EFFECTIVE DATE: OCTOBER 1, 2020
Through our Services offered via our Web Portal and App, you may be able to view your health conditions, procedures, lab results, and allergies; monitor your health dashboard; view and manage medication fills and refills; review medication costs and benefits; set medication reminders; receive personalized medication guidance; chat live with a medication guide; set health goals and reminders to help achieve such goals; receive automated alerts and reminders about drug interactions, refills, and physician visits; and authorize trusted caregivers to manage your account.
Protected Health Information
In certain circumstances, we may collect or use your information through our Web Portal, App and Services while acting as a “business associate” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), which may constitute “Protected Health Information.” A “business associate” includes an entity that provides services to a HIPAA covered entity that involves the use or disclosure of Protected Health Information. If we provide Services through the Web Portal or App on behalf of a HIPAA covered entity such as your employer sponsored health insurance plan or health care provider, we may qualify as their business associate. “Protected Health Information” as defined under HIPAA, generally means information about you that identifies you and that relates to your physical or mental health or condition, the provision of health care to you, or payment for health care provided to you. To the extent we are acting as a business associate, we will only use and disclose your information as permitted by HIPAA and the HIPAA Policy, which may include, but not be limited to, fulfilling our service obligations, our internal management and administration, to carry out our legal responsibilities, de-identify or aggregate data, or as otherwise required by law.
The Information We Collect About You
We collect information about you directly from you and from third parties, and automatically through your use of our Web Portal, App, or Services.
Our Web Portal and App. In order to use our Services offered via our Web Portal and App, you will need to create an account with us. To create an account, you must provide your WithMe Health Member ID, first and last name, date of birth, and phone number. Via your account, we may collect additional information that you choose to provide to us through the Web Portal and App, including:
In addition, the App may access your photos, microphone, and calendar, and we may collect information related to these features to provide the Services, but only if you have enabled/permitted this functionality on your mobile device.
We automatically collect information about your use of our Web Portal and App through cookies, web beacons, and other technologies, including technologies designed for mobile apps. This includes IP address, web browser type; domain name; website access time; mobile device ID; MAC address; domain name; device name and model; operating system type, name, and version; language information; referring URL; cursor movement and/or text box entries; and activities within the App and the length of time that you are logged into the App. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
In addition, we may collect location information from your mobile device to help you conduct location-based searches and to identify other relevant services nearby, but only if you have enabled/permitted this functionality on your mobile device. You may turn off this feature through the location settings on your mobile device.
To the extent permitted by applicable law, we combine the information described above with other information we collect about you, including your personal information. We may share information that we collect automatically with non-affiliated entities, such as a user’s employer-sponsored health plan.
Information We Collect From Other Entities. We may collect information about you from your employer, your health plan(s), clinical laboratory service providers, third party partners, public records, and data aggregators, such as your name, contact information, lab results, current and historical health plan information, and other information.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
How We Share Your Information
We may share your information, including personal information, as follows:
We also disclose information in the following circumstances:
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Web Portal, App, and Services, while others are used to enable a faster log-in process or to allow us to track your activities at Web Portal, App, and Service. There are two types of cookies: session and persistent cookies.
Disabling Cookies. Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to and users of our Web Portal, App, and Services who disable cookies will be able to browse certain areas of the Web Portal, App, and Services but some features may not function at all or may not function well.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Web Portal, App, and Services to, among other things, track the activities of Web Portal, App, and Services users, help us manage content, and compile statistics about Web Portal, App, and Services usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Cross-Device Use. We and our third party service providers, including Google, may use the information that we collect about you (whether directly from our Web Portal App, or Services, or through your device(s), or from a third party) to help us and our third party service providers identify other devices that you use (e.g., a mobile phone, tablet, other computer, etc.). We, and our third party service providers also may use the cross-device use and other information we learn about you to send you emails, push notifications, and other messages. To opt-out of cross-device advertising, you may follow the instructions set forth in the Third Party Ad Networks section below. Please note: if you opt-out of these targeted advertising cookies, your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt-out each browser or device that you use.
Our Web Portal, App, and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.
Security of My Personal Information
We have implemented reasonable precautions to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access to My Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Web Portal, App, or Services for a period of time.
What Choices Do I Have Regarding Use of My Personal Information?
We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
Children Under 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will take steps to delete such information from our systems.
If you have questions about the privacy aspects of our Web Portal, App, or Services or would like to make a complaint, please contact us at Legal@withmehealth.com.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Web Portal, App, and Services. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Web Portal, App, and Services, or by contacting you at the email address we have on file for you.
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