Effective Date: May, 2018

Privacy matters to Change Healthcare, so whether you are new to Change Healthcare or a long-time user, please do take the time to get to know our practices – and if you have any questions contact us.

This Privacy Policy describes how Change Healthcare Ireland Solutions Ltd (also known as Change Healthcare Ireland) a subsidiary of Change Healthcare LLC, may collect, use and share information about you, in association with the operation of our main website, www.changehealthcare.ie, and other of our websites, mobile applications, and HTML-formatted emails that link to this Privacy Policy and do not have a separate privacy notice (collectively, “Digital Services”). 

Some Change Healthcare companies may have a privacy notice that differs from this Privacy Policy.  

This Privacy Policy describes:

• The Types of Information We Collect 
• How We Use the Information We Collect 
• How We May Share the Information We Collect 
• Third-Party Services and Content 
• Protection and Storage of the Information We Collect 
• Your Choices and Rights 
• How to Contact Us 
• Changes to This Privacy Policy 

Personal information we collect

"Personal information" is any information that can be used to identify you or that we can link to you. We may automatically collect certain information when you access, use or interact with our Digital Services. And we may collect information from other sources, including commercially available sources, such as public or subscription-based databases, where permitted by law. Your failure to provide certain information may prevent or delay the fulfilment of our obligations to you or to the organization with which you are affiliated. 

Information you provide us

You generally can use some of our Digital Services without providing us with personal information. We collect information that you voluntarily provide to us, including when you communicate with us by email; when you sign up for or request that we send you information about our products and services; when you apply for a position with us; when you sign up for a webinar or event; and when you respond to our communications or requests for information. The information you provide may include your name, contact information, title, and information about the organization with which you are affiliated; financial account information should you purchase products or services from us. Some of our Digital Services may require that you enter a password or other information to access certain features, and we collect such credentials when you enter them.

Information we may collect automatically

We use browser cookies and similar technologies (collectively, “Cookies”) to collect and store certain information when you use, access, or interact with our Digital Services. We may, for example, collect information about the type of device you use to access the Digital Services, the operating system and version, your IP address, your general geographic location as indicated by your IP address, your browser type, the content you view and features you access on the Digital Services, the web pages you view immediately before and after you access the Digital Services, whether and how you interact with content available on the Digital Services, the search terms you enter on the Digital Services, and information we may generate as a result of your use of the Digital Services, such as our understanding of your interests and whether you are a regular or occasional user of the Digital Services. For information about how we use Cookies and the choices you may have, please see our Cookies Policy.

We do not currently respond to web browser “do not track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Privacy Policy. The following are examples of the other categories of information which we may collect and use about you:

Information we may collect from other sources

We may receive information about you from other sources, including third parties that help us: update, expand, and analyse our records; identify new customers; determine you or your organization’s advertising or purchasing preferences; or prevent or detect fraud. The information we may receive is governed by the privacy settings, policies, and/or procedures of these third-party sources.

How we may use your information

We may use the information we collect:

• To respond to your inquiries;
• To provide you or your organization with products and services that you request;
• To operate, troubleshoot and improve the Digital Services;
• To maintain our contacts;
• To understand how people use our Digital Services;
• To development and improve products and services;
• To assess the effectiveness of our Digital Services and other products and services, promotions, and publications;
• To evaluate, recruit, and hire personnel;
• As we believe reasonably necessary or appropriate to comply with our legal or regulatory obligations; respond to legal process or requests for information from government authorities and other third parties; or to protect your, our and others’ rights.

We may also anonymize or pseudonymize your personal information in such a way that you may not reasonably be re-identified by us or others, and may use this anonymized or pseudonymized information for any other purpose.

How we may share the information we collect

We may disclose your personal information with third parties under the following circumstances:

• To service providers and business partners: that perform operations for us for the purposes set forth above; 
• To other Change Healthcare Group companies: for the purposes set forth above;
•  Where required by law or in the context of an audit or other review: with law enforcement agencies, courts, other government authorities or other third parties, including our advisors, where we believe necessary to comply with a legal or regulatory obligation, or otherwise to protect your, our other others’ rights;
• In the context of a transaction: to potential business partners, service providers, advisors, and other third parties relating to the consideration, negotiation, or completion of a corporate transaction, such as a merger or acquisition or a sale or transfer all or a portion of our assets or business. Should such a sale or transfer occur, we will use reasonable efforts to obligate the entity to which we transfer your personal information to use it in a manner that is consistent with this Privacy Policy.

Grounds for using your personal information

We rely on the following legal grounds to process your information:

• Performance of a contract: We may need to collect and use your personal information to enter into a contract you or to perform a contract that you have or your organization has with us. For example, when you use our Digital Services we will use your personal information to respond to your requests and provide you with products and services.
• Consent: We may use precise location information as described in this Privacy Policy subject to your consent. To withdraw your consent to such use, you can contact us, as provided below, or you may be able to disable the sharing of location information in your browser or mobile application settings. Where required by applicable laws, we will rely on your consent for direct marketing and to collect information from your device or computer.
• Legitimate Interests: We may use your personal information for our legitimate interests to improve our products and services and the content on our Digital Services. Consistent with our legitimate interests and any choices that we offer or consents that may be required under applicable laws, we may use technical information as described in this Privacy Policy and use personal information for our marketing purposes.

Your rights

You have certain rights regarding the personal information we collect and process, subject to local law. These may include the rights to access, correct, delete, restrict or object to our use of, or receive a portable copy in a usable electronic format of your personal information. You also may have a right to make a complaint with your local data protection or privacy regulator.

We encourage you to contact us at the contact information set forth below to update or correct your information if it changes or if the personal information we hold about you is inaccurate.  Where you have provided your consent to any use of your personal information, you can withdraw this consent at any time.  But we may require additional information from you to honour such requests.

If you would like to discuss or exercise any rights you may have under law, please contact us as set forth below.

Information Security and Storage

We implement physical, technical, and organizational security measures designed to safeguard the personal information we process through the Services. These measures are aimed at providing on-going integrity and confidentiality for your personal information. We evaluate and update these measures on an ongoing basis. However, no information system can be 100% secure, so we cannot guarantee the absolute security of your information.

We retain your personal information for as long as we have a relationship with you. When deciding how long to keep your personal information after our relationship with you has ended, we consider our legal obligations and internal information management policies.  For example, we may retain records to investigate or defend against potential legal claims, or where required by law.

International Data Transfers

Your personal information may be transferred to, stored, and processed in a country that is not regarded as providing the same level of protection for personal information as the laws of your home country (for example if you reside in the European Union), and may be available to the government of those countries under a lawful order made in those countries.

We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to provide adequate protections for your personal information.

Privacy Shield

Change Healthcare LLC subsidiaries adhere to the Privacy Shield Framework as set forth by the U.S. Department of Commerce, and publicly certify that they comply with the Privacy Shield Principles. For information, please visit Change Healthcare’s Privacy Shield notice. Change Healthcare is committed to subjecting all personal information received from European Economic Area (EEA), in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, or to view the certifications, please visit the U.S. Department of Commerce’s Privacy Shield website.

Change Healthcare is responsible for the processing of personal information it receives under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Change Healthcare complies with the Privacy Shield Principles for all onward transfers of personal information from the EEA, including the onward transfer liability provisions.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, Change Healthcare is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Change Healthcare may be required to disclose personal information in response to lawful requests by public authorities, including for meeting national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Contact Us

If you have questions or concerns regarding the way in which your personal information has been used, please contact our Data Protection Officer at ChiefPrivacyOfficer@ChangeHealthcare.com, or by mail at Change Healthcare Ireland Solutions Ltd, 1 Woodford Business Park, Santry, Dublin 17, D17 EW81, Ireland.

If you have an unresolved privacy or information use concern that has not been addressed satisfactorily, please contact Change Healthcare’s U.S.-based third party dispute resolution provider (free of charge).

Changes to this Privacy Policy

We may modify or update this privacy policy from time to time. If we make any revisions that materially alter the ways in which we process your personal information, we will notify you by posting notice of the changes in a clear and conspicuous manner on this Website before applying them to your information.  We encourage you to review this page periodically.