Last updated: Oct 10, 2018
“Personal Information” means information that alone or when in combination with other information may be used to readily identify, contact, or locate you, such as: name, address, e-mail address, phone number, social security number, and insurance-issued ID numbers. “Personal Information” also includes identifiable health information collected about you. However, “Personal Information” does not include any information or data which has been anonymized so that it does not allow a third-party to identify a specific individual.
“Protected Health Information”, as defined in the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), 45 C.F.R. Parts 160, 162, and 164, means information, including demographic information, which relates to an individual’s past, present, or future physical or mental health or condition or the provision of health care to the individual, or the past, present, or future payment for the provision of health care to the individual, and that identifies the individual or for which there is a reasonable basis to believe can be used to identify the individual.
DrLife uses cutting edge software to provide education and digital health guidance and support to patients, monitor patient health through wearable technology and patient self-reporting, manage patient progress, collect payments, and provide other healthcare related services. The information that is submitted through the DrLife app and DrLife Service will be held subject to the requirements of our health service provider clients and applicable law, such as the Health Insurance Portability and Accountability Act (HIPAA).
INFORMATION WE COLLECT FROM YOU
Non-Personally Identifiable Information
When you use the DrLife app or DrLife Service, we may collect certain non-personally identifiable information. This may include your browser information (including browser type, browser version, host operating system, and browser language) and your IP address. We use this information to help diagnose problems with our servers and for other administrative purposes.
In addition, aggregate traffic information may also be compiled by the DrLife Service from this non-personally identifiable information. We may use this data for improving the features offered by the DrLife Service.
We may collect information, including Personal Information and Protected Health Information, about you:
when you register to use the DrLife app or other DrLife Services;
when you interact with and use the DrLife app or other DrLife Services;
when you provide Personal Information via the DrLife app or other DrLife Services;
when you upload an image, document, or any other data to the DrLife app or other DrLife Services;
when you communicate with us.
We primarily use two different types of cookies on this website: (1) Strictly Necessary Cookies and (2) Analytics Cookies:
Strictly Necessary Cookies:
These cookies are essential in order to enable you to move around the website and use its features and services, such as accessing secure areas of the website. These cookies do not gather information about you that could be used for marketing or remembering where you have been on the internet.
These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies you. All the information that these cookies collect is anonymous and is used only to improve a website’s services.
Managing Cookies. You can enable, disable or delete cookies within your browser. In order to do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” menu). Disabling a cookie or category of cookie does not delete the cookie from your browser; you will need to do this yourself from within your browser by choosing the option to delete cookies. If you have disabled one or more analytics cookies, we may still use information collected from cookies prior to your disabled preference being set, however, we will stop using the disabled cookie to collect any further information.
USE OF INFORMATION COLLECTED
Primary Purpose of Information Collected
The information and data collected through the DrLife Services, including Personal Information and/or Protected Health Information, is primarily used for the purposes of:
providing you the products and services you request;
notifying you about changes to our service and policies; and
communicating with you.
DrLife may also use the information we collect about you, including Personal Information, for the following purposes:
We may periodically contact you using information supplied to the site (e.g. to provide newsletters or marketing information on new products and services). You may opt out of receiving marketing communications by clicking on the unsubscribe link at the bottom of such emails. Certain communications, such as those regarding changes to our policies or changes to services you have purchased, you may not opt out of.
Surveys and Ratings. DrLife may make the content of any survey or ratings you provide public. DrLife will notify you in advance how it will use any survey or rating feedback in such request for this information.
Anonymized and Aggregate Data.
DrLife may anonymize and aggregate any data collected through the DrLife Service, and use it for business or research purposes. For example, we may use such anonymized and aggregate data for evaluating the performance of content and features provided through the DrLife Service.
DISCLOSURE OF PERSONAL INFORMATION
Vendors and Service Providers
We may share any information we receive with vendors and service providers retained in connection with the provision of the DrLife Service. When Protected Health Information is shared, as such term is defined by HIPAA, our vendors and service providers will be bound by appropriate business associate agreements as required by HIPAA.
Display or Disclosure to Health Service Providers and Others
The content you provide via the DrLife Services or DrLife app may be displayed on the DrLife Service or disclosed to others at your direction. Your DrLife provider (including your health provider’s staff), will have access to certain account information, including Personal Information and Protected Health Information. For example, when you enter biometrics or activity information, manually or through wearable technology, send private messages and/or share journal entries, your DrLife provider and staff will be able to see your name, contact information, as well as any other health information you have provided. However, DrLife will not have access to (i) any payment information, such as your credit card number, or (ii) your account password. You may also be permitted to share the content of your health records with third-parties. DrLife is not responsible for the privacy practices of others who may view and use the information you disclose to others.
Marketing and Advertising
DrLife does not rent, sell, or share Personal Information about you with other third-parties or non-affiliated companies for their marketing or promotional purposes.
When Required by Law.
DrLife reserves the right to disclose your Personal Information, without prior notice to you, as required by law or when we believe that disclosure is necessary to comply with a law, regulation, or any legal request (e.g. court order or subpoena). Furthermore, we may share your Personal Information when we believe it is necessary to address fraud or other illegal or prohibited activity perpetrated through the DrLife Services, or to prevent imminent bodily harm.
Merger, Sale, or Other Asset Transfers
If DrLife is involved in a merger, acquisition, reorganization, bankruptcy, receivership, sale of company asses, or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. We cannot control how such successor entities may use or disclose such information.
With Your Permission
DrLife may disclose your Personal Information according to your instructions and with your permission.
ACCESS AND CORRECTION OF PERSONAL INFORMATION
With respect to most information collected, DrLife obtains your personal information on behalf of a health service provider. To request access to, correction, amendment, or deletion of such Personal Information and/or Protected Health Information, please first contact the health service provider to which the information was provided. If the health service provider is unable to resolve your request, and for all other inquiries regarding your Personal Information, please contact: email@example.com.
We have implemented reasonable measures to protect the information we collect and store (e.g. hashed user password and SSL encryption), taking into consideration the types of risks we face and the reasonable protections available to us. No method of protecting information is 100% secure, and we cannot guarantee its absolute security. Consequently, we cannot ensure or warrant the security of any information you transmit to us and you do so at your own risk. Once we receive your data, we take steps to ensure security on our systems and/or on the systems of our service providers. Please note this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of such safeguards.
DrLife has adopted and maintains appropriate physical, technical and administrative policies and procedures to safeguard and secure the Protected Health Information we process, transmit or receive. We also will not access, use, or disclose the Protected Health Information except as permitted by health service provider clients, you, and/or applicable law, including HIPAA. DrLife takes the privacy of its customers seriously, and strives to protect the privacy of the Personal Information it processes, and to avoid any inadvertent disclosure.
If DrLife learns of a security system breach affecting personal information and/or Protected Health Information, DrLife maintains a breach notification policy pursuant to Business Associate Agreements it may have with a health service provider clients and/or consistent with applicable law.
By using the DrLife Service or providing Personal Information to us, you agree that we can communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the DrLife Service and DrLife app.
Access to and use of the DrLife Service is administered in the United States and is intended for users within the United States.
PRIVACY PRACTICES OF THIRD PARTIES
PRIVACY OF CHILDREN
DrLife does not knowingly collect information from anyone under the age of 13. If we are made aware that we have received information from anyone under the age of 13, we will promptly locate and remove that information from our records.
YOUR CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light” law, California residents have the right to receive information from us regarding categories of Personal Information we shared with third-parties for their direct marketing purposes during the previous calendar year, if any. This information will be provided free of charge, once per calendar year upon request. To request this information please email [firstname.lastname@example.org] with the subject line “Request for California Privacy Information”. We will respond to such written requests within 30 days following receipt at the e-mail or mailing address stated above.
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