Provision record
UnitedHealthcare · UnitedHealthcare Privacy Policy · View original document ↗

Data Combination from Online and Offline Sources

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Document Record

What it is

The Policy states that UnitedHealthcare may combine information collected through Online Services with offline data from internal and vendor sources and use or disclose the combined dataset for the purposes described in the Policy or for internal business purposes.

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This analysis describes what UnitedHealthcare's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology

ConductAtlas Analysis

Why it matters (compliance & governance perspective)

This provision authorizes data aggregation across online behavioral data, health and medical information, financial data, and offline records from vendors, which may produce enriched data profiles extending beyond what users submit directly through Online Services. The permissibility of such combination involving Protected Health Information is subject to HIPAA's minimum necessary and permissible use standards.

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Interpretive note: The operational scope of permitted data combination depends on which specific vendor data sources are used and how HIPAA minimum necessary standards are applied to each combination use case, which is not specified in the document.

Consumer impact (what this means for users)

Under this clause, data collected through UnitedHealthcare's websites and mobile applications may be combined with offline records and vendor-sourced data to create enriched information profiles used for the purposes described in the Policy, including analytics, marketing, and service delivery. The categories of data that may be combined include health and medical information, financial data, and behavioral tracking data.

Cross-platform context

See how other platforms handle Data Combination from Online and Offline Sources and similar clauses.

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▸ View Original Clause Language DOCUMENT RECORD
"
We may, when permitted, combine your Information with other information, whether online or offline, maintained or available to us from you or from other sources, such as from our vendors, and we may use and disclose combined data for the purpose described in this Section or for internal business purposes.

Excerpt from UnitedHealthcare's Privacy Policy

ConductAtlas Analysis

Institutional analysis (regulatory & governance intelligence)

1.

Insight

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Enforcement risk, jurisdiction flags, contract triggers, and due diligence action items.

Applicable agencies

  • Federal Trade Commission (ftc)
    Oversees unfair or deceptive business practices and can investigate companies that mislead consumers about data collection, sharing, or use.
    Who can file: Anyone affected by the company's practices (US or international)
    What you need: Your account details, a timeline of relevant events, and a description of the specific issue
    What to expect: Complaints inform FTC enforcement priorities and investigations but do not result in individual resolution or compensation
    File a complaint →
  • Department Of Health & Human Services, Office For Civil Rights (hhs Ocr)
    Enforces HIPAA Privacy and Security Rules, which protect health information held by healthcare providers, health plans, and their business associates.
    Who can file: Anyone whose HIPAA rights may have been violated by a covered entity (healthcare provider, health plan, or healthcare clearinghouse)
    What you need: Name of the entity, description of the violation, date of the incident, and your contact information. Must file within 180 days of the violation.
    What to expect: HHS OCR investigates and may require the entity to take corrective action. Does not provide individual compensation. Serious violations can result in civil monetary penalties.
    File a complaint →

Provision details

Document information
Document
UnitedHealthcare Privacy Policy
Entity
UnitedHealthcare
Document last updated
May 5, 2026
Tracking information
First tracked
July 12, 2026
Last verified
July 12, 2026
Record ID
CA-P-074533
Document ID
CA-D-00603
Evidence Provenance
Source URL
Wayback Machine
Content hash (SHA-256)
8fd5e1abe15c4edc31df089ee6f248319a8528f2ca9479e303144fdb83757295
Analysis generated
July 12, 2026 17:38 UTC
Methodology
Evidence
✓ Snapshot stored   ✓ Hash verified
Citation Record
Entity: UnitedHealthcare
Document: UnitedHealthcare Privacy Policy
Record ID: CA-P-074533
Captured: 2026-07-12 17:38:39 UTC
SHA-256: 8fd5e1abe15c4edc…
URL: https://conductatlas.com/platform/unitedhealthcare/unitedhealthcare-privacy-policy/provision/CA-P-074533/data-combination-from-online-and-offline-sources/
Accessed: Sept. 26, 2026
Permanent archival reference. Stable identifier suitable for legal filings, compliance documentation, and research citation.
Classification
Severity
Medium
Categories

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Frequently Asked Questions

What does UnitedHealthcare's Data Combination from Online and Offline Sources clause do?

This provision authorizes data aggregation across online behavioral data, health and medical information, financial data, and offline records from vendors, which may produce enriched data profiles extending beyond what users submit directly through Online Services. The permissibility of such combination involving Protected Health Information is subject to HIPAA's minimum necessary and permissible use standards.

How does this clause affect you?

Under this clause, data collected through UnitedHealthcare's websites and mobile applications may be combined with offline records and vendor-sourced data to create enriched information profiles used for the purposes described in the Policy, including analytics, marketing, and service delivery. The categories of data that may be combined include health and medical information, financial data, and behavioral tracking data.

Is ConductAtlas affiliated with UnitedHealthcare?

No. ConductAtlas is an independent monitoring service. We are not affiliated with, endorsed by, or sponsored by UnitedHealthcare.