Last Updated: April 29, 2021

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Welcome to the MyWIC MOSAIC mobile application (“the 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.

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Background

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This Privacy Policy establishes the terms and conditions that apply to “Customers” and “Users” of the Service.  “Customers” 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 Customers and who download and use the App on smart phones or tablets (“device(s)”) or use the Services. Vexcel processes information of Users obtained through the Services on behalf of Customers. 

This Privacy Policy describes how Vexcel handles the personal data that is collected from Users of the Services on behalf of the Customer, as well as any personal data that Vexcel may be given access to while acting on behalf of the Customer, to the extent that the Customer permits Vexcel to access personal data for which the Customer is responsible. This Privacy Policy does not apply to other information that Vexcel may collect through other means, including its website.

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What Does 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 Customer and the User. Customer, 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 Services collects from Users or information that its Customers communicate using the Services for purposes other than those required by the Service Agreements with its Customers 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:

• 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

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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.

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How Vexcel Uses Personal Data

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

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• 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 Customer prior notice, except as stated in this Privacy Policy.

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Unless otherwise agreed to between Customer and Vexcel, all data collected by the Services or communicated using the Services belongs to the Customer. Vexcel may, upon Customer’s request, provide the Customer 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 its Customer’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 its Customers; to maintain the security of the Services; and to protect the rights and property of Vexcel and its Customers. 

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As the Result of a Business Transition  

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Vexcel may disclose information about its Customers 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 Customer, 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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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 use made of personal information described herein.

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How to Contact Vexcel

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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.