Privacy Policy
Last Updated: December, 2025
Effective: December 15, 2025
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Transcarent is the One Place for HealthTM and Care, bringing medical, pharmacy, and point solutions together in the leading personalized health and care experience that people love to use. AI-powered WayFindingTM, pharmacy benefits, 2nd.MD, and virtual primary care combined with comprehensive Care Experiences – Cancer Care, Surgery Care, and Weight Health – support people with all their health needs, simple or serious. More than 1,700 employers and health plans rely on us to provide accurate information, guidance, and trusted care, delivering unmatched choice, quality, and outcomes.
This Privacy Policy (this “Policy”) explains how we collect, use, and share information from users of our mobile applications, digital tools, other platform services, and websites operated by Transcarent and its affiliated companies, Accolade®, Accolade Care, PlushCare®, and 2nd.MD® (the “Sites”) (collectively, the “Services”). This Policy does not apply to our collection, use or disclosure of Protected Health Information, which includes any information that we collect from or about you after you’ve logged in to use one of our services.
TABLE OF CONTENTS
- HIPAA and your Protected Health Information
- Categories of Personal Information We Collect
- How We Use the Personal Information We Collect
- When We Disclose the Personal Information We Collect
- Cookie and Pixels
- Security
- Retention of Personal Information
- Children’s Privacy
- Your Privacy Rights
- Additional Notice for Washington and Nevada Residents
- Other Important Information
- Changes to Our Privacy Policy
- Contact Information
HIPAA AND YOUR PROTECTED HEALTH INFORMATION
Neither this Policy, nor our Consumer Health Data Privacy Notice, covers how we handle any “Protected Health Information” or “PHI” we process about you that is subject to the Health Insurance Portability and Accountability Act, which you may know as “HIPAA.” We treat all information you provide as a Member of Transcarent or a patient of our affiliated medical group as PHI governed by HIPAA. We get this information directly from your health plan, from you on behalf of your health plan, when you share information about yourself with our telehealth clinics, or from the health care providers that treat you.
When you use our Services as a Transcarent Member, your health plan’s HIPAA Notice of Privacy Practices, our agreement with your health plan (called a business associate agreement), and laws and regulations control how we collect and use your information. If you use our AI Care Assistant for benefits in our app, we may disclose your PHI to companies that support our technology; any such disclosure will comply with HIPAA. Please read your health plan’s Notice of Privacy Practices to understand how your PHI can be used and disclosed.
If you are a patient of one of our telehealth clinics, their Notice of Privacy Practices describes how we collect, use, maintain and share PHI, as well as your related rights. To review those policies, click here for The Transcarent Clinic and here for Plushcare or Accolade Care. We may deploy our AI Care Assistant to support your clinician in starting your visit and it may also explain your care plan to you. When this happens, we may disclose your PHI to companies that support our technology; any such disclosure will comply with HIPAA.
CATEGORIES OF PERSONAL INFORMATION WE COLLECT
We may collect, use, or share information that you give us, that we automatically collect when you visit our Sites, and that we get from other sources. In the past twelve (12) months, we may have collected the following types of personal information about you.
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Information Category |
Examples |
Sources and Context |
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Identifiers |
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You, such as when you:
From third party data aggregators that provide us with your contact information. |
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Internet or Other Electronic Network Activity |
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Our service providers and third parties that deploy cookies and similar tracking technologies on our Sites. |
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Non-Precise Geolocation Data |
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Our service providers and third parties that deploy cookies and similar tracking technologies on our Sites. |
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Professional or Employment-related Information |
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You, such as when you:
|
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Sensitive Information |
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You, such as when you do the following but are not logged into an account:
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HOW WE USE THE PERSONAL INFORMATION WE COLLECT
We will use your personal information to respond to your questions, to fulfill your request to sign you up to our newsletter, and for other reasons such as:
- To understand how you use or navigate around our Sites, monitor and improve our Sites, improve your experiences interacting with us, tailor our content to you, and create new products, services, features, and functions.
- When we send you emails, we may track whether you open them to learn how to improve our communications
- To communicate with you, give you information you ask for, respond to your comments and questions, and provide support.
- To follow the law, enforce our Terms of Service or other legal rights, or as required by laws, regulations, or government requests.
- To contact prospective clients with general or personalized messages that may be of specific interest to them. We may also use AI tools to analyze and improve our communications with prospective clients.
- To create deidentified and anonymized datasets for internal and external uses.
- For other reasons we tell you about when we collect the information.
We limit the ways that we use sensitive personal information to legitimate internal business purposes, such as: (i) to perform services or providing goods reasonably expected by an average consumer; (ii) to detect and respond to security incidents and malicious, deceptive, or illegal actions; (iii) to ensure the physical safety of individuals; (iv) for short-term, transient use, including non-personalized advertising; (v) to perform or provide internal business services; and (vi) verify or maintain the quality or safety of a service or device. We do not use sensitive personal information to profile you.
Note about Voice/Text Messaging: We may use an affiliated third-party vendor to help us manage some of our voice/text messaging communications with you. While we do supply this vendor with mobile telephone numbers of those we wish for them to contact, your mobile telephone number is only to be used to communicate with you on our behalf for marketing or transactional messaging. Originator opt in data will not be shared with any non-affiliated third parties.
Note about Use of AI: When talking to potential or current clients, our sales and client success teams might use service providers that leverage AI technology to improve the quality of how we communicate. We may use these tools for emails, calendar invitations, and meetings.
WHEN WE DISCLOSE THE PERSONAL INFORMATION WE COLLECT
In the past twelve months, we may have shared each category of personal information described above with the following categories of recipients:
- Vendors and Service Providers, including analytics companies: We may share any information we get with vendors and service providers, including analytics partners, AI vendors, and providers of marketing, technology, and hosting services. We share this information only as needed for them to do their jobs.
- Corporate Affiliates: To support us in providing, integrating, promoting, and improving the Services, we may share personal information within our corporate family of companies that are related by common ownership or control.
- As required by law and similar disclosures: We may access, keep, and share your information if we believe it is necessary to: (a) follow the law or respond to law enforcement requests and legal processes, like a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.
- Merger, sale, or other asset transfers: We may share your information with service providers, advisors, potential business partners, or other third parties if we are considering, negotiating, or completing a business deal where we are bought or merged with another company, or if we sell, liquidate, or transfer part or all of our assets.
- With your consent: We may disclose your information with your permission.
We do not “sell” your personal information for monetary value. But we do use analytics cookies that some may consider to be a “sale” or “sharing” under certain state consumer privacy laws. In the context of these relationships, we may “sell” or “share” the following information categories to our analytics partners: Identifiers, Internet and Other Electronic Activity Information, and Non-Precise Geolocation Information.
COOKIES AND PIXELS
We and our partners collect personal information using cookies, pixel tags, or similar technologies when you use our Services or visit our Sites. Our partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Some of our advertising may be targeted to topics that we’ve inferred that you may be interested in.
- Cookies: Cookies are small text files containing a string of letters and numbers. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie stays after you close your browser and may be used on future visits to our Services.
- Pixel tags: Also known as “clear GIFs”, “tracer tags”, or “web beacons”, these technologies help us and our partners understand which pages or content you view. Pixel tags help us improve and customize our Site for you and other visitors.
- Browser settings: Your web browser’s “Help” file has information on how to change your cookie settings. Note that deleting or not accepting cookies may affect your experience with Services that do not require logging in.
Analytics Information: We may use analytics services, such as Google Analytics and similar tools, to collect and analyze data. These services may also collect personal information about how you use other websites, apps, and online resources. To understand how you use or navigate our Services and to improve them, we automatically get information about your interactions with our Services, such as the content you view, and the dates and times of your visits. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners, and opt out of Google Analytics’ collection and processing of data by following the instructions at https://tools.google.com/dlpage/gaoptout.
Behavioral and Targeted Advertising Information: We conduct advertising and content personalization on certain of our Sites and on third-party websites. We may track your activity over time and across properties to develop a profile of your interests and advertise to you based on our interests (which is commonly referred to as “behavioral advertising”). We may also measure the effectiveness of advertising campaigns and our communications with you, including identifying how and when you engage with our emails (such as whether you open an email or click on its content).
Setting your Preferences: We use OneTrust for cookie consent management. When you visit our Services, including our Sites, you can set your cookie preferences using a consent banner. You can change your choices later by clearing your cookies in your browser settings and updating your choice in the consent banner, or by using “Manage Cookie Preferences” to choose certain types of cookies. Note that Required Cookies cannot be turned off, and if you decide to opt-out of Functional Cookies, some features of our Sites may not work properly.
SECURITY
We take steps to protect your personal information using physical and electronic safeguards. However, no electronic transmission or storage is completely secure, and we cannot guarantee the absolute security or privacy of your information.
RETENTION OF PERSONAL INFORMATION
We will keep your information for as long as needed to fulfill the purposes in this Policy, to provide our Services to you, or as you instruct, unless a longer period is required or allowed by law.
CHILDREN’S PRIVACY
We do not knowingly collect, maintain, use, sell, or share personal information (including sensitive personal information) from children under 16 years of age. If you learn that a child has given us personal information in violation of our policy, then please let us know at privacy@transcarent.com.
YOUR PRIVACY RIGHTS
This section does not apply to your Protected Health Information. Most of the information we have is PHI regulated by HIPAA. Depending on your relationship with us, you may need to make privacy requests through your health plan or as a medical records request through our telehealth clinics. Because we collect both personal information and PHI, it can be confusing to know which rights apply to your data. If you have any questions about how the rights described in this section apply to you and your data, please contact us at privacy@Transcarent.com.
Depending on where you live, you may have the following rights with respect to your personal information:
- Right to Know and Access: You have the right to access and know what personal information we collect about you, and how we use and share such personal information. For your convenience, we include the following information in this Policy.
- The categories of information we collect or disclose about you.
- The categories of sources of such information.
- The business or commercial purpose for collecting your information.
- The categories of third parties with whom we share or disclose your information
- Right to Correct: You have the right to request that we correct inaccurate personal information we maintain about you.
- Right to Request Deletion: You have the right to ask us to delete your personal information, with some exceptions.
- Right to Opt Out of Sale or Sharing for Targeted Advertising: You have the right to opt out of “sale” of personal information and the “sharing” of personal information for targeted advertising. privacy laws. If your browser or device is configured to send a GPC signal, we will process this request automatically without requiring further action from you.
- If you are a resident of Oregon or Minnesota, you also have the right to request a list of third parties to whom we disclose personal information.
To exercise your right to Opt Out of Sale/Sharing for Targeted Advertising, please disable the use of Targeting Cookies and other non-essential tracking technologies. You can set your cookie preferences using our consent banner. You can change your choices later by clearing your cookies in your browser settings and updating your choice in the consent banner, or by using “Manage Cookie Preferences” to choose certain types of cookies. Note that Required Cookies cannot be turned off, and if you decide to opt-out of Functional Cookies, some features of our Site may not work properly. You must complete this step on each of our websites from each browser and on each device that you use. These steps are necessary so that we can place a first party cookie signaling that you have opted out. We also take steps to recognize and honor Global Privacy Control (GPC) signals as required by applicable privacy laws. If your browser or device is configured to send a GPC signal, we will process this request automatically without requiring further action from you.
To exercise your other privacy rights, please either visit the Data Subjects Rights Portal located here, or call the following toll-free number 888) 914-9661 and use PIN# 494 202 to identify that you are calling with respect to us. We will not treat you unfairly for exercising your privacy rights.
We may ask extra questions to verify that the request is from you or your authorized agent to protect your data privacy. To do that, we need you to:
- provide information that helps us verify your identity, such as your name and zip code; and
- describe your request with enough detail so we can understand, evaluate, and respond to it.
Depending on where you live, you may be able to allow an agent to make a privacy request for you. To protect your data and your privacy, the agent must have written permission from you. Your agent can follow the same instructions we provided for you above. We will need the agent to verify their identity and prove that they are authorized to represent you.
Right to Appeal Decisions Made by Us: If we deny your request to exercise your privacy rights, you can appeal our decision. To do this, submit an appeal request using the same methods described above for privacy requests. Your appeal should include any extra information that helps us to understand, evaluate, and respond to it.
ADDITIONAL NOTICE FOR WASHINGTON AND NEVADA RESIDENTS
Residents of Washington and Nevada may have additional rights related to their consumer health data. Please review our Consumer Health Data Privacy Notice.
OTHER IMPORTANT INFORMATION
Third Parties: Our Services may have links to other websites, products, or services that we do not own or operate. These links are just for your convenience and are not a referral or endorsement of the content of such third parties or the entity, item, or service. Transcarent is not responsible for the content of any linked third-party website or the privacy practices of those third party operators. Our privacy policy does not apply to third party websites. Just as you are reading our privacy policy, you should also read the privacy policies of other websites before giving them any information. Contact the site administrator, webmaster, or privacy contact person of that website if you have any concerns about their links or content.
International Visitors: Our Sites are hosted in the United States and intended for visitors in the United States. If you visit our Sites from the European Union or other regions with different data collection and use laws, note that you are transferring your personal information to the United States and other countries where our vendors may be located for storage and processing. By providing any information, including personal information, you consent to such transfer, storage, and processing.
CHANGES TO OUR PRIVACY POLICY
We will update this Policy so it accurately reflects our data collection and use practices, changes to our privacy policies, or as required by law. We will follow legal requirements to notify you of material updates by, for example, posting notice to the Services or sending you an email.
CONTACT INFORMATION
If you have any questions, comments, or concerns about our processing activities, please email us at privacy@Transcarent.com.