Updated: April 30, 2023
Information we collect about you
- Some Personal Information we collect may constitute protected health information under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). As set forth above, your Provider will provide you with a Notice of Privacy Practices describing their collection and use of your health information, not QuickMD. We will only collect and use protected health information for the purposes of providing the Services and we only collect the minimum amount necessary to fully perform and provide the Services on our Platform. We may combine your protected health information with Personal Information that we have either obtained from you or through a third-party, such as your Provider, health insurer, employee benefits program, or other health care providers. Protected health information will not be used for any other purpose, including marketing, without your consent.
How we use your information
How we share your information
- We may share your information with our business units, affiliates, subsidiaries, business partners, service providers and/or your representatives, in order to provide or improve our Services to you.
- If applicable to you, you acknowledge that you have signed a valid HIPAA authorization (the “HIPAA Authorization”) with your health care provider. With this HIPAA Authorization, we may share certain information with your electronic health record (“EHR”) and those parties that have access to your EHR in order to provide or improve our Services to you.
- We do not share information with third parties so that they can independently market their own products or services to you unless you have chosen to engage with that third party. We will never sell your Personal Information to any third party.
Your Rights Regarding Your Personal Information
- We provide you with the opportunity to be informed of whether we are processing your information and to access, correct, update, oppose, delete, block, limit or object to, upon request and free of charge, our use of your Personal Information to the extent required by applicable law.
Retention of your information
- We keep your account information, like your name, email address, and password, for as long as your account is in existence because we need it to operate your account. In some cases, when you give us information for a feature of the Services, we delete the data after it is no longer needed for the feature. We keep your account data until you use your account settings or tools to delete the data or your account because we use this data to provide you Services. We also keep information about you and your use of the Services for as long as necessary for our legitimate business interests, for legal reasons, and to prevent harm, including as described in the How We Use Your Information and How We Share Your Information sections.
Security of your information
- We work hard to keep your data safe. We use a combination of technical, administrative, and physical controls to protect the confidentiality, integrity and availability of your data. No method of transmitting or storing data is completely secure, however.
- If you have a security-related concern, please contact Customer Support.
Cookies and similar Technologies
Marketing Analytics and Communications
Links to Other Websites
Our Policies for Children
- Our Sites and Mobile Apps are directed toward adults. If you are under the age of 18, or if you otherwise are not of legal age to form a binding contract in your jurisdiction of residence, you must obtain the authorization of a responsible adult (parent or legal custodian) before using or accessing our Sites and Mobile Apps. We will not knowingly collect or use any personal information from any children under the age of 16. Such persons are prohibited from using our Sites and Mobile Apps. If we become aware that we have collected any personal information from children under 16, we will promptly remove such information from our systems.
How to contact us
- If you have questions, suggestions, or concerns about this policy, or about our use of your information, including filing a complaint, please contact our customer service.
INFORMATION WE COLLECT ABOUT YOU
When you use our Services, we collect the following types of information.
INFORMATION YOU PROVIDE US (“PERSONAL INFORMATION”)
Some information is required to create an account on Services, such as your:
- email address
- phone number
You provide this information to us directly by completing fillable webforms on the Services and submitting the information to us.
To help improve your experience or enable certain features of the Services, you may choose to provide us with additional information, such as
- ID information
- profile information (such as a biography),
- country information,
- date of birth,
- demographic information (such as date of birth gender, height, weight and geographical residence location),
- test results as provided by third parties,
- additional health and medical information and logs,
- community or social media username, and
- messages and media on discussion boards or to your social contacts on the Services.
If you contact us or participate in a survey, contest, or promotion, we collect the information you submit directly from you such as your name, email address, contact information, and message.
INFORMATION FROM THIRD-PARTY SERVICES
- If you choose to connect your account on our Services to your account on another service, we may receive information from the other service. For example, if you connect to Facebook or Google, we may receive information like your name, profile picture, age range, language, email address and friend list.
- You may also choose to grant us access to your personal information such as activity data or health data from other services. You can stop sharing the information from the other services with us by removing our access to each other service. However, we will store historical data that has already been collected unless you opt-out.
INFORMATION PROVIDED BY OTHER INDIVIDUALS
PAYMENT AND CARD INFORMATION
Some Company Services support payments and transactions with third parties. We do not store your payment information. We use a third-party service provider to manage payment card processing. Note that third-party payment processors may retain this information in accordance with their own privacy policies and terms. This service provider is not permitted to store, retain or use information you provide except for the sole purpose of credit card processing on our behalf.
INFORMATION WE RECEIVE FROM YOUR USE OF OUR SERVICES
USAGE AND DEVICE INFORMATION
When you use our Services, we receive certain usage data (“Usage and Device Information”). This includes information about your interaction with the Services, for example, when you view or search content, install or open applications or software, create or log into your account, import data into your account, or integrate a third-party service to your account.
We may also collect data about the devices and computers you use to access our Services, including IP addresses, browser type, language, operating system, or mobile device information (including device and application identifiers), the referring web page, pages visited, location (depending on the permissions you have granted us), and cookie information.
HEALTH AND OTHER SPECIAL CATEGORIES OF PERSONAL DATA
To the extent that information we collect directly from you or pulled from your connected EHR is health data or another special category of sensitive personal data subject to the European Union’s General Data Protection Regulation (“GDPR”), we ask for your explicit consent to process such sensitive personal data. We obtain this consent separately when you take actions leading to our obtaining the data, for example, when you enter in health survey data or grant us access to your health or activity data from another service. You can use your account settings or contact us to withdraw your consent at any time by requesting deletion your data or closing your account.
HOW WE USE YOUR INFORMATION
We use the information we collect for the following purposes:
PROVIDE AND MAINTAIN THE SERVICES
We use the information we collect to deliver the Services to you and honor our Terms of Service for each Service or business contract with you. For example,
- to administer, operate, maintain and secure our Services;
- to monitor and analyze trends, usage and activities in connection with our Services;
- to calculate metrics in the Application such;
- for accounting, recordkeeping, backup and administrative purposes;
- to customize and improve the content of our communications, websites and social media accounts;
- to provide customer service and support, service requests sent through the platform, requesting feedback, surveys, requesting testimonials about the Service;
- to communicate with you, including responding to your comments, questions and requests regarding our Services; and
- to process and complete transactions, and send you related information, including alerts and notifications about your service, purchase confirmations and invoices; and
- to educate and train our workforce in data protection and customer support.
· compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
IMPROVE, PERSONALIZE, AND DEVELOP THE SERVICES
We use the information we collect to improve and personalize the Services and to develop new ones. For example, we use the information to troubleshoot and protect against errors; perform data analysis and testing; conduct research and surveys and develop new features and Services.
We may use the information collected about you and your use of the Services to provide you with generalized health and wellness notifications and information that may be of interest to you.
COMMUNICATE WITH YOU
We use your information when needed to send you Service notifications and respond to you when you contact us. We also use your information to promote new features or products that we think you would be interested in as well as request feedback, user surveys, and testimonials. You can control marketing communications and most Service notifications by using your notification preferences in account settings or via the “Unsubscribe” link in an email or sending a message to customer support.
We may also contact you to provide feedback on the Service such as taking surveys or providing testimonials.
CONNECTING YOU TO OTHERS’ PRODUCTS AND SERVICES
We also use the information we collect about you and your use of our Services to provide you with targeted, personalized advertising and promotional information about offers, services or products of third parties that may be of interest to you. We do not share your personal information with third parties in connection with this targeted advertising and promotion (although you may choose to share your information with such third parties if you choose to access the third party’s website, click on the link in an advertisement, contact the third party in regards to the offer or otherwise communicate with the applicable third party whose products or services are being promoted).
Additionally, if you ask us to share your information with a third party provider of products or services, we may transmit information about you to such third party provider and otherwise facilitate your direct communications with such third party providers through our Services or through other communications channels with the third party provider. For example, you may choose to use the Services to associate and connect with an organization (such as in the case of researchers, public health initiatives, healthcare organizations, employers, etc.) in which case we will provide your information to that organization.
ORDERING LAB TESTS OR OTHER SERVICES FROM OUR PARTNERS
Through the Services, we provide certain interfaces that enable you to (1) order lab tests or other services directly from certain third party providers that we have partnered with, and/or (2) view and store within the Services certain information provided from certain third party providers that we have partnered with. If you choose to use the Services in this manner, we may transmit some or all of the following information to the third party provider you have chosen to interact with:
- Your name
- Your e-mail address and other contact information (such as your mailing address, telephone number or mobile telephone number)
PROMOTE SAFETY AND SECURITY
We use the information we collect to promote the safety and security of the Services, our users and other parties. For example, we may use the information
- to authenticate users;
- to facilitate secure payments;
- to respond to a legal request or claim, conduct audits, and enforce our terms and policies;
- to investigate and protect against fraud, malicious or unauthorized access, and other illegal activities; and
- to demonstrate and verify compliance with our internal policies and procedures, and applicable privacy and data security laws and regulations, such as HIPAA and GDPR.
USE AND DISCLOSURE OF DE-IDENTIFIED INFORMATION
“De-identified” means that we have removed, or rendered unreadable through complex computational algorithms, your personally-identifiable information, such as your name, address, or birthdate. We may use de-identified information that we have obtained from our Services for various purposes, including for example:
- In accordance with regulatory requirements, we may de-identify, store and use your information for internal quality control, validation and research and development. This is important for Company to maintain high quality Services. We may use de-identified information as permitted by law.
- We may use or disclose de-identified information for general research and communications purposes. This may include analysis of this information to communicate observations and learnings, for example in the case of aggregated data. This may also include research collaborations with third parties, such as universities, hospitals or other laboratories, in which we utilize de-identified clinical cases, at the individual level or in the aggregate, in accordance with our study protocols, and we may present or publish such information. This may also include commercial collaborations with private companies for purposes such as to determine the prevalence of particular disorders or variants among the patients we have tested, or to determine whether any of the patients we have tested might be suitable for potential recruitment for research, clinical trials, or clinical care.
For personal data subject to the GDPR, we rely on several legal bases to process the data. These include when you have given your consent, which you may withdraw at any time using your account settings and/or other tools; when the processing is necessary to perform a contract with you, like the Terms of Service; and our legitimate business interests, such as in improving, personalizing, and developing the Services, marketing new features or products that may be of interest, and promoting safety and security as described above.
HOW WE SHARE YOUR INFORMATION
We do not share your personal information except in the limited circumstances described below.
WHEN YOU AGREE OR DIRECT US TO SHARE
You may direct us to disclose your information to others, such as when you use our social features in our Mobile Apps or as described in the section above titled “Connecting You to Others’ Products and Services”. For certain information, you may change your privacy preferences in account settings and use other provided tools to control how your information is visible to other users of the Services.
You may also authorize us to share your information with others, for example, with a third-party application when you give it access to your account, or with your employer company or other organizations and provide consent to each organization. Remember that their use of your information will be governed by their privacy policies and terms. You can revoke your consent to share with third-party applications or employee wellness programs using your account settings.
FOR EXTERNAL PROCESSING
We transfer information to our corporate affiliates, service providers and other partners who process it for us, based on our instructions and in compliance with this policy and any other appropriate confidentiality and security measures and laws. These partners provide us with services globally, including for customer support, information technology, payments, sales, marketing, data analysis, research and surveys.
FOR LEGAL REASONS OR TO PREVENT HARM
We may preserve or disclose information about you to comply with a law, regulation, legal process or governmental request; to assert legal rights or defend against legal claims; or to prevent, detect or investigate illegal activity, fraud, abuse, violations of our terms or threats to the security of the Services or the physical safety of any person.
Please note: Our policy is to notify you of legal process seeking access to your information, such as search warrants, court orders or subpoenas, unless we are prohibited by law from doing so. In cases where a court order specifies a non-disclosure period, we provide delayed notice after the expiration of the non-disclosure period. Exceptions to our notice policy include exigent or counterproductive circumstances, for example, when there is an emergency involving a danger of death or serious physical injury to a person.
We may share non-personal information that is aggregated or de-identified so that it cannot reasonably be used to identify an individual. We may disclose such information publicly and to third parties, for example, in public reports about exercise and activity, to partners under agreement with us or as part of the community benchmarking information we provide to users of our subscription services.
IN CONNECTION WITH A MERGER, ACQUISITION OR SALE OF OUR ASSETS
We may disclose your personal information to a buyer or other successor to our business in the event of a sale of equity or assets, reorganization, merger or a similar corporate transaction and any due diligence review with respect to any such proposed transaction. If we are involved in such a transaction or related due diligence activities, we will continue to take measures to protect the confidentiality of personal information and give affected users notice for the transferring of any personal information to a new entity.
NO SALES OF PERSONAL INFORMATION
We do not sell your personal information to third parties (within the meaning provided in the California Consumer Privacy Act of 2018) and will not do so in the future without separately obtaining your prior express consent.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
You can access and control your personal information via account settings and/or our tools we provide to you, regardless of where you live.
REQUEST TO KNOW AND REQUEST TO DELETE
Subject to certain exceptions set forth under the California Consumer Privacy Act of 2018, you have a right to request that we disclose to you (and, if requested, to receive a portable copy of) the personal information about you that we collect, use, disclose and sell to third parties (a “Request to Know”), and you have a right to request that we delete your personal information that we have collected or that we maintain (a “Request to Delete”). You may submit a Request to Know or Request to Delete by contacting us at customer support.
Upon receipt of your Request to Know or Request to Delete, we will take steps to verify your identity in order to confirm that the person making the request is actually the person about whom we have collected personal information (that the “you” making the request is actually you). We verify such requests by asking users to log in to their existing password-protected accounts on the Site or the Mobile App and re-authenticate themselves by re-entering their user name and password. If you choose to submit your Request to Know or Request to Delete using the telephone number or webform described above, we will respond (for verification purposes) by providing detailed instructions directing you to log in to your existing password-protected account on the Site or the Mobile App, access the self-service portal we have provided for you there (as described above), and re-authenticate yourself by re-entering your user name and password. If you choose to submit your Request to Know or Request to Delete by logging in to your password-protected account on the Site or the Mobile App and accessing the self-service portal we have provided for you there (as described above), then for verification purposes we will ask you to re-authenticate yourself by re-entering your user name and password.
If you have submitted a verified Request to Delete, please note that while most of your information will be deleted within 14 days, it may take up to 90 days to delete all of your information, such as the data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. We may also preserve data for legal reasons or to prevent harm, including as described in the How We Share Your Information section.
You may also designate an authorized agent to make a Request to Know or Request to Delete on your behalf. To designate an authorized agent to act on your behalf in this manner, you or your authorized agent must submit verifiable proof (acceptable to us, acting in our reasonable discretion) that either (1) such agent has actually been authorized in writing to act on your behalf, or (2) you have provided the authorized agent with power of attorney pursuant to the applicable laws in your jurisdiction. If a duly-designated authorized agent makes a Request to Know or Request to Delete on your behalf, we will still require you to verify your own identity using the process described above, unless you have submitted verifiable proof to us that you have provided the authorized agent with power of attorney (in which case your submission to us of verifiable proof that you have provided the authorized agent with power of attorney, as described above, will serve as the required verification of your identity for purposes of processing the Request to Know or Request to Delete).
Chief Privacy Officer