PRIVACY POLICY
NUFORM HEALTH AND WELLNESS, INC.
PRIVACY POLICY
Effective Date: November 20th, 2024
Nuform Health and Wellness, Inc. (“Nuform,” “us” or “we”) takes your privacy very
seriously. We created this Privacy Policy to provide you with important information
about the privacy practices applicable to the services provided by us through the
Nuform Platform (the “Platform”) via our website at nuformhealth.com (collectively, the
“Services”). This Privacy Policy describes how we collect, protect, use, disclose and
store the information collected through the Services.
By downloading, accessing, or using the platform or services,and/or by registering with us or providing information to us inconnection with the application, you accept the practices andpolicies outlined in this privacy policy, and you hereby consentthat we will collect, use, and share your information as setforth in this privacy policy. if you are registering an account orusing the services on behalf of an individual other than yourself,you represent that you are authorized to accept this privacypolicy on such individual's behalf.
Your use of the Services is also subject to our Terms of Use, which are available here.
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
Nuform collects Personal Information from users when such users register for and use the Platform. You don't have to use the Platform, but if you do, you acknowledge that Nuform collects and uses your Personal Information for the legitimate interests and purposes described in this Privacy Policy. Nuform collects the following types of Personal Information which you provide to us:
• Registration information related to Patient Users.
• Health information about Patient Users provided by the patients 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.
• Details of transactions you carry out through our Platform.
In addition to collecting Personal Information that you provide to us, we may automatically collect certain Personal Information when you use the Services, such as IP address, information about your browser, device or operating system or similar information. IP addresses are ID numbers for the location of your computer or network on the internet. Log files are recordings of the traffic to and from a server. Nuform servers log IP addresses for systems administration and troubleshooting. We track page hits in the aggregate to track the popularity of pages that people visit. With that information we can improve the quality of our Platform. We may also use or allow third parties to use web beacons on our Platform to monitor the effectiveness of survey qualification. Web beacons are small, graphic images on web pages, web-based documents, or in email messages that allow us or third parties to monitor who is visiting our Platform or if an email has been read. Web beacons collect the IP address of the device where the web beacon is sent, the URL of the page where the web beacon originates, and the time it was viewed. Web beacons may be linked to your Personal Information. We may also use third-party devices, services, links, or electronic mail to deliver surveys to you, which may use cookies, web beacons, or other technology to collect information about your visits to our Platform (or other websites) in order to present surveys that may be of interest to you.
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;
• 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 Nuform 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
• 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.
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
• 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.
Nuform does not 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.
No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All the above categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
We may also disclose to third parties aggregate or de-identified data that is not personally identifiable for any legally permissible purposes.
Your Rights
When it comes to your health information, you have certain rights.
This section explains your rights and some of our responsibilities to help you.Get an electronic or paper copy of your medical record
• You can ask to see or get an electronic or paper copy of your medical record and other health information we have about you. Ask us how to do this.
• We will provide a copy or a summary of your health information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.
Ask us to correct your medical record
You can ask us to correct health information about you that you think is incorrect or incomplete. Ask us how to do this.We may say “no” to your request, but we’ll tell you why in writing within 60 days.
Request confidential communications
• You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address. We will say “yes” to all reasonable requests.
Ask us to limit what we use or share
• You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no” if it would affect your care.
• If you pay for a service or health care item out-of-pocket in full, you can ask us not to share that information for the purpose of payment or our operations with your health insurer. We will say “yes” unless a law requires us to share that information.
Get a list of those with whom we’ve shared information
• You can ask for a list (accounting) of the times we’ve shared your health information for six years prior to the date you ask, who we shared it with, and why.
• We will include all the disclosures except for those about treatment, payment, and health care operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.
Get a copy of this privacy notice
You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.
Choose someone to act for you
• If you have given someone medical power of attorney or if someone is your legal guardian, that person can exercise your rights and make choices about your health information.
• We will make sure the person has this authority and can act for you before we take any action.
File a complaint if you feel your rights are violated
• You can complain if you feel we have violated your rights by contacting us using the information on page 1.
• You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting www.hhs.gov/ocr/privacy/hipaa/complaints/.
• We will not retaliate against you for filing a complaint.
Your Choices
For certain health information, you can tell us your choices about what we share. If you have a clear preference for how we share your information in the situations described below, talk to us. Tell us what you want us to do, and we will follow your instructions.In these cases, you have both the right and choice to tell us to:
• Share information with your family, close friends, or others involved in your care
• Share information in a disaster relief situation
• Include your information in a hospital directory
If you are not able to tell us your preference, for example if you are unconscious, we may go ahead and share your information if we believe it is in your best interest. We may also share your information when needed to lessen a serious and imminent threat to health or safety.
In these cases we never share your information unless you give us written permission:
• Marketing purposes
• Sale of your information
• Most sharing of psychotherapy notes
In the case of fundraising:
We may contact you for fundraising efforts, but you can tell us not to contact you again.
Our Uses and Disclosures
How do we typically use or share your health information?
We typically use or share your health information in the following ways.
Treat you
We can use your health information and share it with other professionals who are treating you.Example: A doctor treating you for an injury asks another doctor about your overall health condition.
Our Responsibilities
• We are required by law to maintain the privacy and security of your protected health information.
• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information.
• We must follow the duties and privacy practices described in this notice and give you a copy of it. We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.
For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html.
COOKIES
A cookie is a small piece of information that a website can store on a computer and sometimes later use to recognize a user. The purpose of cookies is to enhance your ability to receive the information you want. In the future, we may use cookies to enhance the experience of users. A “session” cookie expires when the user closes the browser in which the website was viewed. A “persistent” cookie may be used to help save your settings and customizations. As with all cookies, you can personalize you web browser settings to reject session cookies. Though some cookies, that are strictly necessary for site operation, cannot be toggled off.
Some of our business partners with whom we contract to carry out the Services (e.g., website providers) may use their cookies on our website and/or Platform. Although we may not have direct access to or control over such cookies, this Privacy Policy governs the use of cookies by us and such business partners on our website and Platform. We may also allow social media companies (e.g., Facebook) to put “widgets” on our websites. These third-party tools may also be used to track you across websites. For example, so long as you are logged in to Facebook, every time you land on a webpage that has a Facebook widget, Facebook will know you are on that webpage. We do not control the privacy practices of these third parties.
By completing the intake form on our website, you acknowledge and consent to the use of cookies and tracking technologies as described in this Privacy Policy. These technologies help us provide you with a personalized experience, understand your usage of our website, and improve our services. By submitting your intake form, you confirm that you have read, understood, and consent to these practices.
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 Platform may contain a link.
CHILDREN’S PRIVACY
Nuform 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, Nuform’s Services are intended only for adults. 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 info@nuformhealth.com.
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.
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.
UPDATES TO THIS PRIVACY POLICY
We may occasionally update this Privacy Policy at any time. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available through the Platform. We will update the “Effective Date” date at the top of this Privacy Policy if we make any such changes to this Privacy Policy. Your use of the Platform or the submission of any information in connection with the Platform following any change means that you accept the revised Privacy Policy. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and disclose personally identifiable information.
CONTACTING US
If you have any questions or comments about this Privacy Policy, please contact us by e-mail at info@nuformhealth.com. Please note that e-mail communications are not always secure; so please do not include health information, credit card information or other sensitive information in your e-mail messages to us.