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Privacy Policy

Effective date: Jan 1, 2020

Healthy Culture 360 (hereafter referred to as “Healthy Culture 360”), develops and operates an online healthcare platform for healthcare service providers to manage their services and engage with their patients, hereafter referred to as the ‘Healthy Culture 360’. “We”, “our” and “us” currently refers to Healthy Culture 360 in the terms defined below.

This Privacy Policy is between Healthy Culture 360 and its customers and authorized users using Healthy Culture 360 branded web-based platform or mobile app or white labeled version of web-based platform or mobile app. All user types hereafter referred to as “you” or collectively as “users”.

Customer healthcare service providers using a branded version of Healthy Culture 360 may have their Team Users (employees and/or associates) and Patients Users log in to and use the white label version of Healthy Culture 360 through appropriate interfaces using Authorized User accounts. All data created by users in a branded environment, is owned by the Customer. This privacy policy covers all data generated collectively by these Customers and Authorized Users.

Your privacy is very important to us. This Privacy Policy describes how we handle and secure the personal information and data that you provide to us by using Healthy Culture 360. By using our website, apps and services, you agree to be bound by the terms of this policy. This policy is part of our Terms of Use.

Collected and Received Data

Healthy Culture 360 receives and collects the following type of data or information.

Customer Data

  • Data in a Branded version of Healthy Culture 360 can be added or created by Authorized Users in the Branded version of Healthy Culture 360, whether they be Team users (healthcare service providers, administrative users) or Patient users. This data belongs to the Customer.
  • Personal information includes name, email address and/or phone number used to create Authorized User accounts. It also includes other personally identifiable information that users may choose to add to their user account profile.
  • Personal health information may be added by patient users and/or healthcare providers who are Authorized Users of the Branded version of Healthy Culture 360 enter into the Personal Health Record of a patient. This includes data that is entered manually and/or by syncing with a health monitoring device or from a third-party source that users authorize. It also includes files that users choose to upload.
  • Administrative information about the services provided to Patient Users in the Branded version of Healthy Culture 360.

Other Data

  • Information that the Customer provides to Healthy Culture 360 at the time of setting up their Branded version of Healthy Culture 360 account. This also includes information required for subscription and billing of the account. Healthy Culture 360 does not store the Customer’s credit card or other payment method information
  • In order to enhance your platform usage experience, Healthy Culture 360 uses cookies, logs and analytics to enable certain functionality, improve services and monitor service usage. Information about browser, device, location, IP address, language settings, date and time of use may be captured in logs. These mechanisms are used to help diagnose issues and preferences which help us to evolve the services. Our authorized third-party partners also may receive and log such non-personally identifiable information related to your online service usage as part of supporting platform services.
  • The Customer may choose to configure and use certain Third-Party Services within their Branded version of Healthy Culture 360. This is optional and entirely up to the Customer. For instance, the Customer may configure a third-party payment gateway to accept payments through that gateway for services rendered to Patient users through the Branded version of Healthy Culture 360. In this case the Customer is authorizing the Healthy Culture 360 to receive certain configuration and operational information relevant to the integration with the third-party service. Customers should check the terms of use, privacy policy and usage settings in these Third-Party Services. Healthy Culture 360 does not receive or store any passwords for such third-party services accounts.
  • You may also provide other information to Healthy Culture 360 through support channels.

Note: With regard to the definition of data controller and data processor, as defined by Data Protection laws in the EU, the Customer is the data controller of Customer Data and Healthy Culture 360 is the data processor. Healthy Culture 360 is the data controller of Other Data, as defined above.

Use of Information

Customer Data
  • The Customer is the owner and controller of the Customer Data, which is processed by Healthy Culture 360 as per the configuration settings and instructions of the Customer.
  • The Customer alone decides which Authorized Users to create and terminate; and what access such Authorized Users have to add, update, delete, export or share the data.
  • The Customer defines the policies, practices and usage terms for Authorized Users of the Branded version of Healthy Culture 360, and it is the sole responsibility of the Customer to enforce that.
  • A Customer can terminate Authorized Patient User accounts at any time and such Patients will no longer have further access to their personal health information in event of that happening. Whether or not to share that information with the Patient User before termination of the Patient User account is the prerogative of the Customer only.

Disclosure of Information

Other information and data provided to Healthy Culture 360 is used as follows:

  • We may disclose any information to government or law enforcement officials if we believe doing so is required to comply with law enforcement and legal process; to prevent or stop any illegal, unethical, or legally actionable activity; to protect your, our or other’s rights and safety.
  • Customers determine their own policies and practices for the sharing and disclosure of their own Customer Data, and this is expected to be compliance with legal requirements. Healthy Culture 360 will disclose Customer Data only as per the request and instructions of the Customer, whether as defined in terms of the service configuration that they apply in use of the Branded version of Healthy Culture 360 or by direct requests. Disclosure of Customer Data to Authorized Users of the Customer’s Branded version of Healthy Culture 360 is determined by the Customer, while creating and configuring such Authorized User accounts. The Customer may also be able to request and view usage information of Authorized Users in the Customer’s Branded version of Healthy Culture 360. All Healthy Culture 360 employees are bound by strict privacy policies and will only have access to Customer Data in order to troubleshoot specific cases.
  • Healthy Culture 360 may utilize third party services to sub-process Other Information and support our business by providing hosting, storage, communications, webRTC and analytics services.
  • Customers opting to configure certain third-party services with their Branded version of Healthy Culture 360, should check the privacy policy and settings of such services and should understand what data may be shared between such authorized services and Healthy Culture 360, relevant to the integrated functioning expected.
  • If Healthy Culture 360 becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, Other Information will be transferred to the new entity for the continued performance of service, subject to standard confidentiality agreements.

Data Retention

  • Healthy Culture 360 will retain Customer Data for as long as the Customer has an active Branded version of Healthy Culture 360 account on the Healthy Culture 360.
  • While operating an active Branded version of Healthy Culture 360 account, the Customer controls how this data is retained or deleted, using features and settings in the Branded version of Healthy Culture 360.
  • Deletion of Authorized User accounts in a Customer’s Branded version of Healthy Culture 360 are solely the responsibility of the Customer, Healthy Culture 360 does however reserve the right to deactivate or delete accounts of any user on the platform found to be in violation of our Terms of Use. On receiving a request to delete a Branded version of Healthy Culture 360 account, Healthy Culture 360 will delete the Branded version of Healthy Culture 360 account and all associated data. The deletion of Customer Data may result in the deletion and/or anonymization of associated Other Data. Healthy Culture 360 may retain such anonymized Other Data even after the Customer has deactivated their account if it is required to comply with legal obligations, for audits and for legitimate business needs.

Cookie Policy

  • Healthy Culture 360 uses cookies (both session-based and persistent cookies) and similar technologies like single-pixel gifs, on the domains operated by Healthy Culture 360 for its Healthy Culture 360 and website. We also use third party cookies of Google Analytics on our website.
  • We also use cookies in our website and Platform Services to save user preferences, preserve session settings, help auto-authentication of frequently used services if required by your settings, for certain marketing campaigns and to enable improved understanding of your feature and usage requirements and patterns. You may use browser settings to disable cookies when using our web services, however it may result in the features and services of the applications not functioning properly.
  • Healthy Culture 360 does not collect personal information about online activities of our Customers or visitors to our website across third-party websites or other online services. Do-no-track signals transmitted from web browsers, therefore do not apply to our Platform Services or website. It is important to note that most browsers allow you to disallow cookies from sites that you do not trust.

Transmission and Storage Security

  • All data is stored only in our cloud infrastructure on the highly secured reputed cloud storage in US.
  • We take all necessary measures in providing secure transmission of personal health information before it is transferred across the Internet from your personal computer or devices to our servers and in securing such personal information stored on our systems. However, you should be aware of possible risk involved in transmitting information over the Internet as no data transmission can be guaranteed to be 100% secure and of risk that others could find a way to thwart our security systems. As a result, while we strive to protect your personal information, we cannot ensure or warrant the security and privacy of personal information you transmit to us, and you do so at your own risk.

Restriction on the basis of age

  • All users of the Healthy Culture 360 are expected to be above 18 years of age.
  • Customers are to ensure that only parents or authorized guardians of minors are allowed to operate Authorized Patient User accounts on their behalf.
  • Any Authorized User providing, storing or submitting information on behalf of a child/person under guardianship assumes full responsibility over the submission, use, and transmission of such information.
  • If you believe that any Authorized User in a Branded version of Healthy Culture 360 is younger than the permitted age, immediately contact the Customer operating that Branded version of Healthy Culture 360.
  • If notified directly of such a violation of our Terms of Use, we will promptly delete the concerned user account and related data.

Your Rights

  • Users located in the EU, have certain statutory rights with regard to their personal data as defined by the General Data Protection Regulation. You have the right to seek to request access to your personal data, delete or update it. The Platform Service features and settings support this to some extent. If you cannot use the service features to do this, please contact our support desk for help.
  • In the case of Authorized Users of branded Healthy Culture 360, it is important to directly contact the Customer for such support including objection to processing of your data, as the Customer is the data controller of Customer Data. Based on its legitimate interests and compliance requirements, Healthy Culture 360 may process Other Data that includes user data for legitimate purposes.

Links to Other Websites

  • Our website may contain links to other websites. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personally identifiable information from you. Other sites follow different rules regarding the use or disclosure of the personally identifiable information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Changes to this Policy

  • Please note that this Privacy Policy may change from time to time as we continue to offer evolve our services.
  • In the event of any changes in our Privacy Policy, the updated version will be posted on the Healthy Culture 360 website and take effect from the moment of posting.

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