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Privacy Policy

Last modified: November 20th, 2019

1.              Introduction

This Privacy Policy describes how Medici Technologies, LLC d/b/a Chiron Health collects and uses Personal Data about you through the use of the Chiron Health website, mobile applications, and through email, text, and other electronic communications between you and Chiron Health.

Medici Technologies, LLC d/b/a Chiron Health (“Chiron Health,” or we,” “our,” or “us”) respects your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.chironhealth.com (our “Website”) and the associated Chiron Health application (our “Application”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Privacy Policy applies to information we collect:

  • on our Website and Application;
  • in email, text, and other electronic messages between you and our Website and Application;
  • when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • us offline or any other means, including on any other website operated by Chiron Health (such as medici.md and www.docbookmd.com) or any third-party;
  • your Provider; or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or Application.

Note, Chiron is not a medical group. Any telemedicine consults obtained through our Website or Application are provided by independent medical practitioners (each, a “Provider”).  Your Provider is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not Chiron. If you do not agree to be bound by those terms, you are not authorized to access or use our Website and Application, and you must promptly exit our Website and Application. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website and Applications. By accessing or using our Website or Application, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website or Application after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2.              Children Under the Age of 18

Children under the age of 18 are not permitted to use our Website or our Application without parental consent.

 

If you are under the age of eighteen (18) and wish to create an account with Chiron (“Account”), your parent or legal guardian must create the Account, submit your personal information, and agree to these Terms of Use on your behalf. If you are under the age of 13, you may only use our services and access our Website and Application with the supervision and consent of your parents or legal guardians, including the Provider consultation services.  If we learn that we have collected personal information from someone under the age of 13 that was not provided with the supervision and consent of the minor’s parents or legal guardian, we will promptly delete that information. If you believe we have impermissibly collected personal information from someone under the age of 13, please contact us using the information below.

3.              Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

 

Generally

We collect several types of information from and about users of our Website and Application, specifically information:

  • by which you may be personally identified, such as: name; home, work, billing, and shipping address; e-mail address; telephone numbers; date of birth; credit card, debit card, or financial/bank account numbers (for payment purposes only); government or license identification numbers (including NPI numbers for Providers); driver’s license numbers; photos, audio, and video of you; your gender; your medical history and health information; and criminal background checks / information (through our third party providers); or any other identifier by which you may be contacted online or offline (all of the foregoing collectively, “Personal Data”);
  • that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website or use of our Application, error information, clickstream data, and other communication data and the resources that you access and use on the Website or through our Application; or
  • about your internet connection, the equipment you use to access our Website or use our Application and usage details.

We collect this information:

  • directly from you when you provide it to us;
  • automatically as you navigate through the Website or use our Application. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, geo-location services, and other tracking technologies; and
  • from third parties, for example, our business partners and the Providers.

Information You Provide to Us and Your Provider

The information we collect on or through our Website or through our Application are:

  • information that you provide by filling in forms on our Website or the Application. This includes information provided at the time of registering to use our Website or Application, using our physician consultation or other services, or requesting further services. We may also ask you for information when you report a problem with our Website or Application;
  • records and copies of your correspondence (including email addresses), if you contact us;
  • your responses to surveys that we might ask you to complete;
  • details of transactions and interactions you carry out through our Website or through the Application and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website or Application; and
  • information you provide to our third party service providers on our behalf (including information you provide for background checks and to process payments). We also may obtain information you share with your Provider from him or her. In such a case, we will utilize strict confidentiality as legally required to protect your Personal Data.

Your Provider may record (audio and video) all or part of your interaction with him or her (and may also store text and images from your consultation through the use of an encrypted application on the Medici platform (collectively “Recordings”). Such Recordings are used for quality assurance purposes, to better deliver to you the Products and Services, and to help us improve the Website and Application. Chiron Health will keep such Recordings confidential, and we will not publically display such recordings unless legal required to do so, such as if subject to a court order. By accessing and using the Site, you agree and consent to such Recordings for the purposes and uses set forth in the Terms of Use and as otherwise set forth in this Privacy Policy. You may withdraw your consent to Record at any time by ending the conversation with the Provider and either logging our or ending your session in the Website or Application. You may request that Chiron Health delete the Recording by Contacting Us as set forth below.

 

You also may provide information to be transmitted to other users of the Website or Application or third parties (collectively, “User Contributions”). Your User Contributions are transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable and we have no control over the security of third party social media sites. Additionally, we cannot control the actions of other users of the Website and Application with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website and Application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

  • details of your visits to our Website or Application, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website or use of our Application, error information, clickstream data, and other communication data and the resources that you access and use on the Website or in the Application; and
  • Information about your computer, mobile device, and internet connection, specifically your IP address, operating system, browser type, and Application version information.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and Application and to deliver a better and more personalized service by enabling us to:

  • estimate our audience size and usage patterns;
  • verify your location to ensure we can provide you with our services;
  • store information about your preferences, allowing us to customize our Website and our Application according to your individual interests;
  • recognize you when you return to our Website and our Application.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A “cookie” is a small file placed on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Website or use certain parts of our Application. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or use our Application.
  • Web Beacons. Pages of our Website, screens of our Application, and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Chiron Health, for example, to count users who have visited those pages, used those screens, or opened an email and for other related website and application statistics (for example, recording the popularity of certain Website or Application content and verifying system and server integrity).
  • Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses cookies to help the Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics, please visit Google’s website and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

4.              How We Use Your Information

We use your Personal Data for various purposes described below, including to:

·      provide our Website or Application to you;

·      provide products and services to you;

·      provide you with information you request from us;

·      enforce our rights arising from contracts;

·      notify you about changes; and

·      provide you with notices about your account.

We use information that we collect about you or that you provide to us, including any Personal Data:

  • to present our Website and its contents to you;
  • to present our Application;
  • to register and service your account with us;
  • to provide and improve the products and services we offer to you;
  • to provide you with information, products, or services that you request from us;
  • to administer surveys and promotions;
  • to process, fulfill, and administer transactions and orders for products and services ordered by you;
  • to contact you in response to a request;
  • to enhance and improve our Website and our Applications;
  • to fulfill any other purpose for which you provide it;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • to notify you about changes to our Website, our Application, or any products or services we offer or provide though them;
  • in any other way we may describe when you provide the information; and
  • for any other purpose with your consent.

We may also use your information to send you secure electronic messages and personalized emails pertaining to your interests as inferred from your use of our Website or Application, including news, announcements, reminders and opportunities from Chiron Health, or about our own goods and services that may be of interest to you. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications. For more information, see Choices About How We Use and Disclose Your Information.

We may use how you browse and shop in order to show you ads for company or our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our Website, Application, or third party sites not owned by Chiron Health.

Chiron Health may aggregate or de-identify your information such that it is no longer considered protected health information or personally identifiable information. Chiron Health may disclose, sell, or otherwise use such aggregated or de-identified information for its own purposes or provide such information to third parties for analytics, research, or other purposes.

Where Chiron Health collects your information in its role as a HIPAA business associate to your Provider, Chiron Health will use and disclose that information in accordance with the terms of the Provider’s Notice of Privacy Practices, the business associate agreement between your Provider and Medici, and applicable law.

5.              Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

·      our affiliates and our third-party service providers that we use to support our business;

·      to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;

·      to comply with our legal obligations;

·      to enforce our rights; and

·      with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

  • to our subsidiaries and affiliates;
  • to contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, and ordering, marketing, and payment processing services. Our payment processors’ privacy policies may be found at http://stripe.com/us/privacy;
  • to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Chiron Health about our Website and Application users are among the assets transferred;
  • to fulfill the purpose for which you provide it. For example, we may disclose your personal information to a Provider if you use such feature of our Website or Application;
  • for any other purpose disclosed by us when you provide the information; and,
  • with your consent.

We may also disclose your Personal Data:

  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • to enforce or apply our Terms of Use [https://get.chironhealth.com/terms-of-use] and other agreements, including for billing and collection purposes; and
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Chiron Health, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6.              Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

  • Tracking Technologies and Advertising. You can set your browser or operating to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website or Application may then be inaccessible or not function properly.
  • Promotional Offers from Chiron Health. If you do not wish to have your email address used by Chiron Health to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or logging onto your Account profile page. This opt out does not apply to information provided to Chiron Health as a result of a product purchase, or your use of our services.
  • Targeted Advertising. We belong to ad networks that may use your browsing activity across participating websites to show you interest-based advertisements on those websites. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

7.              Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may review and change your personal information by logging into the Application or Website and visiting your Account profile screen.

You can review and change your Personal Data by contacting customer support or by emailing us at support@chironhealth.com . You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

8.              Do Not Track Signals

We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

We also may use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such signal is broadcast or received.

9.              Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Website confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.

The safety and security of your information also depends on you. Where you have chosen a password for the use of our Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website or on or through our Application. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, in your operating system, or in the Application.

10.           Location-Enabled Features

Certain location enabled features of our Website and Application may be made available through third party vendors with additional terms and conditions and privacy practices.

Certain location-enabled functionality made available in the Website and Application is provided by Google, Apple Inc., and other third party providers. Your use of that functionality may be subject to additional privacy (and other) terms and conditions (as updated from time-to-time), including the terms that are accessible through: http://www.google.com/intl/en-US_US/help/terms_maps.html and https://www.apple.com/legal/internet-services/maps/terms-en.html. You must exercise your own judgment as to the adequacy and appropriateness of the sharing of this information with us.

11.           Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Website. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page or the Application’s home screen. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account or through a notice on the Website’s home page or the Application’s home screen. The date this 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 accessing the Application or visiting our Website and reviewing this Privacy Policy to check for any changes.

12.           Consent to Processing of Personal Data in the United States

This Website and Application are intended only for U.S. residents. Accordingly, we may process your Personal Data outside of your home country, including to the United States.

This Application and Website are not intended for U.S. residents’ use only and are not directed to residents of the European Union. By using and accessing our Application and Website, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.

13.           Contact Information

You may contact us through the contact information below.

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Website or in the Application.

How to Contact Us:

By Mail:

Chiron Health

7500 Rialto Blvd.

Building I

Ste. 260

Austin, TX 78735

 

By Telephone:

For Chiron: (800) 768-8131

 

By Email:

For Chiron: support@chironhealth.com