Pilltyme Privacy Policy Overview

Your access to, and use of, any PillTyme web based service, which includes this web site (www.pilltyme.com) (the “Web Site”), our mobile device applications (the “Apps”) and the information and services that we provide to you and other users through the Web Site and Apps (the “Service” or “Services”) is subject to the PillTyme Terms of Use and this Privacy Policy.

PillTyme, LLC (“PillTyme,” “we,” “us,” or “our”) has created this Privacy Policy to explain what information we gather from you when you use the Service, how we may use this information, the security approaches we use to protect your information, and how you can access and correct certain information that we may collect. We have tried to keep it simple.

Please note that this Privacy Policy applies only to information collected via the Web Site and Apps; it does not apply to information you disclose to PillTyme through offline correspondence or personal contacts with PillTyme representatives. This Privacy Policy is incorporated and made part of the PillTyme Terms of Use.

Your Acceptance of This Privacy Policy and Changes to It

By using the Web Site our Apps, you consent to the collection and use of your information by PillTyme in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, you may not use the Service. PillTyme reserves the right to change this Privacy Policy at any time, without prior notice. Changes take effect on the date that appears on the revised Privacy Policy. If you use our Services following a change in the Privacy Policy, your use will be understood to signal that you accept the changes. We will not provide you with individual notice of changes made to our Privacy Policy. We urge you to review this Privacy Policy frequently for changes.

What information do we collect?

We collect information from you each time you use any feature of the Service, which may include Personal Information. “Personal Information” means information that can specifically identify you as well as information about you that may be combined with identifying information, such as your name, address, phone number, date of birth, social security number, email address, etc.

We collect information about you to provide our Services, to enhance our user’s experience, and to help provide security and/or to improve system performance. We collect information about you from several sources, including:

From You:

  • When you provide us with information.
  • When you choose to complete surveys or questionnaires.
  • When you use the Service.
    • We use various tracking methods when people visit our Web Site or use our Apps
    • When you use the Service we will collect information that is specific to you. The following are some, but not all of the types of information we will collect. The specific elements change over time.
      • date and time of use,
      • type of mobile device,
      • type of browser,
      • number of sessions, and
      • activities you perform while using our application(s).

From Third Parties:

  • If you permit us to contact third parties, such as your employer, your health insurer, third-party administrators or a pharmacy-related service, we may collect medical-related information from these third parties.
  • These sources may provide Personal Information about you, your spouse and your dependents that may include, but is not limited to:
    • individual’s name,
    • date of birth,
    • gender,
    • mailing address,
    • telephone number,
    • email address,
    • medication related information,
    • medical conditions,
    • health insurance related data,
    • marital status, and
    • language spoken.

Non-Identifiable Information:

  • We will collect a range of information from all visitors to our Web Site using various methods and tools, including the use of cookies. Some of this information may be tied to your email address and as such, is identifiable as you. The types of information we collect include, but are not limited, to the following:
    • number of visitors to the Web Site,
    • number of downloads of our Apps,
    • the websites from which visitors came to our Web Site,
    • the pages visited while on our Web Site,
    • the length of visits to our Web Site,
    • the names of internet providers,
    • internet Protocol (IP) addresses,
    • browser information,
    • connection speed, and
    • search terms used to find our Web Site.

Like many web sites, we use “cookies” to enhance your experience and gather information about visitors and visits to our Web Site. Please refer to the “Do we use cookies?” section below for information about cookies and how we use them.

When using the Service we may ask you to provide us with certain health-related information. Please refer to the “Do we disclose the information we collect to outside parties?” section below for information about how we may use or disclose Protected Health Information.

Why Do We Collect Information About You?

We collect information about you in order to determine your eligibility for the Services, to provide you with such Services and to tailor our Services for you. Information may include Personal Information like your name, address, gender, medicine taken or your health conditions.

How do we use your information?

We may use the information we collect from you in the following ways:

  • To allow us to better service you in responding to your customer service requests.
  • To quickly process your transactions.
  • To troubleshoot problems with the Web Site, Apps, or our Services, as requested.
  • To enforce our PillTyme Terms of Use, and to detect and protect against error, fraud and other unauthorized or illegal activities.
  • To provide any legitimate business service or product.

Do we disclose the information we collect to outside parties?

We will disclose information we have about you in order to provide you with our services. We will share your Personal Information with third parties only in the ways that are described in this Privacy Policy. Disclosures will only be made to entities that are legally entitled to the data and are contractually committed to protect the data in accordance with applicable regulatory and contractual requirements.

Disclosure To Our Business Partners

  • We enter into agreements with our trusted business partners to assist us in providing you with our medicine management services, the Web Site and the Apps. These business partners are authorized to use your Personal Information only as necessary to provide our Services to you or as otherwise covered by our agreements with them. These business partners are required by the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”) and our agreements with them to protect your Personal Information (including your Protected Health Information, as defined in HIPAA) and to comply with applicable laws or regulations, including HIPAA.
  • We may also share your Personal Information with any third parties, such as pharmacies, doctors, health plan administrators, that you may authorize us to contact to provide our Services.
  • Research partners – We may share your Personal Information with third parties, such as research institutes, healthcare systems and healthcare providers, that they may associate with other information that they have about you, for research purposes and for improvement of our Services.
  • Providers of personalized third party content – From time to time, we may also ask whether you would like us to share your Personal Information with another company that may want to send you information about their products or services. If you consent to such transfer by us of your Personal Information to another company, please note that the information provided will be subject to such company’s privacy practices and shall not be within our control.
  • Content providers – We may also use your Personal Information in order to provide you with personalized third party content or links to third party sites that might interest you. We provide this third party content and/or links to third party sites for information purposes only and are not liable for such content or sites. For more information see the “Privacy and Third Party Links” section below.
  • Third Party Health Apps – We participate in Apple HealthKit, Samsung S-Health and Google Fit frameworks (the “Health Apps”) (1). We will use information that you consent that we receive from these Health Apps for research purposes, internally in order to improve our Services and in the form of aggregated and/or analytical data as described in the “Use of Aggregated Data” section of this Privacy Policy, and may transfer this data to third parties for such purposes. We may provide our users with the ability to share their data with other authorized services on their device after receiving their consent for the same. We will not sell any Protected Health Information nor will we use such information for advertising purposes. Please note that when you share information with third party apps, such information will be subject to their privacy policy, over which we have no control. In order to learn more, please visit each third party’s relevant pages and their respective privacy policies.
  • Service providers – We may share your Personal Information, as is reasonably necessary, with our contractors or consultants, including vendors and suppliers that provide us with (i) development services, (ii) technology services (such as Google Analytics), (iii) content for the operation, development and maintenance of our Web Site, Apps and data, and (iv) analysis on use of our Web Site and Apps, who are bound by an obligation of confidentiality, provided that we will only share Personal Information to the extent necessary with such contractors or consultants.

Personal Information You May Share Through Our Service

  • Referrals – You may send family members or friends an invitation to use our Services by means of features on the Web Site or Apps, so that those who are invited will receive alerts regarding your compliance with your medication regime (2). By sending such an invitation, you represent that you have the right to contact the person and that you consent to our sending Personal Information about your medications and your compliance with your medication regime to the person. Sharing of your Personal Information in this manner is solely your responsibility.
  • Medical professionals and Doctors – You may use the Service in order to share your Personal Information or other information with your doctor or healthcare providers (3). Such sharing may be enabled by inviting your healthcare provider to monitor your Personal Information, by accepting an invitation from your healthcare provider to download and use the Service, or otherwise using the Service settings to share your information with your healthcare provider; in these cases you consent to our sending Personal Information about your medications and your compliance with your medication regime with your healthcare providers. Such sharing of your information is at your discretion and is solely your responsibility.
  • Pharmacies and coupon companies – you may choose to share your Personal Information with pharmacies with which we partner, and/or third party companies, in order that we may send you coupons and/or provide you with reminders to get your prescription refilled (4). If you choose to share your Personal Information in this manner, please note that such information may be disclosed to these companies and/or pharmacies and will be subject to their privacy practices.

Use of Aggregated Data

Aggregated data will not contain any information that could be used to contact or identify you. We may analyze and/or combine all information we receive, including health information and information regarding your use of the Service, with information from other users to create aggregated data that may be disclosed to and utilized by us, our affiliates and by third parties without restriction, on commercial terms that we can determine in our sole discretion, for purposes such as: content marketing, research purposes, in order to understand behavior patterns, in order to increase adherence to medication regimens, marketing strategies and for entering into commercial contracts in order to provide our users with the Service. (5)

Disclosure To Meet Legal Requirements

We may share your Personal Information with a third party without prior authorization under any of the following conditions: (i) in compliance with law, regulation or other legal processes (ii) to protect the rights, property or safety of us or others, (iii) in emergency situations, or (iv) in the event that we, or substantially all of our assets, are acquired by one or more third parties as a result of an acquisition, merger, sale, reorganization, consolidation or liquidation, in which case Personal Information may be one of the transferred assets.

Sharing of information in any of these above cases will only be done when in full compliance with applicable laws, including HIPAA.

Do I have any options related to the use of my Personal Information?

You may “Opt Out” of communications from us if you wish by changing your communication preferences, but this will limit our ability to support you when or if you have questions. It will also limit our ability to provide you with important updates from us.

You may also tell us you do not want your data shared with us or shared by us with our partners and we will honor any such request, but if you choose this option we will not be able to provide you with the majority of our services.

Can I correct errors in my Personal Information?

You can correct or update your Personal Information by contacting us by electronic-mail xxx@xxx.com or by telephone [•]. It may take us up to 30 days to process your request.

Do we use “cookies”?

Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. Cookies help us in many ways to make your use of the Web Site more enjoyable and meaningful, such as understanding usage patterns and improving functionality of the Web Site.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Mozilla Firefox or Internet Explorer) settings. Each browser is a little different, so look at your browser Help menu to learn the correct way to modify your cookies. If you turn cookies off, you won’t have access to some features that make your Web Site more efficient.

Special Notification for California Residents (6)

Individual customers who reside in California and have provided their Personal Information to us may request information about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us at one of the following addresses: [email address] or PillTyme, LLC, Attn: [•], [physical address]. Within thirty (30) days of receiving such a request, we will provide a list of the categories of Personal Information disclosed to third parties for third-party direct marketing purposes during the immediately preceding calendar year, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the address specified in this paragraph.

Safeguarding Your Personal Information

PillTyme follows generally accepted industry security standards to safeguard and help prevent unauthorized access, maintain data security and correctly use such Personal Information. However, no commercial method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, we cannot guarantee the absolute security of that information during its transmission or its storage in our systems. Other than these security measures, you transmit data, including Personal Information, to us at your own risk.

Privacy and Third Party Links

This Privacy Policy applies solely to information collected by our Web Site and Apps. In an attempt to provide you with increased value, we may include third party links on our Web Site or in our Apps. These linked sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our Web Site and Apps and welcome any feedback about these linked sites (including if a specific link does not work).

Online Policy Only

This Privacy Policy applies only to information collected through our Web Site and Apps. It does not apply to information collected offline.

Retention of Your Personal Information

We will store the Personal Information you provide for as long as we believe is necessary or appropriate (i) to carry out the purpose(s) for which we collected it, or (ii) to comply with applicable laws, contracts, or other rules or regulations.

Disposal of any physical or electronic Protected Health Information is performed in compliance with HIPAA.

Regulatory Requirements

Whenever we collect or receive Protected Health Information, we do so under agreements with our business partners that require us to comply with the applicable Privacy Rule of HIPAA. You can learn more about the HIPAA Privacy, Security and Breach Notification Rules at https://www.hhs.gov/hipaa/index.html.

We take our obligations under HIPAA seriously and we take the necessary steps to safeguard your privacy and security.

Questions and Feedback

We welcome your questions, comments, and concerns about our Web Site and Apps. Please send us any and all feedback to [•].

The information contained in this Privacy Policy is subject to change without notice.

Effective Date: January 3, 2019

References

1. [NTD: As applicable. If they do not specifically use these apps at this time but may in the future, we can change this sentence to something more generic: “We may partner with third party providers of health-related applications for mobile devices (“Health Apps”).”

2. [NTD: Revise or remove as necessary to match actual features of the Service.]

3. [NTD: Revise or remove as necessary to match actual features of the Service.]

4. [NTD: Revise or remove as necessary to match actual features of the Service.]

5. [NTD: Certain third parties may prohibit use of their data in this manner and require an exception to this policy, such as Apple HealthKit.]

6. In compliance with Cal. Code CIV § 1798.83, available at https://codes.findlaw.com/. Note that beginning January 1, 2020, a new law will go into effect that will put further requirements on businesses with respect to personal information and this will need to be revised, see https://privacylaw.proskauer.com.

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