From 7d5616fa993fdc7abc33d1aecaf01bf70d1a3079 Mon Sep 17 00:00:00 2001 From: Jason Kulatunga Date: Wed, 17 Apr 2024 18:01:53 -0700 Subject: [PATCH] adding privacy policy for Fasten Connect. --- connect/privacy_policy.md | 192 ++++++++++++++++++++++++++++++++++++++ 1 file changed, 192 insertions(+) create mode 100644 connect/privacy_policy.md diff --git a/connect/privacy_policy.md b/connect/privacy_policy.md new file mode 100644 index 0000000..27b26fb --- /dev/null +++ b/connect/privacy_policy.md @@ -0,0 +1,192 @@ +--- +nav_order: 26 +title: "Fasten Connect - Privacy Policy" +date: 2024-04-12T20:11:00-07:00 +effective: "April 12, 2024" +type: page +--- + +# Fasten Connect - Privacy Policy + +#### Effective as of {{page.effective}} + +This Privacy Policy outlines the practices of Fasten Health, Inc. ("Fasten Health," "we," "us," or "our") regarding the +Personal Information we collect through your use of the Fasten Connect https://www.fastenhealth.com/connect website (the "Site"), +the Fasten Connect API https://api.connect.fastenhealth.com, Fasten Connect Portal https://portal.connect.fastenhealth.com and any related services (collectively, "Fasten Connect" or the "Services"). +Fasten Health is dedicated to protecting your privacy and managing your Personal Information responsibly. +This policy is dedicated solely to Fasten Connect and does not apply to other products or services offered by Fasten Health. + +This Privacy Policy informs you of our policies regarding the collection, use, and disclosure of Personal Information when you use our Services. + +By visiting the Site, or using any of our Services, you agree that your Personal Information will be handled as described in this Policy. +Your use of our Site or Services, and any dispute over privacy, is subject to this Policy, including its applicable +limitations on damages and the resolution of disputes. + +## Definition of Personal Information + +For the purposes of this Privacy Policy, "Personal Information" refers to both Personal Identifiable Information and +Personal Health Information, which are defined as follows: + +- **Personal Identifiable Information (PII):** This includes any information that can directly identify an individual or is capable of doing so when combined with other information. Examples include but are not limited to an individual's name, address, email address, phone number, or social security number. +- **Personal Health Information (PHI):** This includes any information in an individual's medical record that can be used to identify an individual and that was created, used, or disclosed in the course of providing a health care service such as diagnosis or treatment. It includes, but is not limited to, details such as the individual’s physical or mental health or condition, health care services that the individual receives, or a health plan’s payment for these services, such as the individual’s name, address, telephone number, health insurance information, Medicare Beneficiary number, or financial information related to payment for healthcare services. + +This Policy does not apply to any data such as anonymized or de-identified data which cannot directly or indirectly be used +to identify you or to obtain information about you ("Anonymized and De-Identified Data"). + +--- + +## The Information We Collect About You. + +### Through our Site, fastenhealth.com + +We collect your Personal Information through our Site when you choose to provide that information, such as when you: + +- submit information through the "Contact" page of our website +- register on our website +- respond to our communications (such as responding to an email from us) +- utilize features of our Site + +The Personal Information that we collect can include your: + +- name +- email address +- phone number + +### Through our Fasten Connect Services + +To provide you with the full capabilities of Fasten Connect, we collect certain Personal Information that is necessary +for the operation of our Services. This information is required to fulfill the contract between you and Fasten Health, +and to comply with our legal obligations. Without this information, we cannot provide you with access to Fasten Connect. + +- **Account Information:** When you create a Fasten Connect account, we require details such as your first name, last name, telephone number, and email address. +- **Personal Health Information:** Fasten Connect enables the linking of your Personal Health Information with third-party applications. When you use this feature, you will be asked to consent to share specific health information, which may include diagnostic, treatment, and billing information. This information is temporarily stored on secure Fasten Health servers to enhance service reliability and operation. +- **User Content:** Includes all data, documents, or other content that you upload, input, or otherwise transmit while using Fasten Connect. + +#### Voluntary Information You Provide to Us + +You may also provide us additional information voluntarily to enhance your experience with Fasten Connect. +This may include information submitted when you fill out forms, update your account, respond to surveys, participate in +community forums, engage with promotions, contact our support team, or use other features of the Service. + + +#### Information Collected Automatically + +In addition to the information you provide, we automatically collect data about your usage of Fasten Connect to ensure +optimal service functionality and compliance with legal requirements: + +- **Aggregated Data:** Includes details of your interactions with the service, such as which features you use and how you use them. We may share your Personal Information with third-party service providers to analyze how our Services and features are being used. +- **Log Data and Device Information:** We collect data related to your device and your use of our services, including IP address, device type, operating system, unique device identifiers, browser information, crash data, and other request information. +- **Cookies:** We use cookies and similar tracking technologies to collect information about your interaction with our website, which helps us improve your user experience and tailor our services to your preferences. You can manage cookie settings in your browser, and opting out of certain cookies may affect the functionality of our services. + +--- + +## How We Use Your Information + +We will not sell, rent, license, or trade your Personal Information with third parties for their own direct marketing use. +Unless you give us your permission, we will not share your Personal Information other than as stated in this Privacy Policy. + +We collect and utilize your information to enhance your experience and improve the effectiveness of our Fasten Connect service. Here’s how we use your information: + +- **Communication:** To contact you via email, phone, or postal mail about updates, security alerts, and product offerings related to Fasten Connect. +- **Customization:** To tailor the content and features you see, ensuring a personalized experience on our platform. +- **Legal Compliance and Protection:** To comply with legal obligations, prevent fraud, protect our digital and physical assets, and defend our legal rights or manage disputes where necessary. +- **Operational Necessities:** To manage our services, including data storage, information security, and authentication. These actions are crucial for maintaining the integrity and accessibility of Fasten Connect. +- **Research and Development:** To better understand your needs and interests, leading to enhanced features and new product development. This includes analyzing usage patterns and aggregating information to improve how our services integrate and function. +- **Security and Technical Support:** To secure our services, address and resolve technical issues, and ensure the smooth functioning of Fasten Connect. +- **Service Delivery:** To respond promptly to your requests, provide efficient customer support, and deliver the services you have signed up for. +- **Third-Party Services:** We enable integration with third-party services upon your direction and with your explicit consent. +- **Consent-Based Activities:** For any other purposes for which we have explicitly obtained your consent. + +--- + +## How We Share Your Information + + +Fasten Health takes your privacy seriously and shares your Personal Information with third parties only under specific +circumstances necessary for the operation of the Fasten Connect service and our business functions. + +Third-party service providers must safeguard the Personal Information we entrust to them and are permitted to use such +information solely for fulfilling the services we have contracted them for. They are prohibited from using this personal +information for their own direct marketing purposes. + +The handling of shared information is subject to the privacy policies of these third-party providers, including any +Personal Information accessed through them. These providers are also expected to guide you on how to adjust your privacy +settings on their platforms. + +Here are the ways we may share your information: + +- With affiliates that assist us in providing you with our Services, such as payment processors and cloud service providers, but we will require our affiliates to only use or disclose your information for the purposes of providing the services requested of them and in accordance with this Privacy Policy. +- If we believe that the disclosure is reasonably necessary to (a) satisfy an applicable law, regulation, legal process, or enforceable governmental request; (b) detect, prevent, or otherwise address illegal or suspected illegal activities; or (c) protect the safety, rights, or property of Fasten Health, the public, or any person. +- We may share your Personal Information with other businesses in connection with the sale, assignment, merger or other transfer of all or a portion of our business to those businesses. We will require those businesses to honor the rules of this Privacy Policy. + +It is important to note that our third-party service providers have their own privacy policies, which may differ from ours. We encourage you to read their privacy policies to understand how they handle your information. + +By using Fasten Connect, you agree to the practices described in this section. If you have any concerns about how we share your information, please contact us at [notices@fastenhealth.com](mailto:notices@fastenhealth.com). + +--- + +## How We Secure Your Information + +The security of your Personal Information is important to us, and we strive to implement and maintain reasonable, commercially +acceptable security procedures and practices appropriate to the nature of the information we store in order to protect +it from unauthorized access, destruction, use, modification, or disclosure. + +However, please be aware that no method of transmission over the internet, or method of electronic storage, is 100% secure, +and we are unable to guarantee the absolute security of the Personal Information we have collected from you. + +In the unlikely event that our systems are breached, we will immediately fix any damage and add more protection to prevent +it from happening again. If your personal information is compromised, we will notify you of what was compromised and any +recommended actions you should take. + +--- + +## How to Access, Update or Delete Your Information + +You may contact us to request access, updates or deletions to your Personal Information through the Privacy Center linked +below. We will retain your Personal Information for a long as reasonably useful for our purposes consistent with +the terms of this Privacy Policy and as necessary to comply with our legal obligations, to +resolve disputes and to enforce our agreements. + +[Visit our Privacy Center](https://compliance.fastenhealth.com/) to request a full download or deletion of your data at any time. + +Fasten Health will take action on an individual's request for access no later than 30 calendar days from the receipt of +the request. In cases where, due to unforeseen circumstances, we are unable to meet this timeframe, Fasten Health will provide +the individual, within the initial 30-day period, with a written statement explaining the reasons for the delay and the +anticipated date by which we will complete the requested action. + + +--- + +## California Residents + +If you reside in California, you have specific privacy rights under the California Consumer Privacy Act (CCPA). Fasten Health, +Inc. respects these rights and provides you with the means to exercise them. + +As a California resident, you have the right to request disclosure of the categories and specific pieces of personal +information we have collected about you. You also have the right to ask us to delete any Personal Information we have about you, +with certain exceptions as allowed by law. + +Furthermore, you have the right to know about the Personal Information we collect, our purposes for processing that information, +and if we share it with any third parties. Fasten Health does not sell Personal Information, and we will not discriminate +against you for exercising any of your CCPA rights. + +To make a request related to your rights under CCPA, or if you need further information regarding your rights, please +contact us at [notices@fastenhealth.com](mailto:notices@fastenhealth.com) or [Visit our Privacy Center](https://compliance.fastenhealth.com/). We may +require specific information from you to help verify your identity before processing your request. + +--- + +## Acceptance and Updates to this Privacy Policy + +By using our website, you signify your acceptance of this Privacy Policy. If you do not agree to the terms of this +Privacy Policy, please do not use our Site or Services. We may update this Privacy Policy by posting changes on this website or +otherwise notify you directly. Any Privacy Policy changes will be effective for all information that we maintain, even +information in existence before the change. Your use of our website following any changes to the Privacy Policy signifies +your acceptance of those changes. + + +--- + +## Contacting Us + +If you have any questions or concerns about the Privacy Policy or Fasten Health, please email us at [notices@fastenhealth.com](mailto:notices@fastenhealth.com)