[Last Updated: 9/5/2024]

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Welcome to the myWIC MOSAIC mobile application (“the App” or “the myWIC App”) or web portal (collectively, “the Services”). The Services are operated by Vexcel Corporation (“Vexcel”), a Microsoft company, and a provider of secure, integrated, intelligent management information systems for the Women, Infants, and Children program (“the WIC Program”) for several state governments and tribal organizations. Vexcel is operating in the capacity of a data processor by supporting the myWIC app in its collection of information for use by entities administering benefits under the WIC Program.

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Background

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This Privacy Policy establishes the terms and conditions that apply to Vexcel’s handling of the personal data that is collected through the myWIC App on behalf of its customers, the “WIC Agencies,” from “Users” of the Service. “WIC Agencies” are entities, including state governments and tribal organizations, that have entered into contracts with Vexcel for the provision the MOSAIC Management Information System, the Services, and other software tools for the WIC Program (“Service Agreement”). “Users” are individuals who seek to obtain WIC Program services from WIC Agencies and who download and use the App on smart phones or tablets (“device(s)”) or use the Services. As the data processor, Vexcel processes information of Users obtained through the Services on behalf of the WIC Agencies who control how the information is used, shared and disclosed (as the data controllers). 

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This Privacy Policy describes only how Vexcel handles the personal data that is collected from Users of the Services on behalf of the WIC Agencies, as well as any personal data that Vexcel may be given access to while acting on behalf of the WIC Agencies, to the extent that the WIC Agencies permit Vexcel to access personal data for which the WIC Agencies are responsible. This Privacy Policy does not apply to other information that Vexcel may collect through other means, including its website, and this Privacy Policy does not describe how the WIC Agencies will use, disclose or share such data. Please note that the privacy policy of the WIC Agency administering benefits in your jurisdiction governs the way your information may be used or shared by that WIC Agency.  Contact your WIC Agency for more information.  Helpful links may be found HERE.

 

What the Services Do

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The Services allow Users to enroll, recertify enrollment, view benefits, and schedule appointments, associated with the WIC Program. The Services are provided to support WIC Program communications by, between, among, and with the WIC Agency and the User. The WIC Agency, through Vexcel and the Services, collects the information that it needs to provide WIC Program services to Users. Except as described in this Privacy Policy, Vexcel does not collect, use, disclose or share information that the Users provide through the Services or information that the WIC Agencies communicate using the Services for purposes other than those required by the Service Agreements with the WIC Agencies and as outlined in this Privacy Policy.

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Personal Data Collected by the Services

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The Services may collect the following information from Users:

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• WIC Program eligibility and participation information: the User’s name, telephone number, email address, the name(s) of dependents, user ID and password, state-issued identification information, proof of income, adjunct eligibility program information, proof of residency, proof of identity, health history, and payment card and financial account information including electronic benefit transfer (“EBT”) information.

• Device information: the type of device on which the App is downloaded, operating system name and version, device manufacturer, application version, device ID, IP address, and geolocation data.

• Log file information: log files that record each time a device accesses Vexcel servers, and information about the device.

• Usage information: data about User interactions, use and experience with the Services.

 

Location Permissions

 

To enable certain features of the Services (for example, assisting a User in finding nearby WIC-friendly retailers) the Services may need to access a User’s device geolocation data. The Services only collect and use geolocation data for this purpose with the User’s consent.

 

How Vexcel Uses Personal Data

 

Vexcel uses the data collected by the Services to provide Users with a rich, interactive experience.  In particular, Vexcel uses data to:

• Provide the Services, which includes updating, securing, and troubleshooting, as well as providing support.  It also includes sharing data, when necessary, to provide the Service or carry out the actions Users initiate, including eligibility for and participation in the WIC Program.

• Send and receive User electronic communications about the Services.

• Perform data analysis, audit, fraud monitoring and prevention.

• Compile data about User interactions, use and experience with the Services in an aggregated format for research purposes, assessing the effectiveness of the Services, and improving the user experience.

• Perform any other functions that Vexcel believe in good faith are necessary to protect the security or proper functioning of the Services and to prevent fraud and unauthorized use.

 

Reasons Vexcel May Share Personal Data

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Vexcel will not disclose a User’s information to third parties without giving the User and the WIC Agency prior notice, except as stated in this Privacy Policy.

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Unless otherwise agreed to between the WIC Agency and Vexcel, all data collected by the Services or communicated using the Services belongs to the WIC Agency. Vexcel may, upon a WIC Agency’s request, provide the WIC Agency with access to all data or information created, received, sent, stored, or otherwise processed by Users who have installed the App on their device or used the Services.

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Vexcel shares data with Microsoft-controlled affiliates and with vendors working on Vexcel’s behalf for the Services.  All such third parties are only permitted to use the data to support Vexcel and the WIC Agency’s business activities and may not use, sell, or otherwise share the data for marketing or purposes other than as stated in this Privacy Policy.

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Vexcel shares data when required by law or to respond to legal process; to protect the WIC Agencies; to maintain the security of the Services; and to protect the rights and property of Vexcel and the WIC Agencies. 

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As the Result of a Business Transition  

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Vexcel may disclose information about the WIC Agencies to a third party in the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any of its business, assets, or stock, including in connection with bankruptcy or similar proceedings.

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Sharing Aggregate, Anonymized, Deidentified, or Otherwise Non-Personal Data

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Vexcel may share personal data that has been aggregated, deidentified, or otherwise anonymized and thus does not directly or indirectly identify Users and that cannot, with reasonable efforts, resources, and technologies, be used to reidentify any individual User.  Such aggregated, anonymized, deidentified, or otherwise not re-identifiable information is not personal data within the scope of this Privacy Policy or applicable privacy laws.

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Security

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Vexcel employs reasonable organizational, technical, and administrative measures to provide a level of security appropriate to the risk associated with the personal data that it collects.  Vexcel protects personal data under its control against – and requires its service providers to also protect against – accidental or unlawful destruction, loss, alteration, unauthorized disclosure of or access to, personal data that is transmitted, stored, or otherwise processed.  Users should not disclose their user ID or password required to access the Services to any third party. 

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Data Retention

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Vexcel retains information about a User’s use of the Services in accordance with instructions from the WIC Agencies, and only as long as necessary to accomplish the purposes identified above and to comply with its legal and contractual obligations.  For more information regarding how long User information may be retained please contact the applicable WIC government authority in your state.

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International Transfers

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Vexcel Corporation complies with the EU-U.S. Data Privacy Framework (EU-U.S. DPF), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (Swiss-U.S. DPF) as set forth by the U.S. Department of Commerce. Vexcel Corporation has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (EU-U.S. DPF Principles) with regard to the processing of personal data received from the European Union in reliance on the EU-U.S. DPF and from the United Kingdom (and Gibraltar) in reliance on the UK Extension to the EU-U.S. DPF. Vexcel Corporation has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (Swiss-U.S. DPF Principles) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. In the context of an onward transfer, Vexcel Corporation has responsibility for the processing of personal data it receives under the DPF and subsequently transfers to a third party acting as an agent on our behalf. Vexcel Corporation remains liable under the DPF if our agent processes such personal information in a manner inconsistent with the DPF, unless Vexcel can prove that we are not responsible for the event giving rise to the damage. If there is any conflict between the terms in this privacy statement and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern. To learn more about the Data Privacy Framework (DPF) program, and to view our certification, please visit the U.S. Department of Commerce’s Data Privacy Framework website.

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If you have a question or complaint related to participation by Vexcel Corporation in the DPF Frameworks, we encourage you to contact us at mywiclegal@vexcelco.com. For any complaints related to the DPF Frameworks that Vexcel cannot resolve directly, we have chosen to cooperate with the relevant EU Data Protection Authority, or a panel established by the European data protection authorities, for resolving disputes with EU individuals, the UK Information Commissioner (for UK individuals), and the Swiss Federal Data Protection and Information Commissioner (FDPIC) for resolving disputes with Swiss individuals. Please contact us if you’d like us to direct you to your data protection authority contacts. As further explained in the DPF Principles, binding arbitration is available to address residual complaints not resolved by other means. Vexcel is subject to the investigatory and enforcement powers of the U.S. Federal Trade Commission (FTC).

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Changes to this Privacy Policy

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Vexcel may change and update this Privacy Policy from time to time, including materially changing the way it uses personal information described herein.

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Important notice about Governmental Body use of data collected: All information which is collected and maintained by or on behalf of a governmental body (in this case, a WIC Agency) may be considered under the laws of such governmental body to be public information that is available to members of the public who request it, subject to the Health Insurance Portability and Accountability Act of 1996 (HIPPA) which protects personal health information (PHI).  For more information on how the WIC Agency in your jurisdiction may use or disclose Information collected through the myWIC app, please contact the applicable WIC Agency. The privacy policy of the applicable WIC Agency governs the way it will use or share your information.  Contact your WIC Agency for more information.  Helpful links may be found HERE.

 

How to Contact Vexcel

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DO NOT USE THIS EMAIL TO SEND OR UPLOAD ANY DOCUMENTS OR PERSONAL INFORMATION REQUIRED FOR WIC REGISTRATION OR ACCESS TO WIC SERVICES OR CLINIC APPOINTMENTS. 

 

ALL REQUIRED DOCUMENTS AND PERSONAL INFORMATION MUST BE UPLOADED SOLEY THROUGH THE APP. DO NOT SEND BY EMAIL OR SERVICES AND BENEFITS MAY BE DELAYED AND/OR DENIED UNTIL RECEIVED THROUGH THE APP. 

 

IF YOU ARE HAVING DIFFICULTY UPLOADING DOCUMENTS TO THE APP OR BROWSER, PLEASE CONTACT YOUR LOCAL AGENCY OR CLINIC FOR ASSISTANCE.

 

If you have any questions about this Privacy Policy or about Vexcel’s privacy and data security practices for the Services, please contact mywiclegal@vexcelco.com.