Privacy Policy

Web Site Privacy Policy

Last updated: February 2024

The Website Privacy Policy (“Policy”) of Sterling Health Services, Inc. applies to Sterling Administration, Sterling Managed Services, and Amazing Care Network (collectively, “We”, “Us”, or “Our”. We are committed to providing transparency into our policies and practices in protecting the confidentiality and security of your Personal Information. For purposes of this Policy, “Personal Information” means any information about you that you voluntarily provide or that can directly or indirectly identify you or your household.

YOUR CONSENT

By using our website (“Site”), you consent to the collection, use and disclosure of your Personal Information for the purposes described in our Terms of Use and Privacy Policy. Please contact us if you have any questions or concerns about our use of your Personal Information. Our contact details are in the Contacts section of this Policy.

PURPOSE

This Privacy Policy describes the types of information we collect and how we obtain, use, disclose, retain, and safeguard that information when you visit our Site, use our applications, execute transactions on our digital platforms or interact with our online services for other reasons relating to the services and products we provide. We also explain your privacy rights as they relate to our services that are linked to this Policy and your choices about the Personal Information you provide us.

PERSONAL INFORMATION WE COLLECT-

We collect various categories of Personal Information. Depending upon our relationship with you and the reason for your visit to our Site, the information we collect may consist of personal information that: you voluntarily provide; we obtain from third parties; or is automatically collected from your device when you visit our Site. More specifically, we may collect:

Information You Provide Voluntarily when you request information about our products and services or submit inquiries.

Information You Provide Voluntarily through our online portal:

to create your Account-based plan (“Account”), such as a Health Savings Account (HSA) and similar plans that we administer. We will obtain Personal Information such as your name, Social Security number, date of birth, postal and email addresses, telephone number, driver’s license number and other unique personal identifiers directly from you when you submit the required enrollment forms.
to enable you to control and manage your Account; for example:
to make financial transactions to and from your Account. You may be requested to provide your bank account information such as your bank account number and other details. When transactions involve the electronic transfer of funds, you will be asked to provide additional information to facilitate this transaction and to verify your identity. Such information may include your date of birth, passport or National ID card, bank card statement, or other information linking you to a home or business address.
To give you the ability to control and manage your Account; for example, to designate Account beneficiaries; to upload required substantiation of reimbursement claims, and other Account management activities.

Information That is Automatically Collected

We obtain Usage Data automatically when you access our Site from your devices through the use of Cookies and similar tracking technologies. For example, the data derived from your computer, mobile phone, or tablet helps us to analyze your activity on our Site so that we can improve your experience. Such Usage Data may include, but is not limited to, your device’s Internet Protocol (IP) address, browser type, browser version, the visited webpages, visit date and time, the time spent on those pages and other analytics data. If you linked to our Site from a different website, the address of that website is collected. Usage data helps us to analyze the effectiveness and performance of our Site.

When you access our Site by or through a mobile device, information specific to this device is automatically collected. In addition to web analytics data, such information may include the mobile device model, unique ID, mobile operating system, mobile Internet browser, and other unique device identifiers.

Information from Other Sources

We may obtain Personal Information about you from third parties, for example, our service providers, your employer on whose behalf we provide employee benefit administration and compliance services, and public and non-public information from other sources.

HOW PERSONAL INFORMATION IS OBTAINED

Your Personal Information is collected through our Site when you:

request information about our services
submit forms to create and manage your Account such as an account enrollment form, beneficiary designation form, and forms for financial transactions.
manage your Account through our online portal
register for our online services
request customer service
sign up to receive our newsletters and marketing materials or when you respond to our questionnaires or surveys
contact us regarding a question or concern

HOW PERSONAL INFORMATION IS USED

We will only use Personal Information for the purposes for which it was originally obtained. We collect and process the Personal Information you provide us for the following purposes:

To fulfill our contractual obligations to you; for example, to establish and administer your Employee Benefit Account plan; to assist you and your company in complying with regulatory requirements to which you may be subject as an Employee Benefit Plan sponsor; or to provide other related services that you request
To manage your registration as an authenticated user of the Site and ensure the performance of functionalities that are available to you as a registered user
To verify your access to our online services and resources
To process transactions you initiate through our online portal, for example, for deposits to, and withdrawals from, your account
For internal administrative and operational purposes
To contact you by email, telephone, SMS, or other forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including security updates, when necessary or reasonable for their implementation.
To provide you with news, special offers, and general information about our products and services based on your purchase history (unless you have opted not to receive such information).
To respond to your request for customer support or technical assistance
To provide and maintain our Site, including to monitor its usage and to conduct audits, testing and other activities to ensure the security of the Site
To protect our company’s business operations and enforce our Site’s Terms of Use
For other purposes we disclosed to you when we collected your Personal Information

WHEN PERSONAL INFORMATION IS SHARED

We do not sell your Personal Information. We may share your Personal Information in the following circumstances:

With Affiliates: we may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. ‘Affiliates’ may include any subsidiaries, joint venture partners, or other companies that we control or are under common control with us.
With Authorized Third-Party Service Providers to perform certain services on our behalf. We allow your Personal Information to be used by such Providers only to the extent necessary to provide services to us:
- that support our operations; for example, to monitor and improve the performance of our Site, to analyze Site traffic, and address technical problems; to provide marketing or auditing services, or other services provided at our direction; or
- that are needed to assist us in providing specialized services to you. Our Site may include functionality that permits the disclosure of your Personal Information on a third-party’s website to provide administrative services to you; for example, for COBRA account administration; for billing and payment processing, and other related services.
With Other Service Providers with your Consent and at your Direction, for example, if you request that we transfer funds in your Health Savings Account to a financial institution that offers investment services.

Every Third Party with whom we share Personal Information is obligated to use it only for the limited and specific purposes for which such information is provided and is required to comply with applicable government regulations that govern the protection of Personal Information.

For Business Transfers: we may share or transfer your personal information in connection with, or during negotiations of, any merger, sale of Company assets, financing, or acquisition of all or a portion of our business to another company. We will notify you before your Personal Information is transferred and becomes subject to a different Privacy Policy.
With Law Enforcement Authorities, Regulatory Agencies, or the Courts to enable us to comply with valid subpoenas, court orders or other legal process or requirements.
To Comply with other Legal Requirements or to Protect our Legitimate Business Interests. We may disclose your Personal Information in the good faith belief that such action is necessary to:
- Satisfy other legal, regulatory, or industry requirements
- Protect and defend Sterling’s rights or property
- Protect the personal safety of our staff, clients, users of our Site or the public from imminent harm
- Prevent or investigate possible wrongdoing in connection with the use of our Site
- Prevent or investigate possible wrongdoing that may expose us to legal liability or material financial loss

LINKS TO SOCIAL MEDIA AND OTHER WEBSITES

Our Site may contain links to content provided by other websites and social media sites that are not created or operated by us. If you click on a third-party link, you will be directed to that third party’s website. We strongly advise you to review the Privacy Policy and Terms of Use of every website you visit. When you link to another website, you are subject to the policies, terms, and conditions of that site which may differ from ours. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party websites to which we link.

Retention of your Personal Information

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy after which time it will be deleted or destroyed. We will retain and use your Personal Information to the extent required to comply with applicable laws, resolve disputes, support auditing and investigations, and enforce our legal agreements and policies. To maintain its confidentiality and security, we store retained Personal Information on encrypted servers.

We will retain Usage Data for internal analysis purposes for a short period. However, we may retain this data for a longer period in order to improve our service security or functionality.

PROCESSING OF YOUR PERSONAL INFORMATION

Your information, including Personal Information, is processed at our operating offices and other locations. We may transfer and maintain such information on computers located outside your state, country, or governmental jurisdiction where the data protection laws may differ from those of your location. Your consent to this Privacy Policy, followed by your submission of your Personal Information, signifies your agreement to such transfer. We will not transfer your Personal Information to any external organization or country unless there are adequate controls to ensure its security during the data transfer process. We will take all reasonably necessary steps to ensure that your personal information is transferred, processed, and stored securely and in a manner consistent with this Privacy Policy.

ACCURACY OF YOUR PERSONAL INFORMATION

It is important that the Personal Information you provide to us is accurate and complete. You may update your Personal Information at any time by logging into your Sterling account to correct, supplement, or delete incorrect or obsolete information. If you require assistance to do this, you may contact us as indicated in the Contact Information section.

SECURITY OF YOUR PERSONAL INFORMATION

We have put in place operational, technical and other safeguards to protect this site and your Personal Information from unauthorized access, use or disclosure, modification, destruction or loss. We take appropriate measures to implement privacy and security protections in our administration of programs, operations, and delivery of requested services. Despite these measures, however, no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security.

YOUR PRIVACY RIGHTS

When you visit our Site, you may have rights over the handling of your Personal Information under applicable federal and state law. Without limitation to, and subject to the exceptions allowed by law, such rights may entitle you to:

– decline to provide your Personal Data
– request to access your Personal Information
– request to rectify or delete your Personal Information
– limit the use and disclosure of your Sensitive Personal Information
– exercise your privacy rights guaranteed under applicable laws without being discriminated against for doing so;
– unsubscribe to informational materials, such as newsletters

Our “Do Not Track” (DNT) Policy as Required by the California Online Privacy Protection Act (CalOPPA)

Our Site does not respond to Do Not Track signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such sites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser.

Children’s Privacy

Our website does not address anyone under the age of 16. We do not knowingly request personally identifiable information from anyone under the age of 16. If you are a parent or guardian of a child under 16 years and you learn that your child has provided us with Personal Information, please contact us using the contact information below. If we become aware that we have obtained Personal Information from anyone under the age of 16 without verification of parental consent, we will take steps to remove that information from our servers. We may also limit how we collect, use, and store some of the information of users between 16 and 18 years old. This means we will be unable to provide certain functionality of the website to these users.

CHANGES TO THIS PRIVACY POLICY

We suggest that you review our Privacy Policy periodically as we may update it from time to time. We will notify you in advance, via email and/or by posting a prominent notice on our Site, of any material changes to our privacy policies or practices. The date of the last update will be noted on the top of our policy statement. Your use of our services will be subject to the updated policy when it is posted.

CONTACT US

If you have any questions about this Privacy Policy, you can contact us:

By email: Privacy@sterlingadministration.com

By phone: 800-617-4729

By mail: P.O. Box 71107 Oakland, CA 9461