply with any statute, law, rule or regulation of any governmental authority or any order of any court of competent jurisdiction.
• After Being Fully Deidentified, Incapable of Reidentification. We may share aggregated, de-identified information publicly and with our partners to evaluate the effectiveness, value, and analytic trends of the Services.

We work hard to protect UEFMS and our users from unauthorized access to or unauthorized alteration, disclosure, or destruction of information we hold. In particular:

• We comply with SHIEP’s security rule
• We review our information collection and storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
• We restrict access to Personal Information to UEFMS employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
• We keep Personal Information housed on servers in the Kingdom of Saudi Arabia.
• For Android devices: a VCOSH’s use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy , including the Limited Use requirements.

We store Personal Information for as long as required under applicable law. Where there is no legal, fiscal, administrative, or contractual requirement to retain information for a longer or shorter period, information will be destroyed within five (5) years of its collection.

People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. As such, your privacy rights include:

• Transparency and the right to information. Through this policy we explain how we use and share your information. However, if you have questions or need additional information you can contact us any time at info@ahsera.com.
• Right of access, restriction of processing, erasure. You may contact us to request information about the Personal Information we have collected from you, or to request that your Personal Information be deleted. We will do our best to honor your requests, subject to any legal, ethical, and contractual obligations. To make a request or to ask us a question about our data practices, please contact us via email at info@ahsera.com. When requesting access to your Personal Information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the Personal Information that we hold about you.
• Right to withdraw your consent at any time.
• Terminating Your Account. You may terminate your account with us at any time by contacting our Customer Service or emailing info@ahsera.com Terminating your account will revoke any applicable consents or opt-ins but will be subject to any data retention requirements as described below.

Retention of Collected Information. Except as otherwise permitted or required by applicable law or regulatory requirements, we will retain your Personal Information only for as long as we believe it is necessary to fulfill the purposes for which the Personal Information was collected (including for the purpose of meeting any legal, accounting, or other reporting requirements or obligations). You may request that we delete the Personal Information about you that we hold, as described above.

Cookies. You may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set by us. However, many of our Services may not function properly if your cookies are disabled. For example, we may not remember your location preferences. See our Cookie Policy for more information.

Our Privacy Policy may change from time to time. This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party. If we change this Privacy Policy, we will post any privacy policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email and/or posting a notice in the Services. UEFMS reserves the right to modify this Privacy Policy at any time, so please review it frequently.