Your information belongs to you

Our Privacy Policy

Betterpath, Inc. (“Betterpath,” “we,” “us,” or “our”) welcomes you. We’re really excited that you have decided to use and access the BetterHSA Platform, including betterpath.com, hsa.betterpath.com, and any sub-domains thereof (collectively, “Platform”).

This Privacy Policy sets forth Betterpath’s policy for BetterHSA with respect to health data, personally identifiable information and related data that is collected by the Platform among both visitors and Registered BetterHSA users.

By using the Platform, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service. Capitalized terms not defined in this Privacy Policy shall have the meaning set forth in our Terms of Service.

If you have any questions or comments about this Privacy Policy or our use of your personally identifiable information, please contact us at [email protected].

Information We Collect

  1. Personal Data

    We collect personally identifiable information from you when you voluntarily provide such information, such as when you create a BetterHSA account and become a BetterHSA User (for example, name and email address) or when you otherwise contact us with inquiries or respond to one of our communications (such information is collectively referred to herein as “Personal Data”). Personal Data does not include Personal Health Information provided by you to Betterpath through the BetterHSA or any related Platform App. We do not collect any Personal Data from you when you use the Website or related digital properties unless you provide us with the Personal Data voluntarily. When you voluntarily submit your Personal Data to us, you are giving us your consent to the collection, analysis, and storage of your Personal Data as set forth in this Privacy Policy. We will never share your Personal Data or Personal Health Information for commercial purposes without your approval.
  2. Protected Health Information

    Our collection and use of protected health information (“Protected Health Information”) occurs only when you authorize certain data sources to be connected to the Platform. Data sources are connected through Betterpath’s API, which provides end-to-end encryption to ensure data is secure in transmission. Sources of Protected Health Information may include but are not limited to: mobile apps, web portals, biometric devices and wearables. The Protected Health Information collected from these sources is owned and controlled by you, and will never be shared with any third parties without your authorization.

    When you authorize your Protected Health Information to be shared for commercial purposes, your Personal Data is removed and replaced with a code to reduce the risk of you being identified by a third party. Your Protected Health Information will be stored natively on your mobile device, and will only be accessed and stored on the Platform when you authorize its use for commercial purposes.

  3. Financial Information

    Our collection and use of financial information ("Financial Information") occurs when you create a BetterHSA account and become a BetterHSA User. Financial Information is used by BetterHSA's FDIC-insured Financial Custodians to create a savings account that allows you and Betterpath to contribute money and track expenditures through the BetterHSA Debit Card. Financial Information will never be shared with third parties without your authorization. When you authorize Financial Information to be shared for commercial purposes, your Personal Data is removed and replaced with a code to reduce the risk of you being identified by a third party. Your Financial Information will be stored with BetterHSA's Financial Custodians, and will only be accessed and stored on the Platform when you authorize its use for commercial purposes.
  4. Other Information

    We may collect additional information (collectively, the “Other Information”). Such Other Information may include any details you choose to self disclose which may range from self-reported symptoms or lack thereof to biometric performance data captured by a mobile device. This information is never required and you should only disclose information you are comfortable including in your data set.
    1. From You. Additional information that you voluntarily provide to us, such as characteristics of your hobbies, personal interests, household income range, gender, marital status, occupation, product and service preferences, and other information that may or may not identify you personally.
    2. From Your Activity. Information that we automatically collect when you use the Website, including, without limitation:
      • IP address, browser type and language, referring and exit pages and URLs, date and time, amount of time spent on particular pages, sections of the Website visited, etc.;
      • Information about a mobile device, including universally unique ID (“UUID”), Platform type and version (e.g., iOS or Android), carrier and country location, hardware and processor information (storage, chip speed, camera resolution, NFC enabled, and network type (WiFi, 2G, 3G, 4G); and
      • Activity and usage information occurring via the Website, including search information; when you search on our Website, we store the search terms and the visited pages so that we can continuously improve the quality of our search results.
    3. From Cookies. Information that we collect using “cookie” technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will “remember” information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using the Website. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the Website may not function properly.

The Information Collected by or Through Third-Party Advertising Companies

We may share Other Information about your activity on the Website with third parties for the purpose of tailoring, analyzing, managing, reporting, and optimizing advertising you see on the Website and elsewhere. These third parties may use cookies, pixel tags (also called web beacons or clear gifs), and/or other technologies to collect such Other Information for such purposes. Pixel tags enable us, and these third-party advertisers, to recognize a browser’s cookie when a browser visits the Website on which the pixel tag is located in order to learn which advertisement brings a user to a given Website.

Accessing and Modifying Personal Data and Communication Preferences

If you have provided us Personal Data, you may access, review, and make changes to your Personal Data through your BetterHSA Data Settings. If you have authorized sources of Protected Health Information to be connected through the Platform, you may access, review and make changes to these authorizations at any time through your BetterHSA Data Settings. In addition, you may manage your receipt of marketing and non-transactional communications by clicking on the “unsubscribe” link located on the bottom of any Betterpath marketing email. We will use commercially reasonable efforts to process such requests in a timely manner. You should be aware, however, that it is not always possible to completely remove or modify information in our subscription databases. You cannot opt out of receiving transactional e-mails related to your transactions with us.

How We Use and Share the Information

You are always in control of how your Information is accessed and shared with third parties. We use the Personal Data, Protected Health Information, Financial Information, and the Other Information, (collectively, the “Information”) to process your BetterHSA Debit Card transactions, provide and improve the Platform and our services, solicit your feedback, inform you about our products and services, and administer our rewards and profit sharing programs. When you opt-in to share your Information for commercial purposes, the Information may be used in the following ways:

  • To administer our rewards and profit sharing programs, we may share your Information with our third-party promotional and marketing partners, including, without limitation, businesses participating in our various programs.
  • In an ongoing effort to better understand our users, Platform, and services, we might analyze the Information in aggregate form in order to operate, maintain, manage, and improve our services and/or Platform. This aggregate information does not identify you personally. We may share this aggregate data with our affiliates, agents, and business partners. We may also disclose aggregated user statistics in order to describe the Platform and our business to current and prospective business partners and to other third parties for other lawful purposes.
  • With your permission, we may share Information with other companies who may provide you information about the products and services they offer. However, to the extent required by law, you will be given the opportunity to opt-out of such sharing.
  • We may employ other companies and individuals to perform functions on our behalf. Examples may include providing processing payments for transactions conducted through the Platform, marketing assistance, information technology support, and customer service. These other companies will have access to the Information only as necessary to perform their functions and to the extent permitted by law.
  • With your permission, third-party applications or services may access your Information.
  • As we develop our businesses, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, sale of assets, dissolution, or similar event, the Information may be part of the transferred assets.
  • To the extent permitted by law, we may also disclose the Information when required by law, court order, or other government or law enforcement authority or regulatory agency, or whenever we believe that disclosing the such information is necessary or advisable, for example, to protect the rights, property, or safety of Betterpath or others.

How We Protect Your Information

We take commercially reasonable steps to protect the Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. The Platform's backend service provider is compliant with HITRUST-CSF and HIPAA Security regualations. Our Privacy Policy and Terms of Service are compliant with the highest consumer data protections standards, including GDPR. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the information you supply will not be intercepted while being transmitted to and from us over the Internet.

Important Notice to Non-U.S. Residents

It is important to note that the Platform and its servers are operated in the United States. If you are located outside of the United States, please be aware that any Information you provide to us will be transferred to the United States. By using the Platform and by providing us your Information, you hereby consent to this transfer and our use of the Information in accordance with this Privacy Policy.

Children

We do not knowingly collect Information from children under the age of 13 through the Platform. If you are under 13, please do not give us any Information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide Information through the Platform without their permission. If you have reason to believe that a child under the age of 13 has provided Information to us, please contact us, and we will endeavor to delete that information from our databases.

External Websites

The Platform may contain links to External Websites. Betterpath has no control over the privacy practices or the content of any such External Website. As such, we are not responsible for the content or the privacy policies of those External Websites. You should check the applicable third-party privacy policy and terms of use when visiting any External Website.

Changes to This Privacy Policy

Betterpath reserves the right to make changes to this Privacy Policy at any time. If Betterpath makes a material modification to this Privacy Policy, it will notify you by: (i) sending an email to the address associated with your account (Betterpath is not responsible for your failure to receive an email due to the actions of your ISP or any email filtering service; therefore, you should add Betterpath.com to the list of domains approved to send you email (commonly known as your “whitelist”)); or (ii) displaying a prominent announcement above the text of this Privacy Policy for thirty (30) days, with (i) or (ii) being deemed sufficient notification, of such changes.

After notice of a modification to this Privacy Policy has been posted for 30 days, the notice may be removed. If you choose to continue using the Platform, you agree that by doing so you will be deemed to accept the new Privacy Policy.

Email Communications

Email communication that you send to us via the Platform may be shared with a customer care representative, employee or the expert that is most likely to be able to address your inquiry. The Information you provide in your email will be used only for the purposes of answering your email. From time to time we may send you Platform-related emails, such as a welcome email when you register with the Platform.

Referrals

When you refer a friend to join the Platform, your friend will receive a link to download the BetterHSA App, or an email invitation automatically sent from Betterpath on your behalf. We will not use your friend's email address for any other purpose. Similarly, when you email a message using the Referral function, the email addresses are used to facilitate the email communication and are not retained by us.

Newsletters and Alerts

At various places on the Platform you will be given the option to receive recurring newsletters and to set alerts and reminders. You can unsubscribe from newsletters by clicking on the unsubscribe link. You can manage your alerts and notifications through your account.

How to Contact Us

If you have questions about this Privacy Policy, please e-mail us at: [email protected]

You may also write to us at: Betterpath, 68 Jay Street Suite 201, Brooklyn, NY 11201