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Privacy Policy

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Privacy Policy

Effective Date: September, 2022

Skelehealth LLC (“Skelehealth,” the “Company,” “we,” or “us”) respects your privacy and we want to be transparent about how we collect, use, and disclose information that we collect. 

Here we describe the privacy practices for our devices, applications, software, websites, social media pages, emails, APIs, products, and services (the “Services”). If you are a Skelehealth client through your healthcare provider, health plan sponsor, insurer, pharmaceutical partner, or related organization or company (each a “Skelehealth Partner Company”), this Privacy Policy is not intended to modify or supersede any privacy policy provided by your Skelehealth Partner Company. We handle all information in compliance with applicable laws and in a manner compliant with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), where applicable. Where we receive Protected Health Information in our role as a Business Associate of your healthcare provider, health plan sponsor, insurer or similar obligation, this Skelehealth Privacy Policy does not apply; we will process your information consistent with the obligations in the Business Associate Agreement.

Please read this policy carefully. If you do not agree with our policies or practices do not use our Services. By downloading, registering, or using our Services, you agree to this privacy policy. This policy may change from time to time. Your continued use of our Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

CHILDREN UNDER 13

Our Services are not intended for children under 13 years of age, and we do not knowingly collect information from children under 13. If we learn we have collected or received personal 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 at privacy@skelehealth.com.

CHILDREN OVER 13 AND UNDER 18

This App is only available for individuals aged 13 years or older. If you are 13 or older but under the age of 18, you should review this privacy policy with your parent or guardian to make sure that you and your parent or guardian understand it.

INFORMATION WE COLLECT

When you use our Services, we collect the following types of information both directly from you when you provide it to us, and automatically when you use our Services.

Personal Information:

  • Identifiers – including real name, alias, date of birth, postal address, unique personal identifier, online identifier, internet protocol address, email address, phone number, account name or other similar identifies;
  • Demographic information – including age, gender, and other personal information that may be considered a protected classification characteristic under California or federal laws.
  • Internet or other electronic network activity information – including how you interact with the Services and, if you link your information associated with your social media account such as your name, username, email address, gender, profile picture, etc. 
  • Geolocation data.
  • Audio, electronic, visual, or similar information
  • Records and copies of your correspondence if you contact us
  • Professional or employment-related information

Personal Health Information:

We may collect information regarding your prescriptions, diagnoses, medications, medical history, and other healthcare-related information.

HOW WE COLLECT INFORMATION

Information You Share With Us:

We collect information directly from you (e.g. when you register for the Services or interact with certain Skelehealth features such as assessments, the artificial intelligence-based chatbot, the product matrix and click-throughs to third parties within our Services)

Information We Collect Automatically:

Information is collected from your devices (e.g., when you connect to the Services, your device shares information about you and your session). If you do not want us to collect this information, do not download the App or delete it from your device.

  • Usage Details: When you access and use the Services, we may automatically collect including traffic data, location data, logs and other communication data and the resources that you access and use.
  • Device Information: We may collect information about your device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information and the device’s telephone number.
  • Location Information: Some Services collect real-time information about the location of your device.
  • Communications: The Services allow for SMS/MMS and secure texting between a patient and provider. We will store any and all communications sent. We are a business associate for the purpose of the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Accordingly, we will enter into a Business Associate Agreement with each covered entity for the protection of all communications containing personal health information (PHI) as that term is defined under HIPAA and will enter into a Business Associate Agreement with any subcontractors of the Company that have access to PHI including, but not limited to, cloud storage service providers.

Information You Direct Us To Receive From Third Parties:

Information is sourced from public databases, where permitted by law, or from third-party private sources, such as data brokers or our business partners when applicable.

Information Collection and Tracking Technologies:

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies): A cookie is a small file placed on your smartphone or computer. It may be possible to refuse to accept cookies by activating the appropriate setting on your device. However, if you select this setting you may be unable to access certain parts of our Services.
  • Web Beacons: Pages of the Services may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

HOW WE MAY USE PERSONAL INFORMATION 

Providing The Services:

  • To provide the Services’ functionality to you, such as arranging access to your registered account and providing you with customer service;
  • Respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints, or when you request other information about our Services;
  • Verify your information and provide related customer service; 
  • Send you administrative information, such as changes to our terms, conditions and policies; or to give you notices about your account; and
  • Allow you to send messages to another person through the Services.

Providing You With Information About Our New Services And/Or Marketing Materials And Facilitate Social Sharing:

  • To send you marketing related emails with information about our services, new products and other company news; and
  • To give you the ability and option for social sharing on your preferred platform.

Improving Our Services: 

  • We may use your personal information in order to improve our Services; and
  • Estimate our audience size and usage patterns.

Providing Personalized Services: 

  • To better understand your interests and preferences so we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
  • Locate physicians and availability in your area; and 
  • Recognize you when you use the Services.

Aggregating And/Or Anonymizing Personal Information: 

  • We may aggregate and/or anonymize personal information so that it will no longer be considered personal information.

Accomplishing Our Business Purposes:

  • For data analysis to, for example, improve our efficiency
  • For audits to verify that our internal processes function as intended and to address legal, regulatory or contractual requirements
  • For fraud prevention and security monitoring to, for example, detect and prevent cyberattacks and identity theft
  • For developing new products and services
  • For enhancing, improving, repairing, maintaining or modifying our current products and services, as well as undertaking quality and safety assurance measures
  • For identifying usage trends or determining the effectiveness of our promotional campaigns

DISCLOSURE OF PERSONAL INFORMATION

We may disclose aggregated information about our users, and information that does not identify any individual without restriction. In addition, we may disclose personal information that we collect or you provide with

Affiliates: 

We may share your data with our affiliates for the purposes described in this Privacy Policy. Note, however, that Skelehealth does NOT sell personal information to third parties. 

Partners: 

We may share your data with other companies, such as companies with whom we jointly offer our Services and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

Third Party Service Providers: 

We may share personal information with certain service providers whose services and solutions complement, facilitate and enhance our own. These include hosting and server services, communications and content delivery networks (CDNs), data and cybersecurity services, performance measurement services, data optimization and marketing services, content providers and our legal and financial advisors. Such service providers may have access to personal information according to their particular roles and purposes. 

Information You Share: 

Skelehealth enables you to share your personal information with others, including healthcare providers, friends and contacts via social media, our app, or other platforms. Please use caution when sharing your personal information with others. The information you share will be shared according to your instructions and actions, and we have no control over what happens with your information once you share it with others. 

OTHER USES AND DISCLOSURES OF PERSONAL INFORMATION

Applicable Law: 

We may share personal information to comply with applicable law and regulations, which may include laws outside your country of residence. 

Transaction, Liquidation: 

We may share personal information with third parties in connection with a transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business, or in the event of a bankruptcy or related or similar proceedings. 

Public and Government Authorities, Law Enforcement: 

Where permitted or required by applicable data protection laws, we may disclose your personal information pursuant to a legal request or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you. 

Protecting Rights and Safety: 

Where permitted or required by law, we may share your personal information with others if we believe in good faith that it will help protect the rights, property or personal safety of Skelehealth, any of our users or any member of the general public, with or without notice to you. 

Protected Health Information (PHI): 

Notwithstanding the foregoing, we shall not disclose your PHI to any third party, unless required by law or to a third party subcontractor with an executed business associate agreement. We shall not disclose any personal information to any third party for marketing purposes.

YOUR CHOICES REGARDING PERSONAL INFORMATION 

Email, SMS Messaging: 

We may use your email address or phone number to send you messages, such as feature changes and special offers. If you do not want to receive such notifications, you may opt-out or change your preferences by contacting our support team at privacy@skelehealth(dot)com. Subject to regulatory requirements, opting out may prevent you from receiving notification including notices regarding updates, improvements or offers. We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out. 

Marketing: 

We give you choices regarding our use and disclosure of your personal information for marketing purposes. 

Tracking Technologies:

You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of our Services may then be inaccessible or not function properly.

Tracking Technologies:

You can choose whether or not to allow the App to collect and use real-time information about your device’s location through the device’s privacy setting. If you block the use of location information some parts of the App may then be inaccessible or not function properly.

ACCESS, CHANGE, OR DELETE YOUR PERSONAL INFORMATION

If you would like to request to access, correct, update, suppress, restrict or delete personal information, object to or opt out of the processing of personal information, or if you would like to request a copy of your personal information for purposes of transmitting it to another company (to the extent these rights are provided to you by applicable law), you may contact us per the “Contact Us” section below or email us at privacy@skelehealth(dot)com. We will respond to your request consistent with applicable law.

In your request, please clarify what personal information you would like to have changed or whether you would like to have your personal information suppressed from our database. We may need to verify your identity before implementing your request. We will comply with your request to the extent required by applicable law. If you are a California resident, please refer to the “Information for California Residents” section at the end of this Privacy Policy for more information about the requests you may make under California law.

THIRD-PARTY WEBSITES 

Our Services may contain links to third-party owned and/or operated websites. Skelehealth is not responsible for the privacy practices or the content of such websites. Third-party websites have separate privacy and data collection practices, and Skelehealth has no responsibility or liability relating to them. 

ONLINE ADVERTISING 

We use third-party advertising companies to serve advertisements regarding goods and services that may interest you when you access and use the Services and other websites or online services. You may receive advertisements based on information relating to your access to and use of the Services and other websites or online services on any of your devices, as well as on information received from third parties. These companies place or recognize a unique cookie on your browser (including through the use of pixel tags). They also use these technologies, along with information they collect about your online use, to recognize you across the devices you use, such as mobile phones and laptops. For more information about this practice and how to opt out, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#/. You also may download the AppChoices app at www.aboutads.info/appchoices specifically for mobile.

HOW WE MAY USE COOKIES AND OTHER TRACKING TECHNOLOGIES

When providing our Services, we may use cookies and similar tracking technologies for the purposes set out below. These technologies can track web activity over time and across third-party services. Cookies and local storage may be set and accessed on your computer. Upon your first visit to the Website and Services, a cookie or local storage may be sent to your device that uniquely identifies your browser. (Cookies and local storage are small files containing a string of characters sent to your computer’s browser and stored on your device when you visit a website. Many web-based services use cookies to provide useful features for their users. Each website can send its own cookie to your browser. Most browsers are initially set up to accept cookies.) If you do not want cookies, you may set your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you reject cookies, you will not be able to sign into or take full advantage of our Services. Additionally, if you clear all cookies on your browser at any point after setting your browser to refuse all cookies or indicate when a cookie is being sent, you will need to reset your browser to refuse all cookies or indicate when a cookie is being sent. Learn more about cookies at http://www.allaboutcookies.org/.

To support our Services, we may use one or more of the following cookie and tracking technologies for the purposes set forth below: 

TYPES OF TRACKING TECHNOLOGIES AND PURPOSES: 

For more information, please visit www.allaboutdnt.com.

Analytics and Performance Cookies: 

To collect information about how and when our Services are accessed. We use this information to help operate our Services more efficiently, to gather broad demographic information and monitor activity levels. Note that we also use Google Analytics for this purpose. Google Analytics uses its own cookies. Learn about Google Analytics cookies here and Google’s own privacy policy here. You can prevent the use of Google Analytics relating to your use of our Services by downloading and installing the browser plugin available here: Google Analytics Opt-out Browser Add-on.

Essential Cookies: 

To provide our Services to you. For example, essential cookies allow you to log into secure Services areas and help load content quickly. Without these cookies, Services you requested could not be provided.

Functionality Cookies: 

To allow our Services to remember your user choices, such language preferences, login details, polls you voted in, poll results and any other customizable parts of our Services.

Social Media Cookies: 

Used when you share information from our Services to your social media account(s). This may include selecting “share” or “like” from our Services platform or engaging with our content on our social media accounts. The social network will record that you have done this.

Pixel Tags: 

These small graphic files allow us and third parties to monitor and collect data about your visit, such as the IP address of the computer that downloaded the page where the tag appears, how long you remained on the page, which browser you used to get there, and the identification number of any cookie previously placed by that server on your computer. We may use pixel tags provided by us or by third party advertisers, service providers and ad networks in combination with our cookies to provide offers and information of interest to you. Pixel tags also may enable ad networks to serve you targeted advertisements. 

RETENTION PERIOD 

We will keep your personal information for as long as your user account is active so you can access your information and our Services. 

We may continue to retain your personal information after you deactivate your user account or stop using Skelehealth, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our users, enforce our agreements or protect our legitimate interests, consistent with applicable law. 

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect personal information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us by emailing privacy@skelehealth.

INFORMATION FROM USERS OUTSIDE THE USA. 

The Services are operated in the United States of America. If you are located in another jurisdiction, please be aware that information you provide to us may be transferred to, stored, and processed in the USA. Unless mandated by local laws, by using the Services or providing us with any information, you consent to this transfer, processing and storage of your information in the USA, a jurisdiction in which the privacy laws may not be as comprehensive as those in the country where you reside or are a citizen. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy. 

To request to limit the use and disclosure of your personal information, please submit a written request to privacy@skelehealth(dot)com. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Skelehealth is committed to resolving complaints about your privacy and our collection or use of your personal information transferred to the USA pursuant to applicable data protection law. 

INFORMATION FOR CALIFORNIA RESIDENTS 

California law provides specific privacy rights related to your personal information. These rights include the rights to know, delete, opt out of sale, and to not be discriminated against for exercising your rights. Please note that we do not sell personal information.

You or your authorized agent may submit a request by contacting us via email at privacy@skelehealth(dot)com. Note that we require individuals to identify themselves and the information requested to be accessed or updated before we will process such requests. 

We will comply with your request as soon as reasonably practicable, including by verifying your request by comparing the information you provide against the information we have on file. However, we may maintain personal information where exceptions to your rights apply.

We will not discriminate against you based on your exercise of the above-listed choices. 

CHANGES TO THIS PRIVACY POLICY 

Skelehealth reserves the right to change or update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

CONTACT US 

If you have any questions or comments about this Privacy Policy, please email privacy@skelehealth(dot)com or send a letter to: Skelehealth LLC, 9800A McKnight Rd Pittsburgh PA 15237.