Privacy Policy

Updated 2 March 2026

1. Identity and Scope

Ask Claire, a subsidiary of Wider Circle, Inc., adheres to the HHS OIG General Compliance Program Guidance (GCPG). This policy covers all “personal information” as defined by the CCPA and “Protected Health Information” (PHI) under HIPAA.

2. 2026 Lead Integrity (One-to-One Consent)

We do not share your data with other Third-Party Marketing Organizations (TPMOs) or “referral partners” without one-to-one consent. You must individually authorize each entity that receives your data; we do not utilize “blanket” authorizations.

3. Anti-Discrimination & Risk Adjustment

We collect data solely to provide “high-quality, cost-effective care”. We strictly prohibit using your information to “cherry-pick” healthy individuals or “steer” you based on health status.

4. Cookies and Tracking

To better serve you, the Company uses various technologies, which may include “cookie” technology, to gather information from our website visitors such as pages visited and how often they are visited, and to enable certain features on our website. “Cookies” are small text files that may be placed on your computer when you visit a website or click on a URL. Cookies may include “single-session cookies” which generally record information during only a single visit to a website and then are erased, and “persistent” cookies which are generally stored on a computer unless or until they are deleted or are set to expire. You may disable cookies and similar items by adjusting your browser preferences at any time; however, this may limit your ability to take advantage of all the features on this website. You may also manage the use of “flash” technologies, with the Flash management tools available at Adobe’s website. We may also allow third party service providers to use cookies and other technologies to collect information and to track browsing activity over time and across third party websites such as web browsers used to read our websites, which websites are referring traffic or linking to our websites, and to deliver targeted advertisements to you. We do not control these third-party technologies and their use is governed by the privacy policies of third parties using such technologies. For more information about third party advertising networks and similar entities that use these technologies, see http://www.aboutads.info/consumers, and to opt-out of such ad networks’ and services’ advertising practices, go to www.aboutads.info/choices. Once you click the link, you may choose to opt-out of such advertising from all participating advertising companies or only advertising provided by specific advertising companies. We may use analytics companies to gather information and aggregate data from our website visitors such as which pages are visited and how often they are visited, and to enable certain features on our websites. Information is captured using various technologies and may include cookies. If such technology is used, you may opt out of it by clicking on the “Opt Out” link at the bottom of the home web page.

5. Your California Privacy Rights

Effective January 1, 2020, the California Consumer Privacy Act (CCPA) allows California residents twice a year, upon a verifiable consumer request, to request that a business that collects consumers’ personal information to give consumers access, in a portable and (if technically feasible) readily usable form, to the specific pieces and categories of personal information that the business has collected about the consumer, the categories of sources for that information, the business or commercial purposes for collecting the information, and the categories of third parties with which the information was shared. California residents also have the right to submit a request for deletion of information under certain circumstances. Consistent with California law, if you choose to exercise your rights, we won’t charge you different prices or provide different quality of services unless those differences are related to your information. Send an email to community@askclaire.com to make a request. Please note that you must verify your identity and request before further action is taken. As a part of this process, government identification may be required. Consistent with California law, you may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government issued identification, and the authorized agent’s valid government issued identification. We endeavor to respond to a verifiable consumer request within 45 days of its receipt. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not sell personal information to third parties. We do allow third parties to collect personal information through our Services and share personal information with third parties for the business purposes described in this Privacy Policy, including without limitation advertising and marketing on our Service and elsewhere based on users’ online activities over time and across different sites, services, and devices.

6. Information for Children Under 13

We will not intentionally collect any personal information from children under the age of 13 through the Services without receiving parental consent. If you think that we have collected personal information from a child under the age of 13 through the Services please contact us.

7. Automated Systems and AI Governance

Ask Claire may utilize artificial intelligence (AI) and other automated mechanisms to enhance operational efficiency and accuracy. In accordance with the 2026 Medicare Advantage Industry Segment-Specific Compliance Program Guidance (ICPG), we classify these systems as patient care decision support tools.

To ensure the integrity of our enrollment and coordination services, we adhere to the following governance standards:

Individualized Clinical Circumstances: We ensure that all decisions regarding plan suitability and beneficiary recommendations focus on your individualized medical history, physician recommendations, and clinical records rather than relying solely on broad predictive data sets or algorithms.
Human-in-the-Loop Oversight: All automated tools are subject to regular human review by our Compliance and Clinical teams to prevent algorithmic bias and ensure determinations remain “accurate, complete, and truthful”.
Prohibition of Algorithmic Steering: We strictly prohibit the use of AI to “cherry-pick” healthy enrollees or “lemon-drop” high-cost individuals to maximize risk-adjusted payments.
Utilization Management Safeguards: If automated tools are used to assist in eligibility or coverage discussions, they are audited to ensure they do not inappropriately restrict access to medically necessary covered services.

8. Substance Use Disorder (SUD) Records

In alignment with the February 2026 HIPAA Privacy Rule updates, Ask Claire provides heightened protection for records protected under 42 CFR Part 2. These records will not be used or disclosed in legal proceedings without your specific written consent or a court order, even for treatment, payment, and health care operations purposes.

9. Substance Use Disorder (SUD) Redisclosure

We also notify you that any PHI disclosed may be subject to redisclosure by the recipient and may no longer be protected by the HIPAA Privacy Rule.

10. Contact Us

To contact us regarding this policy and our related privacy practices, contact us at: community@askclaire.com. If you believe we or any company associated with us has misused any of your information, please contact us immediately and report such misuse.

11. Effective Date

The effective date of this policy is 2 March 2026.

12. Changes to this Privacy Policy

We may change this policy. If we do so, such change will appear on this page of our website. We will also provide appropriate notice and choices to you, on this website and in other appropriate locations, based on the scope and extent of changes. You may always visit this policy to learn of any updates.