Last Modified: September 8th, 2020
Introduction
This Privacy Policy describes our practices in connection with information that we collect through the websites from which you are accessing this Privacy Policy (the “Websites”) and software applications made available by us for use on or through computers and mobile devices (the “apps” and together with the Websites, collectively, the “Services”) that we offer in connection with [Anthem,] CareMarket, Inc. (“CareMarket, Inc.,”) (our “Partner”). The Services are available to US residents only.
K Health, Inc. (“K,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information in connection with the Services.
The Symptom Checker and Virtual Visit by data communications are provided by K Health.
This privacy policy applies to K’s use and disclosure of information in connection with the Services. CareMarket, Inc. will also collect your information in connection with the Services. The use and disclosure of your information by CareMarket, Inc. is subject to their privacy policies and not this Privacy Policy.
We encourage you to read about CareMarket, Inc.’s practices available through the link below.
Our vision at K is to provide you with free access to relevant health information. Our ability to offer you relevant health information is based on your agreement to share with us your specific symptoms, and your information such as your age and gender. Only when K knows this information about you, it is able to compare you to similar people and tell you what they were diagnosed with and how they were treated. The more specific information you give us about you and your symptoms, the more accurate and relevant information we are able to provide you.
Our commitment to your privacy means that we will use your data as described in this Privacy Policy. We will never sell your Personal Information to anyone. You will never see advertisements on our service that were tailored to you based on the information you provided us.
We encourage you to take a deep dive and read this Privacy Policy as it explains what types of information we collect about our users, how we collect such information, how we use the information we collect, how we disclose the information we collect, how long we keep it for. You may also read more about your rights in relation to your Personal Information, the security measures we take to protect your personal information and our cookies policy.
If anything in our privacy policy is unclear, or if you have any questions, please ask us at [email protected].
Personal information
We collect personal information, which is information that identifies an individual or relates to an identifiable individual. This information may include your name, date of birth, gender, location, IP address.
Personal information may also be related to your health, such as information about your illness, symptoms and their potential causes, medical history, test results, health plan identification number, and any other personal health information. In some instances, these types of information will only be collected when you chat with a doctor (virtual visit) using our app, and it will be subject to the HIPAA Notice of Privacy Practices.
Collection of Personal Information
We and our service providers collect Personal Information in a variety of ways, including:
- Information you share with us: We collect the information you provide to us, for example when you create an account, contact us directly or write us on social media platforms. This information may include personal information including information relating to your health.
- Information we collect automatically: When you visit or use our app or website, we may gather, collect and record information about it. We do this ourselves or with the help of third-party services, including through the use of “cookies” and other tracking technologies, as further detailed below. This information may include your IP address (which may also be associated with your domain name or the domain name of your internet service provider), data relating to your use and navigation, unique identification numbers associated with your mobile device or our mobile application and your approximate geographical location.
- Information we receive from third parties and social media: We cooperate with third parties who help us operate K. From time to time, we may receive information about you from those third parties (such as Apple’s Healthkit or Fitbit). We may also receive your Personal Information from other sources, such as publicly available databases, or our Partner in connection with your use of the Services.
Use of Personal Information
We are using the information we collect for the following purposes:
- To provide the Services to you:
- To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related customer service. We will use your Personal Information to give you relevant information about your health.
- To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, suggestions, compliments or complaints.
- To complete your transactions, verify your information, and provide you with related customer service.
- To send administrative information to you, such as changes to our terms, conditions, and policies.
- To make K smarter: We may use the information we collect in order to improve our AI models, so that we are constantly improving the information we provide our users. The information we use to improve our machine learning algorithms and technology is always used in an aggregated and anonymized way, and can never be traced back to you.
- To send you marketing materials: We may use the information to be able to send you promotional content about our Services by e-mail, text messages, push notifications and similar forms of communication from us or our Partner. If you do not wish to receive such promotional messages, please follow the instructions described in “Communications Choices” below.
- As part of our user support: We may also contact you with important information regarding our Services, such as in event a certain Service is temporarily suspended for maintenance, to reply to your support inquiries. It is important that you are always able to receive such messages. For this reason, you are not able to opt-out of receiving such service and billing messages unless you are no longer a user of the Services. These types of messages are not encrypted, however, if we need to share information with you of a sensitive nature, we will direct you to log into the app in order to receive such information securely.
- For other business purposes:
- For data analysis, for example, to improve the efficiency of our Services;
- For audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
- For fraud and security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
- For developing new products and services;
- For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
- For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
- For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
- For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.
Aggregating and/or anonymizing Personal Information – We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.
Disclosure of Personal Information
We or our service providers may share your Personal Information with third parties:
- Third-party service providers: We may share Personal Information with certain service providers, whose services and solutions complement, facilitate and enhance our own. These include hosting and server services, communications and content delivery networks (CDNs), data and cybersecurity services, session recording and remote access services, performance measurement services, data optimization and marketing services, content providers, and our legal and financial advisors. Click here to see the list of our third-party service providers.
- Our Services Partner: We may share Personal Information with our Partner for purposes of providing the App Services, to improve the services and for our Partner to provide more or enhanced services, and for research and analytics.
- Your Health Plan: if you are a member of a health plan we support, we may share information about you and/or your dependents with your health plan, including your group health plan.
- Our Affiliated Doctors: If you chose to use our virtual visit service (available only in certain areas), we will share Personal Information with the doctors affiliated with us, in order for them to provide you care. If you are in the United States, communications with our virtual visit service are also governed by our HIPAA Notice of Privacy Practices.
- Business Transactions, Liquidation: We may share Personal Information with third parties in connection with a transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business, or in the event of a bankruptcy or related or similar proceedings.
- Law Enforcement, Legal Requests and Duties: Where permitted by local data protection laws, we may disclose your Personal Information pursuant to a legal request, to cooperate with law enforcement, or in compliance with applicable laws, if we have good faith belief that the law requires us to do so, with or without notice to you.
- For Other Legal Reasons: Where permitted by law, we may share your Personal Information with others if we believe in good faith that it will help protect the rights, property or personal safety of K, any of our users, or any member of the general public, with or without notice to you, or as needed to enforce our terms and conditions.
Personal Information You Share with Others
K enables you to share your Personal Information with others, including healthcare providers, friends and contacts via social media, via our app or otherwise. Please use caution when sharing your Personal Information with others. The information you share will be shared according to your instructions and actions, and we have no control over what happens with your information once you share it with others.
Retention
We will keep your Personal Information for as long as your user account is active, in order to allow you to have access to your information and to provide you with our Services.
We may continue to retain your Personal Information even after you deactivate your user account or stop using K, as reasonably necessary to comply with our legal obligations, to resolve disputes regarding our users, enforce our agreements or protect our legitimate interests.
If you use our virtual visit service, we may be obligated to keep your Personal Information for a longer period, and we will do what is legally required in each case.
Other information
We also collect “Other Information” which is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:
- Browser and device information;
- App usage data;
- Information collected through cookies and pixel tags;
- Demographic information and other information provided by you that does not reveal your specific identity; and
- Information that has been aggregated in a manner such that it no longer reveals your specific identity.
Collection of Other Information
We and our service providers may collect Other Information in a variety of ways, including:
- Your browser or device: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
- Your use of the Services: When you download and use our App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
- Cookies: Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences, and other traffic data. We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience. We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them. We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website. You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.
- Analytics: We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends. This service may also collect information regarding the use of other websites, apps and online resources. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
- Physical Location: We may collect the physical location of your device by, for example, using satellite, cell phone tower or WiFi signals. In some instances, you may be permitted to allow or deny such uses and/or sharing of your device’s location.
Uses and Disclosures of Other Information
We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Privacy Policy. In some instances, we may combine Other Information with Personal Information. If we do, we will treat the combined information as Personal Information as long as it is combined.
Online Advertising
In order to promote our App and Services, we use platforms such as Facebook for online campaigns.
For example, we may use Facebook’s “Custom Audience Tool” to display interest-based ads promoting our app. We do not share Personal Information with Facebook, but given that Facebook knows the identity of their users, they may link the fact you clicked on our ad with your identity. Further, we report app events to Facebook to help optimize our campaigns, but we do not share with Facebook the meaning of such events. In other words, Facebook will receive information about your usage of the app (for example “User X completed apple” which means something about your usage of the app to us, but not to Facebook) but not any personal, medical or health-related content. If you do not want to receive interest-based ads on Facebook, you can adjust your ad preferences through your Facebook settings.
Communication choices
We give you choices regarding our use and disclosure of your Personal Information for marketing purposes. You may opt-out from:
- Receiving marketing-related emails from us. If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by contacting us in accordance with the “Contact Us” section below.
- Receiving text messages from us. If you no longer want to receive text messages from us on a going-forward basis, please follow the instructions within the text message to unsubscribe.
We will try to comply with your request(s) as soon as reasonably practicable. Please note that if you opt-out of receiving marketing-related emails from us, we may still send you important administrative messages, from which you cannot opt-out.
Third-party services
This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link. The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.
In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as Facebook, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with the Apps or our Social Media Pages.
Third-party payment services
We may use a third party payment service to process payments made through the Services. If you wish to make a payment through the Services, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy. We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.
Use of services by minors
At present, the Services are not designed for anyone under the age of 18. Furthermore, we do not knowingly collect or solicit any information from anyone under the age of 18. If we learn or are informed that we unintentionally collected Personal Information from an individual under the age of 18, we will delete such information. If you believe that we might have any information regarding a person under the age of 18, please contact us at [email protected]
Jurisdiction
The information we collect from you may be stored and processed in the United States, Israel, or any other country in which we, or our affiliates or service providers, maintain facilities in, and in other jurisdictions as necessary for the proper delivery of the Services or as may be required by law. If you are located outside the US or Israel, please note that we may transfer your information, including your Personal Information, to a country that does not have the same data protection laws as your jurisdiction, and you consent to such transfer of information to the U.S. or any other country in which the company or its service providers maintain facilities.
Security measures
We seek to use reasonable organizational, technical, and administrative measures to protect Personal Information within our organization. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.
Updates to this privacy policy
We may modify or update our privacy policy from time to time, as we change our business and practices. When we change our policy in a material manner we will notify you, and update the “last modified” date as set forth at the beginning of this policy.
Contacting us
If you have any questions about this privacy policy or wish to exercise any of your rights as set forth in this policy, please contact us at [email protected].
Please contact us also if you have any issues regarding our use of your Personal Information.
You may also contact us by mail at: K Health, Attention: Privacy Officer, 387 Park Ave South, 9th Floor, NY, NY 10016, USA
Additional information regarding California
We are providing the following additional details regarding the categories of Personal Information about California residents that we have collected or disclosed within the preceding 12 months:
- We collected the following categories of Personal Information:
- Identifiers, such as name, contact information, online identifiers;
- Personal information, as defined in the California customer records law, such as name, medical information, insurance information, employment information;
- Characteristics of protected classifications under California or federal law, such as sex;
- Commercial information, such as transaction information;
- Internet or network activity information, such as browsing history and interactions with our website;
- Geolocation data, such as device location and IP location;
- Professional or employment-related information, such current employer;
- Inferences drawn from any of the Personal Information listed above to create a summary about, for example, an individual’s preferences and characteristics.
As described above, we collect this Personal Information from you and from other categories of sources, including publicly available databases or our Partner, when they share the information with us. Also as described above, we may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, using Personal Information to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; and exercise and defend legal claims.
- We disclosed the following Personal Information to third parties for our operational business purposes:
- Identifiers, such as name, contact information, online identifiers;
- Personal information, as defined in the California customer records law, such as name, medical information, insurance information, employment information;
- Characteristics of protected classifications under California or federal law, such as sex;
- Commercial information, such as transaction information;
- Internet or network activity information, such as browsing history and interactions with our website;
- Geolocation data, such as device location and IP location;
- Professional or employment-related information, such current employer;
- Inferences drawn from any of the Personal Information listed above to create a summary about, for example, an individual’s preferences and characteristics.
- We share Personal Information with our service providers and our Partner.
- We have not “sold” Personal Information for purposes of the CCPA.For purposes of this Privacy Policy, “sold” or “sale” means the disclosure of Personal Information for monetary or other valuable consideration but does not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other disposition of all or any portion of our business.
- If you are a California resident, you may request that we:
- Disclose to you the following information covering the 12 months preceding your request:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting Personal Information about you; and
- The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
- Delete Personal Information we collected from you.
To make a request for the disclosures or deletion described above, please contact us in accordance with the “Contact Us” section above.We will respond to your request consistent with applicable law.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
Additional information for Nevada residents
We do not sell Covered Information as defined under Nevada law. If you would like to make any inquiry regarding the sale of your Covered Information, please contact us in accordance with the “Contact Us” section above.
