Attain App for Android and iOS

This Privacy Statement describes Aetna’s practices in connection with information we collect, use, and disclose through "Attain By Aetna,” a healthcare program featuring a mobile application (App) for Android™ or iOS, used with your phone and wearable device to combine sensor and clinical health data to allow participants to complete certain healthy living activities, to receive smart message notifications about healthy living engagement activities, and to facilitate a repository of health data to conduct future research.

This Privacy Statement encompasses information collected from those eligible Aetna members who agree to the “Attain Program Agreement and Terms of Use” (“the Agreement”) for the Attain By Aetna program, and from those who have consented to contribute data to Attain research projects. Some of the information collected for the program will come through your use of the App, while other information used in the program, such as your health plan coverage and claim activity, will come from your Aetna account. By participating in Attain By Aetna, you agree to the terms of this Privacy Statement.

We are committed to treating your information with care and respect and managing Attain By Aetna in a manner which is compliant with applicable law. If you have any questions or concerns about this Privacy Statement, or about the way your information is collected and used, and you are an Aetna member, please contact us at 1-833-288-2461.

Limitations on who may use the Services?

Attain By Aetna does not knowingly collect personal information online or via our App from any person we know to be under the age of 18, and we instruct individuals under 18 not to send us any information to or through the Attain By Aetna App or any related online services.

The Attain By Aetna App is designed for users from, and are controlled and operated by us from, the United States. By using the Services, you consent to the transfer of your information to the United States or storage of your information in the United States, which may have different data protection rules than those of your country.

What types of information do we collect?

We may collect two basic types of information: Personal Information and Non-Personally Identifiable Information.

By “Personal Information,” we mean data that is associated with an identifiable individual, such as a name, address or e-mail address. In connection with health insurance, personal information includes, for example, personally identifiable coverage and claim information. And in connection with participation in Attain By Aetna, it also includes personally identifiable wellness or fitness information, including various activities identified through the App on your phone or wearable device.

By “Non-Personally-Identifiable Information,” we mean information that is not associated with an identifiable individual. Non-Personally-Identifiable information may include information which would otherwise be personal information, but which has been de-identified or aggregated.

The full listing of information that may be collected, used or disclosed as part of your use of Attain, including information collected through the App and other information from Aetna, is described in The Agreement for the Attain By Aetna program and in the “Consent to Participate” for any applicable research study.

How do we acquire and use Personal Information?

We may collect and store the Personal Information you provide to your Health Plan or to your Health Plan’s service providers. We may also collect and store certain device information from your phone or wearable device. Some examples of the Personal Information we collect and when we collect it include:

• Registration: We collect your Personal Information when you register for the Attain By Aetna App.
• Contact Information: We collect Personal Information from users such as your contact and demographic information.
• Information from your health plan or employer: We receive certain Personal Information about you from your health plan or employer such as your medical conditions, medications, and health care services you use. If you have questions about the information your health plan or employer may have shared with us, please contact your health plan or your employer’s human resources department.
• Device information: We may automatically collect certain Personal device information such as device locale, cellular carrier, device manufacturer and device model for purposes of diagnosing problems and to ensure services function properly. We also collect your Personal Information concerning program activities, such as sleep related information and workout related information such as duration, location, and intensity coming from your phone or wearable device.

If you choose not to provide your Personal Information to us, you may not be able to participate in Attain By Aetna.

If you submit any Personal Information to us, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Statement.

We may combine the information collected from you through the Attain By Aetna App with information we receive from and about you from other sources and use the combined information in accordance with this Privacy Statement. Our goal is to offer you content, recommendations, and services that are most likely relevant to your particular situation.

If you agree to participate in Attain By Aetna or in any research study, the information you share will never be sold or used for any underwriting, eligibility, premium or coverage decisions. It may be used, for example, in support of the program to adjudicate rewards or to identify and deliver messages that may be helpful to your health or otherwise of interest to you. If you consent to participate in any research study, the information you share will contribute to research as explained in the applicable “Consent to Participate,” including, potentially, research on links between your activity as measured by your phone or wearable device and health outcomes as recorded in your claims data.

Except in connection with the sale, transfer, merger, consolidation or other transaction involving all or part of our company, we will not sell, license or otherwise transfer any rights to your Personal Information to any third party.

For what and to whom may we disclose your personal information?

We may disclose your Personal Information to CVS Health affiliates or to third parties for the following purposes. In all cases we will require the recipient to protect the information and use it only for the purpose it was provided.

• To enable affiliates and third parties to perform certain services for us in connection with the Attain By Aetna program, including, but not limited to, Program and incentive administration, application maintenance, and performance improvement tasks through the Program.
• To personalize your experience within the Attain By Aetna App and when otherwise interacting with us, including by presenting products and offers tailored to you, and for our business purposes, such as data analysis, audits, fraud monitoring and prevention, improving our services, developing new products and services, determining the effectiveness of our educational, awareness, or promotional campaigns, and operating and expanding our business activities.
• To enable research partners’ work in collaboration with an applicable research study.
• If required by law, such as pursuant to a subpoena, regulatory oversight, or other legal process.
• If we believe in good faith that disclosure is necessary (a) to protect our rights, the integrity of the application, or your safety or the safety of others, or (b) to detect, prevent, or respond to fraud, intellectual property infringement, violations of our Terms of Use, violations of law, or other misuse of the application.

How do we acquire and use Non-Personally Identifiable Information?

When you use Attain By Aetna, we collect certain Non-Personally-Identifiable Information about you. This data helps us to analyze and improve the usefulness of the information and services we provide through the Program. Because Non-Personally Identifiable Information does not personally identify you, we may use such information for any purpose permitted by law and in support of the Program or as otherwise described in the Agreement.

How do we protect your information?

The security, integrity, and confidentiality of your information are extremely important to us. We have implemented technical, administrative, and physical security measures that are designed to protect your information from unauthorized access, disclosure, use, and modification. We regularly review our security practices to consider appropriate new technology and methods. We also periodically subject Attain By Aetna to simulated intrusion tests and have developed comprehensive disaster recovery plans. However, please be aware that despite our best efforts, no security measures are perfect or impenetrable.

What happens if I no longer want to participate?

As stated in the Agreement, you are free to change your mind and stop participating in the Program at any time. You can withdraw from the Program through the Attain App by going to the Settings tab or contacting Aetna support at the number listed below.

You may also be withdrawn from the Program if you no longer are an eligible Aetna member, or if you engage in any practices that are found to violate any participation terms.

If you withdraw or are withdrawn from the Program, no additional data will be collected about you, however, information that was previously collected about you may continue to be used as described in the Agreement and this Privacy Statement. It may take up to two business days from when received to process any withdrawals.

After termination of the Program or user withdrawal, Aetna will keep data in accordance with Aetna’s Record Retention and Management Policy, and in compliance with legal guidelines.

Linking to other websites and applications

The Services may contain links to, or otherwise make available, third-party websites, services, or other resources not operated by us or on our behalf ("Third Party Services"). These links are provided as a convenience only and do not constitute an affiliation with, endorsement or sponsorship of the Third-Party Services. Specifically, the tools and resources section available on the site in connection with the Services are links to Third Party Services.

Any information you provide to such third parties is not subject to the terms of this Privacy Statement, and we are not responsible for the privacy or security of the information you provide to them or their handling of your information. We recommend that you review the privacy statement of any third party to whom you provide personal information online.

In addition, we are not responsible for the information collection, use, disclosure, or security policies and practices of other organizations, such as Apple, Google, Microsoft, RIM, or any other app developer, app provider, operating system provider, wireless service provider, or device manufacturer.

Do Not Track

Currently, we do not respond to “Do Not Track” signals from browsers.

Personal Financial Information Obtained through the Apple Watch Retail Installment Agreement

This section of the Privacy Statement only applies:

• to participants in the Attain By Aetna Program who purchase their Apple Watch through a retail installment agreement with Aetna Life Insurance Company.
• to personal financial information collected through the retail installment agreement. Other personal information, including personal health information, is addressed throughout the rest of the Privacy Statement.

When you purchased your Apple Watch, you entered into a sale agreement called a retail installment agreement with Aetna Life Insurance Company. As such we want to provide you with information as to what we do with personal financial information we collect through that agreement.

Why are we providing this notice?

Companies that offer financial products or services, including retail installment agreements, choose how they share your personal financial information. Aetna Life Insurance Company is considered a financial company for this purpose. Federal law gives consumers the right to limit some but not all sharing of their information. Federal law also requires us to tell you how we collect, share, and protect your personal financial information. Please read the following notice carefully to understand what we do.

What sort of information do we collect?

The types of personal financial information that we collect through the retail installment agreement may include, for example, your address, phone number, email address, and payment and transaction history, among other items of information. When you are no longer our customer, we may continue to use your personal financial information in connection with any outstanding payments you owe.

How do we share your personal financial information?

All companies that offer financial products or services, such as retail installment agreements, need to share their customers’ personal financial information to run their everyday business and meet customers’ needs. In the section below, we list the reasons why financial companies may share their customers’ personal information, the reasons why Aetna chooses to share, and whether you may limit this sharing.

Reasons we can share your personal financial information

• Financial companies may share your personal financial information for their everyday purposes, such as to process your transactions, maintain your account, respond to court orders and legal investigations, or report to credit bureaus. We do share your personal information for this reason, and you cannot limit this type of sharing.
• Financial companies may share your personal financial information for their marketing purposes in order to offer their products or services to you. However, we will not share your information for this purpose.
• Financial companies may share your personal financial information for their joint marketing with other financial companies. However, we will not share your information for this purpose.
• Financial companies may share your personal financial information with their affiliates for their affiliates’ everyday business purposes, specifically information about your transactions and experiences or your creditworthiness. However, we will not share your information for this purpose.
• Financial companies may share your personal financial information with nonaffiliates to market to you. However, we will not share your information for this purpose.

Who is providing this notice?

Aetna Life Insurance Company is offering retail installment agreements for the sale of Apple Watches. This notice only applies to personal financial information we collect in connection with these agreements.

How does Aetna protect your personal financial information?

The security, integrity, and confidentiality of your personal financial information are extremely important to us. We have implemented technical, administrative and physical security measures that are designed to protect your information from unauthorized access, disclosure, use and modification.

How does Aetna collect your personal financial information?

We collect your personal financial information, for example, when you complete a retail installment agreement and pay any amounts owed under the terms of that agreement.

Why can’t you limit all information sharing?

Federal law only gives you the right to limit: (1) the sharing of personal financial information about your creditworthiness with affiliates for their everyday business purposes; (2) affiliates from using your personal financial information to market to you; and (3) the sharing of your personal financial information with nonaffiliates to market to you. We will not share your personal financial information with affiliates or nonaffiliates for marketing purposes. State laws and individual companies may give you additional rights to limit sharing. For example, under California and Vermont law, we will not share information we collect about residents of California or Vermont with companies outside of our corporate family other than as permitted by law.

Key Definitions for this section of the privacy statement

“Affiliates” are companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include, for example, Aetna Life Insurance Company and Aetna Health Management, LLC.

“Nonaffiliates” are companies not related by common ownership or control. They can be financial and nonfinancial companies.

“Joint marketing” means a formal agreement between nonaffiliated financial companies that together market financial products or services to you.

Aetna contact information

If you wish to contact us, email or call 1-833-288-2461 (TTY: 771).

Changes to Aetna’s Privacy Statement

Aetna may change this Privacy Statement from time to time; when updates are made, the version date (located at the bottom of this Privacy Statement) will also be updated to reflect that a revision occurred. We encourage you to periodically reread this Privacy Statement to see if there have been any changes that may affect you. To be sure you are aware of any material change, we will message you through Attain By Aetna. This Privacy Statement is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

Effective Date: July 12, 2022