Privacy Statement

Effective Date: June 27, 2024

(If you are a CA resident, this statement includes your California Privacy Rights. If you are a CO resident, this statement includes your Colorado Privacy Rights. If you are a CT resident, this statement includes your Connecticut Privacy Rights. If you are a MT resident, this statement includes your Montana Privacy Rights. If you are an OR resident, this statement includes your Oregon Privacy Rights. If you are a TX resident, this statement includes your Texas Privacy Rights. If you are a UT resident, this statement includes your Utah Privacy Rights. If you are a VA resident, this statement includes your Virginia Privacy Rights.)

Welcome to the Silver&Fit^® program which is a fitness and healthy aging education program designed for older adults (the “Silver&Fit Program” or “Program”).The Silver&Fit website (the “Silver&Fit Website” or “Website”), are owned and operated by American Specialty Health Fitness Incorporated (“ASH Fitness”), a subsidiary of American Specialty Health Incorporated (“ASH”), a Delaware corporation with a mailing address of 10221 Wateridge Circle, San Diego, CA 92121, on behalf of itself and its subsidiaries. The Silver&Fit Healthy Aging Program as part of the Silver&Fit program is managed by ASH Fitness affiliate, American Specialty Health Management, Inc. (“ASH Management”). The provisions of this Privacy Statement apply to these companies to the extent they support the Silver&Fit program. The terms “ASH” or “We” in this Privacy Statement refer collectively to these companies.

ASH values its users (“you”) and respects your privacy. We are committed to using your information responsibly. The information you provide to us through the Silver&Fit Program or on the Silver&Fit Website is governed by this Privacy Statement. This Privacy Statement informs users about the Silver&Fit information practices, including: what personal information we collect through the Silver&Fit Program and on the Silver&Fit Website; how the personal information is collected; how the personal information will be used; and the choices you have about the collection and use of personal information. If you access the Silver&Fit Website through one of ASH’s health plan partners, any information you provide to us on the Silver&Fit Website will be governed by this Privacy Statement.

This Privacy Statement, together with the Terms and Conditions, governs your use of the Silver&Fit Program and your use of the Silver&Fit Website. By using the Silver&Fit Website, you accept and agree to be bound by this Privacy Statement and the Terms and Conditions.

You should read and familiarize yourself with this Privacy Statement and with the SilverandFit.com Terms and Conditions. By using SilverandFit.com you acknowledge and consent to our collection, processing and use of your information as described in this Privacy Statement. For any questions about this Privacy Statement, please contact us directly through any means noted at the end of this Privacy Statement. If information practices change, SilverandFit.com will post the revised policy on SilverandFit.com and/or will notify users through direct communication.

Information Collected by Silver&Fit

The types of information collected through the Silver&Fit Program or on the Silver&Fit Website (as further described below) may be considered Protected Health Information (“PHI”) and Personally-Identifiable Information (“PII”). We refer to both PHI and PII collectively as Personal Information (“PI”) in this document. We collect only PI that is necessary for users to access and use the Silver&Fit Program tools and features and the Silver&Fit Website (as further described below). Whether or not to provide PI is your choice, but without providing certain information you will not be able to access and use all tools and features of the Silver&Fit Program and Website. Sensitive personal information is information related to reproductive health, sexually transmitted diseases, substance use disorder, gender dysphoria, gender affirming care, domestic violence, and mental health.

The collection of sensitive personal information is limited to our Healthy Aging Program. Should you choose to use the Healthy Aging Program, we must first make sure the coaching services available are appropriate for you. To do so, we ask general questions about mental and/or physical health concerns. Based on responses to such questions, or if you appeal any ASH determination not to make coaching services available to You, ASH may require more information from you or your medical provider. ASH intentionally limits the information needed to make these determinations using the least amount of information necessary. Please do not volunteer more detailed sensitive personal information than what is required.

How we obtain information about you:

when you provide it to us (e.g., by contacting us through our Contact Us, when you call us, when registering or enrolling for the services)
from your use of our website, using cookies,
from your Sponsoring Organization (e.g., Health Plan or Insurer), and
occasionally, from our Service Providers.

This chart is a reference guide on how the Silver&Fit Program collects, uses, and shares your information. This is only a summary. You should review the full privacy statement below for more detail. If you are a California, Colorado, Connecticut, Montana, Oregon, Texas, Utah, or Virginia resident, the full privacy statement below contains important information related to your privacy rights.
Publicly available program features
	Categories of Personal Information	Source of Collection	Business Purpose	Disclosure to Others
Digital Workouts and Educational Videos on Silver&Fit public facing website Live Fitness Class Streaming on Social Media Platforms	Identifiers: IP Address Device ID Fitness ID Profile name (if you comment or interact with Silver&Fit on social media platforms or Streaming Service Providers)	Provided by you to Streaming Service Provider or ASH when you activate or stream a digital workout, educational videos or live fitness class.	Facilitate access to and viewing of streamed materials made available through the program but hosted on, or streamed through, the Streaming Service Provider’s platform or social media platforms. For registered members: to perform services such as maintain and service your account, provide customer service, process transactions, track utilization, and verify customer information.	Your use of the third-party website (Facebook, Youtube, etc.) to view publicly available live classes is governed by its own Privacy Policy and Terms & Conditions. If you comment on a workout video, your comment may be publicly viewable and ASH may receive your profile name, in order to reply to your comment. With Streaming Service Provider for digital workouts. For registered members: We may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes. If you are enrolled in rewards, ASH may use utilization data to process rewards with your Sponsoring Organization.
Blog	Identifier: E-mail address	Provided by you.	To subscribe to notifications of new blog articles posted to the Silver&Fit public website.	We share the email address with the service providers supporting hosting the blog, and delivery of the notifications.
Fitness Center Search	Personal Information: Address	Provided by you.	We use the address information you provide to conduct a search of Fitness Centers near your searched location.	We do not share the address information you enter on our site with any third parties.
Contact Us	Identifier: First and last name E-mail address Personal Information: Phone number, Sponsoring Organization, General inquiry details	Provided by you.	To verify your information and to perform services addressing your questions, suggestions and complaints.	We may share the information outside of ASH as necessary to respond to your message, or to resolve your inquiry or concern when resolution requires third-party action including, if applicable, with your Sponsoring Organization. We share information with our Service Providers for auditing, detecting security incidents, debugging programs, internal research and tech development, and quality assurance and product improvement.
Cookies, Website Analytics, and Benefit Based Marketing	Internet or Electronic Activity Information: Web server logs, Cookies, Web beacons, Silver&Fit Website browsing activity	Provided by Google Analytics and other third-party pixels.	To perform auditing, detecting security incidents, debugging programs, internal research and tech development, quality assurance and product improvement. For registered members: To perform services related to advertising and marketing of affiliate products available to you through ASH as part of your Sponsoring Organization’s plan.	We do not share personal information related to the information that Google Analytics or third-party pixels provides to us with any other third parties.
Program features available to registered members
	Categories of Personal Information	Source of Collection	Business Purpose	Disclosure to Others
Website Registration/ Program Enrollment/ Benefit Administration	Identifiers: First and last name, Email address, Username and password, Security question and answer, Fitness ID, Sponsoring Organization Member ID (provided by your Sponsoring Organization) Personal Information: Phone number (optional) Address Protected Class Information: Date of Birth Other Information: Selected fitness center location	Provided by you during registration and by your Sponsoring Organization for eligibility purposes.	To perform services to maintain and service your account, provide customer service, process transactions, verify customer information and eligibility, and advertising and marketing of affiliate products available to you through ASH as part of your Sponsoring Organization’s plan. To perform auditing, detecting security incidents, debugging programs, internal research and tech development, quality assurance, and product improvement. To provide a directory of Fitness Centers.	Pursuant to the consent that you have given to your Sponsoring Organization, and (if applicable) as permitted under HIPAA and your Sponsoring Organization’s Notice of Privacy Practices, we may share information with the benefit administrator of said organization as necessary for benefit administration purposes. With persons acting on behalf of contracted Fitness Centers and/or Active Options providers (hereinafter “Fitness Providers”) for eligibility, reimbursement, and utilization reporting. Information shared may include name, email address, Fitness ID, location, program name, selected facility, and effective date/termination date. Fitness Providers may share utilization data with Us for benefit administration purposes. We may share email, first name, and last name with service providers who support email communications.
Well-Being Telephonic Coaching	Identifier: First and last name, E-mail address, Mailing address Special Identifier Information: Phone Number Video and/or Audio: Coaching sessions may be telephone or virtual capturing voice and video Personal Information: Sponsoring Organization name, Well-Being Coaching Enrollment Information (e.g., information related to wellness goals, Height, Weight) Protected Class Information: Date of Birth Gender Sensitive Personal Information: General health information	Provided by you. Well-Being Coaching Information is provided by you to ASH Fitness’ affiliate, American Specialty Health Management, Inc. (ASH Management). ASH Management provides the coaching services.	To perform services such as maintain and service your account, provide customer service, process transactions, verify customer information, and advertising and marketing of affiliate products available to you through ASH as part of your Sponsoring Organization’s Plan. General health information is collected to ensure coaching program is appropriate for you.	ASH Management provides the coaching services with administrative support provided by ASH Fitness. Well-Being Coaching Information noted herein is retained by ASH Management. We may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes.
FitnessCoach	Identifier: First and last name, E-mail address, Mailing address Other Information: Sponsoring Organization name, Well-Being Coaching Enrollment Information (e.g., information related to wellness goals, Height, Weight) Protected Class Information: Date of Birth Gender Sensitive Personal Information: General health information	Provided by you.	To perform services such as maintain and service your account, provide customer service, process transactions, verify customer information, and advertising and marketing of affiliate products available to you through ASH as part of your Sponsoring Organization’s Plan. General health information is collected to ensure coaching program is appropriate for you.	ASH Management provides the coaching services with administrative support provided by ASH Fitness. FitnessCoach Information noted herein is retained by ASH Management. We may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes.
Connected!^TM Feature	Identifiers: Device ID Protected Class Information: Date of Birth Personal Information: Your fitness device activity information (e.g., steps, exercise duration, etc.) Height Weight Time Zone	When you agree to participate in the Connected! feature, you authorize your device to share your activity information with an activity aggregator, who forwards the activity information to Us to include in your account. For Apple Watch users: Your device sends information directly to us which is then shared with our activity aggregator Service Provider so that it may be added to your account.	To perform services related to recording your activity, such as steps taken in a day, tracking your progress over time and processing rewards, if applicable. To perform auditing, detecting security incidents, debugging programs, internal research and tech development, quality assurance, and product improvement.	We may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes.
Silver&Fit ASHSync^TM App for Apple Watch users	Identifiers: First Name Last Name Username Password Device ID IP Address Personal Information: Your fitness device activity information for Apple Watch (e.g., steps, exercise duration, etc.) Height Weight Time Zone Username Password	Provided by You when you log in. When you authorize your device to send your information through the app to our activity aggregator Service Provider so that it may be added to your account so that ASH may track incentives, if applicable.	To perform services for the business: (e.g., to track your activity and progress over time, and to process rewards, if applicable.) To provide fitness related services to you, including, but not limited to the Resource Library and access to on-demand digital workouts.	We may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes.
Surveys	Identifiers: First and last name, Email address Mailing address Sponsoring Organization Member ID (provided by your Sponsoring Organization) Protected Class Information: Date of Birth Gender	Provided by your Sponsoring Organization or by you to ASH; when ASH uses our Survey Service Provider, we share this information with the provider.	To gather customer feedback to perform services related to internal research, tech development, quality assurance and product improvement.	With Survey Service Provider for administering the survey. We may share aggregate results of the survey with Sponsoring Organizations, existing and potential clients, and the public.
Home Fitness Kits	Identifiers: First and last name, Email Fitness ID Personal Information: Sponsoring Org. ID Address Phone Number Which Home Fitness Kit you have selected	Provided by you to ASH Service Provider. Information you enter on our Service Providers website may be subject to their Terms and Conditions.	To perform services such as maintaining and servicing your account, provide customer service, and bill your Sponsoring Organization for utilization.	We share with your Sponsoring Organization for benefit administration, utilization reporting, and billing purposes. ASH will receive data from third party service providers to help administer your benefit.
Workout Plans	Personal Information: Exercise goal, Fitness level	Provided by you.	To recommend workout videos, exercise plans, and home fitness kit(s) to you.	We may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes. We may also share aggregate usage and response information with existing and potential clients, and the public.
The Well-Being Club	Personal Information: Well-being habit to create, habit to learn about, preference to connect with others	Provided by you.	To understand your well-being goals. To recommend healthy aging content, options to interact with other members and/or your community.	We may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes. We may also share aggregate usage and response information with existing and potential clients, and the public.
Virtual Events	Identifiers: IP Address Device ID Client ID Email Address	Provided by you to Streaming Service Provider or ASH when you activate or stream a digital workout, educational videos or live fitness class.	Facilitate access to and viewing of streamed materials made available through the program but hosted on, or streamed through, the Streaming Service Provider’s platform or social media platforms. For registered members: to perform services such as maintain and service your account, provide customer service, process transactions, track utilization, and verify customer information.	Your use of the third-party website (Zoom, etc.) to view live classes is governed by the third party’s own Privacy Policy and Terms & Conditions. For registered members: We may share information with your Sponsoring Organization, and/or designated vendor, and our Service Providers for benefit administration, utilization reporting, and billing purposes.
Payment Processing	If you choose to enroll in the Silver&Fit Program, you will be asked to provide your credit card information to process any fees incurred by you as part of the program, including but not limited to, required annual and/or monthly dues. We use a PCI-compliant third-party payment processor to collect and process your credit card information. Our systems store redacted credit card information (first six (6) and last four (4) numbers of your credit card), according to PCI data protection standards. Silver&Fit does not collect or process full credit card numbers or security codes.
Additional Sharing	For legal purposes, including: as reasonably necessary to comply with law or legal process (including a court or government order or subpoena); to detect, prevent, or otherwise address fraud, security or technical issues; to enforce this Privacy Statement or the Terms and Conditions for the Silver&Fit program and the use of this Website; and as reasonably necessary to protect the rights, property or safety of ASH, ASH users, and/or the public. During a corporate reorganization: If ASH is involved in a merger, acquisition, financing, or sale of business or assets, information collected from and about users may be transferred to one or more third parties involved in such transaction and, upon such transfer, the relevant third-party privacy policy or policies may govern further use of the information. In the event of such a change, ASH will endeavor to notify our users of the change as well as any choices our users may have regarding the change. Aggregate information: In addition, ASH may provide service providers, reputable third-party vendors and Sponsoring Organizations with aggregate statistics regarding user participation, Silver&Fit Website traffic patterns and related Usage Information. The information so provided will not include individually identifiable information, meaning we will not share your Personal Information when sharing aggregate information.
Your Silver&Fit Program may include access to other ASH products and programs, such as but not limited to, the ChooseHealthy Program, Well-Being Telephonic Coaching program and the ASHSyncTM app. These products and programs have separate Terms and Conditions and Privacy Statements and may be provided by affiliates of ASH Fitness. You should review and accept their respective Terms and Conditions and Privacy Statements before you use them. If you consent to your information being used to access one of our affiliate products, the use of your information is governed by the Privacy Statement of the affiliate product.
If you choose not to provide your Personal Information, certain features of the Silver&Fit Program and Silver&Fit Website will not be available to you.

How Silver&Fit Uses Personal Information

Publicly available program features

Digital Workouts: For some digital workouts, ASH embeds Streaming Service Providers’ video platform directly onto the Silver&Fit website. For such content, when you view the content, the Streaming Service Provider and ASH will receive analytic information such as IP address, Device ID, videos participants have selected to watch, and the timestamp when such participants watched the videos. The provider and ASH will use this information to receive data about the content being accessed and to process payment to the Streaming Service Provider. In addition, ASH will pair the information with your Fitness ID for program administration purposes. We may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes.
Viewing live-streamed workouts. If you click on the Silver&Fit live workout links hosted on Facebook and YouTube, you will be redirected to those third-party websites to view the workout. Your use of the third-party website (Facebook, YouTube, etc.) is governed by its own Privacy Policy and Terms and Conditions. If you comment on a workout video, your comment may be publicly viewable and ASH may receive your profile name, in order to reply to your comment.
Blog: The blog is available to the public on SilverandFit.com. You can opt in to receive notifications via email when new blog articles are published. Your email address will be shared with the service providers supporting hosting the blog and delivery of the notifications.
Searching for a Silver&Fit Fitness Center: We use the address you provide to help locate Silver&Fit fitness centers near you.
If you Contact Us, we collect your name, phone, e-mail address, inquiry type, and comment. We will use your information to process and respond to your inquiries and requests. We may share with your Sponsoring Organization to respond to your message, or to resolve any inquiry that require third-party action. If you contact us by phone, we may record your phone calls for quality and training purposes.
Additionally, we may collect your IP addresses (which are numerical numbers that are automatically assigned to users’ computers and mobile devices when they use the Internet) and information obtained by tracking the "clickstreams" from usage of SilverandFit.com (page requests, pages visited, content viewed, clicks and search queries made, etc.).

Cookies and other similar technologies

We use cookies and other similar technologies on the Silver&Fit Website to help us remember who you are, to enhance and personalize your experience, to understand and save your preferences for future visits, to compile group information about our users, and to carry out other tasks relating to the operation or improvement of the Silver&Fit Website.

"Cookies" are small text files that are placed on your hard disk by a webpage server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. Most web browsers are initially set to accept cookies, but you can change your browser settings to notify you when you are sent a cookie, giving you the ability to accept or reject it, or you can choose to routinely and manually delete cookies stored on your computer or mobile device. Each time you revisit the Silver&Fit Website, your ability to restrict our use of cookies on that service is subject to your browser settings and limitations at the time. Please note that if you choose to disable or reject cookies from the Silver&Fit Website, some portions and features of the Silver&Fit Website may become inaccessible or may not function properly. For more information on how to manage cookies, visit http://www.aboutcookies.org/.
We may also use "web beacons" – which can be included in web pages or in emails for reporting and analytic purposes, such as counting users who have visited a web page and/or tracking usage patterns. We do not gather personal information of any kind via this activity. Web beacons cannot be declined when delivered via a regular web page. However, web beacons can be refused when delivered via email. If you do not wish to receive web beacons via email, refuse HTML (select Text only) emails via your email.
Third-Party Pixels: There are three types of commonly used pixels: Targeting Pixels, Retargeting pixels, and Conversion pixels. All pixels are tiny snippets of code that allow website owners to gather information about visitors to the website. Website pixels track how you browse, what type of ads you click on, and if you make any purchases. We use tracking pixels to measure our non-targeted, general or benefit-based marketing campaign’s performance, track conversions, and build an audience base.
Do Not Track: Some web browsers incorporate a "do-not-track" (“DNT”) or similar feature that signals to websites that a visitor does not want to have his/her online activity tracked. If a website receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, we (along with many other website operators) do not currently respond to DNT signals. For more information about DNT signals, visit www.allaboutdnt.com.
Data Analytic Providers: We use Google Analytics as our Data Analytics Provider to collect information to improve the Website, such as how often users visit the Website, what pages they visit when they do so, and how users landed on the Silver&Fit Website. Google Analytics places a cookie on your web browser so that it can identify you the next time you visit the Website, and the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. If you don’t want Google Analytics to be used in your browser, you can install the Google Analytics opt-out browser add-on which is available at https://tools.google.com/dlpage/gaoptout.

Program features available to registered members

Registration: When you register on the Silver&Fit Website, we collect your name, date of birth, address, e-mail address, and home phone number. We also require a username and password to enter the password-protected area of the Silver&Fit Website and a security question and answer to help recover your username and/or password. We may share you email, first name, and last name with service providers who support email communication. We will use your registration information to set up, administer, service, and communicate with you regarding your account. Registration on the Silver&Fit Website is required for users to gain access to special tools and features of the Silver&Fit program. If you enroll in the Silver&Fit program, we will use the eligibility information that your Sponsoring Organization sends ASH, including your Sponsoring Organization member ID to verify your eligibility and complete your enrollment.
Searching for and selecting a Silver&Fit Fitness Center: We use the address you provide to help locate Silver&Fit fitness centers near you. If you enroll with a fitness center, we will use your information to process your enrollment along with a Fitness ID we assign to your account with Fitness Centers. We do so to confirm your eligibility for services, to reimburse Fitness Centers and for reporting utilization of the Fitness Center services. Additional information shared with Fitness Centers for these purposes may include your Sponsoring Organization’s program name, your effective date/termination date with Silver&Fit, and the fitness center location and date of your visit or use of the location. We may receive your fitness center location and date of visit information directly from the fitness center if the fitness center is in the Silver&Fit network. By selecting such a fitness center for the purpose of participating in the Silver&Fit program, you acknowledge and agree that the fitness center may provide your visit information to us on your behalf. We also share your visit information, including Fitness Center location and date of visit, with your Sponsoring Organization, if applicable, to manage your program.
If you participate in Silver&Fit Well-Being Telephonic Coaching, ASH will collect your first and last name, date of birth, gender, e-mail address, phone number, mailing address, and Sponsoring Organization name. The coaching is provided through ASH Fitness’ affiliate, ASH Management. ASH Management records video and audio coaching sessions for quality assurance and training purposes. ASH Management shares individually identifiable participation information with ASH Fitness. The two affiliates may share your Identifiers and related Personal Information and Protected Class Information, excluding Sensitive Personal Information, to perform services such as to maintain and service your account, provide customer service, process transactions, and verify customer information. ASH Management does not share coaching records or information obtained in a coaching session with ASH Fitness. ASH Fitness may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes. ASH Fitness may also exchange individually identifiable information with your Sponsoring Organization as necessary to resolve customer service issues that you may have involving your program.
If you participate in FitnessCoach, ASH will collect your first and last name, date of birth, gender, e-mail address, phone number, mailing address, and Sponsoring Organization name. The coaching is provided through ASH Fitness’ affiliate, ASH Management. ASH Management records video and audio coaching sessions for quality assurance and training purposes. ASH Management shares individually identifiable participation information with ASH Fitness. The two affiliates may share your Identifiers and related Personal Information and Protected Class Information, excluding Sensitive Personal Information, to perform services such as to maintain and service your account, provide customer service, process transactions, and verify customer information. ASH Management does not share coaching records or information obtained in a coaching session with ASH Fitness. ASH Fitness may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes. ASH Fitness may also exchange individually identifiable information with your Sponsoring Organization as necessary to resolve customer service issues that you may have involving your program.
If you use the Connected! feature of the Silver&Fit Website, you allow ASH to record your activity related information, such as steps taken in a day, through the eligible enabled device (activity/fitness tracker device) you authorize for use with the feature. When you use the Connected! feature, your activity information will be transmitted from your device by your device manufacturer to a third-party data aggregator that we use. After receiving the information from the aggregator, we will upload the information into your member profile/account on SilverandFit.com. By using the Connected! feature, you also allow us to receive profile information from your device, if applicable, or from your own input, including gender, birth year, height, weight, and time zone. We will record your fitness center visit and exercise and your other independent activity information over time and will use such recorded information to verify and determine whether you are eligible for applicable incentives or rewards under the Silver&Fit program. Silver&Fit may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes. If you enter your gender, birth year, weight, and height into your device that is shared with your Connected! Profile, we may use this information to calculate and display your calorie metrics based on activity reported through your Connected!-enabled device. We may share the number of days in which you had activity with your Sponsoring Organization in order to manage your program.
If you choose to sync your Apple Watch with the ASHSync Mobile App, you allow ASH to receive your fitness device activity information for Apple Watch (e.g. steps, exercise duration, etc.). Your device sends information directly through the Mobile App to our activity aggregator Service Provider so that it may be added to your account. We will use this information to perform services related to recording your activity, tracking your progress over time, and processing rewards (if applicable). We may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes.
Surveys: A portion of members are randomly selected for participation in surveys, if you are selected, your name, email address, mailing address, DOB and gender will be forwarded to our Survey Service Provider for administration of the survey or used to process surveys conducted by ASH. If you receive a survey, your participation is optional. ASH may share non-individually identifiable aggregate survey results with your Sponsoring Organization, existing and potential clients, and the public.
Home Fitness Kits: If you select a Home Fitness Kit on the Silver&Fit website, we collect your name, date of birth, address, e-mail address, and home phone number during the website registration process. Additionally, you will provide your name, shipping address, email address, and phone number to the third-party Service Provider website to complete your Home Fitness Kit order. Information you enter on our Service Providers website may be subject to their Terms and Conditions. ASH will receive data from third party service providers to help administer your benefit. Your Home Fitness Kit selection will be shared with your Sponsoring Organization for billing and utilization reporting purposes.
If you register on the Silver&Fit website, the first time you log in you will have the option to complete the Workout Plans questionnaire about your fitness preferences and exercise level. Your participation is optional. If you choose to participate, ASH will use your information and responses to provide recommendations for Digital Workout Videos and home fitness kit option(s). If you choose to complete the questionnaire, we may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes. ASH may also share non-individually identifiable aggregate answers with existing and potential clients, and the public.
If you register on the Silver&Fit website, you can answer a few lifestyle and goal questions to connect with others, view articles and videos, and join live-streaming classes and events in the Well-Being Club. If you choose to participate, ASH will use your information and responses to understand your well-being goals and recommend healthy aging content. ASH will also provide you with options on how to interact with other members and/or your community. ASH may share information with your Sponsoring Organization and/or designated vendor for benefit administration, utilization reporting, and billing purposes. ASH may also share non-individually identifiable aggregate usage and response information with existing and potential clients, and the public.
If you register on the Silver&Fit website, you can participate in Virtual Events held on the third party Zoom platform. If you choose to participate, you will need to register an account with Zoom, and they will be receive your IP Address, Device ID, an ASH-assigned Client ID, and your email address. Your use of the third-party website to view virtual events is governed by the third party’s own Privacy Policy and Terms and Conditions. ASH may share information with your Sponsoring Organization, and/or designated vendor, and our service providers for benefit administration, utilization reporting, and billing purposes.
Payment: If you are required to pay a fee to ASH in connection with your use of the Silver&Fit program, ASH will use a third-party PCI DSS certified payment processor to collect and process your credit card information. Our systems store redacted credit card information (first six (6) and last four (4) of your credit card), according PCI data protection standards. Silver&Fit does not directly collect or process full credit card numbers or security codes.

Sharing with Third Parties

ASH may provide your PI to your Sponsoring Organization, or other entities that have contracted with your Sponsoring Organization to provide you with health-related services on behalf of your Sponsoring Organization. In certain limited situations, ASH may be required to provide your personal information to your Sponsoring Organization in order to perform billing, eligibility, and other administrative functions. In these situations, ASH ensures that there are security blocks in place so that personal information is only disclosed to those who perform the benefit administration process described above.

ASH may also share your information with third parties in the following circumstances:

With Service Providers: to provide services under the Program and to support the operation and maintenance of the Silver&Fit Website. We may also receive product purchased information and aggregate statistical information from Vendors who are linked to the Silver&Fit website for the purpose of program and product improvement. For example, if you make a purchase on a linked Vendor website for a product advertised on our Website, we may receive aggregate information on the product(s) purchased and website usage data. Silver&Fit will not receive your individual payment or purchase information from Vendors.
For legal purposes, including: as reasonably necessary to comply with law or legal process (including a court or government order or subpoena); to detect, prevent, or otherwise address fraud, security or technical issues; to enforce this Privacy Statement or the Terms and Conditions for the Silver&Fit program and the use of this Website; and as reasonably necessary to protect the rights, property or safety of ASH, ASH users, and/or the public.
During a corporate reorganization: If ASH is involved in a merger, acquisition, financing, or sale of business or assets, information collected from and about users may be transferred to one or more third parties involved in such transaction and, upon such transfer, the relevant third-party privacy policy or policies may govern further use of the information. In the event of such a change, ASH will endeavor to notify our users of the change as well as any choices our users may have regarding the change.

Updating and Retention of User Account Information

If you have an active account on the Silver&Fit Website, you can log into your account to view your account information. Members may update and correct their account information by submitting a written request to ASH through the contact information at the end of this Privacy Statement. Response to the request for amendment of your personal information will be issued within 30 days of receipt of the completed form. However, we may obtain one 30-day extension by sending the member a written notice stating the reason for the delay and the expected date of the response. We may deny the member’s amendment request under the following circumstances:

The PI, including plan eligibility and benefit information, is accurate and complete.
The request for amendment was made verbally.
The request does not state a reason for the amendment
We did not create the PI, unless the originator is not available to act on the request.

NOTE: Except as expressly otherwise stated in this Privacy Statement, and except where applicable law provides otherwise, PI collected on the Silver&Fit Website cannot be deleted or removed from ASH’s database and will be retained for a minimum of 10 years in accordance with ASH’s record retention policy. User accounts, however, may be disabled upon written request, using the contact information at the end of this Privacy Statement.

Opt-out of Communications received from Silver&Fit

If you have provided your email address, postal address, and/or telephone number to ASH, you may opt out of receiving marketing/promotional communications about affiliate programs that may be available to you from ASH by contacting ASH as described at the end of this Privacy Statement. To stop receiving marketing/promotional communications via email, you can also use the “unsubscribe” link contained in a marketing/promotional email you have previously received from ASH. Please note that email unsubscribe requests may not take effect immediately.

NOTE: Your opt-out regarding our marketing/promotional communications will not stop communications from ASH of a transactional nature or as required by law (e.g., communications regarding your account or a purchase, request or inquiry you have made with ASH, notices regarding material changes to the Silver&Fit Website or its information practices, notices regarding an actual or suspected security breach that affects your information stored by or for ASH, etc.).

Privacy of Minors

ASH is concerned about the safety of children when they use the Internet. The Silver&Fit Website may be used by eligible participants at least 13 years old. If ASH becomes aware that a user is under the age of 13 and has provided Personal Information to ASH without prior parental consent, ASH will remove all information provided by such underage user from its database.

Security of Personal Information

In order to maintain the confidentiality of and safeguard the security of users’ PI, ASH enforces strict company-wide policies regarding privacy, security, and confidentiality.

ASH has an organizational commitment to protecting privacy and security. All employees who work on the Silver&Fit Website are made aware of security policies and practices through employee orientation and annual refresher training. PI is secured in an isolated database with tightly restricted access. Employees authorized to view this information are authenticated prior to gaining such access. ASH reviews web security on an ongoing basis. In addition to daily security administration and response activities, the Silver&Fit Website undergoes a security assessment conducted by a security firm on a quarterly and annual basis.

The Silver&Fit Website uses Transport Layer Security (TLS) encryption to protect the security of online information. Users will see an unbroken key or a closed lock (depending on the browser used) near the website address when TLS is active and the website is secure. The website address will also contain "https" instead of "http". In addition, the website uses a third-party PCI DSS certified payment processor to collect and process your credit card information. Silver&Fit does not directly collect or maintain your credit card information.

Third-Party Links and Services

For your convenience, the Silver&Fit Website may provide links to third-party websites and online services not owned or controlled by or affiliated with ASH (each, a “Linked Third-Party Website/Service”). Linking does not mean, and should not be deemed or construed to mean, that ASH endorses or approves or is affiliated with a Linked Third-Party Website/Service. ASH is not responsible for the information privacy and security policies or practices of a Linked Third-Party Website/Service. When you leave the Silver&Fit Website to visit a Linked Third-Party Website/Service, this Privacy Statement no longer applies, and any information collected from or about you by a Linked Third-Party Website/Service will be governed by that site/service’s privacy policies and practices, which may be substantially different from those of ASH. A Linked Third-Party Website/Service may set or use its own cookies, web beacons, etc. to your computer or mobile device, and may collect information from and about you and use the information in ways that ASH would not. You access a Linked Third-Party Website/Service entirely at your own risk. You should always read the privacy policy associated with a Linked Third-Party Website/Service before disclosing any personal information.

For more on Links, please see the Terms and Conditions of this Website.

CALIFORNIA RESIDENTS: YOUR CALIFORNIA PRIVACY RIGHTS
Under California Civil Code Section 1798.83 (known as the “shine the light” law), California residents have a right to request an information-sharing disclosure from a business to which they have provided personal information and which has disclosed the information to any third party for third-party direct marketing uses in the prior calendar year.

ASH does not knowingly share your personal information with third parties for their direct marketing use without your permission. California residents may send requests for information-sharing disclosure under this law by emailing ASH at HIPAA@ashn.com. Please note that, under this law, we are not required to respond to your request more than once in a calendar year, nor are we required to respond to any requests that are not sent to the above-designated email address.

The California Consumer Privacy Act (CCPA) (California Civil Code 1798.100-199) provides California residents with specific rights related to the collection, use and disclosure of their personal information by us. While our privacy practices have adopted many of the CCPA requirements across our program, this section discusses specific rights and elements applicable to persons who are California residents at the time we collected, used or disclosed your personal information.

The CCPA and the details noted here do not apply to situations where your personal information is collected, used or disclosed by us:

Where in our capacity as a business associate of a covered entity, we collect or maintain your personal information in the same manner as protected health information in compliance with privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) and the Health Information Technology for Economic and Clinical Health Act (Public Law 111-5). This may apply when your access to our program is made available to you as part of a health benefit plan operated by a Sponsoring organization who is a covered entity under the laws noted immediately above.
Where your access to our program is made available to you through a sponsoring organization as part of the organizations’ policies or products subject to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations, or the California Financial Information Privacy Act (Division 1.4 (commencing with Section 4050) of the Financial Code)

Silver&Fit is only offered in conjunction with heath plan policies that are governed by the laws identified above therefore the CCPA does not apply to this product.

Additionally, should we receive CCPA-related requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we reserve the ability to either charge a reasonable fee for taking the action requested or refuse to act on the request. If we refuse your request on this basis we will notify you of the reason why.

COLORADO RESIDENTS: YOUR COLORADO PRIVACY RIGHTS

The Colorado Privacy Act (CPA) provides Colorado residents with specific rights related to the collection, use and disclosure of their personal information. While our privacy practices have adopted many of the CPA requirements across our program, this section discusses specific rights and elements applicable to persons who are Colorado residents at the time we collected, used or disclosed your personal information.

The CPA and the details noted here do not apply to situations where your personal information is collected, used or disclosed by us:

Where in our capacity as a business associate of a covered entity, we collect or maintain your personal information in the same manner as protected health information in compliance with privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) and the Health Information Technology for Economic and Clinical Health Act (Public Law 111-5). This may apply when your access to our program is made available to you as part of a health benefit plan operated by a Sponsoring organization who is a covered entity under the laws noted immediately above.
Where your access to our program is made available to you through a sponsoring organization as part of the organizations’ policies or products subject to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations.

Silver&Fit is only offered in conjunction with heath plan policies that are governed by the laws identified above therefore the CPA does not apply to this product.

Additionally, should we receive CPA-related requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we reserve the ability to either charge a reasonable fee for taking the action requested or refuse to act on the request. If we refuse your request on this basis we will notify you of the reason why.

CONNECTICUT RESIDENTS: YOUR CONNECTICUT PRIVACY RIGHTS

The Connecticut Data Privacy Act (CTDPA) provides Connecticut residents with specific rights related to the collection, use and disclosure of their personal information. While our privacy practices have adopted many of the CTDPA requirements across our program, this section discusses specific rights and elements applicable to persons who are Connecticut residents at the time we collected, used or disclosed your personal information.

The CTDPA and the details noted here do not apply to situations where your personal information is collected, used or disclosed by us:

Where in our capacity as a business associate of a covered entity, we collect or maintain your personal information in the same manner as protected health information in compliance with privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) and the Health Information Technology for Economic and Clinical Health Act (Public Law 111-5). This may apply when your access to our program is made available to you as part of a health benefit plan operated by a Sponsoring organization who is a covered entity under the laws noted immediately above.
Where your access to our program is made available to you through a sponsoring organization as part of the organizations’ policies or products subject to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations.

Silver&Fit is only offered in conjunction with heath plan policies that are governed by the laws identified above therefore the CTDPA does not apply to this product.

Additionally, should we receive CTDPA-related requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we reserve the ability to either charge a reasonable fee for taking the action requested or refuse to act on the request. If we refuse your request on this basis we will notify you of the reason why.

MONTANA RESIDENTS: YOUR MONTANA PRIVACY RIGHTS

The Montana Consumer Data Privacy Act (MTCDPA) provides Montana residents with specific rights related to the collection, use and disclosure of their personal information. While our privacy practices have adopted many of the MTCDPA requirements across our program, this section discusses specific rights and elements applicable to persons who are Montana residents at the time we collected, used or disclosed your personal information.

The MTCDPA and the details noted here do not apply to situations where your personal information is collected, used or disclosed by us:

Where in our capacity as a business associate of a covered entity, we collect or maintain your personal information in the same manner as protected health information in compliance with privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) and the Health Information Technology for Economic and Clinical Health Act (Public Law 111-5). This may apply when your access to our program is made available to you as part of a health benefit plan operated by a Sponsoring organization who is a covered entity under the laws noted immediately above.
Where your access to our program is made available to you through a sponsoring organization as part of the organizations’ policies or products subject to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations.

Silver&Fit is only offered in conjunction with heath plan policies that are governed by the laws identified above therefore the MTCDPA does not apply to this product.

Additionally, should we receive MTCDPA-related requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we reserve the ability to either charge a reasonable fee for taking the action requested or refuse to act on the request. If we refuse your request on this basis we will notify you of the reason why.

OREGON RESIDENTS: YOUR OREGON PRIVACY RIGHTS

The Oregon Consumer Privacy Act (OCPA) provides Oregon residents with specific rights related to the collection, use and disclosure of their personal information. While our privacy practices have adopted many of the OCPA requirements across our program, this section discusses specific rights and elements applicable to persons who are Oregon residents at the time we collected, used or disclosed your personal information.

The OCPA and the details noted here do not apply to situations where your personal information is collected, used or disclosed by us:

Where in our capacity as a business associate of a covered entity, we collect or maintain your personal information in the same manner as protected health information in compliance with privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) and the Health Information Technology for Economic and Clinical Health Act (Public Law 111-5). This may apply when your access to our program is made available to you as part of a health benefit plan operated by a Sponsoring organization who is a covered entity under the laws noted immediately above.
Where your access to our program is made available to you through a sponsoring organization as part of the organizations’ policies or products subject to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations.

Silver&Fit is only offered in conjunction with heath plan policies that are governed by the laws identified above therefore the OCPA does not apply to this product.

Additionally, should we receive OCPA-related requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we reserve the ability to either charge a reasonable fee for taking the action requested or refuse to act on the request. If we refuse your request on this basis we will notify you of the reason why.

TEXAS RESIDENTS: YOUR TEXAS PRIVACY RIGHTS

The Texas Data Privacy and Security Act (TXDPSA) provides Texas residents with specific rights related to the collection, use and disclosure of their personal information. While our privacy practices have adopted many of the TXDPSA requirements across our program, this section discusses specific rights and elements applicable to persons who are Texas residents at the time we collected, used or disclosed your personal information.

The TXDPSA and the details noted here do not apply to situations where your personal information is collected, used or disclosed by us:

Where in our capacity as a business associate of a covered entity, we collect or maintain your personal information in the same manner as protected health information in compliance with privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) and the Health Information Technology for Economic and Clinical Health Act (Public Law 111-5). This may apply when your access to our program is made available to you as part of a health benefit plan operated by a Sponsoring organization who is a covered entity under the laws noted immediately above.
Where your access to our program is made available to you through a sponsoring organization as part of the organizations’ policies or products subject to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations.

Silver&Fit is only offered in conjunction with heath plan policies that are governed by the laws identified above therefore the TXDPSA does not apply to this product.

Additionally, should we receive TXDPSA-related requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we reserve the ability to either charge a reasonable fee for taking the action requested or refuse to act on the request. If we refuse your request on this basis we will notify you of the reason why.

UTAH RESIDENTS: YOUR UTAH PRIVACY RIGHTS

The Utah Consumer Privacy Act (UCPA) provides Utah residents with specific rights related to the collection, use and disclosure of their personal information. While our privacy practices have adopted many of the UCPA requirements across our program, this section discusses specific rights and elements applicable to persons who are Utah residents at the time we collected, used or disclosed your personal information.

The UCPA and the details noted here do not apply to situations where your personal information is collected, used or disclosed by us:

Where in our capacity as a business associate of a covered entity, we collect or maintain your personal information in the same manner as protected health information in compliance with privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) and the Health Information Technology for Economic and Clinical Health Act (Public Law 111-5). This may apply when your access to our program is made available to you as part of a health benefit plan operated by a Sponsoring organization who is a covered entity under the laws noted immediately above.
Where your access to our program is made available to you through a sponsoring organization as part of the organizations’ policies or products subject to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations.

Silver&Fit is only offered in conjunction with heath plan policies that are governed by the laws identified above therefore the UCPA does not apply to this product.

Additionally, should we receive UCPA-related requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we reserve the ability to either charge a reasonable fee for taking the action requested or refuse to act on the request. If we refuse your request on this basis we will notify you of the reason why.

VIRGINIA RESIDENTS: YOUR VIRGINIA PRIVACY RIGHTS

The Virginia Consumer Data Privacy Act (VCDPA) provides Virginia residents with specific rights related to the collection, use and disclosure of their personal information. While our privacy practices have adopted many of the VCDPA requirements across our program, this section discusses specific rights and elements applicable to persons who are Virginia residents at the time we collected, used or disclosed your personal information.

The VCDPA and the details noted here do not apply to situations where your personal information is collected, used or disclosed by us:

Where in our capacity as a business associate of a covered entity, we collect or maintain your personal information in the same manner as protected health information in compliance with privacy, security, and breach notification rules issued by the United States Department of Health and Human Services, Parts 160 and 164 of Title 45 of the Code of Federal Regulations, established pursuant to the Health Insurance Portability and Accountability Act of 1996 (Public Law 104-191) and the Health Information Technology for Economic and Clinical Health Act (Public Law 111-5). This may apply when your access to our program is made available to you as part of a health benefit plan operated by a Sponsoring organization who is a covered entity under the laws noted immediately above.
Where your access to our program is made available to you through a sponsoring organization as part of the organizations’ policies or products subject to the federal Gramm-Leach-Bliley Act (Public Law 106-102), and implementing regulations.

Silver&Fit is only offered in conjunction with heath plan policies that are governed by the laws identified above therefore the VCDPA does not apply to this product.

Additionally, should we receive VCDPA-related requests that are manifestly unfounded or excessive, in particular because of their repetitive character, we reserve the ability to either charge a reasonable fee for taking the action requested or refuse to act on the request. If we refuse your request on this basis we will notify you of the reason why.

Program and Contact Information

Questions and requests may be submitted through the Contact Us page of the Silver&Fit Website, or using the following contact information:

U.S. Mail

Silver&Fit Customer Service
P.O. Box 509117
San Diego, CA 92150-9117

By Phone

1.877.427.4788 (TTY/TDD 711), 5 am to 6 pm Pacific Time, Monday through Friday (except for federal holidays).

E-mail

fitnessservice@ashn.com

We will endeavor to respond to your questions and requests within 10 business days from the date of receipt.

If you need assistance with or require this Privacy Statement in an alternative format, please contact us at 1(877) 427-4788.

Privacy and Security Contact Information

ASH has a designated Privacy Officer and an Information Security Officer to oversee our privacy and security programs. You may direct questions about these programs to these individuals by either calling (877) 427-4766 or emailing HIPAA@ashn.com.

Use of this Website is governed by the Silver&Fit Terms and Conditions.