PERSONA DOCTORS PRIVACY POLICY
Last modified: March 1, 2025
THIS PRIVACY POLICY DESCRIBES HOW PERSONA DOCTORS COLLECTS AND USES PERSONAL DATA ABOUT YOU THROUGH THE USE OF OUR WEBSITE, MOBILE APPLICATIONS, AND THROUGH EMAIL, TEXT, AND OTHER ELECTRONIC COMMUNICATIONS BETWEEN YOU AND HEALTHFULLY, INC.
PERSONA DOCTORS (“PERSON DOCTORS,” or “we,” “our,” or “us”) respects your privacy, and we are committed to protecting it through our compliance with this policy.
This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the website app.personadoctors.com (our “Website”) and the PERSONA DOCTORS mobile application (our “App”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
· on our Website and App;
· in email, text, and other electronic messages between you and our Website and App;
· when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
· us offline or through any other means, including on any other website operated by PERSONA DOCTORS or any third party;
· any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or App.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website and Apps. By accessing or using our Website and/or App, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website or App after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.
Terms of Use. Your use of the Website and our App is governed by the PERSONA DOCTORS Anywhere Terms of Use available on our Website and the App.
HIPAA Privacy. Please review our Notices of Privacy Practices at the end of this Policy or provided separately to you by PERSONA DOCTORS and/or your treating physician for additional information about how your health information is collected, used and shared. The telehealth services available to users through the Site (“Services”) are provided by PERSONA DOCTORS affiliated physicians and independent physicians engaged by PERSONA DOCTORS to assist with providing the Services. Please carefully review any other Notices of Privacy Practices or other privacy policies that your treating physicians and other health care providers make available to you.
Medical Treatment. Minors under the age of 18 may use the App or Website to access telehealth services only with the guidance, consent and approval of a parent or legal guardian, unless applicable law provides otherwise (e.g., emergencies and other legal exceptions).
Adults. In order to access the Site and the Services, you represent and warrant that you are older than 18 years old.
WE COLLECT DIFFERENT TYPES OF INFORMATION ABOUT YOU, INCLUDING INFORMATION THAT MAY DIRECTLY IDENTIFY YOU, INFORMATION THAT IS ABOUT YOU BUT INDIVIDUALLY DOES NOT PERSONALLY IDENTIFY YOU, AND INFORMATION THAT WE COMBINE WITH OUR OTHER USERS. THIS INCLUDES INFORMATION THAT WE COLLECT DIRECTLY FROM YOU OR THROUGH AUTOMATED COLLECTION TECHNOLOGIES.
Generally
We collect several types of information from and about users of our Website and App, specifically information:
· by which you may be personally identified, such as name, postal address, billing address, shipping address, e-mail address, home, work, and mobile telephone numbers, driver’s license number (or other government identification number), date of birth, credit or debit card number (through a third-party payment processor solely for payment purposes), Social Security Number, your medical history, personal health information and related health information, and biometric information (including fingerprints) (“Personal Data”);
· that is about you but individually does not identify you, such as traffic data, logs, referring/exit pages, date and time of your visit to our Website or use of our App, error information, clickstream data, and other communication data and the resources that you access and use on the Website or through our App;
· about your Internet connection, the equipment you use to access our Website or use our App and usage details;
· Personal Health Information or PHI that may form part of your care record could also be collected in PERSONA DOCTORS. This could include information about your current health conditions, treatments, medicines, illnesses or allergies, symptoms, vitals, names of your health or social service providers or other patient reported information and health goals; and,
· Device Data information from your medical devices or fitness trackers.
We collect this information:
· directly from you when you provide it to us;
· automatically as you navigate through the Website or use our App. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and
· From third parties, for example, our business partners.
Information You Provide to Us
The information we collect on or through our Website or through our App is:
· information that you provide by filling in forms on our Website or the App. This includes information provided at the time of registering to use our Website or App, using our Provider consultation services, medical treatment, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Website or App;
· records and copies of your correspondence (including email addresses), if you contact us; and
· details of transactions you carry out through our Website or through the App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website or App.
You may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or App or transmitted to other users of the Website or App or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website and App with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website and App, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:
· details of your visits to our Website or App, such as traffic data, location, logs, referring/exit pages, date and time of your visit to our Website or use of our App, error information, clickstream data, and other communication data and the resources that you access and use on the Website or in the App; and
· information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and App version information.
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and App and to deliver a better and more personalized service by enabling us to:
· estimate our audience size and usage patterns;
· store information about your preferences, allowing us to customize our Website and our App according to your individual interests;
· recognize you when you return to our Website and our App.
The technologies we use for this automatic data collection may include:
· Cookies (or browser cookies). We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Website and App through your computer or mobile device. A cookie is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Website or use certain parts of our App. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or use our App.
· Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
WE USE YOUR PERSONAL DATA FOR VARIOUS PURPOSES DESCRIBED BELOW, INCLUDING TO:
· PROVIDE OUR WEBSITE OR APP TO YOU;
· PROVIDE PRODUCTS AND SERVICES TO YOU;
· PROVIDE YOU WITH INFORMATION YOU REQUEST FROM US;
· ENFORCE OUR RIGHTS ARISING FROM CONTRACTS;
· NOTIFY YOU ABOUT CHANGES; AND
· PROVIDE YOU WITH NOTICES ABOUT YOUR ACCOUNT.
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We use information that we collect about you or that you provide to us, including any Personal Data to:
· Present our Website and its contents to you;
· Present our App;
· Provide our products and services to you;
· Provide you with information, products, or services that you request from us or that may be of interest to you;
· Enable your health and social service providers also using {COMPANY NAME} to better provide you with those health or social services;
· Enable your family circle and circle of care to be better informed and engaged on your health and wellbeing to better provide you support;
· Process, fulfill, support, and administer transactions and orders for products and services ordered by you;
· Provide you with notices about your {COMPANY NAME} account;
· Contact you in response to a request;
· Fulfill any other purpose for which you provide it;
· Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
· Notify you about changes to our Website, our App, or any products or services we offer or provide though them;
· In any other way we may describe when you provide the information; and
· For any other purpose with your consent.
We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by visiting your Account Preferences page. For more information, see Choices About How We Use and Disclose Your Information.
There are several ways you can use the App and our Website to help accomplish your health goals:
(1) Health Communities: We enable people to join Health Communities, where they can participate with others to share health information, their own personal health experiences and other information online using {COMPANY NAME}. By doing this, the platform provides support, aids self-management, and improves interactions with professionals; all with the aim of improving day-to-day health and well-being.
When a user posts, comments or replies in our Health Communities they are identified only by their chosen username. A user selects a user-name upon registration and can change it in their profile setting at any time using {COMPANY NAME}. If a user wishes to remain anonymous for postings in Health Communities, we suggest that they choose a username that does not identify them.
(2) Secure Messaging: The purpose of the Secure Messaging is to message with other users in PERSONA DOCTORS about a patient’s health and well-being including the provision or coordination of particular health or social service. Users accessing the Secure Messaging can be the patient, but could include the patient’s caregivers, family members or the patient’s associated health and social service professionals. All the information used in the Secure Messaging is restricted and can only be seen and accessed by the patient’s authorized health and social service providers or those caregivers or family members invited to participate in a patient’s “Circle of Care”.
The Secure Messaging can also send patients or their caregivers surveys to collect information. These surveys are typically used to track symptoms, vital signs, wellbeing questions or patient satisfaction or quality of service information. The messaging and surveys can collect Personal Identifier Information “PII” and Personal Health information “PHI” or both.
The patient, or their caregiver, (if the patient has provided consent to allow the caregiver access), controls who has access to the patient’s Circle of Care. This access can be changed/removed by the Patient or Caregiver at any time by using PERSONA DOCTORS.
When using the Secure Messaging you understand that you are allowing your Circle of Care to view your PII and PHI as it is included in the messaging or surveys you are part of. If you are not comfortable sharing your PII or PHI with your “Circle of Care” do not use PERSONA DOCTORS Secure Messaging or restrict your messaging or responses to only information you wish to share.
We strongly believe that using PERSONA DOCTORS app to connect to others with similar health issues and integrating your health and social services can greatly improve a person’s health, and wellbeing but this may necessarily involve sharing sensitive information about your health and treatment. Therefore, we want to share the clear and transparent privacy guidelines we use to enable you to understand what we do and how we protect your information and how you can control what happens to information you share on PERSONA DOCTORS app.
WE DO NOT SHARE, SELL, OR OTHERWISE DISCLOSE YOUR PERSONAL DATA FOR PURPOSES OTHER THAN THOSE OUTLINED IN THIS PRIVACY POLICY. WE DISCLOSE YOUR PERSONAL DATA TO A FEW THIRD PARTIES, INCLUDING:
· OUR AFFILIATES AND THIRD PARTY SERVICE PROVIDERS THAT WE USE TO SUPPORT OUR BUSINESS;
· TO A COMPANY WE MERGE, ACQUIRE, OR THAT BUYS US, OR IN THE EVENT OF CHANGE IN STRUCTURE OF OUR COMPANY OF ANY FORM;
· TO COMPLY WITH OUR LEGAL OBLIGATIONS;
· TO AFFILIATES AND THIRD PARTIES FOR THEIR OWN COMMERCIAL PURPOSES;
· TO ENFORCE OUR RIGHTS; AND
· WITH YOUR CONSENT.
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We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose Personal Data that we collect or you provide as described in this privacy policy:
· When we have your permission to enable your health and social service providers also using PERSONA DOCTORS to better provide you with those health or social services.
· When we have your permission to enable your family circle and circle of care to be better informed and engaged on your health and wellbeing to better provide you support.
· When we have your permission, including when you choose to share information by posting to our Health Communities, messaging in chats or using the Secure Messaging to message with your Circle of Care.
· With trusted partners who work on behalf of or with PERSONA DOCTORS to provide us with certain services. We share encrypted information with our data storage provider, Amazon Web Services. They may use your personal information to perform services and to help PERSONA DOCTROS communicate with you. For any other provider, PERSONA DOCTORS will maintain contracts with any company restricting their access, use and disclosure of personal information in compliance with this Privacy Policy and any legal obligations.
· With affiliates, contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, and ordering, marketing, and payment processing services.
· With a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by PERSONA DOCTORS about our Website and App users are among the assets transferred.
· To fulfill the purpose for which you provide it.
· For any other purpose disclosed by us when you provide the information.
· With your consent.
We may also disclose your Personal Data:
· to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
· to affiliates and third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information;
· to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and
· if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of PERSONA DOCTORS, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
WE OFFER YOU CHOICES ON HOW YOU CAN OPT OUT OF OUR USE OF TRACKING TECHNOLOGY, DISCLOSURE OF YOUR PERSONAL DATA FOR OUR ADVERTISING TO YOU, AND OTHER TARGETED ADVERTISING.
We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.
In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:
· Opt-Out. Our App and Website permit you to "opt-out". You may contact us at (888) 577-1570, at any time to let us know that you no longer wish to participate in any PERSONA DOCTORS Anywhere service, or receive further emails or for transactions. If you opt-out, we may still send you transactional emails. Transactional emails include emails about your account and our business dealings with you, such as renewals and updates, and, as allowed by applicable law.
· Cookies. When you use our website, you can usually choose to set your browser to remove cookies and to reject cookies from our servers, if we collect information from you. If you choose to remove or reject cookies, this could affect certain features or services of our website. For information about how to remove or manage cookies please read our Cookie Policy.
· Access to and Correction of Your Information. You may have the right, depending on which country you reside in, to ask us to provide a copy of the personal information we hold about you (provided that we may ask you for a few forms of proof of your identity). You may also have the right to ask us to correct any inaccuracies in your personal information or to ask us to delete it. We will always consider and act upon these requests regardless of where you live.
· Tracking Technologies and Advertising. You can set your browser or operating to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website or App may then be inaccessible or not function properly
· Promotional Offers from PERSONA DOCTORS. If you do not wish to have your email address used by PERSONA DOCTORS to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or logging onto your Account Preferences page. This opt out does not apply to information provided to PERSONA DOCTORS as a result of a product purchase, or your use of our services.
· Disclosure of Your Information to Affiliates and Third Parties. By using our Website and App, you consent to our sharing of your Personal Data with our affiliates and third parties for their promotional purposes. If you wish to unsubscribe from such affiliate and third parties’ promotions, you can do so by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from them.
· Targeted Advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.
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YOU MAY REVIEW AND CHANGE YOUR PERSONAL INFORMATION BY LOGGING INTO THE APP OR WEBSITE AND VISITING YOUR ACCOUNT PREFERENCES PAGE.
You can review and change your Personal Data by logging into our Website or App and visiting either the Settings or Account Preferences sections of our App or Website. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
WE CURRENTLY DO NOT USE AUTOMATED DATA COLLECTION TECHNOLOGIES TO TRACK YOU ACROSS WEBSITES. WE CURRENTLY DO NOT HONOR DO-NOT-TRACK SIGNALS THAT MAY BE SENT BY SOME BROWSERS.
Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals, but we currently do not use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services (behavioral advertising).
INFORMATION TRANSMITTED OVER THE INTERNET IS NOT COMPLETELY SECURE, BUT WE DO OUR BEST TO PROTECT YOUR PERSONAL DATA. YOU CAN HELP PROTECT YOUR PERSONAL DATA AND OTHER INFORMATION BY KEEPING YOUR PASSWORD TO OUR WEBSITE CONFIDENTIAL.
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.
The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website or App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website or on or through our App. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, in your operating system, or in the App.
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the immediately prior calendar year (e.g. requests made in 2012 will receive information regarding such activities in 2019). You may request this information once per calendar year. To make such a request, please contact us using the Contact Information below.
WE WILL POST ANY CHANGES TO OUR PRIVACY POLICY ON OUR WEBSITE. IF WE MAKE MATERIAL CHANGES TO OUR PRIVACY POLICY, WE MAY NOTIFY YOU OF SUCH CHANGES THROUGH YOUR CONTACT INFORMATION AND INVITE YOU TO REVIEW (AND ACCEPT, IF NECESSARY) THE CHANGES.
We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page or the App’s home screen. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Website’s home page or the App’s home screen. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically accessing the App or visiting our Website and reviewing this Privacy Policy to check for any changes.
If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact Us” page on our Website or in the App.
How to Contact Us:
8120 Woodmont Ave, Suite 150
Bethesda, MD 20814
Telephone: 888-577-1570
Email: info@persona-doctors.com