Privacy Policy

Effective date: 29 March 2018

For Your Protection

Further is committed to providing you with best in class products and services.  As part of obtaining our products and services, we understand that you provide Further with personal, private information and we take this responsibility seriously. This notice is provided so that you will be aware of the measures we take to protect the privacy of your nonpublic personal information.  It also describes information we collect and how we use this information to conduct our business.  You should know that we are required by law to provide you this notice about our legal duties and privacy practices. We hope that this notice will clarify our responsibilities to you and provide you with a good understanding of your rights. This notice describes how your information may be used and disclosed, and how you can get access to this information. Please review this notice carefully.

How Further Safeguards Your Protected Health Information

Further Compliance has the overall responsibility to implement and enforce privacy policies and procedures to protect your protected health information. You can be assured that every effort is taken to comply with federal and state laws — physically, electronically and procedurally — to safeguard your information. In some situations, where state laws provide greater protection for your privacy, we will follow the provisions of that state law. Further requires all of its employees, business associates, providers and vendors to adhere to federal and state privacy laws. Following are descriptions of how your protected health information is handled throughout our administration of your personal spending account.

Permitted Handling of Protected Health Information

At Further, your protected health information is handled in a number of different ways as we administer your personal spending account. The following examples show you the various uses we are permitted by law to make without your authorization:

Treatment. We can use your health information and share it with professionals who are treating you. This may include information about your visits with health care providers related to your personal spending account claims.

Payment. We can use and disclose your health information as we pay for your health services. This may include information about your financial transactions with us, such as your personal spending account information, your account balance, fees, payments, withdrawals, deposits and payment history.

Additional uses and disclosures. In certain situations, the law permits us to use or disclose your protected health information without your authorization. Learn more.

Your Rights

Further would like you to know that you have additional rights regarding your protected health information. Your additional rights are described below:

Your right to request restrictions. You have the right to request restrictions on the way we handle your protected health information for treatment, payment or health care operations as described in the “Permitted handling of protected health information” section of this notice. The law, however, does not require us to agree to these restrictions. If we do agree to a restriction, we will send you a written confirmation and will not use or disclose your protected health information in violation of that restriction. If we don’t agree, we will notify you in writing.

Your right to confidential communications. We will make every effort to accommodate reasonable requests to communicate with you about your protected health information at an alternative location. For our records, we need your request in writing. It is important that you understand that any payment or payment information may be sent to the original address in our records.

Your right to access. You have the right to receive (or request that a designated person receive), by written request, a copy of your protected health information that is contained in a “designated record set,” (click the link for definition) with some specified exceptions. For example, if your doctor determines that your records are sensitive, we may not give you access to your records. You also have the right to request an electronic copy of protected health information that is maintained electronically.

Your right to amend your protected health information. You have the right to ask us to amend any protected health information that is contained in a “designated record set.” (click the link for definition) For our records, your request for an amendment must be in writing. Further will not amend records in the following situations:

• Further does not have the records you want amended
• Further did not create the records that you want amended
• Further has determined that the records are accurate and complete
• The records have been compiled in anticipation of a civil, criminal or administrative action or proceeding

If you have requested an amendment under any of these situations, we will notify you in writing that we are denying your request. You have the right to file a written statement of disagreement with us, and we have the right to rebut that statement. Please note that changes of addresses are not required in writing.

Your right to information about certain disclosures. You have the right to request (in writing) information about any times we have disclosed your protected health information for any purpose other than the following exceptions:

• Treatment, payment, or health care operations as described in the “Permitted handling of protected health information” section of this notice
• Disclosures that you or your personal representative have authorized
• Certain other disclosures, such as disclosures for military, national security, and presidential protective services purposes.

Your right to receive notifications of breaches of protected health information. In the event of any unauthorized acquisition, use or disclosure of your unsecured protected health information (a “breach”), Further will notify you of such breach, unless there is a low probability that your protected health information has been compromised.

What Other Personal Information Does Further Gather?

Information you give us: We receive and store any information you enter on our Web site or give us in any other way (see examples of what we collect).  You can choose not to provide certain information, but then you might not be able to take advantage of many of our features. We use the information that you provide for such purposes as responding to your requests, improving our services, and communicating with you.

Automatic Information: We receive and store certain types of information whenever you interact with us.  We may also collect certain information your browser sends us, which is used to improve the content of our web services and help us understand how people are using our services. We analyze data generated by your visits to our website to continually improve the value of the materials and services available on our site. Data utilized in such analysis is not personally identifiable, and we make no attempt to link it with the individuals that browse our website. Learn more.

Mobile: When you download or use apps created by Further, we may receive information about your mobile device, including a unique identifier for your device.

E-mail Communications: We may utilize read-receipt notifications in our e-mail communications with you, as well as collect forwarding statistics from information you copy and paste from our website and send to others.

Social Media Connection: We include social media features and widgets, such as sharing posts and content on our website. Social media features and widgets are either hosted by a third party or hosted directly on our website. We may collect information such as your internet protocol address when you use these features. Your use of these features are governed by the privacy statement of the companies that provide them.

Cookies and Other Tracking Technologies

Cookies are unique data identifiers that are assigned to your browser by our web servers and are stored by your device. They enable our systems to recognize your device and to enable website features. We also use cookies for purposes such as maintaining continuity during an online session, gathering data about the use of our site, monitoring online promotions, and anti-fraud and information security purposes. We may also, from time to time, utilize additional technologies such as pixel tags, web beacons, script-based trackers, clear GIFs, and other similar techniques, and may permit our third party service providers to use these technologies. We use these technologies for purposes such as measuring the effectiveness of our advertisements or other communications, determining viewing and response rates, measuring technical performance of our sites and mobile apps, and determining which offers to present to you on our own or on third party sites. With selected business partners (for example, Amazon’s FSA|HSA-eligible Store), we may also use tracking technologies for mapping of attribution or referral sources when you click on links that connect to offerings and programs made available in coordination with these partners.

If you wish to disable cookies, the Help feature on most browsers will tell you how to set configuration options for processing cookies, including disabling cookies altogether. By disabling cookies, be aware that you may also disable certain features and functions normally available when visiting our website.

Do Not Track disclosure: Industry standards are currently evolving and we may not separately respond to or take any action with respect to a “do not track” configuration set in your internet browser. Click here to learn more about how Further complies with privacy laws and Do Not Track settings. Additional information about other methods to opt-out from tracking can be found at http://www.aboutads.info/choices.

How Does Further Use the Information We Gather?

We may use and disclose other personal information gathered as described above unless restricted by this policy or by law; for example:

• Customizing your experience on this website including managing and recording your preferences;
• Marketing, product development, and research purposes;
• Tracking resources and data accessed on the website;
• Developing reports regarding website usage, activity, technical performance, and other statistics;
• Assisting users experiencing website difficulties;
• Enabling certain functions and tools on this website;
• Tracking paths of visitors to this website and within this website.

We may share information with service providers with whom we work, such as data processors and companies that help us market products and services to you. When permitted or required by law, we may share information with additional third parties for purposes including response to legal process or law enforcement.

Remarketing

Further uses Google Analytics Remarketing to advertise online.  This means we may continue to show ads to visitors who have previously visited our website. Google remarketing helps us tailor ads that we think may be of interest to you. As always, we respect your privacy and do not collect any personally identifiable information through the use of Google’s remarketing system.

Further and third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on your past visits to our website. It could mean that we advertise to previous visitors who have completed a specific task on the website, for example, downloading a PDF document. We may also tailor advertising based on the specific product pages you viewed on the website. These ads may appear across the internet, including websites on the Google Display Network.

You may opt out of Google’s use of cookies by visiting Google Ads Settings. You can also learn more about opting-out of Google Analytics by using the Google Analytics Opt-outBrowser Add On.

Of course, any data collected will be used in accordance with our own privacy policy and Google’s privacy policy.

Children’s Privacy

Further does not knowingly collect personal information from individuals under the age of 13 without obtaining verifiable consent from their parents. We request that such individuals do not provide personal information through the services.

For more information about the Children’s Online Privacy Protection Act (COPPA), visit the FTC website: http://www.ftc.gov.

Future Changes

Although Further follows the privacy practices described in this notice, you should know that under certain circumstances these practices could change in the future. For example, if privacy laws change, we will change our practices to comply with the law. Should this occur:

• We will post a new notice on our website (www.hellofurther.com) by the effective date of the new notice and will also provide a copy of the new notice, or information about the new notice and how to obtain the new notice, in our next annual mailing to members.
• The changes will apply to all protected health information we have in our possession, including any information created or received before we change the notice.

Contact Us

For more information or to request a copy of this notice please visit www.hellofurther.com.or call us at 1-800-859-2144.

If you think that your privacy rights may have been violated you may either:

1. Call us at the number listed above
2. File a written complaint with our privacy officer at the following address: Further Compliance, P.O. Box 64193, St. Paul, MN 55164-0193
3. Contact the Minnesota Department of Commerce at (651) 296-2488 or call toll free at 1-800-657-3602
4. Contact the Minnesota Department of Health at (651) 282-5600 or toll free 1-800-657-3916
5. Notify the Secretary of the U.S. Department of Health and Human Services (HHS). Send your complaint to: Office for Civil Rights, U.S. Department of Health and Human Services, 233 N.Michigan Ave., Suite 240, Chicago,, IL 60601; Voice Phone (312) 886-2359 or Fax (312) 886-1807 or TDD (312) 353-5693
6. Call the HSS Voice Hotline number at 1-800-368-101

Notice of Privacy Practices