Privacy Policy

Last updated March 27, 2020

Overview

Your access to, and use of the PatientPower, Co. (d/b/a Sibi or Sibi Health) (“Sibi”) services which include this web site (www.sibihealth.com) and the information, products and services that we provide to you and other users through this web site, as well as any mobile applications (“Sibi App(s)”) provided by us in connection with our products and services (collectively, the “Sibi Services”) is subject to the Sibi Services Terms of Service and this Privacy Policy.

Sibi has created this Privacy Policy to explain what information we gather from you when you use the Sibi Services, how we may use this information, the security approaches we use to protect your information, and how you can access and request modification of certain information that we may store about you. Please note that this Privacy Policy applies only to information collected via the Sibi Services – it does not apply to information you disclose to Sibi through other means. This Privacy Policy is incorporated and made part of the Sibi Services Terms of Service.

Your Acceptance of This Privacy Policy and Changes to It

By accessing, viewing or otherwise using any Sibi Service, you consent to the collection and use of your information by Sibi in accordance with this Privacy Policy. If you do not agree to this Privacy Policy, you may not use any Sibi Service. Sibi reserves the right to change, modify, add or remove portions of this Privacy Policy at any time, without prior notice. Changes take effect on the date that change appears on the revised Privacy Policy. If you use any Sibi Service following a change in this Privacy Policy, your use will be understood to signal that you accept and agree to be bound by the changes. Accordingly, we urge you to review this Privacy Policy frequently for changes.

What information do we collect?

We collect personally identifiable information (“Personal Information”) and other non-individually identifiable information from you when you register on the Sibi Services, respond to communication such as e-mail, or otherwise use the Sibi Services in any manner.

To participate in certain features of the Sibi Services, you will be required to provide certain Personal Information. For example, when registering as a user on any Sibi Service, we may ask you for your name, e-mail address, birth date, mailing address, zip code, phone number, credit card information or other Personal Information. You may, however, visit portions of the Sibi Services without providing any Personal Information.

We may collect and use mobile device identifiers, IP addresses and session identifiers to analyze trends, to administer the Sibi Services, to track user activities, to infer user interests, and to otherwise induce, deduce, and gather information about individual users and market segments.

If necessary to perform the Sibi Services, we may collect protected health information (“PHI”), as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Sibi will do it’s best to use PHI in accordance with applicable laws, including HIPAA, however, Sibi is not a “covered entity,” “health insurance issuer,” “health care clearinghouse” or “health care provider” and is therefore not required to comply with the privacy rules and security rules implemented under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). You are strongly encouraged to discuss your provider’s health information privacy policies and procedures with your provider.

Like many web sites and certain mobile apps, we use and may allow third party service providers to use "cookies", flash cookies, local shared objects, web beacons, pixels, single pixel GIFs, clear GIFs, and/or other tracking technologies to enhance your experience and gather information about visitors and visits to the Sibi Services, including how you use the Sibi Services (“Usage Data”). Please refer to the "Do we use 'cookies'?" section below for information about cookies and how we use them.

We may also collect transactional information, customer services information, or any other legally permissible information.

We may also collect and store certain other personally non-identifiable information. This information is collected passively using various technologies, and cannot presently be used to specifically identify you.

Your information may be supplemented with additional information from other companies such as publicly available information, information about households and other information that we may append or match to your information.

How do we use your information?

We may use the Personal Information and other data we collect from you when you register, purchase services, respond to a survey or marketing communication, access or view the Sibi Services, or use certain other Sibi Service features in the following ways:

To provide any legitimate business service or product.

To personalize your Sibi Service and to allow us to deliver the type of content and product offerings in which you are most interested (including to present offers to you on behalf of business partners and advertisers).

To allow us to better service you in responding to your customer service requests.

To contact you when necessary or requested.

To quickly process your transactions.

To verify and validate your identity.

To administer a promotion, survey or other Sibi Service features.

To the extent you have not opted out of receiving marketing communications, to send you information about Sibi or our products or the Sibi Services, including by letter, email, text, telephone or other forms of communication.

To the extent you have not opted out of receiving marketing communications, to provide you with information about third-party businesses, products and services, including by letter, email, text, telephone or other forms of communication.

To show you advertisements, including interest-based or online behavioral advertising. To troubleshoot problems with the Sibi Services, or any services, as requested.

To enforce the Terms of Service, and to detect and protect against error, fraud and other unauthorized or illegal activities.

To operate and improve the Services available through us.

To fulfill your requests for tools, software, functionality, features and other products, and services;

To communicate with you and respond to your inquiries.

To conduct research about your use of our products; and

To help offer you other products, features or services that may be of interest.

We reserve the right to make full use of Usage Data. For example, we may use Usage Data to provide better service to Service visitors or end users, customize the Services based on your preferences, compile and analyze statistics and trends about the use of our Services and otherwise administer and improve our Services.

You understand and agree that if you are using any Sibi Service from a country outside the United States and provide Personal Information to the Sibi Service, you will be authorizing and consenting to the transfer of Personal Information about yourself to the United States. You understand that the privacy laws of the United States may be different from and not as comprehensive or protective as those in your country, and you agree that the transfer of your Personal Information to the United States occurs with your consent. Personal Information collected on the Sibi Service may be stored and processed in the United States or abroad.

Do we disclose the information we collect to outside parties?

You understand and agree that we can disclose your Personal Information and other data to third parties, as follows:

To our subsidiaries or affiliates, strategic partners and to third parties we engage to provide services, such as medical services, web site hosting, credit card payment processing, order processing, analytics services etc.

In the event of the sale or transfer of Sibi, of one or more of our business units or of some or all of our assets, or in the context of some other business acquisition transaction.

In response to lawful governmental requests or legal process (for example a subpoena, court order, or search warrant); to establish or exercise our legal rights, or to defend against claims; or to protect the safety or security of the public or of users of the Sibi Services; or in other circumstances in which we have a good-faith belief that a crime has been or is being committed by a user of our Services, that an emergency exists that poses a threat to the safety of you or another person,

When necessary to protect either our rights or our property or for us to render the service you have requested.

We can disclose aggregate information and other non-individually identifiable information about users of the Sibi Service to our service providers, partners, advertisers or others. For example, we may share information publicly to show trends about the general use of our websites and/or other products or services.

Correcting and Updating Your Personal Information

You can correct or update your Personal Information by re-registering or by contacting us by e- mail at security@sibihealth.com. It may take us up to 30 days to process your request.

Do we use "cookies"?

Yes. Cookies are small files that a site or its service provider transfers to your computer's hard drive through your Web browser or mobile device that enables the site's or service provider's systems to recognize your browser and capture and remember certain information. Cookies help us in many ways to make your use of the Sibi Services more enjoyable and meaningful, such as understanding usage patterns and improving functionality of the Sibi Services. For instance, we use cookies to help us understand your preferences based on previous or current Sibi Services activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about Sibi Services traffic and Sibi Services interaction so that we can offer better Sibi Services experiences and tools in the future.

We may contract with third-party service providers to assist us in better understanding our Sibi Service visitors. For example, we use Google Analytics, a web analytics service provided by Google, Inc. ("Google"). Google Analytics uses cookies to help us analyze how users use the Sibi Services and enhance your experience when you use the Sibi Services. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.

If you are using our website, you can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn o all cookies. You do this through your browser settings. If you are accessing our mobile app, you can choose to change your permissions and settings on your mobile device. Each browser and device is different, so look at your browser or devices Help or Settings menu to learn the correct way to modify them. If you turn cookies off or disable certain permissions, you won't have access to many features that make your Sibi Service more efficient and some of our services will not function properly.

“Do Not Track”

Our Sibi Services currently do not respond to “Do Not Track” (DNT) signals and do not recognize browser-based “do-not-track” requests.

Safeguarding Your Personal Information Privacy and Third Party Links

Sibi follows generally accepted industry security standards to safeguard and help prevent unauthorized access and maintain data security of Personal Information. However, no commercial method of information transfer over the Internet or electronic data storage is known to be 100% secure. As a result, we cannot guarantee the absolute security of any Personal Information submitted to or otherwise collected during your use of any Sibi Service.

Accordingly, you understand and agree that you transmit all data, including Personal Information, to us at your own risk.

Privacy and Third Party Links

This Privacy Policy applies solely to information collected by the Sibi Service through our web site located at sibihealth.com and the mobile application(s) we make available. In an attempt to provide you with increased value, we may include third party links on the Sibi Services. This Privacy Policy does not apply to the third party sites and services that are accessible through these links and we suggest that you contact the operator of the third party service to obtain details about their privacy policies. We have no responsibility or liability for the content and activities of these linked sites or services. Nonetheless, we seek to protect the integrity of the Sibi Services and welcome any feedback about these linked sites (including if a specific link does not work).

Exclusions

This Privacy Policy shall not apply to any unsolicited information you provide to us through the Sibi Services or through any other means. This includes, but is not limited to, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non- confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Children’s Privacy

Only individuals 18 years of age or older are authorized to use the Sibi Services, either for themselves or on behalf of their minor children. We do not knowingly collect information directly from children under the age of eighteen. If you have reason to believe that an individual under the age of 18 has provided Personal Information to us through a Sibi Service, please contact us, and we will endeavor to delete that information from our databases.

Retention of Your Personal Information

We will store the Personal Information you provide for as long as we believe is necessary or appropriate (i) to carry out the purpose(s) for which we collected it, or (ii) to comply with applicable laws, contracts, or other rules or regulations.

Questions and Feedback

We welcome your questions, comments, and concerns about the Sibi Services. Please send us any and all feedback pertaining to the Sibi Services to security@sibihealth.com.

YOUR CALIFORNIA PRIVACY RIGHTS

For California residents: We may share your personal information with third parties and affiliated third parties (such as local, state and regional affiliates and affiliate alliances), some of which do not share the We name, for their direct marketing purposes. As these third parties and this category of affiliated third parties are considered an unaffiliated party under California law, you may opt-out of our disclosure of personal information to third parties for their direct marketing purposes. To opt out, please contact us as described in the “How to Contact Us” Section below.

We will continue to provide your information to local, state and regional affiliates and affiliate alliances identified in your membership application or account for the purpose of processing your membership in such affiliate and affiliate alliance programs.

California Consumer Privacy Act

The California Consumer Privacy Act (CCPA), effective January 1, 2020, gives California consumers enhanced rights with respect to their personal information that is collected by businesses. First, California consumers may opt out of having their personal information sold to other persons or parties. Second, they have a right to know:

  • What specific pieces of information a business has about the consumer;

  • Categories of personal information it has collected about the consumer;

  • Categories of sources from which the personal information is collected;

  • Categories of personal information that the business sold or disclosed for a business purpose about the consumer;

  • Categories of third parties to whom the personal information was sold or disclosed for a business purpose; and

  • The business or commercial purpose for collecting or selling personal information.

In addition, California consumers can request that the personal information a business has collected about them be deleted from the business’s systems and records.

Company may be considered a covered business under the CCPA as it collects and processes the personal information of California consumers. This Privacy Policy provides the required notices to California consumers. The CCPA also prohibits covered businesses from providing discriminatory treatment to California consumers if they exercise their rights under the Act.

We do not rent or sell your personally identifiable information (such as name, address, telephone number and credit card information) to unaffiliated third parties for their marketing purposes. We may share your information with third parties to provide products and services you have requested, when we have your consent, or as described in this Privacy Policy.

To make a “request to know” or request to delete your personal information, send us an e-mail at contact@sibihealth.com (Please put either “Request to Know” or “Request to Delete” in the subject heading of your email.) We will use commercially reasonable efforts to honor these requests whether or not you would qualify as a California consumer under the CCPA.

If and to the extent we are considered a covered business under the CCPA: We will confirm receipt of your request within 30 days along with a description of what steps we will take to verify and respond. We must provide the requested information or delete your personal information within 45 days of receipt of your request but can use an additional 45 days, but we must let you know the additional time is needed.

When contacting us, we may ask you to provide certain, limited personal information, such as your name, email address and/or account login ID and/or password, to verify your request and to match with our records and systems. This is also to protect against fraud. We will not retain this personal information or use it for any other purpose. Also please be advised that we need to search our records and systems only for the preceding 12 months.

Residents of other states may also have similar rights to request information about or delete their personal information. To inquire about exercising these rights, please contact us at contact@sibihealth.com.

Pursuant to California’s “Shine The Light law (California Civil Code § 1798.983), California residents are entitled, once a year and free of charge, to request the disclosure of certain categories of personal information to third parties for their own direct marketing purposes in the preceding calendar year, if any. Under the law, a business should either provide California customers certain information upon request or permit California customers to opt out of this type of sharing. You may request this information by contacting us at contact@sibihealth.com and indicate in the email subject line, “California Shine The Light Request.” Please include your mailing address, state of residence and email address with your request.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time, and so you should review this Policy periodically. Your continued use of any Services constitutes your acceptance of any such changes.

Please send any questions or feedback pertaining to the Privacy Policy to Sibi’s Data Protection Officer at security@sibihealth.com.

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