Last Updated: February 17, 2016
Welcome. The information below explains how Zitter Health Insights, Inc. (the “Company”) collects, uses, and discloses information collected by us, including via our website, located at www.yourcaremoments.com (the “Website”), as well as our use and disclosure of information provided to us by third-parties. Please take a moment to read the following privacy notice (this “Privacy Notice”) to learn how we handle your personal information.
The Company (“we” or “us” or “our”) understands that individuals with whom we conduct business and who share their information with us value their privacy. We are committed to taking reasonable steps to both protect your privacy online and manage your information responsibly. This Privacy Notice is intended to notify you of our online privacy practices, the type of information that may be collected and stored, how the information is used, with whom the information may be shared, what choices are available to you regarding the collection, use and distribution of the information, what kind of security procedures are in place to protect the loss, misuse or alteration of information under our control, and who to contact with questions or concerns.
This Privacy Notice does not apply to other websites that we may utilize to collect survey responses or receive information from, or to which we may otherwise link, or to other companies, or third-party vendor who provide services to us, or persons who might be listed as third-party contacts on the Website, each of which may be governed by their own privacy policies. By using the Website and/or by contacting us or providing any personal information, you consent to the collection, transfer, storage, disclosure and use of information by us in accordance with this Privacy Notice. If we decide to change our Privacy Notice, we will post those changes on this page.
Why We Collect Information:
We collect personal information because it helps us deliver our products and services, design and deliver our Website, and to deliver targeted surveys and rewards to you.
How We Collect Information:
We collect information in three primary ways:
1. You Give Us Information: We collect information from you when you submit it to us through our Website or through an alternative collection mechanism (e.g., phone survey or other third-party website or mechanism).
2. We Collect Information Automatically: We automatically collect certain types of information when you visit our Website. For example, we automatically collect various types of technical information when you use our Website as otherwise described in this Privacy Notice.
3. We Collect Information from Other Sources: We may obtain information about you from outside sources. For example, we may obtain commercially available information about you from third parties or purchase e-mail lists from third parties for advertising and marketing purposes. We may also receive information from third-parties who provide services for us through web-beacons and other technologies as otherwise discussed in this Privacy Notice.
What Information We Collect:
We may collect, store and use the following kinds of personal and or sensitive data:
- Information you otherwise provide to us directly or via third-parties, including but not limited to your email address, medical condition and information regarding your experiences in connection with pharmacies, physicians and other medical providers and covered entities;
- Information about your visits to and use of this the Website, and other information that you otherwise provide to us such as for the purpose of registering with us, and/or subscribing to our Website services and/or email notifications, and/or downloading resources, or through other methods of contacting us.
Even if you do not submit personal information through the Website, we gather navigational information about where visitors go on the Website and information about the technical efficiencies of our Website and services (i.e., time to connect to the Website, time to download pages, etc.). This information allows us to see which areas of our Website are most visited and helps us better understand the user experience. This information also helps us improve the quality of the Website by recognizing and delivering more of the features, areas, and services our visitors prefer. In this process of gathering information, we may collect personally identifiable and non-personally identifiable information (for example, domain type, browser type and version, service provider and IP address, referring/exit pages, operating system, date/time stamp, and click-stream data). We may also create and use electronic records to compile statistics about how our visitors collectively interact with our Website.
A web "server log" is a record of activity created by a computer that delivers certain webpages to your browser. Certain activities that you perform on our Website may record information in server logs. For example, if you enter a search term into a search box located on the Website, the server log may record the search term, the link you clicked on to bring you to our Website and/or information about your browser, such as your IP address and the cookies set on your browser.
Search Queries on Our Website:
We may provide you with options to search for information on our site. If you enter information in a search query box, we may store that information and we may aggregate that information with other information we may have about the browser and/or IP address from which the search query originated.
From time to time, we may request information from users via surveys. Participation in these surveys or contests is completely voluntary and the user therefore has a choice whether or not to disclose any information. Information requested may include contact information, which will be used to provide you with financial remuneration for participation (such as email address and phone number), demographic information (such as postal code, age level, gender) and other personal information pertaining to the provision of health care to you. The aggregate, non-personally identifiable information collected from all survey respondents may be shared with third-parties who sponsor such surveys. If your information gathered via a survey will be used in a manner different from that described in this Privacy Notice, such use will be detailed in the survey instructions.
Applicability of HIPAA to the PHI Collected by the Company
The Company uses information that it receives for research and analysis, which may be shared with the Company’s partners and customers pursuant to appropriate agreements and applicable law. In addition, the Company may receive PHI from Covered Entities to create aggregate or de-identified information. Please note that HIPAA will not apply to any Individually Identifiable Health Information that you submit to us, unless such information is PHI is submitted to us by a Covered Entity, or we administer a survey on a Covered Entity’s behalf. However, the Company is committed to ensuring the privacy and security of all Individually Identifiable Health Information created, received, maintained, or transmitted by the Company, irrespective of whether HIPAA applies to such information. Accordingly, Company uses appropriate administrative, physical and technical safeguards to protect the confidentiality, integrity, and availability of all Individually Identifiable Health Information under our care and control.
As used in this Privacy Notice, the following terms are defined as follows:
“Business Associate” means a person or entity who performs functions or activities on behalf of, or certain services for, a Covered Entity that involve the use or disclosure of Protected Health Information, and as further defined at 45 C.F.R. § 160.103.
“Covered Entity” means either (1) a health plan, (2) a health care clearinghouse, or (3) health care providers who electronically transmit any health information in connection with transactions for which the Department of Health and Human Services has adopted standards, and as further defined at 45 C.F.R. § 160.103.
“HIPAA” means the Health Insurance Portability and Accountability Act of 1996, as amended, as well as its implementing regulations.
“Individually Identifiable Health Information” is any information about the health status, provision of health care, or payment for health care that can be linked to a specific identifiable individual.
“Protected Health Information” or “PHI” means Individually Identifiable Health Information which is received, transmitted or maintained by a Covered Entity.
Circumstances where HIPAA Applies
If we receive PHI from a Covered Entity, HIPAA will apply to such PHI. If you respond to a survey that the Company administers on behalf of a Covered Entity, any PHI collected will be governed by HIPAA generally, and specifically by the terms of the applicable business associate agreement. Any survey sent on behalf of a Covered Entity shall prominently identify the Covered Entity on whose behalf it is being administered. If your PHI is governed by HIPAA, you have certain rights in and to the information you provide, including the right to request amendments to your PHI, review an accounting of the disclosures of your PHI, and to have that PHI made available to you. Please see the applicable Covered Entity’s notice of privacy practices for more information regarding the privacy and security of your PHI.
Circumstances where HIPAA Does Not Apply
If you submit Individually Identifiable Health Information to us independently of a Covered Entity, HIPAA will not apply to such Individually Identifiable Health Information. This is because, when the Company is not administering surveys on behalf of a Covered Entity, it is neither a Covered Entity nor a Business Associate under HIPAA, and accordingly is not required to comply with HIPAA’s rules and regulations. However, whether or not HIPAA applies to your Individually Identifiable Health Information, the Company remains committed to ensuring the privacy and security of your Individually Identifiable Health Information and will only use your Individually Identifiable Health Information in de-identified and aggregate form.
How We Use the Information We Collect:
First and foremost, we do not sell data we collect in any individualized form - period.
We use the information we collect in a variety of ways. Generally, using all of the above mentioned, and similar type tools, we may collect, aggregate, and use information from or about you such as data about the type of browser and operating system used, your geographical location, which webpages you view, the time and duration of your visits to our site, the search queries you may use on this site and any other submissions you may make, whether you clicked on any items or links on the site, whether you have clicked on any links in any emails sent from us, or third-parties on our behalf, whether you have chosen to opt-out of certain services or information sharing, and whether you have viewed or ordered certain products or services.
We use the information we collect internally in our business for many business purposes, such as to: (i) provide the Website and conduct surveys; (ii) analyze trends and conduct research, including providing aggregate data and trends to our customers; (iii) provide support and respond to questions from users and Website visitors; (iv) improve our Website, products or services; (v) learn about users' needs; (vi) contact users for research, informational, and marketing purposes, including customizing our Website for you based upon your information and browsing habits; (vii) track traffic patterns and site usage; (viii) provide customer service and technical support; (ix) correlate information with other commercially available information to identify demographics and preferences to assist us in our research and marketing efforts; (x) provide specific relevant marketing, promotional, or other information to you; (xi) address information security and/or privacy practices, network functioning, engineering, and troubleshooting issues; (xii) investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (xiii) comply with law, or based on our good faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud to reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the Website, our partners or customers, or the public; and (xiv) process or engage in a sale of all or part of our business, or if we go through a reorganization or merger.
We may also share personally identifiable information and non-personally identifiable information externally with our affiliates and business partners, as well as with other third-party service providers who help us provide operational services for the site and our business, which might include, but is not necessarily limited to: business entities that provide e-mail address management and communication contact services, retargeting services, network equipment and application management providers and hosting entities, credit and debit card payment gateways and processors and the issuing and acquiring banks involved in the funds settlement procedures necessary to charge your cards or financial accounts, entities which obtain information such as demographic information which might be aggregated with information we have about you, entities that allow us to personally identify visitors to the website, judicial, administrative and/or legal or financial accounting providers in the event that information must be reviewed or released in response to civil and/or criminal investigations, claims, lawsuits, or if we are subject to judicial or administrative process (such as a subpoena) to release your information or to prosecute or defend legal actions, and other service providers which may be involved in the other types of services and activities otherwise discussed in this Privacy Notice.
We may also use your personally identifiable information to contact you in ways other than e-mail or regular mail, such as via telephone contact or facsimile. All use of personally identifiable information will be as permitted by applicable law.
If Company or substantially all of its assets were acquired, or in the unlikely event that Company goes out of business or enters bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of Company may continue to use your personal information as set forth in this Privacy Notice.
Your Choices about the Information We Collect
The Company retains your information for as long as you have an open and active account profile with us or as needed for the purposes outlined in this Privacy Notice. If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us. If you do not wish to receive emails about special offers and other promotions from us, click the unsubscribe link located in our emails or opt out in your account profile. If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Notice, please provide us with your exact name and address and advise us that you wish to opt-out for information sharing or receiving information from us or both as the case may be. Please note that while we will never share Personally Identifiable Health Information with our partners, de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request to the following contacts:
290 W. Mt. Pleasant Avenue, Suite 2210
Livingston, NJ 07039
Privacy of Children Who Visit the Website
We recognize the importance of children's safety and privacy. The Website is not designed to attract children, and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18.
Your California Privacy Rights
We collect various types of personal information about you during the course of your relationship with us. Under California law, if you are a resident of California, you may make a written request to us about how we have shared your information with third parties for their direct marketing purposes. In response to your written request, we are allowed to provide you with a notice describing the cost-free means to opt-out of our sharing your information with third parties with whom we do not share the same brand name, if the third party will use such information for its direct marketing purposes.
If you would like to exercise your rights under California law, please send your written request to the e-mail address or postal address below. Please include your postal address in your request. Within thirty (30) days of receiving your written request, we will provide you with a Third Party Direct Marketing Opt-Out Form so you may request that your personal information not be disclosed to third parties for their direct marketing purposes.
290 W. Mt. Pleasant Avenue, Suite 2210
Livingston, NJ 07039
Visitors to the Website Outside of the United States
If you are visiting the Website from a location outside of the United States, your connection will be through and to servers located in the United States. All information you receive from the Website will be created on servers located in the United States, and all information you provide will be maintained on web servers and systems located within the United States. The data protection laws in the United States and other countries might not be as those in your country. By using this Website and/or submitting information to us, you specifically consent to the transfer of your information to the United States to the facilities and servers we use, and to those with whom we may share your information.
Updating Personal Information
We prefer to keep your personal information accurate and up-to-date. If you would like to change your contact information, please update your profile or send an email to firstname.lastname@example.org.
For your convenience, the Website may contain links to other websites. We are not responsible for the privacy practices, advertising, products, or the content of such other websites. None of the links should be deemed to imply that we endorse or have any affiliation with the links.
We believe in providing a safe and secure experience for all of our online visitors. To that end, we have implemented security measures to protect the information collected from you. We maintain reasonable physical and electronic safeguards designed to limit unauthorized access to your personally identifiable information, and to protect you against the criminal misuse of that information.
While we use the foregoing security measures to protect your information, please note that no data transmitted over the Internet or stored and utilized for business purposes can be guaranteed to be completely secure. No security measures are perfect or impenetrable. We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share on the Website will not become publicly available. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.
Questions / Changes in Notice
If you have questions or concerns with respect to our Privacy Notice, you may contact us at email@example.com. We may elect to change or amend our Privacy Notice; in such event, we will post the notice changes in our Privacy Notice on the Website.