Wellbility Mobile Application Privacy Policy

OVERVIEW

Effective Date/Last Modified: 6/25/20

This Privacy Policy describes:

 

  • Information that we receive from you when you interact with the Services

  • How we use and process the information that we receive

  • If and why Personal Information may be disclosed to third parties

  • Your choices regarding the collection and processing of your Personal Information

Please note that this Privacy Policy does not apply to information collected through third-party websites or services that you may access through the Services

PLEASE REVIEW THIS PRIVACY POLICY CAREFULLY. When you submit information to or through the Services, you consent to the collection and processing of your information as described in this Privacy Policy.

By using the Services, you accept the terms of this Privacy Policy and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy. By using our Services you waive your right to forum selection, choice of law, and right to class action suits. IF YOU DISAGREE WITH ANY ELEMENT OF THIS PRIVACY POLICY OR ANY OTHER TERM OF USE OF OUR SERVICES YOU MUST NOT USE OUR SERVICES. WE DISALLOW ANY USE OF OUR SERVICES WITHOUT USER AGREEMENT TO ALL TERMS STATED HEREIN.

 

USERS FOUND TO BE IN DISAGREEMENT WITH ANY TERM OF SERVICE CONTAINED HEREIN WILL BE TERMINATED FROM FROM UTILIZING OUR SERVICES.

IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE ANY OF THE SERVICES.

The Effective Date of this Privacy Policy is set forth at the top of this Policy. Whenever possible, we will provide you with the advance written notice of our changes to this Privacy Policy. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The amended Privacy Policy supersedes all previous versions.

INFORMATION WE COLLECT

 

Types of Information

We collect various kinds of information that you provide to us as well as the information we obtain from your use of the Services. Some of the types of information that we collect include:

Personal Information”—information associated with or used to identify or contact a specific person. Personal Information includes (1) contact data (such as e-mail address, telephone number, university enrollment, and employer); (2) demographic data (such as gender, date of birth and zip code); [and] (3) certain Usage Data (defined below), such as IP address; and (4) all user-generated content, purchases, or otherwise inputted data.

Certain Personal Information, such as information about personal health or finances, is characterized as Sensitive and subject to stricter regulation than other personal information. Before providing it to us, we urge you to carefully consider whether to disclose your Sensitive Personal Information to us. If you do provide Sensitive Personal Information to us, you consent to its use and disclosure for the purposes and in the manner described in this Privacy Policy.

Usage Data”—information about an individual's online activity that, by itself, does not identify the individual, such as

  • technical information, including your browser type, service provider, IP address, operating system, and application pages visited;

  • information about what you've searched for and looked at while using the Services;

  • metadata, which means information related to items you made available through the Services, such as the date, time, or location that a shared photograph or video was taken or posted.

(Generally, we do not consider Usage Data as Personal Information because Usage Data by itself usually does not identify an individual. Personal Information and Usage Data may be linked together. Different types of Usage Information also may be linked together and, once linked, may identify an individual person. Some Usage Data may be Personal Information under applicable law.)

Location Data” is a category of Personal Information collected about the location of a mobile device or computer, including:

  • the location of the mobile device or computer used to access the Services derived from GPS, Bluetooth, and/or WiFi use;

  • the IP address of the mobile device used to access the Services,

  • other information made available by a user or others that indicates the current or prior location of the user for purposes of Contact Tracing or to serve the optimization of Services offered through the Application (Wellbility)

"Personally Identifiable Health Information" - information that may reveal your health status. This information can include all subsets of health information, including demographic information collected from an individual. We will collect all data created or received by a healthcare provider, health plan, employer, or healthcare clearinghouse, associated with Services. We will collect past, present, or future physical or mental health or condition of an individual. We will collect information pertaining to the provision of healthcare to an individual that will identify the individual. We will collect healthcare payment information. However, we are not a healthcare provider, we are a Business Associate as identified under 45 CFR § 164.504. We will not use this information for anything other than what is permitted by law. You are EXPRESSLY consenting to the use of your personally identifiable health information for the purpose of facilitating healthcare services and the promotion of public health as broadly defined. 

How We Collect Information

Whether we collect certain types of information and how we process it depends on how you use and access the Services. Some information is collected automatically through the use of cookies and similar data collection tools. We collect information about you in the following ways:

From You. We collect information from you when you:

  • Use the Services. We collect Personal Information from you when you create an account to use one of the Services, contact us for help or information or otherwise voluntarily provide your Personal Information. WE COLLECT ALL DATA INPUTTED PERTAINING TO SYMPTOMS THAT ARE SUBMITTED TO THE APPLICATION. How you interact with the Application and what pages and services is collected by On-Site Medical Services.

  • Connect with social media through the Services. The Services may offer you the ability to use Facebook Connect or other social media services (collectively, “social media”) in conjunction with certain Services. When you access the Services through your Facebook or other Social Media account, the Services may, depending on your privacy settings, have access to information that you have provided to the Social Media platform. We may use this information for the purposes described in this Privacy Policy or at the time the information was collected. When you associate your social media account with your account and authorize us to have access to this information, you agree that we may collect, use and store the information provided by social media services as described in this Privacy Policy.

  • When you submit an order for service or product. We collect all data pertaining to submissions for requests such as telehealth services, and/or other products and services. 

  • When your symptom data indicates you should be tested. We collect data pertaining to symptom data submitted by you. If you have exceeded a threshold that the application suggests you should be tested we will immediately collect the data and use it.

From Our Business Partners and Service Providers. Third parties that assist us with our business operations also collect information (including Personal Information and Usage Data) about you through the Services and share it with us. For example, our vendors collect and share information with us to help us detect and prevent fraud. We may collect and share information with partners, vendors, or third parties to facilitate commercial healthcare transactions, billing, identification, and achieve public health goals. Any vendors that can be accessed through the use of the application (Wellbility) will have access to your data for purposes of facilitating a purchase, testing, and achieving public health goals (or to otherwise achieve a commercial healthcare objective).

We may combine the information we collect from you with information from other sources and use the combined information as described in this Privacy Policy.

Usage Data. We also automatically collect Usage Data when you interact with the Services.

 

From data collection tools. We, along with the service providers that help us provide the Services, use small text files called “cookies”, which are small computer files sent to or accessed from your web browser or your computer's or tablet's hard drive that contain information about your computer, such as a user ID, user settings, browsing history and activities conducted while using the Services. Cookies are not themselves personally identifiable, but may be linked to Personal Information that you provide to us through your interaction with the Services. A cookie typically contains the name of the domain (internet location) from which the cookie originated, the “lifetime” of the cookie (i.e., when it expires) and a randomly generated unique number or similar identifier.

Cookies help us improve the Services by [Include all that apply: tracking users' navigation habits and storing users' password, customizing users' experience with the Services; enabling us to analyze technical and navigational information about the Services; and helping to detect and prevent fraud].

We also use other cookies and other data collection tools (such as web beacons and server logs), which we collectively refer to as “data collection tools,”to help improve your experience with the Services. [For example, data collection tools help us remember users and make the Services more relevant to them].

The Services also may use data collection tools to collect information from the device used to access the Services, such as operating system type, browser type, domain and other system settings, as well as the operating system used and the country and time zone in which the computer or device is located.

Web browsers allow some control of most cookies through the browser settings. To find out more about cookies, including how to manage and delete cookies, visit www.allaboutcookies.org. Some web browsers (including some mobile web browsers) provide settings that allow a user to reject cookies or to alert a user when a cookie is placed on the user's computer, tablet or mobile device. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to some features available through the Services.

OUR DATA COLLECTION TOOLS ARE EXTENSIVE AND WILL COLLECT PERSONAL INFORMATION ON USERS INCLUDING BUT NOT LIMITED TO: LOCATION DATA, PERSONAL INFORMATION, HEALTH INFORMATION, AND INTERACTIONS WITH OTHER USERS. YOU MUST AGREE TO EXTENSIVE COLLECTION OF INFORMATION BY THE MEANS MENTIONED HEREIN, BUT COLLECTION MEANS ARE NOT LIMITED TO MEANS MENTIONED HEREIN. 

How We Use Your Information

We may use the information we collect for any of the following purposes:

  • to provide the Services to you;

  • to operate, improve and personalize the products and services we offer, and to give each user a more consistent and personalized experience when interacting with us;

  • for customer service, security, to detect fraud or illegal activities, or for archival and backup purposes in connection with the provision of the Services;

  • to communicate with users: using contact tracing technology as broadly understood;

  • to better understand how users access and use the Services, for the purposes of trying to improve the Services and to respond to user preferences, including language and location customization, personalized help and instructions, or other responses to users' usage of the Services;

  • to help us develop our new products and services and improve our existing products and services;

  • to provide users with advertising and direct marketing that is more relevant to you;

  • to enforce our Application Use Terms or other applicable policies; 

  • to facilitate health service or product transaction over the Application;

  • to facilitate public health objectives;

  • to achieve commercial health ventures; and 

  • to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with the Services.

Please note that, in order to provide you with a better experience and to improve the Services, information collected through the Services may be used in an aggregated or individualized manner. For example, personal information collected during use of one of the services may be used to suggest particular content that can be made available to the user on another of the Services or be used to try to present more relevant advertising in another of the Services.

How We Share and Disclose Your Information

We may share and disclose information as described at the time information is collected or as follows:

When you consent. We may share Personal Information with third parties if you have given us your consent to do so. We will only share Sensitive Personal Information when you have given us your opt-in consent.

To perform services. We may disclose Personal Information to third parties in order to perform services requested or functions initiated by users, such as transaction processing, debt collection, telehealth, and others. In addition, we may disclose Personal Information in order to identify a user in connection with communications sent through the Services. We also may offer users the opportunity to share information with friends and other users through the Services.

With third party service providers performing services on our behalf. We share information, including Personal Information, with our service providers to perform the functions for which we engage them (such as hosting and data analyses). We may share information as needed to operate other related services.

For legal purposes. We also may share information that we collect from users, as needed, to enforce our rights, protect our property or protect the rights, property or safety of others, or as needed to support external auditing, compliance and corporate governance functions. We will disclose Personal Information as we deem necessary to respond to a subpoena, regulation, binding order of a data protection agency, legal process, governmental request or other legal or regulatory process. We may also share Personal Information as required to pursue available remedies or limit damages we may sustain.

WE MAY DISCLOSE PERSONAL HEALTH INFORMATION SUCH AS TEST RESULTS FROM COVID-19 IF WE ARE COMPELLED BY A GOVERNMENT AGENCY, OR IF SUGGESTED BY LAW, REGULATION OR IN FURTHERANCE OF GOOD PUBLIC POLICY TO ACHIEVE UNIVERSAL HEALTH GOALS.

In aggregated form. We may share Personal Information about you in an aggregated form—that is, in a statistical or summary form that does not include any personal identifiers—with third parties in order to discover and reveal trends about how users like you interact with our services. Your data may be unidentified and used for purposes of COVID-19 research, this data may be sold, however, your personal information will not be used without your information and all information will be stripped of identifying markers. 

During corporate changes. We may transfer information, including your Personal Information, in connection with a merger, sale, acquisition or other change of ownership or control by or of us or any affiliated company (in each case whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify users before your information is transferred or becomes subject to a different privacy policy.

Information Storage and Security

We retain information as long as it is necessary and relevant for our operations. We also retain Personal Information and Personal Health Information to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation and other actions permitted by law. After it is no longer necessary for us to retain information, we dispose of it according to our data retention and deletion policies. IF WE DO NOT HAVE ANY USE FOR YOUR DATA AFTER 1 YEAR WE WILL NOTIFY YOU THAT WE WILL DELETE THE DATA WITHIN 90 DAYS, DURING THIS PERIOD YOU MAY DOWNLOAD YOUR DATA OR SEND TO ANOTHER SERVICE PROVIDER, AND WE WILL ASSIST IN THIS PROCESS.

We employ industry-standard security measures designed to protect the security of all information submitted through the Services. However, the security of information transmitted through the internet can never be guaranteed. We are not responsible for any interception or interruption of any communications through the internet or for changes to or losses of data. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our digital services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of the Services are restricted to authorized users only. Unauthorized access to such areas is prohibited and may lead to criminal prosecution.

Your Rights

It is important to us that you are able to access and review the Personal Information we have about you and make corrections to it or delete it, as necessary. You can visit [your account] to manage and correct the information we have on file about you. If you have any questions about how to access your Personal Information, please contact us at: privacy@wellbility.com

Links to Third Party Services

The Services may contain links to third-party websites and services (“Third Party Services”) with which we have no affiliation. A link to any Third Party Service does not mean that we endorse it or the quality or accuracy of information presented on it. If you decide to visit a Third Party Service, you are subject to its privacy policy and practices and not this Privacy Policy. We encourage you to carefully review the legal and privacy notices of all other digital services that you visit.

Disclaimer: Not Child-Directed

The Services are not intended for use by children. NO INDIVIDUALS UNDER THE AGE OF 18 ARE PERMITTED TO USE THE APPLICATION. 

WE DO NOT PERMIT USERS OUTSIDE OF THE UNITED STATES TO USE OUR APPLICATION. YOU MAY NOT USE OUR APPLICATION (WELLBILITY) IF YOU ARE A MINOR OR LIVE OUTSIDE THE UNITED STATES.

© 2020 On-site Medical Services LLC

Tel: 603-826-6500

71 Belknap Ave Newport, NH 03603