The Mobile Health program (the “Program”) is a voluntary employee health program that encourages healthy lifestyle changes. The Program is paid for by your employer, your spouse’s employer or other sponsoring organization (the “Program Sponsor”) and operated by Mobile Health Consumer, Inc., a corporation organized under the laws of the State of Delaware, headquartered at 530 Lytton Ave Ste 200, Palo Alto, CA, 94301-1541 (“Mobile Health”, “Us”, “We” or “Our”).
This Privacy Notice applies to US and non-US users for all Mobile Health Programs, unless there is a specific Privacy Notice published for that program or for a particular region.
This Privacy Notice (the “Notice”) explains what data We collect about you and how We store, analyze and share the data We collect about you through the platform and the mobile applications (CarePlus Mobile Health). This Notice applies to all Personal Information whether collected online or offline. The Notice also explains your rights with regards to your data, and how to contact Us to request access, corrections, transfer, restriction, or deletion of the data We have collected about you.
We have designed this Privacy Notice in a question and answer format to make it easy to read and understand. Please read through it carefully. If you do not agree with Our policies and practices contained in this Notice, please do not enroll in the Mobile Health Program.
Yes. We collect anonymous and Personal Information about you to provide you with the Program and Our services. “Personal Information” means any information, including personal and material circumstances, that allows a person to become identifiable. The Personal Information We collect includes, but is not limited to:
Please keep in mind that the extent of the Personal Information you may be able to share with Us will depend on the Program design and the features made available to you, as well as your level of participation in the Program. You are under no obligation to provide any Personal Information to Us at any time. However, if you choose to withhold some Personal Information, We may be unable to provide you with certain services.
We will use the Personal Information collected only to provide you with access to Our services, including:
We may, from time to time, send you push notifications to provide you with reminders and notices. If you no longer wish to receive such communications, you may turn them off at the device level.
From time to time, We may send you e-mails with information about your Program, any available features, or related services. You may opt-out of Our communications, free of charge, at any time, by clicking the “Unsubscribe” link at the bottom of the e-mails, or by contacting Support directly.
We collect Personal Information you voluntarily provide as you submit it through the web-based platform and the mobile application, by reviewing your use of the web-based platform and mobile application (for example through the participation in a challenge, or completion of a wellbeing questionnaire), and your use of a synched tracking device. We may also collect information about you and your participation in the Program through engagement surveys. Depending on your Program design, your Program Sponsor may have the opportunity to create surveys (the “Mobile Health Surveys”) for its Members to complete.
When you register for an account to use the Program or at any later time, you may provide to Mobile Health Consumer what is generally known as "personally identifiable information" (such as your name, password, email address. Certain features of the Program may permit you to upload your photo and provide certain health-related information if you so choose and if Mobile Health Consumer deems it necessary or helpful in the provision of the Program or any part thereof. If you choose to provide such information, during registration or otherwise, you are giving Mobile Health Consumer the permission to use and store it consistent with this policy.
Mobile Health Consumer may also obtain information, including personally identifiable information, from third parties and sources other than the Program. If Mobile Health Consumer combines or associates information from other sources with personally identifiable information that it collects through the Program, it will treat the combined information as personally identifiable information in accordance with this Privacy Policy.
We may also automatically collect additional information when you visit Our web-based platform or mobile application, including the type of browser used, the files viewed on Our site (e.g., HTML pages, graphics, etc.), date and time stamps of activity on the platform, and the accessing user. We use this additional information to derive a broad understanding of the locations from which Our Users access Our services, and to enhance the security controls around platform access. We also use it to analyze trends, administer the web-based platform, track User’s movements on the platform and around the website.
Depending on your Program design, your Program Sponsor may be able to create and submit customized Mobile Health Surveys for its Members to complete. If you decide to take part in a Mobile Health Survey the results will be shared with your Program Sponsor in aggregated reports. Your Program Sponsor will not be able to identify you from these reports. However, if the survey offered gives you the ability to respond to a question by writing in a response, the response will be shared with the Program Sponsor. If you include identifiable Personal Information in these open-ended responses, your Program Sponsor may be able to identify you.
Depending on your Program design, you may have access to a wellbeing questionnaire. Wellbeing questionnaires can be customized by Program Sponsors and may be used to assess your overall health, your lifestyle across multiple areas of wellbeing or both. You do not have to complete wellbeing assessments if you do not want to share this type of information with Us.
As is explained in the Terms of Service, the Program is designed for adults over the age of 18. We do not knowingly collect Personal Information about children under the age of 13. If you have reason to believe that We have collected Personal Information about anyone under the age of 13, you can contact Us to remove the Personal Information.
As a Program Member, you will be able to connect tracking devices, such as smart watches, smart scales and other devices, to your account. If you choose to synchronize a tracking device with the Program, We will receive limited information about your activity to populate your account. Tracking devices can track a wide number of different aspects of your daily activities, including, among others, your daily steps and fitness activity, your heartbeat and sleep pattern. Depending on the brand and model of tracker you use, the data collected may vary. In general, companies selling tracking devices have specific privacy policies available, which outline what data the specific activity tracking device collects. We strongly suggest you review the right privacy notice to know what specific data points your activity tracking device collects about you.
You may authorize third parties to provide certain data to us, such as fitness tracker information through third-party devices, applications or services (for example, Apple HealthKit or Google Fit platforms). By linking your tracking device or tracking application through the Services, the Services will have access to your data (such as your daily steps and fitness activity) collected through such tracking device or tracking application. At any time, you can unlink your tracking device or tracking application to the Services by revoking access through the applicable tracking device or tracking application, which stops the flow of your data from that specific tracking device to the Services.
You may authorize third parties to provide certain data to us, such as fitness tracker information through third-party devices, applications or services (for example, Apple HealthKit or Google Fit platforms). By linking your tracking device or tracking application, We will receive limited information about your activity to populate your account. Tracking devices can track a wide number of different aspects of your daily activities, including, among others, your daily steps and fitness activity. Depending on the brand and model of tracker you use, the data collected may vary. In general, companies selling tracking devices have specific privacy policies available, which outline what data the specific activity tracking device collects. We strongly suggest you review the right privacy notice to know what specific data points your activity tracking device collects about you. At any time, you can unlink your tracking device or tracking application to Us by revoking access through the applicable tracking device or tracking application, which stops the flow of your data from that specific tracking device.
Yes. We may receive information about you from various sources to support the Program and services included in it. The sources may include:
Depending on your Program design, your Program Sponsor may provide Us your Personal Information to identify you as an individual who is able to join the Program and become a Member. We call this an “Eligibility File”. Please contact your Program Sponsor directly if you wish for your Program Sponsor to stop sending Us information about you. Keep in mind that if you are removed from the Eligibility File you will no longer have access to the Program and will not be able to enroll in the Program.
In some cases, your Program Sponsor may offer benefits through other providers that integrate with the Program. At the direction of your Program Sponsor, We may exchange data with these other providers to provide Our services to you. We may send them information, such as an employee ID, identifying who you are. They may send Us information about you specifically related to participation in the Program, either before or after you begin participating in the Program.
Depending on your Program design, you may have access to organizations through Our Program that partner with Us to provide you additional health and related services (Our Program Partners). If you use these services, the Program Partners may share activity information and results with Us. This data sharing would be limited to information necessary to support your wellness activities or manage incentives (if applicable) in the Program.
Mobile Health, its Program Partners and vendors use tools such as Cookies, tags, scripts and other similar technologies to enhance and support your experience on the platform. These technologies help Us administer the web-based platform and mobile application, measure traffic patterns and the total number of users, as well as to personalize and customize the platform’s content, so that your settings are “remembered” when you login.
“Cookies” are small pieces of text sent to your browser by a website you visit. Cookies help Our web-based platform to remember information about your visit, like your preferred settings. Cookies play an important role, they can make your next visit easier and the web-based platform more useful to you. You can learn more about Cookies by visiting www.allaboutcookies.org, where you will also find information about how to block Cookies on different types of browsers. Depending on your location, additional information about Cookies may be presented to you when you visit the web-based platform, and you are given the opportunity to object to the use of Cookies. However, please be aware that by blocking or deleting Cookies you may not be able to take full advantage of the web-based platform or mobile application.
Our web-based platform uses Cookies to collect information about Member usage of the Program. Additionally, some Cookies on Our web-based platform may be set by third parties who are delivering services on Our behalf. Within the mobile application, webpages are sometimes displayed. Cookies allow you to avoid having to reenter your login credentials when accessing webpages.
We use Cookies:
We use analytics software to allow Us to review the functionality of Our software, and how to improve its quality and Our services. The analytics software may record information such as how often you use the application, the events that occur within the application, crash reports and performance data, and other metrics, such as aggregated usage.
Our web-based platform and mobile application may contain links to other websites that We do not own or control. We provide these links and connections for your convenience. We have no control over these third parties, their privacy policies, and the content they display on their websites or mobile applications. If you choose to submit Personal Information while visiting these websites or using these mobile applications, please be aware your rights will be governed by the third parties’ privacy policies. We strongly encourage you to carefully read the privacy notice of any website or mobile application you visit or use.
We rely on role-based access and only grant access to Our employees, contractors and agents who are involved with delivering the Program services to you according to Our policies and procedures. Our employees, who are located in the United States, may be required to access your Personal Information to provide you with quality services, including user support through Mobile Health Email Support. Our employees are obligated to respect the confidentiality of your Personal Information and are only authorized to access your Personal Information as necessary to provide you with services or support. Examples of the employees who have access to your Personal Information include Our member services staff, billing staff and Our data reporting staff.
You can participate in Challenges with other members of the Program offered by your Program Sponsor. If you choose to participate in Challenges, other Members who choose to participate in the Challenges will have access to (a) certain portions of your profile, (b) the number of steps you have taken in challenges you choose to participate in, and (c) other activity data related to your participation in the Program.
By joining a Mobile Health Program, your name, profile picture (if you add one) and challenge performance information (step information added to your account) will be visible to other Members in the Program. Additionally, some performance information such as a leaderboard may be shared with your Program Sponsor on an individual or team basis.
Additionally, the Program may make message boards and messaging forums available to you. Please be aware that any information disclosed in these settings may become public information. You should exercise caution if disclosing Personal Information while using these features.
The type of information We share with your Program Sponsor depends on who your Program Sponsor is. In general, across all types of Program Sponsors, We share aggregated data with your Program Sponsor where permitted by law. Your Program Sponsor will not be able to use such aggregated data to directly identify you. Your Program Sponsor may use the information in its discretion, including to evaluate the overall program, as well as to provide additional benefits, programs and services.
In specific circumstances and for limited purposes, such as to ensure proper Program administration or to support tax compliance, We may share reports containing identifiable information with your Program Sponsor where permitted by law. In these circumstances, We limit the Personal Information to the least amount necessary to support the specific, necessary purpose.
If your activity information indicates there may be an abnormality or Program abuse, We may share your activity information with your Program Sponsor where permitted by law, and make adjustments, or suspend or terminate your account, in accordance with your Program Sponsor’s instructions.
We may, from time to time, share your Personal Information with third parties to allow Us to provide you with Our services. If We need to share your Personal Information with third parties, We will limit the information disclosed to the minimum amount necessary to ensure the provision and quality of the services We offer you. We never use, disclose, or share your Personal Information for marketing purposes, and We never sell, rent or lease your Personal Information. Subject to any limitations imposed by applicable laws, We reserve the right to disclose aggregated Data at Our discretion.
In certain situations, Mobile Health may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In the event that We (a) undergo reorganization or liquidation under bankruptcy, or (b) are sold to a third party, any Personal Information We hold about you may be transferred to the reorganized entity or third party, in accordance with applicable laws. In any such event, the new entity will continue to use your Personal Information in accordance with and within the limits of this Notice to ensure continuation of service.
Your Program Sponsor may have engaged Our services through a distributor or aggregator service. If directed to do so by your Program Sponsor, We may share limited amounts of Personal Information with these services related to your participation in the Program to facilitate coordination of services across multiple health and wellness providers.
We may use or disclose your Personal Information to allow your participation in additional third-party provided wellness services or to support the administration of the Program. These third parties may be Our partners (“Program Partners”), your Program Sponsor, or other entities your Program Sponsor contracts with directly (“Third Party Providers”).
We may provide information in an aggregated format or provide your Personal Information in a group format to third parties that process that Personal Information (“Analytics Processors”) to derive analytical information. The Analytics Processors do not have any independent right to use your Personal Information, except to provide the aggregation and analysis services.
Our Program Partners are industry leading health, wellness and wellbeing providers We select to enhance your experience. In certain instances, the use of such Program Partners may require you to provide additional Personal Information and data to these Program Partners. If you choose to use Program Partner services or you provide additional Personal Information and data to these Program Partners, you will be subject to the Program Partner’s privacy notice and terms of use.
We may be required to disclose your Personal Information if:
From time to time We may need to disclose limited amounts of your Personal Information. We limit Our disclosures to the least amount of information required to meet the permissible purpose. We disclose your Personal Information for the following limited purposes:
All your data, including any Personal Information We collect about you, is stored at Amazon Web Services data centers located in the United States of America (USA). Because your data is stored on USA soil, it may be subject to USA laws, including the “Uniting and Strengthening America by Providing Appropriate Tools Required to Intercept and Obstruct Terrorism Act of 2001” (USA PATRIOT Act), as well as the jurisdiction of the USA government, tribunals, law enforcement and regulatory agencies, which may require Us to grant them access to your data.
We are committed to protecting your data and your privacy. To ensure data security, We follow reasonable physical, electronic and managerial procedures designed to safeguard and secure your data and Personal Information. However, no company can fully eliminate security risks associated with the provision of online services. Transmission of personal information to and from our Sites is at your own risk. You should only access the services within a secure environment.
Among the security features We use to protect your Personal Information and other data, We require that you use a unique username and password to access the web-based platform and mobile application. We use multiple layers of security to protect your Personal Information and data, including antivirus software.
When We receive Personal Information from a third party, or share Personal Information with a third party, We execute appropriate written agreements based on the applicable jurisdiction. For example, We execute EU approved standard contractual clauses with Our subcontractors that assist us in processing EU based data, as the data exporter.
Various laws from around the world establish varying levels of data subject rights. At Mobile Health We strive to provide a similar level of data rights to all Our non-US members, regardless of where they live, but some of those rights are governed by local laws. In addition to the basic rights of confidentiality, those rights include:
Yes, you can review and change your Personal Information. Except in specific circumstances identified by local laws, you have a legal right to access and correct or update the information We have collected about you. You can request a copy of all the Personal Information and data We hold about you. We will provide you with a copy of all the data We have collected about you in a standard format (such as Excel) through a secure channel. You can contact Us via an email to Support to request a copy of all your Personal Information or to request a change in your Personal Information. We will respond to your request within a reasonable timeframe.
Please keep in mind that We may not be able to accommodate your request if We reasonably believe the change would violate any laws or cause the information to be inaccurate or incorrect. Additionally, We may not be able to fulfill a request where it would impose a burden on Us that is disproportionate to the risk to your privacy, or where your request may affect another individual’s rights to privacy. If We are unable to fulfill a request We will provide you with the reasons why We are unable to comply.
Yes, you can request that We delete your account, Personal information, identifying information and data from Our system by emailing CarePlusSupport@mobilehealthconsumer.com. After you make this request, please note that while most of your information will be deleted within 30 days, it may take up to 90 days to delete all of your information, like the data stored in our backup systems. This is due to the size and complexity of the systems we use to store data. Please also note that we will retain your information under these circumstances:
Following your deletion request, We may still receive some information about you on your Program Sponsor provided Eligibility Files. To remove your information from these sources you will need to submit that request directly to your Program Sponsor.
You will not be able to claim any incentive rewards (if applicable) after We terminate your Membership.
Beyond the information necessary for enrollment you are not required to share any additional information with Us, however, choosing not to share information may limit your ability to participate fully in a Program - including the ability to earn Rewards if they are made available to you by your Program Sponsor. You can choose to limit the data you share with Us by not inputting or not using certain features. However, once you have shared information, We are unable to accommodate requests to restrict the processing of certain sets of data. If you wish for Us to stop processing parts of your data, you can request that We delete your identifying information from Our system (as described above).
Yes, you can object to Our processing of your data by contacting the Privacy Officer and notifying Us that you wish for your account to be suspended while your concerns about the processing of your data are resolved. Once you feel comfortable resuming use of the Program, you can contact Us to unlock your account. If you realize during the time your account is suspended that you do not feel comfortable resuming use of the Program, you can request that We delete your identifying information from Our system (as described above). Your data will be deleted in accordance with Our standard process, except that you will not be able to access your account while the cancellation process takes place unless you first request for the suspension to be lifted.
We may update this Notice from time to time to reflect changes in Our information practice and services offered. The date indicating the last update can be found at the top of the Notice. If there are changes in the Notice We may correct them without notifying you.
If you have a privacy or data use concern, please contact us by sending an email to CarePlusSupport@mobilehealthconsumer.com.
We comply with any applicable laws and regulations based on your physical location, according to the information provided to Us in the Eligibility File (described above).
The level of data protection established in the USA is generally lower than the one established in the European Union (EU) and other countries with data protection laws similar to the EU; therefore, We take measures to ensure that your Personal Information is stored safely with Us, meeting regulatory privacy and security requirements imposed on EU businesses. Nothing in this Notice limits or attempts to limit your rights under applicable laws, including your ability, depending on your country of residence, to file a complaint with your local Data Protection Authority.
We ensure the lawful transfer of personal data from the EEA, UK and Switzerland to the US through mechanisms such as the Standard Contractual Clauses, as approved by the European Commission.
Please note that any translation of this Notice is intended solely to facilitate your access to this information. The English version is the only official version of this Notice and any translation inaccuracies or discrepancies are not binding and have no legal effect for compliance or enforcement purposes.
If you have general questions about your Program, you can contact Member Services by sending an email to CarePlusSupport@mobilehealthconsumer.com.
If you have any questions, comments or concerns, about this Notice, or your rights and obligations under this Notice, you may contact Us via email at CarePlusSupport@mobilehealthconsumer.com.
Alternatively, you can contact Us by writing to:
Data Protection Officer
Mobile Health, Inc.
530 Lytton Ave Ste 200. Palo Alto , CA, 94301