CircleCare Privacy Policy

Last modified: August 2, 2016

CircleCare Inc. (“CircleCare” or “we”) provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use, and disclosure of personal information we receive from users of our our mobile applications (collectively, “CircleCare App” or “CircleCare Services”). This Privacy Policy applies to your access to and use of the CircleCare App, and by choosing to use them, you consent to the collection, transfer, processing, storage, disclosure and other uses of your information described in this Privacy Policy.

As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.

As used below, the term “Personal Information” is used to indicate any piece of information or data that can be used to identify any individual. Personal Information may relate to you as a Member, or it may relate to the individual that is the subject of any Profile that you create, if you create a Profile for a child, parent or other loved one.

Any other defined term that is not defined in this Privacy Policy has the meaning given that term in the CircleCare Terms of Service or any Additional Terms of Service, as applicable.

MODIFICATIONS

CircleCare reserves the right, at its sole discretion, to modify this Privacy Policy at any time, and without prior notice. If we modify this Privacy Policy, we will post the modified Privacy Policy and alert you to the modified Privacy Policy on the Site and the CircleCare App or will otherwise provide you with notice of the modification. We will also update the “Effective Date” at the top of this Privacy Policy. By continuing to use the CircleCare App after we have posted a modified Privacy Policy or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the CircleCare App. Information we collect under the old Privacy Policy will remain subject to the old Privacy Policy unless and until you consent to the application of any modified Privacy Policy to such information.

THE INFORMATION WE COLLECT

Personal Information

The CircleCare App requires a user to provide basic information during the registration process. When you register with us to create an account and become a member/user, we will ask you for certain Personal Information. If you elect to add any other Personal Information to your Account we will collect that information and use it and share it as set forth below.

As a Member, you may also set up one or more profiles within the CircleCare Services. The profile may be personal to you and your healthcare or the subject of the profile may be a child, parent or other loved one. When you set up a profile, you will be asked to provide personal Information about the individual that is the subject of the profile, whether yourself or your child, parent or other loved one. When you set up a profile in CircleCare Services we will collect and store any information that you may elect to provide to us as part of the profile content, which may include but is not limited to medication information, gender, date of birth, personal contacts, photographs and files, notes on your symptoms and other journal information, medical treatment instructions, medical appointments, insurance information, your doctor’s address information, advance directives, and prescription refill information. In the event you set up a profile that relates to someone other than yourself, you are solely responsible for ensuring that you have any and all consents and permissions to share that personal information with us and to use that information as part of the CircleCare Services.

Non-Personal Information

We also collect the following information any time you use CircleCare App. This information may not necessarily identify you, but if we have your personal information, or you otherwise set up an account with us, we may link any of the below non-personal information with your personal Information in our records.

App Usage Data: When you use the CircleCare App, our servers automatically record information that your mobile device sends whenever you use an Internet service. (“App Usage Data”). This App Usage Data may include information such as your device’s IP address, device model and version, device identifier, operating system, time zone, name of your mobile operator or ISP, application performance measurements, and error conditions. It may also include a record of when specific features of the CircleCare App are used. We use this information to monitor and analyze use of the CircleCare App for its technical administration, to increase functionality and user-friendliness, and to better tailor them to our visitors’ needs. For example, we use this information to measure the popularity of different features and to more effectively resolve customer issues. We may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.

Location Information: The App, with your consent, may access your location. Your location is used for your family members to gain information about your whereabouts. However, you can limit accessing your location through the setting on the App, or through your device’s location services settings. CircleCare uses FourSquare’s Venue Service API for location searches and Google Maps/Google Earth API(s) for location display. Pursuant to the Google Maps/Google Earth APIs Terms of Service, use of this location feature is also subject to the Google privacy policy, which can be found at http://www.google.com/privacy.html, and is incorporated with this reference. Furthermore, pursuant to the FourSquare APIs Terms of Service, use of this location feature is also subject to the FourSquare privacy policy, which can be found at https://foursquare.com/legal/api/platformpolicy, and is incorporated with this reference.

HOW WE USE YOUR INFORMATION

We do not sell your personal information.

We will use any personal information in your account to provide the CircleCare Services, complete your transactions, administer your inquiries, and present you with offers for products and services that we think may be of use or interest to you. We may contact you in various ways including but not limited to, via email, Inbox in the app, telephone, cell phone, and SMS/text messages. We may aggregate and combine all personally de-identifiable usage data and usage pattern that we receive through your Member Accounts. We use this anonymous information in an attempt to provide you with a better experience, to improve the quality and value of our services and to analyze and understand how our CircleCare App is used.

INFORMATION SHARING AND DISCLOSURE

You expressly release CircleCare from any responsibility and liability resulting from any other user access to any personal information or content that you may permit. Any information you choose to provide and make available to people in your circle via the CircleCare App should reflect how much you want others to know about you.

Aggregate Information and Non-Identifying Information:

We may share aggregated information that does not include Personal Information and we may otherwise disclose non-Personal Information with third parties for industry analysis, demographic profiling and other purposes.

Service Providers:

We will disclose personal information to the third party service providers that we engage to assist us in making and managing the CircleCare App. These service providers consist of our datacenter provider, storage provider, customer support system provider, email service providers, and software development contractors. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Compliance with Laws and Law Enforcement:

While CircleCare maintains information regarding your health on your behalf, CircleCare is not a covered entity under the Health Insurance Portability and Accountability Act (HIPAA). However, we take the protection of your private health information very seriously. In the event that we receive any subpoena or similar request from a court, government or law enforcement official, we will only disclose any personal information about you or other information in our custody or control as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of CircleCare or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity. Given the sensitivity of the personal information within your profiles, it is our policy to carefully review any such request for information in our systems and we will decline to comply with any such request in our discretion.

Assignment:

CircleCare may sell, transfer or otherwise share some or all of its assets, including your personal information and related account, profiles and profile content, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

CHANGING OR DELETING YOUR INFORMATION

All users may review, update, correct or delete their account information and any associated personal information or profile content via the CircleCare App. If you would like to close your account or delete any profile from your account, please contact us at support@MyCircleCare.com. We will use commercially reasonable efforts to honor your request. We will retain an archived copy of your records as set forth below.

DATA RETENTION

We will retain the information you provide to the CircleCare App for as long as your Account is active or as needed to provide you with the CircleCare Services. We will also retain and use the information you provide via CircleCare App, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you delete your account, any personal information associated with the same is moved out of our active databases, but will still be retained in our systems pursuant to our data backup and retention policies.

SECURITY – HOW WE PROTECT YOUR DATA

All communications between you and the App, are encrypted. Every user is assigned with an unique public-private encryption key pair and these keys are kept in a totally separate server farm.

IDENTITY THEFT

Identity theft is of great concern to CircleCare. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about identity theft, visit the Federal Trade Commission’s website at www.ftc.gov.

SECURITY BREACH

The CircleCare App relies on the internet and mobile networks, which are not always secure. We use commercially reasonable efforts to maintain the confidentiality, availability and integrity of any information we collect, but we cannot assure that the use of the CircleCare App is secure or that your personal information or any other data that we may have will be secure. In the event we become aware of a security incident, we will notify you to the extent required under applicable law.

REPORTING A PROBLEM

If you feel your account may have been compromised, or you discover abuse or misuse of CircleCare App, please report it immediately to abuse@MyCircleCare.com; our technical team will investigate this issues.

If you’re a security researcher who’s discovered an issue, please see our security response page for our reporting procedure.

DATA LOCATION AND GLOBAL DISTRIBUTION

CircleCare is marketed globally and users from any country can download and use our mobile app. Therefore, your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, CircleCare transfers personal information to the United States and processes it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

LINKS TO THIRD PARTY MOBILE APP AND WEBSITES

The CircleCare App may display links to third party websites, mobile app or web contents. If you choose to click on a third party link, you will be directed to that third party’s website or mobile app. The fact that we link to a website or mobile app is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites or mobile apps. These other websites or mobile apps may place their own cookies or other files on your mobile device, collect data or solicit personal information from you. Other websites or mobile apps follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites or mobile app you visit or use.

AGE REQUIREMENT POLICY

The CircleCare App is not directed to persons under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with personal information without their consent, he or she should contact us at minor-guard@MyCircleCare.com. If we become aware that a child under 13 has provided us with personal information, we will delete such information from our files. If you have created a profile for a minor under the age of 18, you represent and warrant to us at CircleCare that you are the parent or legal guardian for that minor with a right to provide us the personal information of that minor.

CONTACTING CircleCare