Website and Mobile App Privacy Policy

Website and Mobile App Privacy Policy

Welcome to this website or mobile application, a service of 1819 LLC (“we” “us” or “our”). This Privacy Policy (“Privacy Policy”) explains how we collect and use data when you use this website or mobile application, or any other website, mobile application or interactive features that link to this Privacy Policy.

The 1819 Websites and Services Covered by this Privacy Policy

This Privacy Policy describes the information we collect about you, how we use that information, and how we protect your privacy when you use our website(s), mobile application(s) or other interactive feature(s) (each, a “Service, and collectively, “Services”) that links to this Privacy Policy, including, but not limited to:

1819 LLC or Quil-branded websites, including www.quilhealth.com

1819 LLC or Quil-branded mobile applications

Interactive text messaging features, when you provide your cell phone number to us, or consent to our use of your cell phone number, in a website or mobile application that links to this Privacy Policy.

We are not responsible for the privacy practices of any third party service providers (such as health plans, health care providers, internet service providers or cloud service providers) or other third parties operating websites or applications to which our Services link, unless we have contracted with them to deliver a portion of our Services. The inclusion of a link in any Services to the services provided by another party does not imply that we endorse, or otherwise monitor the privacy practices of that linked third party website or application.

The Categories of Data We Collect When You Use Our Services

We may collect two basic types of information: Personal Information and Non-Personally Identifiable Information.

By “Personal Information,” we mean data that is unique to an individual, such as a name, address, social security number, e-mail address, telephone number, and certain personal device information. Personal Information may also include information known as Protected Health Information (or PHI) which is defined by and managed in accordance with the Health Insurance Portability and Accountability Act of 1996, as amended (including its implementing regulations, “HIPAA”).

By “Non-Personally-Identifiable Information,” we mean information that does not identify you personally, but can provide us with usage data, either individually or in the aggregate. Non-Personally Identifiable Information may include demographic information, anonymized or aggregated information, certain information collected automatically through your device such as web browser information, server log files, cookie technology, pixel tags or beacons, and other technologies, and other non-personally identifiable information collected by us or provided by you.

How We Collect Personal Information

We collect Personal Information when you voluntarily register or create a personal profile with us, request products, services, or information from us or interact with our Services. Some of this Personal Information includes personal device information – such as physical location, IP address, battery information, application activity, data usage, and malware information – which we collect automatically to authenticate you and/or your personal device. When you authorize us to do so, we also collect Personal Information from your health plan and health care providers.

How We Collect Non-Personally Identifiable Information

If you have not registered for an account, then we treat you as a “Visitor” to our websites and/or mobile applications. After you have registered for an account, we treat you as a “Consumer” of our Services. When you visit or interact with our Services as a Visitor, we collect data from you through a number of different automated technologies (“Tracking Technologies”), including:

  • Browser and device information. We may automatically collect certain web browser information. Web browsers collect and store information about the type of device and operating system you are using to access our Services, as well as your device’s media access control (“MAC”) address for facilitating network communications. Accessing this information helps us to establish a secure and consistent connection to you and to customize experience and content when you use our Services.
  • “Cookie” technology. A “cookie” is an element of data that we can send to your web browser when you link to our Services. It is not a computer program and has no ability to read data residing on your computer or instruct it to perform any step or function. By assigning a unique data element to each visitor, we can recognize repeat users, track your usage patterns and better serve you when you return to our Services later. The cookie can also track your usage patterns as you visit other websites across the internet. Your browser may offer you a “Do Not Track” option, which allows you to prevent us from tracking your online activities over time and/or across different websites. Our Services do not support Do Not Track requests at this time, which means that we collect information about your online activity both while you are using a Service and after you leave the Service. However, as we describe below under “How We Share and Disclose Your Personal Information with Others”, we do not share or disclose this information as Personal Information with any third parties.
  • Client-side page tagging. This technology uses code on each web page to write certain information about the page and the visitor to a log when a page is rendered to you by our Applications. “Tagging” does result in a JavaScript program running in your browser, but it is limited to providing information about the page that you are requesting and the configuration of your browser. It will not read any of your data files, nor execute any additional programs. It does not extract any Personal Information about you. You can prevent tagging by disabling JavaScript in your browser, but that may prevent you from using all of our Services’ functions.
  • Tracking pixels or beacons. Tracking pixels (sometimes referred to as “web beacons”) are tiny graphics with a unique identifier that perform a similar function to cookies, except that we include them our websites and mobile applications to help us collect data about user activity. By contrast, cookies are stored on a user’s computer hard drive. Web beacons are embedded invisibly on our web pages and are about the size of the period at the end of this sentence.
  • IP Address. When you subscribe to an Internet Service Provider (ISP), your computing device is assigned an IP Address. We may track and store this address to help us manage security, monitor usage volume and patterns, and to customize experience and content when you use our Services.
  • Device ID. Each mobile or web-accessible device has a unique alpha-numeric device identifier. By tracking and storing the Device ID for your device, our Services are able to recognize repeat users (or households), track usage patterns and better serve you when you return at a later time. It also helps us manage security, and monitor usage volume and patterns.
  • We treat data collected through Tracking Technologies as Non-Identifiable Personal Information if you are Visitor to our Services or when it is aggregated with anonymized data. It only becomes Personal Information if you become a Consumer of our Services. It only becomes PHI if we associate it in our systems with your registered account.

How We Use the Data We Collect

We use Personal Information and Non-Personally-Identifiable Information so that we can:

  • Verify your identity and authenticate access to your account
  • Provide you with the Services
  • Personalize the Services
  • Provide you with customer service and technical support
  • Evaluate and improve our Services
  • Notify you of new Service features or new Services that we provide
  • Notify you of other health services or plan benefits that your health care providers or health plan may provide
  • Bill and collect payment for any applicable fees or charges
  • Take action that helps us to maintain the security of our Services, the privacy of your Personal Information, obey laws and help prevent fraud and abuse
  • Update any hardware, software or other tools that we provide in conjunction with the Services
  • Take actions to enforce our agreements and policies

How We Share and Disclose Information With Others

Our policies for sharing and disclosing your Personal Information with others depends on whether you have registered for an account with any of our Services and whether Non-Identifiable Personal Information has been linked to your Personal Information. If you have not registered for an account, then we treat you as a “Visitor” to our websites and/or mobile applications. After you have registered for an account, we treat you as a “Consumer” of our Services.

Third Party Service Providers. We consider all data we collect from our Services to be confidential. We use third party service providers to assist us in delivering our Services to you, including internet service hosting, technical integration, analytics, customer service, and fraud protection providers. We may share Personal Information we collect about you with these third parties, to the extent necessary for them to provide these services. These companies are acting on our behalf and are required, by contract with us, to keep this information confidential and are only authorized to use it for specific purposes.

Health Plans and Health Care Providers. Our Services may give Consumers the option of exchanging Personal Information with your health plan or healthcare providers. In these cases, we will first request your consent. The consent will:

  1. Identify the entity with which we would exchange Personal Information
  2. Identify the types of information that would be exchange with the other entity
  3. Identify the purposes for exchanging the Personal Information
  4. Include a link to the entity’s applicable privacy policies

You should read these privacy policies to understand how these entities use your Personal Information, as we do not endorse and have no control over how these organizations handle your Personal Information after we disclose it to them.

With Your Authorized Representatives. Our Services may give Consumers the option of designating one or more individuals or organizations to access their Personal Information through the Services. In these cases, we will first request your consent and contact information that we can use to verify the identity of these individuals or organizations. You should only authorize this access to individuals or organizations with whom you have a trusted relationship, as we cannot control these individuals or organizations’ use of your Personal Information or the access credentials that we issue to them with your consent.

Legal Authorities. We may be required by law or legal process to disclose Personal Information to our lawyers, to third parties in connection with litigation, or to law enforcement personnel. We will disclose your Personal Information in compliance with applicable laws. We may provide this information without your consent and without notice to you when we are required to do so in order to comply with a valid legal process such as a subpoena, court order, or search warrant.

Business Transfers. If we enter into a merger, acquisition, or the sale of all or part of our assets, your Personal Information will likely be part of the assets transferred. We will notify you if this happens if we have a means to contact you and we are required to provide you with notice.

What You Can Do With Your Information

If you are a Consumer, you may update your Personal Information (or correct it if it is incorrect) through your account or by contacting us at help@1819health.com. If you’d like us to help you remove your account or any of your Personal Information that we have previously collected through a Service, contacting us at help@1819health.com. We will respond to your request within [30 days]. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so, and why.

Retention of Your Personal Information

We will retain Personal Information for as long as your account is active or as needed to provide you with Services, or as otherwise necessary to help us improve our products and services, comply with our legal and contractual obligations, resolve disputes, and enforce our agreements with you.

Security

We have implemented technical, administrative and physical security measures based on generally accepted industry standards that are designed to protect your information from unauthorized access, disclosure, use and modification. We regularly review our security practices to consider appropriate new technology and methods. However, no method of transmission over the Internet or method of electronic storage is entirely secure. We enter into agreements with our third-party service providers that require them to adhere to privacy and security standards that are no less stringent than our own for the services that we delegate to them.

Children

We do not knowingly collect personal data from anyone under the age of 13 through our Services website, and our Services are not directed to children under the age of 13. Children should always get permission from a parent or legal guardian before sending any information about themselves (such as their names, email addresses, and telephone numbers) to us.

Users Outside of the United States

The Services that link to this Privacy Policy are for users located in the United States. If you use any of our Services from outside of the United States, then by providing us any of your data, you understand and consent to the collection, use, processing, sharing, and disclosure of your personal data as described in this Privacy Policy. You also consent to the transfer of your personal data to the United States for this collection, use, processing, and disclosure. The European Commission has determined that the United States does not provide an adequate level of protection to personal data and it may not offer the same level of data protection as the country in which you reside, whether that country is in the European Economic Area or elsewhere outside of the United States.

Email and Text Messages

Email and SMS text messaging are interactive communications technologies that we may use to deliver our Services. Because of how these technologies operate, email and text messages that we send you or you send us are not encrypted. This means that when they are sent over a network, someone else might be able to read, delete or alter them without your permission or knowledge. While interception or alteration of these messages is illegal, it is possible. In addition, we have no control over the electronic networks that are used to transmit email or text messages. There are some locations on our Services where we provide for a more secure environment in which to exchange information with you. If instead you choose to send or request information over unencrypted email or SMS text message, you agree that you understand and accept this risk.

Changes to this Privacy Policy

We reserve the right to change this Privacy Policy. When we change it, we will make a copy of it available to you by posting it on our website and including a link to it in our mobile applications. If we make changes to this Privacy Policy, we will make you aware of them where we post the updated policy and may also notify you by other reasonable methods that we select. If we make material changes to this Privacy Policy that will result in a new use, disclosure, or permission of access to your personal data that we previously collected and stored, we will obtain any consent that may be required by law. You understand and agree that if you use this website after the effective date of the updated Privacy Policy, we consider your use as acceptance of it.

Effective date: 10/29/2018