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Simple Steps To A Healthier Life Privacy Policy

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space placeholder. Introduction.
space placeholder. Data Usage.
space placeholder. User Registration.
space placeholder. Security Of Information.
space placeholder. Privacy Concerns.
space placeholder. Cookies.
space placeholder. IP Addresses.
space placeholder. User Age Restriction.
space placeholder. Leaving Simple Steps To A Healthier Life.
space placeholder. Effect Of Privacy Policy.
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space placeholder. Introduction
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The mission of Simple Steps To A Healthier Life is to improve the health and well-being of health-care consumers by offering a Health Assessment (HA), educational materials and health-management informational programs online.

When you visit and navigate our Web site, we will not collect personal information or personal health information about you unless you provide us with that information voluntarily. By "personal information," we mean data that is unique to an individual, such as a name, address, e-mail address or telephone number. By "personal health information" we mean the data and responses you voluntarily provide when completing the HA. We recommend that you read our Privacy Policy whenever you visit our site. This Privacy Policy may be revised periodically.

Significant changes to the policy will be highlighted.

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space placeholder. Data Usage
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The Simple Steps To A Healthier Life tool and the Health Assessment are an important part of Aetna's overall health-care benefits-administration programs, and with your authorization, will be used in a variety of ways in support of these programs. In general, the information will be used in much the same way as information gathered in connection with Aetna's patient-management programs. For example, it may be made available to our patient-management nurses to help coordinate your care and assist you with appropriate disease-management tools. It also may be used for purposes of internal studies of the effectiveness of care coordination and disease management, and it may be shared with one or more third parties outside of Aetna. Overall, your information will be used and disclosed in accordance with the HIPAA Privacy Rules as part of Aetna's payment activities and health-care operations. Please see Aetna's "Notice of Privacy Practices" (or your employer's "Notice of Privacy Practices" (for self-insured business) for a more detailed description of the different ways in which protected health information may be used and disclosed. Aetna's notice can be found at www.aetna.com. If you have questions regarding this notice or would like a paper copy of the notice, please call the toll-free number on your ID card if you are an Aetna Health Plan member or mail your correspondence to:

Aetna Legal Support Services Department
151 Farmington Avenue, W121
Hartford, CT 06156

If a user decides at any time that he or she does not wish to have access to his or her Health Assessment and no longer wants his or her personal data, registration information and personal health information used or shared by Aetna, the user may revoke his or her authorization at any time by canceling his or her registration with Simple Steps To A Healthier Life.

The Health Assessment is a computer-generated review based upon the data and information a user provides in response to the questions presented. The Health Action Plan, produced from those responses, does not diagnose, prescribe or give medical advice and is not a substitute for medical care. All health-care needs should be coordinated through a health-care professional.

You can update a completed Health Assessment at any time by selecting the "Update My Health Assessment" link on the Simple Steps To A Healthier Life home page. Or, create a new Health Assessment by selecting the "Create" link.

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space placeholder. User Registration
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Registration is required to access our site. When you register, we require the following personal information: e-mail address, first and last name, date of birth, Social Security number or Aetna member identification number, gender, zip code and phone number. We treat any personal information you give us as confidential. We do not analyze your personal information without your consent.

You can update your personal information at any time by selecting the "My Profile" link on the Simple Steps To A Healthier Life home page.

In addition to any clinical information you may provide, we also collect a record of your usage of the particular condition areas of the site.

All of this information is collected by us and pooled and stored in our secure database behind an electronic firewall. Unless you have agreed otherwise or we are permitted by the HIPAA Privacy Rules, we use all of this information in aggregated form only. In other words, the information is combined with data collected from other individuals to produce anonymous, aggregated statistical information. This information will show, for a particular employer's registered users, site usage information such as the number of registrants, site visits, and HA completions, as well as the number of registrants who are participating in particular health-management programs (aggregated usage information), what percentage of an employer's population are at of certain health conditions (aggregated -factor reporting), and information on how certain illnesses impact a company's workplace productivity (aggregated health and productivity measurements). This information will be used and shared by us for the purpose of gaining a better understanding of product utilization, workplace productivity and health issues. We also may share information pertaining to Aetna membership status in a non-personally identifiable form with our affiliates for purposes of analyzing use of the Simple Steps To A Healthier Life product by Aetna's membership.

We will not disclose to third parties any identifying personal information or personal health information gathered from you during registration unless (1) we are required to disclose such information by any applicable law or legal process (such as a subpoena or court order), or (2) we tell you how your information will be used and you give us specific permission to share this information, in which case we will require the recipient to use the information only for the purpose you permit, or (3) your employer has a rewards incentive program, in which case we will disclose to your employer your: name, location, social security number, completion date of the rewardable activity and the amount of the incentive for which you have qualified.

Your personal information and personal health information may be sold in the event of the sale, transfer, merger, consolidation or other extraordinary transaction involving all or part of our assets or securities with another entity. Additionally, we may share your personal information and personal health information with such other entity in the course of any due diligence investigations related to any such transaction.

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space placeholder. Security Of Information
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We commit to use security procedures to protect personal information and personal health information you submit to us from misuse or unauthorized disclosure. The personal information and personal health information that you submit to us is stored in our secure database behind an electronic firewall.

Access to the data within Simple Steps To A Healthier Life is limited to a few computer technicians for our site who need to maintain the database and who also use passwords for that access, as well as outside vendors who may occasionally assist us in maintaining and improving our hardware and software tools.

We make every effort to safeguard your personal information and personal health information. However, like other Internet sites, we cannot guarantee that it is completely secure from people who might attempt to evade security measures or intercept transmissions over the Internet.

Similarly, we cannot completely ensure the privacy of e-mail communications to and from our site because they are not encrypted and, therefore, not secure. These communications, like most Internet e-mail, could be intercepted without your knowledge and permission, while in transit to or from our site. This includes e-mail you send to us through our various mailboxes. If you are concerned about your privacy, we suggest that you do not use e-mail to communicate information to us that you consider sensitive.

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space placeholder. Privacy Concerns
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If you have any concerns about the security or privacy of your personal information or personal health information on the Simple Steps To A Healthier Life Web site, please complete this information form or send a written notification to:

Aetna InteliHealth Inc.
c/o Simple Steps To A Healthier Life
Customer Service Department
930 Harvest Drive
Mail stop: U33N
Blue Bell, PA 19422

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space placeholder. Cookies
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Cookies are small bits of information that help Web sites manage and, in most cases, enhance your experience on their sites. The site you're on may return a cookie to your browser. Your browser may store it on your hard drive or hold it in memory until the browser is closed. Your browser sends only those cookies related to the site you're on with every request. The relationship between a cookie and a Web site is determined by the domain name (like www.simplestepslife.com). The only piece of data a Web site can access on your hard drive is its related cookie (if it was physically stored there). One Web site cannot access cookies from other sites nor any information on your hard drive placed there by you or any other source.

We use only benign cookies that have no functionality. This means the cookie cannot do anything nor read information from your computer's hard drive. The life of the cookie only lasts for the period your browser is open. They're typically called session cookies. The cookies aren't stored on your hard drive, they only persist in the browser's memory until the browser is closed.

Unlike many other Web sites, we do not use cookies to tailor advertisements or other information that appear during your visit to your preferences or your use of our site.

If you click on an advertisement or sponsorship acknowledgment, you will be leaving Simple Steps To A Healthier Life and will be directed to the advertiser or sponsor's site. Be aware that we have no control over the practices of other Web sites. Your computer may receive cookies from other sites and you will not be protected by our security and privacy policies.

Web browsers give you the ability to turn the cookie feature on or off. See your browser's help menu for more information. We require that this feature be on in order for you to use Simple Steps To A Healthier Life. Most browsers, by default, have this option turned on.

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space placeholder. IP Addresses
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An Internet Protocol (IP) address is a number that is automatically assigned to your computer by your Internet Service Provider (ISP) whenever you access the Internet. This number may be the same each time you access the Internet or it may change. Like other Internet sites, we use IP addresses to collect aggregate information about numbers of visitors and site usage. The address is logged on our server when your computer requests information from Simple Steps To A Healthier Life. However, to allow users to access our site anonymously, your IP address is not linked with personal information about you. We reserve the right, in rare instances, to use IP addresses to identify individuals who threaten our site, service or customers.

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space placeholder. User Age Restriction
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We will not knowingly allow anyone under the age of 18 to register on our site for any purpose or to access any features that require registration. We require visitors to indicate their year of birth to register. If we learn that we inadvertently have collected identifying personal information from anyone under the age of 18, we will promptly delete that information from our system.

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space placeholder. Leaving Simple Steps To A Healthier Life
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This Privacy Policy applies only as long as you remain on our Web site. Once you leave Simple Steps To A Healthier Life to visit another site, we have no control over your privacy or security issues, even if you reached the other site by clicking on a link within Simple Steps To A Healthier Life.

At times, clicking on a hyperlink within an article will bring up information on another site without warning. In these cases, however, the information will appear in a second, smaller "pop-up" window and the Simple Steps To A Healthier Life page will remain clearly visible on your computer screen.

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space placeholder. Effect Of Privacy Policy
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This Privacy Policy is not intended to and does not create any contractual or legal rights in or on behalf of any party.

This policy is effective as of January 27, 2005.
Revisions effective as of June 11, 2008.

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