Mobile Health Consumer Privacy Policy

Last modified: July 22nd, 2020

Welcome and thank you for your interest in the Mobile Health Consumer website (“Website”) and mobile applications (“Apps”). The Website and Apps and all content, services and/or products available on or through the Website and Apps include access to a health management & wellness platform(collectively, the “Services”) are owned, operated, and brought to you by Mobile Health Consumer, Inc. (“Mobile Health Consumer” or “We”). This Privacy Policy describes our policies and procedures regarding the collection, use and disclosure of your personal information on or through Services. Mobile Health Consumer values the privacy of the visitors to the Website and users of Services (individually, “User” and collectively, “Users”), and makes it a priority to protect any personally identifiable information that it obtains from its Users.

This Privacy Policy describes what information Mobile Health Consumer gathers from you, how Mobile Health Consumer uses that information, and what Mobile Health Consumer does to protect that information. By using Services or any part thereof (whether or not you register for an account for Services), you expressly consent to the information handling practices described in this Privacy Policy. If you do not want information about you to be used in the manner set forth in this Privacy Policy, please do not access, browse or otherwise use Services or any part thereof.

Mobile Health Consumer provides a health management & wellness platform that benefits administrators, insurance carriers and insurance brokers deliver to employees through their employers. We act as a service provider to benefits administrators, insurance carriers and insurance brokers, and we receive, maintain, use, and disclose data on their behalf and limited by our agreements with them. We may also have an agreement with them that limits the purposes for which they can use the data we provide to them. We do not provide information to employers about their employees without employees’ consent, unless it is de-identified and/or in the aggregate for general management purposes. This Privacy Policy does not reflect the privacy practices of the benefits administrators, insurance carriers and insurance brokers using our platform, and we are not responsible for their privacy policies or practices. We do not review, comment upon, or monitor their privacy policies or their compliance with their respective privacy policies. We also do not review their instructions with respect to our processing of information to determine whether such instructions are in compliance or conflict with the terms of their applicable privacy policies. Please contact your benefits administrator, insurance carrier or insurance broker if you have questions about their privacy policies and practices.

The Information Mobile Health Consumer Collects:

  • User-provided Information: When you register for an account to use the Services or at any later time, you may provide to Mobile Health Consumer what is generally known as “personally identifiable information” (such as your name, password, age, gender, email address, postal mailing address, zip code, and home/mobile telephone number). Certain features of Services may permit you to upload your photo and provide certain health-related information if you so choose and if Mobile Health Consumer deems it necessary or helpful in the provision of Services or any part thereof. If you choose to provide such information, during registration or otherwise, you are giving Mobile Health Consumer the permission to use and store it consistent with this policy.
  • Information from Other Sources: Mobile Health Consumer may also obtain information, including personally identifiable information, from third parties and sources other than Services. If Mobile Health Consumer combines or associates information from other sources with personally identifiable information that it collects through Services, it will treat the combined information as personally identifiable information in accordance with this Privacy Policy.
  • “Cookies” Information: When you visit the Website, whether or not you register for an account, Mobile Health Consumer may send one or more cookies – small text files containing a string of alphanumeric characters – to your computer. Cookies remember information about your activities on a website. Mobile Health Consumer may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to the Website. Persistent cookies can be removed. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. However, without cookies you may not have access to certain services or features available on Services. Third party content displayed in connection with Services may also contain cookies set by such third party. Mobile Health Consumer does not control these cookies and you should check the privacy policy of such third party to see whether and how it uses cookies.
  • “Automatically Collected” Information: When you access or use the Website or any other part of Services, Mobile Health Consumer’s servers may automatically record certain information from your browser by using different types of technology, including standard log files, “clear gifs” or “web beacons.” Such “server logs” may include your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system and the dates and times that you visit the Website. Additionally, Mobile Health Consumer may record certain information regarding your use of features Mobile Health Consumer may make available on or through the Website, such as information regarding the services or features you have used, and your healthcare providers who have also registered for Services.
  • Third Party Web Beacons: Mobile Health Consumer may also implement third party content, such as textual or graphical links, on the Website that uses “clear gifs,” “web beacons,” or other similar techniques, which allow the third party content provider to read and write cookies to your browser, or implement similar tracking mechanisms, in connection with your viewing of that third party content displayed on the Website or otherwise made available through Services. This information is collected directly by such third party, and Mobile Health Consumer does not participate in that data transmission. Information collected by third parties in this manner is subject to that third party’s own data collection, use, and disclosure policies and Mobile Health Consumer is not responsible for, reviews or controls those policies.
  • Your communications: When you send email or other communications to Mobile Health Consumer, Mobile Health Consumer may retain such email or other communications and collect information associated with such email or other communications such as the content, date and time of such messages.

The Way Mobile Health Consumer Uses Information:

  • Mobile Health Consumer uses the information that you provide or that it collects in order to establish and enhance its relationship with you. Mobile Health Consumer generally uses such information to operate, maintain, enhance, and provide all of the features and services found on Services. Mobile Health Consumer may use the information that you provide or that it collects in order to periodically provide you with reminders about posting or submitting new data or content to your healthcare providers through Services. Mobile Health Consumer may also use your personally identifiable information to provide you with information, newsletters or offers about Mobile Health Consumer’s features and services that may be of interest to you.
  • Mobile Health uses your responses to the COVID-19 Return To Work assessment to assess the appropriateness for you to return to work based on guidelines from the Centers for Disease Control and Prevention.
  • Mobile Health Consumer uses all of the information that you provide or that it collects from Users to understand and analyze the usage trends and preferences of its Users, to improve the way Services work and looks, and to create new features and functionality.
  • Mobile Health Consumer may use “cookies” information to: (a) remember some of your information so that you will not have to re-enter it during your visit or the next time you visit the Website; and (b) monitor aggregate site usage metrics such as total number of visitors and pages viewed.
  • Mobile Health Consumer’s employees, agents and contractors must have a legitimate business reason to obtain access to the personally identifiable information you may provide to register for an account for Services. We may share your personally identifiable information with companies that provide services to us, including outside contractors or agents who help us manage our information activities, but they may only use your personally identifiable information to provide us with a specific service and not for any other purpose.

 

When Mobile Health Consumer Discloses Information to Third Parties:

  • Services may enable you to share your User Submissions, including personally identifiable information, with other Users (such as your healthcare providers). Any personally identifiable information that you choose to include in, or that is associated with, such User Submissions will be accessible by such other Users. Once you make your personally identifiable information available to others in any of these ways, it may be collected and used by the recipients without restriction. Therefore, Mobile Health Consumer strongly recommends that you think carefully about what information you transmit or post to or through Services.
  • When you access the Services through a healthcare provider, including a benefits administrator, insurance carrier or insurance broker, they access and use the information you submit through the Services so they can provide health-related services to you, such as providing health management and wellness coaching services, developing trend reporting so they can provide better services, and performing other services specified in their privacy policies and terms of service. We may sign agreements with such health care providers to help protect the privacy and security of your information.
  • When you use the COVID-19 Return to Work features, Mobile health may share information you provide with your employer. When directed by your employer, Mobile Health may also share this information with companies that are contracted with your employer to provide services.
  • Mobile Health Consumer may disclose automatically collected and other aggregate non-personally-identifiable information to third parties in order to assist such parties in understanding the usage, viewing, and demographic patterns for certain content, services, and/or functionality available on or through Mobile Health Consumer Service.
  • Mobile Health Consumer may also disclose your personally identifiable information if required to do so by law or in the good-faith belief that such action is necessary to comply with state and federal laws (such as U.S. Copyright law) or respond to a court order, judicial or other government subpoena, or warrant.
  • Mobile Health Consumer also reserves the right to disclose User information that it believes, in good faith, is appropriate or necessary to take precautions against liability; to protect Mobile Health Consumer from fraudulent, abusive, or unlawful uses; to investigate and defend itself against any third party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of Services; or to protect the rights, property, or personal safety of Mobile Health Consumer, its Users, or others.
  • In the event that Mobile Health Consumer is acquired by or merged with a third-party entity, it reserves the right, in any of these circumstances, to transfer or assign the information that it has collected from its Users as part of such merger, acquisition, sale, or other change of control. However, in such cases, Mobile Health Consumer will take reasonable steps to provide you notice before your personally identifiable information is transferred to and becomes subject to the privacy policy of a different entity.

 

Your Choices:

You may, of course, decline to enter any or all of your personally identifiable information with Mobile Health Consumer, in which case Mobile Health Consumer may not be able to provide to you some of the features and functionality found on or through Services. If you register for an account for Services, you may update, or correct, your account information and preferences at any time by going to your account settings page. To protect your privacy and security, we take reasonable steps to verify your identity before granting you account access or making corrections to your information. However, you are SOLELY responsible for maintaining the secrecy of your unique ACCOUNT AND password Information at all times. Most browsers are initially set up to accept cookies, but you can choose to configure your browser to refuse all cookies or to indicate when a cookie is being sent.

Links to Other Sites:

The Services may be linked to internet websites operated by third parties not affiliated with Mobile Health Consumer. These third-party websites may use technology to send, directly to your browser, some of the links that appear on the Website. These third parties may automatically receive your IP address if this happens. These third parties may also use other technologies (such as cookies, JavaScript, or Web Beacons) to personalize the content they send to you. You should consult the respective privacy policies of these third-party websites. Mobile Health Consumer’s Privacy Policy does not apply to, and Mobile Health Consumer cannot control the activities of, such other third party websites. Please be aware that Mobile Health Consumer does not warn you when you have chosen to link through to another website from the Website.

Our Commitment to Children’s Privacy:

Mobile Health Consumer does not knowingly collect personally identifiable information on or through Services from persons under 18 years-of-age without their parent’s or legal guardian’s consent. Services are available only to Users who are at least 18 years old or who use Services under the supervision of their parent or legal guardian. If Mobile Health Consumer learns that personally identifiable information has been collected from persons under 18 years-of-age through Services without their parent’s or legal guardian’s consent, then Mobile Health Consumer will take the appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 18 has a registered account with Services or Mobile Health Consumer has received any personally identifiable information of that child without your consent, then you may alert Mobile Health Consumer at abuse@mobilehealthconsumer.com and request that Mobile Health Consumer delete that child’s personal information and/or account from its systems.

Our Commitment to Data Security:

Mobile Health Consumer uses certain physical, managerial, and technical safeguards to help preserve the integrity and security of your personal information. These safeguards comply with the current security standards for protection of health information as required by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Mobile Health Consumer cannot, however, ensure or warrant the security of any information you transmit to Mobile Health Consumer, and you do so at your own risk. Once Mobile Health Consumer receives any information from you, it makes commercially reasonable efforts to help secure its systems. However, this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by a breach of any of Mobile Health Consumer’s physical, technical, or managerial safeguards. If Mobile Health Consumer learns of a security systems breach, then it may attempt to notify you electronically so that you can take appropriate protective steps. Mobile Health Consumer may post a notice on or through Services if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

International Visitors:

Services are intended solely for Users located within the United States. If you nonetheless choose to use the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personally identifiable information outside of those regions to the United States and by providing your personally identifiable information on or through the Service you consent to that transfer.

Changes and Updates to this Privacy Policy:

This Privacy Policy may be revised periodically without further notice to you and this will be reflected by a “Last modified” date above. Please revisit this page to stay aware of any changes. Your continued use of Services constitutes your agreement to this Privacy Policy and any future revisions.

Contact Information: Please contact Mobile Health Consumer with any questions or comments about this Privacy Policy, your personal information, or your consent choices by email at info@mobilehealthconsumer.com or by mail at: Mobile Health Consumer Privacy Officer, 1730 South Amphlett Blvd., Suite 200, San Mateo, CA 94402