Legal and Privacy

eternalHealth is committed to the highest standards of business ethics and integrity as well as strict observance and compliance with the laws and regulations governing its business operations.

woman walking down street

Our Code of Conduct provides comprehensive guidelines to help us sustain the highest possible standards of ethical behavior in our work. It serves as a cornerstone for our commitment to integrity, accountability, and professionalism. By adhering to these principles, we ensure that our actions reflect our core values and foster a culture of trust and respect.

Download Code of Conduct 

Notice of Non-Discrimination: Discrimination is Against the Law

eternalHealth complies with applicable Federal civil rights laws and does not discriminate based on race, color, national origin, age, disability, religion, or sex.  eternalHealth does not exclude people or treat them differently because of race, color, national origin, age, disability, religion, or sex.

eternalHealth:

  • Provides free aids and services to people with disabilities to communicate effectively with us, such as:
    • Qualified sign language interpreters
    • Written information in other formats (large print, audio, accessible electronic formats, other formats)
  • Provides free language services to people whose primary language is not English, such as:
    • Qualified interpreters
    • Information written in other languages.

If you need these services, contact eternalHealth Member Services at 1 (800) 680-4568 (TTY 711).

If you believe that eternalHealth has failed to provide these services or discriminated in another way on the basis of race, color, national origin, age, disability, or sex, you can file a grievance with:

eternalHealth (Mail)

eternalHealth, Inc.
eH Privacy Officer
C/O Appeals & Grievances
PO Box 1377
Westborough, MA 01581

eternalHealth (Phone/Fax)
Local Phone Number: 617-684-2348 (TTY 711)
Toll Free Phone Number: 1-800-680-4568 (TTY 711)
Fax: 1-866-326-1073

eternalHealth (In Person)
eternalHealth, Inc.
31 St. James Ave, Suite 950
Boston, MA 02116

You can file a grievance in person, by mail or fax. eternalHealth Member Services is available to help you.You can also file a civil rights complaint with the U.S. Department of Health and Human Services, Office for Civil Rights, electronically through the Office for Civil Rights Complaint Portal, available at https://ocrportal.hhs.gov/ocr/portal/lobby.jsf, or by mail or phone at:

U.S. Department of Health and Human Services

200 Independence Avenue
SW Room 509F, HHH Building
Washington, D.C. 20201

Phone: 1-800-368-1019800-537-7697 (TDD)

Complaint forms are available at https://www.hhs.gov/sites/default/files/ocr-cr-complaint-form-package.pdf

You deserve a Medicare Advantage Plan that you can count on. eternalHealth is committed to making healthcare accessible, affordable, and effective for our members while maintaining Medicare program integrity.

The eternalHealth Compliance Program

eternalHealth has a comprehensive compliance program designed for the prevention, detection and reporting of fraud, waste, and abuse among providers, members, employees, and subcontractors. Any questions, issues or concerns regarding the eternalHealth’s Code of Conduct, Policies & Procedures, or any federal or state laws, regulations, guidelines or other authorities governing our operations can be sent to our Compliance Department compliance@eternalhealth.com. The eternalHealth Code of Conduct and Compliance Program Policies & Procedures are available upon request.

Conflict of Interest

eternalHealth directors, officers and employees are responsible for disclosing any transaction or relationship that could reasonably be expected to give rise to a conflict of interest to Human Resources, the Chief Compliance Officer, Chief Executive Officer, or the Board of Directors. eternalHealth determines whether such transaction or relationship constitutes a conflict of interest.

Reporting a Concern to eternalHealth

Compliance concerns can be reported without fear of retribution or retaliation. Reports may be made orally, by telephone, in person, in writing, or by email. Reports may be made anonymously and will be held in the strictest of confidence except as may be necessary to complete an investigation or required enforcement action. eternalHealth investigates all reports and take such remedial and/or disciplinary action deemed appropriate upon completion of an investigation.

eternalHealth’s confidential compliance & ethics hotline is accessible 24/7 by calling 1-833-823-8603 or eternalHealth.navexone.com. The eternalHealth reporting hotline is administered by an independent third-party vendor. All allegations received are thoroughly investigated by eternalHealth.

Report A Compliance Concern to Oversight Agencies

External resources are available for reporting, and include but are not limited to the following:

Non-Retaliation

eternalHealth does not tolerate retaliation for reports of possible violations made in good faith, using any of the procedures described. Any reports of such retaliation or retribution will be investigated thoroughly and appropriate discipline will be imposed.

What is covered by this Privacy Policy?

This eternalHealth Privacy Policy (the “Policy”) describes how we collect and use personal information about you when you visit our website or use our products and services.

In this Policy, “we” and “our” mean eternalHealth, and “you” means any person who visits our website or uses our products and services.

By “personal information”, we mean information that directly identifies you, such as your name, address, phone number (including mobile phone number), or email address.

This portion of the Policy deals with how eternalHealth collects, uses, shares, and protects this personal information. View our Notice of Privacy Practices to learn more about how eternalHealth collects, uses, shares, and protects information collected from you.

Your Personal Information

eternalHealth protects your personal information

Protecting data and your information is a top priority for us. Additionally, we utilize industry best practices to make commercially reasonable efforts to ensure the security of your personal information. We have implemented organizational and technical safeguards designed to protect personal information within our organization from unauthorized access, destruction, alteration or misuse, loss, consistent with applicable regulatory requirements and applicable published security standards. This includes measures designed to ensure that personal information is only accessible to a limited number of personnel who must access the information to perform their duties, and that those personnel are required to keep the information confidential.

The safety and security of your information also depends on you. We encourage you to take steps to protect the confidentiality of your account and personal information, including by doing the following:

  • Reviewing all personal online accounts periodically and immediately reporting any suspicious activity;
  • Installing the latest security updates and anti-virus software on your devices to help prevent malware and viruses;
  • Using strong passwords;
  • Not using the same password for multiples websites / applications;
  • Using two factor authentication where applicable;
  • Not sharing your password with others;
  • Password protecting your computer and devices; and
  • Signing out / Logging off of website sessions, especially when using a public computer.

Text messaging is not an encrypted (secure) channel. If you text Protected Health Information (PHI) there is a risk that PHI could be intercepted or viewed by third parties, including others who access your device.

Our use and disclosure of PHI in text messaging may be governed by additional privacy protections. Please see our Notice of Privacy Practices for additional information.

Information transmitted through the internet may not be entirely secure. For this reason, we cannot guarantee the security of your personal information and we are not responsible for the circumvention of any privacy or security measures on our website unless otherwise required by law. In the event of a data breach, we will notify you as required under applicable law.

How eternalHealth uses your information

We use the information that we collect to conduct our business and to improve your experience with our products and services. To do so, we also may combine any or all of the information that we collect or obtain. Examples of how we use information include:

  • To provide you with products and services, such as to: share services that are relevant to your needs; deliver content that you may find interesting or helpful; and process, maintain, and service your account;
  • To respond to you, such as when you send us an inquiry via text message; fill out a form to be contacted; make a request or an inquiry; wish to set up an appointment with a sales representative; request materials in the mail, or share a comment or concern;
  • To personalize your experience with us, including to: remember your interests and preferences; customize the product, services, and content we share with you; facilitate your interactions with our sales and customer service representatives; track and categorize your activity and interests on our website, including by identifying the different devices you use; and to enhance your experience with our products, services, and website;
  • For advertising and marketing, such as to: send you marketing and advertising communications; to customize the marketing and advertising that we show you; and to identify others like you who may be interested in similar products and services;
  • For analytics, such as to: understand how you use our website; understand how you shop for and interact with our products and services; and improve our website;
  • For business purposes, such as: to operate and improve upon our business and lawful business activities; to maintain our programs, accounts, and records; for research; to send communications about changes to our website and our products and services; to determine your satisfaction with our products and services; fraud monitoring and prevention;
  • For legal and safety purposes, such as to: defend our members from harm or in legal proceedings; protect the security of our members, employees, property, and our rights; respond to court orders, lawsuits, subpoenas, and government requests; address legal and regulatory compliance; and notify you of any critical issues; and
  • To fulfill any other purpose for which you provide it and any other purpose with your consent, for which we will inform you of the purpose for which we collect it or seek your consent as necessary.

Information collected

To improve your experience when using our website, plan, services, or products, we collect various types of information. Examples include:

  • Contact information, such as your name, address, phone number, or email address. Examples include when you subscribe to a newsletter, fill out a form, or enter information on our website;
  • Preference information, such as your contact preferences and plan or product interests;
  • Profile and account information, which may include Preference and Contact information;
  • Demographic information, which may include age or birth date, gender, ZIP code, and other information about you;
  • Call recordings, including information about your call and that you share when you call us on the phone;
  • Location information of your device that you use when interacting with our website or calling us, if your device settings allow us to collect location information; and
  • Device and browsing information, including information about your phone, tablet, computer, or other device, and online browsing activity (collectively, “automatically collected information”).

The ways we collect your information

As general practice, we always collect the least amount of data necessary to provide our services. We collect information on our website, during calls with you, and through our in-person interactions. We also obtain information from you and from third parties. For example, we collect and obtain information:

  • You provide, such as when you submit an online form, interact with a broker or customer service representative, contact us, respond to a survey, register to attend an event or appointment, or sign up for emails or mailings;
  • At events you attend, such as: the types of information noted above that you provide, and video recordings and photographs that we collect for security, fraud, loss prevention, incident reporting, and operational purposes;
  • From mobile devices, such information about your device when you access our website; and information about your device and location that you have consented to share through use of your device or browser, even if you are not currently on our website or on the phone with us;
  • From third parties, such as service providers that we use, data analytics companies, advertising networks, third parties that provide us with information about you and the different devices you use online, and other third parties that we choose to collaborate or work with;
  • From social media platforms and networks that you use in connection with our website, or that share or allow you to share information with us, such as Facebook, Instagram, and Twitter. For example, if you use functionalities, plugins, or tools from social media platforms or networks in connection with our website (e.g., to log into an account, or to share content with your social media followers), we may collect the information that you share with us, or that those social media platforms or networks share with us; and
  • Using cookies and automatic collection methods. For example, we and third parties we work with may collect information from the computer, tablet, phone, or other device: that you use to access our website; or that you use to open an email or click on an advertisement from us. This collection includes automatically collected information, and generally does not include personal information unless you provide it through our website or you choose to share it with us.

How we share information

We will never sell your personal information. Additionally, we will never share personal information about you with third parties for their marketing or advertising purposes without your explicit consent. We do, however, share personal information with third parties for other operational purposes. For example, we share personal information with:

  • Third parties and service providers that provide products or services to our members and us, as well as those that help us market or advertise to you on our behalf. These organizations are under contractual obligations to use your personal information only for providing the services to us and to maintain this information as strictly confidential;
  • Social media platforms and networks such as Facebook, Twitter, and Instagram that offer functionalities, plugins, widgets, or tools in connection with our website (e.g., to log into an account or to share content with your followers on social media). If you choose to use these functionalities, plugins, widgets, or tools, certain information may be shared with or collected by those social media companies—for more information about the information shared or collected, and how it is used, see the applicable social media company’s privacy policy;
  • To a buyer or other successor in interest in the event of 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 website’s and products’ users are among the assets transferred;
  • For other purposes related to the reasons for which you provide your information. For example, when you sign up for one of our Medicare Advantage plans, we may share your information with Medicare to verify your eligibility and for them to cover all or part of the premiums for our plans; and
  • Additional third parties such as law enforcement, government entities, courts, or other third parties as required or allowed by applicable law, such as for the legal and safety purposes described under the “How eternalHealth uses your information” Section above, or otherwise to help prevent harm or fraud to you, our customers, other third parties, or to eternalHealth. We also may share personal information with third parties upon your request or with your approval, though we may not be able to accommodate all requests.

Notices and Disclosures

  • Information from Children and Children’s Privacy. eternalHealth does not knowingly request or collect personal information from any person under 13 years of age. If you believe that your child under the age of 13 has submitted personal information to eternalHealth in connection with our website, and without prior verifiable parental consent, please contact us at compliance@eternalhealth.com so that we can take steps to delete the personal information that they provided.

Your rights and choices regarding personal information

We strive to offer you choices about how personal information is used and shared. Your choices include:

  • Direct Mail Choices. You may opt out of receiving marketing or advertising by direct mail if you contact us as indicated below under “Additional Information and Contacting Us”, and share the name and mailing address that you would like to opt out. Requests take up to 8-10 weeks to become effective.
  • Online Advertising. You can manage third party advertising preferences for some of the third parties we work with to serve advertising across the internet. Some of these third parties allow you to opt out of cookies and interest-based advertising through the Network Advertising Initiative (https://optout.networkadvertising.org/?c=1) and Digital Advertising Alliance (https://www.aboutads.info/choices/). We cannot guarantee that all the third parties we work with will honor the elections you make using those options, but we strive to work with third parties that do.
  • Social Media Platforms and Networks. We encourage you to review your privacy options and settings with the social media platforms and networks you use to understand what choices you have about sharing information from those platforms and networks with us.
  • Email Choices. You can opt out of marketing or advertising emails by utilizing the “unsubscribe” link or mechanism noted in marketing or advertising emails you receive from eternalHealth. You may also request to opt out of marketing or advertising emails by contacting us through one of the methods specified in the “How to Contact Us” Section below, and sharing the email address at which you are receiving marketing or advertising emails.
  • Mobile Location Choices. You may choose not to provide your location to us by customizing your mobile device settings to prevent sharing of location information.

Updating Your Information

You may contact us through one of the methods in the “How to Contact Us” section below to inform us of changes or errors in any personal information we have about you to ensure that it is complete, accurate, and as current as possible. We may require you to verify your identity before we provide you with any personal information about you or permit you to change it. We reserve the right to limit or deny your request if you have failed to provide sufficient information to verify your identity or to satisfy our legal and business requirements. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause your personal information to become incorrect.

Do Not Track Signals and Related Mechanisms

We may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (this is often referred to as behavioral tracking). Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers integrate and activate this feature, it’s not always clear whether users intend for these signals to be transmitted, or whether they are even aware of their presence. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received.

How to Contact Us

If there are any questions regarding this privacy policy, you may contact us using the information below:
eternalHealth Privacy Officer
eternalHealth
31 St James Ave, Suite 950
Boston, MA 02116

Phone: 1-(888) 712-4150 (TTY 711)
Email: compliance@eternalhealth.com

To inform us of changes or errors in any personal information we have about you, you may contact us using the information below:

Phone: +1 (800) 680-4568 (TTY 711)
Oct 1 – Mar 31, 8am – 8pm, 7 days a weel
Apr 1 – Sep 31, 8am – 8pm, Monday – Friday
10am – 2pm, Saturday

Updates to This Policy

Future Changes to this Policy

We may make changes to this Policy, and may apply any changes to information previously collected, as permitted by law. When we make material changes to this Policy, we will post the updated Policy on our website, and we will update the effective date at the end of this Policy.

Effective date: This Policy is effective October 12th 2021.

Terms of Use

Please read the following items. They describe the terms governing your use of the eternalHealth (“Our”) website as well as important information concerning privacy, security, and links to other sites. When you (“You” or “User”) access Our website or conduct any transaction on Our websites, You are agreeing to accept the following Terms of Use and all privacy and security policies.

User’s Responsibilities and Obligations. You agree that You have the legal right and ability to agree to these Terms of Use and that You will use Our website in a manner consistent with these Terms of Use. If You use the password-protected sections of Our website, You understand that your password is intended to protect your privacy and should be kept confidential. You are solely responsible for your use of Our website as well as for the access and use of information relating to You by anyone whom You authorize to access that information or to whom You disclose your password or other information designed to protect your privacy.

Unauthorized Use/Misuse. Unauthorized entry (known as hacking) into any portion of Our website, or misuse (for fraudulent, malicious and/or deceptive purposes) may constitute crimes or torts under state or federal law. Any such violations will be pursued and prosecuted to the fullest extent permitted by law.

No Medical Advice. The health-related information and resources on Our website are made available to you solely for informational purposes. They do not constitute medical advice and are not intended to be a substitute for professional medical care. Nothing on Our site is intended to be used for medical diagnosis or treatment. Always seek the advice of your health care provider before beginning any new treatment or if You have any questions regarding a medical condition. If You are ill or need immediate medical care, please contact your health care provider or, in an emergency, call 911 or go to the nearest medical facility.

Disclaimer. eternalHealth will attempt to keep the information available through our website current and accurate, but make no guarantees and disclaim any implied warranty or representation about its accuracy, relevance, timeliness, completeness, or appropriateness for a particular purpose. Information on this website may be updated at any time and without notice.

Copyright and Trademark. All materials on this website, including the site’s design, layout, and organization, are owned by eternalHealth, and may be protected by U.S. and international copyrights.

Only personal use of such materials is permitted, which means that you may access, download, or print such materials for your personal, non-commercial use only. You agree not to change or delete any copyright or proprietary notice from materials downloaded from this site.

Links to Third Party Websites. Our website may provide links to other websites (“Third Party Websites”) that are not owned or controlled by us in order to connect you to additional sources of health information or third-party services that may be of interest to you. If these websites are not Vendor Websites (see below), a link to such a site is offered only as a convenience to you. We do not have any business relationship with the party that controls this type of Third Party Website. In each such instance we will let you know when you are leaving our website and going to a Third Party Website or accessing third-party services. We are not responsible for the content, security or the privacy practices of these types of Third Party Websites. Please review the privacy statement and any terms of use of each Third Party Website you visit. Unless we specifically advise you otherwise, links to Third Party Websites that are not Vendor Websites do not constitute or imply endorsement by us of the information they contain or any products or services they describe.

Links to Vendor Websites. We may also provide links to websites managed by companies with which we contract to provide you services (“Vendor Websites”). These Vendor Websites may be co-branded, but they are owned and controlled by the Third Party. Please review the privacy statement and any terms of use of each Vendor Website you visit.

Changes and Updates. These Terms of Use may change from time to time and changes will be posted here so that you will always be aware of our Terms of Use. By using or accessing Our website after changes have been made to these Terms of Use, you are agreeing to accept these changes.

SMS Text Messaging. By voluntarily providing your phone number to eternalHealth, you consent to receiving SMS (Text) messages from us. These messages may include one time, periodic, or recurring texts. We may send these messages directly, or use automated technology. Message frequency will vary.

While providing your phone number is not mandatory as part of your enrollment, if you do choose to enroll in a program, product, or service that involves periodic or recurring SMS (text) messages, you can opt out at any yime. Simply text “STOP” to unsubscribe. Upon receiving your STOP message, we’ll confirm you unsubscription.

Page Last Updated On: September 30, 2024
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Tom Cunniffe

Tom Cunniffe

Director of Operations 

Tom Cunniffe comes to eternalHealth with over 20 years of healthcare operations’ experience, having held leadership positions in Call Center, Enrollment, Credentialing, UAT and Reimbursement teams. Tom has worked with Medicaid, Commercial and Medicare lines of business and has consistently built teams who are metrics driven with proven successful outcomes. Making sure our business strives for an efficient, best-in-class customer experience is at the center of Tom’s philosophy.

Tom has a bachelor’s degree from Fordham University and a master’s in business administration from University of Massachusetts at Amherst.

Tom Lawless

Tom Lawless

Chief Financial Officer

Tom Lawless has spent the past 20+ years building, sustaining, and growing new healthcare-related programs that balance fiscal responsibility & prudence with creativity & innovation, focusing on models of care that are novel, person-centered, and improve the social welfare of those who are served. He is very excited to continue doing so in his role as the Chief Financial Officer of eternalHealth.

Tom comes to eternalHealth from a not-for-profit, member-centric, health insurance cooperative. He helped the company continuously strive toward its dual goals of thriving financially, while keeping members at the very epicenter of its mission and service model. While there, Tom also spearheaded the creation of a brand new private, charitable foundation, which will be meaningfully giving back to those in need in the surrounding communities for years to come. Previously, Tom worked in the finance department of a successful hospice that provided high-quality care to persons experiencing their unique and poignant end-of-life journeys, assuring that the appropriate financing was always available. Tom’s career began as a civil servant in the Wisconsin Medicaid program, where he helped to create a program that expanded the institutional entitlement to care into home and community-based settings. Starting with only a blueprint in hand, the program now serves more than 57,000 frail elders and disabled adults and is considered a national model. Growing into a senior leadership role, Tom was a key architect of an innovative financing model, through which the public and private sectors successfully collaborated to better the lives of persons in great need.

Tom holds undergraduate and graduate degrees from the University of Chicago, with additional graduate work in economics completed at the University Wisconsin-Madison.

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