Privacy Policy : Active Wellness 1

Terms of Service

Active Health Technologies LLP Privacy Policy

Active Health Technologies LLP. (“Active Wellness”) knows that you care about how your personal information is used and shared and takes your privacy seriously.

Active Wellness is an e-health platform that creates an ecosystem for patients to connect with our network of affiliated healthcare professionals Providers, Allied Healthcare Professionals, (“Providers”) to obtain online health, wellness, prevention, lifestyle and Chronic Disease Management Advise besides counseling and therapeutic services. “Providers” includes but not limited to doctors, employees, agents, or independent contractors of Providers, ActiveMD Online Care Services, ActiveH Online consumer Services, ActiveLAB Online Test Services, ActiveMED Online Medication Services and Business Associates including but not limited to Active Wellness Pvt. Ltd. “Active Wellness” or the terms “we” or “us” or similar terms refer to Active Health Technologies LLP. Term “You” or “your” or any similar terms refers to you as a user of our Services (defined below).

THIS PRIVACY POLICY IS BOTH AN AGREEMENT HEREBY ENTERED INTO BY YOU AND ACTIVE WELLNESS, AND THE POLICY OF ACTIVE WELLNESS IN MAKING THE SERVICES AVAILABLE TO YOU THROUGH ITS PLATFORM.

1. What We Promise to You.

We respect you for entrusting us with some of your personal and related information, that includes among others your personal health information. As your "Trust PARTNERS IN HEALTH" we are not only committed to the privacy and confidentiality of your information but also safeguarding and protecting it.

Our present Privacy Policy is to inform you on our processes, policies, and procedures regarding the collection, use, and disclosure of your PHI that you may store on our e-health platform through the website, www.activewellness.in (the “Site”).

The Active Wellness e-health platform includes, without limitation, the following services (collectively, the “Services”):

(a) the facilitation of electronic, video or telephonic communications with Providers,

(b) the provision of appointment scheduling and reminders, alerts, claims submission and processing, and other services related but not limited to wellness, prevention, risk & disease management besides both clinic and online counseling by provider and therapeutic and health goals monitoring tracking and escalating compliance gaps to care teams therapy for our registered users that includes but is not limited to consumers, Providers, etc.

This Privacy Policy applies only to information that you provide to us through the use of Services. Unless mentioned otherwise this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service [website link to Terms of Service] (the “Terms”).

By accepting our Privacy Policy at the time of registration, or during your visit to the Site and/or when you consume the Services offered by the platform either directly or through the partner network, you hereby grant your express consent to not only the collection, but also the use and disclosure of your Personal Information (as defined below) in accordance with this Privacy Policy.

The terms “using” and “processing” as used in this Privacy Policy includes information collected using cookies on a computer, and subjecting the information to analysis of all types including what not limited to the use or handling information in any way, including, storing, collecting, evaluating, modifying,using, deleting, combining, disclosing, transferring information within our organization or among our affiliates, disclosing, to the care teams and/or to other Providers both within India or internationally.

2. Collection and Use of Information – In General.

During the use of our Services, we will ask you for certain PHI (Personal Health Identifiers). This is the information about you that can be used to identify or contact you, and information on your use or potential use of the health care & related services (collectively, “Personal Health Information”). Personal Health Information that we might collect would include things like your name, gender, phone number, occupation, hometown, personal interests, credit/debit card or other billing information, your email address and the email and phone numbers & addresses of your contacts, and the postal addresses of home and business , website URLs, insurance/payer data (such as your insurance carrier and insurance plan), certain health information (such as your health care teams (providers) you have seen, reasons for an appointment scheduling with a Treatment Provider, and your medical history), and any other information that you provide when using the Services. The information collected is provided by you voluntarily in free-form text boxes on the Site and through responses to surveys, questionnaires and the like. Using the communications methods such as email, facsimile or letter, any information provided in such communication may be collected as Personal Information.

The main reason for collecting your Personal Information is to provide you a safe, smooth, efficient, and customized and personalized user experience. The collection of Personal Information of the users also enables them to establish a consumer account and their profile that can be used to interact with the Providers and other users through the Site. The healthcare information that we collect is used to create your personalized health profile and allow the running of algorithms to predict potential risk and impending adverse health events. We only collect your Personal Health care Information that allows you easy retrieval at provider offices and a single repository that will act as your medical records repository for your health care journey, and to achieve your health goals. The platform uses the information to create your health profile, some of which is mandatory and partly optional. You always have the option not to provide the same or any, Personal Information by either choosing not to become a registered user of the Services or by skipping the particular feature of the Services that require the Personal Health Information. You can also use some of the Services anonymously, as a visitor but once you become a registered user on the platform, we will ask you to provide Personal Information, such as · Contact and identity information (e.g., phone number and mailing address)

· Health information (e.g., date of birth, past health history, family history, allergies, etc.)

· Insurance and other billing information (e.g., credit card number)

· Other personal information as may be required is indicated (our forms indicate what information is needed, and what information is optional)

You are under no obligation to provide us with this Personal Information. We use your Personal Information to provide the Services and administer your inquiries. You may change some of the information that you provide. Please see “Changing or Deleting Your Information” below for further details.

3. How We Use Your Non-Medical Personal Information.

Some of the Personal Information we collect from you is unrelated to your receipt of counseling, medical advice, servicing medication, laboratory services, home health, and other therapy services through the Services integrated with the portal. The different ways in which your Personal Information is used to include, but are not limited to, the following:

· Enable you to navigate the Services easily

· Troubleshoot technical problems

· Resolve service and billing problems via email or telephone

· Better understand users’ needs and interests

· Bill any amounts due from you

· Personalize your experience and achieve precision care

. Detect and protect us against fraud, error, and other criminal activity

· Enforce our Terms

· Provide you with a system or administrative messages, and as otherwise described to you at the time of collection

· Provide you with further information and offers from us that we believe you may find useful or interesting

. Enable online scheduling and servicing of your healthcare needs and purchases of medical services, medication, consultations and conducting of tests.

If you decide at any time that you no longer want to receive certain communications from us, please follow the unsubscribe instructions provided in any of the communications or select the appropriate option in your user profile. (See “Changing or Deleting Your Information,” below.) You cannot choose to unsubscribe some administrative communications, such as notification of new messages from your Providers or health alerts related to the care management process. To stop receiving these communications, you will require to deactivate your account.

4. How We Use Your Personal Health Information (PHI).

We are dedicated to maintaining the integrity and privacy of your protected health information (“PHI”). PHI is the information about you that may be used to identify you (such as your name, address, or social security number), and that relates to (a) your present, past, or future physical or mental health or condition, (b) the provision of health care to you, or (c) your present, past, or future payment for the provision of health care. In providing these Services, we will receive and create records containing your PHI, and may use it to help you in scheduling the appointments, remind you of upcoming or follow-up appointments, inform you of canceled appointments, manage your health across the wellness care continuum from healthy to diseased states allow Providers to make appointments with other Providers/ care team members on your behalf through the Services, bill amounts due for health care services provided by a Treatment Provider under the Services or the Site, develop and conduct surveys with you to help in providing you better health Services, conduct our management and administrative activities, and otherwise as stated in this Privacy Policy. We may also use your de-identified PHI to run (or authorize third parties to run) statistical research on individual or aggregate health or medical trends. Such research would only use your PHI in an anonymous manner that cannot be tied directly back to you. We are required by law to maintain the privacy and confidentiality of your PHI, and we operate the Services consistent with applicable federal and state laws governing health information privacy and security.

This Privacy Policy describes how we protect your privacy as a general consumer of the Services, not as a patient receiving health advice or consultation through the Services from a Treatment Provider. If you are a patient receiving health advice or consultations through the Services from a Provider, you have other rights concerning the access, use, and disclosure of PHI. For a complete description of a patient’s rights under HIPAA, please refer to your Provider.

5. Log Data.

When you visit the Active Wellness Services, our servers automatically record information that your browser sends whenever you visit a website (“Log Data”). This Log Data includes information such as your computer’s Internet Protocol (“IP”) address, browser type, pages of our website and Services that you visit, the time spent on those pages, or the webpage you were visiting before you came to our Services, information you search for on our Services, access times and dates, and other statistics. We use this information to monitor and analyze use of the Services and for the Services’ technical administration, to increase our Services’ functionality and user-friendliness, and to better tailor it to our visitors’ needs. For example, some of this information is collected so that when you revisit the Services, it will recognize you and provide information appropriate to your interests. Your location data to generate proper alerts and warnings. We also use this information to verify that visitors to the Services meet the criteria required to process their requests.

Generally, this data is collected by the service automatically such as the numbers and frequency of visitors who visit our site and its components and functions, similar to ratings for TV that indicate how many people watched a particular show. Active Wellness uses this data in aggregate form. It is a statistical measure, and is not used in a manner that would identify you personally. Aggregate data enables us to identify frequency with which users use parts of the Site or the Services so that we can improve the Services to meet their needs.

6. Cookies.

We also 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 cookies for two purposes. First, we may utilize persistent cookies to save your user credentials for future logins to the Services. Second, we may utilize session ID cookies to enable certain features of the Services, to better understand how you interact with the Services and to monitor aggregate usage by users of the Services and web traffic routing on the Services. Unlike persistent cookies, session cookies are deleted from your computer when you log off from the Services and then close your browser. We may work with third parties that place or read cookies on your browser to improve your user experience.

You have the ability to instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit. If you do not accept cookies, however, you may not be able to use all portions or all functionalities being offered.

7. Web Beacons.

We may at a times be using “web beacons” (also known as “clear gifs,” “web bugs,” “1-pixel gifs,” etc.) that allow us to collect non-personal information about your response to our email communications, and for other purposes. Web beacons are tiny images, placed on a Web page or e-mail, that can tell us if you have visited a particular area of the Services. For example, if you have permitted us to send you emails, we may send you an email urging you to use a certain feature of the Services. If you do respond to that email and use that feature, the web beacon will tell us that our email communication with you has been successful. We do not collect any PHI with a web beacon and do not link web beacons with any PHI you have given us.

Because Web beacons are used in conjunction with persistent cookies (described above), if you set your browser to decline or deactivate cookies, Web beacons cannot function.

8. Emails/ SMS.

We may use a third-party vendor to help us manage some of our email /SMS communications with you. While we may supply this vendor with email addresses or phone numbers of those we wish to activate their services and become either registered or paid users for dispatch of communications. Your email address is never used for any purpose other than to communicate with you by the clinical care teams on our or your Treatment Provider's behalf. When you click on any mentioned link in an email, you may temporarily be redirected through one of the vendor’s servers (this process will be invisible to you) which will register that you have clicked on that link, and have visited the Active Wellness Services. We also often receive a confirmation when you open an email from Active Wellness if your computer supports this type of program. Active Wellness uses this confirmation to help us make emails more useful to you.

Secure electronic messaging is always preferred to insecure email, but under specific circumstances, insecure email communication containing PHI may take place between you and Active Wellness.

For your convenience, Active Wellness allows you to choose whether to receive email communications containing PHI. This email communication is not encrypted and may include messages from your Treatment Provider, treatment referrals, appointment reminders, and prescription information.

You should consider that standard email is not a secure means of communication. There is some risk that any PHI contained in the email may be disclosed to, or intercepted, printed, or stored by, unauthorized third parties. Active Wellness cannot ensure the security or confidentiality of messages sent by email.

You will receive email communication from Active Wellness and Providers. If you accept the Privacy Policy, you authorize Active Wellness to send you messages that include PHI, which may include disclosure of risk, disease states, prevention, and mental illness, substance abuse, and sexually transmitted diseases. This authorization indicates you understand and accept the risks involved with insecure email communication of your PHI.

You may always elect not to receive message content containing PHI. In that case, you would instead receive secure notifications of new messages that require you to log in to Active Wellness’s secure site to read message content. We recommend this option if you want to increase the security and confidentiality of your communications on Active Wellness.

Even if you have requested us to send an email containing PHI to you, you may revoke this request by changing this setting at any time on the user registration page, at the bottom of emails from Active Wellness, or in your account profile.

Even if you have permitted us to send emails to you, you may revoke that permission at any time by following the “unsubscribe” information at the bottom of each such email.

9. Messages and Transactions.

Comments or questions sent to us using email or secure messaging forms will be shared with our staff who are most able to address your concerns. These may include business associates such as providers, laboratories, pharmacies. We will archive your messages once we have made our best effort to provide you with a complete and satisfactory response. However, these communications will not become part of your medical record (or other appropriate treatment records) unless and until you use the Services to obtain but not limited to medical, preventive and mental health advice or consultation from a Treatment Provider.

When you use a service on the secure section of the Services to interact directly with the Providers, some information you provide may be documented in your medical record or other appropriate treatment records, and available for use to guide your treatment as a patient.

10. Information Sharing and Disclosure

In terms of our policy, we do not rent, sell, or share Personal Information about you with other people or non-affiliated companies except where we have to provide the Services when we otherwise have your permission, or under the following circumstances:

· Providers/Care team Members. When you use the Site to access health services, you will be required to share your Personal Health Information with a Provider via the Services. By using the Services, you expressly consent to share your PHI with your Provider or care team members, and you understand that all information shared with your Provider or care team is subject to your Provider’s professional and legal duties of responsibility and confidentiality, which Active Wellness does not control. Active Wellness facilitates and increases coordination with care team members and reduce overhead for you, you further authorize the sharing of this information with other Providers on Active Wellness who you elect to contact and/or add to your care team.

· Group Sessions. If you join a group session, any information you provide during the session, which could include posts, audio, and video is shared with the other group participants.

· User Profiles. User profile information, including your name, location, and other information you enter in your profile, may be displayed to your Providers to facilitate user interaction with the Site.

· Communications in Response to User Submissions. As part of the Site and the Services, you will receive communications from Active Wellness and other users via email/SMS/IM and other communications relating to your requests, health services, and all transactions on the system. When you transmit information relating to your mental health service’s needs, Active Wellness and the Providers or care team members you select may send you emails/SMS/IMs and other communications that they deem fit at their sole discretion related to your mental/physical/social health and services related but not limited to wellness, primary prevention, secondary prevention.

· Aggregate Information and Non-Identifying Information. We may at times, share aggregated information that does not include PHI (Personal Health Information ) and we may otherwise disclose deidentified Information and Log Data with third parties for analytical purposes, population analytics that leads to segmentation and stratification, demographic profiling etc. Any aggregated information shared in the above context will not contain your Personal Information and is deindentified.

· Service Providers. Active Wellness may employ third-party companies and individuals to process your payments, facilitate delievery/execution of Services, and to provide the Services on our behalf, or independent of us. Such-related services (include but not limited to, maintenance services, database management, web analytics and improvement of the application features), or to help us in analyzing how our Services are used. These third parties have access to your PHI only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

· Compliance with Laws and Law Enforcement. We cooperate with governments and law enforcement officials and private parties to enforce and comply with the provision of law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, which we believe is necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Active Wellness or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity. This includes, without limitation, exchanging information with Providers and law enforcement in response to Providers’ professional and legal responsibilities.

· Business Transfers. We may sell, transfer license or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy.

PLEASE NOTE THAT ANY INFORMATION, TEXT AND IMAGES THAT YOU POST OR DISCLOSE ON OR THROUGH PUBLIC PORTIONS OF THE SITE, OR ANY OTHER PUBLIC FORUMS, BECOMES PUBLIC INFORMATION AND MAY BE AVAILABLE TO VISITORS TO THE SITE AND/OR SEARCHABLE VIA THE INTERNET. Information regarding your activities in such Services may also be available for view by other users (for example, other users may be able to view a list of all postings you have made in all available forums). We urge you to exercise discretion and caution when deciding to disclose your Personal Information through a forum or otherwise through the Site. ACTIVE WELLNESS IS NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION YOU VOLUNTARILY DISCLOSE THROUGH A FORUM OR OTHERWISE THROUGH THE SITE OR THE SERVICES.

11. Changing or Deleting Your Information.

You may review, correct, update, or delete some portions of your PHI in your registration profile by making the appropriate changes in your user account settings or by contacting us at helpATactivewellnessDOTin. Some Personal Information, such as your responses to online assessments, may not be updateable or deleted once submitted. If you delete certain information required to receive Services, such as a credit card on file, then you may no longer be able to receive Services and your account may be deactivated. If you would like us to remove your records from our system, please contact us and we will attempt to accommodate your request if we do not have any legal obligation to retain the records.

Please note that we may need to retain certain information for recordkeeping purposes, and there may also be residual information that will remain within our databases and other records, which, irrespective of any efforts by us to delete information, will not be removed from them. We also reserve the right, from time to time, to re-contact former users of the Site. Finally, we are not responsible for removing information from the databases of third parties with whom we have already shared Personal Information about you.

12. Security.

We employ administrative, technical, and physical measures designed to safeguard and protect the information under our control from unauthorized access, use, and disclosure. Except for appointment reminders, prescription information and treatment referrals, these measures may include encrypting your communications by utilizing Secure Sockets Layer (“SSL”) software, and using a secured messaging service when we send your Personal Information electronically. In addition, when we collect, access, use, maintain, or disclose your Personal Information, we will do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws, including, without limitation, HIPAA. Except when you have requested us to send emails to you outside of the secure section of our Services and the Site, all electronic PHI will be encrypted when we store it or transmit it, and we will use secure servers that we will back up regularly.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted electronically stored “personal information” (including but not limited to PHI or “medical information” (as defined in applicable state statutes on security breach notification)). To the extent permitted by applicable laws, we will make such disclosures to you via email or conspicuous posting on the Services in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Services by Internet or email, or any electronic storage system, cannot be guaranteed. As a result, although we strive to protect your Personal Information, we cannot ensure or warrant the security of any information you transmit to us through or in connection with the Site or that is stored by us. You acknowledge and agree that any information you transmit through the Site or upload for storage in connection with the Site is so transmitted or stored at your own risk. 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), you must immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below (note that if you choose to notify us via physical mail, this will delay the time it takes for us to respond to the problem). In addition, if you have privacy or data security related questions, please feel free to contact the office identified at the end of this document.

13. Our Employees.

Every one of our employees, whose job might allow them to come into contact with your Personal Information has completed HIPAA training and job-specific training on how to protect and respect your Personal Information, including your Personal Health Information (PHI). We have clear policies in place in the event of a privacy or security concern regarding your Personal Information, so we can react quickly and resolve the issue appropriately. We will limit access to your Personal Information to personnel who have a need to know it for purposes of delivering our Services. All of our personnel must comply with our restrictions on access, use, and disclosure of PHI or face disciplinary action, up to and including termination.

14. International Transfer.

Your information may be stored and maintained in India. If you are located outside India and choose to provide information to us, we may transfer your Personal Information to India servers and process it there. Your submission of such information represents your agreement to that transfer.

15. Links to Other Sites.

We may offer you the chance to access third-party services, content, or products by linking to a third party’s website. If you try to visit an advertiser by “clicking on” a banner ad or other type of advertisements, or click on another third party link, you will be directed to that third party’s website. The fact that we may link to a website or present a banner ad or other type of advertisement is not an authorization, endorsement, or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not handle control over third-party websites. The other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other services follow different rules regarding the use or disclosure of the Personal Information you submit to them. Our Privacy Policy only applies to our Services and we are not responsible for the privacy practices or the content of other websites. You should check the privacy policies of those sites before providing your Personal Information to them.

16. Children.

The Services are not directed to children. We do not knowingly solicit or allow anyone under the age of 13 to participate independently in our Services. We do not knowingly collect personal information from children, except in the context of a Treatment Provider’s preventive, specialty, sick event or second opinion - consultation through the Services when a parent is present and has consented to the treatment. If a parent or guardian becomes aware that his/her child has provided us with Personal Information without their consent, please contact us at helpATactivewellnessDOTin. Access to the Services for dependents including children above the age of 3 or a spouse or domestic partner; is only permitted through the primary account holder’s username and password. Children/Minors are not allowed to use the Services without parental consent and assistance. If we become aware that a user of the Services is under the age of 13 and has provided us with Personal Information without verifiable parental consent, we may delete such information from our files and may deactivate the related account.

17. Agreement and Changes.

By using our Services, you agree to the current Privacy Policy of the Active Wellness and Terms, into which this Privacy Policy is incorporated. We reserve the right, in our sole discretion, to modify, terminate or discontinue the Services or to modify this Privacy Policy at any time. If we modify this Privacy Policy, we will notify you of such changes by posting them on the Services or providing you with notice of the modification. We will also indicate when such terms are effective below. By continuing to access or use the Services after we have posted a modification or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease using the Services.

18. Contacting Us.

We encourage you to contact us at helpATactivewellnessDOTin if you have any queries concerning our Privacy Policy or any concerns about our access, use, or disclosure of your PHI. Please note that email communications maynot necessarily be secure; accordingly, you should not include your credit card information, PHI, or other sensitive information in your email correspondence with us. If you would like to contact us via physical mail, our mailing address is: Active Health Technologies LLP, C-184, Industrial Area, Sector 75, Sahibzada Ajit Singh Nagar, Punjab 160059 Last Revised: Jan 1, 2019