Privacy Policy

 

Effective Date: 3/1/2017

 

Aces Health, Inc. (“we”, “us”, “our”) is committed to protecting the privacy of visitors to the Aces websites located at http://www.aces.md and http://admin.aces.md (collectively, the “Website”) and users of the Aces Health mobile application (the “App”), and users of the products and services available through the Website and the App (collectively, the Website, the App, and the products and services available through the Website and App are referred to herein as the “Services” and each, as a “Service”).  When you access, browse, or use the Services, information will be collected, transferred, processed, stored, and disclosed in accordance with this privacy policy (“Policy”).  This Policy governs the information collection, use, and disclosure practices for the Services.  By accessing, browsing, or using the Services, including registering an account with our Services, you expressly consent to the collection, transfer, use, processing, and storage of your information (including personal information), as described in this Policy.  Please fully review this Policy before you use the Services or submit information to us.  IF YOU DO NOT AGREE WITH THIS POLICY OR THE INFORMATION COLLECTION, USE, AND DISCLOSURE PRACTICES DESCRIBED IN THIS POLICY, DO NOT USE THE SERVICES OR REGISTER AN ACCOUNT.

 

  1. INFORMATION COLLECTION PRACTICES

 

This section of the Policy, Information Collection Practices, outlines the various ways that we gather information about you.

 

  • Information that You Provide.  We may collect and store any and all information that you enter through the Services or give to us in any other way.  This section, Information that You Provide, provides examples of the information that you provide to us.  You can choose not to provide certain information to us, but then you might not be able to access or use all of the Services.

 

  • Account Registration and Login. You may visit and browse the Website without registering or submitting personal information about yourself.  However, to use the App and other Services available through the Website and the App, you will be required to register for an account and, if you use multiple Services, you may be required to register for a distinct account for each Service (each, an “Account”) by entering information.  When you register for an Account, you may be asked to provide some personal information, such as your name (or, if you are a trial or study participant (a “Trial Participant”), an authentication code or PIN), EHR login credentials, preferred device information, and a username and password that you select. When you register for an Account and log in to a Service you must provide your current, complete, and accurate information. It is your responsibility to keep your information up to date. We are not responsible for any problems, interruptions in access, or liability that may arise if you do not give us complete and accurate information or if you fail to update your information so that it is current.

 

  • Profile Creation. After you register for an Account, some Services will ask you to create a user profile (a “Profile”).  If you choose to create a Profile, we may collect and store personal information about you that you provide when you create your Profile, such as information requested by trial coordinator, study administrator, sponsor representative, or other party that instructed you to download the App, your address, zip code, phone number, email address, gender, ethnicity, age or age range, birth date, additional contact information, a user name that you choose, and a Profile image.  If you are a Trial Participant, we may also ask you to provide a unique identification number and  additional personal information as requested by the individual or entity that has engaged us to provide services with respect to the study or trial in which you are participating, and will collect and store any such personal information that you provide.

 

  • Correspondence; Contact Us Feature. If you send us personal correspondence, such as emails or letters, or if other users or third parties send us information about your use of the Services, we may save the information in a profile specific to you.  Additionally, we collect and store the personal information you provide when you use the “Contact Us” feature within the Services, such as your first name, last name, address, email address, the reason for your inquiry, and your comments.

 

  • Your Use of the Services. We collect and store the information that you and other users provide about you when you and they use and interact with the Services.  For example:

 

  1. If you are a Trial Participant, we collect and store your responses to surveys and questionnaires that you complete in connection with the study or trial in which you are participating.

 

  1. If you are a Trial Participant and designate an “emergency contact” or guardian/caretaker within the Services, we collect and store the emergency contact or guardian/caretaker’s name and contact information that you provide.

 

  • If you are an Administrator, we collect and store the information you provide when using the Services to request additional medical supplies and equipment in connection with a trial or study.

 

  1. We collect and store data and documents that you upload into the Services, including but not limited to medical documents, pictures, lab results, text, audio and video files, and data from other devices.

 

  • Information that is Automatically Collected. We collect and store information about you and any computer or device you use to access or use the Services automatically using a variety of technologies.  This section, Information that is Automatically Collected, provides examples of information that we collect about you automatically.  We collect this information for the purposes described in this Policy, including to better understand our user base and to improve the quality of the Services.

 

  • Device and Log Information. We automatically collect and store information about any product or device you use to access or use the using a variety of technologies.  This information may include your diagnostic log information, IP address or other persistent identifier, mobile number, operating system, browser type and language, referring/exit pages and URLs, other browser history, number of clicks, landing pages, the pages you requested and viewed, the amount of time spent on particular pages, information about the source of internet connectivity, type of device, and the date and time.  We may associate your device-specific information with you and your Account.

 

  • Location Information. If you give us permission through the Services, we may collect location information (including geolocation and GPS location) about you through the Services or your device.  Once you have given us permission to collect location information, we may continue collecting that information without asking permission again.  You may be able to disallow our use of certain location data through your device settings, for example, by disabling “Location Services” for specific Services in your device’s privacy settings.  If you block the use of location information, some features of the Services may be inaccessible or not function properly.

 

  • Cookies and Other Tracking Technologies. We may use cookies, web beacons, tracking pixels, web bugs, scripts, tags, and other similar technology (collectively, “Cookies”) to record information about your activities in the Services and on third-party websites that you visit.  Some Cookies remain on your device until you delete them; others are stored only during an individual session.  You may set your device settings to attempt to reject Cookies, but doing so may affect functionality of the Website.  See Section 4 (Online Tracking and Your Choices) for more information on how the Website may respond to your device settings.  We do not control the use of Cookies by third parties.  See Section 3.3 (Sharing with Third Parties) for more information and review the privacy policies of all third-party providers for information about third-party Cookies.

 

  • Information that is Collected from Other Sources. We may collect and store information about you from other sources.  This section, Information that is Collected from Other Sources, provides examples of information that we collect from other sources.

 

  • Information that is Collected by Third Parties. Some Services link or allow you to access or sign up for services provided by third parties (“Third Party Sites and Services”). The collection, use, and disclosure of information by Third Party Sites and Services are subject to the privacy policies of the third-party operator, which we do not control.

 

  • Trial/Study-Related Records and Data. If you are a Trial Participant, we may collect and store personal information through the Services in connection with the trial or study in which you are participating.  For example, we may collect and store your electronic health records that you authorize us to collect from third parties; information that is provided to us by your health care provider or the coordinator/administrator of a trial or study; and data that you authorize us to collect through the Services from wearable devices, sensors, and mobile health applications (e.g., wearable fitness trackers, insulin pumps, glucometers, rescue inhalers, smart pill boxes, etc.) in connection with the trial or study in which you are participating.

 

  1. HOW WE USE INFORMATION

 

This section of the Policy, How We Use Information, outlines the various ways that we use the information that we collect about you.

 

  • General. We may use your personal information (including personal health information and tracking information) for any lawful purpose, including to manage your account; operate, maintain, and improve the Services and any successor or future versions of the Services (including to provide you a more personalized experience); prepare analytics for our customers; otherwise analyze trends, conduct research, and track users’ movements around the Services; develop new products and services; allow you to log in more conveniently; understand where requests originate; conduct security and statistical analysis; communicate with you; produce traffic volume statistics; maintain a record of customer service requests; provide you information about products and services (including products and services of third parties); sell and deliver advertising; market; conduct research; resolve disputes; detect and protect against errors, fraud, and criminal activity; assist law enforcement; enforce this Policy and any other terms related to the Services; and for any other purpose described in this Policy or that we describe to you at the time of collection.

 

  • Email Communications. We may use your personally identifiable information to send you emails or other communications related to your Account or the Services, or in response to your inquiries or requests. You may not opt-out of receiving service-related messages that are not promotional in nature. We may also send you marketing emails, surveys, or newsletters to notify you about products, services, or trials and studies that may be of interest to you. If you would like to stop receiving marketing emails from us, please click on the unsubscribe link at the bottom of any marketing email you receive. If you opt-out, you will continue to receive service-related emails.

 

  • Retaining Your Information. In general, we will retain your information indefinitely, or as long as legally required or allowed. If you cancel your Account or your Account is otherwise terminated, we may, but are not obligated to, delete information we have collected or obtained from you and third parties and we may continue to use and disclose it in accordance with this Policy.

 

  1. HOW WE SHARE INFORMATION

 

This section of the Policy, How We Share Information, describes how we share the information that we collect about you with other parties.

 

  • Generally. We may disclose your personal information to third parties for any lawful purpose, including to any affiliated entity or organization and to agents and service providers; and according to our agreement with our customer in relation to a particular study or trial. We may also, to the extent permitted by law, sell your personal information to third parties for commercial purposes, including, if you are a Trial Participant, to third parties who may use that information to contact you about studies and trials in which you may be interested.

 

  • Sharing on the Services. Some of the Services allow users to connect and communicate with others.  Other users with whom you communicate within the Services can view all information that you include in those communications.

 

  • Sharing with Third Parties. We may share information about you with third parties to help us operate and improve the Services.  Additionally, we may be required to disclose information about you to comply with law, or in connection with a business transition.  This section, Sharing with Third Parties, provides examples of how we share your information with third parties.

 

  • Service Providers. We use third parties to help us operate and improve the Services. We may provide these third parties information we collect and they may collect information from you and about your use of the Services. We may provide information we collect to third parties and it will, unless specifically noted otherwise in this Policy, be governed by this Policy and may only be used by those third parties to help us operate or improve our business or the Services and provide services to us. We do not control information collected by third parties and are not responsible for their use of that information.

 

  • Human API. We use Human API, a third-party service provider, to facilitate the collection of Trial Participants’ electronic health records and the collection of data from wearable fitness trackers, devices, sensors, and mobile health applications.  Human API may obtain certain personal information related to you and your use of the Services.

 

  • io. We use Slope.io, a third-party logistics service provider, to assemble and ship medical supplies to Trial Participants.  Slope.io may obtain certain personal information related to you and your use of the Services.

 

  • Google Analytics. We use Google, a third-party analytics provider, to collect information about Website usage and users of the Website.  Google uses Cookies to collect usage information from users that visit the Website, including information about the pages where users enter and exit the Website, what pages users view on the Website, time spent on each page, browser version, operating system, internet protocol address, and geolocation information.   Cookies allow Google to recognize a user when a user visits the Website and when the user visits other websites.  Google shares the information it collects with us.  For more information regarding Google’s use of cookies and collection and use of information, see the Google Privacy Policy.  If you would like to opt out of Google Analytics tracking, please visit the following link: Google Analytics Opt-Out Browser Add-on.

 

  • Legal Requirements. In some cases, we may disclose your personal information as required by law; if we believe that disclosure is needed to protect our rights; to government regulators; to law enforcement authorities; in connection with any judicial proceeding, court order, subpoena, or legal process served on us or the Services; and to respond to a physical threat to you or another person.

 

  • Insolvency and Business Transitions. If we ever file for bankruptcy or engage in a business transition such as a merger or joint venture with another company, or if we purchase, sell, or reorganize all or a part of the Services or our business or assets or the business or assets of our affiliates, we may transfer your personal information in connection with one of these transactions.

 

  • Disclaimer. We cannot ensure that all of your personal information will never be disclosed in ways not otherwise described in this Policy. For example, we may be required to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your personal information that they collect from the Services. No storage or transmission of data can be 100% secure.

 

 

  1. ONLINE TRACKING AND YOUR CHOICES

 

As discussed above, because we and our third-party service providers automatically collect Services usage information through the use of Cookies (including as described in the “Information that is Automatically Collected” section above, and otherwise in this Policy), your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of automatically collected information. One way to attempt to “opt out” of the collection of any information through Cookies and some (but not all) other tracking technology is to actively manage the settings on your browser to delete and disable Cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult and may not be possible. Using browsers as an example, not all tracking technologies can be controlled by browsers; unique aspects of your browser might be recognizable even if you disable a tracking technology; not all settings will necessarily last or be effective; even if a setting is effective for one purpose data still may be collected for another; and even if one website observes a “Do Not Track” signal, that website usually will not be able to control other websites.  Additionally, if you select a “Do Not Track” option or disable Cookies on your device, certain Services may become unavailable or may not function properly.

 

  1. INFORMATION SECURITY MEASURES

 

Keeping secure personal information that we collect is of great concern to us. While we have mechanisms in place to safeguard your personal information once we receive it, no storage or transmission of data can be guaranteed to be 100% secure. When you provide information to the Services, you do so at your own risk.

 

  1. CHILDREN

 

The Services are intended for general audiences and are not directed to children under 13. If you become aware that a child has provided us with personal information without parental consent, please contact us by using the contact information in the Privacy Questions section at the bottom of this Policy, and we will take steps to remove the information and terminate the child’s Account.

  1. MINORS

 

Any individual under the age of 18 may request that his or her information, including content posted to the Services by that individual, be removed from the Services by contacting us by using the contact information in the Privacy Questions section at the bottom of this Policy, and we will take steps to remove the information. It is important to note that removal of content or termination of an account does not ensure complete or comprehensive removal of the content or information posted through the Services.

  1. CALIFORNIA SHINE THE LIGHT LAW

 

California Civil Code Section 1798.83 permits California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed personal information (as defined under that statute) of that California resident for direct marketing purposes in the preceding calendar year and the categories of that kind of personal information that was disclosed to them. If you are a California resident and you wish to make such a request you may contact us by using the contact information in the Privacy Questions section at the bottom of this Policy.

  1. ACCESSING AND UPDATING YOUR PERSONAL INFORMATION

 

If would like to cancel your Account or update your personal information associated with your Account, you may make such changes by contacting your trial coordinator, study administrator, sponsor representative, or other party that instructed you to download the App.

 

  1. MODIFICATION OF THIS POLICY

 

We will occasionally update this Policy.  When we post changes to this Policy, we will revise the “Effective Date” at the top of this Policy.  We recommend that you check the Services from time to time to inform yourself of any changes in this Policy or any of our other policies.  By continuing to access or use the Services after a change to this Policy becomes effective, you agree to the revised Policy.

  1. PRIVACY QUESTIONS

 

If you have questions or concerns about our privacy practices, please email us at: info@aces.md