Cole Managed Vision Web Privacy Policy
Last Updated: 09/28/2005

Your privacy concerns are important to us at Cole Managed Vision. Our Web Privacy Policy is designed to provide you with the knowledge you need to control your personal information. We encourage you to read the entire policy so you have a firm understanding of what information we collect, how we use that information, how we protect that information and what you can do to control the use of your information.

This web site is designed to serve the users of our vision services ("Users") and the participating providers of those services ("Providers"). This Web Privacy Policy attempts to distinguish between Users and Providers. If it is unclear to which group a provision applies, or if a provision is not specifically limited to Users or Providers, then the provision applies to both Users and Providers.

Cole Managed Vision is dedicated to the fundamentals of protecting your privacy on the Internet.

TABLE OF CONTENTS
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What Information We Collect
How We Use Your Information
How We Protect Your Information
Your Control of Your Information
Changes to the Web Privacy Policy
Questions About the Web Privacy Policy



1.     WHAT INFORMATION WE COLLECT
Find a Provider Service: When Users utilize our Find a Provider service, we
collect non-personally identifiable information about our Users, including their plan number and zip code.


Provider Registration:
When a Provider registers to use this web site, we collect information about that Provider over the web site, including their doctor number, password and/or location number.

Provider's Request of Member Eligibility: Within the Provider area of our web site, Providers can send us requests for member eligibility, which lets a Provider know whether or not a certain User is eligible for vision services. As part of this process, we collect the plan number, User name and individually identifiable number assigned to each User (i.e. social security number) in order to process the Provider's request for eligibility.

Provider Claim Submission: Within the Provider area of our web site, Providers can send us claim submissions. Claim submissions are a request for payment from Cole Managed Vision for services that the Provider has provided to one of our Users. To submit a claim, a Provider will send us the plan number, User name, individually identifiable number assigned to each User (i.e. social security number), Provider number and claim related information.

Aggregate Information: Cole Managed Vision collects aggregate, non-personal information about its users and their usage of this web site and any related services. The web server supporting this site collects internet protocol ("IP") addresses and/or domain names, but not the e-mail addresses, of visitors. This information is not used to identify any individual user.

Cookies: Cole Managed Vision also collects information about your use of the site through the use of cookies. Cookies are small pieces of information passed by the web server to your browser. We use cookies to identify you to the web server during page requests. We also use cookies to tailor your experience on our web site. You can control the use of cookies through your browser settings.

Information from Children: Cole Managed Vision does not direct its web site to children under thirteen (13) years of age. Individuals under eighteen (18) should consult with their parent or guardian about the use of this site for their benefit.



2.     HOW WE USE YOUR INFORMATION
Third Parties: Cole Managed Vision only collects personal information from our visitors on a voluntary basis. Cole Managed Vision does not sell that information. Cole Managed Vision shares information with its affiliated organiziations and contracted entities involved in providing services for or administering vision services. Cole Managed Vision does share your personal information with Users' health plan, employer or plan sponsor ("plan") in order to perform Cole Managed Vision's contractual obligations with these plans. At times, Cole Managed Vision also shares personal information with our contractors enabling them to perform certain functions for Cole Managed Vision. Some Cole Managed Vision services are offered in conjunction with a plan or a contractor. In order to provide these services to you, it is necessary for us to share information with these entities.

Find a Provider Service: Cole Managed Vision does not use the non-personally identifiable information collected from Users to utilize the Find a Provider service to identify any individual Users, or distribute the information to any third parties.

Provider Registration: Information collected about our Providers during the registration process is not disclosed to third parties.

Provider's Request of User Eligibility and Claim Submission: Personally identifiable information collected about our Users during the eligibility and claim submission processes will only be used for legitimate business purposes. Specifically, we use this information to process eligibility inquiries and pay your claims.

Aggregate Information: Cole Managed Vision uses aggregate information to measure number of visits, average time spent on the site, pages viewed, and the like. Cole Managed Vision uses this information to measure the use of our site and to improve the content of our site. External companies may be provided aggregate information about our Users or Providers.

Cookies: Information collected via cookies helps Cole Managed Vision determine what areas of our site are important to our Users and Providers. Cole Managed Vision does not use cookies to identify individual Users or Providers.

Transmission Errors or Unauthorized Acts: Although Cole Managed Vision will use all reasonable efforts to safeguard the confidentiality of your personal information, transmissions made by means of the Internet cannot be made absolutely secure. Cole Managed Vision will not be liable for disclosures of your personal information due to errors in transmission or the unauthorized acts of third parties.

Required by Law: In cases, where required by law or the court, Cole Managed Vision may be forced to release information regarding our Users or Providers to permit the investigation of credit card fraud, illegal use of the Internet or some other cases of misconduct on our web site.

Change of Ownership or Control: In the event that Cole Managed Vision becomes owned or controlled by other individuals or entities, the information we have collected may be transferred to such party or parties. In this case, such individuals or entities will follow this Web Privacy Policy in the place of Cole Managed Vision's current owners.

Links: Cole Managed Vision's web site may contain links to other sites. However, we are not responsible for the content or the privacy practices employed by other sites. To the extent that you disclose personal information to other web sites, you are subject to the other web sites' privacy policies. We encourage you to review a third party web site's privacy policy before you disclose any personal information.



 
3.     HOW WE PROTECT YOUR INFORMATION
Security: Any information provided to Cole Managed Vision is treated with care and discretion. Cole Managed Vision uses all reasonable efforts to keep information from our users secure against unauthorized access and use.

Passwords: As part of the registration process, your Provider access is password protected. The transmission of your password is encrypted. It is important for you to protect your password and computer from unauthorized access.

Encryption: When you submit personal information to the secure areas of Cole Managed Vision's web site, we encrypt it using Secure Sockets Layer ("SSL"), an encryption software program. Encryption is the industry standard means to protect information as it passes over the web to our server. We use care to protect this information against unauthorized access and modification once it is stored on our database.



4.     YOUR CONTROL OF YOUR INFORMATION
Cole Managed Vision respects your decisions about the collection and use of your information. By accessing and using this web site, you consent to the use of your personal and health information by Cole Managed Vision in the manner specified in this Web Privacy Policy. Also, we provide e-mail addresses to enable you to provide comments and ask questions about our web site,. These e-mails are non-encrypted Internet communications and may be accessed and viewed by other users, without your knowledge and permission. Please do not use e-mail to communicate information to us that you consider confidential.

  
5.     CHANGES TO THE WEB PRIVACY POLICY
Cole Managed Vision may make changes to its Web Privacy Policy from time to time without notice. When significant changes are made that affect how information that you provided to us is used, Cole Managed Vision will alert you to changes by revising this Web Privacy Policy. By continuing to use this web site, you agree to be bound by any such revisions and should therefore periodically visit this page of the web site and print the latest version of the Web Privacy Policy for your records. For your information, the date of the last update to this Web Privacy Policy is stated at the top of the document.


6.     QUESTIONS ABOUT THE WEB PRIVACY POLICY
If you have any questions regarding this Web Privacy Policy,
please forward your inquiries to:

COLE MANAGED VISION
ATTN: RESEARCH DEPARTMENT
1925 ENTERPRISE PARKWAY
TWINSBURG, OH 44087