Privacy Policy - Memora Health Inc.


Memora Health Inc. (“Memora,” “we,” “us,” or “our”) respects your privacy. This Privacy Policy explains how Memora collects, uses, discloses, and secures information about you through www.memorahealth.com/, along with our related websites, networks, applications, mobile applications, our electronic communications, including email and text messages, and other services provided by us (collectively, the “Service”). By using the Service, you consent to the processing of your information as set forth in this Privacy Policy, now and as amended by us.
In providing the Service, we collect and obtain information about individual consumers (“End Users”) to, among other things, provide End Users access to an artificial intelligence engine that delivers behavioral health suggestions, reminders, and related information through the delivery and receipt of health related text messages. In providing the Service, we at times act as a service provider to health care providers (“Providers”) who use the Service to engage with End Users.


INFORMATION WE COLLECT

Memora collects information from and about users of the Service in a variety of ways. This information includes:

  1. Information You Provide. We collect information you provide when you use the Service or otherwise communicate with us. If you register an account with us, we will collect the information you provide, such as your name, email address, and phone number. We will also collect any information you submit through your use of the Service. For example, if you are an End User, the information you provide can include your messaging history and any information included in your messages via the Service. We may also collect information through your communications with our customer-support team.

  2. Provider Submitted Information about End Users. Providers may provide us information about End Users they recommended to the Service such as the End User’s name, date of birth, gender, telephone number, and prescribed medications. We use and disclose this information only in accordance with your express authorization, which we require the relevant Provider obtain from you through a separate document when you sign up to use the Service. Please be aware that if you do not provide your authorization, or if you subsequently withdraw your authorization, you may not be able to use the Service, but may continue to receive services from the Provider outside of the Service.

  3. Device and Usage Information. Like most online services, we automatically receive standard technical, information when you interact with our Service including browser and device information such as unique device identifiers, mobile phone carrier, internet protocol (IP) addresses (which may identify your general geographic location), browser types, and the date and time of your interactions. We also receive information about your interactions with our Service, such as which website pages you visited and how much time was spent on the page.

  4. We may collect this information using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your device. Cookies enable us to personalize your experience on the Service, maintain a persistent session, passively collect demographic information, and monitor advertisements and other activities. Our Service may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).


HOW WE USE YOUR INFORMATION

We use information in a variety of ways to provide our Service and to operate our business, including the following:

  1. Service Related Usage. We use the information we collect about and from you for a number of purposes, including: providing and supporting the Service, analyzing how you use the Service, and better tailoring features.

  2. Communications. We use your information to communicate with you for Service-related purposes. For example, we may send email to the email address you provide to us or text messages, to verify your account and for informational and operational purposes, such as account management, customer service, system maintenance, and other Service-related purposes.

  3. Improve our Service. We use the information that we collect (i) to understand and analyze usage trends and preferences; (ii) to monitor and analyze the effectiveness of our Service; and (iii) to improve our Service and develop new products, services, features, and functionality.

  4. Marketing. As permitted by applicable law, we may use information we collect about you for marketing purposes, such as providing you with promotional materials that may be useful, relevant, valuable or otherwise of interest to you. Where required under applicable law, we’ll obtain your prior opt-in consent to send you electronic marketing communications.

  5. Anonymous Data. We may de-identify your information and process it in an anonymous form for other purposes than described above.


HOW WE SHARE YOUR INFORMATION

We may share, transfer, or disclose your information, if you consent to us doing so, as well as in the following circumstances:

  1. Providers and Approved Persons. If you are an End User that was enrolled by a Provider, we share information collected from you through the Service with your Provider. In addition, the Service may allow End Users to share information collected with explicitly designated third-parties.
  2. Service Provders. We share information with third parties who provide services to us, such as analytics, web site management, information technology, and other similar service providers. In addition, we may use third party analytics vendors to evaluate and provide us with information about your use of the Service. We do not share your information with these third parties, but theses analytics service providers may set and access their own cookies, pixel tags and similar technologies on the Service and they may otherwise collect or have access to information about you which they may collect over time and across different websites. On our website, we use Google Analytics to collect and process certain analytics data; Google provides some additional privacy options described at https://www.google.com/policies/privacy/partners/.

  3. Comply with Legal Requirements. We may disclose your information as we believe to be necessary or appropriate to: (i) comply with applicable law and legal processes; (ii) respond to requests from public and government authorities, including public and government authorities outside your country of residence; (iii) enforce our Terms of Service; (iv) protect our rights, privacy, safety, or property, and/or that of our affiliates, you or others; and (v) allow us to pursue available remedies or limit the damages that we may sustain.

  4. Corporate Transactions. We reserve the right to transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.

  5. Aggregate, De-Identified Information. We may use your data to create aggregate or statistical information that does not directly identify a specific person, and we may share that information. For example, we may share anonymous and aggregated reports and information on user demographics and traffic patterns with third parties.


HIPAA

Some of our Providers may be regulated as “covered entities” under the Health Insurance Portability and Accountability Act (“HIPAA”). Please be aware that this Privacy Policy is distinct from such Provider’s HIPAA Notice of Privacy Practices, which describes in detail how that Provider uses and discloses individually identifiable health information. If an End User would like to review a copy of their Provider’s HIPAA Notice of Privacy Practices, the End User should request a copy directly from their Provider.


INFORMATION SECURITY

We take steps in an effort to treat your information securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.


CHILDREN'S PRIVACY

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with personal information without your consent, you may alert us at the contact information listed below. If we learn that we have collected any personal information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.


INTERNATIONAL USERS

The Service is intended for users located within the United States. We make no representation that the Service is appropriate or available for use outside of the United States. Access to the Service from countries or territories or by individuals where such access is illegal is prohibited. If you are visiting our website from the European Union or other regions with laws governing data collection and use, then please note that you are agreeing to the transfer of your information to the United States and processing globally. By providing your information to the website, you consent to any transfer and processing in accordance with this Privacy Policy.


YOUR CHOICES

If you do not want the Service to collect information through the use of cookies, your browser may allow you to be notified when you receive certain types of cookies and restrict or disable certain cookies. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. Please be aware that if you disable or reject cookies, some features may not work properly.

You can opt-out of receiving further promotional emails from us by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly at the email address listed below.

To the extent you have registered an account with us and designated a third-party to receive information collected about you, you can manage this feature by logging into your account and adjusting, adding, or removing ‘Contact Name’ and ‘Contact Phone’ details listed under the ‘Emergency Contacts’ section of your profile. This can be accessed from the settings page on your individual user profile. Contact us at [email protected] if you have any questions about adjusting this feature.

You can opt-out of receiving further text messages from us by texting “STOP” to the number from which you are currently receiving messages and health information. Alternatively, you can contact us at [email protected] to adjust or opt-out of further text messages.


CONTACT US

If you have any questions or comments about this Privacy Policy, our privacy practices or if you would like to exercise your rights and choices, please contact us at [email protected]lth.com or by writing to us at:

    Memora Health
    34 Worthington St.
    Unit 4
    Boston, MA 02120


PRIVACY POLICY UPDATES

We may update this Privacy Policy from time to time. If we make any changes, we will notify you by revising the "Effective Date" at the bottom of this Privacy Policy. If we make any revisions that materially change the ways in which we use or share the information previously collected from you through the Service, we will give you the opportunity to consent to such changes before applying them to that information.


Effective Date: June 2nd, 2017