Introduction
Care Thread, Inc. (“Care Thread”) provides a mobile platform (the “Application”) which is designed to assist providers of health care (the “Providers”) and other users of the Application (also referred to as “you” or “End-Users”) to communicate with each other in connection with the coordination of care. This privacy policy is designed to inform users of the Application about how Care Thread (also referred to as “we” or “us”) gathers and uses personal information collected by us in connection with the Application. We will take reasonable steps to protect user privacy consistent with the guidelines set forth in this policy and with applicable U.S. laws. In this policy, “user” or “you” means any person using or otherwise benefiting from the Application, registering with us by creating an account, or participating in any other activities available through the Application. BY ACCESSING OR USING THE APPLICATION, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR SERVICE TERMS AND CONDITIONS. IF YOU DO NOT AGREE TO THESE TERMS, DO NOT USE THE SERVICE.
Protected Health Information
Some of the information we collect in connection with the Application may be “Protected Health Information” (as that term is defined at 45 C.F.R. § 160.202) protected under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and Subtitle D of the Health Information Technology for Economic and Clinical Health Act (the “HITECH Act”). We will use, protect and disclose any Protected Health Information in accordance with our Notice of Privacy Practices, as mandated by HIPAA, available here: Notice of Privacy Practices. To the extent that there is any inconsistency between this Privacy Policy and the Notices of Privacy Practices, the Notice of Privacy Practices will prevail.
What Information Do We Collect?
We collect the following personal information in connection with the Application: (a) when you sign up to create a Care Thread account, we collect the personal information you disclose on the account registration form, including your name, address, mobile number; (b) if you communicate with us by email, we will collect your email address; (c) when you use the Application, our servers may automatically recognize your IP address; and (d) if you use the Application to respond to questions or other requests for information, we collect the information you provide in your responses. All of this information is referred to in this Policy as “Personal Information”. Some Personal Information may also be Protected Health Information.
We receive information you choose to transmit to others or information other End Users choose to transmit to you through the Application, including but not limited to the content contained in text messages transmitted through the Application. This provision only applies to non-Protected Health Information transmitted through the Licensed Application. Transmission and retention of Protected Health Information is covered by the HIPAA Security Rule.
We receive information whenever you interact with the Application, including but not limited to when you log on, when you log off, when you send someone a text message, or when you read a message that has been sent to you. For example, when you access the Application, the information may be stored in cookies, which are data files stored by your web browser on your computer, and/or web server logs and log files, which are records for when you request to view a webpage. This information (“Tracking Information”) helps us recognize you and customize your experience with the Application
We receive information from you whenever you communicate directly with us, such as when you have you have requested customer service support.
How Do We Use the Information We Collect?
Personal Information: We will use and store Personal Information for the purpose of delivering the Application to you and where applicable to Providers, and to enhance and analyze the operation of the Application. We may also use Personal Information and other information obtained from Providers internally, for the operational and administrative purposes of the Application.
Aggregate Information: We will also use End User information to create statistical, aggregated data for analytical purposes. Though this statistical information may be derived from Personal Information, in its aggregated form it does not relate to or identify any particular individual and is used to understand our customer base and to develop, improve and market our services.
Legal Exception: Notwithstanding the above, we may in any event use Personal Information and other information collected through the Application to the extent required by law or legal process, to resolve disputes, to enforce our agreements (including this Privacy Policy and the Terms of Service) with you, or if in our reasonable discretion use is necessary to protect our legal rights or to protect third parties.
Email Communications: If you create an account and provide your email address, we may send you administrative or promotional emails. If you wish to opt out of promotional emails, you may do so by following the “unsubscribe” instructions in the email, or by editing your account settings as described below. All users receive administrative emails, and so you cannot opt out of them while you remain an accountholder.
What Information Do We Disclose to Third Parties?
Personal Information: We will not disclose your Personal Information to any third parties except as follows:
(i) to third party contractors engaged to provide services on our behalf (“Contractors”), such as performing hosting and communications services, analyzing data and usage of the Application, operating the Application or providing support and maintenance services for the Application, or providing customer service. We enter into agreements with all Contractors that require Contractors to use the Personal Information they receive only to perform services for us.
(ii) if the Notice of Privacy Practices allows disclosure of Protected Health Information, we may disclose related Personal Information to the same extent that Protected Health Information may be disclosed.
(iii) when we have your consent to share the information.
Tracking Information: We disclose Tracking Information to Contractors, in order for us and such third parties to analyze the performance of the Application and the behavior of users and to operate and improve the Application. We may also publish this information in order to promote the Application.
Aggregate Information: We may disclose anonymous, aggregated information to third parties such as potential business partners and funding sources, in order to describe our business and operations.
Network Operators: Use of the Application may involve use of the services of third party telecommunications carriers. Such carriers are not our contractors, and any information that a carrier collects in connection with your use of the Application is not “Personal Information” and is not subject to this Privacy Policy. We are not responsible for the acts or omissions of telecommunications carriers.
Additional Disclosures: We reserve the right to disclose any information we collect in connection with the Application, including Personal Information, (a) to any successor to our business as a result of any merger, acquisition, asset sale or similar transaction; and (b) to any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights or to protect third parties.
Privacy Settings/Opt Out
If you would like your Personal Information permanently removed from our database, please contact us at [support@carethread.com]. We will promptly delete your account and you will no longer receive email from Care Thread. Your removal from the mailing list or database will not remove records of past transactions or delete information stored in our data backups and archives. Data on past transactions and data stored in backups and archives will be maintained and/or deleted in the ordinary course of Care Thread’s business or in a manner consistent with this policy and the Notice of Privacy Practices.
Access and Updating of Information
Care Thread is happy to allow you to review or amend your email address or contact details held in our database, at any time. Please contact us by sending an email to: support@carethread.com or by using your settings panel in your account online
General
Security: We use reasonable security precautions to protect the security and integrity of your Personal Information in accordance with this policy and applicable law. However, no Internet or cellphone or other mobile transmission is completely secure, and we cannot guarantee that security breaches will not occur. Without limitation of the foregoing and except as otherwise provided by law, we are not responsible for the actions of hackers and other unauthorized third parties that breach our security procedures.
Links: The Application may contain links to other websites. Care Thread is not responsible for the privacy practices or the content of those sites. Users should be aware of this when they leave our Application and review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by the Application.
Amendments: Care Thread may modify or amend this policy from time to time. If we make any material changes, as determined by Care Thread, in the way in which Personal Information is collected, used or transferred, we will notify you of these changes by modification of this Privacy Policy, which will be available for review by you at the Application. Notwithstanding any modifications we may make, any Personal Information collected by Care Thread from you will be treated in accordance with the privacy policy in effect at the time information was collected, unless we obtain your consent otherwise.
Children: Care Thread does not knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of the Application is directed at persons under 13. If you are under 13 years of age, then please do not use the Application. If Care Thread learns that personally identifiable information of persons less than 13 years of age has been collected without verifiable parental consent, then Care Thread will take the appropriate steps to delete this information. To make such a request, please contact us at support@carethread.com.
Effective Date of this policy: October 06, 2014
