Skip to Content

PRIVACY POLICY FOR USERS OF CARE INNOVATIONS® PRODUCTS AND SERVICES

Effective Date: June 18, 2013
Last Updated: April 23, 2020

What This Privacy Policy Covers

This Privacy Policy for Users of Care Innovations Products and Services (“Privacy Policy”) applies only to individuals who use the Care Innovations applications, products,  and services (called “Users”) and their personal information that we collect, use, and disclose in connection with those applications, products, and services.

This Privacy Policy uses certain words that are defined by privacy laws, including for Patients the Health Insurance Portability and Accountability Act of 1996 as amended by the health information Technology for Economic and Clinical Health Act and its implementing regulations (collectively “HIPAA”) and for California residents California Consumer Privacy Act of 2018 and the regulations that implement it (called the “CCPA”).

Why Are We Providing You This Privacy Policy?

Care Innovations offers technology solutions that support the collection and monitoring of your information to support your patient care by clinical care teams or your self-care and monitoring.  You choose to use our applications, products, and services, either at the suggestion of your health care provider or through an offer to you by an organization.

  • Your care provider may direct your health information to our applications and products.
  • Or you can direct your information that you collect on your applications to send your information to our applications and products.

No matter how you choose to engage with us, our mission is to support your patient care or self-care.

This Privacy Policy is intended to describe how we collect, use, and disclose information about you to achieve these goals. Specifically, we are providing you with notice of

  • the personal information that we may have collected, used, and disclosed in the past twelve months and may continue to collect, use, and/or disclose.
  • your rights under the laws that provide you with rights.

NOTE: If you have provided or will provide a separate consent or authorization for our collect, use, or disclosure of your personal information, then we may collect, use, and disclose your personal information according to that consent or authorization.

If we provide you with a privacy notice in another context, such as when we interact with you through our website, that notice may provide relevant information about additional information collection, use, and disclosure.

What Information Do We Collect?

Much of the information we collect is provided directly by you or at your direction. For example:

  • General information about you: When you sign up or enroll, we request your name, email address, and other contact information. We also may ask you to create a username and password to authenticate your access to our products or services.
  • Health information and vitals: You can provide us with the health information we need to support your care in several ways. You may choose to enter your health information manually, such as submitting your temperature by typing it in. You also may direct our application to access health information generated by other health apps and devices. For example, you can direct our application to collect your temperature directly from a Bluetooth-enabled thermometer or collect your heart rate directly from databases generated by your other health apps.
  • Precise location: If you agree through your system settings, our application will collect your precise, real-time location. You can change your preference regarding this data collection by adjusting the settings in your device.

Also, if you are interacting with our products or services because your health care provider directed or requested your use, then we may have already received information about you from your health care provider and enrolled you through our engagement with your provider. After you log in to our product or service, you and your healthcare provider may provide us with additional information.

If you choose to engage with our call center, which we provide for support purposes but not to deliver health care, we will receive any information you decide to share with us during the conversation, which may be recorded.

We also may receive information simply because you are interacting with our products or services through your device. For example, we will collect your device identifier, IP address, and cookie identifiers, as well as information about the frequency of your interaction with our products and services.

We do not permit other organizations to collect personal information from your use of our applications, products, and services over time and across third-party sites and services.

How Is My Information Used and Disclosed?

Because different laws provide Users with different rights, different parts of this Privacy Policy apply to different types of Users.

  • If you are a patient using the products and services, then Section 1 applies to you.
    • A patient is a User who has been provided access to the products and services by or at the direction of the User’s health care provider.
    • A patient is a User whose information is transmitted to us from or on behalf of the User’s health care provider.
  • If you are not a patient, then Section 2 applies to you.
    • A User is not a patient if the User has obtained access to the products and services through a means other than the User’s health care provider. This includes:
      • Enrolling as an individual and paying directly
      • Enrolling through an offer provided by a User’s employer or other association
  1. Privacy Policy: Use and Disclosure of Personal Information of Patients

This Privacy Policy does not replace your health care provider’s responsibility for providing you with a notice of its privacy practices, which describes your health care provider’s uses and disclosures of your information.

The primary purpose in providing our products and services is to support telehealth services, support selfcare and monitoring, and support other health related activities.  We have and will continue to collect, use, and disclose your information for these purposes.

When we receive information that is subject to HIPAA from a care provider, we are a “Business Associate” of your health care provider and we sign an agreement with the health care provider that:

  • Provides our commitment to comply with HIPAA as it applies to us.
  • States the permitted uses and disclosures of your health information.

We will use and disclose your information in compliance with that agreement, such as disclosing your health information to your provider for their use, to other health care providers for treatment and payment purposes, to public health authorities and for health oversight activities as permitted by HIPAA, and otherwise at the direction of your health care provider.

In addition, we may disclose personal information in response to legal process or if required by law, such as a mandatory reporting obligation to a public health authority. We also may disclose personal information in connection with security and fraud prevention, as necessary to investigate or prevent fraud or other malicious activities, to protect our rights and the safety of others. We will disclose personal information if we or our assets are acquired by, sold to, or merged with another company as part of a bankruptcy or business reorganization.

You may have certain rights with regard to your personal information, including a right to access and a right to amend it.  You should submit your requests directly to your care provider.  If you submit the request to us, we will pass it on to your health care provider.

  1. Privacy Policy: Use and Disclosure of Users’ Personal Information Who are Not Patients

Uses of Your Information

The primary purpose in providing our products and services is to support telehealth services, support selfcare and monitoring, and support other health related activities, and we will collect, use, and disclose your health information for these purposes.  Your health information may also be subject to state laws that describe the permitted uses and disclosures of your health information.  We use and disclose your health information according to those laws.

We may have used and may continue to use your personal information for the following purposes:

  • provide the products and services and communicating with you, including through the call center services;
  • communicating with your caregivers and assisting in coordination of your care;
  • communicating with you regarding features, products, or services that may be of interest to you;
  • auditing related to your current interaction with us and related transactions, including for example auditing your compliance with the care program, which is part of our services;
  • performing technical and support services, including maintaining or servicing accounts, providing customer service, verifying customer information, providing analytics services, or providing other similar services;
  • creating aggregated data or de-identified data in accordance with laws that apply to the information and to the extent permitted by those laws;
  • to comply with laws and orders;
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • debugging to identify and repair errors that impair existing intended functionality;
  • enhancing current or developing new services and products; and
  • undertaking internal research for technological development and demonstration.

Sources of Personal Information

We may have obtained during the past 12 months and will continue to obtain personal information about you from the following categories of sources:

  • directly from you.
  • from your devices, such as when you log in to our products or receive our services.
  • companies that are our affiliates and subsidiaries.
  • vendors who provide services to us or for us.
  • government entities.

Sharing of Personal Information

We may have shared during the past 12 months and will continue to share:

  • All categories of your personal information listed above with our affiliates and subsidiaries, or with governmental authorities as necessary to comply with law or a valid request
  • All categories of your personal information listed above with our vendors and other professionals who provide us with services, such as supporting our communications.

If reasonably necessary, in the future, we may transfer all categories of your personal information to another entity if we sell or transfer all or a portion of our business or assets; for example, as the result of a sale, merger, or reorganization, insolvency, dissolution, or liquidation.

California Consumer Privacy Rights

If you are a California resident, then you may have certain choices regarding your personal information. As described further above, in the prior 12 months, we collect the following categories of personal information:

  • Identifiers such as a real name, postal address, telephone number, email address, and unique personal identifier (such as a device identifier, cookies, and similar technology, and other forms of persistent or probabilistic identifiers), internet protocol address, and other similar identifiers
  • Internet or other electronic network activity information such as information about your interactions with our application and products
  • Physical characteristics
  • Protected characteristics that are protected by laws such as age, sex, gender, gender identity, and veteran and military status
  • Sensory information, if you contact our call center in which case your voice is recorded
  • Employment information, if you choose to share it with us, such as when contacting our call center, or if you choose to use your employer-issued email address to communicate with us
  • Commercial information, including records of the products and services you obtained from us
  • Inferences drawn from any of the information we collect and use to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes
  • Geolocation data, if you enable location tracking for our application and devices through your system settings

With respect to that information, you may have the following privacy rights:

Request to know: You may have the right to request to know the personal information we have collected, used, and shared: the specific pieces of personal information we collected during the prior twelve months; the categories of your personal information that we collected during the prior twelve months; the categories of your personal information that we shared for a business purpose to a third party during the prior twelve months; the categories of the sources of the personal information that we collected; the business or commercial purpose for collecting your personal information; and the category of third parties to whom we disclosed your personal information.  You may exercise this right twice a year.

Deletion: You have the right to request that we delete certain personal information we have collected from you.  However, we may not be able to continue to provide the products and services if we delete your personal information.

Sale: We do not sell the personal information of Users.

If you exercise certain rights, please understand that you may be unable to use or access certain features of our services.  If you choose to exercise any of your rights under the CCPA, we will not discriminate against you.

How to Contact Us

How to Submit a Request. To ask questions about this Privacy Policy and for those who have a right to submit an access or deletion request, or call us at +1 877.202.0559.  If you are legally authorized to act as an agent of an individual whose personal information we collect, use, or disclose, you may make these requests and we will ask you to provide proof of your authority. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

Verifying Requests. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to personal information or complying with your request to delete or opt out.  Usually, we will ask you to provide us with specific information that identifies you which we would match to information we have on file.  If we cannot verify your identity based on the information you provide, we will let you know that we cannot fulfil your request and we reserve the right to do so.  For example, if you do not have an email address or other direct contact information on file with us, then there may be no reasonable method for us to verify your identity.

Please note that if we maintain your personal information on behalf of another organization, we may need to refer you to that organization to respond to your request.

What Security Do We Provide?

We recognize the importance of maintaining the security of your personal information. We use reasonable security measures, including physical, administrative, and technical safeguards to protect your personal information.

What if we Change this Privacy Policy?

Modifications to this Policy

  • We reserve the right, at our discretion, to make changes to this Privacy Policy at any time.
  • We will notify you of any material changes to this Privacy Policy by posting a notice on the home page of our website with the new effective date to let you know the Privacy Policy has changed. It is your responsibility to check our website periodically for changes to this Privacy Policy.