This Privacy Statement is designed to tell you about our practices regarding the collection, use, and disclosure of information about you through your use of the digital health and wellness tools (the “Programs”) provided to you by New Ocean Health Solutions (“New Ocean”).
This application (the “Application”) allows you to use the Programs made available to you by your sponsor, which may be your employer-sponsored health plan, your health insurer, HMO, or your healthcare provider (your “Sponsor”). The Application’s primary function is to provide the Programs to you. In addition, the Application may be used as a point through which you may access other information and services made available to you by your Sponsor. Your participation in the Programs and use of the Application are voluntary and based on your eligibility as determined by your Sponsor.
By registering for the Application and participating in the Programs, you agree to the terms of this Privacy Statement.
- Collection of Personally Identifiable Information.
- Information about you is collected directly from you through the Application and may also be collected from your Sponsor. This information will include your name, date of birth, address, telephone number, and health information about you, including information pertaining to medications, appointments, medical conditions, medical history, measurements, etc. This information may reveal sensitive information about you, such as mental health, HIV/AIDs status, or substance abuse information.
- We also collect certain information through automated means. Some of the information we collect through automated means may, whether alone or combined with other data, be personally identifiable information. You can learn more about this in the Section below called “Passive Information Collection, Uses and Choices.”
- If you allow us to access data from third party applications and services, such as fitness applications that you use, we may receive information collected by those applications and services, such as heart rate, calorie burn, sleep patterns, steps, speed, etc.
- Certain Programs offer location-based features, such as mapping, routes, speed calculations, and other tracking. If you activate these features, then we may receive location data including GPS signals, device sensors, Wi-Fi access points, and cell tower IDs to determine your location. You can learn more about this in the Section called “Passive Information Collection, Uses, and Choices” below.
- Use of Personally Identifiable Information Collected. We may use personally identifiable information to deliver the Programs to you, and to respond to your inquiries or requests. We may also use information that we collect to improve the Programs or the Application, and for our analyses. We may remove the elements of your information that could identify you. We may use and disclose the resulting “de-identified” information without restrictions. For example, New Ocean may create de-identified, statistical, and aggregate data to prepare reports about the Programs for your Sponsor that do not identify any individual participants. [You may opt to receive e-mails, SMS text messages, and telephone notifications from the Application. Email or telephone communications and text messages will be sent to the email address and/or mobile telephone number that you provide to the Application. These communications may contain health information.]
- Disclosure of Personal Information. We may share information about you with the following parties for the purposes described below:
- to your Sponsor. We may provide personally identifiable health information about you and your participation in the Programs to your Sponsor. Your Sponsor may use and disclose such information for the purposes described in the Notice of Privacy Practices that your Sponsor has delivered to you as required by the Health Insurance Portability and Accountability Act (HIPAA).
- to health coaches who may assist you with your participation in the Programs.
- to our contractors who assist us in managing, administering or delivering the Programs. We will require such parties to protect and govern the use of the information about you according to this Privacy Statement and other requirements that we place upon them by contract.
- in connection with the sale, assignment, or other transfer of the business of our Programs or this Application, we may transfer the information about you, in which case we will require any such buyer or acquiring party to agree to treat the information in accordance with this Privacy Statement.
- to respond to law enforcement requests or where required by applicable laws, court orders, or government regulations
- We will not sell or otherwise give information about you to other parties for their marketing purposes.
- If you choose to share information with a caregiver using the Application, we may share information with that caregiver in accordance with the authorization you sign specifically giving the caregiver access to information about you.
- Security Measures and Communicating with New Ocean. We take reasonable steps to protect information about you in our possession and control, such as for information associated with the Application, and to protect such information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. You should keep in mind that no Internet transmission is ever completely secure or error-free. In particular, e-mail sent between you and us may not be secure.
- Passive Information Collection, Use, and Choices
As you navigate the Application, certain information may be passively collected, meaning it is gathered without your actively providing it. This is done using the following technologies in the following ways:
- Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.
- Through your device: If you access the Application through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the Application.
- (i) recognize your computer or device to make your use of the Application easier, such as to remember your locations of interest and other preferences with the Application;
- (ii) gather statistical information about use of the Application in order to continually improve its design and functionality, understand how individuals use it, and to assist us with resolving questions regarding it; and
- (iii) select which offers are most likely to appeal to you and display them while you are on the Application.
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- Using Monitoring Tools: The Application may utilize pixel tags, web beacons, clear GIFs, Flash Shared Objects, HTML5 Local Storage, HTML5 Mini Databases, and other similar technologies, both on certain aspects of the Application and in HTML-formatted e-mail messages to you. These monitoring tools are used for the purpose of, among other things, compiling statistics about Application usage and response rates, and tracking the activities of users of the Application and e-mail recipients.
- IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Application, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Application usage levels, helping diagnose server problems, and administering the Application.
- Analytic Tools: We also use tools and third party services to collect information about usage of the Application, including Google Analytics. You can learn more about Google Analytics, and its privacy practices, at the Google Analytics Help Page. Generally speaking, Google Analytics collects information on how often users visit the Application, what aspects of the Application they visit when they do so, and what other websites users visited prior to accessing the Application. The Application makes use of Google Analytics services for demographics and interest reporting, You may prevent your data from being collected and used by Google Analytics by opting out through the use of the Google Analytics Opt-out Browser Add-on.
If you are uncomfortable with the idea of your information being collected and used in these ways, most computer systems, devices, and web browsers offer privacy settings and options, such as disabling cookies, resetting your IDFA, turning off location-based services, or opting for “Do Not Track” features. We do not override these settings or options and encourage you to use them to enhance your choices and personalize your experiences. However, in order to access certain content, features, services, products, or benefits of the Application, you may be required to provide us with certain information. If you do not wish to provide that information through the Application or if you opt to utilize the aforementioned privacy features, you may be unable to obtain certain content, features, services, products, or benefits of the Application.
If you have any questions or concerns about this Privacy Statement, the practices of New Ocean, or your experience with the Application, you can contact New Ocean Health Solutions at support@NewOceanHealthSolutions.com.
Dated: December 1, 2017.
Copyright © 2017 New Ocean Health Solutions; All rights reserved.