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Privacy Policy

Updated: October 3, 2024

GENERAL INFORMATION

We at Centivo Corporation (“Centivo,” “We,” “Us,” or “Our”) have created this Privacy Notice to apply to all users and clients of this website located at https://www.centivo.com (the “Site”), our Centivo Pre-Enrollment sites (“Pre-Enrollment sites”), our employer portal at https://employer.centivo.com and https://client.centivo.com (“Employer Portal”), our provider portal at https://provider.centivo.com (“Provider Portal”), our referral portal which is made available through https://referrals.centivo.com (“Referral Portal”), our member portal at https://my.centivo.com (“Member Portal”), and all mobile applications (“App”) accessible through tablets, smart phones, and other devices and digital assets offered by us (collectively, our “Services”). Member Portal, Employer Portal, Referral Portal and Provider Portal are collectively referred to herein as the “Centivo Portals.”

This Privacy Notice describes the types of information we collect, how we use it, and your rights concerning your Personal Information (defined below).

We may choose or be required by law to provide different or additional disclosures relating to the processing of Personal Information about residents of certain countries, regions, or U.S. states. Please refer below for disclosures that may be applicable to you.

This Privacy Notice is integrated into our Terms & Conditions of Use (“Terms & Conditions”) https://centivo.com/terms.

This Privacy Policy applies to visitors to the Site, who view only publicly available content (the “Visitors”), Authorized Users (as defined below) of our Customers, and Members (as defined below).

“Customers” means employers who have signed up to access and use our Services made available through the Employer Portal.

“Authorized Users” means employees, contractors, providers, brokers, agents, or representatives of Customer who are authorized by Customer to access and use our Services made available through the Employer Portal or the Provider Portal.

“Members” means (i) employees of Customer, together with their dependents who are enrolled in a health plan administered by Centivo and who have signed up to access and use our Services made available through the Member Portal; or (ii) individuals who have signed up to access and use our Services made available through the Member Portal.

CONSENT

By accessing and/or using our Services and providing us with Personal Information, you agree to the practices described in this Privacy Notice and to the updates posted here from time to time. If you withdraw consent, you agree that despite withdrawal, Centivo may continue to use your Personal Information previously provided to use to the extent that we are legally or contractually obligated to do so and to the extent necessary to enforce any contractual obligations you may have to us. You also understand that by withdrawing your consent, we may no longer be able to provide you with Services previously available with consent. 

If you consented to receiving email communications from Centivo, you will continue to do so unless you unsubscribe. You may choose to opt out or unsubscribe from receiving future marketing email messages from us. Each marketing email sent from us contains a link with instructions on how to remove yourself from our email list.  

PERSONAL INFORMATION

In this Privacy Notice, when we use the term “Personal Information,” and except where a different definition is noted, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to you, directly or indirectly, as defined under applicable laws and regulations. Personal Information does not include information that is not covered by applicable privacy laws, including that which cannot be reasonably linked to you (e.g., de-identified or aggregated data) or publicly available information.

PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect the following types of information about you which are described in more detail below:

  1. Personal Information you provide to us, which may include your name, address, email address, telephone number, and facsimile;
  2. Persona Information we may automatically collect; and
  3. Personal Information we may receive from third parties.

      1. Information You Provide to Us
All the information listed above is detailed below and referred to as “Personal Information.”

  1. In using our Services, you may provide us with Personal Information, including, without limitation, the list below. You may provide us with Personal Information when you ask us to assist you.
  2. General Users. We collect Personal Information provided to use by Visitors to, and Users of, the Services, including, for example, through your use of our Employer or Provider Portal; through our requests to receive information; by completing a registration using the Services, such as registration for an account; and through your contact with customer service. Examples of the types of Personal Information include (but are not limited to) names, email addresses, company addresses, phone numbers, facsimile, zip code, health care dependent identity, background health information, date of birth, gender, and Member ID. You are responsible for ensuring the accuracy of all Personal Information (such as your credit card number) you provide to us. We use third-party tools to collect information from current and prospective Users of our Services, which may include Personal Information, but primarily consists of business contact information.
  3. Job Candidates. Individuals who apply for employment with Centivo will be required to upload a resume or CV and provide their name, mailing address, email address, desired salary information, and work authorization status. Applicants can optionally include a cover letter and information about their social media and communication profiles.
  4. Employers and Providers. Centivo, on behalf of and at the direction of Centivo Clients using certain Services, electronically collect and store certain Personal Information of Users, which may include names, email address, billing and Tax ID/NPI numbers.

     2. Personal Information We Automatically Collect About You
In order to provide certain features and functionality of our Services, we may, automatically collect, through the use of our Services, Personal Information including the website, such as through the use of cookies, tracking pixels (also known as “web beacons”), embedded scripts and similar web tracking technologies (collective, “Web Technologies”), which are described in more detail below, or through security monitoring and recording at our offices and facilities, on phone calls, and through third parties.

This Personal Information may include:

  • System and Device Information
    • We collect information about the computer, tablet, smartphone, or other electronic device you use to connect to our Services.
    • Every computer on the Internet has a unique address called an Internet Protocol (“IP” Address). An IP Address is just like a telephone number in that it is a long string of numbers. IP Addresses are automatically assigned to all Internet Users by their Internet Service Providers (“ISP”). However, since it would be difficult to remember everyone’s IP Address, the Internet allows you to type in an easy to remember name, i.e., a domain name or e-mail address which corresponds to the IP Address. When you use the Internet, your IP Address, as well as other information is automatically logged by web servers.
    • Along with your IP Address, we collect browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers.
    • Internet or other electronic network activity information, including browser and app logs, content you view or engage with, and app, browser, and device information.
    • Domain server from which you are using our Services.
    • Type of computer, web browsers, software, search engine used, operating system, or platform you use.
    • Mobile device information, including the type of device you use, operating system version, your device’s telephone number (if it has one), the device identifier (or “UDID”). This also includes behavior, use, and aggregated usage, performance data, and from where the application was downloaded.
    • Location information related to the IP address of devices used to access the Services, type of browser software, operating system, or mobile device in use, associated region or location data, Internet domain and service provider used, and referring/exit pages from which you linked to our Services.
  • Date and Time
    • Date and time of your visit or use of our Services.
  •  Activity
    • Data identifying the website pages you visited prior to and after visiting our website or use of our Services.
    • Your movement and activity within the website, which is aggregated with other information.
    • For example, the website from which you came and the website to which you are going when you leave our website, how frequently you access the Services, the time you access the Services and how long you use them, whether you open emails or click the links contained in emails, whether you access the Services from multiple devices, interaction with email content, access times, error logs, and other similar information, and other actions you take on the Services. Information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services.
  • Location Related Information
    • Location data generally, or with your consent, your precise GPS location.
  • Social Media
    • Information provided by social networks connected to the Service, in accordance with your privacy settings on the social media platform. The connected social network may provide us with information such as your name, ID, profile picture, network, gender, username, user ID, email address, friend list, age or age range, language, country, friends list, follower list, photos, location, generated contact, and any other information you have agreed it can share or that the social network provides to us. It also includes information you provide to us directly through our Services on social media networking and blogging platforms (e.g., Facebook, Instagram, YouTube, and X).
    • Inferences drawn from any of the information identified above reflecting your preferences and characteristics.

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Cookies & Technologies Used to Collect Information About You

We collect the above Personal Information directly and through the use of third parties. We collect this Personal Information by using certain technologies, such as cookies, web beacons, and other technologies. Third-party service providers, advertisers, and/or partners may also view, edit, or set their own cookies or place web beacons. The use of these technologies by such third parties is subject to their own privacy notices and is not covered by this Privacy Notice, except as required by law.

Cookies (or browser cookies)

Cookies and similar technologies are small files of letters and numbers that we store on your web browser or the hard drive of your computer or mobile device. Cookies contain information that is transferred to the hard drive of your computer or mobile device and enable the website’s or service provider’s systems to recognize the user’s browser and capture and remember certain information.
Cookies may be sent to your browser’s temporary memory system to assist you in navigating during a particular session only, or a cookie can be sent to your hard drive to serve you better when you return to the website (for example to recognize you when you return to the website, to save your password and to offer you customized content).

There are three types of cookies that we may use:

  1. Strictly Necessary: These cookies are essential to enable you to browse our Site and use its features. The information collected by these cookies relate to the operation of our Site (e.g., website scripting language and security tokens to maintain secure areas of our Site).
  2. Performance/Analytics: These cookies collect anonymous information about how you use our Site (e.g., which pages you visit most often, whether you receive any error messages, and how you arrived at our Site). Information collected by these cookies is used only to improve your use of our Site and never to identify you.
  3. Functionality: These cookies remember choices you make (e.g., the country you visit our Services from, your language and any changes you have made to text size or other parts of web pages that you can customize), to improve your experience of our Services and to make your visits and use more tailored and enjoyable. The information these cookies collect may be anonymized and cannot be used to track your browsing activity on other websites.

Most Internet browsers are automatically set up to accept cookies. However, if you want to refuse or delete any cookies (or similar technologies), please refer to the help and support area on your Internet browser for instructions on how to block or delete cookies. Please note you may not be able to take advantage of all the features of our Site, including any personalized features, if you delete or disable cookies.

You can set your browser to notify you when you receive a “cookie” giving you the opportunity to accept or refuse it. See “Help” in your browser. Deleting or not accepting cookies will not prevent you from accessing this website or participating on the website. However, if you do not employ the technology your navigation may be less convenient or personalized given the purposes for cookies.

You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.

Some website browsers have incorporated “Do Not Track” features that send an automated signal to the websites that you visit using that browser. Currently, the Services do not recognize or respond to these signals. However, you can adjust your preferences regarding the data we collect using the tools and methods described above.

For more information on managing cookies, please go to www.allaboutcookies.org or http://www.aboutads.info which have further information about behavioral advertising and online privacy.

Flash Cookies

We may use local shared objects, also known as Flash cookies, to store your preferences such as volume control or display content based upon what you view on our site to personalize your visit. Third parties, with whom we partner to provide certain features or to display advertising based upon your browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount and type of data stored and the method of storing this data. Cookie management tools provided by your browser will not remove Flash cookies.

For Flash cookies, you can access Flash management tools from Adobe’s website. In addition, some, but not all, browsers provide the ability to remove local shared objects within cookie and privacy settings.

Web Beacons

Website pages may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages and for other related statistics (for example, recording the popularity of certain content and verifying system and server integrity). We also use these technical methods to analyze the traffic patterns, such as the frequency with which our users visit various parts of the Services. These technical methods may involve the transmission of information either directly to us or to a third party authorized by us to collect information on our behalf. Our Services may use retargeting pixels from Google, Facebook, and other ad networks. We may also use web beacons in HTML emails that we send to determine whether the recipients have opened those emails and/or clicked on links in those emails.

Analytics

Analytics are tools we use, such as Google Analytics, to help provide us with information about traffic to our website and use of our Services, which Google may share with other services and websites who use the collected data to contextualize and personalize the ads of its own advertising network. Learn more about Google’s Privacy Notice here: https://policies.google.com/privacy?hl=en-US. You can opt out of having your activity on our Services made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout.

Mobile Application Technologies

If you access our website and Services through a mobile device, we may automatically collect information about your device, your phone number, and your physical location.

By using our Services, you agree that we may contact you by calling or sending messages to your phone, including messages sent to your personal telephone device, i.e., “Mobile Push Notifications.” You can use the settings on your mobile device to enable or turn off mobile push notifications from us or Contact Us https://centivo.com/get-in-touch/ directly at privacy@centivo.com.

     3. Personal Information We May Receive from Third Parties

We may collect additional Personal Information about you from our affiliates, partners or vendors, third-party analytics services the Centivo Portals and the Centivo Pre-Enrollment sites, social media platforms, such as, but not limited to, Facebook, X, Instagram, LinkedIn (“Social Media Platforms”), and/or sources providing publicly available information (e.g. the U.S. Postal Service) to help us provide the Services to you, confirm, enhance, or supplement our existing information about you (e.g. with your consent, background checks for credit history), help prevent fraud, maintain security, and for marketing, advertising, and other business purposes.

Personal Information we may access about you, with your consent, may include, but is not limited to, your basic social media platform information, your location data, your list of contacts, friends or followers and certain information about your activities on the Social Media Platforms. This information is used by Centivo for the operation of our Services, to maintain quality of the service, and to provide general statistics regarding the use of Centivo Services. Please keep in mind that when you provide Personal Information through Centivo public message boards or on a third-party website or platform (for example, via our applications), the information you provide may be separately collected by the third-party website or the social media platform. Note: Centivo does not read any of your private online communications.

We may also collect Personal Information to perform our Services, including billing, public filings, and other information available from third-party websites.

The Personal Information we collect is covered by this Privacy Notice, and the information the third-party website or social media platform collects is subject to the third-party website or platform’s privacy practices. We encourage you to review the privacy statements of websites you choose to link to from Centivo so that you can understand how those websites collect, use, and share your Personal Information. Centivo is not responsible for the privacy statements or other content on websites outside of Centivo. You are responsible for reading those privacy statements on third party websites.

For information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out, you may not be able to use our Services.

TEXT MESSAGES

You may opt-in to receive SMS text messages from us relating to the Centivo Portals and Services. By opting-in to receive SMS text messages from us, you acknowledge that messaging and data rates may apply depending on your phone service provider. You may opt-out of receiving SMS text messages at any time by texting STOP in response to the text messages you receive or by changing your notification and communication preferences in the App. However, by opting-out of receiving text messages, you may not be able to use full functionality of the Centivo Portals.

HOW WE USE YOUR PERSONAL INFORMATION

We use and process your Personal Information for purposes that may include, but are not limited to:

  • Operating the Centivo website and providing our Services to you;
  • Inform you about other products and Services available from Centivo;
  • Provide related products, promotions, newsletters, and information you request;
  • Contact you via surveys to conduct research about your opinion of current Services or of potential new services that may be offered;
  • Respond to your inquiries and provide you with requested information and other communications, including by email, text, or chats, including customer support services;
  • Personalize or customize your experience;
  • Allow you to participate in interactive features when you choose to do so;
  • Deliver location-based Services and comply with the territorial requirements and restrictions;
  • Fulfill contracts we have with you;
  • Maintain, improve, customize, or administer the Services, perform business analyses, or other internal purposes to improve the quality of our business, the Services, resolve technical problems, or improve security or develop other products and Services,
  • Comply with our Terms & Conditions;
  • Assess your application for employment;
  • Perform analytics for business purposes and business intelligence, including how Services are used so we can improve and expand upon them;
  • Comply with any applicable laws and regulations and respond to lawful requests;
  • Operate our business;
  • For any other purposes disclosed to you at the time we collect your information and/or pursuant to your consent.

SHARING OF YOUR PERSONAL INFORMATION

Centivo does not sell or share your Personal Information to third parties for monetary or other valuable consideration as defined under the California Consumer Privacy Act. However, Centivo may share your Personal Information as set forth in this Privacy Notice and in the following circumstances:

  • Agents, Providers and Related Third Parties. We may share your Personal Information with third party service providers or data processors that perform certain business-related functions or services on our behalf (such as to provide technical assistance, store or manage data, provide customer service, perform analyses, provide marketing assistance, or send communications for us). These other companies will process this data only for purposes as specified by us and will be bound by contract to meeting our obligations to the extent permitted by law. We may also share your Information with any of our parent companies, subsidiaries, or other companies under common control with us.
  • Aggregated Information. In an ongoing effort to better understand users of the Site, Centivo Portals, Centivo Pre-Enrollment sites and the Services, we may analyze the Information in aggregate form in order to operate, maintain, manage, and improve the Site, the Centivo Portals, the Centivo Pre-Enrollment Sites and the Services. This aggregate information does not identify you personally. We may use this aggregate information for marketing purposes. We may share this aggregate information with our affiliates, agents, business and business partners, and other third parties. We may also disclose aggregated user statistics in order to describe the Site, the Centivo Portals, the Centivo Pre-Enrollment sites and the Services to current and prospective business partners and to other third parties for other lawful purposes.
  • Safety and Security. We may share your Personal Information to protect the safety and security of our users and Customers, to prevent fraud, abuse, or unauthorized activities, to protect the rights of property of us, third parties, you, or others, including enforcing the terms of our agreements.
  • Business Transfers. To fulfill our everyday business purposes.
  • Legal and Administrative Reasons. We may disclose your Personal Information without notice: (i) when required by law, court order, subpoena, search warrant, or other legal process; (ii) to cooperate or undertake an internal or external investigation or audit; (iii) to comply with legal, regulatory or administrative requirements of governmental authorities (including, without limitation, requests from the governmental agency authorities to view your Personal Information); (iv) to protect and defend the rights, property of safety of us, our subsidiaries, and affiliates and any other officers, directors, employees, attorneys, agents, contractors, or partners, and the website Service users, (v) to enforce or apply our Terms & Conditions; (vi) to verify the identity of the user of our Services; and (vii) whenever we believe that disclosing such Information is necessary or advisable.
  • With Your Consent. We may share Personal Information consistent with this Privacy Notice with your consent.
  • Lawful Purpose. For other purposes permitted by law.

ACCESSING AND MODIFYING PERSONAL INFORMATION AND COMMUNICATION PREFERENCES

If you have signed up to use the Services, you may access, review, and make changes to your Personal Information by following the instructions found on the Centivo Portals. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Centivo marketing email. You cannot opt out of receiving transactional e-mails related to your account. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases.

HOW WE HELP PROTECT PERSONAL INFORMATION

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information that you supply will not be intercepted while being transmitted to and from us over the Internet. In particular, e-mail sent to or from the Site or the Centivo Portals or the Centivo Pre-Enrollment sites may not be secure, and you should therefore take special care in deciding what information you send to us via e-mail.

CONSUMER DATA PRIVACY RIGHTS

  • A.  Your Rights. You may reside in a state that provides certain privacy rights that are applicable to Centivo. For certain U.S. consumers who are protected by comprehensive privacy laws, the  provisions of this Section prevail over any conflicting provisions in other sections of this Privacy Notice.
  • B.  Collection of Personal Information. Personal Information that we collect includes your account and profile information, your content, your communications with us, and information about your activity and engagement with the Centivo platform(s).
  • C.  Use and Disclosure. As referenced throughout this Privacy Notice, Centivo discloses the Personal Information we collect for business purposes, to provide our Services, to comply with applicable law, and to prevent misuse of the Services.
  • D.  Resources. We only share your Personal Information with service providers, affiliates, law enforcement authorities, and as needed with third parties to provide our Services. We do not sell and, within the last 12 months, we have not sold, Personal Information.
  • E.  Consumer Rights. U.S. consumers in states with applicable data protection laws have the right to make the following requests of Centivo regarding their Personal Information:
    • Right to Know/Access: The right to request that we disclose to you the Personal Information we have collected about you over the past twelve (12) months.
    • Right to Request Correction/Ratification: The right to request that we correct inaccurate Personal Information that we maintain about you.
    • Right to Request Deletion/Erasure: The right to request that we delete your Personal Information that we have collected from or about you.
    • Right to Opt Out/Withdraw Consent: The right to opt out of the sale or sharing of Personal Information or opting out of processing of your Personal Information obtained from your activities on nonaffiliated websites or online applications for the purposes of targeted advertising. You may also object to automated decision making.
    • Right to Object To, Limit Use and Disclosure/Restrict Processing. The right to limit the use and disclosure of Personal Information, including transfers of your information to other parties.
    • Right to Data Portability: The right to receive the Personal Information collected in a format easily understandable and in a usable format.
    • Right to Non-Discrimination: The right not to receive discriminatory treatment for exercising your privacy rights.
    • Right to Limit the Use of Sensitive Personal Information: This right applies only to California consumers; “Sensitive Personal Information” which includes, but is not limited to, information such as financial account information, credit card numbers, precise geolocation, racial or ethnic origin, citizenship, or immigration status.

You may request to exercise the rights above by:

Email:
privacy@centivo.com

Address:
Centivo Privacy Officer
199 Scott Street, Suite 800
Buffalo, New York 14204

  • As required under applicable law, please note that we will take steps to verify your identity before granting you access to information or acting on your request to exercise your rights. We may require you to provide your email address to verify your identity in response to exercising requests of the above type. You will, therefore, need access to your email account to receive our communications necessary to process your request. Please make sure to check your spam inbox to ensure these important communications are not missed. We may limit our response to your exercise of the above rights as permitted under applicable law.
  • F.  Designated Agent. You may designate an agent to make a request on your behalf. That agent must have access to your account in order for us to verify the request. You may make such a designation by providing the agent with written permission to act on your behalf. We will require the agent to provide proof of that written permission. As permitted by law, we may require you to verify your own identity in response to a request, even if you choose to use an agent.

HOW WE PROTECT THE INFORMATION

Centivo employs commercially reasonable measures as it relates to physical, electronic, and procedural safeguards to help protect your Personal Information. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, nor should you expect, that your information or private communications will always remain private or secure. We do not guarantee that your Personal Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features. You agree that we will not have any liability for misuse, access, acquisition, deletion, or disclosure of your Personal Information.

It is your responsibility to maintain the confidentiality of your login credentials and unique identifiers used to access the Services. You are also responsible for ensuring the accuracy of the Personal Information you submit to Centivo. Submitting inaccurate Personal Information or failing to maintain the accuracy of Personal Information that changes (for example, a change of email address) may disrupt your ability to use our Services, may affect the Services you receive from us, and may impact our ability to contact you.

If you believe that your Personal Information has been accessed or acquired by an unauthorized person, promptly Contact Us https://centivo.com/get-in-touch so that necessary measures can quickly be taken.

CHILDREN

Our Services, including our website and any mobile applications, are intended only for users over the age of eighteen (18).

CHILDREN: If you are under eighteen (18) years of age, please do not use or access our Services at any time or in any manner. Please Contact Us https://centivo.com/get-in-touch at privacy@centivo.com if you believe that we have mistakenly or unintentionally collected information from a child under the age of eighteen (18). We will take prompt and appropriate steps to delete it.

EXTERNAL WEBSITES

The Site may contain links to third-party websites (“External Sites”). We do not endorse such External Sites and we are not responsible for the privacy practices of such External Sites. We do not disclose your Personal Information to these third-party websites without obtaining your consent. In addition, from our Services you may be able to interact with social media platforms, for example, by “liking” us on Facebook. If you choose to click on a link to one of these third-party websites or choose to interact with or through a social media platform, your activities are not governed by this Privacy Notice and will be governed by the Privacy Notice on that third-party website or social media platform. This Privacy Notice only applies to Personal Information collected by us. Please review their privacy notices and terms of service before disclosing any Personal Information to determine their respective privacy practices. Centivo does not review, does not endorse, and is not responsible for the privacy practices of these third-party websites and social media platforms.

  • We may also maintain a page on Facebook or other social media platforms. Those pages and your interaction with them are governed by the privacy notices of Facebook or other relevant social media platform, and not our Privacy Notice. As with other third-party websites, we do not endorse and are not responsible for the privacy practices of these forums, although we may have a presence on them.
  • We are not responsible for the privacy and security practices of those other websites or social media platforms or the information they may collect (which may include IP address). You should refer to such third parties’ privacy notices on their sites to determine their respective privacy practices.

CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the date stated at the top of this Privacy Notice. We reserve the right to change, modify, or amend this Privacy Notice to reflect company and customer feedback, changes in our services, accommodate new technologies or regulatory requirements, or for other purposes. If we modify our Privacy Notice, we will post any changes on the Site, the Centivo Portals or the Centivo Pre-Enrollment sites, and update the “Effective Date” below. Such changes will be effective upon posting. By accessing and/or using the Site, Centivo Portals or the Centivo Pre-Enrollment sites after we make any such changes to this Privacy Notice, you are deemed to have accepted such changes. Please refer back to this Privacy Notice on a regular basis.

HOW TO CONTACT US

If you have questions about this Privacy Notice, please e-mail Centivo’s Privacy Officer at privacy@centivo.com, with “PRIVACY NOTICE” in the subject line, or mail us at the following address:

Centivo Privacy Officer, 199 Scott Street, Suite 800, Buffalo, NY 14204