Privacy Statement

HealthTap Technologies, Inc. Privacy Statement

In this Privacy Statement, "HealthTap or "we" refers to HealthTap Technologies, Inc.

What is this document?

This Privacy Statement describes what personally identifiable information you can share with us on this website (the "Site") or our other mobile and related services (e.g., your date of birth or some aspect of your medical condition), how that information is stored, how we use that information, and what information other members and doctors can see when they use HealthTap and HealthTap Prime. For a description of our services (including HealthTap and HealthTap Prime), please read our Terms of Use.

For the purpose of this Privacy Statement, "Personally Identifiable Information" means any information that, by itself or in combination with other information, identifies or can reasonably be used to identify an individual, such as their name, email address, telephone number, address, or date of birth. Personally Identifiable Information does not include information that is anonymized, or publicly available information that has not been combined with non-public Personally Identifiable Information.

HealthTap complies with the EU-U.S. Privacy Shield Framework and/or the Swiss-U.S. Privacy Shield Framework(s), as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and/or Switzerland, to the United States. HealthTap has certified to the Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. The HealthTap Privacy Shield notice is published at Privacy Shield Program Notice.

Why should I read this Privacy Statement?

When you sign up for or use HealthTap, we ask you to confirm that you've read and agree to our Privacy Statement. This means that by submitting Personally Identifiable Information and other information to the Site, you consent to the collection, use, and disclosure of such information as set out in this Privacy Statement.

What information do we collect?

Generally, you may browse the Site and/or our applications without providing any Personally Identifiable Information. However, we ask that you provide information at various times and locations through the Site.

This section sets out what Personally Identifiable Information we may collect from you when you use our services:

Information you store on your Profile

We collect information you provide when you create a HealthTap account, including your name, email address, and date of birth. You can add optional health information to your HealthTap Profile ("Profile"), for example personal information, health goals, medications, conditions, and other information, which helps to personalize your HealthTap experience. You choose what health information to add to your Profile when using HealthTap and adding information into your Profile.

Information provided on HealthTap Premium Services

If you decide to sign up for HealthTap Premium Services, including Prime and Concierge, we ask you to provide additional information, including payment information. For more information on HealthTap Premium Services, please consult our Terms of Use.

Information provided in Virtual Consults

At the end of every successfully-completed virtual consult (meaning a consultation between a doctor and a patient through a HealthTap service using a video link), the doctor with whom you have had your virtual consult will prepare a brief doctor's note about the virtual consult (the "Consult Summary"). These Consult Summaries become part of your Profile. When you initiate Virtual Consults on HealthTap, the doctor you see will be able to view all of the Consult Summaries on HealthTap.

Why do we ask you for certain types of information?

Health conditions and appropriate actions often depend on your age group, geography, and gender. This data helps us to provide you with a personalized online health experience. Your Personally Identifiable Information is not visible to other members or doctors on HealthTap. This data is only visible to doctors you connect with using HealthTap Premium Services (including Prime and Concierge).

How do we use your information?

We will use your Personally Identifiable Information only for the purpose for which it was provided, as well as other purposes for which you have given consent. This includes, but is not limited to, the following purposes:

  • Administration of your Profile: We use your profile information and your health and wellness goals to help you better understand, stay engaged with, and track your health and to present you with personalized, relevant information. Your email address is used to create, log into, and manage your account on HealthTap.
  • Connecting with doctors: We use the information you provide to help you find or connect with doctors.
  • Marketing: You may subscribe or unsubscribe to receive marketing communications from us, such as announcements of new features. Please note that we have a strict "No-Spam" policy. We do not share email addresses or other contact information with third parties without your permission.
  • Notifications: We will ask you if you want to receive notifications when you open an account with HealthTap. If you agree, HealthTap may send you email, SMS, or mobile push notices, providing you with account-related reminders or updates, or letting you know that you have a message on HealthTap.

We also may use your Personally Identifiable Information to comply with our legal obligations, resolve disputes, and enforce our agreements, as required and/or allowed by applicable privacy laws.

Automated decision making and profiling

We use any relevant information in your health profile to generate better answers to your health questions. For example, we use the information you provide about your medical condition to better triage your symptoms. Your experience on the site and/or our applications is tailored to you based on the profile information you provide. The information you provide is not used for advertising.

Disclosing Personally Identifiable Information to Third Parties

When providing our Services, our members choose the types of Personal Information we process and the purposes of the processing. Accordingly, our affiliated service partners, e.g.- prescription services, are sometimes responsible for providing notice to members. In the event Personal Information is (i) to be used for a purpose that is materially different from the purposes for which the Personal Information was originally collected or subsequently authorized, or (ii) transferred to a third party acting as a data controller, members will be given, where practical and appropriate, an opportunity to opt out of having their Personal Information so used or transferred where it involves non-sensitive information. Where such use or transfer involves sensitive information, members must opt-in before such use or transfer.

With whom do we share your Personally Identifiable Information?

In some instances we may retain other companies and individuals to perform functions on our behalf, including, but not limited to, website developers, IT services providers, shipping or direct mail organizations, storage facilities, or parties assisting us in a recruitment process.

Such third parties may be provided with access to your Personally Identifiable Information to perform the functions for which they have been retained. Our agreements with these third parties will not permit them to use your Personally Identifiable Information for any other purposes and commit them to comply with applicable data privacy standards.

We further may disclose any information, including Personally Identifiable Information, we deem necessary, in our sole discretion, to comply with any applicable law, regulation, legal process or governmental request.

Who else can see your Personally Identifiable Information?

All Personally Identifiable Information is stored securely in your Profile, which is not visible to other users or doctors on HealthTap. Revealing Personally Identifiable Information in content publicly visible on HealthTap (such as in public questions) is not permitted under our Terms of Use.

Also, the questions you may enter on HealthTap are anonymous. Only the questions, not your identity,are publicly visible.

Are HealthTap Premium Services anonymous?

Like an in-person patient-doctor interaction, HealthTap Prime and HealthTap Concierge are confidential but not anonymous services. When using Premium Services, some Profile information (including your real name and health information from your Profile) is visible to doctors with whom you enter into virtual consults.

Your personal contact information is never visible on HealthTap to other members or doctors.

By using HealthTap Premium Services (including Prime and Concierge), you consent to sharing your name and the health information in your Profile with the doctors with which you interact when using these services.

Accountability for Onward Transfer of Personal Information

HealthTap may transfer Personal Information for the purposes described in the HealthTap Privacy Statement to a third party acting as a data controller or as an agent. If we intend to disclose Personal Data to a third party acting as a data controller or as an agent we will comply with, and protect, Personal Information as provided in the Accountability for Onward Transfer Principle. When providing our Services, we disclose Personal Information as provided in our agreement with members.

We remain responsible for the processing of Personal Information received under the Privacy Shield and subsequently transferred to a third party acting as an agent if the agent processes such Personal Information in a manner inconsistent with the Principles, unless we prove that we are not responsible for the event giving rise to the damage.

By sending Personally Identifiable Information to us, you acknowledge and consent that your data will be transferred across national borders, including to countries outside the EU/EEA.

Security

HealthTap and HealthTap Premium Services use industry-standard security safeguards, such as encryption in transit and at rest.

HealthTap meets HIPAA security standards for all interactions subject to HIPAA security regulations. We use a variety of technologies and procedures to help protect the security of your Personally Identifiable Information from unauthorized access, use, or disclosure. HealthTap takes reasonable and appropriate precautions, considering the risks involved in the processing and the nature of the Personal Information, to help protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Public Content

Some content on HealthTap is publicly visible by logged in or logged out users ("Public Content"). Any information provided in Public Content might be read, collected, and used by others who access them. Please note that our Terms of Use do not allow you to include Personally Identifiable Information (such as your name, email address, or phone number) in any Public Content posted to HealthTap. HealthTap cannot control how Public Content is seen or used.

Contact our support team to request removal of such information.

Sharing on social media

You can share certain information from HealthTap using the sign-in services of certain social media services such as Facebook and Twitter. Please consider any impact on your privacy and anonymity when posting content to public services. Content posted to these services will be governed by the respective privacy policies of those services.

How can I update my data?

You can add, edit, or delete optional information appearing in your Profile at any time in your account settings ("Settings"). You can edit, but not remove, certain information (like an email address) required for login and to use HealthTap, and doctor consult notes. You can amend your health records and can add information to your consult notes or health record to make it more accurate or complete, or have a disagreement with notes. Accordingly, if you want to request access, or to limit use or disclosure of your Personal Information, please contact the company to which you submitted your Personal Information and that uses our Services. If you contact us with the name of our customer to which you provided your Personal Information, we will refer your request to that customer and support them in responding to your request.

Deactivation

To deactivate your account, simply sign in, go to Settings, and deactivate your account. You will receive an email confirming that your account has been deactivated. Please note: your public questions that have received answers will continue to appear anonymously on HealthTap after account deactivation.

Your California Privacy Rights

California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes.

Children

Our Site and/or Apps are not intended for children under 13 years of age. No one under age 13 may provide any information to us through the Site. We do not knowingly collect Personally Identifiable Information from children under 13. If you are under 13, do not access, use, or provide any information on the Site or on or through any of its features. If we learn we have collected or received Personally Identifiable Information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us.

Cookies

A "cookie" is a data element that a website can send to your browser, which may then be stored on your system. We use different kinds of cookies on the Site. For detailed information, please see our Cookie Policy.

Google Services

On the Site, we use several services provided by Google:

Google Analytics

This Site uses Google Analytics, a web analytics service provided by Google, Inc. ("Google").

Google Analytics uses "cookies", which are text files placed on your computer, to help our, Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage to the website provider. Google will not associate your IP address with any other data held by Google.

You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use the full functionality of our Site. Furthermore, you can prevent Google's collection and use of data (e.g., cookies and IP address) by downloading and installing the browser plug-in available under:

https://tools.google.com/dlpage/gaoptout?hl=en-GB

Further information about how Google uses advertising cookies can be found at:

http://www.google.com/analytics/terms/gb.html

Google Maps

Additionally, because we use visual mapping services on the Site and/or our applications, please be aware that the Google Maps/Earth Terms of Service, including the Google Privacy Policy, at https://www.google.com/intl/en-US_US/help/terms_maps.html also applies.

Third- Party Sites

Our Site may contain links to other third-party sites. When you click on one of these links you are visiting a website operated by someone other than HealthTap, and the operator of that website may have different privacy policies. HealthTap is not responsible for the individual privacy practices of those sites. We encourage you to investigate the privacy policies of these third-party operators.

How Long We Store Your Personally Identifiable Information

Personally Identifiable Information will be stored as long as the information is required to fulfill our legitimate business needs or the purposes for which the information was collected, or for as long as is required by law.

Contacting us

You may reach us via email at [email protected] or you may write to us at our most current address. Please see our "CUs" page for current information.

Revisions to this Privacy Statement

We reserve the right to change this Privacy Statement at any time whereby relevant changes take effect for the future. The applicable version of this Privacy Statement is available on the Site.

Date last modified: Nov 15, 2018