Effective as of: May 2nd, 2019
INFORMATION COLLECTION PRACTICES
Personal Information We Collect
When you register for the Application, subscribe to our Services, or transmit a request for an appointment with a licensed mental healthcare provider (each, a “Provider”), we collect personally identifiable information (“PII”), which may include personally identifiable health or medical information (“Personal Health Information” or “PHI”). PII is information about you that may be used to identify you (such as your name, phone number, or address). Personal Health Information is PII combined with information that relates to (a) your past, present, or future physical or mental health or condition, (b) the provision of health care to you, or (c) your past, present, or future payment for the provision of health care. We will not use any health-related information for any other purpose without your written authorization, or unless otherwise permitted or required by law. You may revoke, in writing, any such authorization at any time, by terminating your Neb account and use of Services, by emailing email@example.com, except to the extent we have taken action in reliance thereon.
Please keep in mind that certain features on the Application or Site may give you an opportunity to interact with us and others. These may include forums, message boards, chats, creating community profiles, and rating, tagging and commenting on articles. When you use these features you should be aware that any information you submit, including your name, location, health issues, and email address, may be publicly available to others. We do not protect the privacy of and are not responsible for your disclosure of any information through these interactive features, including, but not limited to information that you might post related to a minor.
HIPAA and PHI
Additional Information We Collect
Tracking and/or Analytics Services. We may use tracking and/or analytics services. These services may record unique mobile gestures such as tap, double-tap, zoom, pinch, scroll, swipe and tilt but do not collect PII that you do not voluntarily enter in the Application or Site. These analytics services generally do not track your browsing habits across web services external to Neb that do not use the same services. We use the information collected by these services to understand user behavior and optimize application or site performance.
Web Beacons. We may also use web beacons (invisible images often referred to as pixel tags or clear GIFs) to recognize users and assess traffic patterns, and we may include web beacons and cookies in our email messages to count how many email messages have been opened.
Mobile Device Information. Your use of the Application may also include collection of information from your mobile device. For example, the Application may request access to multimedia (photos or videos) stored on your mobile device. Multimedia will only be collected from your device if you affirmatively select it to upload to the application (i.e., you choose an image or video to store within the Application). Multimedia will not be shared with other Application users (with the exception of your profile photo, to the extent such feature is offered, which will appear in your user profile).
Third-Party Links. Our Application or website may contain links to sites that are not operated by Neb. You may be asked by those sites to provide PII or to release information you may have provided on our Application or Site. You are not required to provide or release any PII. We may also allow certain “widgets” (i.e., social share buttons) on our Site to allow users to easily share information to social media or other platforms. The third parties that own these widgets may have access to information about your browsing history on websites where the widgets are placed. We encourage you to review the privacy policies of any third-party websites you choose to navigate to via hyperlink from our Application or Site, or social media platforms so that you can understand how those websites/platforms collect, use, and share your information. Neb does not control, and is therefore not responsible, for the privacy policies or other content on third-party websites or social media platforms.
USE AND SHARING OF INFORMATION
What We Do With Collected Information
PII. We will not share your PII with any third parties without your consent, except as necessary to provide you with the services offered by us or to comply with the law. We may use your PII to verify your identity, to check your qualifications, or to follow up with transactions initiated on the Application and Site. We may also use your contact information to inform you of any changes to the Application and Site, or to send you additional information about Neb.
Anonymous Information. We use anonymous information, meaning non-personally identifiable information that alone or in combination withsimilar information can not be used to identify you, to analyze our Application and Site traffic, but we do not examine this information for PII. In addition, we may use anonymous IP addresses to help diagnose problems with our server, to administer our Application and/or Site, or to display the content according to your preferences.
Disclosure of PII. We may disclose PII that you provide via the Application and Site to the following third parties:
Providers upon a request by you to book an appointment with a Provider. That Provider’s treatment of your information is subject to such Provider’s own policies and procedures.
Our subsidiaries, affiliates, and joint venture partners.
Contractors, vendors, and service providers we use to support our business and the Application and Site.
Disclosure for Legal Purposes. We may also disclose PII that you provide via the Application and Site in the event of a merger, acquisition, or any form of sale of some or all of our assets, in which case PII we collect via the Application and Site will be among the assets transferred to the buyer. Further, we may disclose your PII to third parties to:
Comply with any court order or other legal obligation;
Protect the rights, property, or safety of our business, our patients, clients, customers, employees, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, information security, and other related matters.
The Application and Site have security measures in place to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration.
NOTICE CONCERNING CHILDREN
We support and comply with the Children’s Online Privacy Protection Act (COPPA) and we do not knowingly collect information from children under the age of 18, nor do we share such information with third parties. Children under the age of 18 may not use the Application. If you seek health care services for a minor, you will be responsible for providing information related to the minor and for paying for the requested treatment for the minor.
FOR RESIDENTS OF CALIFORNIA
Under California Civil Code Section 1789.3, California residents are entitled to the following specific consumer rights notice: If you have a question or complaint regarding the Application or Website, please contact us at: Neb Health Inc, (408) 320-5289, 453 West San Carlos Street Suite #104, San Jose CA 95110 or firstname.lastname@example.org. California residents may reach the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs may be contacted in writing at 400 R Street, Suite 1080, Sacramento, California 95814, or by telephone at (916) 445-1254 or (800) 952-5210.