Pager Privacy Policy

Jurisdictional Issues

We intend to provide our Services in the United States. Accordingly, this Policy, and our collection, use, and disclosure of your Personal Information (as defined below) is governed by U.S. law. We do not represent or warrant that the Application, or any functionality or feature thereof, is appropriate or available for use in any particular jurisdiction. If you choose to access or use the Application from outside the United States, you do so on your own initiative and at your own risk, and are responsible for complying with all local laws, rules and regulations. By using the Application and submitting any Personal Information from outside the United States, you acknowledge that the Application is subject to U.S. law and consent to the transfer of your Personal Information to the United States, which may provide a different level of data security than in your country of residence.

Personal Information

Personal Information We May Collect

In order for you to use the Services, we may require you to provide us with information that identifies you as an individual (“Personal Information”). We and our service providers may collect Personal Information from you that includes, but is not limited to: (1) your name and your contact data (such as your email address, phone number, billing and physical addresses, and your Application login and password); (2) demographic data (such as your gender, your date of birth and your zip code); (3) insurance information (such as your insurance carrier and insurance plan); (4) payment information (such as your credit or debit card number); (5) confirmation that your Provider provided services to you; and (6) health and medical data (such as the previous doctors, dentists or other health care providers you visited, your reason for visiting those providers, your date of visiting providers, your medical history and condition, and other medical and health information you choose to share with us) that you provide through the Application. If you communicate with us by, for example, email or letter, any information provided in such communication may be collected as Personal Information.

In addition to the information that we collect directly from you, we may also collect certain Personal Information about you from or on behalf of your Providers. We use and disclose this information only in accordance with your express authorization, which we request from you through a separate document when you sign up to use the Application. Please be aware that if you do not provide your authorization, or if you subsequently withdraw your authorization, you may not be able to use the Services through the Application, but may continue to receive services from a Provider outside of the Application.

We may also collect precise information about the location of your mobile device with your consent. Please see below under “How We Collect Non-Personal Information” for additional information about our collection of location information.

How We May Use Personal Information

We and our third-party service providers may use Personal Information to:

• respond to your inquiries and fulfill your requests, such as to arrange transportation for a house call or to establish a telephone conference;

• send to you administrative information, including information regarding the Application, and changes to our terms, conditions and policies;

• schedule and provide services related to the scheduling of house call appointments, for example, to send to you appointment confirmation; communicate with you and your Providers regarding your health status, appointments and related services provided by your Provider; obtain or facilitate payments for appointments and related services provided by your Provider and send you payment receipts; and provide you with related customer service;

• confirm that services you request were provided to you by your Providers;

• send to you marketing communications that we believe may be of interest to you;

• allow you to send messages to a friend through the Application (please note that, by using such functionality, you are agreeing that you have the right to provide to us your friend's name and email address for such purpose);

• personalize your experience on the Application by presenting products and offers tailored to you;

• further our business purposes, such as quality assessment, data analysis, audits, developing new products, enhancing the Application, improving our services, identifying usage trends, developing tools which help you assess the performance, competence and qualifications of healthcare professionals and conducting training programs for such professionals, and determining the effectiveness of our promotional campaigns; and

• act as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public or government authorities; (d) to enforce our Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; (g) at our discretion under emergency circumstances, to notify emergency services or your family members, personal representative or other individuals involved in your care of your location and condition; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.

Our use of your Personal Information may also be subject to certain restrictions set forth in an agreement between us and your Provider.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed to:

• our third-party service providers that provide services such as hosting of the Application, data analysis, IT services and infrastructure, customer service, email delivery, auditing and other similar services;

• Providers, including your Providers, to schedule and fulfill appointments and provide healthcare services and confirm those services were delivered to you;

• our affiliates, for the purposes described for Personal Information in this Privacy Policy, including marketing purposes relating to their products and services;

• third parties, to permit them to send marketing communications to you regarding our products or services or the services of your Providers;

• [identify you to anyone to whom you send messages through the Application;]

• for other treatment, payment or health care purposes of your Provider;

• a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding); and

• a third party as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public or government authorities; (d) to enforce the Terms of Use; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; (g) at our discretion under emergency circumstances, to notify emergency services or your family members, personal representative or other individuals involved in your care of your location and condition; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.

  
  

Our disclosure of your Personal Information may also be subject to certain restrictions set forth in an agreement between us and your Provider.

Non-personal Information

Non-Personal Information We May Collect

“Non-Personal Information” is any information that does not reveal your specific identity. The types of Non-Personal Information that we collect are described in more detail below under “How We Collect Non-Personal Information.”

How We Collect Non-Personal Information

We and our third-party service providers may collect Non-Personal Information in a variety of ways, including:

• Through your device: Certain information is collected automatically through your device, such as your operating system name and version, device manufacturer and model, device identifier, language, the name and version of the software application you are using. We use this information to ensure that the Application functions properly and to understand usage of the Application.

• Through server log files: Your “IP Address” is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user uses the Application, along with the time of the use and the pages visited within the Application. We use IP Addresses for purposes such as helping to calculate Application usage levels, diagnose server problems and administer the Application.

• Physical Location: If you give us your consent, we may collect information about the physical location of your device, for example, using your device’s GPS functionality. We may use such information to provide you with personalized location-based services and content (for example, information regarding local Providers). We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. You will be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.

• From you: We may collect Non-Personal Information such as your general geographic location, as well as other information, such as your preferred means of communication, when you voluntarily provide such information to us. Unless combined with Personal Information, this information does not personally identify you or any other user of the Application.

• By de-identifying information: Aggregated Personal Information is information that is derived from Personal Information that does not personally identify you or any other user of the Application. For example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code or a particular medical condition.

How We Use and Disclose Non-personal Information

Because Non-Personal Information does not personally identify you, we may use and disclose Non-Personal Information for any purpose. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your zip code with your name, or with your name together with a medical condition). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is so combined.

THIRD PARTIES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including Providers, the manufacturer of your mobile device, and any other third party mobile application or website to which the Application may contain a link. We encourage you to review the Notice of Privacy Practices of each Provider who provides you with services and the privacy policies of each website and application you visit and use.

HIPAA

Your Provider may be regulated as a “covered entity” under the Health Insurance Portability and Accountability Act (“HIPAA”). Please be aware that this Privacy Policy is distinct from your Provider’s HIPAA Notice of Privacy Practices, which describes in detail overall how your Provider uses and discloses your individually identifiable health information. If you would like to review a copy of your Provider’s HIPAA Notice of Privacy Practices, please request a copy directly from your Provider. Our use and disclosure of your Personal Information, which we receive pursuant to your express authorization, is not restricted under HIPAA. We will use and disclose your Personal Information consistent with the terms of your authorization and this Privacy Policy.

COMMUNITY FEATURES

The Application may feature community areas and other public forums where users can share information and post reviews or questions. Any information that you may reveal in a review posting or other online discussion or forum is intentionally open to the public and is not in any way private. You should think carefully before disclosing any Personal Information in any public forum. What you have written may be seen and/or collected by third parties and may be used by others in ways we are unable to control or predict.

SECURITY

We seek to use reasonable physical, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system is 100% secure, and therefore we cannot guarantee against all potential security breaches.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the "Contacting Us" section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. Specifically, you may opt-out from:

• Receiving marketing-related emails from us based upon your Personal Information: If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out of receiving such marketing related emails by sending an email to privacy@pager.com.

• Our sharing of your Personal Information with affiliates for their marketing purposes: If you would prefer that we do not share your Personal Information on a going-forward basis with our affiliates for their marketing purposes, you may opt-out of such sharing by sending an email to support@pager.com.

We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out as described above, we will not be able to remove your Personal Information from the databases of our affiliates with which we have already shared such information (i.e., to which we have already provided such information as of the date that we implement your opt-out request). Please also note that if you do opt-out of receiving marketing-related messages from us, we may still send administrative messages to you; you cannot opt-out from receiving administrative messages.

How you can access or update your Personal Information

If you would like to review or update your Personal Information that has been previously provided to us, you may do so by logging into your account within the Application. We will try to comply with your request to update your Personal Information as soon as reasonably practicable. We are not responsible for changing information from the databases of third parties with whom we have already shared your Personal Information. You may have additional rights to access, correct or modify the health information that is held by your Provider. Please consult your Provider’s Notice of Privacy Practices for a description of those rights and how to exercise them.

Use of Application by Minors

The Application is not directed to individuals under the age of 13, and we do not knowingly collect Personal Information from users under the age of 13. If we learn that we have received any information from an individual under the age of 13, we will use that information only to respond directly to that child (or a parent, legal guardian or personal representative) to inform him or her that he or she cannot use the Services and subsequently we will delete that information from our own servers. However, if you are a parent, legal guardian or personal representative of a minor child, you may, in compliance with the Terms of Use, use the Services on behalf of such minor child. Any information that you provide us while using the Services on behalf of your minor child will be treated as Personal Information as otherwise provided herein.

Your California Privacy Rights

California Civil Code Section 1798.83 permits users of the Application who are California residents to request certain information regarding our disclosure of personally identifiable information to third parties for their direct marketing purposes. To make such a request, please write to us at: privacy@pager.com

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how we do so in this Privacy Policy. Visit the following website, "http://www.allaboutdnt.org," for more information on this developing area.

Controlling Your Personal Information

As a registered user of the Services, you can modify some of the Personal Information you have included in your profile or change your username by logging in and accessing your account. Upon your request, we will use commercially reasonable efforts to delete your account and the Personal Information in your profile; however, it may be impossible to remove your account without some residual information being retained by us, and we may be required by law or our agreement with your Provider to retain certain information. We have no obligation to delete any data or information you provide on a Medical History Form following termination of your account or the account of any Provider to whom your Medical History Form was submitted through the Services. Registered users who wish to close their account should email: privacy@pager.com