Privacy Policy

Last updated: November 3, 2021

This privacy policy describes the practices of Engooden Health (“we” or “Engooden”) with regard to personal information about you that we obtain, either directly or indirectly through you and/or third-party vendors, through our digital properties that link to this Privacy Policy, including the Chronic Care Management application (“the application”), our website, and other activities described in this Privacy Policy.

WHAT PERSONAL INFORMATION WE COLLECT

Information you provide to us: Personal information you may provide to use through the CCM or otherwise includes:

  • Contact data, such as your name, email address, mobile phone number and NPI.
  • Profile data, such as your username, password, and photograph, your name, gender,
  • Business data, such as office contact information, practice specialty areas, practice type, hospital affiliations, whether you are accepting new patients, and insurance accepted, and other information you may provide in any CCM profile/user account.
  • Marketing data, such as your preferences for receiving communications about our or our vendors, service providers, or partners products, and services, and details about how you engage with our communications.
  • Content that you upload or share to the CCM, including text, photos, and videos.
  • Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise described at the time of collection.

Please note that if you choose not to provide categories of requested information, you may not be able to use certain features of the application.

Information automatically collected about you: Whenever you use our application, we, our service providers, and our business partners may automatically collect data about you or your device such as your device ID and related device identifier information (e.g., cookies information, web beacon technologies, IP Address, etc.), and information about how you use our application, such as:

  • Online activity data, such as which users are logging onto and using the application, how frequently such users access the application, and how long you use the application.
  • Device data, such as data about the equipment used to visit the application and the patterns of utilization of the application, your device’s operating system type and version, manufacturer and model, browser type, RAM and disk size, CPU usage, device type (e.g., pone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and general location information such as city, state, or geographic area.

Cookies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Policy.

Data about others. Users of CCM may have the opportunity to refer friends, family members, care providers, colleagues, or other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with use unless you have their permission to do so.

HOW WE USE YOUR INFORMATION

We use your personal information for the following purposes or as otherwise described at the time we collect it:

CCM delivery. We use your personal information to:

  • Deliver the application and provide related services, as applicable;
  • Improve the functionality of the application; for example, we may track the number of visitors using certain portions or features of the application to make changes that may be necessary to improve the application’s functionality;
  • Track the popularity of features on the application to guide the development of new features; and
  • Send you confirmations, technical notices, updates, security alerts, and support and administrative messages.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the CCM, our website and our business.

Marketing. We use your personal information to communicate with you via email, mobile alerts and other messaging services about:

  • Commercial, non-commercial, sponsored and non-sponsored clinical information; and
  • Engooden Health-related or other direct marketing communications as permitted by law.

You may opt-out of our marketing communications as described in the Opt-out of marketing communications section, below.

Compliance and protection. We may use your personal information to:

  • Comply with applicable laws, lawful requests, andlegal processes, such as to respond to subpoenas or requests from government authorities;
  • Protect our, your, or others’ rights, privacy, safety or peroperty (including by making and defending legal claimes);
  • Audit our internal processes for compliance with legal and contractual requirements and internal policies;
  • Enforce the terms and conditions that govern the CCM; and
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

HOW WE SHARE YOUR INFORMATION

Engooden Health may share your information with the following parties and for the following purposes, and as otherwise described in this Privacy Policy or at the time of collection:

Affiliates. Our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the CCM or our business (such as information technology, hosting, customer relationship management and support, payment processing, email delivery, advertising, marketing, and website analytics, including Google Analytics and Pendo).

Professional advisors. Companies and individuals that provide professional services, such as lawyers, auditors, bankers, accountants, and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate to protect the rights and property of our agents, customers, and others, including to enforce our agreements, policies, and terms of use, and in an emergency to protect the personal safety of Engooden Health, its employees, customers, or any person.

Business transactions. Acquiring and other relevant parties to business transactions (or potential transactions) in connection with or during negotiation of any merger, consolidation, reorganization, financing, acquisition or bankruptcy transaction or proceeding involving sale or transfer of all or a portion of our business or assets of or equity interests in, Engooden Health or our affiliates.

YOUR RIGHTS AND CHOICES

You have the following choices or rights with respect to your personal information:

Access or update your information. If you have registered with the CCM, you may review and update certain account and profile information from the CCM account.

Opt-out of marketing communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email or by contact us. You may continue to receive emails related to the CCM and other non-marketing emails.

Do Not Track. Some internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit: http://www.allaboutdnt.com.

OTHER SITES AND SERVICES

The CCM and our website may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and are not responsible for their actions.

COOKIES POLICY

Like many websites, we and our marketing partners, affiliates, analytics, and service providers use “cookies” to collect information. A cookie is a small data file that we transfer to your computer’s hard disk for record-keeping purposes. We use both persistent cookies that remain on your computer, mobile device, or similar device (such as to save your login password for future logins to the CCM) and session ID cookies, which expire at the end of your browser session. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it may limit your use of certain features or functionality of the CCM. To do this, follow the instructions provided by yoyur browser (usually located within the “Help,” “Tools” or “Edit” facility). Please note that if you set your browser to disable cookies, you may not be able to access certain parts of the website or of the application. Other parts of the website or the application also may not work property. You can find out more information about how to change your browser cookie settings at: www.allaboutcookies.org.

SECURITY

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

PERSONAL HEALTH INFORMATION – HIPAA

For information about how we handle any personal health information in connection with your use of CCM, please refer to the BAA that was included as part of your contract.

CONTACT US

If you have any questions about this privacy policy or any other aspects of your privacy with respect to Engooden Health, please contact us at: Engooden Health, Attn: Privacy Officer, 945 Concord Street, Unit 714, Framingham, MA 01701, or at: privacy@engooden.com

California Residents. Pursuant to California’s Shine the Light law, you have the right to request information regarding how Engooden Health shares your information with third party vendors, if at all, for their marketing purposes. Please use the above contact address to submit a request.

UPDATES TO THIS PRIVACY POLICY

Engooden Health reserves the right to make periodic updates and revisions to this Privacy Policy. Any changes will be posted on this page. Please check this page to review whether any changes have been made to the policy.