Last Updated: March 18, 2019
INTRODUCTION TO PRIVACY AT DYNAMICARE HEALTH
We at DynamiCare Health (“DynamiCare”) know the value of trust and transparency, and we understand the need for responsible and secure protection of the information you choose to share with us. Your security is important to us, and we take your privacy seriously. Please read the following to learn more about our policies and practices for keeping your data secure.
As noted in the Terms of Service (available at: http://www.dynamicarehealth.com/terms-of-service ), DynamiCare does not knowingly collect or solicit Personal Information from anyone under the age of 14. If you are under 14, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from an individual under age 14, we will delete that information as quickly as possible. If you believe that a child under 14 may have provided us Personal Information, please contact us at email@example.com . If you are aged 14-17, you and your parent or legal guardian must sign a consent form to be allowed to use the Services.
DynamiCare gathers various types of Personal Information from our users for a variety of reasons. We use Personal Information internally in connection with our Services, including as a means of identifying you as a DynamiCare subscriber, to personalize and improve our Services, to allow you to set up a user account and profile, to contact you, to fulfill rehabilitation requirements, to provide and improve the Service, and to analyze how you use the Services. We may share some Aggregate de-identified data with third parties. DynamiCare will not access your camera, your contacts, your location, or any other device content without your permission. DynamiCare will never contact others or post to social networks on your behalf without your permission. The following sections explain what information we collect and how we use it.
THE INFORMATION DYNAMICARE COLLECTS
DynamiCare collects both Personal Information and Anonymous information through the standard operation the Services. This information is used to identify you as a DynamiCare subscriber, track your preferences and settings, and to improve and personalize your experience. Certain information is required for the effective operation of the Services. These types of information are defined in the subparts below and used as described in the corresponding sections.
You may request access to all your personally identifiable information that we collect online and maintain in our database by emailing us at firstname.lastname@example.org .
a) Information provided to us by you or and/or your treatment facility:
We receive and store any information you voluntarily provide to us. For example, through the registration process, online assessment, and/or through your account settings, we may collect personal information such as your name, your email address, or your phone number. Certain information may be required to register with us, or to take advantage of some of the features within the DynamiCare application. Instant messages, emails, contact requests and other forms of communication are kept private and confidential.
b) Information collected automatically when using our Services
c) Information collected from other websites
d) Enabling the “Do Not Track” Feature on your browser
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and Services (including behavioral advertising Services) that you do not wish such operators to track certain of your online activities over time and/or across different websites. When you turn on the Do Not Track function in your browser, we stop collecting the information from your browser that allows us to tailor advertisements and other content specifically to you that is based on your visits to our advertising partners’ websites. Specifically, we stop collecting information from the unique browser cookie that links your browser to visits to third party sites. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked. Remember that this is just our Do Not Track policy, and we can’t and don’t make any promises about how third parties respond when you set this signal on your browser. Not all third parties will allow you to opt out of tracking or cookies.
The DynamiCare app uses the built-in Global Positioning System (GPS) and location capabilities built into your device. These data are used to track your location as well as the length of your stay at appointments. This feature enables you to check into required locations as a part of ongoing treatment. You can choose whether this feature is enabled on your device. Please note that if you choose to turn off the location capabilities on your phone you will not be able to benefit from some of the features of this application. The Application will log that the user has disabled tracking.
f) Substance Testing
The DynamiCare app conducts breath and saliva tests through selfie video. The results of these tests are stored on DynamiCare’s secure servers. The videos are automatically deleted after 1 week, unless you dispute the results. Healthcare providers using the DynamiCare system may also enter in the results of substance tests collected outside of DynamiCare’s Services to be stored in our system.
g) Smart Debit Card
DynamiCare uses a smart debit card to provide incentive funds, when applicable. DynamiCare tracks and stores all transaction data on this card.
h) Other Features
The DynamiCare app will store other types of data as you interact with the app and enter information to it. For example, any information you enter in the Surveys or Cognitive Behavioral Therapy modules in the app will be stored by DynamiCare and made available to your healthcare provider.
i) Aggregated Anonymized Data:
The term “Anonymized Data” refers to information that is no longer associated with a specific individual. “Aggregate Data” are data that describe groups or populations as opposed to individuals. DynamiCare may use, reproduce, sell, publicize, or otherwise exploit Aggregate Data in any way, in its sole discretion. Anonymized data can be used to improve user experience and application efficacy by giving us insights into the demographics and behaviors of our users. We may de-identify or anonymize your personal information so that you cannot be individually identified, and provide that information to our partners. We also may combine your de-identified information with that of other users to create aggregate de-identified data that may be disclosed to third parties who may use such information to understand and analyze our Services. These data will not contain individual identifiers, nor will any constellation of information be collated which can identify an individual.
HOW WE USE YOUR DATA
DynamiCare uses the information you provide to us to personalize and improve your experience with our services. Sometimes our healthcare partners need to access these data in order to partner with us effectively. The following sections explain how the data we collect are employed.
COMMUNICATION WITH DYNAMICARE
We may communicate with you if you’ve provided us the means to do so. For example, if you’ve given us your email address, we may send you promotional email offers opportunities to participate in research studies, or email you about your use of the Services. These offers are independent of the Service the application provides, and your participation will not affect your receipt of the Services. Also, we may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our Services, and is in no way associated with your receipt of the Services. If you do not want to receive communications from us, please indicate your preference by emailing us at email@example.com .
DynamiCare will not share information about you in personally identifiable form with anyone outside of our partners. However, de-identified information can provide valuable insights into the efficacy and quality of our product. In the interest of maintaining the highest standards, we may share information with third parties as described below:
DynamiCare’s partners are businesses such as treatment centers, insurance companies, technology providers with whom we have non-disclosure agreements or Business Associates Agreements to protect your data. Our partners may provide Services to you through or in connection with the DynamiCare Services (either alone or jointly with DynamiCare). We will share your Personal Information with that Partner only to the extent that it is related to your care.
SECURITY AT DYNAMICARE
We are committed to ensuring that your information is collected, applied and stored in the securest manner. We have implemented a variety of commercially standard encryption and security technologies and procedures to protect your personal information stored by us from unauthorized access. We also maintain standard physical and electronic procedural safeguards that limit access to your personal information to our employees (or people working on our behalf and under confidentiality agreements) who, through the course of standard business activities, will need to access your personal information.
Information stored or transferred electronically is never completely secure, so while we at DynamiCare do our best to protect you and your privacy, please be aware that absolute security cannot be guaranteed by DynamiCare.
SPECIAL PROVISIONS FOR RESEARCH SUBJECTS
DynamiCare applies tighter controls for research studies conducted under oversight from an Institutional Review Board. Minimal personal information is collected from research subjects and is used only to enable access and use of DynamiCare Services or as otherwise directed by the study principal investigator. Research study data may be connected to subject username or other unique identifier rather than person name or other identifying information. DynamiCare will not collect information from research subjects about their online or mobile phone activity that is not part of the research study design. The “Do Not Track” option will be the default for all subjects enrolled in research studies. DynamiCare will terminate research subject’s subscriptions to their services, thereby removing subject’s history and data on DynamiCare servers, upon completion of the research study or as directed by study principal investigator. DynamiCare Health agrees to let study principal investigators control all communications with research subjects and will not initiate communication with research subjects for any purpose other than as directed by study investigators.
YOUR ACCOUNT SECURITY
Access to the Service is enabled only by usernames and passwords. You should maintain your username and password in strict confidence. Under no circumstances should you share your username or password with any third party, or allow another person to access the Service using your username and password. Please notify us immediately if you have any reason to believe that your username or password has been lost, compromised or misused in any way. You are fully and solely responsible for any and all use of the Service using your username and password. We reserve the right to revoke or deactivate your username and password at any time. If you have security concerns, questions, or need to reset your password, contact us at firstname.lastname@example.org .
SAFETY, SECURITY, AND COMPLIANCE WITH LAW.
We may disclose any information, including personal information, we deem necessary to comply with any applicable law, regulation, legal process or governmental request, to enforce our rights, or to protect the safety and security of our Applications or other users.
All information passed through DynamiCare is handled in the United States. By using the Services, you agree that the handling of your personal information and any communication through the Services will be governed by the laws of the United States.
NOTIFICATION OF CHANGES