GINA/PHI Notice
Last updated: March 12, 2026
The Personify Health Program is a voluntary wellbeing program which may include health screenings, health assessments, coaching, and other clinical services. We administer the Program according to federal rules permitting employer-sponsored wellness programs that seek to improve employee health or prevent disease, including the Americans with Disabilities Act of 1990 (the “ADA”), the Genetic Information Nondiscrimination Act of 2008 (“GINA”), and the Health Insurance Portability and Accountability Act (“HIPAA”) as applicable, among others (collectively, the “Federal Rules”). Which laws apply to your workplace wellness program depends on your program sponsor’s program design.
This notice pertains to your right to the privacy of your Protected Health Information (PHI) and relates to participation in the Personify Health Program.
Our Program is administered according to Federal Rules, which allow organizations, such as employers, to sponsor wellbeing programs that seek to improve health or prevent disease. Your eligibility or enrollment in your employer health plan and payment or reimbursement for healthcare services will not be based on your participation in the Program.
What is Protected Health Information (“PHI”)?
PHI is a special category of personal information defined and protected by HIPAA. PHI includes individually identifiable information, like your name, combined with medical or health insurance-related information that is collected or maintained on behalf of your health insurance provider or your medical provider.
How Is my PHI Collected, Used or Disclosed?
Your PHI will be collected, used, and disclosed as you share it through your participation in the Program and the services and features that may be available to you including, but not limited to:
Health Screening. The results of health screenings from your health provider, an onsite provider or other community access vendors can be made available through the Program. Your results may be used to direct you to tools that can help you meet your health goals or to help you understand your current health conditions and potential risks. Your results may also be used to introduce other features of the Program to you and, if applicable, services under your program sponsor’s health plan. You are encouraged to share your results or concerns with your own doctor.
Health Assessment. Our health assessments ask questions about your health history, such as your health numbers, lifestyle, and diagnosed conditions. Your responses may be used to direct you to health and wellbeing tools that can help you meet your health goals or to help you manage current health conditions and potential risks. Your responses may also be used to introduce other features of the Program to you and, if applicable, services under your program sponsor’s health plan. You are encouraged to share your results or concerns with your own doctor.
Phone and Onsite Services. Through services like health coaching and next steps consults, our coaches and guides will ask questions about your health and wellbeing status, including your health numbers, lifestyle, diagnosed conditions, and medications. Your information may be used to help you set and achieve your health and wellbeing goals or to help you understand your current health and potential risks. Your information may also be used to introduce other features of the Program to you and, if applicable, services under your program sponsor’s health plan.
You should never disregard professional medical advice or delay seeking it because of something you have read or heard in or on the Program.
How Is my PHI Protected?
Your PHI, including health screening results, health assessment responses, and coaching notes, will not be obtained by your program sponsor except as described in this notice and will not be used by your program sponsor for any employment-related purposes. Your PHI will not be sold, exchanged, transferred, or otherwise disclosed to third parties for commercial purposes.
Your PHI will not be disclosed except as permitted by this notice, our Privacy Notice, or to the extent permitted by law. You will not be asked or required to waive the confidentiality of your PHI as a condition of participating in the Program or receiving an incentive. You may not be discriminated against in employment because of the PHI you provide as part of participating in the wellbeing program, nor may you be subjected to retaliation if you choose not to participate.
We will only share your PHI with entities that have a legal right to access it, that are obligated to protect it in similar ways that we are obligated to protect it, and that assist in providing the Program or other health benefits to you. Although we and your program sponsor may use collected aggregate information to design programs based on identified health risks, the PHI you provide in connection with the Program will not be provided to your program sponsor except as permitted by law. For more information, please read our Privacy Notice.
Can I Choose Not to Participate?
Yes. You are not required to participate in the Program or share your PHI with us.
However, you may have been offered an incentive to participate in all or some of the Program, and only Members who participate in the Program can qualify to receive that incentive.
What If I Cannot Participate for Medical or Health Reasons?
If you are unable to participate in any of the health-related activities or achieve any of the health outcomes required to earn an incentive, you may be entitled to a reasonable accommodation or an alternative standard. You may request a reasonable accommodation or an alternative standard by contacting your program sponsor.
How can I Contact Personify Health?
If you have general questions about your Program, you can contact Member Services by calling 1-888-671-9395 (in the US) or by sending an email to [email protected].
If you have any questions, comments or concerns about this Notice, or your rights and obligations under this Notice, you may contact us via email at [email protected] or via the “Contact Us” section of the Personify Health web-based platform and mobile application.
Alternatively, you can contact us by writing to:
Personify Health, Inc.
Attn: Privacy Officer
Suite 1057591
N. Ingram Ave
Fresno, CA 93711-5839
USA