Liberate Ideas, Inc. Privacy Policy

Modified: August 1st 2019

Introduction

We at Liberate Ideas, Inc. and Liberate Health (Liberate) are committed to protecting your privacy. This Privacy Policy applies to the information and data collected by Liberate as a controller, including the information collected on our Websites (www.liberate.com, www.Liberatehealth.com, www.liberatehealth.co.com) or through other channels as described below. It also describes your choices regarding use, access and correction of your personal information. If you do not agree with the data practices described in this Privacy Policy, you should not use the websites.

Your use of the Liberate Subscription Service (the Subscription Service) as a customer of Liberate, including use of our associated mobile applications (Mobile Apps), is covered under the Liberate Product Privacy Policy.

This Privacy Policy (this Policy) describes how our Site and the services we offer (collectively, the Services) handle and secure information collected. This Privacy Policy is part of, and incorporated into, the Terms of Use for our Site and our Services. If you have entered into a Terms of Use for one of our Services (your Terms of Use), this Policy will supplement and amend your Terms of Use. Because the Terms of Use and your Terms of Use include subjects that may not be covered in this Policy, and may narrow or modify the scope of our use of information under this Policy, please review them carefully.

We periodically update this Privacy Policy. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice by sending you an email notification, or if you subscribe to the Subscription Service, through the Notification app in your Liberate portal.

While we will notify you of any material changes to this Privacy Policy prior to the changes becoming effective, we encourage you to review this Privacy Policy periodically. We will also keep prior versions of this Privacy Policy in an archive for your review.

If you have any questions about this Privacy Policy or our treatment of the information you provide us, please write to us by email at Support@liberate.com or by mail to Liberate Ideas, Inc 26 Park Street, Suite 2056 Montclair NJ 07042 USA, Attn: Data Protection Officer.

1. Information We Collect

2. How We Use Information We Collect

3. Consents and authorizations

4. How our Services Allow Users to Share Information

5. How We Share The Information We Collect International

6. The Importance of Protecting Our Services and the Information they Safeguard

7. Cookies and Similar Technologies

8. Security

9. Third Party Services

10. Changes to this Policy

11. How to Access and Control Your Personal Data

1. Information We Collect

Information You Submit: When you use our Services, you can (depending on the Service you use) submit information by:

       Typing-in data (such as when you register for our Services, or type a message to send to us or another user, or type a search request, or complete an optional form);

       Uploading a document, image or other data file; or

       Authorizing us to retrieve and import information from another user or other third party on your behalf.

Engagement Tools and Data: Our Services also gather information whenever you visit, log in or otherwise interact with them. As with other websites and interactive services, whenever you interact with our Services, your computer, mobile phone or tablet (a Device) and its software transmit a request to us. That request includes non-personal information received from your Device (and its software) necessary for us to identify and appropriately route the information your Device is requesting. These requests and replies are the backbone of all websites and Internet services. Therefore, whenever you:

       Visit and navigate through our Services

       Click on a link

       Open a webpage or web form

       Open a web-enabled email sent by us

       Post a comment or question on a blog or user forum

       Send a message via our interactive chat or instant message feature

       Otherwise take an action or interact with elements of our Services or its pages, content or features,

your Device, and its software, are sending non-personal information to us.

In addition to managing the appropriate routing of information, we use so-called cookies; web beacons, server logs and other Engagement Tools to enhance the quality of the service and content you receive. For example, we use Engagement Tools to:

       Save user preferences;

       Preserve session settings and activity;

       Help authenticate users;

       Allow users to auto-fill sign-in pages of websites they frequently visit;

       Tailor the delivery of ads and other content; and

       Analyze the performance of our Services and its various features and content.

Therefore, even if you do not register with us or submit any personal information on our Services, our Engagement Tools automatically receive information about your Device and the software running on it. We call such data Engagement Data.

Engagement Data often includes elements such as the date and time a request is made, the model of the Device making the request, the type and version of operating system running on a Device (e.g., Mac OS or Microsoft Windows), the browser making the request (e.g., Internet Explorer, Chrome or Firefox), routing information, IP address, the Device s geographic location, search terms a user enters, what URL a Device most recently visited, and, if a mobile application is used, an anonymous unique number. Engagement Data generally does not personally identify a Device s user. However, it can be combined with personal information. If so, we treat such combined information the same way we treat personal information. Additionally, in the event that our Engagement Tools collect data elements that contain personal information, we treat those data elements as personal information.

You have the ability to control how certain Engagement Tools operate by modifying the settings on your Device or its software. Most browsers, for example, allow you to refuse accepting cookies, and many mobile Devices allow you to disable the sending of location information. In some cases, doing these things could diminish the performance of our Services or render them inoperable.

Third Party Tools: From time to time, we may receive Personal Information about you from third party sources including partners with which we offer co-branded services or engage in joint marketing activities, and publicly available sources such as social media websites. We work with certain third parties who deploy their own engagement tools on our Services. In some instances, they do so exclusively on our behalf. In other instances, they may retain and use the data they collect pursuant to publicly available privacy policies. These Third Party Tools are frequently deployed by companies providing online advertising services or analytics, but they may be deployed in other contexts as well, such as social media plug-ins. We treat personal and non-personal information that we receive from these Third Party Tools the same way we treat personal and non-personal information that we directly collect from our Services. We, however, do not control how these third parties manage the information they gather. Please see our Third Party Tools for more information.

Personal and Non-Personal Information: Information you submit to us that identifies you or can be used to contact you (e.g., email or mailing address) is your personal information. This includes identifiers that a governmental authority, financial institution or insurance carrier may use to uniquely identify you (e.g., a physician identification, patient identification). When we combine non-personal information with personal information, or non-personal information with other non-personal information in a way that renders the combined information personal information, we treat that combined information the same way we treat personal information. When we combine personal information with information from third party sources, we also treat that combined information the same way we treat personal information.

We may use your Personal Information to recommend certain resources. We may use your Contact Data to send you information about Liberate our products or Services, to contact you when necessary, including to remind you of upcoming or follow-up appointments, and in conjunction with your use of certain Interactive Tools. We may use your Demographic Data, your Traffic Data, or your Medical Data to customize and tailor your experience on the Site, in emails and in other communications, displaying content that we think you might be interested in and according to your preferences. We may also use your de-identified Personal Information to run (or authorize third parties to run) statistical research on individual or aggregate health or medical trends. Such research would only use your Personal Information in an anonymous manner that cannot be tied directly back to you.

2. How we Use the Information We Collect

Compliance with our Privacy Policy

We use the information we collect only in compliance with this privacy policy. We use personal and non-personal information (including Engagement Data) for the following purposes:

       Operating, maintaining, managing and administering our Services, including processing registrations and providing customer support;

       Responding to questions and communications, which we retain in the ordinary course of business;

       Administrative announcements about features, functionality, terms or other aspects of our Services; and, if applicable, informing you about offers for services or products we believe may be of interest (for further information, see also Service Emails and other Communications below);

       Safeguarding and protecting our Services, the information they safeguard, the rights of third parties and in response to legal process, in each case, as more fully described below in The Importance of Protecting our Services and the Information they Safeguard; and

       Any other purpose described in this Policy or your Terms of Use.

We use non-personal information for the following purposes:

       Auditing, research, measurement and analysis in order to maintain, administer, enhance and protect our Services, including analyzing usage trends and patterns and measuring the effectiveness of content, advertising, features or services;

       Creating new features and services;

       Contextual and cookie-based automated content delivery, such as tailored ads or search results;

       Health and medical research; public health and service activities; healthcare- and medical-related services; and

       Other purposes described in this Policy or your Terms of Use.

We may also use non-personal information to prepare aggregate reports for current or future advertisers, sponsors or other partners to show trends about the general use of our Services. Such reports may include age, gender, geographic, demographic or other general user information, but do not include personal information.

We Never Sell Your Personal Information

We will never sell your Personal Information to Any Third Party.

Legal Basis for processing Personal Information (EEA Visitors only)

If you are a visitor located in the European Economic Area, Liberate UK is the data holder of your personal information. Liberates Data Protection Officer can be contacted at support@liberate.com.

3. Consents and Authorizations:

From time to time, we may request your consent or authorization (your consent) in connection with the use or sharing of your information. In some instances, this will be because your Terms of Use, this Policy or applicable law or regulations requires us to obtain such consent. In other instances, such consent will be for informational purposes. In the latter case, the request to obtain your consent should not be interpreted as narrowing the scope or applicability of your Terms of Use or this Policy – by entering into your Terms of Use or using the applicable Services, you have accepted and agreed to our information handling practices in the manner described in your Terms of Use and this Policy.

In cases where you consent or opt-in to the use or sharing of your personal information in a manner that is not otherwise provided for in your Terms of Use or this Policy, unless otherwise explicitly stated in such consent, you will have the ability to rescind your consent and opt-out of our use or sharing of such information in the future. In that event, we will refrain from our use or sharing of such information, but we may not be able to require the removal of such information from the databases of the recipients with whom such information has been shared.

4. How our Services Allow Users to Share Information

One-on-One Communications: Our Services can be used to facilitate one-on-one communications between users. Examples include:

       Send a patient content: Deck, video, audio;

       Sending an appointment or other reminder to another user.

In any one-on-one communication, users are sending information to one another. Depending on the message, this could include contact and other personal information. See also Service Emails and other Communication below.

Communities, Blogs, Forums: Our Services may include publicly displayed communities, blogs and other public forums that allow users to communicate with groups of users or the general public. All information a user posts in one of our communities will be available to a wide range of individuals, and should be presumed public. We strongly advise users to exercise care in selecting what information they share with our communities or public forums, and strongly recommend against sharing any personal, health or other sensitive information that could directly or indirectly be traced to any individual, including yourself.

Records: Our Services allow users to store personal and health information (Records), including Records created for that user. Our Services permit users to share all or portions of these Records at their discretion.

You should be aware that this Policy covers only the information submitted through our Services. If you contact or exchange information with another person or through a means other than our Services, such activity is not covered by this Policy.

What Other Users Do with Information You Share with Them: Because our Services enable users to share the information you share with them, you should take care in selecting with whom you share your Records and other information. Although our Services process such transmissions, we cannot take responsibility for the actions of other users or persons with whom you share your Records and other information.

Confidentiality of Health Information: Some of our users – such as healthcare providers – are subject to laws and regulations governing the use and disclosure of health information they create or receive, such as: in the US, the Health Insurance Portability and Accountability Act of 1996 (HIPAA), the Health Information Technology for Economic and Clinical Health of 2009 (HITECH), and the European Union General Data Protection Regulation effective in 2018 (GDPR) the regulations adopted thereunder. When we store, process or transmit individually identifiable health information on behalf of a health care provider who has entered a Healthcare Provider (HCP) Terms of Use, we are prohibited from, among other things, using individually identifiable health information in a manner that the provider itself may not. We are also required to, among other things, apply reasonable and appropriate measures to safeguard the confidentiality, integrity and availability of individually identifiable health information we store and process on behalf of such providers. We are also subject to laws and regulations governing the use and information of certain personal and health information as a result of our dealing with HCP’s.

Service Emails and other Communications: Our Services may allow HCP users to communicate with patients and caregivers through our Service-branded emails, SMS and other electronic communication channels. These type of communications may be real time communications or communications triggered automatically upon the occurrence of certain events or dates – such as a repeated sign-in failure, a video email from the HCP to their patient, an appointment reminder and the like.

Email communications received from users and our administrative announcements are often transactional or relationship messages, appointment requests, reminders and other treatment or Service notifications. You can opt out of receiving certain messages and Liberate Services may provide a means to modify the frequency of receiving them. In cases in which we believe user emails are not primarily transactional or relationship messages, it will include the capability to opt-out of receiving further e-mails. If you sign-up to receive marketing or informational announcements from us, such emails will include capability to opt-out of receiving such e-mails in the future.

Our Services may deploy Engagement Tools (such as cookies, web beacons and server logs) on outbound emails to users and others to collect Engagement Data, and we may use vendors to assist us in sending outbound emails to users who may deploy Third Party Tools.

Emails and other communications from individuals who are not users of our Services, or that are being sent in connection with business, agreements or subject matter other than your Terms of Use or your use of our Services, are not covered by this Policy. If, for example, you contact us regarding a job opening, that communication to us is not covered by this Policy even though that job opening may have been posted on our Services. Likewise, if you submit to us any ideas, suggestions or proposals (collectively, Suggestions) relating to our Services or other products or services by any means – such as through Contact Us, by email or other communication channels, one of our communities or user forums, or to our customer support or other personnel – such Suggestions are not governed by this Policy.

5. How We Share Information We Collect

We will not share personal information you submit except under the following circumstances:

       When you choose to share such information through our Services. Under certain circumstances this may require a specialized consent before our Services complete certain such transmissions;

       When you are otherwise notified at the time we collect such information or we otherwise have your express consent;

       When we share such information with our current and future affiliates;

       When we share such information with trusted service providers operating on our behalf consistent with the terms of this Policy and your Terms of Use. Such service providers shall be bound by appropriate confidentiality and security obligations, which may include, as applicable, business associate contract obligations. We will not sell, rent or trade your personal information with any third parties for their promotional or marketing purposes, except that we may permit our trusted service access to your personal information to provide return on investment analysis to our sponsors.

       When we protect our Services, the information they safeguard, the rights of third parties and in response to legal process, as more fully described below in The Importance of Protecting our Services and the Information they Safeguard;;

       In connection with a sale, merger, transfer, exchange, reorganization or other disposition (whether of assets, stock, or otherwise) of all or a portion of the business conducted by the services to which this Privacy applies. If such a transaction occurs, the acquiring company s use of your personal information will remain subject to this Policy; and

       Any other purposes described in this Policy or your Terms of Use.

It is important for you to understand that other users who submit to, or receive from, our Services personal information about you, may share that information with other persons, even without separately notifying you or seeking your consent.

6. The Importance of Protecting our Services and the Information they Safeguard

Many of our Services are protected by technical measures intended to safeguard the confidentiality, integrity and accessibility of sensitive information our users store and share on our Services. Further, certain regulations require us to investigate potential or suspected threats on our Services or the confidentiality, integrity or availability of the information they safeguard. Accordingly, we may preserve, use and disclose information – including personal and non-personal information – when we have a good faith belief it is necessary or advisable to:

       Detect, prevent and address potential or suspected: threats on our Services or the confidentiality, integrity or availability of any information they house; fraud and other illegal activity; or violations of our Terms of Uses or Terms of Use; and

       To protect ourselves, you and third parties.

We may also preserve, use and disclose such information in response to a search warrant, court order, subpoena, judicial proceeding or other legal process if we have a good faith belief that the law requires us to do so. Such legal process may prohibit us from notifying the users or other individuals or entities identified by such information or take such other actions, as would otherwise be a violation of your Terms of Use or this Policy. When we preserve information pursuant to this section, it may be for extended periods of time, as we in good faith believe are necessary or appropriate under the circumstances, and may include the preservation of information from accounts that have been disabled.

7. Cookies and Similar Technologies

Cookies

Liberate and its partners use cookies or similar technologies (such as web beacons) to analyze trends, administer the website, track users’ movements around the website, and to gather demographic information about our user base as a whole. To find out more about how we use cookies on our Websites and how to manage your cookie preferences please see our Cookie Policy.

Navigational Information Collected by Our Customers

Our customers can use the tools we provide, as well as tools provided by third parties, to collect Navigational Information when you visit their webpages on via the Service. Liberate does not control our customers' use of these tools, nor do we control the information they collect or how they use it.

Flash Cookies and Other Third Party Tracking Technologies

The Adobe Flash Player (and similar applications) use technology to remember settings, preferences and usage similar to browser cookies but these are managed through a different interface than the one provided by your Web browser. This technology creates locally stored objects that are often referred to as "Flash cookies." Liberate does not use Flash cookies. However, our customers of our platform may create pages that employ Adobe Flash cookies. For more information on "Flash cookies" and how you can manage them please visit our Cookie Policy.

Advertising

We partner with a third party ad network to either display advertising on our Web site or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect information about your activities on this and other websites to provide you targeted advertising based upon your interests. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by clicking here: http://preferences.truste.com/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising. You will continue to receive generic ads.

Third Party Tracking Technologies

The use of cookies and web beacons by any tracking utility company is not covered by our Privacy Policy or Cookie Policy.

8. Security

The security of our Services and the information they store, process and transmit is a top priority. To prevent unauthorized access, maintain data accuracy, and ensure the appropriate use of the information we collect, we deploy a wide range of industry recognized technical, physical and administrative safeguards. Under our Healthcare Provider Terms of Use and applicable law, we are required to apply reasonable and appropriate measures to safeguard the confidentiality, integrity and availability of individually identifiable health information residing on and processed by our Services. It is important to remember, however, that no system can guarantee 100% security at all times. Accordingly, we cannot guarantee the security of information stored on or transmitted to, or from, our Services.

 

9. Third Party Services

This Policy applies only to our Services. It does not apply to services offered by third parties, including websites and other online services that our Services may display links to or advertisements for. When you click on such links or advertisements, you will be visiting websites or interactive services operated by third parties, who have their own information collection practices and may also collect information through the use of tracking tools, such as cookies, web beacons, server logs and the like. When you click on or interact with an ad appearing in our Services, the advertiser or sponsor may infer that you meet targeting criteria that they may have used in connection with the sponsoring such ad. This may lead to similar ads being targeted to you on our Services or elsewhere. We do not have control over how any third party gathers or uses information, so you should review their privacy policies to learn of their information gathering and handling practices.

10. Changes to this Policy

We work hard to continuously improve and enhance our Services. Some of these improvements and enhancements may result in changes to this Policy. We will post such changes along with their effective date on this page, and if the changes are significant, we will provide a more prominent notice. Because our Policy can change at any time, we encourage you to reread it periodically to see if there have been any changes that affect you. If you disagree with any changes to this Policy and do not wish your information to be subject to the revised Policy, you will need to deactivate your account before the new Policy becomes effective. Your use of our Services following any such change constitutes your agreement that all information collected from or about you through our Services after the revised Policy is posted will be subject to the terms of the revised Policy.

11. How to Access and Control Your Personal Data

Our Services aim to provide you with access to the personal information you submit and the means to update it. This can be accomplished by logging into our Services or contacting us using the contact information below. Under certain circumstances, we may ask you to verify your identity before your request is processed. This will be done free of charge except where it would require a disproportionate effort. We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup tapes).

If you desire to deactivate your account you may do so through your account profile page. Upon confirming that you genuinely wish to delete your account, your account will be deactivated and your personal information and Records will be made permanently inaccessible, including to us. Residual data may continue to exist in an encrypted form on secure data backups.

We retain archived information for a period of five years (or longer if required by law) as necessary to comply with legal obligations, resolve disputes and enforce our agreements and other authorized uses under this Policy.

Applicable law grants patients certain rights to access and correct certain health information their healthcare providers retain about them. Patients should submit requests to access or correct their health information directly to their healthcare providers.

You should also be aware that we store indefinitely non-personal information, including Engagement Data and de-identified health information, as well as all information that you have share on any of our public forums, blogs, communities, surveys and the like.

Contact Us:

If you have any comments, concerns or questions about this Privacy Policy, please contact us at: 

 

Privacy

Liberate Ideas, Inc.

26 Park Street

Suite 2056

Montclair, NJ 07042

 

Phone: 1-973-509-4671

Data Protection Officer (DPO): Collin Nordstrom

Email: support@liberate.com

 

Last Updated August 1st 2019