Privacy Policy

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 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 ( and Digital Advertising Alliance ( 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
31 St James Ave, Suite 950
Boston, MA 02116

Phone: 1-(888) 712-4150 (TTY 711)

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.

Page Last Updated On: March 31, 2023
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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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