LEGACY HEALTH STRATEGIES Privacy Policy
EFFECTIVE DATE: October 18, 2018
Legacy Health Strategies (“Legacy Health Strategies,” “we,” “us,” or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website https://www.legacyhealthstrategies.com and any other Legacy Health Strategies website or webpage in which this Policy is posted (collectively, the “Sites”), our mobile website activity tracker websites (the “Activity Tracker”) and the services available through our Sites and Activity Tracker (collectively, the “Services”).
This Privacy Policy also describes how we collect, use, and disclose information that we obtain about visitors to certain patient management program portals that we operate (upon which this Policy is posted) (“Portals”) and the services available through our Portals (collectively, the “Portal Services”).
In some cases, we may host and manage websites, health care provider and patient portals and activity trackers on behalf of our clients, but these will be provided in our client’s name; this Policy does not apply to the information that we collect through such portals, websites or activity trackers on behalf of a particular client; their privacy policy will apply to such information.
By visiting the Sites or Portals or using any of our Services or Portal Services, you agree that your personal information will be handled as described in this Policy. Your use of our Sites or Services, and any dispute over privacy, is subject to this Policy and our Terms of Service, https://www.legacyhealthstrategies.com/terms-of-use/, including its applicable limitations on damages and the resolution of disputes. The Legacy Health Strategies Terms of Service are incorporated by reference into this Policy.
https://www.legacyhealthstrategies.com/terms-of-use/
The Information We Collect About You
Information We Collect Directly From You
Information We Collect from Third Parties
Information We Collect Automatically
How We Use Your Information
How We Share Your Information
Information We Collect Through Our Portals
Our Use of Cookies and Other Tracking Mechanisms
Clear GIFs, pixel tags and other technologies
Third Party Analytics
Do-Not-Track
Third-Party Links
Security of My Personal Information
Access To My Personal Information
What Choices Do I Have Regarding Use of My Personal Information?
Children Under 13
Special Information for California Consumers
Contact Us
Changes to this Policy
The Information We Collect About You
We collect information about you directly from you and from third parties, as well as automatically through your use of our Sites or Services.
If you submit any personal information relating to anyone other than yourself, you represent that you have obtained any necessary consent from that individual for use and disclosure of that individual’s personal information as described in this Policy.
Information We Collect Directly From You. The type of information that we collect from you depends on your interaction with our Sites and Services. We collect information from you when you register with us, request information from us, use our portals, or use our Activity Tracker. Specifically, we request the following information when you register an account on the Sites: your name and email address. You may also include information about what industry you work in. We also collect information when you communicate with us through the Sites, such as for customer services purposes.
When you register an account with our Portals or Activity Tracker, we request your email address and other personal information. You will receive an email (either automatically or from a particular care manager) with instructions on how to set your password.
You may also voluntarily provide Information to us while using our Sites and Services. Please consider carefully the types of information you volunteer when submitting open-ended responses as any information you provide will be stored and processed by us under the conditions of this Policy.
Patient Profile Information. The type of information that we collect from you depends on your interaction with our Sites, a Portal or our Activity Tracker or the Services you utilize. We collect information from you when you register with us and when you update your information. Specifically, we request the following information when you register an account: your name, your email address, phone number and zip code, and the year you were born in. You may also include additional information in your profile, such as your location, sex, and your health information. We may also collect information from you when you contact us through the Sites or Services, or when we conduct surveys. This Privacy Policy does not apply to the personal information we collect from our clients (or through their websites) as part of a patient program that we are running on behalf of such client.
Information We Collect from Third Party Sources. When you use our Portals or Activity Tracker, you may be able to sync your wearable fitness devices to your Portal or Activity Tracker account. If you sync your wearable fitness devices, we will ask permission to collect certain information from the device, which may include heartrate, pedometer information, information about sleep patterns, location information, and/or other information.
Information We Collect Automatically. We may automatically collect the following information about your use of our Sites or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; location information; the length of time you visit our Sites and or use our Services; and the referring URL, or the webpage that led you to our Sites. We may combine this information with other information that we have collected about you, including, where applicable, your user name and other personal information. Please see the section “Cookies and Other Tracking Mechanisms” below for more information.
How We Use Your Information
We use your information, including your personal information, for the following purposes:
• To provide our Services to you, to communicate with you about your use of our Services, to respond to your inquiries, to fulfill your orders, and for other customer service purposes.
• To tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Sites, Portals, Activity Tracker or our Services.
• To send you patient and treatment information that you may find useful.
• With your permission, to send you certain informational text messages.
• For marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about products or information we think may interest you.
• To better understand how users access and use our Sites, Portals, Activity Tracker and Services, both on an aggregated and individualized basis, in order to improve our Sites, Portals, Activity Tracker, and Services and respond to user desires and preferences, and for other research and analytical purposes.
• To comply with applicable legal obligations, including responding to a subpoena or court order.
Where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person or violations of our Terms of Use or this Policy.
How We Share Your Information
Website and Activity Tracker. We may share information collected through the Sites, Portals, Activity Tracker and Services, including personal information, as follows:
• Our Clients. We may share information we collect from you with our clients. For example, if the Activity Tracker is used as part of a particular program offered by one of our clients, we may share Activity Tracker information with that client.
• Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
• Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
Portal Information. We may share information collected through the Portal and Portal Services, including personal information, as follows:
• Our Clients. We may share information we collect from you with our clients on whose behalf we operate the Portal. For example, if the Portal is designed to assist you with using a particular medication or device, we will share Portal information with that medication or device manufacturer.
• Affiliates. We may disclose the information we collect from you to our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personally identifiable information will be subject to this Policy.
• Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.
Additional Sharing. We may also share any of the information we collect as follows:
• Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or as part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other company.
• In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
• To Protect Us and Others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which Legacy Health Strategies is involved.
• Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
Our Use of Cookies and Other Tracking Mechanisms
We and our third-party service providers use cookies, web beacons, java, and other tracking mechanisms to track information about your use of our Services. We may combine this information with other personal information we collect from you (and our third-party service providers may do so on our behalf).
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies).
Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Sites.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether.
Clear GIFs, pixel tags and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with our Sites to, among other things, track the activities of Sites visitors, help us manage content, and compile statistics about Sites usage. We and our third-party service providers also use clear GIFs in HTML e-mails to our clients and users, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Third Party Analytics. We use automated devices and applications to evaluate usage of our Sites and Portal. We use these tools to help us improve our Services and Portal Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.
User Generated Content
We invite you to post content on our Sites, Activity Tracker or Portal, including your comments, pictures, and any other information that you would like to be available on our Sites. If you post content to our Sites, Activity Tracker or Portal, all of the information that you post will be available to us or, if using a Portal, the client on whose behalf we operate the Portal. If you post your own content on our Services or Portal Services, your posting may become public and Legacy Health Strategies cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy. Consistent with your obligations under the Terms of Use for the Services, you further agree that you have obtained consent for processing of information about third-parties you disclose via any of the Services.
Third-Party Links
Our Sites, Activity Tracker, Portal, Services and Portal Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
Security of My Personal Information
We have implemented measures to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
Access To My Personal Information
You may modify personal information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Sites, Activity Tracker or Portal for a period of time.
Marketing Choices
We may send periodic promotional or informational emails to you. You may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us.
Children Under 13
Our Services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
Special Information for California Consumers
California residents may request a list of certain third parties to which we have disclosed personally identifiable information about you for their own direct marketing purposes. You may make one request per calendar year. In your request, please attest to the fact that you are a California resident and provide a current California address for your response. You may request this information in writing by contacting us at: privacy@legacyhealthstrategies.com. Please allow up to thirty (30) days for a response.
Contact Us
If you have questions about the privacy aspects of our Services or would like to make a complaint, please contact us at privacy@legacyhealthstrategies.com or call us at 858-568-7555.
Changes to this Policy
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Sites. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Sites.
Privacy and Visitors Outside the United States
If you reside outside the United States, please be aware that any information collected and/or provided via the Site will be processed in the United States. You consent to have your information transferred, processed, and stored in the United States and under United States privacy standards and the terms of this Policy.
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