LOOPER
PRIVACY POLICY
1 WHAT WE DO
1.1 Social Health Innovations Inc. (“we,” “us,” “our”) is the owner of the Looper apps, widgets, software and the http://www.bealooper.com website (collectively, the Platform). The Platform is a mobile and web application that allows primary users (Loopers) to answer questions about how they are tracking on a scale from 1 to 10, and share their answers with secondary users that the Looper authorises to use the Platform (Followers)..
1.2 In order to achieve the above requires Users to create, store and edit electronic health records on the Personal and Health Information of the Looper (EHR).
1.3 This Privacy Policy should be read in conjunction with our Terms of Service that govern the use of Looper.
THE PLATFORM MAY COLLECT PERSONAL, MEDICAL AND HEALTH-RELATED INFORMATION ABOUT YOU. BY USING THE PLATFORM, YOU AGREE THAT WE CAN COLLECT AND USE YOUR PERSONAL AND OTHER INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT USE THE PLATFORM.
2 PRIVACY STATEMENT – OUR COMMITMENT TO YOU
2.1 Keeping customer information private and confidential is the foremost priority for us. To enable us to provide you with our services, we need to collect certain information from you. We provide this privacy notice to inform you of what personal information we collect about you and how we treat that information.
2.2 This Privacy Policy governs the manner in which we collect, use, maintain and disclose information collected from users of Looper. We may update this Privacy Policy from time to time as a result of changes in technology or privacy law. In the event of any major changes, we will post a notice on the Looper Platform.
2.3 This privacy policy applies to the Looper Platform and all products and services offered by us. By signing up for any of the products or services offered by us, you agree to the terms of this Privacy Policy and our Terms of Service http://www.bealooper.com.
2.4 Our privacy practices are intended to comply with the Health Insurance Portability and Accountability Act (“HIPAA“). We will maintain the privacy of your Health Information as required by HIPAA and the regulations promulgated under that Act.
2.5 All individuals with access to personally identifiable information (hereinafter, the Personal Information)—as defined in Title 18 of the United States Code, section 1028, subsection d—about our customers are required to follow this policy effective as of 3/1/2016.
3 PURPOSE OF OUR POLICY
3.1 We have adopted this Privacy Policy to ensure that we have standards in place to protect the Personally Identifiable Information that we collect about individuals that is necessary and incidental to:
(a) Providing the system and services that we offer; and
(b) The normal day-to-day operations of our business.
3.2 By publishing this Privacy Policy we aim to make it easy for our customers and the public to understand what Personal Information we collect and store, why we do so, how we receive and/or obtain that information, and the rights an individual has with respect to their Personal Information in our possession.
4 THE INFORMATION WE COLLECT
4.1 In the course of business it is necessary for us to collect Personal Information. This information allows us to identify who an individual is for the purposes of our business, contact the individual in the ordinary course of business and transact with the individual. Specifically, we require this information in order to verify the identity of our users, to protect our customers, and to ensure the integrity of the sales we facilitate.
4.2 Without limitation, the type of information we may collect is:
(a) Health Information. We may collect information for an EHR about the health (including mental health) injuries, disability, health services, medical histories, prescriptions, allergies and other information about an individual defined as electronic “protected health information” in the Health Insurance Portability and Accountability Act of 1996 (HIPAA);
(b) Personal Information. We may collect personal details such as an individual’s name, location, date of birth, and other information, as defined in Title 18 of the United States Code, section 1028, subsection d, that allows us to identify who the individual is;
(c) Contact Information. We may collect information such as an individual’s email address, telephone & fax number, and other information that allows us to contact the individual;
(d) Financial Information. We may collect financial information related to an individual such as any bank or credit card details used to transact with us and other information that allows us to transact with the individual and/or provide them with our services;
(e) Statistical Information. We may collect information about an individual’s online and offline preferences, habits, movements, trends, decisions, associations, memberships, finances, purchases and other information;
(f) Other Personal Information. We may collect other Personal Information about an individual, which we will maintain in accordance with this Privacy Policy. We may also collect non-Personal Information about an individual such as information regarding their computer, network and browser. This may include their IP address.
(g) Children under 13. As noted in the Terms of Use, we do not knowingly collect or solicit Personal Information from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Information about yourself to us. If we learn that we have collected Personal Information from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Information, please contact us.
5 HOW INFORMATION IS COLLECTED BY US AND OTHERS
5.1 Most information will be collected in association with an individual’s use of Looper, making an enquiry about Looper or generally dealing with us. However we may also receive Personal Information from sources such as advertising, an individual’s own promotions, public records, mailing lists, contractors, staff, recruitment agencies and our business partners. In particular, information is likely to be collected as follows:
(a) Registrations/Subscriptions. When an individual registers or subscribes for a service, account, membership or other process whereby they enter Personal Information details in order to receive or access something, including a transaction;
(b) Payment. When an individual submits their details to open a payment account or make a payment;
(c) Sales and Purchases. When individuals transact sales and purchases using the Service;
(d) Supply. When an individual supplies us with goods or services;
(e) Contact. When an individual contacts us in any way;
(f) Access. When an individual accesses our offices we may require them to provide us with details for us to permit them such access.
(g) Cookies. Looper may use "cookies" to enhance user experience. Your web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. You may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of Looper may not function properly.
(h) Social Media Features. Our Web site may include social media features, such as the Facebook Like button. These features may collect your IP address and which page you are visiting on our Site, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Site. Your interactions with these features are governed by the privacy policy of the company providing them.
(i) Third Party Links. Our Site or Services may contain links to third party 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. If you submit personal information to any of those sites, your information is governed by their privacy policies. 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.
(j) Phishing. It has become increasingly common for unauthorized individuals to send e-mail messages to consumers, purporting to represent a legitimate company such as a bank or on-line merchant, requesting that the consumer provide personal, often sensitive information. Sometimes, the domain name of the e-mail address from which the e-mail appears to have been sent, and the domain name of the web site requesting such information, appears to be the domain name of a legitimate, trusted company. In reality, such sensitive information is received by an unauthorized individual to be used for purposes of identity theft. This illegal activity is known as “phishing”. If you receive an e-mail or other correspondence requesting that you provide any sensitive information (including your password or credit card information) via e-mail or to a Web site that does not seem to be affiliated with Looper, or that otherwise seems suspicious to you, please do not provide such information, and report such request to us at support@bealooper.com
5.2 As there are many circumstances in which we may collect information both electronically and physically, we will endeavour to ensure that an individual is always aware of when their Personal Information is being collected.
5.3 Where we obtain Personal Information without an individual’s knowledge (such as by accidental acquisition from a client) we will either delete/destroy the information, or inform the individual that we hold such information.
6 THE SAFETY & SECURITY OF PERSONAL INFORMATION
6.1 Physical Facilities. We will take all reasonable precautions to protect an individual’s Personal Information from unauthorised access. We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on Looper. This includes appropriately securing our physical facilities and electronic networks.
6.2 Industry Standards. We follow industry standards on information security management to safeguard sensitive information, such as financial information, intellectual property, employee details and any other Personal Information entrusted to us. Our information security systems apply to people, processes and information technology systems on a risk management basis.
6.3 Servers. We may use a variety of cloud services to store our data. Personal Information may be stored, hosted, and accessed from data centers in the United States. Data privacy laws or regulations in your home country may differ from those in United States. By using the Service, you consent to having some of your data hosted in the United States.
6.4 Privacy Officer. We may appoint a Privacy Officer to oversee the management of this Privacy Policy. This officer may have other duties within our business and also be assisted by internal and external professionals and advisors.
6.5 Internet Security. The security of online transactions and the security of communications sent by electronic means or by post cannot be guaranteed. Each individual that provides information to us via the internet or by post does so at their own risk. We do not accept responsibility for misuse or loss of, or unauthorised access to, Personal Information where the security of information is not within our control.
6.6 Authorised Recipients. A core function of the Platform is to enable authorised Users to monitor a Looper’s progress remotely. To do this requires the creation of an EHR. We require that such authorised Users have a compliant privacy policy in place, if so required by law. Users authorised by the Looper to view an EHR may use or copy the Personal Information in an EHR. We are not responsible for any use that a Caregiver or authorised User of the Platform makes of an EHR, or their compliance with privacy law.
6.6 Retention. We will store your personal information for as long as is reasonably necessary for the purposes for which it was collected, as explained in this privacy policy. Where your information is no longer needed, we will ensure that it is disposed of in a secure manner.
7 WHEN PERSONAL INFORMATION IS USED, SHARED & DISCLOSED
7.1 Purpose. The purpose of collection is determined by the circumstances in which the information was collected and/or submitted.
7.2 Sharing With Authorised Users. The primary reason Personal Information is used or disclosed is to share EHRs with other Users authorised by the Looper to view the EHR (such as Followers). We will never use Personal Information in the Platform for any other purpose than making the individual’s EHR available to Followers or other users authorised by the Looper to receive it. We will never use the information in an EHR for any marketing or commercial purposes, and we maintain all Health Information in the strictest confidence.
7.3 Non-Disclosure. We will not disclose or sell an individual’s Personal Information to unrelated third parties under any circumstances. We do not sell, trade, or rent users personal identification information to others.
7.4 Business Operations. Information is used to enable us to operate our business, especially as it relates to an individual. This may include:
(a) The provision of services between an individual and us;
(b) Verifying an individual’s identity;
(c) Communicating with an individual about:
i Their relationship with us;
ii Our services;
iii Our own marketing and promotions to customers and prospects;
iv Competitions, surveys and questionnaires;
(d) Improve Customer Service. Information you provide helps us respond to your customer service requests and support needs more efficiently.
(e) Personalize Your Experience. We may use information in the aggregate to understand how our users as a group use the services and resources provided on Looper.
(f) Site Improvement. We may use feedback you provide to improve our products and services.
(g) Payments. We may use the information Users provide about themselves when placing an order only to provide service to that order. We do not share this information with outside parties except to the extent necessary to provide the service.
(h) Emails. We may use the email address to send you information and updates pertaining to their order. It may also be used to respond to inquiries, questions, and/or other requests and will be shared with Partners. If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information, etc. If at any time you would like to unsubscribe from receiving future emails, you may do so by contacting us.
7.5 Sharing your information. There are some circumstances in which a third party may have access to your information.
(a) Service Providers. With third parties who help manage our business and deliver services.
(b) Partners. We may share personal information with Partners in order to facilitate the Service or as otherwise indicated in this Privacy Policy.
7.6 Liability for onward transfer. In the context of an onward transfer, SHI has responsibility for the processing of personal information it receives and subsequently transfers to a third party acting as an agent on its behalf. SHI shall remain liable under the Principles if its agent processes such personal information in a manner inconsistent with the Principles, unless the organization proves that it is not responsible for the event giving rise to the damage.
7.7 Disclosure. There are some circumstances in which we must disclose an individual’s information:
(a) Subpoena. Where we are required to disclose by a United States Court of Law under subpoena.
(b) Illegal Activities. Personal information may be shared with third parties to prevent, investigate, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms of Service or any other agreement related to the Services, or as otherwise required by law.
(c) Change of Ownership. Personal information may also be shared with a company that acquires our business, whether through merger, acquisition, bankruptcy, dissolution, reorganization, or other similar transaction or proceeding. If this happens, we will post a notice on our home page.
7.8 International Transfer. Your personal information may be disclosed, transferred to or processed outside of your country of residence. This includes to Australia, and the United States of America, where it will be subject to the laws of the country to which it is transferred. These jurisdictions may not have an equivalent level of data protection laws as those in your country.:
7.9 We will take appropriate steps to ensure that transfers of personal information are in accordance with applicable law and carefully managed to protect your privacy rights and interests and transfers are limited to countries which are recognised as providing an adequate level of legal protection or where we can be satisfied that alternative arrangement are in place to protect your privacy rights.
7.10 Consent. Except when required by law, we will never disclose your Personal Information without obtaining your consent.
8 HOW TO ACCESS AND/OR UPDATE INFORMATION
8.1 The User can modify their information in the User’s account settings page.
8.2 If for any reason an individual cannot update his or her own information, we will correct any errors in the Personal Information we hold about an individual as soon as feasible after receiving notice from them about those errors.
8.3 It is an individual’s responsibility to provide us with accurate and truthful Personal Information. We cannot be liable for any information that is provided to us that is incorrect.
9 RIGHTS OF THE INDIVIDUAL
9.1 You have a number of rights in relation to your personal information.
9.2 You may have these rights under applicable laws, including the EU General Data Protection Regulation (GDPR), but we offer them regardless of your location.
9.3 Informed. You have the right to be informed, which is the purpose of this section of the policy.
9.4 Access and Portability. You have the right to request a copy of your data, and for it to be in a portable format.
9.5 Correction and Rectification. Your data may be corrected by mechanism provided within the website or software. You may request correction of the personal information that we hold about you by contacting us.
9.6 Erasure. Except when required by law, we will never disclose your Personal Information without obtaining your consent.
9.7 Object and Restrict Processing. You may opt out of the service should we advise via a change in this policy that your personal information is to be disclosed to a new type of third party, or will be used for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by the individuals. Opting out of the service will ensure your personal data is not utilised for new types of services or processing.
9.8 Identification. We may ask you for additional information to confirm your identity and for security purposes, in particular before disclosing personal information to you.
9.9 Request process.You may exercise your rights via mechanism provided though the software or website, such as updating your details, or closing your account. Alternatively, you may contact us via the detail in the Contact Us section.
7.8 Response to requests.We will respond to your requests to access or correct personal information in a reasonable time and will take all reasonable steps to ensure that the personal information we hold about you remains accurate, up-to-date and complete.
7.8 Cost of requests.There is no charge for requesting access to your personal information but we may require you to meet our reasonable costs in providing you with access (such as photocopying costs or costs for time spent on collating large amounts of material).
7.8 Exemption to a request. We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.
10 TERMINATION OF ACCOUNT
10.1 Even after you close your account, we will continue to store archived copies of your Personal Information for legitimate business purposes and to comply with the law.
10.2 We will continue to store anonymous or anonymized information, in order to improve our Service.
11 COMPLAINTS AND DISPUTES
11.1 If an individual has a complaint about our handling of their Personal Information, they should address their complaint in writing to the details below.
11.2 If we have a dispute regarding an individual’s Personal Information, we both must first attempt to resolve the issue directly between us.
11.3 If we become aware of any unauthorised access to an individual’s Personal Information we will inform them at the earliest practical opportunity once we have established what was accessed and how it was accessed.
12 CONTACTING INDIVIDUALS
12.1 From time to time, we may send an individual important notices, such as changes to our terms, conditions and policies. Because this information is important to the individual’s interaction with us, they may not opt out of receiving these communications.
13 YOUR ACCEPTANCE OF THESE TERMS
13.1 By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use Looper. Your continued use of Looper following the posting of changes to this policy will be deemed your acceptance of those changes.
14 CHANGES TO THIS POLICY
14.1 We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify Customers by email (sent to the e-mail address specified in a Customer’s account) or users, including Customers, by means of a prominent notice on the Site or Services prior to the change becoming effective. Any access or use of the Site or Services by you after such notice shall be deemed to constitute acceptance by you of such changes, modifications or additions. We encourage you to periodically review this page for the latest information on our privacy practices. If you do not agree to abide by these practices or any future privacy policy, please do not use or access the Site or Services.
15 EU-U.S. AND SWISS-U.S. FRAMEWORK
15.1 SHI has adopted this Policy (“Policy”) to establish and maintain an adequate level of Personal Data privacy protection. This Policy applies to the processing of Personal Data that SHI obtains from Customers, and Staff located in the European Union and Switzerland.
15.2 SHI commits to resolve complaints about our collection or use of your personal information. EU and Swiss individuals with inquiries or complaints regarding our policy should first contact SHI at outlined in the Contact Us section of this policy.
16 CONTACTING US
16.1 If you have any questions about this Privacy Policy, the practices of this site, or your dealings with this site, please contact us at:
Looper
http://www.bealooper.com
support @ bealooper.com
This document was last updated on 6 May 2021.