“Company” or the terms “we” or “us” or similar terms refer to Courage Health, Inc. “You” or “your” or similar terms refer to you as a user of our Services.
Personal Information – In General
Protected Health Information
We collect Personal Information you choose to provide us (e.g., through registrations, applications, use of the Services, surveys, and in connection with your inquiries), starting from the time that you initially access our Site, our Chatbot or use our Services. The information we gather from you enables us to administer your account, provide you with the Services, respond to your inquiries and send you communications regarding the Services and your access to and use of the same, obtain your feedback on our Site, our Chatbot and our Services, analyze user behavior and activity, personalize and improve our Services, conduct research activities and contact you about the services that we offer.
We collect the following types of information:
Personal Information You Provide to Us
We receive and store any information you enter on our Site, our Chatbot or provide to us through the Services, including any third party services that you connect with our Services. Personal Information that we collect may include things like your full name, gender, certain health information (e.g., cancer stage, cancer grade, date of diagnosis, etc.), and any other information or data that you provide when using our Site, our Chatbot and/or our Services.
Personal Information Collected Automatically.
We receive and store certain types of information whenever you interact with the Site, the Chatbot and / or use the Services. We automatically receive and record information on our server logs from your browser, including your Facebook username if accessing via Facebook Messenger, and the page you requested.
Messaging Services: We may provide functionality to permit you to send messages to other users through the Site, and or chatbot. Further, if a message you send using such functionality contains Personal Information, we cannot control how the Personal Information will be used or disclosed by the recipient of your message. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, in any message, and to be careful about the people to whom you send such messages.
Protection of the Company and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of the Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection, detection or suppression, and credit risk reduction. If necessary, we will make all legally required disclosures of any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted, electronically stored “personal information” or “medical information” (as defined in applicable state statutes on security breach notification). To the extent permitted by applicable laws, we will make such disclosures to you via email or conspicuous posting on your private profile on the Site or the Chatbot in the most expedient time possible and without unreasonable delay, insofar as consistent with (a) the legitimate needs of law enforcement, or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to control the sharing of this information.
De-identified Information: We may create De-Identified Information from the information that you share with us, including any Personal Information, and use such De-identified Information without restriction. We may, for example, share De-identified Information with the sponsors paying for your participation in the Services (e.g., reports containing data related to enrollment, engagement, retention, and outcomes to evidence overall program success metrics) and with third party administrators working with the sponsors to administer certain services to you (e.g., incentives vendors, wellness administrators, etc.). Again, we never disclose aggregate information in a manner that would identify you personally.
We employ industry standard administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. In addition, when we collect, maintain, access, use, or disclose your Personal Information, we will do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws, including, without limitation, HIPAA.
As stated previously, you can always opt not to disclose information, even though it may be needed to take advantage of certain features of the Site, the Chatbot and the Services.
If you would like us to remove your records from our system, you may request deletion of your account with us by sending e-mail to firstname.lastname@example.org. Please note that some information may remain in our records after deletion of your account, including any information or records we are legally obligated to retain. We will process your request within a reasonable time, but please note that you may receive additional communications and offers as we process your request.
The Services are not directed to children. We do not knowingly allow or solicit anyone under the age of 18 to participate independently in any of the Services. We do not knowingly collect Personal Information from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, please contact us. If we become aware that a user of the Services is under the age of 18 and has provided us with Personal Information without verifiable parental consent, we will delete such Personal Information from our files.
If you have any questions, concerns or complaints regarding privacy on our Site or Chatbot or if you want to make a request to access or correct your Personal Information, please contact our Privacy Officer at: email@example.com
We will make every effort to respond to your questions, concerns, complaints and requests within a reasonable time.
Effective Date: October 1, 2017