Privacy policy

Privacy Policy

Last Updated: March 28, 2019

This Privacy Policy (the “Policy“) describes how we at Healthdom handle information collected from users of our website (www.healthcom.com) and mobile application (collectively, the “Platform“). By using the Platform, you agree to the terms of this Privacy Policy, so please do not use the Platform if you do not agree with these terms.  

We may update this Privacy Policy at any time. Any changes to the Policy will become effective upon the date of our posting of the revised Policy on the Platform. If you use the Platform following the effective date of the revised Policy, you will be deemed to have accepted the Policy’s updated terms.

1. What Types of Information Does Healthdom Collect?
Healthdom gathers different types of information from Platform users depending on their interactions with us. Some of this information is collected automatically by the Platform when you use it; other information you provide at your discretion, as described below.

a. Information Automatically Collected When You Visit Our Platform. The Platform automatically collects information from users of the Platform, which we refer to here as “Usage Information.” This information is “passively” collected through browser navigational tools, such as cookies, that recognize your IP address — the Internet Protocol address of the computer or device that you use to access the Platform. We notify first-time Platform visitors at the time of their first visit that we use cookies. A cookie is a small data file that a website transfers to a user’s hard drive when a user visits the website. A cookie file can contain information such as a unique ID that the website uses to track the pages visited. You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. However, refusing a cookie may in some cases preclude you from using, or negatively affect the display or function of, our Platform or certain areas or features of the Platform. To learn more about cookies, please visit AllAboutCookies.org.
We may also use other tools to track your usage of the Platform, such as “pixel tags,” “web beacons,” “clear GIFs” or similar technologies. All of these tools, as used by Healthdom, are means through which we can gain an understanding of your and other Platform users’ preferences so that we can better design and otherwise improve our Platform to accommodate those preferences. Currently, the Platform does not respond to a “Do-Not-Track” signal from Platform users.

b. Information Actively Provided By Platform Users. The Platform is designed to interact with users who will provide information about themselves, primarily as relevant to their health. We refer to this information as Personal Information, as it is directly related to you as an individual. 

When you visit the Platform, you will have an opportunity to complete a health assessment survey. The survey asks questions about, among other things, your birthdate, gender, ethnicity, address, medical history, diet, weight, exercise, sleep, and various other factors relevant to your health. We do not save this information (your “Profile”) unless you decide you would like to create an account with us.

To create an account, you must provide your name, email address and a password. We offer you the opportunity to import this information from your Facebook or Google account, if you have one. You may do this by clicking on either the “Sign in with Facebook” or the “Sign in with Google” banner on the account-creation page. Once you click on either of these banners, Healthdom will collect from Facebook or Google, respectively, the following information about you: first name, last name, email address, profile picture (if any), and time zone.

Based on the information you provide to create your Profile, the Platform may invite you to pursue certain tests, such as basic blood assay tests. If you decide to undertake those tests, we will collect on your behalf the results of those tests from the laboratory that performs them. 

If you subscribe to receive enhanced services or features for which payment is required, we may collect your credit or debit card information as needed to process your payment. 

If you use a fitness tracking device or a mobile phone collecting behavioral data, and seek to add that data to your information on the Platform, we provide a means for you to upload the fitness tracker data, which may include Personal Information, to the Platform. We also may provide you with the option to upload to the Platform electronic medical records to which you have access through your health care providers. These uploads are additional means by which we may collect your Personal Information.

2. How Does Healthdom Use the Information Collected Through the Platform and Services?

a. Usage Information. As noted, we use Usage Information to help us improve the Platform, such as by analyzing Platform user trends, including usage of certain pages or functions on the Platform.

b. Personal Information. We use the Personal Information we collect for any or all of the following purposes:

i. To Provide You With Health-Related Suggestions. We use the Personal Information we collect from you to analyze, based on algorithmic data we have compiled and created, how your health might benefit from certain activities and choices.

ii. Fulfillment of Requests. We will use Personal Information about you to fulfill your requests, including to facilitate your payments for use of the Platform, and to provide you with information you may request, including doctor appointment dates and reminders, test order confirmations, and test results.

iii. Administrative Communications. We will use your Personal Information to send you updates and notices related to the Platform, such as changes to our terms, conditions, and policies and/or other administrative information. Because this information may be important, you may not opt out of receiving such communications

iv. Other Communications. We may use your Personal Information to inform you of products, programs, services and surveys that we believe may be of interest to you. We will not use the data gathered from the HealthKit or CareKit API may not be used for advertising or other use-based data mining other than improving health.

v. Internal Business Purposes. We may use Personal Information about you for our internal business purposes, such as audits, developing new products and expanding our Platform’s services, enhancing the design and functionality of the Platform, and determining the effectiveness of our promotional campaigns. This may include combining your Personal Information with that of other users so that it is aggregated and no longer identifiable to you or the other users, and analyzing the combined data to infer statistical relationships, which analyses might be used to form certain medical or behavioral hypotheses, both by us or others.

3. With Whom Does Healthdom Share Personal Information Collected Through the Platform and Services?

a. Health Care Providers. Healthdom is not a medical provider, but coordinates with health care providers in order to enable users to obtain orders for tests for health factors that can provide the user with more information on how best to manage their health. For users that seek to undergo such tests, Healthdom provides the health care providers in its network with the users’ Personal Information needed to assess the need for and to order the relevant tests.

b. Service Providers. We may share Personal Information with unaffiliated third parties who provide us with services, such as the designer and administrator of the Platform, our payment processing vendors, and others who assist us with ordering procedures, technology, data analysis, or similar services.

c. Operational Partners. Healthdom has partnered and may in the future partner with selected organizations whose technologies, experience, services and other assets can enhance the benefits of the Platform for its users. Where such partners play an integral role in the operation of the Platform, they may have access to users’ Personal Information. Any such partners will be subject to strict requirements to protect the privacy and security of the Personal Information to which they have access.

d. Acquirers or Assignees. In the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Healthdom or its assets, we may transfer any and all information that we collect from Platform users, including Personal Information, to the acquiring party or assignee.

e. Entities Entitled Under Law. We may disclose Personal Information we collect to others as we believe to be appropriate in the following circumstances: (i) when required by applicable law, including laws outside your country of residence; (ii) to comply with legal process (iii) to respond to requests from public and government authorities; (iv) to enforce the terms and conditions for use of the Platform and Services, including this Privacy Policy; (v) to protect and defend our rights and property; (vi) to protect the legitimate interests of Healthdom or others; and (vii) to permit us to pursue available remedies or limit the damages that we may sustain. We have no obligation to notify you of such disclosures, except as required by applicable law.

4. How Can You Manage Personal Information We Collect?

a. Updating, Correcting, or Deleting Personal Information. If you would like to correct, update, or delete Personal Information you have provided to Healthdom, you may log on to your account on the Platform to access and amend the information or you may contact us as indicated in Section 9 below (“Contacting Us”). For your protection, we may need to verify your identity before implementing your request. We will endeavor to comply with your request as soon as reasonably practicable. Please note that we are not responsible for correcting, updating or deleting any information in the databases of third parties.

b. Our Communications With You. If you no longer wish to receive promotional information from us, you may opt-out of receiving such information by following the “unsubscribe” directions provided in messages we have sent to you, or by changing your preference settings on any page on the Platform where you consented to receive such communications. We will endeavor to comply with your request as soon as reasonably practicable.

5. How Does Healthdom Protect and Maintain Personal Information Collected Through the Platform?

a. Security. We use reasonable organizational, technical and administrative measures to help protect against the loss, misuse and alteration of the information under our control, and we have taken steps to make our system security consistent with the HIPAA security standards. However, you should be aware that no data transmission over the Internet, and no data storage system, can be guaranteed to be 100 percent secure. You should be mindful of security risks whenever you opt for electronic transmission of information you consider confidential.

b. Data Integrity and Retention. We will retain Personal Information for the period necessary to fulfill the purposes outlined in this Policy or Healthdom’s data retention policies unless a longer retention period is required by law.

c. Other Websites. From time to time, the Platform may contain links to websites operated by parties not affiliated with Healthdom. Any such websites are not under Healthdom’s control and we are not responsible for the privacy practices of any such unaffiliated parties or the operations of their websites. If you provide any Personal Information through any such third-party website, your transaction will occur on such third party’s website (not any of the Platform) and the Personal Information you provide will be collected by, and controlled by the privacy policy of, that third party. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, as they are not related to this Privacy Policy.

6. Collection and Use of Personal Information by Others. We do not allow others to collect the Personal Information of visitors to our Platform by tracking the usage of our Platform and other websites over time. We do not knowingly share Personal Information with third parties for their own marketing purposes.

7. Use and Retention of Aggregated Information. As noted, we may use your Personal Information to created aggregated information by combining your Personal Information with that of others. The aggregated information we create is not identifiable to you or those others. We may retain, use and disclose this aggregated information without limitation for our or others’ legitimate business purposes.

8. Use of the Platform by Children. This Platform are not directed to children under the age of eighteen (18), and we do not knowingly collect Personal Information from any children under age 18. If you are under age 13, please do not submit any Personal Information to us.

9. International Transfers of Information. We store the Personal Information we collect on servers in the United States, and we use servers outside the United States to process some Personal Information. By using the Platform and Services, you are deemed to understand and unambiguously consent to the collection and processing of your Personal Information in the United States and elsewhere.

10. Contacting Us. If you have any questions or concerns related to this Privacy Policy or the information practices of the Platform or Services, you may contact us:
– By e-mail: info@www.healthdom.com
– By mail: Healthdom, 650 California Street, San Francisco, CA 94018