Effective Date: February 25, 2022
About this Privacy Policy and Our Commitment to Your Privacy
Whiplash Technology, Inc. d/b/a CareVirtue (“CareVirtue”, “we”,”us”, “our”) provides online products and services (collectively, the “Services”) through our technology platform and carevirtue.com (collectively, the “Site”) that may, among other things, provide you with tools to engage in supportive care management for persons that require care assistance (for Alzheimer’s disease and other chronic situations). We provide this privacy policy (“Privacy Policy”) to outline the information CareVirtue collects from users of the Site (“Users”,“you”), CareVirtue Partners (defined below) and how we may use and disclose this information when the Site is accessed through any device. It also describes the choices available to you regarding our use of your information and how you can manage and update this information. Some online services offered by or affiliated with CareVirtue may be governed by a separate privacy policy. We suggest you review each of the privacy policies for the services you are wishing to receive.
Your Consent to this Privacy Policy by Using the Site
As described in this Privacy Policy, we may use and disclose your information to provide you with products and services and to improve your experience using those products and services. By using the Site, or any other website, online service or mobile application where this Privacy Policy is posted, you agree to our collection, use, disclosure, and storage of information as described in this Privacy Policy.
Information Addressed by this Privacy Policy
We want you to have a clear understanding of the information addressed by this Privacy Policy. We will collect information about you (“Information”) in a variety of ways, including directly from you, through automatic means, or from third parties. The Information that is collected depends on how you use the Site.
Personal Information and Privacy
When you use our Service, you may be creating and maintaining a personal, private area of the application (“Individual Team”) on behalf of yourself and/or one or more persons within your care team (“Care Team”), or visiting and posting to an Individual Team created by someone else within your Care Team. By their very nature, these Individual Teams contain a great deal of personal information about the subject of the Individual Team and other Users on the Care Team. Our goal is to balance our Users’ need to find each other and communicate information and support against our Users’ desire for a measure of privacy. By establishing an Individual Team, you represent that you have all consents and authorizations necessary to use the information relating to members of your Care Team necessary to establish the Individual Team.
Site Access
The Individual Team is accessible “By Invitation Only.” Once established, every member of a Care Team, including the creators of Individual Teams and all Users are responsible for maintaining the confidentiality of the Individual Team in accordance with the care recipient’s wishes.
Information You Provide Directly to CareVirtue
When you use the Site, you may provide certain information directly to us. For example, without limitation, when you choose to register a user account, you will be required to provide, among other things, your e-mail address, name, and phone number. When you create a Care Team, we may collect identifying information about members of the Care Team and the caregiver, such as the caregiver’s work status and living situation. We also collect information about how the supporter can help the care recipient. We may use this information to suggest services that may be of use to the caregiver or care recipient. When you use our coaching services, we may collect information regarding your past and present medical history (i.e., diagnosis, medical events, medications, etc.). We may also collect financial information in order to determine eligibility for certain programs and benefits. Finally, we may collect information regarding your insurance coverage and benefits.
Certain Information in the Services is Visible to Other Users
Information regarding the care recipient’s needs, actions taken and updates may be shared among and be available to Care Team members, but is not publicly visible to other Users outside of the Care Team.
Information that is Automatically Collected
We and third parties may use automated means to collect information about you, your computer or other device that you used to access the Site, and your use of the Site. These automated means include common technologies such as cookies or similar technologies. These technologies help us analyze trends, administer the Site, track Users’ movements around the Site, gather demographic information about our user base as a whole, and otherwise provide you with relevant content (e.g., by gathering your zip or postal code). We may receive reports on an individual as well as aggregated basis based on the use of these technologies by CareVirtue, and any third-party vendors acting on CareVirtue’s behalf.
Information We Collect from Third Parties
CareVirtue enters into business relationships with business partners including: healthcare providers and/or networks of healthcare providers (“Providers”), health plans or health insurers, including, without limitation, employer-sponsored health plans (“Health Insurers”), and companies that contract with Providers, Health Insurers, and/or CareVirtue (“Contractors”) to make CareVirtue’s products and services available to Users who are patients of such Providers or enrollees, members, or participants of such Health Insurers or Contractors. CareVirtue’s business partners such as Providers, Health Insurers, and Contractors are collectively referred to in this Privacy Policy as “CareVirtue Partners.” When you use the Services, we may collect information about you, directly or indirectly, from or through applicable CareVirtue Partners as well as other Users of the Services. With your consent, we may also collect Information from other third parties.
Cookies and Tokens
Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of local storage (such as browser-based or plugin-based local storage, or application-based local storage on a mobile device). You may be able to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Site.
Our cookies, tokens and similar technologies (collectively, “Tracking Technologies”) also are used for administering the Site, including without limitation, for authentication, to remember Users’ settings, to customize the content and layout of the Site for Users, to contact you about the Site, and to improve our internal operations, the content of our Site and our services. Users may be able to control the use of, or reject or disable, some Tracking Technologies at the individual browser level. If you reject or disable Tracking Technologies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. We use Tracking Technologies to identify your device and keep track of your Internet session with our Site. Using these Tracking Technologies, we may automatically end your session on our Site after a period of inactivity (as determined by us in our sole discretion). We also use Tracking Technologies that allow us to recognize your device when you return to the Site within a certain period of time (as determined by us in our sole discretion) and automatically log you back into your account with us. UNLESS YOU AFFIRMATIVELY LOG OUT of your account PRIOR TO YOUR SESSION ENDING (whether by you or by us), YOU WILL BE AUTOMATICALLY LOGGED BACK IN THE NEXT TIME YOU OR ANY USER OF YOUR DEVICE VISITS OUR SITE within the period of time determined by us. If you do not wish to be automatically logged back in when you (or someone using your device) next initiate a session with our Site (using the same device that is being used for your current session), you should log out of your account (i) prior to ending your session, or (ii) if you will be inactive on our Site for more than a few minutes.
Web Logs
In conjunction with the gathering of data through cookies, Web servers may log records such as your device type, operating system type, device advertising identifier, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The Web server logs also may record the address of the Web page that referred you to our Site, the IP address (and associated city and state or province for the IP address) of the device you use to connect to the Internet, and data about your interaction with our Site, such as which pages you visit.
Pixels/Web Beacons
To control which Web servers collect information by automated means, we may place tags on our Web pages or in our app called “Web beacons” (or “pixels”), which are files that associate certain behavior with a session or user. We also may include Web beacons in e-mail messages to record whether an email has been opened or whether certain links in such email have been clicked. We or third parties also may send instructions to your device using JavaScript or other computer languages to store or gather the sorts of data described above and other details about your interactions with the Site. We may use third party pixels on the Site’s registration and login pages. For example, we may use these pixels to assess your progress in registering for our Site. If you start but fail to complete the registration process, we may also use third party pixels to deliver reminders to complete your registration. We may also use these pixels to deliver notices about new and existing features on our Site. These reminders and notices may appear on other websites, and third parties who provide the pixels may use the information obtained from pixels for their business purposes.
Online Analytics
We may use third-party web analytics services on our Site, such as those of Google Analytics. These service providers use the sort of technology described in this “Information that is Automatically Collected” section to help us analyze how Users use the Site, including by noting the third-party Web site from which Users arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Site.
Mobile Application Technologies
Our mobile applications may also collect information specific to use of your mobile device, such as unique device identifier and, with your consent, precise geolocation information, motion coprocessor data (e.g. recording information such as steps, distance, and elevation), accelerometer data (showing whether you’re stationary or moving), and gyroscope data. We may also use third-party analytics, such as those of Google Analytics.
Collection of Information Across Personal Devices and Applications
Sometimes, we (or our service providers) may use the information we collect—for instance, log-in credentials, IP addresses, hashed email addresses, and unique mobile device identifiers—to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor content, features, and advertising (for CareVirtue on other sites), and provide you with a seamless experience across the devices you use to access our services.
Our Use of Information
Use and Storage of Information to Provide You with the Site and Related Services
CareVirtue, and any third party vendors acting on CareVirtue’s behalf, may use and store your Information to perform activities associated with providing you with the Site and related services such as: (i) registering you to use the Site and otherwise logging you into the Site, including the authentication of your identity, where applicable, and otherwise enabling your access to the Site; (ii) resolving disputes and/or troubleshooting problems including logging into your account to troubleshoot problems or otherwise help you navigate the Site; (iii) verifying your compliance with your obligations in our Terms of Service or other CareVirtue policies; (iv) improving the quality of the Site, (v) fulfilling any request you make; (vi) communicating with you; (vii) connecting you with and providing you with information about services, providers of services, resources or programs to which you may have access; (viii) providing you with Site content, including, without limitation, generating recommendations (such as recommended Site activities or services), providing coaching services, creating action plans for caregivers, helping caregivers anticipate the needs of the care recipient, and processing your preferences and requests; (ix) analyzing, customizing, and personalizing the Site, including through the delivery of tailored content and communications; and (x) otherwise as directed by you or provided for herein. Except where prohibited by law, and only to the extent permitted by CareVirtue’s agreements with applicable CareVirtue Partners, we may also use your Information in connection with any other services we make available to you.
Additional Information Regarding Use of Information for Communications with You
If you choose to tell a friend about our Service or share an Individual Team through our Site, we will ask you for your friend’s name and email address or phone number. We will automatically send your friend a one-time email or text message inviting him or her to visit the Site. We retain this information to identify the User as part of the care team when they sign in.
CareVirtue, CareVirtue Partners, and any third-party vendors acting on CareVirtue’s behalf, may also use your Information to communicate with you (including, without limitation, via email and/or mobile push notifications) about the Site and/or our products and services (and related features and functionality) or those of any CareVirtue Partner that is providing services to you. Our communications to you will include, without limitation, contacting you by SMS text message or at the email address(es) that you use to register for our Site to communicate with you regarding the Site and actions that you take in connection with the Site.
Your Choices Regarding Our Communications with You
In accordance with applicable law, we will offer you the opportunity to opt out of certain communications, such as, for example, communications that deal with any of our products or services you are not using but that we think might be of interest to you. Where applicable, you can opt out by emailing us at support-at-carevirtue.com. However, even if you opt out of such communications, you may continue to receive other transactional, relationship, and/or administrative communications from or through CareVirtue that are important or related to your CareVirtue account or the products and services you are using (such as, for example, a notice that there has been a change in one of your services or a change to this Privacy Policy). Please also note that you, not CareVirtue, have control over certain settings for how communications such as emails and push notifications are displayed on your devices, and the settings you select will affect how CareVirtue’s communications are displayed.
Creation and Use of Combined Data, De-Identified Data, and Aggregated Data
As permitted by law and by CareVirtue’s agreements with applicable CareVirtue Partners, CareVirtue, and any third-party vendors acting on CareVirtue’s behalf, may aggregate and/or de-identify your Information and/or combine your Information with other information maintained or available to CareVirtue and use or disclose such information as follows:
We may use aggregated or combined data to communicate with you about the Site and/or our products and services and disclose such aggregated or combined data to CareVirtue Partners in connection with providing the Site.
We may also use and disclose de-identified data, de-identified aggregated data, and/or de-identified combined data for any business purpose, which may include, without limitation, improving our products and services, conducting analytics such as evaluating our Site and developing additional benefits, programs, and services, and disclosing to CareVirtue Partners for analytics purposes.
Disclosure of Information
We may share your Information in the following circumstances:
Disclosures to Service Providers and CareVirtue Partners
With the limited exceptions discussed below, we do not share your information with third parties, unless you tell us to. We will not share your personal information under any circumstance with any third parties for the purpose of allowing them to conduct direct marketing to you. In this section, we describe the potential uses of your information in greater detail
With Third Parties That Provide Requested Benefits: As stated above, we primarily share your information, including your personal information, with third parties for the purpose of providing certain benefits that you request. Specifically, at your direction, we will submit your information to the appropriate third parties for purposes of filling your third-party service requests. For example, if you are interested in transportation or coaching services, then we will share your information, at your direction, with third parties that work with CareVirtue to provide transportation or coaching services, which may fit your particular needs. The third party, not CareVirtue, will evaluate your eligibility to obtain service from its program. The third party’s use of your personal information will be governed by the third party’s own terms of service and privacy policy, not CareVirtue’s; CareVirtue does not have any control over your information once it is submitted to a third party for receipt of benefits. While we work with reputable third-party service providers, we cannot represent how any of them will use your personal information in connection with their services, and recommend that you review their terms of use and privacy policies before requesting their services.
To Perform Services on Our Behalf: We may hire vendor companies to provide limited services on our behalf, such as payment processing, sending postal and electronic mail, providing technical support, and to assist us in providing the products and services that you request from us. We only provide those service providers with the information necessary to perform the requested service.
Safety, Security and Compliance with Law
Your Information and the contents of your communications through the Site may be disclosed to third parties as required by law, such as to comply with a subpoena or similar legal process, or when we reasonably believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, report improper or unlawful activity, or respond to a government request.
Subsidiaries and Affiliated Companies
Except where prohibited by law or precluded by contract, we may share your Information with any subsidiaries or other affiliated companies under the control of, or under common control with CareVirtue for the purposes set out in this Privacy Policy.
Sale, Merger or Similar Transaction
We may share your Information in connection with any proposed or actual merger, reorganization, a sale of some or all our assets, a financing or acquisition of all or a portion of our business by another company, or to a receiver, trustee or successor in interest in bankruptcy, in which case such company may continue to process your Information as set forth in this Privacy Policy (except where prohibited by law) or otherwise with your consent.
We Do Not Control the Privacy Policies of Third Parties
Our Site may contain links that enable you to visit or use other third-party websites, resources or programs. However, we do not have control over the other websites, resources, or programs that you choose to visit, so this Privacy Policy does not apply to information collected or that you provide while visiting such other websites, resources, or programs. You should refer to the privacy policies, if any, applicable to the other websites, resources, or programs.
Data Security and Integrity
The security of your Information is important to us. We follow security standards to protect the Information submitted to us from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction, both during transmission and once we receive it. These safeguards vary based on the sensitivity of the Information that we collect, process and store and the current state of technology. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. We also maintain procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current. If you have any questions about data security and integrity on our Site, you can contact us at support -at- CareVirtue.com.
Be Sure to Log Off When Using Public or Third-Party Computers
As described above, we use Tracking Technologies that automatically log you back into your account with us unless you affirmatively log out of your account prior to your session ending (whether you end your session or we end your session, for example if our Site has “timed out” – i.e. we have ended your session automatically after a period of inactivity as determined by us in our sole discretion). If you log into the Site using a public computer or device, or a computer or device of that belongs to or is shared with another person, you should affirmatively log out of your account. Otherwise, the next user of that computer or device may be able to access your account and your Information in your account if your session has not ended.
Your Use of Persistent Login
The log-in in our application is persistent. We recommend that you log-out after use of the application, if you are concerned about the unauthorized use or disclosure of Information via persistent login.
Managing and Updating Information
To access, review, update and/or delete certain Information, you may contact us at support-at-CareVirtue.com, and you may update and/or delete certain Information by logging into the Site and updating your account. We will respond to your request within a reasonable and lawful timeframe under the circumstances of your request. Please remember, however, if we have already disclosed some of this Information to third parties, we cannot access that Information any longer and cannot force the deletion or modification of any such Information by the parties to whom we have made those disclosures. Additionally, if you modify certain Information on our Site that we received from a third party, we reserve the right, but are not obligated, to share the updated information back to that third party. As a result, you will need to provide updated information to those third parties if you want to be sure they have your updates.
Certain Information is necessary in order for us to provide the Site and our related Services; therefore, if you delete such necessary Information you will not be able to use the Site or receive our Services. If you wish to have your account deactivated, you may contact us at support-at-CareVirtue.com. After we receive your request, within a reasonable timeframe under the circumstances of your request, we will deactivate your account; provided, however, that: 1) CareVirtue (and our third-party vendors acting on our behalf), our CareVirtue Partners, and any other applicable third parties may continue to use and share for any purpose de-identified data and aggregated or combined data developed using your Information that has been de-identified and 2) CareVirtue may continue to use Information in your deactivated account for compliance with applicable regulations. Also, please note that even though you may deactivate your account or request the deletion of your Information, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, or troubleshoot problems) to retain this information, in which case we will comply with your deletion request only after we have fulfilled such requirements. We may also keep a copy of your Information to protect our legal rights, such as in connection with your use of the Site or your agreement to our Terms of Service, as permitted or required by applicable law.
California Do-Not-Track Disclosure Requirements (for California Users)
We are committed to providing you with meaningful choices about the information collected on our Site for third-party purposes. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
Uses and Disclosures as Required or Permitted by Law, Including Research, Health Care Operations, and Public Health
To the extent not prohibited by law or precluded by CareVirtue’s agreements with the applicable CareVirtue Partner, CareVirtue, and any third party vendors acting on CareVirtue’s behalf, may use and disclose your Information: (a) as required or permitted by law, including, where applicable, the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), which may include disclosures to the applicable CareVirtue Partner; (b) for Research purposes; (c) for purposes of Health Care Operations of the applicable CareVirtue Partner; and (d) for Public Health, as each is defined and in accordance with HIPAA.
Retention of Personal Data
Personal data will be retained only for so long as reasonably necessary for the purposes set out in this Privacy Policy, considering criteria such as applicable rules on statute of limitations and at least the duration of your use of our Site and Services. Information may persist in copies made for backup and business continuity purposes for additional time.
Modifications to this Privacy Policy
From time to time, we may update this Privacy Policy to reflect changes to our information practices. If we make changes to this Privacy Policy, they will be reflected in an updated Privacy Policy that will be posted on the Site, and all changes will be effective upon such posting or upon any later date specified by us in writing. We encourage you to periodically review this page for the latest information on our privacy practices. You can determine when this Privacy Policy was last revised by referring to the “Effective Date” legend at the top of this Privacy Policy. By continuing to use the Site or any services following the effective date of any updated Privacy Policy, you are agreeing to be bound by the terms and conditions of such updated Privacy Policy.
How to Contact Us with Questions about this Privacy Policy
If you have questions regarding our Privacy Policy or privacy practices, please contact us at: support – at – carevirtue.com.