1. IMPORTANT INFORMATION AND WHO WE ARE
Via our Sites and Apps, AZOVA provides a platform for healthcare professionals and pharmacists to build digital health businesses, including telemedicine clinics and other digital clinics and to conduct e-commerce transactions and a platform for patients to obtain in-office, e-visit, house call, mobile or onsite clinic consultations from any healthcare professional or pharmacist, and to access laboratory, vaccination, imaging center or other medical products and services and to upload, request and share health information (collectively known as the “Services”)
Unless you are advised otherwise, AZOVA Inc. is the data controller for the Application and in relation to information you provide when using our Services, and is the company responsible for processing your data.
Children Under 18
2. PERSONAL INFORMATION WE COLLECT
When you contact us through the Application, correspond with us or otherwise use our services, we may collect a range of personal data:
We use different methods to collect data from and about you including through:
3. AUTOMATIC DATA COLLECTION
We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:
Generally, we do not rely on consent as a legal basis for processing your personal data, other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time.
We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
|Purpose/Activity||Type of Data||Lawful basis for processing including basis of legitimate interest|
|To respond to an expression of interest in our services.||a) Identity
(d) Marketing and Communications
|Necessary for our legitimate interests (to respond to potential sales enquiries).|
|To register an account on the Application.||(a) Identity
|Performance of a contract.|
|To provide you with medical services.||(a) Identity
|Performance of a contract.|
|To provide reports to your doctor and other medical professionals.||(a) Identity
|Performance of a contract.|
|To report concerns about your vital interests to other medical professionals.||(a) Identity
|To protect your vital interests.|
|To administer and protect our business, services and the Application, including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data, co-operate with regulators or comply with a legal obligation, and deal with disputes and legal claims.||(a) Identity
|(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise).
(b) Necessary to comply with a legal obligation.
|To use data analytics to improve our Application, products/services, marketing, customer relationships and experiences.||(a) Technical
|Necessary for our legitimate interests (to define types of customers for our products and services, to keep our Website or App updated and relevant, to develop our business and to inform our marketing strategy).|
|To make suggestions and recommendations to you about goods or services that may be of interest to you.||(a) Identity
|Necessary for our legitimate interests (to develop our products/services and grow our business).|
When using the Application, your personal information will be visible to all healthcare providers with whom you register for an appointment, send a secure message to or with whom you interact or share your personal information with in any way on the Application. Your vaccination history and your medical history will be shared with all healthcare professionals or pharmacists with whom you register for an appointment and that, if you register for any service with a school on the Application, your vaccination records will be shared with that school. Your personal information may be shared with healthcare professionals located in other states and jurisdictions for purposes of virtual consults and medical record sharing as is necessary to carry out patient care on your behalf. If your health care provider discloses your PHI, he or she will obtain your consent for such disclosure, to the extent required by state law.
You may send an invitation to join AZOVA’s platform to family members, friends, healthcare professionals, pharmacists. You may also send an invitation to be your “health helper” by means of the Application, so that such supporter will receive alerts regarding your compliance with your health goals, recommended treatment plans or medication regime. By sending such invitation, you represent that you have the right to contact the health helpers and that you consent to our sending your personal information and your health information and medication adhe
4. PERSONAL INFORMATION WE COLLECT BY AUTOMATED MEANS
Sites: We collect information about your use of our Sites (IP address, type of computing or mobile device you use, language of your operating system, the Internet browser you are using, geo-location and use of the Sites) through the use of various technologies, such as cookies, web beacons and navigational data collection (log files, server logs, clickstream).
Also, you are free to delete any existing cookies at any time. If you delete or disable cookies from our Sites, some parts or functions of the Sites may not work properly for you.
Our Sites may use analytics to create statistical reports. These reports would tell us, for example, how many users visited our Sites, what pages have been browsed, and from what geographic regions users visited the Sites. The information collected through the use of analytics may include, for example, your IP address, the website from which you visited us, the type of device you used and your search query that led you to the Sites. Your IP address is masked on our systems and will only be used on a need-to-know basis to resolve technical issues, to administer our Sites and to understand visitor preferences. Traffic information on our Sites is accessed only by authorized personnel. We do not use any of this information to directly identify visitors. We process personal information for these purposes because we have a legitimate interest in understanding how our Sites are used.
6. INFORMATION WE SHARE
Additionally, we may share your information with service providers we have retained to perform services on our behalf (e.g., laboratories, prescription drug providers, and other clinically relevant companies), that help us process orders, and fulfil and deliver products and services that you purchase from or through us. We may use third parties to help host our Application, send out email updates about the Application, remove repetitive information from our user lists, and process payments. These service providers are not authorized by us to use or disclose the information except as necessary to perform services on our behalf or to comply with legal requirements.
In addition, we may disclose information about you (i) if we are required to do so by law or pursuant to legal process, such as under the Health Insurance Portability Act (“HIPAA”) (for example, we may disclose your information as necessary to comply with an authorized civil, criminal or regulatory investigation), (ii) in response to a request from law enforcement authorities or other government officials, or (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity.
7. HEALTHCARE PRIVACY AND SECURITY RULES
8. LINKS TO OTHER SITES
9. HOW WE PROTECT PERSONAL INFORMATION
We maintain administrative, technical and physical safeguards for the Application designed to protect against loss, misuse or unauthorized access, disclosure, alteration or destruction of the personal information we collect through our Application. However, you should keep in mind that no Internet transmission is ever completely secure. We maintain a high level of data protection via safeguards such as data backup, audit controls, access controls, and some data encryption. We use account information in a password-protected environment as a security measure to protect your data. Our Application and Services use industry standard SSL encryption to enhance the security of electronic data transmissions.
In addition, we urge you to take precautionary measures in maintaining the integrity of your data. Please be responsible in making sure no one can see or has access to your personal account and login/password information. If you use a public computer, e.g., at a library or a university, always remember to logout of the Application. If you use our Application or Services through your employer’s computer network or through a potentially non-secure internet connection, such use is at your own risk. We are not responsible for your handling, sharing, re-sharing and/or distribution of your personal or personal health information.
10. INFORMATION WE TRANSFER
11. HOW LONG WE KEEP INFORMATION
12. YOUR RIGHTS
Subject to applicable law, you have the right to request access to and rectification of the personal information we maintain about you, to request the restriction of the processing of your personal information, or to object to that processing on grounds relating to your particular situation. In addition, you may have the right to request erasure of your personal information in certain circumstances provided by applicable law. Subject to applicable law, where technically feasible, upon written request and verifiable identification, we will provide you with a copy of your personal information in a structured, commonly used, machine-readable format.
To exercise these rights, please contact us as indicated below. Depending upon where you are located, for example in the European Union, you may lodge a complaint with a data protection authority if you are not satisfied with our response. We would, however, appreciate the opportunity to deal with your concerns before you approach a data protection authority, so please contact us in the first instance.
You can close your online patient account by sending an e-mail message to request account closure to firstname.lastname@example.org. You will no longer have access to any of the information on your AZOVA account. AZOVA will not be able to restore access to this account in any way. Any person or provider with whom you have communicated or shared information via your AZOVA account or with whom you have had an appointment on AZOVA will continue to have access to your records, communication and data. If you would like to request that the information you have shared with any healthcare professional be deleted, you must contact that healthcare professional directly and make the request.
13. CALIFORNIA PRIVACY RIGHTS
Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses with which we shared customer information for the immediately prior calendar. To obtain this information, please email us with “Request for California Privacy Information” on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.
15. REPRESENTATION FOR DATA SUBJECTS IN THE EU
We value your privacy and your rights as a data subject and have therefore appointed Prighter as our privacy representative and your point of contact. Prighter gives you an easy way to exercise your privacy-related rights (e.g. requests to access or erase personal data).
16. HOW TO CONTACT US
Full name of legal entity: AZOVA Inc.
Email address: support@AZOVAhealth.com or email@example.com
Postal address: 144 S. Main Street, Alpine, UT 84004