Last modified: July 2022.
”) describes the types of information we may collect from you or that you may provide when you visit KeyCare.org or any of our affiliated websites where this Policy is posted(collectively, “Website
”) and the KeyCare application ( “Application
”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. This policy applies to information we collect: on our Website and Application; in emails, text message, phone conversations, audio and video interactions and other electronic messages between you and our Website and Application; when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy. It does not apply to information collected by: us offline or through any other means, including on any other website operated by KeyCare or any third party; any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or Application.
Note, KeyCare is not a medical group. Any telemedicine consults obtained through our Website or Application are provided by independent medical practitioners including, but not limited to, KeyCare Medical Group, P.A., KeyCare Medical Group (DE), P.A., KeyCare Medical Group of New York, KeyCare Medical Group (IL), LLC, KeyCare Medical Group(NC), P.C., KeyCare Medical Group (NJ), LLC, KeyCare Medical Group NM, LLC, KeyCare Medical Group of California ,and MDL Medical Group (TX), PLLC (collectively, “KeyCare Medical Group”), which are independent medical groups with a network of United States based health care providers (each, a “Provider”). KeyCare Medical Group (or your own medical provider if you do not use a KeyCare Medical Group Provider) is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not KeyCare. If you do not agree to be bound by those terms, you are not authorized to access or use our Website, and you must promptly exit our Website or Application.
2. Children Under the Age of 18.
3. Information We Collect About You and How We Collect It.
We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.
We collect several types of information from and about users of our Website and Application (collectively, “Personal Information
”), specifically information: by which you may be personally identified, such as name, address, e-mail address, home, work, and mobile telephone numbers, date of birth, credit or debit card number (for payment purposes only), audio (including recordings and transcripts), images and videos of you, gender, Social Security Number, your medical history, health insurance subscriber information, and health information; about your Internet connection, the equipment you use to access our Website or use our Application and usage details, such as traffic data, logs, referring/exit pages, date and time of your visit to our Website or use of our Application, error information, click stream data, and other communication data and the resources that you access and use on the Website or through our Application. We collect this information: directly from you when you provide it to us; automatically as you navigate through the Website or use our Application. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and from third parties, for example, our business partners.
Information You Provide to Us
The information we collect on or through our Website or through our Application is: information that you provide by filling in forms on our Website or the Application videos, images and recordings when interacting with a Provider on our Website or the Application. This includes information provided at the time of registering to use our Website or Application as well as information provided when using our Provider consultation services, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Website or Application; records and copies of your correspondence (including email addresses), if you contact us; and details of transactions you carry out through our Website or through the Application and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website or Application. You also may provide information to be published or displayed (hereinafter, “posted
”) on public areas of the Website or Application or transmitted to other users of the Website or Application or third parties(collectively, “User Contributions
”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website and Application with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons. The audio portion of your medical telehealth visit (including audio from visits that include video) is recorded for purposes which may include treatment, quality, improvement of health status, customer and patient experience, customer and patient engagement and/or behavior modification, peer review, payment, efficiency, cost effectiveness and/or other purposes relating to operations and provision of telehealth services. Behavioral health visits are not recorded. By using the telehealth services available through our Website and Application you specifically consent to the recording of the medical visit.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Website and Application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically: details of your access to and use of the Application and Website, including traffic data, location data, logs, and other communication data and the resources that the end user accesses and uses on or through the Application and Website; information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number; information stored on your mobile device, including in other applications. This may include, photographs, audio and video clips, personal contacts, and health information. In particular, we may collect information through your Health Kit application. This data will be used only to provide and improve our services, and will not be used or shared with third parties for marketing purposes; or real-time information about the location of your device. The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Website and Application and to deliver a better and more personalized service by enabling us to: estimate our audience size and usage patterns; forecast future needs, functions, and uses of our services, the Website, and the Application; better understand user satisfaction levels and experiences; store information about your preferences, allowing us to customize our Website and our Application according to your individual interests; recognize you when you return to our Website and our Application; in other ways to improve your experience and the quality of our Website, Application, and services. The technologies we use for this automatic data collection may include:
Cookies (or browser cookies).
Certain features of our Website and Application may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Web site and Application. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website.
We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”
).We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.org/analytics/learn/privacy.html.
We use Facebook Pixel, a web analytics and advertising service provided by Facebook Inc.(“Facebook”
) on our Website and Application. With its help, we can keep track of what users do after they see or click on a Facebook advertisement, keep track of users who access our Website and Application or advertisements from different devices, and better provide advertisements to our target audiences. The data from Facebook Pixel is also saved and processed by Facebook. Facebook can connect this data with your Facebook account and use it for its own and others advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.org/about/privacy/
. Please click here if you would like to withdraw your consent for use of your data with Facebook Pixel https://www.facebook.org/settings/?tab=ads#_=_
.Please also refer to Choices About How We Use and Disclose Your Information
below for more information about tracking technologies, targeted advertising and your choices relating to the use of your information for these purposes.
Other Third Party Cookies:
We encourage you to review the privacy policies of the other third party cookies deployed on our Website and Application, including Live Ramp’s (https://liveramp.org/privacy/service-privacy-policy/
)and Adobe’s (https://www.adobe.org/privacy/policy.html
4. How We Use Your Information.
We use your Personal Information for various purposes described below, including to: provide our Website or Application to you; provide services to you; provide you with information you request from us; enforce our rights arising from contracts; notify you about changes; and provide you with notices about your account. We use information that we collect about you or that you provide to us, including any Personal Information: to provide and improve our Website, Application, products, and services. For example, we may convert our recordings to text and perform machine learning on data we receive; to provide you with information, products, or services that you request from us or that may be of interest to you; for purposes of treatment, quality, improvement of health status, customer and patient experience, customer and patient engagement and/or behavior modification, peer review, payment, efficiency, cost effectiveness and/or other purposes relating to operations and provision of telehealth services; to process, fulfill, support, and administer transactions and orders for products and services ordered by you; to provide you with notices about your KeyCare account; to contact you in response to a request; to administer surveys; to fulfill any other purpose for which you provide it; to carry out our obligations and enforce our rights arising from any contracts entered into between you and us or between us and health plans or other benefit programs, including for billing and collection; to notify you about changes to our Website, our Application, or any products or services we offer or provide though them; in any other way we may describe when you provide the information; and for any other purpose with your consent. We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at anytime by clicking unsubscribe at the bottom of these communications. For more information, see “Choices About How We Use and Disclose Your Information”
Some information KeyCare collects constitutes protected health information (“PHI”) under the U.S. Health Insurance Portability and Accountability Act (“HIPAA”). As set forth above, KeyCare Medical Group (or your own medical provider if you do not use a KeyCare Medical Group Provider) will provide you with a Notice of Privacy Practices describing its collection, use and disclosure of your PHI, not KeyCare, Inc. KeyCare is a “business associate” (as that term is used under HIPAA) that provides services to and for KeyCare Medical Group, other health care providers and health care plans, referred to as “covered entities” under HIPAA, and enters into business associate agreements with these covered entities. KeyCare will use and disclose PHI only in accordance with the business associate agreements and HIPAA.We may de-identify your Personal Information so that it no longer reasonably identifies you. In this case, we may use this de-identified data without restriction and for any purpose, including to improve our Website, Application, and products and services.
5. Disclosure of Your Information
and other agreements, including for billing and collection purposes; and if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of KeyCare, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
6. Choices About How We Use and Disclose Your Information
We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted advertising. We do not control the collection and use of your information collected by third parties. We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with control over your Personal Information:
Tracking Technologies and Advertising.
Promotional Offers from KeyCare.
If you do not wish to have your email address used by KeyCare to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any promotional emails or other marketing communications you receive from us. This opt out does not apply to information provided to KeyCare as a result of a product purchase, or your use of our services.
You can choose whether or not to allow the Application to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Application may then be inaccessible or not function properly.
To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance
and the Network Advertising Initiative
). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.
7. Your Rights Regarding Your Information and Accessing and Correcting Your Information
You may review and change your Personal Information by logging into the Application or Website and visiting your User Preferences page. You can review and change your Personal Information by logging into our Website or Application and visiting either the Account Details section of our Application or Website. You may also notify us through the Contact Information below of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect. With respect to any PHI in our possession, you have certain rights under HIPAA as described in the Notice of Privacy Practices provided to you by your healthcare Provider.
8. Do Not Track Signals
We currently do not use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not automatically honor such signals. However, please review other portions of this Policy regarding your ability to disable tracking technologies (e.g., Information We Collect Through Automatic Data CollectionTechnologies
, Choices About How We Use and Disclose Your Information
9. Data Security
Information transmitted over the Internet is not completely secure, but we do our best to protect yourPersonal Information. You can help protect your Personal Information and other information by keeping your password to our Website confidential.We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use application timeouts and encryption technology for information sent and received by us.The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website or Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the Internet is not completely secure. Although we work diligently to try and protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website or on or through our Application. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, in your operating system, or in the Application.
10. California Privacy Rights
California residents have certain additional privacy rights as described in this Section. These California Privacy Rights
” or “you”). This notice is to comply with the California Consumer Privacy Act of 2018 (“CCPA
“) and any terms defined in the CCPA have the same meaning when used in this notice. We may update these California Privacy Rights as necessary and in the event of changes in the CCPA. These terms apply only to California residents. Please note that the CCPA expressly excludes personal information regulated under the California Confidentiality of Medical Information Act (CMIA) and protected health information (PHI) collected by a “covered entity” (e.g. a health care provider or insurance plan) or “business associate” (e.g., KeyCare) that provides services to a covered governed by HIPAA.
Categories of Personal Information KeyCare collects
for additional information and details. Personal information does not include information that is: (a) publicly available information from government records; (b) de-identified or aggregated consumer information; or (c) certain information excluded from the scope of CCPA (e.g., PHI covered under HIPAA and medical information covered under the CMIA as discussed above).
Categories of Sources from which KeyCare has collected Personal Information:
We collect Personal Information directly from you, for example when you provide it to us to when you contact us to our Website for Application, for create an KeyCare account; and indirectly from you automatically through your computer or device as you use our Website or Application. We may also collect Personal Information about you from our advertising partners and service providers.
Use of Personal Information:
Sharing Personal Information:
KeyCare may disclose your Personal Information to a third party for one or more business purposes. When we disclose Personal Information for a business purpose, such as to service providers, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for Business Purposes:
We may disclose your Personal Information for our business purposes, such as your contact information, other information you have provided to us and unique identifiers that identify you to us or to our service providers, such as companies that assist us with marketing and advertising. Please refer to Information We Collect About You and How We Collect It
for additional information and details. We disclose your Personal Information to certain third parties such as our health care Provider partners, service providers, including companies that assist us with marketing and advertising. For additional information please refer to How We Use Your Information
and Disclosure of Your Information
Access Request Rights:
You have the right to request that KeyCare disclose certain information to you about our collection and use of your Personal Information over the past 12 months for the above business and commercial purposes. To submit an access request, see Exercising Access and Deletion Rights. Once we receive and confirm your verifiable consumer request, we will disclose to you: The categories of Personal Information we collected about you. The categories of sources for the Personal Information we collected about you. Our business or commercial purpose for collecting that Personal Information. The categories of third parties with whom we share that Personal Information. The specific pieces of Personal Information we collected about you. If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing: sales, identifying the Personal Information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights:
You have the right to request that KeyCare delete your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless certain exceptions apply.
Exercising Access and Deletion Rights:
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by emailing us at privacy@KeyCare.org. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must: Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: Deny you goods or services. Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties. Provide you a different level or quality of goods or services. Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Other California Privacy Rights:
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g. requests made in 2020 will receive information regarding such activities in 2019). You may request this information once per calendar year. To make such a request, please contact us by email at compliance@KeyCare.org.
12. Contact Information: