OPENNETWORKS COOPERATIVE PRIVACY AND COOKIES POLICY

Last Revised on January 13, 2025

Welcome to the OpenNetworks Cooperative, Inc. (“OpenNetworks”) Privacy and Cookies Policy (the “Privacy Policy”) for https://opennetworks.org/ (the “Website”). This Privacy Policy describes how we collect, use and disclose information from our users, including with respect to the Website and its related content, applications, services, tools and features (collectively with the Website, the “Services”). For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services. If you use the Services on behalf of a company or other entity then “you” includes you and that entity, and you represent and warrant that (a) you are an authorized representative of the entity with the authority to bind the entity to this Privacy Policy and (b) you agree to this Privacy Policy on the entity’s behalf.

The Services can only be accessed and used subject to the Terms of Service and this Privacy Policy. PLEASE READ THIS PRIVACY POLICY CAREFULLY. BY USING, ACCESSING, OR DOWNLOADING ANYTHING ON THE SERVICES, YOU AGREE THAT YOU ARE BOUND BY THE TERMS OF SERVICE AND PRIVACY POLICY. IF YOU DO NOT AGREE TO OUR TERMS OF SERVICE AND PRIVACY POLICY, THEN YOU MAY NOT ACCESS AND USE THE SERVICES.

1. SCOPE OF SERVICES

OpenNetworks provides an open marketplace for purchasers and providers of healthcare services. Our network operates through contracts that enable employers and other purchasers to access agreements with healthcare providers that govern reimbursement, credentialing and payment.

1. TYPES OF INFORMATION WE MAY COLLECT

We may collect the following categories of information from you (“Information”), which includes:

• “Personal Information” means Information that identifies (whether directly or indirectly) a particular individual, such as the individual’s name, postal address, phone number and email.
• “Non-Personal Information” means Information that does not directly or indirectly identify, and cannot reasonably be used to identify, an individual user. When Non-Personal Information is directly or indirectly associated with Personal Information, this Non-Personal Information is treated as Personal Information.
• Information you provide to us when you access or use the Services and each time you interact with the Services.
• Information you provide in public forums through the Services.

1. HOW WE COLLECT YOUR INFORMATION

• We collect Information you provide to us when you use the Services. The Information we collect is covered by this Privacy Policy. Privacy choices you make on any third-party site or platform will not apply to our use of the Information we collect directly through our Services.
• We use third parties’ analytic and tracking tools to better understand who is using the Services, how people are using the Services and how to improve the effectiveness of the Services and its content. Those third-party companies may use cookies, pixel tags or other technologies to collect and store Non-Personal Information such as time of visit, pages visited, time spent on each page of the Service, device identifiers, type of operating system used and other website(s) you may have visited. They might combine information they collect from your interaction with Service with Personal Information they collect from other sources. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies.

1. USE OF YOUR INFORMATION

We may use your data for the following purposes:

• To provide you with the Services, upon your request;
• To communicate with you about features of the Services or changes to our policies;
• To ensure consistency with local law and choices and controls that may be available to you;
• To personalize content and experiences;
• To detect, investigate and prevent activities that may violate our policies or be illegal;
• To optimize or improve the content, products, services, and features of the Services;
• To personalize and improve the Services and user experiences, to increase the functionality and user friendliness of the Services, to deliver content or features that match user profiles or interests; and
• To monitor and analyze the Services usage and trends and otherwise measure the effectiveness of the Services.
• To comply with applicable state and federal laws, including cooperating with judicial proceedings or court orders, and responding to lawful requests from public and government authorities;
• To respond to lawsuits and legal actions;
• Any other purpose with your consent.

We may also send you newsletters about the Services, provided you have consented to receive these.

1. HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal data to third parties only in certain circumstances or for certain purposes:

At Your Request:

• In the event that you instruct or request us to do so, we may share your Personal Information to third parties with your consent.

Legal Obligations:

• To comply with applicable state and federal laws, we may share your Personal Information to public and government authorities if reasonable and necessary.

Business Purposes:

• We may share your personal data with our service providers or affiliates who assist us in delivering our Services. These may include but are not limited to data storage, analytics and advertising, technology services and support, performance measurement services, data optimization and marketing services, data security, law firms, and accounting firms. Such service providers may have access to sensitive personal data, according to their roles and purposes and may only use the information for such purposes.

Business Transfer:

• In the case of any reorganization, merger, sale, joint venture, assignment, transfer, or disposition of all or part of our corporate entity, assets, or stock (including as part of any bankruptcy or comparable proceedings), we may share your personal information.

1. PUBLIC VENUES AND SEMI-PUBLIC VENUES OF THE SERVICES.

If you use a message board, comment function, conversation pages, blogs, social community environments, profile pages, or other public or semi-public venues or forums of the Services, you will be identified on those venues by the username you submit.

1. YOUR CONTROLS AND CHOICES

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your Information. Your controls and choices may include:

• You may change your choices for newsletters and alerts; and
• You may request access to the Personal Information we hold about you and that we amend or delete it.

You may exercise your controls and choices, or request access to your Personal Information, by contacting us at Operations@opennetworks.org or following instructions provided in communications sent to you. Please be aware that, if you do not allow us to collect Personal Information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. If you have questions regarding the specific Personal Information about you that we process or retain, please contact us at Operations@opennetworks.org.

1. THIRD PARTY WEBSITES AND LINKS

Our Services may contain links to other sites operated by third parties. We do not control such other sites and are not responsible for their content, their privacy policies, or their use of Personal Information. Information you provide on public or semi-public venues, including Information you share on third party social networking platforms may also be viewable by other users of the Services and users of those third-party platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such sites or of their owners or operators except as disclosed on the Services. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of Personal Information by third parties. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.

1. CHILDREN’S PRIVACY

We do not seek or knowingly collect any Personal Information about children under 18 years of age. If we become aware that we have unknowingly collected Personal Information from a child under the age of 18, we will make commercially reasonable efforts to delete such information from our database.

If you are the parent or guardian of a minor child who has provided us with Personal Information, you may contact us to request it be deleted.

1. DATA SECURITY, INTEGRITY AND RETENTION

We use reasonable security measures, including computer safeguards and secured files and facilities that comply with federal law to protect and limit access to Personal Information. Please note that Information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your Personal Information for the length of time needed to fulfill the purposes outlined in this privacy policy unless a longer retention period is required, or for the establishment, exercise or defense of legal claims, or for legitimate business purposes, or as provided by law.

1. UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make changes that are material, we will use reasonable efforts to attempt to provide notice to you and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on the Services, or by other means, consistent with applicable law. However, it is your sole responsibility to review the Privacy Policy from time to time to view any such changes. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy. IF YOU DO NOT ACCEPT AND AGREE TO THIS PRIVACY POLICY, INCLUDING ANY CHANGES THERETO, THEN YOU MUST NOT ACCESS OR USE THE SERVICES.

1. CALIFORNIA PRIVACY RIGHTS

This Section describes how we may share Information for marketing purposes. It applies to California residents.

The Company does not sell (as such term is defined in the California Consumer Privacy Act (“CCPA”)) the personal information we collect (and will not sell it without providing a right to opt out). Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification.

As a California resident, you may contact us with any questions or to request a list of third parties to whom we may disclose information for such third parties’ marketing purposes and categories of information we may disclose. See “How to contact us” below.

Right to Know

California residents have the right to request that we disclose the categories and specific pieces of personal information we collected, used, and disclosed during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purposes for collecting their personal information, and the categories of third parties with whom we shared their Personal Information.

Right to Delete

California residents have the right to request deletion of the Personal Information we have collected from them.

Request Submission

You or your authorized agent can submit a request by emailing Operations@opennetworks.org. You will need to provide us with Personal Information for us to match with information we have on file in order to verify your identity and residency. The Personal Information that we use to verify your identity and residency will not be used for any other purpose.

Right Against Discrimination

California residents have the right to not be discriminated against for exercising their rights under the CCPA. We do not discriminate against California residents who exercise their CCPA privacy rights.

13. COOKIESWhat are cookies?

Cookies are small, often encrypted text files, located in browser directories (also known as browser cookies or tracking cookies). Cookies are used to collect information about you and your use of the websites and/or mobile apps. They are downloaded to your computer or smart device when you visit the Website. Cookies allow us to recognize your device and preferences and provide us information which can be used to improve your experience with us.

How we use cookies.

This section sets out information about our use of cookies. We use cookies or other tracking technologies to help us enhance and understand your user experience on the Website. We also use cookies for honoring your preferences and settings, enabling you to sign in, providing you with personalized advertising, and fulfilling other legitimate purposes.

Types of Cookies we use.

A cookie can be classified by its lifespan, purpose and the domain to which it belongs. Our Website uses the following types of cookies:

Strictly Necessary Cookies: These cookies are essential in order to enable you to move around the Website and use its features, such as accessing secure areas of the Website. Without these cookies, services like enabling appropriate content based on your type of device cannot be provided.

Analytics Cookies: These cookies collect information about how you use the Website, for instance, which pages you visit most often. This information is used to improve how the Site works and improve the user experience.

Tracking Cookies: These cookies collect information on a user’s tendencies and preferences on the Website including clicks, device specifications, locations and search history.

Manage the use of cookies.You have the right to manage the use of cookies. You can adjust your cookies settings through our Website. Below you can determine if you want to remove, manage, or block cookies. Please keep in mind that deleting and blocking cookies may have an impact on your user experience.

Removing cookies from your device.

You can delete all cookies that are already on your device by clearing the browsing history of your browser. This will remove all cookies from all websites you have visited. Be aware though that you may also lose some saved information (site preferences, etc).

Managing Website-specific cookies.

For more detailed control over site-specific cookies, check the privacy and cookie settings in your preferred browser.

Blocking cookies.

You can set most modern browsers to prevent any cookies being placed on your device, but you may then have to manually adjust some preferences every time you visit the Website, and some services and functionalities may not work properly at all. If you are in the EU and would like to opt out of third-party cookies relating to behavioral advertising, please go to www.youronlinechoices.eu. Opting out does not mean you will no longer receive online advertising. It does mean that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.

Cookie Retention.

We retain cookies as long as we receive consent from you and as long as we have a legitimate basis to do so. This legitimate basis is based on our use of strictly necessary cookies which in any case, the retention period shall not exceed a period of thirteen (13) months. Once this period has expired, we will be required to renew your consent for the use of cookies.

Third Party Cookies.

Some of our pages display content from external providers. To view this third-party content, you first must accept their specific terms and conditions. This includes their cookie policies, which we have no control over. However, if you do not view this content, no third-party cookies are installed on your device.

14. HOW TO CONTACT US

You may contact us regarding the Services or this Privacy Policy at: 4023 Kennett Pike #50633, Wilmington, DE 19807, or by e-mail at Operations@opennetworks.org. We will not retaliate against you for filing a complaint.