PURSUANT HEALTH PRIVACY POLICY

Pursuant Health (alternately, “we”, “us” or “our”) respects your privacy and is committed to complying with this privacy policy (“Privacy Policy”), which describes what information we collect about you, including how we collect it, how we use it, with whom we may share it and what choices you have regarding our use of your information. This Privacy Policy applies to information collected through our Pursuant Health Kiosks (the “Kiosks”), on our website located at: https://pursuanthealth.com (the “Website”), any current or future mobile application associated with the Website (the “Mobile Applications”), all interactive features, applications, widgets, social networks and social network “tabs”, and other online or wireless offerings that post a link to this Privacy Policy, whether accessed via computer, mobile device or other technology or any associated content, material, or functionality contained on the Kiosks, Website or Mobile Application (collectively, the “Services” and, together with the Kiosks, Website and the Mobile Applications, the “System”). 

This Privacy Policy is incorporated into and is part of the Pursuant Health Terms of Service available at https://pursuanthealth.com/legal/, including their applicable limitations on damages and the resolution of disputes. We encourage you to become familiar with the terms and conditions of both this Privacy Policy and the Terms of Service. By accessing and using the System, or any part thereof, you agree that you have read and understand this Privacy Policy, and that in exchange for access to the System, you accept and consent to the privacy practices (and any uses and disclosures of information about you) that are described in this Privacy Policy. 


Information We Collect

As described in detail below, we may collect certain identifying information from or about you in connection with your use of, or your submissions to, the System (collectively, the “Collected Information”).  Collected Information includes, without limitation, any information that may be used to identify an individual, including, but not limited to, a first and last name, a home, business, or other physical address, business name, a phone number, an email address, employer name, employer information (i.e., employer address and other identifying information). 

Information we Collect About Website Visitors and Users

When you browse our Website, or use our Website to submit questions about our services, register for an account, access your health assessment and account information or request services from us, we may collect information from or about you, including, but not limited to: name, address, e-mail address, telephone number, age, gender, date of birth, health information and any other information you choose to provide. You do not have to provide us personal information to use the Pursuant Health Kiosks. However, if you want to use certain features of our services, we ask for certain personal information. For example, if you want to receive a copy of your health assessment, you must provide us with your email address.

We may also automatically collect certain information regarding how you interact with the System, which may include pages you view, links you click or hover over, selections you make on the Website, your web browser’s HTTP referrer header, features you use, preferences you set, your web browser type and version, the operating System type and version of the device you are using to access the System, the Internet protocol (IP) address of the device you are using to access the System (or any portion thereof), general physical location, Internet service provider. For more information, see the sections below entitled “Cookies and Usage Reports,” “Google Analytics,” and “Web Beacons and other Tracking Technologies.”

Information we Collect About General Users of Pursuant Health Kiosks

When you take a health assessment or use other Services offered through the Pursuant Health Kiosk, we may collect information from or about you including, but not limited to: name, address, e-mail address, telephone number, age, gender, date of birth, health information and any other information you choose to provide in connection with your use of the Kiosk and Services.

You do not have to provide us personal information to use the Pursuant Health Kiosks. However, if you want to use certain features of our services, we ask for certain personal information. For example, if you want to receive a copy of your health assessment, you must provide us with your email address. Additionally, some information, such as age, gender and date of birth, is necessary for us to complete an accurate assessment or screening.

Information we Collect about Members or Patients of our Covered Entity Customers

In some cases, we may provide the System or Services for or on behalf of your health plan, health insurance company or health care providers who are subject to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Health Information Technology for Economic and Clinical Health Act (the “HITECH Act”), regulations promulgated thereunder (“HIPAA Regulations”). These entities are our “Covered Entity” customers. Individually identifiable health information (“Protected Health Information”, or “PHI”) that we collect for or on behalf of Covered Entities is subject to additional legal protections. Accordingly, we will only collect, use and disclose PHI as permitted by our contracts with such Covered Entity customers and as permitted or required by applicable law.

To provide the Services for or on behalf of our Covered Entity Customers, we may collect certain information from you in addition to information collected from general users of the Pursuant Health Kiosks, such as your health insurance member ID. Additionally, certain information including your name, e-mail address or phone number may be necessary if you request or authorize us to submit your information, assessment or screening to the Covered Entity or another third party. In these situations, the Kiosk screen will notify you about the information that is being collected, why, and how it will be shared, and you will be able to choose whether you want to proceed. 

Cookies and Usage Reports

By placing a small file known as a “cookie” on your computer (or other device), Pursuant Health’s and its third party service providers’ servers passively gather information about all visitors’ use of the Website for several reasons, including, but not limited to, the following: statistics collection and analysis, Website optimization, analytics (as described below), market research, and maintenance of user login information. The information that we and our third party service providers track with cookies includes, but is not limited to, the type of browser (such as Google Chrome or Internet Explorer) and Internet-connected devices being used to access the Website, your Internet protocol (“IP”) address, your home domain or Internet service provider, your referrer URL (which is the URL for the website that you were viewing prior to visiting the Website), how you were directed to the Website, which specific pages you access on the Website, how long you view each page, the time and date you access our Website and the total number of visitors to the Website and any portions thereof.  We, and/or our third party service providers, may use the information collected from cookies or similar files on your computer for security purposes (such as authentication), to facilitate site navigation and to personalize your experience while visiting the Website. This data helps us and our third party service providers improve our respective product and services. 

Most popular Internet browser applications will allow you to configure the browser so as not to accept cookies. However, setting your browser to reject cookies may, in certain instances, prevent you from taking full advantage of the Website (or some portion thereof) and its capabilities, or cause some features of the Website to function improperly or more slowly.

Google Analytics

Our websites may use Google Analytics, a web analysis service provided by Google, in order to better understand your use of our Website and how we can improve it. Google Analytics collects information such as how often users visit a website, what pages you visit when you do so, and what other websites you used prior to coming to such website. Google Analytics collects only the IP address assigned to you on the date you visit a website, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with your personal information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit a website, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to Pursuant Health’s Website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google utilizes the data collected to track and examine the use of the Pursuant Health Website, to prepare reports on its activities and share them with other Google services. Google may use the data collected on the Pursuant Health Website to contextualize and personalize the ads of its own advertising network. To more fully understand how Google may use the data it collects on the Pursuant Health Website, please review “How Google uses data when you use our partners’ sites or apps,” (located here or any successor URL).

Web Beacons and other Tracking Technologies

Some of the areas of the Website may contain electronic images known as web beacons (sometimes known as clear gifs) that allow Pursuant Health, and its third party providers or affiliates, to count and track users who have visited certain portions of the Website. We also partner with one or more third parties (such as advertisers and ad networks) to display advertising on our Website and/or to manage and serve advertising on other sites. Pursuant Health and its third party providers may use web beacons, cookies, pixel tags and similar tracking technologies to collect and use certain information about your online activities, either on our Website and/or other sites or mobile apps, to infer your interests and deliver you targeted advertisements that are more tailored to you based on your browsing activities and interests (“Interest Based Advertising”).  Specifically, Pursuant Health may use a type of web beacon known as a “retargeting pixel,” which will allow users to receive targeted advertising from Pursuant Health via certain social media websites, including Facebook.com.

How We Use Your Information

Visitors to our Website and General Users of Pursuant Health Kiosks

Pursuant Health and our third party services providers collect and use the Collected Information to:

•      Operate the System and deliver the Services;
•      Verify your identity;
•      Administer your account;
•      Provide you with customer support;
•      Tailor the features, performance and support of our System and Services to you;
•      Market our products and services, as well as those of third parties, which we believe may be of interest to you, subject to applicable contractual and legal restrictions;
•      Respond to your requests, resolve disputes and/or troubleshoot problems;
•      Improve the quality of our Website and our Services;
•      Communicate with you about the System and our Services;
•      Communicate your screening and assessment results with third parties, if you authorize it;
•      Address System integrity or security issues;
•      Conduct research and analysis to maintain, protect, develop, and improve the System; and
•      As described below or elsewhere in this Privacy Policy or the Terms of Service.

We may send you information that you request from us and promotional materials regarding Pursuant Health or any third party entity, as permitted by applicable law, and any other communication for any other legitimate and lawful business purposes. Additionally, we may retain and use certain Collected Information to facilitate and otherwise address certain inquiries or requests regarding the Services or the System, or respond to your questions or requests for information about or from Pursuant Health.  We may also use Collected Information as necessary to ensure compliance with any Pursuant Health policies and any applicable law, regulation or order. 

Except as set forth in this Privacy Policy, Pursuant Health will not use, disclose, or transfer your Collected Information unless:

1)      you expressly authorize us to do so,
2)      it is necessary to allow our service providers, agents, or other third parties to provide products or services for or to us,
3)      it is necessary in order to provide the System or the Services,
4)      we are sending you other information that may be useful to you,
5)      subject to applicable contractual or legal restrictions, it is disclosed to entities that perform marketing services on Pursuant Health’s behalf or to other entities with whom Pursuant Health has joint marketing agreements,
6)      it is necessary to protect the confidentiality or security of your records,
7)      it is necessary in connection with other business purposes including, without limitation, verifying identity, age, and/or payment details, investigating complaints about the System, risk assessment, security, fraud and crime prevention/detection, monitoring, research and analysis, marketing, customer purchasing preferences and trends and dispute resolution,
8)      it is necessary to comply with law enforcement, governmental mandate, or other legal requirement, if appropriate, for your protection or in connection with an investigation or prosecution of possible unlawful activity;
9)      subject to applicable contractual or legal restrictions, it is necessary in connection with a sale of all or substantially all of the assets of Pursuant Health or the merger of Pursuant Health into another entity or any consolidation, share exchange, combination, reorganization, or like transaction in which Pursuant Health is not the survivor, or
10)      it is otherwise necessary for Pursuant Health to use or disclose it as required or permitted by law.

Notwithstanding the above, we may freely use your Anonymous Information and information with all personal identifiers removed (“De-Identified Information”).

Members and Patients of our Covered Entity Customers

When we collect PHI from you for or on behalf of our Covered Entity customers through the System, we will only use such information as permitted or required by applicable law and the terms of our Agreement with the Covered Entity.

How We Share Your Information

In addition to the uses mentioned or described elsewhere in this Privacy Policy or in the Terms of Service, we may share Collected Information about you:

•      With third-party vendors who help us provide services or who provide additional goods and services through the website;
•      With third parties as requested or authorized by you (for example, your health insurance company);
•      To a parent company, any subsidiaries, joint ventures, or other companies under a common control (collectively, “Affiliates”), in which case we will require our Affiliates to honor this Privacy Policy;
•      To entities that perform marketing services on Pursuant Health’s behalf or to other entities with whom Pursuant Health has joint marketing agreements, subject to applicable contractual or legal restrictions;
•      With third parties to market their products or services which may be of interest to you, subject to contractual or legal restrictions; or
•      If we believe in good faith that such disclosure is necessary to (i) resolve disputes, investigate problems, or enforce compliance with our Website Terms of Service or this Privacy Policy, or to otherwise protect our services, website, systems, information, employees, business partners, providers, users, customers or others; (ii) comply with relevant laws or to respond to requests from law enforcement or other government officials relating to investigations or alleged illegal activity, in which case we can (and you authorize us to) disclose Personal Information without subpoenas or warrants served on us; (iii) protect and defend our rights or property or the rights and property of you or third parties; or (iv) as evidence in litigation in which we are involved. 

We may also use and disclose Collected Information to establish or exercise our legal rights, to assert and defend against legal claims, or if we believe such disclosure is necessary to investigate, prevent, or take other action regarding actual or suspected illegal or fraudulent activities or potential threats to the physical safety or well-being of any person.

As Pursuant Health grows and develops its business, it is possible that its corporate structure or organization might change or that it might merge or otherwise combine with, or that it or portions of its business might be acquired by, another company. In any such transactions, customer information generally is, and should be expected to be, one of the transferred business assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, your information may be considered a company asset that may be sold or transferred to third parties.

Use and Disclosure of Protected Health Information

We will only collect, use and disclose PHI as permitted by our contracts with Covered Entity customers and as permitted or required by applicable law.

In instances where you have authorized Pursuant Health to use and disclose your PHI for certain purposes, such consent may be withdrawn in the future. You may withdraw your consent by sending your request in writing to:

        Pursuant Health, Inc.
        780 Johnson Ferry Road, Suite 625
        Atlanta, GA 30342

Please note that your withdrawal will not be effective until your request is received, and will not apply to uses and disclosures made in reliance on your consent.

Access, Amendment and Deletion of Your Personal Information

You may request to access and correct the personal information we maintain about you by emailing us at privacy@pursuanthealth.com or by logging in to your account at https://pursuanthealth.com and updating your account information. In some cases, you may also use the Pursuant Health Kiosks to update information we maintain about you.

You may request deletion of personal information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete Personal Information, it will be deleted from the active database, but may remain in our archives, and we may also retain Anonymous Information about your use of our services. After we delete personal data, we may retain De-Identified Information and will continue to use such De-Identified Information as permitted under this Privacy Policy and applicable law.

Your Choices

You can choose not to submit your information to us, but if you do not submit the information requested, you may not be able to access many of the products, services, and features that we offer.

If you do not wish to receive communications from Pursuant Health about products, services, or features that may be of interest, you can unsubscribe to any e-mail that we may send to you. We will include an opt-out link or reply address in each e-mail that we send. Please allow up to 10 business days to process your request. After unsubscribing, you may still receive messages about the status of your account, order or request, to resolve technical issues, or to confirm a new subscription.

Linked Websites

For your convenience, some hyperlinks may be posted on the System that link to other websites not under our control. We are not responsible for, and this Privacy Policy does not apply to, the privacy practices of those sites or of any companies that we do not own or control. We cannot be responsible for the privacy practices of any such websites or pages not under our control and we do not endorse any of these websites or pages, the services or products described or offered on such sites or pages, or any of the content contained on those sites or pages. We encourage you to seek out and read the privacy policy of each website that you visit. In addition, should you happen to initiate a transaction on a website that our System links to, even if you reached that site through the System, the information that you submit to complete that transaction becomes subject to the privacy practices of the operator of that linked website. You should read that website’s privacy policies to understand how personal information that is collected about you is used and protected.

User-Provided Content

Any information, communications, or material of any type or nature that you submit to the Kiosk, Website or any Mobile Application by e-mail, posting, messaging, uploading, downloading, or otherwise (collectively, a “Submission”) is done at your own risk and without any expectation of privacy.  We cannot control the actions of other users of the System and we are therefore not responsible for any Submissions contained on the Website. By visiting any of our pages that are contained on the Website, you are representing and warranting to us that you have reviewed this Privacy Policy and the Terms of Service and that you will abide by all such provisions contained therein.

Additionally, in the event that we offer a message board or any other interactive or social-type feature on the Website, please be aware that these areas may allow you to post, and share with other users, certain messages, content, or other information.  We encourage you to be wary of giving out any personal information, or any personal information of others to which you may have access, in such forums. The information you post can be collected and used by other people. We cannot guarantee the privacy and safety of these areas and are therefore not responsible for any information you choose to post. Your use of these features is fully at your own risk.

Social Media Platforms and Websites

Any Submission that you submit to any of our pages contained on a social media platform or website by e-mail, posting, messaging, uploading, downloading, or otherwise is done at your own risk and without any expectation of privacy.  We cannot control the actions of other users of a social media platform and we are therefore not responsible for any Submissions contained on a social media platform or website. By visiting any of our pages that are contained on any social media platform or website, you are representing and warranting to us that you have reviewed the applicable privacy policy and terms of use of such website or social media platform and that you will abide by all such provisions contained therein.

Important Information for California Consumers

If you reside in California, you may request information about our disclosures of your protected health information or personally identifiable information to third parties for their direct marketing purposes. Such requests must be submitted to us by e-mail at Privacy@pursuanthealth.com. For all requests, you must put the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code. Within thirty days of receiving such a request, we will provide a list of the categories of protected health information or personally identifiable information disclosed to third parties for direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. Please note that we will not accept requests via telephone, and we are not responsible for notices that are not labeled or have not been sent properly, or that do not have complete information. 

Do Not Track Requests

California and Delaware laws require that we indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising. “Do Not Track” is a standard that is currently under development. As it is not yet finalized, we adhere to the standards set out in this Privacy Policy and do not monitor or respond to any Do Not Track browser requests.

Children

The System (including the Kiosks, Website, Mobile Applications, and Services included therein) is intended for a general audience and is not intended for use or view by children under 18 years of age. If you are under age 18, please do not attempt to use our services or provide any personal information about yourself to us. Consistent with the Children’s Online Privacy Protection Act, we will not knowingly collect any information from children under the age of 13. If we learn that we have collected personal information from a child under age 13, we will delete that information.


How We Protect Your Information

We employ reasonable physical, electronic and managerial security methods to help protect against unauthorized access to Personal Information. Please be aware that no data transmission over the Internet or data storage facility can be guaranteed to be perfectly secure. As a result, we cannot ensure or guarantee the security of any information you provide to us, and you do so at your own risk. Please report any security violations or concerns to us at privacy@pursuanthealth.com.


Visiting The System From Outside The United States

If you are visiting the System, or any part thereof, from outside of the United States of America, please be aware that your information may be transferred to, stored or processed in the United States, where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country, but please be assured that we take steps to protect your privacy.  By using any portion of the System, you understand and consent to the transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy.

Changes to Privacy Policy

Pursuant Health reserves the right to change this Privacy Policy at any time, without prior notice to you. The most recent version of the Privacy Policy is reflected by the version date located at the bottom of this Privacy Policy. All such updates and amendments are effective immediately upon notice thereof, which we may give by any means, including, but not limited to, by posting a revised version of this Privacy Policy or other notice on the System. You should view this Privacy Policy often to stay informed of changes that may affect you, as your continued use of the System signifies your continuing consent to be bound by this Privacy Policy. Our electronically or otherwise properly stored copies of this Privacy Policy shall be deemed to be the true, complete, valid, authentic, and enforceable copy of the version of this Privacy Policy which were in force on each respective date you visited the System. This Privacy Policy is not intended to and does not create any contractual or other legal right in or on behalf of any party other than Pursuant Health.

Acknowledgement

BY ACCESSING OR USING THE SYSTEM, OR ANY PORTION THEREOF, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND CONSENT TO THE PRIVACY POLICY, AND TO THE USES AND DISCLOSURES OF COLLECTED INFORMATION ABOUT YOU, THAT ARE DESCRIBED IN THIS PRIVACY POLICY AND YOU AGREE TO BE BOUND BY THE TERMS OF SERVICE REFERENCED ABOVE.

Contact Us

Please contact us at privacy@pursuanthealth.com if you have any questions about this Privacy Policy.

 

 

Last Updated: August 28, 2017

Questions? Reach out to us by clicking the button below or by emailing us at privacy@pursuanthealth.com