Privacy Policy
Introduction
Easy Health Medical Solutions, P.C. (on behalf of itself, its management services organization, and its affiliated entities, collectively “Easy Health”, “we”,“our” or “us”) handles your personal information when you:
· Visit our websites at www.easyhealthmedical.com and related pages (“Site”).
· Inquire about our value-based care professional services (the “Professional Services”).
· Sign up as a patient of our clinical services (the “Clinical Services”).
· Contact us or otherwise provide uswith personal information.
The HIPAA Notice of Privacy Practices (“HIPAA Notice”) describes how Easy Health handles your health information when you receive Clinical Services from our healthcare providers. Please refer to the HIPAA Notice for additional details on patient privacy rights.
Easy Health’s Professional Services and Clinical Services are collectively referred to as the “Services.” The Site and Services are collectively referred to as the “Platform”.
IF YOU ARE CALIFORNIA RESIDENT: If you are a resident of California,this entire Privacy Policy applies to you. However, please also see the sectiontitled AdditionalInformation for California Residents below, which will inform you indetail about our information collection practices and your specific rights.
We recommend that you read this Privacy Policy and, where applicable, the HIPAA Notice, carefully as it provides important information about your personal information. It also tells you about your rights under the law. If, after reviewing this Privacy Policy or HIPAA Notice, you have any questions or concerns, please send us an email to privacy@joineasyhealth.com.
Your access to and use of the Platform is subject to our Terms of Service , which define some of the terms used throughout this Privacy Policy. Please make sure that you have carefully read and understand the Terms of Service before you use our Platform.By using our Platform, you accept the Terms of Service and accept our privacy practices described in this Privacy Policy.
CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will post our updated Privacy Policy on the Site, and for a reasonable period of time we will post notice of the change such that it is visible to visitors after the change is posted. By your continued use of the Platform, you will be deemed to consent to the terms of the revised Privacy Policy.
WHAT PERSONAL INFORMATION DO WE COLLECT?
As used in this Privacy Policy, “personal information “means any information about an individual from which that person may be identified.Personal Information includes obvious things, like your name, telephone number, email address and street address, as well as less obvious things like your IP address, device ID and location information. Personal information does not, however, include information from which the identity of an individual has been definitively removed (also known as anonymous or anonymized data).
In order to provide the Platform and Services, we collect various types of information. We collect personal information directly from you when you provide it to us, such as when you obtain medical services or otherwise communicate with us verbally or in writing. We also may collect information indirectly, such as through automated technologies (e.g., cookies).As well, we may receive your personal information from affiliate partners that you provided your information to directly.
PERSONAL INFORMATION YOU PROVIDE TO US
General Inquiries
You can generally visit the Platform without having to submit any personal information about yourself to us. However, if you require more information about our Services, you may contact us via email, telephone or otherwise, in which case we will collect your name and email address, as well as any other information that you submit to us via email.
Clinical Services
If you wish to obtain Clinical Services from our practice group, you may be required to provide the following information:
· Full name
· Email address
· Phone number
· Address
· Age
· Gender
· Health plan information
· Other health information
Protected health information will be handled in accordance with all applicable laws, including the Health InsurancePortability and Accountability Act (“HIPAA”), and protected health information shall be subject to the HIPAA Notice.
PERSONAL INFORMATION WE COLLECT INDIRECTLY
Automatically-Collected Information
When you visit our Site, we (or our authorized service providers) automatically collect information about the computer or devices(including mobile devices) you use to access the Platform, and your interactions with the Platform, such as through cookies and other automated technologies.For example, we may collect and store information such as your browser type, IP address, language, operating system, location of your wireless device (e.g.,latitude and longitude), the state or country from which you accessed the Platform, unique device identifier, the pages you view, length of time spent on pages, the manner in which you use the Platform (e.g., the content you access, view, click on, search for etc.), the date and time of your visit, the websites you visited immediately before and after visiting the Platform, error logs, and other hardware and software information, as well as other geographic and demographic information.
We may use cookies and similar tools, to assist in collecting this information, as further explained below. We may use this information to formulate statistical models about use of the Platform, enhance the Platform for our users, and provide you with information about new opportunities, and tailored content, advertising, marketing and as otherwise discussed in this Privacy Policy.
For more information about our use of cookies and similar technologies, please see Cookies and Similar Technologies below.
Location Information
We or our authorized third–party service providers also collect broad geographic location (e.g., country or city-level location) based upon IP address, in order to determine which services are available in your area and to guide marketing strategies.
Please check your specific browser or device settings to disable location services.
ThirdParties
We may collect personal information from third parties, such as our service providers, in connection with and in order to facilitate a transaction.
COOKIES AND SIMILAR TECHNOLOGIES
What are Cookies, Pixels and Local Storage?
The Site uses “cookie” technology and similar online tools, such as web beacons and web pixels. “Cookies” are small files that a website stores on a user’s computer or device and through which personal information may be collected. The Site use cookies for various purposes, including to keep the information you enter on multiple pages together.
Some cookies are first-party cookies – meaning our cookies –and others are third-party cookies, meaning that they are placed on the Site by authorized third parties, such as Google. Most web browsers automatically accept cookies, but you may set your browser to block certain cookies (consult the instructions for your particular browser on how to do this). Please note that if you decide to block cookies, this may interfere with your ability to perform certain transactions, use certain functionality, and access certain content on the Site.
We use “session” cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the Site and to limit the amount of redundant data that is downloaded during a single session.We also use “persistent” cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our Site.
Generally speaking, technologies that work like cookies include “pixels”, which many websites use to learn whether you’ve interacted with certain web or email content, and “local storage”, an industry-standard technology that allows a website or application to store information locally on your computer or mobile device.
Some of the cookies or similar technologies that may be use dare “essential” for the Site to function, while other are “functional” in that they allow sites to add additional functionality. Other cookies or similar technologies help us improve our Site and measure audiences through analytics, including via Google Analytics and Hotjar, as further explained below.
Your Choices
Most web and mobile device browsers automatically accept cookies, but if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. Some browser manufacturers provide comprehensive help relating to cookie management in their products. Please see your web browser provider’s settings for more information.
You can also learn more about cookies by visiting www.allaboutcookies.org, which includes additional useful information on cookies and how to block cookies using different types of browsers or mobile devices.
Please note, however, that by blocking or deleting all cookies used on the Site, you may not be able to take full advantage of the Site and you may not be able to properly log on to the Site. In addition, we cannot control how third parties track you across the Internet, irrespective of our activity.
Analytics
The Site uses Google Analytics, a service that drops cookies and/or similar technologies to collect and store information about your device and use of the Site. We use Google Analytics to calculate visitor, session and campaign data for analytics reports.
You can read Google’s privacy policy here. You can opt-out from being tracked by Google Analytics on the Platform in a particular browser on a particular device by downloading and installing the Google Analytics Opt-out BrowserAdd-on for that browser, which is available here.
SOCIAL MEDIA AND PLUGINS
Our social media accounts may enable us to collect information from you when you interact with our accounts. We also have social plug-ins on our Site and may include icons that allow you to interact with third-party social networks such as LinkedIn and Twitter. The third-party social plugins generally set a cookie when your browser creates a connection to the servers of such social networks and may transmit your personal information to the social networks. Your use of these social plugins, and your use of the products offered by these social networks, is subject to the privacy policies of the third-party social networks.
HOW WE USE YOUR INFORMATION
We will use your information for the purpose for which you provided it or for which we collected it. We use your information to:
· Provide the Services and maintain theSite
· Respond to your inquiries and communicate with you
· Better understand how our Platform is used, and what Services users may be interested in
· Improve and enhance your experience with the Platform, including the content and general administration of thePlatform
· Market or advertise new products andServices to you
· Retain records as may be required fortax, legal and financial purposes
· Provide information to regulatory bodies when legally required, and only as outlined in this Privacy Policy
· Comply with the law.
DO NOT TRACK SIGNALS
We do not currently respond to “Do Not Track” signals.
DISCLOSURE OF YOUR INFORMATION
We may share your information in the following ways:
We may share information about you with the following types of companies:
o Health plans, physicians, and other entities involved in the provision of medical care;
o Companies that perform services on our behalf, such as consultants, business process outsourcing providers, website hosting services, communication tools, or third-party content providers; and
o Analytics partners, including behavior analytics services.
In some cases, these third parties or service providers collect information directly from you via the Platform.
- We may share your information with any person or entity where we believe in good faith that such disclosure is necessary or otherwise appropriate to: (a) comply with the law or in response to a valid subpoena, court order, government request, or other valid legal process; (b) produce relevant documents or information in connection with litigation, arbitration, mediation, adjudication, government or internal investigations, or other legal or administrative proceedings; (c) protect the interests, rights, safety, or property of Easy Health or others; or (d) enforce our rights or other contractual obligations.
- We may transfer your personal information to a successor entity in preparation for or upon a merger, consolidation, or other corporate re-organization in which Easy Health participates, or to a purchaser or acquirer of all or substantially all of Easy Health’s business or assets, including a successor in bankruptcy.
- We may share your information with any person or entity when we have your consent, or when you direct us to share your information with a person or entity. This includes authorized representatives.
· We may use and share non-personal information about you or use of the Platform and Services, including any de-identified and aggregated data with third parties without limitation.
SECURITY AND ACCOUNT PROTECTION
We have implemented commercially reasonable physical, administrative, technical, and electronic security measures designed to protect against the loss, misuse, and alteration of your personal information. Despite our efforts, however, no security measures are perfect or impenetrable, and we do not promise that your information will remain secure.
We appreciate your help in safeguarding the integrity of your own and others’ privacy. We encourage you to let us know immediately if you suspect that any personal information you shared with us is being used contrary to this Privacy Policy.
CHILDREN’S INFORMATION
Easy Health’s Platform is not directed toward persons under eighteen (18) years of age. We do not knowingly market to or collect any personal information from children under the age of eighteen (18). If you are under eighteen (18), you are not permitted to submit any personal information to us.
If you are a parent or guardian and believe that we have the personal information of your minor child in our database, please contact us immediately at privacy@joineasyhealth.com to request that we remove such information from our records.
INTERNATIONAL TRANSFERS
We are located in the United States. As such, the Platform andServices are intended for use in the United States and the personal information that we collect is stored on servers located in the United States. This means that your personal information will be collected, processed and stored in theUnited States, which may have data protection laws that are different from (and sometimes less protective than) the laws of your country or region.
By sending us personal information, you agree and consent to the processing of your personal information in the United States, which may not offer an equivalent level of protection to that required in other countries(particularly the European Union), and to the processing of that information by us on servers located in the United States, as described in this Privacy Policy.
YOUR RIGHTS
You may opt out of further communications by sending an email to privacy@joineeasyhealth.com.
Where provided by state law, you may have additional rights including requests to: (1) confirm whether we are processing personal data and access any applicable data; (2) correct inaccuracies, taking into account the nature of the personal data and the purposes of the processing of the personal data; (3) delete personal data provided by or obtained about the consumer; and(4) provide a copy of the personal data that the consumer previously provided to the controller in a portable and, to the extent technically feasible, readily usable format that allows the consumer to transmit the data to another controller without hindrance, where the processing is carried out by automated means; an
We will respond to all requests in the period of time set forth under applicable law.
CONTACTING US
Should you have any questions about this Privacy Policy, contact us by sending an email to privacy@joineasyhealth.com or writing to us at Easy Health, 8605 Santa MonicaBlvd PMB38903 West Hollywood CA 90069.
Last updated: April 25, 2023
ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS
This Privacy Policy for California Residents (“CaliforniaNotice”) supplements the information contained in the Privacy Policy and applies solely to all visitors, users, and others who reside in the State ofCalifornia (“Consumers”). We have created this California Notice in order to comply with California laws that may apply to the Company in the future.
Information Not Covered by this California Notice
This California Notice does not address or apply to:
· Personal information that we collect about employees, contractors, or job applicants, which is addressed in a separate Notice specific to employees, contractors, or job applicants.
· Other types of personal information that are specifically exempt from California law.
Categories of Personal Information We Collect
Easy Health collects personal information as that term is defined underCalifornia law (CCPA), both online (via the Platform) and offline, such as when you visit our physical locations. Within the last twelve (12)months, Easy Health has collected the following categories of personal information from Consumers:
Category
General Examples
(A) Identifiers
A real name, unique personal identifier, online identifier, Internet Protocol address, or email address.
(B) Personal Information categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))
A name, address or telephone number.
(D) Commercial information
Records of products purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
(F) Internet or other electronic network activity information
Browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.
(G) Geolocation data
Physical location/address.
Personal information does not include:
· Information that is not or cannot reasonably be linked to you
· Publicly available information from government records
· De identified or aggregated Consumer information.
As explained in more detail What Personal Information Do We Collect? Easy Health obtains the categories of personal information listed from the following categories of sources:
· Directly from you, such as when you use our Site, send us an email, give your information to a customer service representative, or otherwise provide information to us.
· Indirectly, for example, from observing your actions on our Site, including through the use of cookies and from affiliate partners.
Use of Personal Information
We may use the personal information we collect for one or more of the following business purposes:
Categories of Information
Business Purpose
(A) Identifiers
(B) Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
(D) Commercial information
(F) Internet or other electronic network activity information
(G) Geolocation data
· Provide the Platform
(A) Identifiers
(B) Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
(D) Commercial information
(F) Internet or other electronic network activity information
(G) Geolocation data
· Respond to your inquiries and communicate with you.
(A) Identifiers
(D) Commercial information
(F) Internet or other electronic network activity information
(G) Geolocation data
· Better understand how our Platform is used, and what Services users may be interested in.
· Improve and enhance your experience with the Platform and Services, including the content and general administration of the Platform.
(A) Identifiers
(B) Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
(D) Commercial information
(F) Internet or other electronic network activity information
(G) Geolocation data
· Market or advertise new products and Services to you.
(A) Identifiers
(B) Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
(D) Commercial information
(G) Geolocation data
· Retain records as may be required, for instance for legal and financial purposes.
(A) Identifiers
(B) Personal Information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
(D) Commercial information
(F) Internet or other electronic network activity information
(G) Geolocation data
· In the event of a merger, acquisition, bankruptcy or other sale or transfer.
Any category of personal information as may be required and only as outlined in this Privacy Policy
· To provide information to regulatory bodies when legally required, or otherwise comply with the law.
Disclosure of Personal Information to Service Providers
Easy Health may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the services for us.
We share your personal information with certain categories of service providers who assist us in providing our Platform and Services and with our business.
Your Rights and Choices
California law provides Consumers with specific rights regarding their personal information, provided that we are able to verify their identities. This section describes your rights and explains how to exercise those rights.
Access and Data Portability Rights
You have the right to request that Easy Health disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. Once we receive your request and verify your identity, we will disclose to you:
· The categories of personal information we collected about you;
· The categories of sources for the personal information we collected about you;
· Our business or commercial purpose for collecting or selling that personal information;
· The categories of third parties with whom we share that personal information; and
· The specific pieces of personal information we collected about you (also called a data portability request).
We may withhold certain information as permitted or required under California law. If reasonably feasible, we will provide the information in a portable format.
Deletion Request
You have the right to request that Easy Health delete your personal information, subject to certain exceptions. Once we receive your request and verify your identity, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Exercising Your Rights
Only you, or a person that you authorize to act on your behalf, may make a verifiable Consumer request related to your personal information. You may also make a verifiable Consumer request on behalf of your minor child.
An authorized agent is a natural person or a business entity registered with the Secretary of State that a Consumer has authorized to act on his or her behalf. When a Consumer uses an authorized agent to submit a request to know or a request to delete, Easy Health will require that theConsumer provide the authorized agent written permission to do so and verify their own identity directly with Easy Health, unless the Consumer has provided the authorized agent with a valid power of attorney. Easy Health may deny are quest from an agent that does not submit proof that they have been authorized by the Consumer to act on his or her behalf.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable Consumer request to us by sending us an email at:
· privacy@joineasyhealth.com
· 1-877-880-4693
The verifiable Consumer request must:
· Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
· Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable Consumer request does not require you to create an account with us
Response Timing and Format
We endeavor to respond to a verifiableConsumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
We do not charge a fee to process or respond to your verifiable Consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination and Notice of Financial Incentives
We will not discriminate against you in a manner prohibited by California law because you exercise your rights. Please note that to use our Services, we do require he collection of your personal information, for example to sign up or in order to complete a paid transaction. While you may request to delete your personal information, such deletions may affect Easy Health’s ability to offer the Services.
Questions
If you have any questions regarding this California Notice, please contact Easy Health at info@joineasyhealth.com.
