CareNav PRIVACY POLICY

Revised: April 20, 2016

CareNav (“we, “us” or “Company”) operates the <carenav.co> website and related services. This policy applies to our website (“Site”) as well as to the services and applications we provide, collectively known as the “Services.”

Company is committed to ensuring that your personal information shared over our Site and/or Services is protected and kept confidential. By accepting Company’s Terms of Service, you consent to the use and disclosure of personally identifiable information as outlined therein and in this Privacy Policy.

INFORMATION COLLECTION

Personal information or protected health information is health information that includes, but is not limited to, identifying data such as name, date of birth, age, social security number, address, contact information, as well as information about personal health issues submitted through the Services. This is the information we aim to protect.  Information about personal health issues includes but is not limited to:

·        Diagnostic/procedural data

·        Test results

·        Correspondence between a patient and their health care providers

·        Reports concerning examination, treatment, observation

Upon your becoming a user of our Services, we will only collect information that you voluntarily authorize for submission. We know that privacy is of the utmost importance. Company vigorously believes in keeping confidential any and all personally identifiable information that identifies an individual whether it relates to personal identifying information or relates to an individual’s past, present, or future physical or mental health condition. We store your data in the United States. Privacy, security and use of your data is governed by the Terms of Service and this Privacy Policy.

We maintain health information in compliance with applicable health care privacy and security rules and our contractual obligations with our users. Currently we act as a repository and conduit between (a) individuals who elect to share their records with us (who may also now or in the future store these heath records using the Services) and (b) care navigators, who are independent contractors of ours who review such records and consult with individuals on their interactions with their health care providers.

By agreeing to the Terms of Use you are authorizing the storing and accessing of your data as described herein and therein. You authorize Company to access all such data, including data that may relate to HIV and/or other sexually-transmitted diseases, mental and behavioral health conditions and treatment, substance abuse conditions and treatment, and other sensitive data, throughout the term of your use of the Services, to store such data as described above, and to store and use it as described above even once you are no longer using the Service. You may stop sending us new data at any time.

If you visit the Site, whether or not you become a user of our Services, be advised that Company will maintain web logs to record data about all visitors and customers who use this site and interact with the Services and we will store this information. These logs may contain IP address information, types of operating system you use, the date and time you visited the site, and, if you are a user of our Services, information about the data you have shared with us.

All web logs are stored securely and are accessible to a very limited number of employees who have to adhere to strict guidelines regarding user data security and privacy.

"Cookies" and internet tags

We may collect and process information about your visit to this website, such as the pages you visit, the website you came from and some of the searches you perform. Such information is used by us to help improve the contents of the site and to compile aggregate statistics about individuals using our site for internal, market research purposes. In doing this, we may install "cookies" that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access. A cookie is a small piece of information which is sent to your browser and stored on your computer’s hard drive. Cookies do not damage your computer. You can set your browser to notify you when you receive a cookie. This will enable you to decide if you want to accept it or not. If you do not accept cookies you may not be able to use all functionality of your browser software or this Site. We may obtain the services of outside parties to assist us in collecting and processing information collected through cookies.

We may also use internet tags (also known as action tags, web beacons, single-pixel GIFs, clear GIFs, invisible GIFs and 1-by-1 GIFs) and cookies at this site and may deploy these tags/cookies through a third-party advertising partner or a web analytical service partner which may be located and store the respective information (including your IP address) in a foreign country. These tags/cookies may be placed both on online advertisements that bring users to the Site and on different pages of the Site. We use this technology to measure the visitors' responses to the Site and the effectiveness of our advertising campaigns (including how many times a page is opened and which information is consulted) as well as to evaluate your use of this website. The third-party partner or the web analytical service partner may be able to collect data about visitors to our and other sites because of these internet tags/cookies, may compose reports regarding the Site’s activity for us and may provide further services which are related to the use of the Site and the internet. They may provide such information to other parties if there is a legal requirement that they do so, or if they hire the other parties to process information on their behalf. If you would like more information about web tags and cookies associated with on-line advertising or to opt-out of third-party collection of this information, please visit the Network Advertising Initiative website http://www.networkadvertising.org. (We are not affiliated with the Networking Advertising Initiative in any way.)

NON-PERSONAL DATA

We may also use non-personal information to analyze data into useful information. This process of data mining is done in the aggregate, is non-personal, and allows Company to find correlations and patterns in the data.

SECURITY OF INFORMATION COLLECTED

Company uses account information in a password-protected environment as a security measure to protect your data. Company uses administrative, physical and technical safeguards to protect data. We maintain a high level of data protection via safeguards such as data backup, audit controls, access controls, and some data encryption. Our Site and the Services use industry standard TLS encryption to enhance security of electronic data transmissions. In addition, we urge you to take precautionary measures in maintaining the integrity of your data. Please be responsible in making sure no one can see or has access to your personal accounts and log-in username and password information. If you use a public computer, such as at a library or a university, or a shared device, always remember to log out of the Site or Services.

If you use our Site or Services through your employer’s computer network or through an internet café, library or other potentially non-secure internet connection, such use is at your own risk. It is your responsibility to check beforehand with the company’s privacy and security policy with respect to Internet use.

Company is not responsible for your handling, sharing, re-sharing and/or distribution of your personal health information. Moreover, if you forward personal health information electronically to another person on or off the Site or Services, we are not responsible for any harm or other consequences from third party use or re-sharing of your information.

SELF REVIEW OF DATA AND ABILITY TO DELETE YOUR ACCOUNT INFORMATION

If you are a user of the Services you may review your personal information by logging in to your account. You may also request to delete any personal information and to de-authorize the collection or sharing of personal information from or to other parties in the future by sending us an email at <admin@carenav.co> Any such deletion or deauthorization will have no effect on sharing of personal information before we receive and are able to act upon such a request, and any work product of the navigators will be retained.

THIRD PARTY SITES/TRUSTED RELATIONSHIPS

Company’s Site contains links to other sites including but not limited to GradTrain, WebRTC, Stripe, and PayPal. We use their services in order to facilitate providing the Services to you. We do not share your personally identifiable information with those sites except as authorized under the Terms of Service and are not responsible for their privacy procedures. Company seeks to work with trusted partners and organizations that will adhere to appropriate privacy and ethical standards. We encourage you to review their particular privacy policies.

We disclose personally identifiable information about you as required or permitted by law, including complying with legal process (for example, we may disclose your information as necessary to comply with an authorized civil, criminal or regulatory investigation). We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities and may, in our sole discretion, disclose personal information or other information to satisfy any law, regulation, subpoena, or government request. We reserve the right to release personal information or other information about users who we believe are engaged in illegal activities or are otherwise in violation of our Terms of Service, even without a subpoena, warrant or court order, if we believe, in our sole discretion, that such disclosure is necessary or appropriate to operate our web site or to protect our rights or property, or that of our affiliates, or our officers, directors, employees, agents, third-party content providers, suppliers, sponsors, or licensors. We also reserve the right to report to law enforcement agencies any activities we reasonably believe in our sole discretion to be unlawful. If we are legally compelled to disclose information about you to a third party, we will attempt to notify you by sending an email to the email address in our records unless doing so would violate the law or unless you have not provided your email address to us.

CHILDREN

We do not knowingly allow individual Customers under the age 18 to create accounts that allow access to our secure site.

CHANGES TO THIS PRIVACY POLICY

Company may amend our Privacy Policy in the future. In the event changes are made, we will be sure to post changes at the Site and at other places we deem appropriate.

QUESTIONS OR SUGGESTIONS

If you have any questions or suggestions on ways we can improve our privacy policy with respect to personal information, please email us at <info@carenav.co>.