Private Health Services Plan, PHSP


Privacy Statement

Neo Plan is committed to protecting the privacy of our customers' personal data and we encourage you to read this privacy statement.

Statement.

This statement describes the personal data that Neo Plan Plus Company (Neo Plan hereafter) collects from the members. It is also describes the methods we collect data and why, how collected data will be used, who we can disclose collected data to and why, how data can be corrected or deleted, the procedures around protect of collected data, and the process and contact information that customers can use to raise enquiries, concerns and complaints.

1. Our Commitment to Personal Data Protection.

Neo Plan is committed to safeguarding our members' personal data by adherence to the following obligations:

i.            Information Security Policy and the related policies;

ii.            The Canadian Government's Privacy Framework;

iii.            Personal Information Protection and Electronic Documents Act (PIPEDA);

iv.            The relevant local data protection laws and regulations; and

v.            The contractual commitment to our members.

 

2. Statement Application.

This statement applies to the services and products offered by the Neo Plan and bind all our employees. Neo Plan expects that all our service providers have introduced data protection principals and technical measures that are similar to the ones Neo Plan has adopted. This statement refers to personal data from our Business members or the employees of our Business members and their families such as a beneficiary under the Plan and in this statement, we refer to this group of individuals or businesses as: "you".

3. What Information is collected and how is it done?

Neo Plan collects personal data about you when you enroll, use or benefit from Neo Plan 's services or products or when this data is given to Neo Plan by third parties, such as companies employing you or your relatives, insurance companies, private medical insurers, assistance companies, financial institutions, medical service providers, travel agencies and similar companies, that are permitted to share this personal data.

"Personal data" constitutes information that will help someone to identify or contact you, including, for example, your full name, address, telephone number or email address, date of birth, gender, nationality, family status, information related to your professional activity, status of your health and health of you family.

If collected data does not permit the identification of individual persons, such as statistics on the number of expatriates and travellers that are eligible in a member company to receive assistance services or the number of people visiting the Neo Plan website each month, this data is not considered to be a “Personal data”.

You provide certain personal data to Neo Plan when, you, for example:

       i.               Call for assistance providing services under a medical services contract; seek a consultation with our consultants;

     ii.               Contact us to receive Plan related consultations;

    iii.               Contact us to receive Plan member support services;

    iv.               Contact us to receive security consultations and security services;

      v.               Order services from Neo Plan websites;

    vi.               Submit forms and questionnaires through our web sites;

   vii.               Make enquiries, requests or complaints.

Subject to your agreement to the applicable terms and conditions, you may access services through the Web, including but not limited to medical, health and security information and other services which may be added by Neo Plan from time to time.

When you choose to pay for Neo Plan services or products by credit card directly from the Neo Plan website, you will be required to provide Neo Plan with the name of your credit card issuer, credit card number, expiration date and other security information. When you choose to pay for Neo Plan services or products by other means, we may ask you for your credit card details, contact details and bank account details.

You also provide information to us when you choose to email data to us, or you participate in marketing and sales initiatives.

Neo Plan will only gather data that is relevant for the purposes for which it will be used and will not gather excessive or unnecessary data.

Neo Plan shall take reasonable steps to ensure that data is reliable, accurate, complete, and current, bearing in mind its intended use. You have a responsibility to keep the data you provide to us updated and we will take reasonable steps to facilitate this.

4. Acceptance and Links to other Websites

This Neo Plan website may contain links to other websites, which are provided solely as a convenience to you and not as an endorsement by Neo Plan of the contents of other web sites. The other web sites may have their own policies, which Neo Plan does not control, and thus are not addressed or controlled by this statement or the Neo Plan Data Protection Policy.

5. Cookies

A cookie is a piece of data stored on your hard drive containing information about you. Neo Plan uses cookies in order to identify a user session, but usage of a cookie is in no way linked to any personally identifiable information while on the Neo Plan website. Neo Plan also uses ‘analytical cookies’. These allow us to recognize and count the number of visitors logging into our web site and to see how visitors move around the site when they are using it. This helps us make sure sites are meeting users’ needs and to find out how we could improve. The analytical cookies do not capture any personally identifiable information.  Most browsers are initially set up to accept cookies. Though most cookies expire after a certain period of time, you can choose to delete a cookie file at any time. You can do so by resetting your browser to refuse all cookies or to indicate when a cookie is sent.  However, some Neo Plan features or services may not function properly without cookies. Some of our service providers (e.g. International SOS's service providers monitoring our satisfaction survey) use cookies on the Neo Plan site. Neo Plan has no access to or control over these cookies. This privacy statement covers the use of cookies by the Neo Plan site only and does not cover the use of cookies by anyone else.

6. How the Personal Data will be used

Neo Plan will use your personal data to provide you with services and products that:

       i.               you paid for;

     ii.               paid for by your employer or your relative's employer;

    iii.               paid for by an association or institution (including an educational establishment) of which you are a member;

    iv.               part of services provided through the Plan or as part of services that are provided to you.

Neo Plan may also gather your personal data to assist us in managing services or products provided to you or your employer. The personal information collected from the App enables Neo Plan to provide better and more relevant services.

Your personal data may be transferred to companies within the Neo Plan group or to service providers that are performing services for Neo Plan or acting as Neo Plan’s agents. Neo Plan will require that any such service providers agree to keep your personal data secure and confidential, use it only for the purposes for which the personal data is transferred and use it only in accordance with Neo Plan's directions.

Your personal data may be transferred to Government authorities, agencies and institutions as required or permitted by applicable laws and regulations.

Neo Plan shall not collect, use, disclose or transfer your personal data except as described in this Statement unless you give us your permission to collect, use, disclose or transfer it for other purposes.

 

8. What Choices are Available to Users Regarding Collection, Use, Storage, Disclosure or Transfer of the Personal Data?

You are given the opportunity to 'opt-out' of receiving our services and products. You may ‘opt-out‘ of email alerts for instance by replying to the email or clicking the "unsubscribe" link.

You will also be given the choice to prohibit Neo Plan from disclosing your personal data to a third party or for purposes other than to provide services and products.

If you are receiving services as an employee or as a member of an employee's family, or as a member of an association or institution, as a credit card holder or the recipient of other financial services, the company, association or institution that has contracted for our services and products on your behalf will determine the method and means by which you can opt-out and opt-in. Note that if you choose to 'opt-out', withhold, block or request that we delete your personal data, you may not be able to receive the benefit of Neo Plan's services and products. 

9. How Can Users Correct Inaccuracies in their Personal Data?

You can review the personal data that Neo Plan has collected from you by contacting our: assistance center; customer service personnel; or by using your password to access your records through our website. In order to update, delete, amend or block any personal information that we create and that we are able to change, contact us using the following e-mail address: [privacy@NeoPlanPlus.com] or through the contact link on our website. Should you need our assistance to access or make changes to your personal information, please submit your request to us. Corrections or deletions of data resulting solely from errors by Neo Plan or our service providers shall be paid for by Neo Plan. In making your request to review, update, amend or block data, you will be required to provide Neo Plan with details of the data requested and the reasons why the data needs correction. Neo Plan will ask for proof of your identity. Neo Plan may ask you to assist in verifying the accuracy of the updates and the amendments to the personal data. Neo Plan may ask you to cover the reasonable cost of accessing and providing copies of your personal data if this is not provided through the Neo Plan website. Neo Plan will strive to address your request as soon as practicable as and no later than thirty (30) calendar days from the date your request is received and understood. If Neo Plan is asked to destroy the personal data, Neo Plan shall use means that prevents its recreation and Neo Plan shall take reasonable care to ensure that there is no unauthorised disclosure during the destruction of the data.

 

10. What Kind of Security Procedures are Used to Protect the Loss, Misuse, or Alteration of Your Personal Data under International SOS's Control?

 

Neo Plan takes precautions to protect its users' information.   Neo Plan has implemented policies that forbid its employees from using or disclosing personal data in an inappropriate or unlawful manner and maintains security measures to safeguard the personal data that it maintains from unauthorized access, misuse, alteration, loss or destruction.

Information Collected by Electronic Means

When you provide Neo Plan with personal data through online forms and other electronic methods, the data is protected using industry-standard encryption.

The Information Security Policy and the Information Security Procedures and Processes

All Neo Plan employees are required to follow the Information Security Policy. The policy is implemented through the Information Security procedures and processes. These are periodically reviewed and updated, as the information security landscape is in a constant state of flux.  All new employees are required to sign a written confirmation that they have read and understood the Information Security Policy and a confidentiality agreement. Employees also have confidentiality obligations in their contracts of employment with Neo Plan.

11. How do I resolve disputes with Neo Plan relating to Personal Data?

If you are unsatisfied with the manner in which your question or concern was addressed, in respect of our online services, you may contact Neo Plan at privacy@NeoPlanPlus.com.

If you do not wish to make a complaint through our online services, you may direct all enquiries, concerns or complaints regarding the collection, use, storage, correction, deletion, blocking, disclosure or transfer of personal data to the Data Protection Administrator using the contact details attached to this statement. 

Neo Plan will investigate all concerns and complaints and will address them expeditiously. An acknowledgement of the identity of the employee addressing the complaint and the approximate length of time that will be taken to review the complaint will be provided no later than five (5) business days from the date the complaint is received and understood. Regular updates shall be given to you on the progress of the review if the review is likely to take longer than seven (7) business days.

You have the right at any time, to raise your issues with a data protection authority or to take your case to a court.

If you receive services from Neo Plan through an employer or through a relative's employer or through an association or institution, or an insurance or financial services program and your personal information has been improperly collected, used, stored, disclosed, amended, destroyed, blocked or transferred as a result of the actions or inactions of the employer, association or institution, insurance company or financial services company, then you will be directed by Neo Plan to such employer, association or institution, insurance company or financial services company. Neo Plan will not be liable for resolving disputes between you and such companies, associations or institutions.

13.  Changes to this Statement

Neo Plan reserves the right to change this policy at any time by notifying users through its website of the existence of a new privacy statement. This statement and the policies outlined herein are not intended to and do not create any contractual or other legal rights.

 

 

 Updated: June 2012