Privacy Policy

emocha Mobile Health Inc.

Last modified: October 3, 2019

Introduction

emocha Mobile Health Inc., a Delaware corporation (“emocha” or “Company” or “We”), respects your privacy and is committed to protecting it through our compliance with this Privacy Policy.

This Policy describes how emocha treats personal information. It applies to information we collect on our Website and App where it is posted. Read this Policy to learn about what we do and your choices. We value the privacy of our users and visitors and make it a priority to protect any personally identifiable information that we collect, use, or disclose. This Privacy Policy is incorporated into and is subject to emocha’s [Terms of Service].

This Privacy Policy applies to information we collect on the Website and App.

  • In e-mail, text and other electronic messages between you and the Website or App.
  • Through mobile and desktop applications you download from the Website or App, which provide dedicated non-browser-based interaction between you and the Website or App.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • us offline or through any other means, including on any other website; or
  • any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or App.

Please read this Privacy Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website/App. By accessing or using the Website or App, you agree to this Privacy Policy. This Policy may change from time to time. Your continued use of the Website or App after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Scope of this Privacy Policy

emocha is a mobile health software platform designed to support medication adherence. We act as a service provider to health care professionals, public health agencies, health care facilities, and other health entities, and we receive, maintain, use, and disclose data on their behalf and as limited by our agreements with them. This Privacy Policy does not reflect the privacy practices of the third party entities and providers using our platform, and we are not responsible for their privacy policies or practices. Please contact your health care provider if you have questions about their privacy policies and practices.

Services Outside of the United States

Our services may be made available to individuals located outside of the United States. Our servers reside within the United States and personal information about you will be transferred internationally to the United States. Laws governing data collection and use within the United States may differ from those in your country. By accessing our services from outside of the United States, you are consenting to the transfer of your personally identifiable information outside of your country to the United States and acknowledge that you may not have the same data protections. We do not knowingly collect any information from individuals located within the European Union or market to individuals residing in the European Union.

Our Services are Not Intended for Children

Our Website and App are not intended for independent use by children. We do not knowingly collect personally identifiable information from children under 13. If you are a parent or legal guardian and think your child under 13 has given us information, you can contact us at info@emocha.com. Please mark your inquiries “COPPA Information Request.” If we learn that personally identifiable information has been collected from persons under 13 without their parent’s or legal guardian’s consent, then we will take the appropriate steps to delete this information.

Parents can learn more about how to protect children’s privacy on-line here.

Information We Collect About You and How We Collect It

We collect several types of information from and about users and visitors of our Website and App, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number and health information (“personal information”);
  • that is about you but individually does not identify you; and/or
  • about your internet connection, the equipment you use to access our Website or App and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the Website or App. Information collected automatically is collected through cookies and other tracking technologies.
  • From third parties which may include usage details, IP addresses and other information.

Information You Provide to Us

The information we collect on or through our Website or App may include:

  • Information that you provide by filling in forms on our Website or App. This includes information provided at the time of registering, subscribing or requesting services or products. We may also ask you for information when you report a problem with our Website or App.
  • When you register for an account to use our services or at any later time, you may provide certain personally identifiable information such as: your name, password, age, gender, email address, postal mailing address, zip code, and home/mobile telephone number. When using our services, you may also upload videos of yourself taking your medication.
  • Records and copies of your correspondence (including e-mail addresses), 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 our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

Information that is Automatically Collected

When you visit our Website, whether or not you register for an account, emocha may send one or more cookies to your computer. Cookies remember information about your activities on a website. Please review your web browser “Help” file to learn the proper way to modify your cookie settings. You can configure your browser to accept all cookies, reject all cookies, or notify you when a cookie is set. However, if you remove cookies, you may not have access to certain services or features available on the Website

emocha may also implement third party content, such as textual or graphical links, on the Website which allow the third party content provider to read and write cookies to your browser, or implement similar tracking mechanisms, in connection with your viewing of that third party content displayed on the Website or otherwise made available through our Services. This information is collected directly by such third party, and emocha does not participate in that data transmission and is not responsible for the privacy practices of such third parties. We have no access or control of the cookies or web beacons set by third parties. 

We collect device identifiers. We may also collect information about your location. emocha Mobile Health’s servers may also automatically record certain information from your browser such as your Internet Protocol (IP) address, browser type, internet service provider (ISP), referring or exit pages, click stream data, operating system, and the dates and times that you visit our Website.

Usage Details, IP Addresses and Other Technologies

As you navigate through and interact with our Website, we may automatically collect certain information about your equipment, browsing actions and patterns, including:

  • Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system and browser type.

The information we collect automatically is statistical data. It helps us to improve our Website and to deliver a better and more personalized service.

We Combine Information About You

We combine information that we have collected offline with information we collect online. We may combine information that we have collected across other third party sites. We combine information collected across devices, such as computers and mobile devices. We also combine information we get from third parties with information we already have.

Use and Disclosure of Protected Health Information

The privacy of the individually identifiable health information we collect in connection with some of our relationships with health plans, health insurers, health care clearinghouses, other health care providers (“Covered Entities”), and large employers, may be protected by federal law (the Health Insurance Portability and Accountability Act or HIPAA, the HITECH Act, and their regulations).  Your individually identifiable health information may also be protected by state privacy laws in some instances.  This health information is referred to as “protected health information” (“PHI”).  In providing our services or products, we may be a “Business Associate” (as defined by HIPAA regulations), but we are not a Covered Entity.  Your PHI will only be used for the purpose of supplying you with products or services that you request, for our own management and administration purposes, or for other purposes for which you have given your consent, except where otherwise permitted by law. 

For example, we may use your PHI to communicate with you regarding products, services, and features that may be of interest to you and that are offered by our affiliates and business partners, if you authorize it.  We may also use and share your personal contact information to communicate with you about products and services that you have requested through the Website or App. 

In instances where you have authorized the Company to use and disclose your PHI for certain purposes, you may withdraw your consent in the future.  You may withdraw your consent by sending your request in writing to: info@emocha.com or a letter addressed to emocha Mobile Health Inc., 916 N. Charles Street, 2nd Floor – Suite 200, Baltimore, MD, 21201.  Please note that your withdrawal will not be effective until your request is received, and will not apply to uses and disclosures that have already been made in reliance on your consent.

How We Use Your Information

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

  • To display our Website/App and its contents to you.
  • To provide you with information, products or services that you request from us.
  • To respond to your questions. This includes questions about our services or your relationship with us.
  • To improve our Website and App.
  • We use “cookies” information to: (a) remember some of your information so that you will not have to re-enter it during your visit or the next time you visit the Website; and (b) monitor aggregate information such as total number of visitors and pages viewed.
  • To provide you with notices about your account/subscription, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website/App or any products or services we offer or provide though it.
  • To allow you to participate in interactive features on our Website.
  • To verify your identity and administer your account.
  • For security purposes. We may use your information to protect our Website and App. We may use your information to prevent, discover, and investigate violations of our Privacy Policy or Terms of Service.
  • To fulfill any other purpose for which you provide it.
  • For any other purpose with your consent.

We may also use your information to contact you about 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 info@emocha.com.

We will not use or disclose your personal information, other than as set forth in this Privacy Policy or as described in our written agreements with you.

Disclosure of Your Information

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

We may disclose personal information that we collect or you provide as described in this Privacy Policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers and other third parties we use to support our business.
  • To third parties to whom you specifically ask us to send such information (for example, your insurer or physician). Once you make your information available to others, it may be collected and used by the recipients and we no longer have control over that information or how it is used.
  • 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 Website users is among the assets transferred.
  • To third parties to market their products or services to you if you have consented to/not opted out of these disclosures.
  • To fulfill the purpose for which you provide it.
  • 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 to respond to any government or regulatory request.
  • To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
  • 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.

We do not sell any personal information.  We may sell certain information that cannot individually identify you.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. You can always choose not to submit your information to us, but if you do not submit the information requested, you may not be able to access many of the products, services, and features that we offer.

If you do not wish to receive communications from us about products, services, or features that may be of interest, you can unsubscribe to any e-mail that we may send to you.  You may request deletion of your personal information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements).  When we delete personal information, it will be deleted from the active database, but may remain in our archives, and we may also retain anonymous information about your use of our services and products. Once we disclose some of your personal information to third parties, we cannot access that personal information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures.  After we delete personal information, we may retain anonymous information and will continue to use such anonymous information as permitted under this Privacy Policy.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.

Marketing Opt-Out

To stop receiving our marketing communications please email us at info@emocha.com or follow the instructions in any message you get from us. If you opt out of marketing emails you will continue to receive messages from us about your relationship with us where permitted by law.

Access and Amendment of Your Information

Upon request, we will provide you with a copy of the personal information we have on file for you. To request this information, please contact us using the contact information at the bottom of this Privacy Policy. If you notice any errors that you are not able to update yourself, you may contact us and request that we correct your information. If we determine that the information is inaccurate and we are the source of the error, we will correct the information. Because we collect information about you from a variety of sources, we may ask you to contact the source of the information to correct the information. In certain cases, we may need to ask you to contact your health care provider or insurer to correct, amend, or delete inaccurate information.

Data Security

We use appropriate and reasonable security measures to protect your personal information from accidental loss and from unauthorized access, use, alteration and disclosure as required by relevant law. emocha uses certain physical, administrative, and technical safeguards to help protect your personal information. These safeguards comply with the current security standards under HIPAA. However, the Internet is not 100% secure.  We cannot promise you that your use of our Website and App will be completely safe. We encourage you to use caution when using the Internet.

If emocha learns of a security systems breach, then we may attempt to notify you electronically so that you can take appropriate protective steps. We may post a notice on or through the Website or App if a security breach occurs. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website or App, you are responsible for keeping this password confidential. Do not to share your password with anyone. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Please report any security violations or concerns to us at info@emocha.com.

Covered Entities with whom we interact must follow state and federal laws protecting the privacy and security of PHI received from us; their activities are not subject to this Privacy Policy.  If you have questions about how a Covered Entity uses and discloses your PHI you should ask for a copy of their Notice of Privacy Practices.

California Residents

If you reside in California, you have the right to ask us one time each year if we have shared personal information with third parties for their direct marketing purposes. To make a request, please send us an email at info@emocha.com or write to us at the address below.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Website home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: info@emocha.com or by mail to the following address: emocha Mobile Health Inc., 916 N. Charles Street, 2nd Floor – Suite 200, Baltimore, MD, 21201.