Notice of security incident involving third-party file-sharing platforms used by Imagine360.

Imagine360, LLC (“Imagine360”) is making potentially impacted individuals aware of a data security incident involving third-party file sharing platforms used by Imagine360 to process claims associated with individuals’ health insurance plans.

What Happened?
On or around January 30, 2023, Imagine360 identified unusual activity within a third-party file sharing platform, Citrix. Citrix is used by Imagine360 to securely exchange files related to self-insured health plans. In response, Imagine360 terminated access to the platform, reset passwords, and confirmed the security of its environment since the platform is externally hosted outside of the Imagine360 environment.

In conjunction with these efforts, Imagine360 promptly launched an investigation to determine the full nature and scope of the activity. During the course of this investigation, on or around February 3, 2023, Fortra, a third-party vendor who owns and manages another third-party file sharing platform used by Imagine360 notified Imagine360 of a data security incident. According to Fortra, an unauthorized actor copied data maintained in this platform belonging to multiple organizations, including Imagine360.

In response, Imagine360 worked with Fortra to gather more information regarding the full nature and scope of this incident, since the platform is also externally hosted outside of the Imagine360 environment. In addition to this, Imagine360 decided to conduct its own internal investigation into the incident to confirm the full scope of the incidents. Through its investigation of both incidents, Imagine360 learned files were copied from both platforms between January 28 and January 30, 2023.

What Information Was Involved?
The information identified in the impacted files includes name, medical information, health insurance information, and Social Security Number.

What We Are Doing
Imagine360 takes these incidents and the privacy of information in its care seriously. We conducted a diligent investigation to confirm the full nature and scope of these incidents. We also took prompt steps to ensure that the incidents did not impact Imagine360’s internal systems while conducting a comprehensive review of the information potentially affected. We also reported these incidents to federal law enforcement and will be notifying applicable state and federal regulators.

Further, as part of our ongoing commitment to the privacy and security of information in our care, we suspended use of Fortra’s platform and implemented additional safeguards to our existing policies, processes, and security measures.

 What You Can Do
Individuals are encouraged to remain vigilant against incidents of identity theft and fraud, and to review their account statements and explanation of benefits along with monitoring their free credit reports for suspicious activity and to detect errors. It is also recommended that individuals review the “Steps Individuals Can Take To Protect Personal Information” section below.

For More Information
We understand you may have additional questions not addressed by this letter. If you have questions, please contact our dedicated call center at (888) 220-5801, Monday through Friday, from 6 a.m. – 6 p.m. Pacific Time (excluding U.S. holidays).

We regret any inconvenience caused by these incidents.

Monitor Your Accounts
Under U.S. law, a consumer is entitled to one free credit report annually from each of the three major credit reporting bureaus, Equifax, Experian, and TransUnion. To order your free credit report, visit www.annualcreditreport.com or call, toll-free, 1-877-322-8228.  You may also directly contact the three major credit reporting bureaus listed below to request a free copy of your credit report.

Consumers have the right to place an initial or extended “fraud alert” on a credit file at no cost. An initial fraud alert is a 1-year alert that is placed on a consumer’s credit file. Upon seeing a fraud alert display on a consumer’s credit file, a business is required to take steps to verify the consumer’s identity before extending new credit.  If you are a victim of identity theft, you are entitled to an extended fraud alert, which is a fraud alert lasting seven years.  Should you wish to place a fraud alert, please contact any one of the three major credit reporting bureaus listed below.

As an alternative to a fraud alert, consumers have the right to place a “credit freeze” on a credit report, which will prohibit a credit bureau from releasing information in the credit report without the consumer’s express authorization. The credit freeze is designed to prevent credit, loans, and services from being approved in your name without your consent. However, you should be aware that using a credit freeze to take control over who gets access to the personal and financial information in your credit report may delay, interfere with, or prohibit the timely approval of any subsequent request or application you make regarding a new loan, credit, mortgage, or any other account involving the extension of credit. Pursuant to federal law, you cannot be charged to place or lift a credit freeze on your credit report.  To request a security freeze, you will need to provide the following information:

1. Full name (including middle initial as well as Jr., Sr., II, III, etc.);
2. Social Security number;
3. Date of birth;
4. Addresses for the prior two to five years;
5. Proof of current address, such as a current utility bill or telephone bill;
6. A legible photocopy of a government-issued identification card (state driver’s license or ID card, etc.); and
7. A copy of either the police report, investigative report, or complaint to a law enforcement agency concerning identity theft if you are a victim of identity theft.

Should you wish to place a credit freeze, please contact the three major credit reporting bureaus listed below:

You may further educate yourself regarding identity theft, fraud alerts, credit freezes, and the steps you can take to protect your personal information by contacting the consumer reporting bureaus, the Federal Trade Commission, or your state Attorney General.  The Federal Trade Commission may be reached at: 600 Pennsylvania Avenue NW, Washington, DC 20580; www.identitytheft.gov; 1-877-ID-THEFT (1-877-438-4338); and TTY: 1-866-653-4261. The Federal Trade Commission also encourages those who discover that their information has been misused to file a complaint with them.  You can obtain further information on how to file such a complaint by way of the contact information listed above. You have the right to file a police report if you ever experience identity theft or fraud.  Please note that in order to file a report with law enforcement for identity theft, you will likely need to provide some proof that you have been a victim. Instances of known or suspected identity theft should also be reported to law enforcement and your state Attorney General. This notice has not been delayed by law enforcement.

For District of Columbia residents, the District of Columbia Attorney General may be contacted at: 400 6th Street, NW, Washington, DC 20001; 202-727-3400; and oag.dc.gov.

For Maryland residents, the Maryland Attorney General may be contacted at: 200 St. Paul Place, 16th Floor, Baltimore, MD 21202; 410-576-6300 or 1-888-743-0023; and www.marylandattorneygeneral.gov. Imagine360 is located at 1550 Liberty Ridge Dr. Suite 330 Wayne, PA 19087.

For New Mexico residents, you have rights pursuant to the Fair Credit Reporting Act, such as the right to be told if information in your credit file has been used against you, the right to know what is in your credit file, the right to ask for your credit score, and the right to dispute incomplete or inaccurate information.  Further, pursuant to the Fair Credit Reporting Act, the consumer reporting bureaus must correct or delete inaccurate, incomplete, or unverifiable information; consumer reporting agencies may not report outdated negative information; access to your file is limited; you must give your consent for credit reports to be provided to employers; you may limit “prescreened” offers of credit and insurance you get based on information in your credit report; and you may seek damages from violator.  You may have additional rights under the Fair Credit Reporting Act not summarized here.  Identity theft victims and active duty military personnel have specific additional rights pursuant to the Fair Credit Reporting Act.  We encourage you to review your rights pursuant to the Fair Credit Reporting Act by visiting www.consumerfinance.gov/f/201504_cfpb_summary_your-rights-under-fcra.pdf, or by writing Consumer Response Center, Room 130-A, Federal Trade Commission, 600 Pennsylvania Ave. N.W., Washington, D.C. 20580.

For New York residents, the New York Attorney General may be contacted at: Office of the Attorney General, The Capitol, Albany, NY 12224-0341; 1-800-771-7755; or https://ag.ny.gov/.

For North Carolina residents, the North Carolina Attorney General may be contacted at: 9001 Mail Service Center, Raleigh, NC 27699-9001; 1-877-566-7226 or 1-919-716-6000; and www.ncdoj.gov.