OPUM Privacy Policy
Last Updated: 31st July 2020
This Privacy Policy explains how OPUM Technologies, Inc. (“OPUM,” “we,” “us,” and “our”) collects, uses, and discloses information about you, a healthcare provider or product user (each considered a “User”), through its website, mobile application, and other online products and services (collectively, the “Services,” as defined below) or when you otherwise interact with us.
We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification). We encourage you to review the Privacy Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.
Contents
Important Definitions
Collection of Information
Use of Information
Sharing of Information
Advertising and Analytics Services Provided by Others
Security
Rights Specific to Californians
Your Choices
Other Important Information
Contact Us
Important Definitions
The following definitions are provided to assist you in understanding our Privacy Policy.
Service or Services. Our website, mobile application, web application, other online products and services, devices, products, and software as accessed by a user whether or not a user has an account.
Personal Information. Personal Information is information that can identify you, either alone or in combination with other information. Personal Information includes sensitive or special categories of personal information such as health information including information related to health and wellness, medical and surgical procedures, medical tests ordered and related results, and medical records including information, treatment, therapies, and other health-related information submitted through our Services (“Health Information”). Please review the “Use of Personal Information” section below for more details.
Healthcare Providers. Healthcare providers are individual physicians or allied health professionals (e.g., physical therapists) who contract with OPUM to incorporate our Services as a component of their products or services (e.g., physical or post-surgical rehabilitation program improve one or more areas of health and wellness).
De-identified Information. De-identified information does not identify you based on individual pieces of information or combinations of information. Your direct information (e.g., name) and indirect information (e.g., Device ID) are removed, such that you cannot be reasonably re-identified as an individual.
Aggregate Information. Your personal information is combined and compiled with other individuals’ personal information for the purpose of analysis and improving our Services.
Collection of Information
Information You Provide to Us
We believe in keeping confidential the Personal Information entered into our Services. To this end, we maintain your Personal Information in compliance with applicable privacy and security rules, License Agreement and Terms of Purchase, and End User License Agreement.
We collect Personal Information as part of providing Services to our users (both healthcare professionals and product users). Upon becoming a user of our Services, we collect Personal Information you authorize for submission to OPUM. For example, we collect Personal Information when you:
Create an account or profile;
Purchase a product or Services;
Participate in any interactive features of the Services;
Fill out a form or assessment survey;
Upload medical records;
Add or attach information via the notes function;
Communicate with us via third party social media sites;
Request information or assistance from us, including correspondence with our customer service team; or
Otherwise communicate with us.
The categories and types of Personal Information we collect directly from you include:
Identifiers, such as your name, username, e-mail address, phone number, mailing address, date of birth, and any other Personal Information that you choose to provide;
Demographic information, such as age, height, weight and gender (note that some demographic information may be considered characteristics of protected classifications under state or federal law);
Health Information (e.g., biomechanics, activity, regimen compliance, clinical outcomes etc.);
Payment information, such as payment and billing information;
Visual and audio information, such as photos and videos; and
Any other information you choose to provide or you authorize to be collected from or uploaded by healthcare providers, health tracking devices (e.g., exercise or other activity data), or third parties.
Automatically Collected Information
When you access or use our Services, we automatically collect information about you, including:
Transactional Information: When you make a purchase or subscribe to our Services, we collect information about the transaction, such as product details, purchase price, and date and location of the transaction.
Log and Usage Information: We collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to our Services. You may interact with our customer service team during the use of our Services, in which case, we would collect information about your communications.
Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware type and model, operating system and version, unique device identifiers, IP address and browser type, Internet service provider (ISP), mobile advertising ID, media access control (MAC) address, language preferences and location, date and time of your access to the Services, internet service provider, internet domain and host name, referral URL, and mobile network information.
Location Information: In accordance with your device permissions, we may collect information about the precise geolocation of your device. We may also use your IP address to estimate your approximate location. For more details, please see the "Your Choices" section below.
Information Collected by Cookies and Other Tracking Technologies: Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which a Service areas and features are popular and count visits. Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. To learn more about our practices and the controls available to you, please review our Cookie and Tracking Technology Policy. For more information about cookies and how to disable them, please see the "Your Choices" section below.
The categories and types of Personal Information we may automatically include:
Identifiers, such as your name, email address, or Device ID; and
Other information that relates to or is capable of being associated with you, such as location information and transaction history.
Information We Collect from Other Sources
We may obtain information from other sources and combine that with information we collect through our Services. For example, for product-users, we may collect Personal Information from healthcare providers and other third parties such as health tracking devices and electronic medical record systems (“EMR”). Additionally, if a product-user creates or logs into our Services through a social media site we will have access to certain information from that site, such as the product-user’s name and account information, in accordance with the authorization procedures determined by such social media site.
The categories and types of Personal Information we may collect from other sources include:
Identifiers, such as your name, email address, user name or ID; and
Other information that relates to or is capable of being associated with you, such as medical appointment dates (including testing and results) and location information from your health tracking device.
Use of Personal Information
We use the information we collect to provide, maintain, and improve our Services. Examples of how we use your information include:
Processing your registration and related transactions for the Services, including authenticating your identity and access to the Services, and creating and managing your online account and profile;
Collecting Personal Information entered by you, imported by you (e.g., from your OPUM or other health tracking device), or authorized by you (e.g., medical records);
Transmitting information to a third party that you authorize to receive your Personal Information through our Services;
Developing, enhancing, and providing the Services you request or that are reasonably anticipated within the context of our ongoing relationship;
Undertaking activities to maintain and improve the quality of our websites and Services, including by conducting internal research and development to improve the Services and the products that we offer;
Responding to your requests and any other communications from you, including providing customer service;
Analyzing and auditing your use of and engagement with our Services for trends and statistics and to assess patterns of use and understand your interests and behaviors to customize your experience on our Services;
Providing advertising or marketing services about products, services (including our Services), offers, promotions, rewards and events offered by OPUM and others, and providing news and information that we believe may be of interest to you;
Creating an export of your Personal Information based on your authorization;
Sending you account notifications and updates about your Services;
Conducting scientific and statistical research and studies;
De-identifying your data which we may use and disclose for any purpose;
Troubleshooting our Services or enforcing our License Agreement and Terms of Purchase and/or End User License Agreement;
Sending you technical notices, updates, security alerts, support and administrative messages;
Detecting security incidents and protecting against malicious, deceptive, or illegal activity, including fraudulent transactions, error, negligence, and breach of contract, and protecting against harm to the rights, property or safety of OPUM and our users, and healthcare providers;
Debugging to identify and repair errors that impair existing intended functionality of our Services, such as problems with our websites or servers;
Complying with our legal obligations, including our tax obligations, those related to an applicable legal process, an enforceable government request, or the prevention of fraud and money laundering, and those required for you to benefit from rights recognized by law, or any regulatory requirements or provisions; or
Carrying out any other purpose described to you at the time the information was collected.
Use of Non-Personal Information
We may also use non-Personal Information such as Aggregated or De-identified Information to study population health, wellness, chronic, or physical conditions to better understand trends and metrics that may improve Services.
Sharing of Information
OPUM does not sell your Personal Information. We may share Personal Information to the categories of third parties and for the purposes described below, or as otherwise described in this Privacy Policy:
With Service Providers. We share Personal Information with unaffiliated companies or individuals we hire or work with that perform services on our behalf, including customer support, web hosting, information technology, payment processing, product fulfilment, fraud control, direct mail and email distribution, contest, sweepstakes and promotion administration, and analytics services. We only share with service providers the Personal Information that they need to perform services for us.
With Third Parties. We do not share or sell Personal Information with unaffiliated companies or individuals for their own services or marketing purposes.
With Our Professional Advisors. We share Personal Information with our legal, financial, insurance, medical, and other advisors in connection with the kinds of corporate transactions described above or in connection with the management of all or part of OPUM’s business or operations.
In Corporate Transactions. Personal Information may be disclosed or transferred as part of, or during negotiations of any purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization, or financing involving OPUM.
With Law Enforcement Authorities and Individuals Involved in Legal Proceedings. We disclose Personal Information when we believe doing so is reasonably necessary to comply with applicable law or legal process (including requests from authorities), to respond to claims (including inquiries by you in connection with your purchases or use of our Services), or to protect the rights, property or personal safety of OPUM, our users, employees or the public.
With Your Consent or at Your Direction. We share Personal Information with third parties when we have your consent to do so. For example, if you decide to participate in certain interactive areas or features of our websites, you consent to or are directing the disclosure of this information to other users of our website and Services. We may also share your Personal Information with third parties, when you intentionally direct us to do so or when you use our Services to intentionally interact with such third parties.
We may also share Aggregated or De-identified information, which cannot reasonably be used to identify you. For example, we may share Aggregated or De-identified health outcomes information with medical device, insurance/payor, and/or pharmaceutical/biotechnology companies to facilitate research, development, and/or improvement of related therapeutic options..
Advertising and Analytics Services Provided by Others
We may allow others to provide analytics services and serve advertisements on our behalf across the internet and in applications. These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked and conversion information. This information may be used by OPUM and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” or “Opt Out of Ads Personalization” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes.
Security
OPUM takes reasonable measures including reasonable technical, physical, and administrative controls, designed to protect your Personal Information from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction. We maintain safeguards such as data backup, audit controls, access controls, and data encryption. Our Site and Services use Secure Socket Layer (SSL) technology to encrypt all connections to and from our Site and Services to enhance security of electronic data transmissions. However, no data transmission or storage system is guaranteed to be 100% secure. If you have questions about security or possible reason to believe that your interaction with our Site or Services is no longer secure (e.g., you feel that your account’s security may be compromised), please contact us immediately at support@OPUMtechnologies.com.
Rights Specific to Californians
California Civil Code Section 1798.83 entitles California customers to request information concerning whether a business has disclosed personal information (as defined in the law) to any third parties for their direct marketing purposes. We will not disclose your personal information (as defined in the law) to non-affiliated companies for their direct marketing purposes without your consent. California customers who wish to request further information about our compliance with this law or have questions or concerns about our privacy practices and this privacy policy may contact us as specified in the “Contact Us” section below.
Your Choices
As the owner of your Personal Information, you have certain rights, protections, and choices under law regarding the processing of your Personal Information. If you would like to exercise any of these rights, you may contact us as specified in the “Contact Us” section below.
Access
OPUM will take reasonable steps to ensure the Personal Information it holds is accurate, complete and up to date. Upon your written request, subject to certain exceptions provided by law, OPUM will inform you of the existence, use, and disclosure of your Personal Information and give you access (a copy) to that information.
Amendment
If you believe that the Personal Information OPUM holds about you is not accurate, complete, or up to date you may contact us as specified in the “Contact Us” section below. If you are able to establish that the information is not accurate, complete or up to date, with written request and subject to certain exceptions provided by law, OPUM will take reasonable steps to correct the information so that it is accurate, complete and up to date.
Deletion
You may request that we delete the Personal Information we have collected from you. Please note that we may retain certain information as required or permitted by applicable law. You may request that we delete Personal Information or deactivate your account by emailing support@OPUMtechnologies.com or contact us toll free at +1 (858) 333 5092 (from USA)/0800-220 7070 (from NZ) to make the request. If you request to delete your Personal Information, certain of our products and Services may no longer be available to you. Please note, we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
Disclosure
Upon your written request, subject to certain exceptions provided by law, OPUM will inform you of to whom it has disclosed your Personal Information.
Location Information
When you first launch any of our Services that collect location information, you will be asked to consent to the application's collection of this information. If you initially consent to our collection of this location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device. If you do so, our Services, or certain features thereof, may no longer function properly.
Marketing Communications Choice
You may opt out of receiving promotional emails or text messages from OPUM by following the instructions in those emails or text messages or, if you have an account with us, managing your communications preferences by logging into your account online by emailing OPUM support@OPUMtechnologies.com and the specific nature of your request. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.
Other Important Information
Cookies
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Children
OPUM recognizes the privacy interests of children and OPUM encourages parents and guardians to take an active role in their children's online activities and interests. We do not knowingly sell the personal information of users under 18 years old without the permission of such users’ parent or guardian.
Data Retention
If you visit the Site, whether or not you become a user of our Services, we maintain web logs to record data about all Site visitors who use this Site and interact with the Services. We store this information for as long as is necessary for the purpose(s) for which we originally collected it pursuant to our legitimate business purposes or as required applicable law and our records retention practices. These logs may contain IP address information, types of operating system you use, the date and time you visited the site, and, if you are a user of our Services, information about the type of any personal tracker or other device or service you connect to the Services and information about the data uploaded from any such device or service.
Your Health Information
If you access the Services at the direction of your healthcare provider(s), we will safeguard your Health Information in accordance with applicable law and pursuant to our agreements with your healthcare provider(s). You understand that your use of our Services may be subject to your healthcare provider’s privacy policy. Please contact your healthcare provider if you have any questions about their policies.
Contact Us
If you have any questions about this Privacy Policy, please contact us at +1 (858) 333 5092 (from USA)/0800-220 7070 (from NZ) or at support@OPUMtechnologies.com.