Hale Health, Inc. (“Hale”) develops, operates and distributes certain software applications ("Apps"), which include web apps, hosted applications and applications for mobile devices. The Apps, together with the services for communications, coordination and management by patients and healthcare professionals regarding medical conditions, and the data collection, storage, analysis and reporting tools, functions and services, that are provided via the Apps, are collectively referred to as the "Service".
The following policy explains how Hale collects, uses and disseminates information obtained from or about you as a user of the Service. Capitalized terms used herein without definition will have the same meanings as defined in the Terms of Service applicable to the Service, which are available at www.hale.co/tos.
When you visit the Hale website (the "Site") or otherwise access the Service, web servers collect general information about your visit (such as, for example, traffic data like time, date and the address of the website from which you entered the Site), which is stored as anonymous, aggregate data. Hale also collects more specific information about you and your use of the Service (such as, for example, demographic data, profile data and frequency or duration of use). Collecting such data (collectively, "Traffic Data") may entail the use of software programs, web beacons, pixel tags, cookies, IP addresses or other numeric codes used to identify a computer.
The Service may be accessed: by visiting the Hale website directly; or by using an App that is downloaded from Hale (or a Channel Partner), which then communicates with Hale’s web servers.
Regardless of how you access the Service, to ensure the integrity of the Service, you must complete an account registration process and provide Hale with current, complete and accurate information, as more specifically required by then current registration procedures and operational prompts. If some or all of your registration information has already been provided to Hale by the Clinical Partner, then you will need to review and confirm, complete or correct your information.
By way of illustration and not limitation, you may be required to provide the following information in order to establish your account and register for and use the Service: name, address, telephone number, e-mail address, date of birth, username, password and certain preferences and permissions.
Whenever you interact with the Service, a variety of technologies are employed to automatically or passively collect Service Data. The term "Service Data" means all data and information that are provided by you during registration and subsequent use of the Service (including messaging related to Healthcare Services), and all other data and information about you that are otherwise discerned or collected by Hale based on your access and use of the Service. For clarity, Service Data includes, but is not limited to: PII; PHI; browser or device type; operating system; time of day; identification of Site or App page views; use of particular Service features (such as, for example, report requests or viewing or responding to queries from Clinicians); and geographic location. At no time will an App access, collect or store any of the personal contacts or photographs or any other information stored on your device without your permission.
Except as set forth below, at no time will any of your Personal Data be shared with any third party by Hale. Your IP address is not linked to personally identifiable information, but is used to gather broad demographic data and to monitor statistics to improve the Service.
Hale uses Traffic Data to help diagnose problems with its web servers, to administer the Service and to analyze user trends and behaviors. Hale will share Traffic Data with certain third parties for the purposes of technical and customer support.
Hale collects, stores, processes and analyzes Service Data and produces Analytics. The term "Analytics" means user profiles and statistics, metrics, abstractions and other analyses that are based on or derived from your use of the Service and Service Data, which are developed in the aggregate with other data, results and measurements or in a manner that does not disclose the identity of any Patient, Clinician or Clinical Partner or any specific Service Data (except in aggregated or de-identified form).
Hale will use your Service Data and exploit Analytics in the manner and for the purposes described in the Terms of Service, including without limitation: to use Service Data to communicate with you and your Patients, Clinician(s) and Clinical Partner (as the case may be); to include, copy, disclose, distribute, transmit and display Service Data in communications between a Patient and his or her Clinician (and vice versa) that have been properly initiated via the Service; to access, record, collect, copy, store, process, analyze and use Service Data to provide the Service (including with regard to the use of PHI in messaging between a Patient and his or her Clinician); to develop, improve, extend and test the Service (and underlying technology platforms); to design, develop and produce Analytics; to market and promote Hale and the Service using Analytics; and to disclose, distribute and transmit Service Data and/or Analytics to Clinical Partners.
Hale uses your IP address to help diagnose problems with its web servers and administer the Service. Your IP address is used to help identify you, gather demographic information, and provide an audit trail regarding use of the Service.
Cookies are pieces of information that a website transfers to your computer’s hard disk for record-keeping purposes. Cookies in and of themselves do not personally identify users, although they do identify a user’s computer.
At this time, the Service does not utilize cookies. However, Hale does use the local storage on your device to track whether or not you are logged in and to store session-specific preferences. We do not save any other information about you in local storage.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities, over time and across different websites.
When you turn on the Do Not Track function in your browser, Hale stops collecting the information from your browser that allows us to tailor the Service specifically to you. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked.
For clarity, this is just our Do Not Track policy. Hale cannot and does not make any promise about how third parties react when you set the Do Not Track signal on your browser. In addition, the Do Not Track signal does not apply to the use of information collected prior to such request.
Currently, Hale will not share Personal Data with any third party for purposes that are not related to the Service or its arrangements with applicable Clinical Partners. Hale may, however, disclose Personal Data if (a) reasonably necessary for Hale (or its service providers) to operate the Service, including processing your queries, responses and other messages, (b) to communicate with Patients, Clinicians and Clinical Partners, (c) otherwise permitted under the Privacy Policy or elsewhere in the Terms of Service, (d) Hale reasonably believes that such action is necessary to conform or comply with any legal, regulatory, law enforcement or similar requirement or investigation, to protect or defend the rights or property of Hale or any third party or to enforce the Terms of Service or (e) otherwise authorized by you.
In operating the Service, and as it relates to PHI, Hale endeavors to comply in all material respects with HIPAA. Please request our full policies for more information.
Shine the Light. Under California Civil Code Section 1798.83 (the “Shine the Light” law), California residents who provide personal information in obtaining products or services from Hale are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2020 will receive information regarding 2019 sharing activities). If you are a California resident and would like a copy of this information, please submit a written request to:
Hale Health, Inc., P.O. Box 225310, San Francisco, CA 94122
CCPA. For purposes of this CCPA Section only, the terms “personal information,” “collection,” “sell,” “business purpose,” and “commercial purpose” have the meanings assigned to them under the California Consumer Privacy Act of 2018 (the “CCPA”).
If you reside inCalifornia, you have certain rights as set forth below. These rights are in addition to any other rights you may have under this Policy. If you have any questions about these rights or how to exercise the, please contact us as described in the Contact Section of this Policy. Please note that we may disclose your personal information for business or commercial purposes as described in this Policy. For more information about the categories of personal information we collect, the sources from which we collect personal information, and how we use, disclose, and share this information, please see theInformation Collected Section and the Use of Information Section of thisPolicy.
Disclosure and deletion requests. You have the right to request that we disclose to you what personal information about you we collect, use, disclose, and sell. Subject to certain limitations in the CCPA, you also have the right to request that we delete your personal information. You may submit such a request by contacting us as described in the Contact Section of this Policy. If you submit a request by email, please include “CCPA” in the subject line. We will not discriminate against you for exercising your rights under the CCPA.
Right to opt out. The CCPA also provides California consumers the right to opt out of the sale of their personal information. As explained in this Policy, we do not sell the personal information of our users.
Verification. We reserve the right to verify any request made under the CCPA by asking you to provide supporting documentation that the request is submitted by you, although we are not obligated to verify a request. You may also choose to have an agent submit a request on your behalf, in which case we may, but are not obligated to, verify that the agent is authorized to act on your behalf. We assume no responsibility for responding to any consumer requests.
Hale may transfer Traffic Data, Service Data (including Personal Data) and Analytics to any successor to all or substantially all of its business or assets that concerns the Service. In the event of any such transfer, the successor will have all of the rights and be subject to all of the obligations of this Privacy Policy, including, without limitation, the right to modify or replace this Privacy Policy, as provided herein.
Information collected by Hale is stored in operating environments that are secured using commercially available tools and procedures, and which are not made generally available to the public. Unfortunately, no data transmission over the Internet and/or wireless networks can be guaranteed to be 100% secure. As a result, Hale cannot unequivocally guarantee the security of any information you provide, and you do so at your own risk. Once Hale receives your information, it will make reasonable efforts to ensure its security on Hale’s systems.
You may be able to obtain an App, access the Service and/or communicate with the Service from, and you may be able to link or communicate from the Service to, applications, devices, distribution platforms and websites owned and operated by Channel Partners and Clinical Partners. These other applications, devices, platforms and websites are not operated or controlled by Hale. Additional or different terms and conditions (including without limitation, privacy and security practices) apply when you access and use such other applications, devices, platforms and websites, which are not the responsibility of Hale.
If you terminate your registration and account for the Service, or if your registration or account is terminated for any reason by Hale, then Hale will remove Service Data from the Service if explicitly requested by the Patient; provided, Hale may retain and use your Service Data in the manner described herein, but only in aggregated or de-identified form.
YOU EXPRESSLY CONSENT TO THE TRANSMISSION, COLLECTION, STORAGE, PROCESSING AND USE OF THE ANALYTICS AND YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. YOUR PERSONAL DATA MAY BE COLLECTED, STORED, PROCESSED, USED AND TRANSMITTED WITHIN, FROM AND TO THE COUNTRY WHERE IT WAS COLLECTED AND THE UNITED STATES. UNITED STATES LAWS REGARDING THE USE OF PERSONAL DATA MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.
Hale reserves the right, at its sole discretion, to update, modify or replace this Privacy Policy, in whole or in part, at any time. Hale will use reasonable efforts to notify you of any material change in advance of the effective date of any change. Change notices may be communicated by postings at the Site, via the Apps, e-mail or otherwise. In any case, you should periodically check this Privacy Policy for changes. Continued access or use of the Service following any change to this Privacy Policy constitutes your acceptance of those changes. The Privacy Policy may not otherwise be amended, as they apply to you, except by a written agreement executed by you and Hale.
Information collected by the Service is subject to the Privacy Policy in effect at the time of use.
You may correct or otherwise change your registration data by contacting Hale, as provided below.
Hale is based in California, in the United States. Hale has appointed an internal data protection officer for you to contact if you have any questions or concerns about Hale’s personal data policies or practices. Hale’s data protection officer’s name and contact information are as follows:
Chris Lintz
P.O. Box 225310
San Francisco, CA 94122
dpo@hale.co
+1 855-400-8855
If you have any questions regarding this Privacy Policy or your dealings with the Service, please visit www.hale.co/tos or contact us at: support@hale.co