- The Information We Collect and the Sources of Such Information
- Purposes for How We Use Your Information
- Online Analytics and Advertising
- How We Share and Disclose Your Information
- Your Marketing Choices
- Third Party Services and Notice About Health Information
- How We Protect Your Information
- Retention of Your Information
- Contacting Us
THE INFORMATION WE COLLECT AND THE SOURCES OF SUCH INFORMATIONWe obtain information about you through the means discussed below when you use the Services. Please note that we need certain types of information so that we can provide the Services to you. If you do not provide us with such information, or ask us to delete it, you may no longer be able to access or use part or all of our Services.
1. Information You Provide to UsWe collect a variety of information that you provide directly to us. For example, we collect information from you through:
- Account and product registration and administration of your account
- Processing your orders and requests for treatment
- Questions, communications, or feedback you submit to us via forms or email
- Your participation in research and surveys
- Requests for customer support and technical assistance, including through online chat functionalities
- Uploads or posts to the Services
- Employment applications you submit
- Name, address, telephone number, date of birth, and email address
- Information about your medical conditions, treatment options, physician referrals, lifestyle and personal preferences, prescriptions, and lab results or other related health information, such as your physical and emotional characteristics
- Log-in credentials, if you create an account
- Billing information, such as shipping address, credit or debit card number, verification number, expiration date, and identity verification information (e.g., driver’s license or other identifier), collected by our payment processors on our behalf
- Information about purchases or other transactions with us
- Information about your customer service and maintenance interactions with us
- Demographic information such as your gender, race/ethnicity, and age, and similar information in connection with the Services
- Information about others, such as if you share a family or friend’s email address or contact information to allow access to your information or name them as an emergency contact
- User-generated content you post in public online forums on our Services
- Any other information you choose to directly provide to us in connection with your use of the Services.
- A web server log is a file where website activity is stored.
- An SDK is a set of tools and/or code that we embed in our Apps and software to allow third parties to collect information about how users interact with the Services.
- A cookie is a small text file that is placed on your computer or mobile device when you visit a site, that enables us to: (i) recognize your computer/device; (ii) store your preferences and settings; (iii) understand the parts of the Services you have visited and used; (iv), enhance your user experience by delivering and measuring the effectiveness of content and advertising tailored to your interests; (v) perform searches and analytics; and (vi) assist with security and administrative functions.
- Tracking pixels (sometimes referred to as web beacons or clear GIFs) are tiny electronic tags with a unique identifier embedded in websites, online ads and/or email that are designed to: (1) collect usage information like ad impressions or clicks and email open rates; (2) measure popularity of the Services and associated advertising; and (3) access user cookies.
4. Information We Receive From Other SourcesWe work closely with third parties (including, for example, third party intermediaries, such as the physicians, medical professionals, and pharmacies with whom we partner to provide you with the Services and their health care services, sub-contractors in technical, advertising networks, analytics providers, and search information providers). Such third parties will sometimes provide us with additional information about you.
PURPOSES FOR HOW WE USE YOUR INFORMATIONIn connection with providing you with the Services, we may use your information for our business purposes to:
- Carry out, improve, and manage the Services and, as applicable, facilitate the provision of health care services to you by physicians or other health care providers and ensure that the physicians or health care providers have the services and support necessary for health care operations.
- Engage in internal research to understand the effectiveness of our Services, improve our Services, and better understand our user base. If we publish or provide the results of this research to others, such research will be presented in a de-identified and aggregate form such that individual users cannot be identified.
- Communicate with you about the Services, your use of the Services, or your inquiries related to the Services and send you communications on behalf of physicians or other health care providers utilizing the Services to meet your needs.
- Communicate with you by email, postal mail, or phone about surveys, promotions, special events or our products and Services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses and those of our third-party partners.
- Provide you with technical support and customer service, and troubleshoot any technical issues or errors.
- Verify your identity and administer your account, including processing your payments and fulfilling your orders.
- Ensure that content from our Services is presented in the most effective manner for you and for your computer or device, allow you to participate in interactive features of our Services (when you choose to do so), and as part of our efforts to keep our Services safe and secure.
- Provide you with more relevant advertisements and personalized content, and measure or understand the effectiveness of advertising and content we serve to you and others, and to deliver and customize relevant advertising and content to you.
- Help us better understand your interests and needs, such as by engaging in analysis and research regarding use of the Services.
- Comply in good faith with any procedures, laws, and regulations which apply to us where it is necessary for our legitimate interests or the legitimate interests of others.
- Establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others, such as protecting against malicious, fraudulent, or illegal activity.
ONLINE ANALYTICS AND ADVERTISING
1. Online AnalyticsWe may use third-party web analytics services (such as those of Google Analytics (including Google Signals, Google User-ID, and other Google Analytics features) and MixPanel) on our Services to collect and analyze usage information through cookies and similar tools; engage in auditing, research, or reporting; assist with fraud prevention; try to locate the same unique users across multiple browsers or devices to better tailor services and features; and provide certain features to you. If you have a Google account with personalized advertising enabled, through Google Signals, Google will also be able to gather for us analytics and engagement information from across the various devices you use to access the Services. To prevent Google from using your information for analytics (including cross-device tracking for personalization purposes), you may install the Google Analytics Opt-out Browser Add-on. And to opt out of Google Signals, please open your “Settings” app, locate and tap “Google,” select “Ads,” and turn ON “Opt out of Ads Personalization.” You may also be able to disable cross-device tracking through your Android or Apple device-based settings. If you receive email from us, we may use certain analytics tools, such as clear GIFs to capture data such as when you open our message or click on any links or banners our email contains. This data allows us to gauge the effectiveness of our communications and marketing campaigns.
3. Mobile AdvertisingWhen using mobile applications from us or others, you may also receive tailored in-application advertisements. We may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. Each operating system, iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. You may review the support materials and/or the device settings for the respective operating systems to opt-out of tailored in-app advertisements.
4. Notice Concerning Do Not TrackDo Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our website for third party purposes, and that is why we provide the variety of opt-out mechanisms listed above. However, we do not currently recognize or respond to browser-initiated DNT signals. To learn more about Do Not Track, you can do so here.
HOW WE SHARE AND DISCLOSE YOUR INFORMATIONWe may share your information for our business purposes in the following ways:
- Affiliates and Subsidiaries. We may share information we collect within any GAPhealthmember or group (i.e., our subsidiaries and affiliates, including our ultimate holding company and its subsidiaries) to deliver products and services to you, ensure a consistent level of service across our products and services, and enhance our products, services, and your customer experience.
- Health Care Providers and Services. We share your information with health care providers: (i) to schedule and fulfill appointments and provide health care services as part of the Services, (ii) to whom you send messages through our Services, and (iii) for other treatment, payment or health care operations purposes, including pharmacy services, upon your request.
- Service Providers. We provide access to or share your information with select third parties who use the information to perform services on our behalf. They provide a variety of services to us, including billing, sales, marketing, advertising, analytics, research, customer service, shipping and fulfillment, data storage, IT and security, fraud prevention, payment processing, and auditing and legal services. These entities may also include health care organizations, pharmacies, and other third parties we use to support our business or in connection with the administration and support of the Services.
- Advertising Networks. Please see the “Online Advertising” section above for details about how we share information with advertising partners.
- Business Transfers. As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions, (including in contemplation of such transactions) user information may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, customer information (including your email address) would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.
- Public Forums. Certain features of our Services make it possible for you to share comments publicly with other users. Any information that you submit through such features is not confidential, and we may use it for any purpose (including in testimonials or other marketing materials). For example, if you submit a product review on one of our sites, we may display your review (along with the name provided, if any) on other GAPhealth websites and on third-party websites. Any information you post openly in these ways will be available to the public at large and potentially accessible through third-party search engines. Accordingly, please take care when using these features.
- Consent. We may also disclose your information in other ways you direct us to and when we have your consent.
- Aggregate/De-Identified Information. We reserve the right to create Aggregate/De-Identified Data from the information we collect through the Services and our sharing of such Aggregate/De-Identified Data is in our discretion.