Website Privacy Policy Supplement - Blue Cross and Blue Shield of Kansas City

This Privacy Policy Supplement for California, Colorado, Connecticut, Virginia, Utah, Montana, Tennessee, Oregon, Texas, Iowa, Indiana, and Delaware Residents (the “Supplement”) supplements the information contained in Blue Cross and Blue Shield of Kansas City (“Blue KC”, “we”, “us”, or “our”) Privacy Policy (the “General Privacy Policy”) and applies solely to those consumers who reside in the States of California, Colorado, Connecticut, Virginia, Utah, Montana, Tennessee, Oregon, Texas, Iowa, Indiana, Delaware (“consumers” or “you”). The terms of this Supplement shall govern over any conflict with the General Privacy Policy. We adopt this Supplement to comply with the California Consumer Privacy Act of 2018 (“CCPA”), Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), Virginia Consumer Data Protection Act (“VCDPA”), Utah Consumer Privacy Act (“UCPA”), Montana Consumer Data Privacy Act (“MTCDPA”), Tennessee Information Protection Act (“TIPA”), Oregon Consumer Privacy Act (“OCPA”), Texas Data Privacy and Security Act (“TDPSA”), Iowa Consumer Data Protection Act (“ICDPA”), Indiana Consumer Data Protection Act (“INCDPA”), and Delaware Personal Data Privacy Act (“DPDPA”) and any terms defined in the CCPA, CPA, CTDPA, VCDPA, UCPA, MTCDPA, TIPA, OCPA, TDPSA, ICDPA, INCDPA, DPDPA have the same meaning when used in this Supplement.

Information We Collect

Our websites (www.bluekc.com, www.spiracare.com, www.medicarebluekc.com, www.bluekcforyou.com, www.shutoutthestigma.com, www.mindfulbluekc.com, www.cobalt-venture.com and their subpages and content, collectively the “Site”) collects information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household, or device (“personal information”). Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Other information deemed under applicable California, Colorado, Connecticut, Virginia, Utah, Montana, Tennessee, Oregon, Texas, Iowa, Indiana, and Delaware law not to be personal information.

In particular, our Site has collected within the last twelve (12) months, and intends to continue collecting, the following categories of personal information from consumers:

Category	Examples	Collected
A. Identifiers.	For example, Blue KC may collect one of the following identifiers: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80I).	For example, Blue KC may collect one of the following identifiers: A name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California, Colorado, Connecticut, Virginia, Utah Montana, Tennessee, Oregon, Texas, Iowa, Indiana, Delaware or federal law.	For example, Blue KC may collect one of the following identifiers: A Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	For example, Blue KC may collect one of the following identifiers: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	For example, Blue KC may collect one of the following identifiers: A Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	For example, Blue KC may collect one of the following identifiers: A Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	For example, Blue KC may collect one of the following identifiers: A Physical location or movements.	YES
H. Sensory data.	For example, Blue KC may collect one of the following identifiers: A Audio, electronic, visual, thermal, olfactory, or similar information.	NO
I. Professional or employment-related information.	For example, Blue KC may collect one of the following identifiers: A Current or past job history or performance evaluations.	NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	For example, Blue KC may collect one of the following identifiers: A Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	NO
K. Inferences drawn from other personal information.	For example, Blue KC may collect one of the following identifiers: A Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

We obtain the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on our Site.
From other third parties, including those listed on our General Privacy Policy.

The information we obtain about you from third parties may be combined and utilized with the information you provide to us.

Use of Personal Information

We may use, share, or disclose the personal information we collect for one or more of the following purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To provide, support, personalize, and develop our Site, products, and services.
To create, maintain, customize, and secure your account with us.
To process your requests, purchases, transactions, and payments and prevent transactional fraud.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Site, third-party sites, and via email or text message (with your consent, where required by law).
To help maintain the safety, security, and integrity of our Site, products and services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve our Site, products, and services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
As described to you when collecting your personal information or as otherwise set forth in the CCPA, CPA, CTDPA, VCDPA, UCPA, MTCDPA, TIPA, OCPA, TDPSA, ICDPA, INCDPA, DPDPA.
For other purposes provided in our General Privacy Policy.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our Site users and customers is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

We may share your personal information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the personal information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, we have disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.

We may also share your personal information, including by selling it to third parties, subject to your right to opt-out of those sales. Our personal information sales do not knowingly include information about individuals we know are under the age of sixteen (16), regardless if we have parental consent. In the preceding twelve (12) months, we have sold the following categories of personal information to the categories of third parties indicated in the chart below. For more on your personal information sale rights, see Personal Information Sales Opt-Out and Opt-In Rights.

Personal Information Category	Category of Third-Party Recipients
Personal Information Category	Business Purpose Disclosures	Sales*
A. Identifiers.	IP Address, first and third-party cookies, name and email address may be collected.	No
B. California Customer Records personal information categories.		No
C. Protected classification characteristics under California, Colorado, Connecticut, Virginia, Utah or federal law.		No
D. Commercial information.		No
E. Biometric information.		No
F. Internet or other similar network activity.	May be collected	No
G. Geolocation data.	May be collected	No
H. Sensory data.		No
I. Professional or employment-related information.	May be collected	No
J. Non-public education information.	May be collected	No
K. Inferences drawn from other personal information.		No

* Except as provided on our Privacy Policy.

Reselling Personal Information

The CCPA, CPA, CTDPA, VCDPA, UCPA, MTCDPA, TIPA, OCPA, TDPSA, ICDPA, INCDPA, and DPDPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. If you would like a list of the businesses with whom we may share or resell your information, you may contact us to request that information. Generally speaking, however, we only share your information with our business partnership who aid in providing you the services associated with Blue Cross and Blue Shield of Kansas City’s website and application, and for third-party website analytics (e.g. Google). To opt-out of those sales, please see opt-out procedure provided on Your Rights and Choices Under the CCPA section.

Your Rights and Choices Under the CCPA

The CCPA provides consumers, employees, potential employees and businesses that are California residents with specific rights regarding their personal information. This section describes CCPA rights available to those persons and explains how to exercise those rights.

NOTE: In some instances, we may NOT be able to comply with your request given that we are not the data controller, but instead, are a data processor and/or may be required under applicable law to maintain your data.

Right to Know and Data Portability

You have the right to know what information we have collected about you over the past twelve (12) months and how we use it. Once we receive your request to exercise your right to know and confirm your identity (see Exercising Your Rights), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
If we sold or disclosed your personal information for a business purpose, two (2) separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
The specific pieces of personal information we collected about you in a readable format (also called a data portability request).

Right to Correct

You have the right to correct inaccuracies in your personal information that we collected from you and retained. Once we receive your request to exercise your right to correct and confirm your identity (see Exercising Your Rights), we will use commercially reasonable efforts to correct the inaccurate personal information as directed by you. We may deny your request if a response is impossible or would involve disproportionate effort to correct inaccurate information.

Right to Delete

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive your request to exercise your right to delete and confirm your identity (see Exercising Your Rights), we will review your request to see if an exception allowing us to retain the information applies. We may deny your request if retaining the information is necessary for us or our service provider(s) to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

If your request to delete is not subject to one of the above exceptions, we will grant your request to delete or deidentify personal information from our records and will direct our service providers to take similar action.

Right to Opt Out of Sale or Sharing

You have the right to opt out of the sale or sharing of your personal information to third parties. For instructions on exercising your right to opt out of the sale or sharing of your personal information, see Personal Information Sales and Targeted Advertising Opt-Out and Opt-In Rights.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have the right to limit the use of your sensitive personal information to that use which is necessary to perform the services and goods we provide as mentioned above in the “Sharing Personal Information” section.

Exercising Your Rights

To exercise your right to know, right to correct, right to delete, or right to limit as further described above, please submit a request by either:

Calling us at 816-395-3784 or toll free at 1-800-932-1114
Emailing us at privacy@bluekc.com

Only you, or someone legally authorized to act on your behalf, may make a request related to your personal information.

You may also make a request on behalf of your child by contacting us at the information above and provide information that will allow us to properly identify your child and your relationship as the parent or guardian of your child.

You may only submit a request twice within a twelve (12) -month period. Your request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include:
- Contact information.
- Information about prior purchase history.
- Other information as we may reasonably request.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
If you are an authorized agent of a third party, you must provide us with: (i) sufficient information demonstrating your role as an authorized agent for the individual you are making the request about (e.g. Court order, power of attorney, etc.); (ii) information that will allow us to verify your identity; and (iii) any other information that we may reasonably request consistent with applicable law in order to authenticate your request.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

You do not need to create an account with us to submit a request to know or delete. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.

Please note that additional time may be needed to process the deletion of personal information from backup and/or archival databases.

For instructions on exercising your sale opt-out or opt-in rights, see Personal Information Sales and Targeted Advertising Opt-Out and Opt-In Rights.

Response Timing and Format

We will confirm receipt of your request to exercise your right to know, right to correct, right to delete, and/or right to limit within ten (10) business days. If you do not receive confirmation within the ten (10) -day timeframe, please call us at 816-395-3784 or toll free at 1-800-932-1114.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the twelve (12) -month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales and Targeted Advertising Opt-Out and Opt-In Rights

If you are age sixteen (16) or older, you have the right to opt-out of the sale of your personal information at any time. We do not sell the personal information of consumers we actually know are less than sixteen (16) years old regardless if we receive parental consent. Consumers who opt in to personal information sales may request to opt out of future sales at any time.

To exercise the right to opt out of the sale of your personal information, you (or your authorized representative) may submit a request to opt-out to us by visiting the following Internet Web page link: “Do Not Sell My Personal Information”.

Once you make a request to opt-out of the sale of your personal information, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales at any time by contacting us.

You do not need to create an account with us to exercise your right to opt-out of the sale of your personal information. We will only use personal information provided in a request to opt-out of the sale of your personal information to review and comply with the request to opt-out.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights set forth above. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time by calling us at 816-395-3784 or toll free at 1-800-932-1114 or emailing us at Privacy@bluekc.com. We may provide financial incentives from time to time including through promotions, contests, gift cards, giveaways, discounts/sales, and rewards. The terms of any such incentives will be communicated with that particular financial incentive.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are consumers, employees, potential employees and businesses that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email or write us at the addresses provided below.

Your Rights and Choices under the CPA, CTDPA, VCDPA, UCPA, MTCDPA, TIPA, OCPA, TDPSA, ICDPA, INCDPA, DPDPA

The disclosures in this section apply solely to individual residents of the States of Colorado, Connecticut, Virginia, Montana, Tennessee, Oregon, Texas, Iowa, Indiana, and Delaware as applicable. If you are a resident of one of these states, we may share your personal information by disclosing it to a third party for a business purpose.

Privacy laws in these states give residents certain rights with respect to their personal data when they take effect over the course of 2023 through 2026. Those rights include:

Right of Access: You have the right to access and obtain a copy of your personal data.
Right to Correct: You have the right to correct inaccuracies in your personal data.
Right to Deletion: You have the right to request that we delete personal data provided by or obtained by you.
Right to Opt-Out of Targeted Advertising: You may ask us not to use or disclose your information for the purposes of targeting advertising to you based on your personal data obtained from your activity across different businesses, services, websites, etc.
Right to Opt-Out of Personal Information Sales to third parties.
Right to Non-Discrimination: We may not process personal data in violation of state and federal consumer anti-discrimination laws or discriminate against you for exercising rights under these state laws.

To submit a request to exercise any of the above rights, please refer to the above section “Exercising Your Rights”. You may email us at privacy@bluekc.com with the subject line “Privacy Rights Request” and let us know in which state you live. Please see the above section “Personal Information Sales and Targeted Advertising Opt-Out and Opt-In Rights” for a description of how to exercise your right to opt-out of targeted advertising or sales and uses for purposes not directly related to the Website.

Changes to this Supplement

We reserve the right to amend this Supplement at our discretion and at any time. When we make changes to this Supplement, we will post the updated notice on the Site and update the notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes to this Supplement.

Contact Information

If you have any questions or comments about this Supplement, the ways in which Blue KC collects and uses your information described herein this Supplement, your choices and rights regarding such use, or wish to exercise your rights under California, Colorado, Connecticut, Virginia, Utah, Montana, Tennessee, Oregon, Texas, Iowa, Indiana, Delaware law, please contact us at:

Phone:	816-395-3784 or toll free at 1-800-932-1114
Website:	www.bluekc.com
Email:	privacy@bluekc.com
Postal Address:	P.O. Box 417012, Kansas City, MO 64141.

If you need to access this Supplement in an alternative format due to having a disability, please contact Privacy@bluekc.com or 816-395-3784 or toll free at 1-800-932-1114.