Effective Date: April 6, 2023
Through the Platform, patients (“Patient Users”) can connect with Handspring counselors, nurse practitioners, and psychiatrists (our “Providers”) and receive services from the Providers via telehealth.
COLLECTION, USE, AND DISCLOSURE OF INFORMATION
What is Personal Information?
Personal Information is any information relating to a natural person who is, or can be, identified either directly or indirectly from such information and includes information such as a user’s name, address, telephone number, email address, Internet activity (such as browsing history), or other information directly linked to that person. Personal Information that we collect also includes the personal medical information which users provide to us through the Services. You are not legally required to provide Personal Information to us, but if you refuse to provide such information, we may not be able to register you to use the Platform.
Information that We Collect
▪ Registration information related to Patient Users and their parents/legal guardians;
▪ Health information about Patient Users provided by the patients, their parents/legal guardians, and/or Providers through use of the Services;
▪ Records and copies of your correspondence (including email addresses), if you contact us;
▪ Contact details you may provide, such as your name and email address; and
▪ Details of transactions you carry out through our Platform.
In addition, from time to time, we may use or augment the Personal Information we have about you with information obtained from other sources, such as public databases, social media platforms, and other third parties.
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;
▪ communicate with health care professionals who will help you identify the appropriate level of care and healthcare setting for the healthcare services you are requesting;
▪ send to you administrative information, including information regarding the Platform, and changes to our terms, conditions and policies;
▪ schedule and provide services related to the scheduling of an appointment, for example; communicate with you 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;
▪ personalize your experience on the Platform by presenting products and offers tailored to you;
▪ create diagnostic or therapeutic models intended for use by the Handspring community;
▪ further our business purposes, such as quality assessment, data analysis, audits, developing new products, enhancing the Platform, improving our services, identifying usage trends to inform members of the Handspring community which aspects of the Platform might be useful to them, 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
Our use of your Personal Information may also be subject to certain restrictions set forth in an agreement between us and your Provider.
We may also use aggregate or de-identified data that is not personally identifiable for any legally permissible purposes without restriction.
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 Platform, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing and other similar services;
third parties, to permit them to send marketing communications to you regarding our products or services or the services of your Providers;
▪ 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
Handspring does not, to the best of our knowledge, sell or rent Personal Information that we have collected or retained about you to any other third-party for any purpose. Accordingly, we do not offer individuals the ability to “opt-out” of the selling or renting of Personal Information because we do not engage in those practices.
We may also disclose to third parties aggregate or de-identified data that is not personally identifiable for any legally permissible purposes.
Handspring is concerned about the safety and privacy of children online. Because of this, we will make all efforts to comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). COPPA and its accompanying FTC regulations establish United States federal law that protects the privacy of children using the internet. Further, Handspring Services are intended only for minors whose parents/legal guardians have consented to their use of such Services. However, it is possible that by fraud or deception by others we may receive information given to us or pertaining to minors, including children under 13. If we are notified of this, as soon as we verify the information, we will immediately obtain parental consent or else delete the information from our servers. If you want to notify us of our unauthorized receipt of information by minors, including children under 13, please email email@example.com.
Notwithstanding the foregoing, depending upon the functionality available in the Platform, you, a partner or legal guardian may register a minor under their supervision for access to our Services as a Patient User. In such cases, our Services may include features through which a parent or guardian may be permitted to view the Personal Information or manage the benefits on behalf of registered minors. The parent or guardian shall have permission to view the Personal Information of the minor they register until such minor reaches the age of majority or otherwise qualifies as an emancipated minor under applicable law and provide Handspring with evidence of such emancipated status. The availability of the Personal Information of a minor's information to the parent or guardian may depend on the minor’s preferences, available website functionality, and applicable law. Upon turning 18, we will cease providing access to Services to the parent or guardian related to a minor that reaches the age of majority, at which point the minor that reaches the age of majority will be required to take ownership of their own registered account.
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.
STORAGE OF DATA
We will only store Personal Information for as long as it is needed to fulfill the purposes for which it was collected, subject to applicable data retention periods imposed upon us by applicable law. This may mean that your Personal Information is stored by us for a number of years, depending on the purpose and need for that data to be processed.