Privacy Policy2019-03-10T23:28:20+00:00

Privacy Policy

Last Updated: as of 3/1/2019

HealthSnap Inc., a Delaware corporation (“HealthSnap,” “we,” “our,” or “us”) provides the HERA™ platform that translates a consumer’s (“End User”) lifestyle health data from multiple sources, such as wearables, health and medical devices, and questionnaires, into a normalized format so that End Users can sync and track their lifestyle health data and share it with a healthcare provider (“Provider”) or multiple Providers (a “Care Team”) who are able to easily and quickly make better and more informed, data-driven decisions about their patients’ health. HERA™ includes a mobile application (“Mobile App”) and web-based dashboards for both End Users/Patients and Providers (“Dashboard”)( HERA™ Mobile App and Dashboards collectively, the “Services”). the Services may be used by an End User who is not “connected”, or sharing his account data, to a Provider, or by an End User who is connected to a Provider (a “Patient). 

HealthSnap, Inc. is committed to protecting the privacy of all its users. This Privacy Policy is incorporated by reference into HealthSnap’s Terms of Service and describes the information we collect when you use the Services, how we use the information we collect and any disclosures of that information. 

The term “you,” as used in this Privacy Policy, refers to an End User, a Patient or Provider of the Services. By using the Services, you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. We may change this Privacy Policy by posting a new version through the Services, and it is your responsibility to review this Privacy Policy periodically. When we do change the policy, we will also revise the “last updated” date at the beginning of this Privacy Policy and may notify you or post a message via the Mobile App and/or the Dashboard. Your continued use of the Services constitutes your agreement to this Privacy Policy and any updates.

INFORMATION WE COLLECT

  1. Personal Information. As used in this Privacy Policy, “Personal Information” means any information that may be used to identify you. We receive and store any information you provide to us. For example, we collect Personal Information such as your first and last name, age, email address, browser information, third-party encrypted account credentials and phone number. If you provide your third-party account credentials to us, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us if you authorize such transmissions, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy. You can choose not to provide us with certain information, but you may not be able to register with us or to take advantage of some of our features. We may anonymize your Personal Information so that you cannot be individually identified, and provide that information to our partners. 
  2. Technical Information. When you use the Services, we may track or collect information unique to you or the device you use to access the Services (“Technical Information”). We may do this directly or through third party tools, services, stores, accounts or hosting platforms involved with or connected to the Services (including without limitation, anonymous usage statistics, by using cookies, server logs, analytics tools and ad serving technologies).  This information may be used to improve the quality of our services, to administer the site and analyze its usage, to allow users to set up a user account and profile, to contact users and to fulfill your requests for certain products and services.  Whenever you interact with the Services, we may automatically receive and record information on our server logs from your browser including your IP address, “cookie” information, and the page you requested. This information is not deemed by HealthSnap to constitute Personal Information and while we will not use it in a way that associates such information with you, such information it may be aggregated and used. HealthSnap owns this information and may use it in any manner it deems appropriate. 
  3. Protected Health Information. By using the Services, we provide you the ability to store, upload information from third party tracking health platforms (such as Apple Health and Google Fit), and track protected health information (“PHI”) and allow you to connect with a “Care Team” (comprised of health and wellness Providers with whom there is a relationship for the provision of healthcare products and services). PHI is any information about your health status, provision of health care, or payment for health care that is created or collected by Providers or us and can be linked back to you. Some examples of PHI used by the Services are your medical history, family history, health background and current health status information, age information, demographic information and information related to the diagnosis and treatment of health conditions, over-the-counter and prescription medications, laboratory test results, fitness status, nutritional and behavior information.

HOW WE USE AND DISCLOSE THE INFORMATION

Except as described in this Privacy Policy and in our Terms of Service, information that you provide or that we collect from you will be kept confidential and used to support use of the Services by End Users, Patients, and Providers and applications that interact with it. 

HealthSnap needs to ensure that we have your explicit permission to utilize the information collected through your use of and interaction with the Services for the purposes that we envision. Because of that, we need your permission, or license, to use information collected either from you or any Provider in of your Care Team. You hereby grant to HealthSnap a non-exclusive, transferable, sublicensable, irrevocable, royalty free license to use the information in order to provide the Services to you, your Provider and your entire Care Team as necessary to monitor and improve the Services, and to provide treatment to or collect payment from you. The license is non-exclusive, fully-paid and royalty-free, sublicensable, transferable, irrevocable and worldwide. You also grant HealthSnap a perpetual, non-exclusive, transferable, sublicensable, irrevocable, royalty free license to use such information and other data we collect from you via your or a Provider’s use of and interaction with the Services in order to collect, develop, create, extract or otherwise generate statistics and other information and to otherwise compile, synthesize and analyze such information and de-identified data. Notwithstanding anything to the contrary in this Privacy Policy, to the extent that HealthSnap collects or generates de-identified data, such de-identified data will be owned solely by HealthSnap and may be used for any lawful business purpose without a duty of accounting to you. 

Except as described below, we will never rent or sell your information in a personally identifiable form to anyone:

A.     Vendors, Agents, Contractors. Agents, technology vendors and/or contractors of HealthSnap may have access to your information on a need-to-know basis for the purpose of performing services on behalf of HealthSnap or providing or enabling elements of the Services. All such agents or contractors who have access to such information are contractually bound to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for HealthSnap or as otherwise required by law. 

B.     Your Provider Invitees and Providers. If you have a provider that you want to share your wellness journey with on the Services and said provider has not already invited you to use the Services, you may be able to send an invitation to the provider to connect with you directly from the app. In order to send an invitation to the Provider Invitee, we may ask you for information such as their name, their email address, and their relationship to you. 

When you share the email address of a Provider Invitee, you are doing so under the full knowledge that if accepted, the Provider Invitee becomes a connected Provider for you and as such, will receive the Personal Information you have entered into the app. The Provider will be able to view and participate in all activity including viewing all your historical personal health information that is already in your account, adding personal health information for you,  viewing and adding content including notes, images, etc., viewing and adding comments, make recommendations, etc. Additionally, the Provider will be able to see, share, add to, modify or delete content that you have added to the app including, but not limited to notes, messages, photos and personal health information. Additionally, the Provider may may invite other users to become “Invitees.”    

If, and only if, you connect with a Provider (either by inviting and the Provider accepting or  by you accepting a Provider’s invitation to connect), you acknowledge that your Personal Health Information will be disclosed without your written authorization to that Provider which has a legal commitment to maintaining the privacy and security of your Personal Health Information – and as otherwise permitted or required by law to any of the aforementioned parties. Again, we will never share your Personal Health Information with any Provider unless you are connected. 

HIPAA – This Privacy Policy is designed to comply with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Providers, to the extent they are “Covered Entities” under HIPAA (as defined in HIPAA) have their own privacy and security obligations with respect to your Personal Information and PHI. HealthSnap has agreements, called Business Associate Agreements, in place with Providers, which define our security and privacy obligations to them and their patients. Our Business Associate Agreement with Providers can be viewed here and is incorporated herein by reference as if fully set forth. We encourage you to contact each Provider with whom you interact with through the Services regarding their privacy and security practices. For more information regarding your rights under HIPAA, see http://www.hhs.gov/ocr/privacy/. 

C.     Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, business collaboration or partnership or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract. 

D.     As Required By Law and Similar Disclosures. We may disclose Personal Information and any other information to comply with the law, judicial proceeding, court order, subpoena or other legal process; to detect, prevent, or otherwise address fraud, security, emergency situations or technical issues; to enforce or apply our Terms of Service and other agreements, rights and remedies; or to protect the rights, property, or safety of us, our employees and contractors, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes. 

E.     Customer support and troubleshooting. If you contact us with a question, our support team may view your data if doing so is necessary to solve your problem. We may also ask you follow-up questions requiring additional information. Access to your data is limited to the information reasonably necessary for the employee to perform the function needed to resolve the issue or to improve the service.

F.     Scientific research. At HealthSnap, we’re looking for breakthroughs in lifestyle medicine that will make people’s lives better. Both we and our research partners, including academics or medical facilities may use your de-identified, aggregated data from the Services to conduct and/or publish this research. These findings could be used for scientific and/or medical abstract, journals, oral presentations, poster presentations, journalism, or internal usage to better your and other patients’ experience. Depending on the situation and the purpose of the research investigation, we may or may not charge third parties for de-identified, aggregated information. We require medical facilities and research groups whom we share aggregate information to agree that they will not attempt to make this information personally identifiable, such as by combining it with other databases. Information we share with outside researchers will be de-identified (anonymous) and not associated with your name or any Personal Information you provided to us. By accepting this Privacy Policy and Terms of Service, you give consent to third-party medical facilities and research groups to use the de-identified, aggregate data provided by HealthSnap, our website or related apps and tools. 

G.     E-mail and Other Communications. We may contact you, by email or other means; for example, we may send you promotional offers on behalf of other businesses, or communicate with you about your use of the Services. We may receive a confirmation when you open an email from us which makes emails more relevant and improve our service. If you do not want to receive email or other mail from us, please indicate your preference by selecting the opt-out option in emails received from us or by adjusting your account settings.

CONFIDENTIALITY AND SECURITY OF INFORMATION

We take steps to ensure that information provided to us is treated securely and in accordance with this Privacy Policy. We maintain physical, electronic, and procedural safeguards designed to protect the Information. These safeguards include, without limitation, encrypting all Personal Information and Protected Health Information using AES 256-bit encryption and encrypting all other data using TLS encryption. Unfortunately, the Internet is not 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

If you use our Services, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing your account.

By using the Services or any HealthSnap service you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice in the Services, on our website or by sending an email to you. You may have a legal right to receive this notice in writing. To receive written notice of a security breach (or to withdraw your consent from receiving electronic notices), please notify us at info@HealthSnap.io.

CHILDREN’S PRIVACY

We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register for the Services. If you are under 18, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

INTERNATIONAL USERS

Please note, at this time the Services are not for use by international users, and specifically not for use by users within the European Union. If you access the Services in contravention of the previous prohibition, note that information collected from you will be stored and processed in the United States or any other country in which HealthSnap or its affiliates, subsidiaries, agents or contractors maintain facilities and that if you are accessing the Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your data to the United States and processing globally. By providing your Information you consent to any transfer and processing in accordance with this Privacy Policy and that any dispute over privacy or anything contained in this Privacy Policy will be governed by the laws of the United States and jurisdiction will lie in the state of Florida.  

UPDATING YOUR INFORMATION; QUESTIONS; SUGGESTIONS

If you have any questions or concerns about this Privacy Policy or the use of your information, or to modify or update any information we have received, please contact us at info@HealthSnap.io. 

You may request access to, correction of, or deletion of your Personal Information. For instructions on accessing your information, updating your information or for any privacy or data-protection-related question, please write to info@HealthSnap.io.

If at any point you do not want your aggregated data used for research purposes, you must submit a written letter to HealthSnap’s main office located at the address set forth below with this request. HealthSnap will have 60 days to respond to the request. Upon receiving your request, we will delete your Personal Information from our active databases to the fullest extent possible keeping in mind that it is technologically impossible to remove each and every record of the information you have provided to HealthSnap or records saved by former and current Providers.

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

We may update this privacy policy to reflect changes to our information practices. If we make any changes to our Privacy Policy it will be posted on this page. We encourage you to periodically review this page for the latest information on our privacy practices.

CONTACT US
For questions or comments about this Privacy Policy, please email us at info@HealthSnap.io. 

You can also reach us by mail at:
HealthSnap Inc.
attn: Compliance Officer
1951 NW 7th Ave, Suite 600
Miami, FL 33136