Privacy Policy
INTRODUCTION
Cooey Health, Inc. on its own behalf and on behalf of its affiliates and/or wholly owned subsidiaries including but not limited to Cooey Technologies, Inc. (collectively referred to as “Cooey Health”, “Cooey”, “we”, “us”, or “our”), Cooey Health makes certain telehealth related information available to you and/or facilitates your access to telehealth (or telemedicine) and expert medical services, and access to various types of health care information and information about our services (“Cooey Health Services”). Cooey Health owns and operates (i) various publicly-available websites, including without limitation, www.cooeyhealth.com, www.mycooey.com, www.cooey.co.in(collectively, “Websites”) and (ii) various web-based and mobile applications that require you to create an account in order to use a Cooey Health Service (collectively, “Platforms”). Through these Websites and Platforms we offer various online services that enable users or visitors to the Websites and Platforms (“you” or “Visitors”) to receive access to Cooey Health Services.
Cooey understands that privacy of information is of great importance to our Visitors.
APPLICABILITY OF THIS PRIVACY POLICY
This Web and Mobile Privacy Policy (“Privacy Policy”) describes what information Cooey Health collects about Visitors on the publicly available portions of the Websites and/or Platforms and how that information is used.
AGREEMENT TO THIS PRIVACY POLICY
Your access and use of the Websites and/or Platforms is subject to your agreement with this Privacy Policy and the Web and Mobile Terms and Conditions. By using the Website and/or Platform, you expressly agree to the terms of this Privacy Policy and consent to the collection and use of information as discussed in this Privacy Policy.
If you do not agree with this Privacy Policy, please do not use or access the Websites and/or Platforms for any purpose. Please print a copy of this Privacy Policy for your records.
Services provided by Cooey Health includes information acquired from third-party sources and which is bound by their respective privacy policies.
MODIFICATIONS TO THIS PRIVACY POLICY
Cooey Health may revise this Privacy Policy regarding the collection of information at any time. Should this Privacy Policy change materially, Cooey Health will give notice to you by posting a notice regarding the new policy on the Websites and/or Platforms. The revised Privacy Policy will be effective as of its posting unless otherwise stated.
By accessing or using the Website and/or Platform after such changes are posted you agree to all such changes.
COLLECTION OF INFORMATION
Either Cooey Health or a third party vendor on behalf of Cooey Health may automatically collect information while Visitors browse or use the Websites and/or Platforms. We may collect such information by tracking, or asking a third party vendor to track, your click-stream activity when such information is not tied to a user ID through the use of “cookie” technology or by tracking internet protocol (IP) addresses, as explained below.
Because we want our Websites and/or Platforms to better serve Visitors’ needs, we collect some basic information about Visitors and their devices, including, but not limited to:
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IP address (the computer’s address on the Internet)
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Operating system (e.g. Windows 10)
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Browser software (e.g. Microsoft Internet Explorer, Chrome, Firefox)
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Internet Service Provider (e.g. Comcast, AT&T)
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Geographic location (e.g. Ft. Myers, Florida)
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Type of device (e.g. iPad, desktop)
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Mobile device crash information
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Locale and language of device and whether it has fingerprint/face sensors
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Dates and time you accessed and used the Website and/or Platform, features you used in the Website and/or Platform, and how long you use the Website and/or Platform overall
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Links you click and pages you view within the Website and/or Platform
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Pages you view before and after you leave the Website and/or Platform
HOW WE USE PERSONAL INFORMATION
Personal Information is information that can be used to identify you (such as your name, address or credit card number, and the identities of your emergency contacts), and other information about you that is linked to information that can be used to identify you, such as information about your location or physical condition that we receive with an alert from devices- health devices, tablets, phones- in your possession.
We will use Personal Information to provide our Cooey Health Services to you. This includes:
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Operating our Cooey Health Services, including developing, evaluating and improving our Cooey Health Services, personnel training and management, business management and general administrative activities, and customer service.
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Communicating with you about our devices and Cooey Health Services, for example to arrange and conduct testing and servicing, to provide user support, and to provide guidance and alerts about the devices or Cooey Health Services.
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Customizing our Cooey Health Services to your preferences or to show you specific content or advertisements that we think may be of interest to you.
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Providing you with general information about our products and Cooey Health Services, and about third-party products and services, including electronic newsletters and educational, promotional and marketing materials on behalf of Cooey or third parties. However, without your consent, we will not provide personal information about you to unaffiliated third parties for marketing.
We will disclose Personal Information about you to others-
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To respond to alerts, including providing information about your identity, condition and location to emergency responders and your emergency contacts.
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To allow your participation in our telehealth or remote patient care programs with your medical provider.
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To allow access to your emergency contacts as specified by you to your medical provider or in the Cooey online portals.
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When you store personal health information in your Cooey’s dashboard, and you allow your medical provider and your family to have access to that information by registering them in your dashboard. You authorize us to give access to your dashboard, and to all of the personal and health information in the dashboard to anyone you register for access to your dashboard.
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For legal compliance, including responding and reporting to law enforcement authorities, and detecting and preventing abuse of our Cooey Health Services.
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To respond to and mitigate security incidents.
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To process and collect payment for our Cooey Health Services.
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For dispute resolution, including prosecuting or defending claims by or against us.
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In the event of a change of ownership or control, including the sale, transfer, merger, or consolidation of all or part of our business with a third party (in which event we may transfer our users’ personal information to the acquiring or surviving entity), and any related due diligence disclosures.
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When we are required by law to make a disclosure.
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If you agree or opt-in to our sharing your personal information with others, for example, if you agree to receive information or promotional materials directly from a third party.
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For contests and promotions. We may offer sweepstakes, contests, and other promotions through the service that may require registration. By participating in a promotion, you are agreeing to the rules governing the promotion, which may allow the disclosure of your Personal Information to third parties in connection with the promotion.
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To aggregate or de-identify your information. We may de-identify your personal and health information by removing identifiers or by combining it with the information of other Cooey users, so that it cannot reasonably be identified with you. We may use and disclose de-identified information without restriction.
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For other purposes that we determine are necessary for the operation of our company, the provision of Cooey Health Services, or the safety of our users.
However, we will not disclose Personal Information about you to unaffiliated third parties for their marketing purposes without your consent. -
For other purposes disclosed at the time you provide your information or as otherwise set forth in this Privacy Policy, as amended from time to time.
If you subscribe to our service, you will have the ability to allow others access to your online profile. We do not control this access, and anyone to whom you allow access will be able to see all the information in your profile.
We may also share personal information about you with contractors and service providers who help us operate our Cooey Health Services, or who provide services to you in conjunction with our Cooey Health Services. These may include, for example, contractors who provide cellular service for our devices, staff our call centers, host or manage our user database or technology systems, provide customer support, and help us track and analyze the use of our Cooey Health Services. Third-party service providers (such as our cellular service provider) may collect information about your use of their services. We are not responsible for the activities of third parties, or for their compliance with their own privacy policies.
We may share information about you, including personal information with our parent, subsidiaries and affiliates, and they may use or disclose the information in accordance with this Privacy Policy.
Please remember that we do not control the use of your information by third parties. You can opt out by reaching us at privacy@mycooey.com, and stating that you would like to opt out, but opting out will not affect information we have already shared.
We reserve the right to use and disclose information that is not personal information without restriction. This is information that cannot reasonably be used to identify you, or that would require access to other information that is not publicly available in order to identify you. It includes, for example, usage information, aggregated information, and location information that does not identify you.
THE HEALTH INSURANCE PORTABILITY AND ACCOUNTABILITY ACT OF 1996 (HIPAA)
Cooey Health is not a health care provider, and is not a covered entity under HIPAA. If you participate in the Cooey Health’s remote patient care programs, and if your medical provider is a covered entity under HIPAA, Cooey Health acts as a HIPAA “business associate” of your medical provider. Business associates are not covered entities under HIPAA, but are required to maintain the privacy and security of health information that they create, receive or maintain on behalf of the covered provider. These requirements are contained in a business associate agreement between us and your provider.
If you participate in the Cooey Health’s remote patient care programs, Cooey Health makes the health-related information that we receive from your health devices available to your medical provider to enable him or her to monitor your health. If your medical provider is a HIPAA covered entity, we treat individually identifiable health information we receive from you for the remote patient care programs as protected under our business associate agreement with your physician. Our business associate agreement restricts the way we can use and disclose protected health information that we receive for the remote patient care programs. In general, we can use and disclose that information only—
To provide services to your medical provider
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To manage and administer our company and our Cooey Health Services, and to carry out our legal responsibilities
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If we are required by law to disclose the information.
We may also de-identify your health information or aggregate it with other users’ health information so that it does not identify you personally, and we may use and disclose the de-identified or aggregated information without restriction.
While we protect the privacy of Personal Information that is identifiable in the manner described in this policy, we are not required to comply with HIPAA or our HIPAA business associate agreements for information that we receive from customers otherwise than through their participation in the Cooey Health’s remote patient care program.
SECURITY
We incorporate safeguards to help protect and secure your personal information. However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information is completely secure. We cannot ensure the security of any information you transmit to us, and you use our service and provide us with your information at your own risk.
YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION
Amendment. You have a right to request that Cooey amend or delete the Personal Information it collects from your use of the Websites and/or Platform if you believe it is incorrect or incomplete, and you may request an amendment or deletion for as long as the Personal Information is retained by Cooey. You must submit your request in writing to Cooey and provide a reason to support the requested amendment. Cooey may, under certain circumstances, deny your request by sending you a written notice of denial.
Withdrawal of Consent. Subject to applicable law, you may withdraw your consent to uses and disclosures of Personal Information as outlined in this Privacy Policy. You must submit your request in writing to Cooey. Withdrawing consent does not invalidate consent to any collection, use or disclosure of Personal Information to which you consented before consent was withdrawn. If you withdraw consent, or refuse further consent, Cooey’s ability to offer services to you may be limited.
HOW TO CONTACT US?
Questions or comments regarding this Policy should be submitted to the Cooey Health President by electronic means as follows: privacy@mycooey.com
Effective: April 1, 2020