Mobile App Privacy Policy

Introduction

American TrueCare, Inc. (“Company” or “We”) respects your privacy and are committed to protecting it through our compliance with this policy. This policy describes:

  • The types of information we may collect or that you may provide when you purchase, download, install, register with, access, or use the TrueCare Application (the “App”) as a free App.
  • Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies only to information we collect in this App and other electronic communications sent through or in connection with this App, including push notifications received for check-in through external Bluetooth proximity beacons.

This policy DOES NOT apply to information that:

  • We collect offline or on any other Company apps or websites, including websites you may access through the App.
  • You provide to or is collected by any third party (see Third-Party Information Collection).

Our websites and apps and these other third parties may have their own privacy policies, which we encourage you to read before providing information on or through them.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use this App. By downloading, registering with, or using this App, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this App after we revise this policy means you accept those changes, so please check the policy periodically for updates.

Children Under the Age of 16

The App is not intended for children under 16 years of age, and we do not knowingly collect personal information from children under 16. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at operations@truecareccm.com.

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see California Privacy Rights for more information.

Information We Collect and How We Collect It

We collect information from and about users of our App:

  • Directly from you when you provide it to us.
  • Automatically when you use the App.

Information You Provide to Us

When you download, register with, or use this App, we may ask you provide information:

  • By which you may be personally identified, such as name, geographic subdivision, telephone numbers, fax numbers, email addresses, dates (birth dates, etc.), full-face photographs or images, healthcare record numbers, account numbers, device identifiers, certificate or license numbers, insurance card images, device OS details and device name, biometric identifiers, and any other identifier by which you may be contacted online or offline. (“Personal Information”).
  • That is about you but individually does not identify you.

This information includes:

  • Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App, subscribing to our service, posting material, and requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with the App.
  • Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through the App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App.
  • Your search queries on the App.
  • Records and copies of messages sent through the App.

Automatic Information Collection and Tracking

When you download, access, and use the App, it may use technology to automatically collect:

  • Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, vitals, logs, and other communication data and the resources that you access and use on or through the App and our devices.
  • Device Information. We may collect information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
  • Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
  • Location Information. This App does not collect real-time information about the location of your device.
  • If you do not want us to collect this information do not download the App or delete it from your device.We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).

Information Collection and Tracking Technologies

The technologies we use for automatic information collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
  • Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

Third-Party Information Collection

When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Your mobile device manufacturer.
  • Payment processing companies.
  • Location technologies provider.
  • Cloud Platform providers.

These third parties may use tracking technologies to collect information about you when you use this app. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information, to:

  • Provide you with the App and its contents, and any other information, products, or services that you request from us.
  • Fulfill any other purpose for which you provide it.
  • Give you notices about your account.
  • Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • Notify you when App updates are available, and of changes to any products or services we offer or provide through it.
  • Make our services and applications better.
  • Continuity of care with your primary care physician

The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our App according to your individual interests.
  • Speed up your searches.
  • Recognize you when you use the App.

We may also use your information to contact you about our own goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at the email provided in this policy. For more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect, or you provide:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about our App users is among the assets transferred.
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email a friend” feature of our Website or App, we will transmit the contents of that email and your email address to the recipients.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
  • To comply with any court order, law, or legal process, including responding to any government or regulatory request.
  • To enforce our rights arising from any contracts entered into between you and us, including the App EULA, and for billing and collection.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies or to alert you when cookies are being sent. This App does not collect real-time information about the location of your device.
  • Promotion by the Company. If you do not want us to use your contact information to promote our own products or services, you can opt-out by emailing us at operations@truecareccm.com.

Accessing and Correcting Your Personal Information

You can review and change your personal information related to demographics by logging into the App and visiting your account profile page.

We cannot delete your personal information except by also deleting your user account. We may not accommodate a raccessequest to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. You may send us an email at operations@truecareccm.com for additional information.

Privacy Notice to California Residents under CCPA:

Under the California Consumer Privacy Act of 2018 (CCPA), California residents are granted consumer rights that we are prepared to uphold upon request:

  • The right to know which personal information is being collected.
  • The right to know if personal data is being sold or shared, and to whom.
  • The right to object to the sale of personal data.
  • The right to access one’s own personal information.
  • The right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.
  • The right to equal service and price, even for consumers who exercise their privacy rights.

Access to Specific Information and Data Portability Rights Under CCPA:

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, 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.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    osales, identifying the personal information categories that each category of recipient purchased; and
    odisclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

HIPAA Notice of Privacy Practices:
The Health Insurance Portability and Accountability Act of 1996 (HIPAA) Privacy Rule allows clients the right to receive a notice that describes how individual health information may be used and/or disclosed and how to acquire access to this information. TrueCare software is fully committed to the spirit and letter of the Health Insurance Portability and Accountability Act of 1996 (HIPAA), including but not limited to the Privacy Rule that was issued pursuant to HIPAA. A major provision of the Privacy Rule is to safeguard sensitive, personal Health information (PHI), and includes individually identifiable health care and demographic data.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

  • Calling us at: (800) 638-1355
  • Emailing us at: operations@truecareccm.com
  • Only you, or someone legally authorized 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. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. 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.
  • 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. However, we do consider requests made through your password-protected account sufficiently verified when the request relates to the personal information associated with that specific account.We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

    Response Timing and Format

  • We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

    Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily usable and should allow you to transmit the information from one entity to another entity without hindrance.

    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.

    Personal Information Sales Opt-Out and Opt-In Rights

    The California Consumer Privacy Act (CCPA) gives residents of the state of California the right to prevent businesses from selling their personal information. We do not sell, rent or otherwise disclose personal information collected by our site to third parties in the ordinary course of business. However, certain third-party providers who perform support activities may have limited access in order to fulfill any transaction associated with user activities within the App.

    Nevertheless, in support of California residents and CCPA, we inform you of your rights if in the future the sale of information is foreseen. We shall update the Privacy Policy for CCPA residents and appropriately informed them of the update. If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We won’t sell the personal information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is at least 13 but not yet 16 years of age or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. We will provide an opt-out and an opt-in option in both cases and a link for you to submit your request. In the event you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back into personal information sales as instructed in the updated policy. You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.

    Non-Discrimination

    We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny your goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.‌Data SecurityWe have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on a console accessible only through authorized user credentials or on our secure servers behind firewalls. Any payment transactions and identifiable and protected personal health information will be encrypted using SSL technology.
    The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

    Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our App. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.

    Changes to Our Privacy Policy

    We may update our privacy policy from time to time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated and notify you by an in-App alert the first time you use the App after we make the change.

    The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have up-to-date active and deliverable contact information for you and for periodically visiting this privacy policy to check for any changes.

    Contact Information

    If you have any questions about this privacy statement, our information handling practices, or any other aspects of your privacy, please send an e-mail to: operations@truecareccm.com or, you may call via our phone number: (800) 638-13