2.1 INFORMATION WE COLLECT DIRECTLY FROM YOU.
There are certain services that require us to learn everything about you so that we can best meet your needs.
When you access the Services, or through any interaction with us via emails, telephone calls or other correspondence, we may ask you to voluntarily provide us with certain information that personally identifies you or could be used to personally identify you.
• (1) contact data (such as your e-mail address and phone number);
• (2) demographic data (such as your gender, your date of birth and your zip code);
• (3) insurance data (such as your insurance carrier, insurance plan, member ID, group ID and payer ID);
• (4) medical data (such as the doctors, dentists or other healthcare specialists, professionals, providers, organizations, or agents or affiliates thereof (collectively, “Healthcare Providers”) you have visited, your reasons for visit, your dates of visit, your medical history, and other medical and health information you choose to share with us);
• (5) Other identifying information that you voluntarily choose to provide to us, including without limitation unique identifiers such as passwords, and Personal Information in emails or letters that you send to us.
We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent. You can access and use some services if you choose to not provide the information. But the features that need your information will not be accessible to you.
Some information, which may include Personal Information, is automatically collected when you use our Services, such as the following:
• Traffic Data: We also may automatically collect certain data when you use the Services, such as
(1) IP address;
(2) domain server;
(3) type of device(s) used to access the Services;
(4) web browser(s) used to access the Services;
(5) referring webpage or other source through which you accessed the Services;
(6) geo-location information;
(7) other statistics and information associated with the interaction between your browser or device and the Services (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be Personal Information.
3. How We Collect Information
We also collect information (including Personal Information and Traffic Data) when you use and interact with the Services, and in some cases from third party sources. Such means of collection include:
• When you use the Services’ interactive tools and services, such as searching for Healthcare Providers, searching for available appointments with Healthcare Providers and completing medical history forms (“Medical History Forms”) prior to Healthcare Provider appointments; • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys, questionnaires and the like;
• If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices;
• If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable;
• Through cookies, web beacons, analytics services and other tracking technology (collectively, “Tracking Tools”), as described below; • When you use the “Contact Us” function on the Site, send us an email or otherwise contact us.
4. Tracking Tools, Behavioral Advertising, and Opt Out Options
4.1. Tracking Tools
We might use a type of advertising mainly known as interest-based or online behavioral advertising. This means that some of our partners use Tracking Tools, such as cookies, pixel tags, and web beacons, to collect information about a user’s online activities to display Find my doctor ads to the user based on the user’s interests (“Behavioral Advertising”). Such partners might in-corporate third-party service providers, advertisers, advertising networks or platforms, traffic measurement service providers, marketing analytics service providers, and other third party service providers (collectively, “Advertising Service Providers”). Other than that, there are many tracking tools used by our partners to collect all the information when the services are being used, such as IP address, mobile device ID, operating system, web page interactions, geographic location and demographic information such as gender and age range. These Tracking tools help Find My Doctor learn more about our users’ demographics and internet behaviors. 4.3. Options for Opting out of Cookies and Mobile Device Identifiers
At times, the web browser allows you to reject cookies or alert you when they’re about to pop up on your computer, tablet or mobile device. You may be able to reject mobile device identifiers by activating the appropriate setting on your mobile device. Although you are not required to accept Find My Doctor cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.
4.4. How Find My Doctor Responds to Browser “Do Not Track” (DNT) Signals Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (DNT) or similar feature that signals to web services that a visitor does not want to have his/her online activity and behavior tracked. If a web service operator elects to respond to a particular DNT signal, the web service operator may refrain from collecting certain Personal Information about the browser’s user. Not all browsers offer a DNT option and there is currently no industry consensus as to what constitutes a DNT signal. For these reasons, many web service operators, including Find My Doctor, do not proactively respond to DNT signals. For more information about DNT signals, visit http://allaboutdnt.com.
5. How We Use Your Information
We may use information that is neither Personal Information nor PHI (including non-PHI Personal Information that has been de-identified and/or aggregated) to understand in better ways who uses Find My Doctor and how we can deliver a better healthcare experience (for example, testing different kinds of emails has helped us understand when and how patients prefer to get Wellness Reminders for preventive care), or otherwise at our discretion. We use information, including Personal Information, to provide the Services and to help improve the Services, to develop various new services, and to advertise (for example, to display Find My Doctor ads on other web services). Specifically, such use may include:
• Providing you with the products, services and information you request;
• Responding to correspondence that we receive from you;
• Contacting you when necessary or requested, including to remind you of an upcoming appointment;
• Providing, maintaining, administering or expanding the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
• Customizing or tailoring your experience of the Services, which may include sending customized messages or showing you Sponsored Results;
• Notifying you about certain resources, Healthcare Providers or services we think you may be interested in learning more about;
• Sending you information about Find My Doctor or our products or Services;
• Sending emails and other communications that display content that we think will interest you and according to your preferences;
• Showing you advertisements, including interest-based or online behavioral advertising;
• Using statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
• Fulfilling our legally required obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities;
• Resolving disputes;
• Protecting against or deterring fraudulent, illegal, or harmful actions; and
In certain circumstances, and in order to perform the Services, we may share certain information that we collect from you, as described in this section:
• Healthcare Providers: We may share your Personal Information with Healthcare Providers with whom you choose to schedule through the Services. For example, if you complete a Medical History Form using the Services in advance of an appointment and elect to share it with your selected Healthcare Provider, we may share your Medical History Form with such selected Healthcare Providers. Provided that you choose to use the applicable Services, we may share your Personal Information with your Healthcare Providers to enable them to refer you to and make appointments with other Healthcare Providers on your behalf or to perform analyses on potential health issues or treatments. We may share your Personal Information with Healthcare Providers in the event of an emergency.
• We do not sell email addresses to third parties. We may share your Personal Information with our partners to customize or display our advertising.
• We may share your Personal Information and/or Traffic Data with our partners who perform operational services (such as hosting, billing, fulfillment, data storage, security, insurance verification, web service analytics, or ad serving) and/or who make certain services, features or functionality available to our users.
• Cross Device Matching: To determine if users have interacted with content across multiple devices and to match such devices, we work with partners who analyze device activity data and/or rely on your information (including demographic, geographic and interest-based data). To supplement this analysis, we also provide de-identified data to these partners. Based on this data, we may then display targeted advertisements across devices that we believe are associated or use this data to further analyze usage of Services across devices.
• We may share your Personal Information with the insurance provider you identify to us (and do so via our partners) to determine eligibility and cost-sharing obligations, or otherwise obtain benefit plan and other insurance-related information on your behalf.
• Public Information and Submissions: You agree that any information that you may reveal in a review posting, online discussion or forum is intended for the public and is not in any way private. Carefully consider whether to disclose any Personal Information in any public posting or forum. Your submissions may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.
• Protection of Find My Doctor and Others: We also may need to disclose your Personal Information or any other information we collect about you if we determine in good faith that such disclosure is needed to:
• (1) comply with or fulfill our obligations under applicable law, regulation, court order or other legal process;
• (2) protect the rights, property or safety of you, Find my doctor or another party;
• (3) enforce the Agreement or other agreements with you; or (4) respond to claims that any posting or other content violates third-party rights.
• Other Information: We may disclose information that is neither Personal Information nor PHI (including non-PHI Personal Information that has been de-identified and/or aggregated) at our discretion.
7. Storage and Security of Information
The security of your Personal Information is important to us. We endeavor to follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and in storage. Your account is protected by a password for your privacy and security. If you access your account via a third party site or service, you may have additional or different sign-on protections via that third party site or service. 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. Although we make good faith efforts to store Personal Information in a secure operating environment that is not open to the public, we do not and cannot guarantee the security of your Personal Information. If at any time during or after our relationship we believe that the security of your Personal Information may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address you have provided us in your account profile. Please keep your e-mail address in your account up to date. You can update that e-mail address anytime in your account profile.
8. Your Choices
You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features. If you are a registered user of the Services, you can modify certain Personal Information or account information by logging in and accessing your account. The information you can view, update, and delete may change as the Services change. If you wish to close your account, please email us at email@example.com. Find my doctor will use reasonable efforts to promptly delete your account and the related information. Please note, however, that Find my doctor reserves the right to retain information from closed accounts, including to comply with law, prevent fraud, resolve disputes, enforce the Agreement and take other actions permitted by law. You must promptly notify us if any of your account data is lost, stolen or used without permission.
9. How Long We Retain Your Information
We retain Personal Information about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Information for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, prevent fraud, enforce the Agreement, or as otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.
10. Information Provided on Behalf of Children and Others
11. Other Web Services