Monument Privacy Policy

Effective Date: June 27, 2024

Introduction

This privacy policy explains how Monument complies with the various applicable US State privacy laws. The intention of this policy is to inform how information is collected on our websites and mobile applications. Any clinical clients of Monument enter into agreements upon admission that contain further privacy policy and client rights. This can be further explored in Monuments various HIPAA disclosures and Notice of Privacy Practices.

Please read this Privacy Policy carefully before using the Sites or Services. By visiting or using any of the Sites or Services, you are accepting the practices described in this Privacy Policy, as well as the Monument Terms of Service and other terms, agreements, statements of rights, consent forms, and policies referenced above, as applicable. If you do not agree to this Privacy Policy, or any of the documents referenced above, please do not use the Sites or Services.

For this policy, it is Monument’s intent to inform you on the following:

• What specific personally identifiable information is collected from you on the website
• How the information on the website is used
• Who we share the information collected from the website with
• The rights and choices you have in regards to the use of your data
• Our security practices in place to protect your information

Monument, Inc. (“Monument”, “Company”, “we”, “us”, or “our”) operates the websites located at joinmonument.com or jointempest.com, and other websites, products, services, and mobile applications with links to this Privacy Policy, (collectively, the “Sites” or “Websites”, unless otherwise specified). Users of the Sites or Services are referred below as “Users”, “Members”, “you”, “your”, or “yours”.

Health Information Collected

We offer online telehealth services enabling our Members to report their health history and engage independent healthcare professionals (“Providers”) to obtain medical and healthcare services.

The Providers who deliver clinical services (“Services”) through Monument are independent professionals practicing within several groups of independently owned professional practices (collectively, “Live Life Now Health”). Please refer to the Live Life Now Health Notice of Privacy Practices to learn more about how these groups use and protect you personal health information. Interactions with our website or applications do not collect any health information from you unless you explicitly provide the information when signing up for any treatment or services.

Your Rights Under HIPAA Regarding Protected Health Information

This section excludes Services performed by or associated with the Live Life Now Health Providers. For more information, please see the Live Life Now Health Notice of Privacy Practices.

You have certain rights regarding your protected health information under HIPAA that may be available to you. For official notice concerning these rights, you should refer to your Plan’s Notice of Privacy Practices. Monument also provides a Notice of Privacy Practices for any services performed on the organization’s behalf.

To exercise these rights, you may contact your Plan at the contact information listed in your Plan’s Notice of Privacy Practices or follow the instructions below under “How to exercise your privacy rights”. Where applicable, we will respond to your request in accordance with the business associate agreement we have with your Plan. In the event of any inconsistency between the below summary, and your Plan’s Notice of Privacy Practices, we will follow your Plan’s Notice of Privacy Practices as applicable, unless we are otherwise instructed by your Plan, subject to a relevant business associate agreement.

Personal Information Collected

We may collect personal information about you when you visit our Website, inquire about our services, if you explicitly agree to any marketing communications, and directly through any Services provided.

The following describes the types of personal and other information Monument may collect about you, and how we may use and maintain that information, including, but not limited to:

• Eligibility, claims, medical history, and other Employer data

  If you are eligible for our Services through your employer, Plan, or labor union (collectively, your “Employer”), your Employer may provide to us directly or via a third-party data required to verify your eligibility, to allow us to communicate with you, and to understand your health. This information may include your name, email address, phone number, Service eligibility data, carrier membership data, biometric data, medical history and claims data, and information used to verify your identity (such as birthday, partial social security number, and/or employee ID number).

• Registration

  Before you can utilize certain services that we offer on the Sites or otherwise, we may ask that you register with the Sites and provide us with your email address, a password, your first and last name and other contact information and personal details. We request this information for identification purposes, to communicate with you regarding your account, and to facilitate the functioning of certain services.

• Forms

  To fully utilize the services we offer, you may be required to fill out forms that will contain personal information such as your name, address, telephone number, social security number, account information, employment, health status and other personal information relevant to your health insurance coverage, diagnosis and treatment.

• Surveys

  At various points in your Member experience with us, you may be presented with optional surveys intended to measure your Service experience in some way.

• Correspondence

  If you correspond with us, including postal, email, in-app chat or messaging, phone, or video, we may retain those records.

• Technical information and usage information

  Like many other websites, we collect information about users’ devices (such as browser and device types, device identification numbers, or other online identifiers) and users’ utilization and navigation of our Sites. This information helps us to design our Sites to better suit our users’ needs. For example, our Sites will track the URL that you visited before you came to our Sites, the URL to which you next go and your Internet Protocol (IP) address. We use your IP address to help diagnose problems with our server and to administer our Sites. Your IP address also is used to help identify you and to gather broad demographic information.

• Information Collected With Cookies

  Like most major websites, we use cookies on certain pages of our Sites. Cookies are small files stored on Your computer’s hard drive that are used to track certain information. These cookies enable Us to track and target the interests of Our users to enhance their experience on Our site.

  Cookies make using the Internet easier by, among other things, saving your preferences for you. For example, a cookie lets the Sites remember that you’ve registered, which allows us to speed up your future activities at our Sites, and which allows you to enter your registration information less frequently while visiting our Sites. We may also use cookies to deliver content tailored to your interests. Our cookies may enable us to relate your use of our Sites to personally identifying information that you previously submitted, such as calling you by name when you return to our Sites.

  If your browser is set to reject cookies, or if your browser notifies you that you are about to receive a cookie and you reject it, then your use of the Sites may not be as efficient or as enjoyable as it would be if the cookie were enabled. The information that we collect with cookies allows us to improve our marketing and promotional efforts, to statistically analyze Sites’ usage, to improve our content and product offerings and to customize our Sites’ content, layout and services.

• Monument Websites

  For users of Monument Websites, in addition to other types of information described above (such as contact information), we also collect: information users provide directly to us, including by registering for events through the Sites, when requesting support, by contacting us with inquiries or comments, or accessing the Sites pages; usage information, such as website traffic patterns; location information, meaning information used to locate the device the user uses to access services (e.g., the location of the device derived from GPS or WiFi use, the location derived from the IP address of the device or internet services used to access services, and other information made available by a user or others that indicates the current or prior location of the user); and any other information that users may provide to us that can be used to identify them. We may also collect personal information about users from other sources, including from employers, which we may combine with the information we collect directly from users to help us tailor communications and improve the services. In connection with the services, we also use information collected from users to connect users with healthcare service providers or organizations and enhance user experiences, such as by tailoring content and remembering user preferences.

• Promotional Offers from Monument

  We will only use your email address to promote our own products and services with your express consent. If you wish to opt-out from such use, you can do so by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or by emailing us at support@joinmonument.com. You may continue to receive service-related and other non-marketing emails.

• Do Not Track Signals

  Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals, and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

To whom does Monument disclose information about you that we collect?

Monument will not share, rent, sell or otherwise disclose any of the personally identifiable information that we collect about you, except when we have your permission or in any of the following situations:

• If you have requested a Service, we may use information about you to fulfill such requests (including providing that information to third parties). We may also at any time review your case, your medical records from prior to and after your interaction with the Sites, and any records created as a result of Services received. We may share information about you, your care, and your use of Services to your healthcare payor, or as necessary to implement plan designs described to you in your applicable Plan documentation, or on your request. If your Plan provides incentives for utilization of services, we will share information required to implement such incentives. We may request courtesy notices from your treating physician(s) and/or request additional medical records from them, including records pertaining to care you received after receiving the services. We may review these records for, among other purposes, reviewing the quality of service you received, reviewing the quality of service provided by the physicians and medical professionals treating you (including the physicians and medical professionals to whom you may have received a referral), to better understand the course of treatment for your condition(s) including information regarding outcomes and costs, and to improve treatments and recommendations for people with similar or different conditions. We will take care to minimize personally identifying information in this process. We may also use anonymous information gathered, including information from your medical records, to generate conclusions about the healthcare process, particular conditions, and other matters. We and our affiliated physicians and researchers may publish this anonymous information in journals, websites and other locations. However, we will not publish your name or any identifying information about you without your permission; we will use only anonymous data for any public purpose.
• We may disclose information that we collect about you to our third-party contractors who perform services for us in order to provide certain services or to complete or confirm a transaction that you conduct with us.
• We may use information we know about you to contact you to inform you about relevant services, including by telephone, text message, email, or direct mail.
• We may disclose the results of anonymized aggregated data about you for marketing or promotional purposes (for instance, that a certain percentage of our Sites’ users are living in a particular state of the United States). In these situations, we do not disclose to these entities any information that could be used to personally identify you. Certain information, such as your password, is not disclosed to marketing advertisers at all, even in aggregate form.
• We may disclose information about you as part of a merger, acquisition or other sale or transfer of its assets or business. We do not guarantee that any entity receiving such information in connection with one of these transactions will comply with all terms of this Privacy Policy.
• We may disclose information about you for purposes such as to provide services available on the Sites; to coordinate with insurance, reinsurance and excess or stop loss insurers; to enforce our Members’ rights; to protect against actual or potential fraud; to resolve Member inquiries or disputes; to receive payments; to carry out our business; to protect the confidentiality or security of our records; to administer preventive health and case management programs; to perform auditing and ratemaking functions; to enable our service providers to perform marketing services on our behalf and inform Users about our own products or services; to comply with federal or state laws and other applicable legal requirements.
• We may disclose your information, to the extent permitted by law, in court or in the stages leading to possible legal action arising from improper use of this website, application or services, or due to a dispute in connection with the related services.
• Moreover, we may be legally obligated to disclose information about you to the government or to third parties under certain circumstances, such as in connection with illegal activity on our Sites or to respond to a subpoena, court order or other legal process. We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary, appropriate or as required under law, such as your statement to hurt yourself or others.
• We may disclose personal information to providers with whom the users have a relationship or with whom users request that we facilitate a consultation or appointment as part of Services.

If you use our Sites or Services outside of the United States, information that we collect about you will be transferred to servers inside the United States, which may involve the transfer of information out of countries located in the European Economic Area. By allowing us to collect information about you, you consent to such transfer and processing of your data.

Security of your Data

Monument takes precautions to protect your information. When you submit sensitive information via the website or applications, your information is protected both online and offline. Encryption is used for any information sent to us.

In addition, we take steps to protect the user data we collect against unauthorized access. However, you should keep in mind that the Sites and our services are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. Please also be aware that despite our best intentions and the guidelines outlined in this Privacy Policy, no data transmission over the Internet or encryption method can be guaranteed to be 100% secure.

We limit access to personal information to our employees and service providers who require access in connection with their role or function. Your data that is stored or transmitted by us is protected by security and access controls and we deploy data encryption where appropriate and possible. Each of our employees is responsible for maintaining the confidentiality of all personal information to which they have access. We keep our employees informed about our policies and procedures for protecting personal information.

The safety and security of your information also depends on you. Where you have chosen a password for the use of our Websites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

How can you correct or update information that we collect about you?

You can review and change your account password and other Personal Data by logging into our Websites and visiting the Account Settings page.

You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible. If you wish to delete your account, you may do so by emailing us at support@joinmonument.com. Please note that we cannot delete your Personal Data except by also deleting your account with us subject to applicable retention periods. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Websites, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Websites users. Proper access and use of information provided on the Websites, including User Contributions, is governed by our Terms of Use.

You may also have the right, in specified circumstances, to request access to or correction of your Personal Data, to request a copy of your Personal Data, to withdraw your consent to our processing of your Personal Data or to have your Personal Data deleted. Your rights are subject to applicable legal restrictions and we may take appropriate steps to verify your identity before responding to your request. To exercise any of these rights, please contact us in writing using the contact information set out in the “Contact Information” section below”.

What are the policies of linked Sites and other third parties?

This Privacy Policy only addresses the use and disclosure of certain information Monument collects from or about you. You should be aware that when you are on the Sites, you can be directed to other websites that are beyond our control, and we are not responsible for the privacy practices of third parties or the content of linked websites. We encourage you to read the posted privacy policy whenever interacting with any website.

How will I know about changes in the Privacy Policy?

Monument’s Sites are owned and operated by Monument. Our Sites are continually under development and changes to the Sites or Services may be made at any time. We reserve the right to revise or remove any part of this Policy in our sole discretion at any time and without prior notice to you, unless where legally required. Thus, you should visit this page periodically for changes. Any changes to this Policy are effective upon posting to the Sites, unless otherwise specified. If you disagree with this Policy, your sole remedy is to discontinue your use of the Sites and Services. Your continued use after a change has been posted constitutes your acceptance of the changes.

What is our policy on children users of our Sites?

Monument does not knowingly collect or maintain personally identifiable information from persons under 18 years old, and no part of our Sites is directed to persons under 18. IF YOU ARE UNDER 18 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS OUR SITES AT ANY TIME OR IN ANY MANNER. Where permitted, any personal information relating to those children will be health information governed by this Privacy Policy or the applicable Notice of Privacy Practices.

If you are a parent or guardian and discover that your child under the age of 18, or equivalent minimum age depending on jurisdiction, has obtained an Monument account, then you may alert us using the contact information below under “Contact Us” and request that we delete that child’s personal information from our systems. If we learn that we have collected the personal information of a child under 18, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible, except where prohibited by applicable law.

We do collect from employers information regarding Members of all ages, so that we may know who is eligible to receive Services. A parent/guardian may request that we stop processing that information if eligible under CCPA or GDPR, as further described below, however you should contact your Employer if you would like that information no longer provided to health carriers.

What law governs my use of the Sites and Monument’s services?

By choosing to visit Monument’s Sites, use our Services, or otherwise provide information to us, the law that governs the rights that you do have is where you are an active resident. This means that you must ensure that there is sufficient evidence and support that can determine the privacy rights that you are entitled to. Monument’s privacy program is intended to cover the most stringent privacy requirements but not all rights are guaranteed due to your local or state law restrictions. You also agree to abide by any limitation on damages contained in our Terms of Service or other agreement that we have with you.

Additional Information About This Privacy Statement

Our Sites are owned and operated by Monument. The terms indicated in this Privacy Policy will remain effective, even if the Member’s coverage is terminated, to the extent we retain information about a Member.

Information about Particular Services

Please note that the descriptions below concerning particular services may not apply to all services, sites, or mobile applications provided by Monument.

Additional Information for California Consumers

This part of the document integrates with and supplements the information contained in the rest of the Privacy Policy, and applies to any personal information processed by Monument of Users who are consumers, residing in the state of California, United States of America, and subject to The California Consumer Privacy Act (CCPA) of 2018. For such consumers, these provisions supersede any other possibly divergent or conflicting provisions contained in the Privacy Policy.

This section of the Policy uses the term “personal information” as it is defined in CCPA.

Categories of personal information collected, disclosed or sold

Please refer to the list above under “What information do we collect from users and how is it used?”

How we use the information we collect: sharing and disclosing of your personal information with third parties for a business purpose

We may disclose the personal information we collect about you to a third party for business purposes. In this case, we enter a written agreement with such third party that requires the recipient to both keep the personal information confidential and not use it for any purpose(s) other than those necessary for the performance of the agreement.

We may also disclose your personal information to third parties when you explicitly ask or authorize us to do so, in order to provide you with our Service.

To find out more about the purposes of processing, please refer to the relevant section of this document.

Your right to opt out of the sale of personal information

We do not sell Member information, including lists of Members or any personal information of Members otherwise.

To the extent our website uses third party cookies and these cookies collect personal information, such collection may in some cases be considered a “sale” of personal information for purposes of the CCPA.

You have the right to opt out of the sale of your personal information. This means that whenever you request us to stop selling your data, we will abide by your request.

You can opt out of such sales. Such requests can be made freely, at any time, without submitting any verifiable request by following the below instructions.

Instructions to opt out of the sale of personal information

On our Sites are cookie banners with a button labeled “Do not sell my data.” This button was added in order to comply with the CCPA, and it offers information about our use of these third-party cookies, and provides consumers an opportunity to opt-out of certain of these cookies.

Should you wish to opt-out of these cookies, please click on the “Do not sell my data” button on the banner that pops up. This will result in the placement of an opt-out cookie on your device browser.

If you’d like to know more, you can contact us at the contact details below under “Contact Us”.

What are the purposes for which we use your personal information?

We may use your personal information to allow us to render services to you and your Employer (if applicable), the operational functioning of the Sites and features thereof (all together, “business purposes”).

We may also use your personal information for other reasons such as for commercial purposes as well as for complying with the law and defending our rights before the competent authorities where our rights and interests are threatened or we suffer an actual damage.

Your California privacy rights

The right to know and to portability

You have the right to request that we disclose to you:

• the categories and sources of the personal information that we collect about you, the purposes for which we use your information and with whom such information is shared;
• in case of sale of personal information or disclosure for a business purpose, two separate lists where we disclose:
  • for sales, the personal information categories purchased by each category of recipient; and
  • for disclosures for a business purpose, the personal information categories obtained by each category of recipient.
• The disclosure described above will be limited to the personal information collected or used over the past 12 months.

If we deliver our response electronically, the information enclosed will be “portable”, i.e. delivered in an easily usable format to enable you to transmit the information to another entity without hindrance – provided that this is technically feasible.

The right to request the deletion of your personal information

You have the right to request that we delete any of your personal information, subject to exceptions set forth by the law (such as, including but not limited to, where the information is used to identify and repair errors on this Website, to detect security incidents and protect against fraudulent or illegal activities, to exercise certain rights etc.). For example, we cannot delete information that explains medical treatment decisions, as we are legally obligated to keep such information.

If no legal exception applies, as a result of exercising your right, we will delete your personal information and direct any of our service providers to do so.

How to exercise your privacy rights

How to make a request

At Monument, member and consumer privacy are very important to us. As a result, before we process any requests we first must verify your identity and ensure we have enough information. To exercise rights described throughout the Privacy Policy, you must submit to us a “verifiable request by:

• providing sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
• describing your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

With that in mind, at this time:

• Requests from Members are considered verified if submitted using our Services. If you are an existing Member, please submit your request either by calling us and confirming your identity, or by submitting via the application (e.g., using the chat service, or via an open case). If, however, there is indication or suspicion of fraud or other malicious activity on the Member’s account, we may suspend reliance on these verification methods and defer to other methods to confirm authenticity.
• You may alternatively contact us via the information provided below under “Contact Us”. However, please note that emailed requests are not considered verified, and we may request additional information from you (that we would already have in our records) in order to confirm your identity.
• We may also recognize verified requests submitted on an individual’s behalf by “Authorized Agents”. To be valid, we must receive from the Agent a signed authorization from the individual on whose behalf the Agent is acting. We will also need to verify the authorization with the consumer.
• For “household” requests subject to the CCPA, we will need to verify each household Member’s individual identity and current status as household members.
• And we will not process any requests of children under 13 years of age without verifiable consents from their parents or legal guardians.

We will not respond to or process any unverified request. This is all done to protect your confidentiality and ensure, to the best of our ability, that we only process such requests for the right persons.

You can submit a maximum number of 2 requests over a period of 12 months, free of charge. Requests over this amount may be subject to additional fees. We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

If you choose to exercise your privacy rights, you will not receive discriminatory treatment or a lesser degree of service from us.

How and when we are expected to handle your request

Unless otherwise specified in this Policy, the following applies for timing and expectations around how and when we will respond to your requests. If our response to a privacy request is restricted by an agreement between us and your Employer, we will process your requests in accordance with that agreement and related authorization. Otherwise, the following applies.

To the best of our ability, we will confirm receipt of your verifiable request within 10 days and provide information about how we will process your request.

For CCPA-related requests, we will respond to your request within 45 days of its receipt, and for all other requests within 30 days of receipt. Should we need more time, we will explain to you the reasons why, and how much more time we need. In this regard, please note that we may take up to 90 days to fulfill your request.

Our CCPA disclosures will cover the preceding 12 month period.

Should we deny your request, we will explain to you the reasons behind our denial.

We do not charge a fee to process or respond to your verifiable request unless such request is manifestly unfounded or excessive. In such cases, we may charge a reasonable fee, or refuse to act on the request. In either case, we will communicate our choices and explain the reasons behind it.

Contact Us

If you have questions, want to submit a request, have concerns about this Policy or Monument’s Privacy Practices, or would like to report a violation, see the below contact options:

You may contact us:

How to Contact Us:
Monument, Inc. Attn: Monument Team
350 7th Ave Suite 600 New York, New York 10001
Telephone: (646) 960-3553
Email: support@joinmonument.com
Support Request Form: https://support.joinmonument.com/hc/en-us/requests/new