Effective Date: May 29th, 2018
I. COLLECTION OF INFORMATION
We may collect the following kinds of information when you use the Services:
Information you provide directly to us. For certain activities, such as when you register, use our telemedicine services, subscribe to our alerts, or contact us directly, we may collect some or all of the following types of information:
- Contact information, such as your full name, email address, mobile phone number, and address;
- Username and password;
- Payment information, such as your credit card number, expiration date, and credit card security code;
- For health care providers, information about your employment, such as your job title, practice area, primary specialty, and medical license status, gender, date of birth, languages spoken, educational background, address, photograph, social security number, Tax ID, NPI number, professional license information and bank account information;
- Personal health information, including information about your diagnosis, previous treatments, general health, and health insurance; and
- Any other information you provide to us.
We may combine such information with information we already have about you.
Information we collect automatically. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, device and advertising identifiers, browser type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, information about the links you click and pages you view within the Services, and other standard server log information. We may also collect certain location information when you use our Services, such as your computer’s IP address, your mobile device’s GPS signal, or information about nearby WiFi access points and cell towers.
We may also collect technical data to address and fix technical problems and improve our Services, including the memory state of your device when a system or app crash occurs while using our Services. Your device or browser settings may permit you to control the collection of this technical data. This data may include parts of a document you were using when a problem occurred, or the contents of your communications. By using the Services, you are consenting to the collection of this technical data.
Information we obtain from your health care providers and other sources. In connection with your treatment, we may collect medical records from your past, current, and future health care providers. This may include information about your diagnosis, previous treatments, general health, laboratory and pathology test results and reports, social histories, any family history of illness, and records about phone calls and emails related to your illness.
We may also receive information about you from other sources, including through third-party services and organizations. We may combine our first-party data, such as your email address or name, with third-party data from other sources and use this to contact you (e.g. through direct mail). For example, if you access third-party services, such as Facebook, Google, or Twitter, through the Services to login to the Services or to share information about your experience on the Services with others, we may collect information from these third-party services.
II. USE OF INFORMATION
We generally use the information we collect online to:
- Provide and improve the Services;
- Contact you;
- Fulfill your requests for products, services, and information;
- Send you information about additional clinical services or general wellness from us or on behalf of our affiliates and trusted third-party partners;
- Analyze the use of the Services and user data to understand and improve the Services;
- Customize the content you see when you use the Services;
- Conduct research using your information, which may be subject to your separate written authorization;
- For any other purposes disclosed to you at the time we collect your information or pursuant to your consent.
III. SHARING OF INFORMATION
We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect.
- Healthcare providers, insurance companies, and other healthcare-related entities. We may share your information with other health care providers, laboratories, government agencies, insurance companies, organ procurement organizations, medical examiners or funeral directors, and other entities relevant to providing you with treatment options and support.
- Authorized third-party vendors and service providers. We may share your information with third-party vendors and service-providers that help us with specialized services, including billing, payment processing, customer service, email deployment, business analytics, marketing (including but not limited to advertising, attribution, deep-linking, direct-mail, mobile marketing, optimization and retargeting) advertising, performance monitoring, hosting, and data processing. These third-party vendors and service providers may not use your information for purposes other than those related to the services they are providing to us.
- Research partners. We may share your information with our research partners to conduct health-related research; such sharing may be subject to your separate written authorization.
- Corporate affiliates. We may share your information with our corporate affiliates that are subject to this policy.
- Business transfers. We may share your information in connection with a substantial corporate transaction, such as the sale of a website, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
- Legal purposes. We may disclose information to respond to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend the rights, interests, health, safety, and security of American Well, our affiliates, users, or the public. If we are legally compelled to disclose information about you to a third party, we will attempt to notify you by sending an email to the email address in our records unless doing so would violate the law or unless you have not provided your email address to us.
- With your consent or at your direction. We may share information for any other purposes disclosed to you at the time we collect the information or pursuant to your consent or direction.
If you access third-party services, such as Facebook, Google, or Twitter, through the Services to login to the Services or to share information about your experience on the Services with others, these third-party services may be able to collect information about you, including information about your activity on the Site, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.
If you choose to engage in public activities on the Site or third party sites that we link to, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in these public areas
We use reasonable measures to help protect information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. You should understand that no data storage system or transmission of data over the Internet or any other public network can be guaranteed to be 100 percent secure. Please note that information collected by third parties may not have the same security protections as information you submit to us, and we are not responsible for protecting the security of such information.
V. YOUR CHOICES
You may opt out of receiving general health and wellness or treatment options that may be relevant to you by emailing us at email@example.com. You may also request that we delete your personal information by sending us an email at firstname.lastname@example.org.
You may be able to refuse or disable cookies by adjusting your web browser settings. Because each web browser is different, please consult the instructions provided by your web browser (typically in the “help” section). Please note that you may need to take additional steps to refuse or disable Local Shared Objects and similar technologies. For example, Local Shared Objects can be controlled through the instructions on Adobe’s Setting Manager page. If you choose to refuse, disable, or delete these technologies, some of the functionality of the Services may no longer be available to you.
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal information to third parties for their direct marketing purposes in the preceding calendar year. We do not share personal information with third parties for their own direct marketing purposes.
VI. THIRD-PARTY ADVERTISING, LINKS, AND CONTENT
Some third parties collect information about users of our Services to provide interest-based advertising on our Services and elsewhere, including across browsers and devices. These third parties may use the information they collect on our Services to make predictions about your interests in order to provide you ads (from us and other companies) across the internet. Some of these third parties may participate in an industry organization that gives users the opportunity to opt out of receiving ads that are tailored based on your online activities. Due to differences between using apps and websites on mobile devices, you may need to take additional steps to disable targeted ad technologies in mobile apps. Many mobile devices allow you to opt out of targeted advertising for mobile apps using the settings within the mobile app or your mobile device. For more information, please check your mobile settings. You also may uninstall our apps using the standard uninstall process available on your mobile device or app marketplace.
To opt out of interest-based advertising across browsers and devices from companies that participate in the Digital Advertising Alliance or Network Advertising Initiative opt-out programs, please visit their respective websites. You may also be able to opt out of interest-based advertising through the settings within the mobile app or your mobile device, but your opt-out choice may apply only to the browser or device you are using when you opt out, so you should opt out on each of your browsers and devices if you want to disable all cross-device linking for interest-based advertising. If you opt out, you will still receive ads but they may not be as relevant to you and your interests, and your experience on our Services may be degraded.
Do-Not-Track Signals and Similar Mechanisms. Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.
VII. INTERNATIONAL USERS
We participate in and have certified our compliance with the EU-U.S. Privacy Shield Framework. We are committed to subjecting all personal data received from European Union (EU) member countries, in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, visit the U.S. Department of Commerce’s Privacy Shield List. [https://www.privacyshield.gov/list]. We are responsible for the processing of personal data we receive, under the Privacy Shield Framework, and subsequently transfer to a third party acting as an agent on our behalf. We comply with the Privacy Shield Principles for all onward transfers of personal data from the EU, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at https://www.jamsadr.com/eu-us-privacy-shield. Under certain conditions, more fully described on the Privacy Shield website [https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint], you may invoke binding arbitration when other dispute resolution procedures have been exhausted.
We do not knowingly allow individuals under the age of 18 to create accounts that allow access to our Services.