Quartet Health Privacy Policy

Last updated: June 4, 2020

Thank you for registering at www.quartethealth.com (the “Website”). At Quartet, it is our priority to protect your information. This privacy policy will help you understand how we collect, use and disclose your information. If you have any questions, don’t hesitate to reach out to [email protected].

 

BY USING THE SERVICES, YOU AGREE TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND YOU HEREBY CONSENT TO OUR TRACKING, COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, DO NOT USE THE SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE (SUCH AS YOUR LEGAL GUARDIAN) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S OR ENTITY’S BEHALF.

 

Remember that your use of Quartet’s Services is at all times subject to the Terms of Use, which incorporates this Privacy Policy. Any terms without definitions in this Privacy Policy are defined in the Terms of Use.

Information we collect

As described in this Privacy Policy, we may collect certain personal information from or about you in connection with your use of, or your acceptance of, the Services. Personal information, for purposes of this Privacy Policy, generally includes information that may be used to identify you. The types of personal information we collect about you will depend on your relationship with Quartet. You are not required to provide all personal information identified in this Privacy Policy; however, please be advised that if you do not provide the personal information requested by us, including personal information necessary to respond to customer inquiries, we may be unable to provide some or all of the Services to you. In some cases, and if applicable, we may request additional consent from users if we think there is other information that will improve our ability to coordinate care or tailor our services to the needs of our users.

Categories of personal information.
We may collect the following categories of personal information:

Identifiers

Name; email address; phone number; username and password; member ID, group ID, network ID, provider ID and payer ID; government-issued identification number; languages spoken; and personal information in any emails or letters that you send to us.

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

Health insurance information, including information regarding insurance carrier, insurance plan, insurance network; medical information, including information regarding reasons for visits to healthcare providers, dates of visits, medical history, prescription information, and other medical and health information you choose to share with us

Protected classifications under applicable law

Gender; date of birth; marital status; race; ethnicity

Internet or similar network activity

Browsing history, search history, clickstream data, session information, browser and operating system type, navigation paths, date/time stamps, cookie identifiers, and other information about device characteristics and how you interact with the Services

Geolocation data

Latitude and longitude information regarding individuals’ residential and employment addresses; geolocation data derived from your Internet activity

Professional or employment-related information

For healthcare providers, information about area of practice and where care is provided

HIPAA-related information.
Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some of the demographic, health and/or health-related information that Quartet collects as part of providing the Services may be considered “protected health information” or “PHI”. Quartet works as a “Business Associate” to healthcare providers and health plans (a vendor who performs work on behalf of the healthcare provider for the purpose of payment, treatment, or healthcare operations – with whom the healthcare provider has entered into a separate agreement upon registration that specifically indicates how we will protect patient information). When Quartet receives identifiable information about an individual from or on behalf of healthcare providers, this information is PHI. HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. As a Business Associate, Quartet may only use and disclose PHI in the ways permitted by Healthcare Provider(s) that we are performing work for.

Cookies and similar technologies.
We may collect certain personal information using cookies and other technologies, such as web beacons, device IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and other purposes. When you visit the Website, we may also automatically collect certain data about your device, including information about your web browser, IP address, time zone, and geolocation. Additionally, as you browse the Website, we may collect information about the individual web pages that you view, what websites or search terms referred you to the Website, and information about how you interact with the Website. Our Use of Cookies and Similar Technologies section contains more information and options to control or opt-out of certain data collection or uses related to cookies and similar technologies.

Anonymous data.
We may create de-identified or anonymous data from personal information by removing data components (such as your name, email address, or other data elements) that makes the data personally identifiable to you or through obfuscation or through other means. Our use of anonymized and de-identified data is not subject to this Privacy Policy.

Marketing and informational communications.
If you have provided your contact information to us, we may store and use that information to contact you for marketing and promotional purposes by various means, including regular mail, email, telephone, voicemail, or SMS (text message). Users may receive messages about appointment reminders, general health care information and wellness programs sponsored by Quartet. You can recognize when an affiliated business is associated with our services, and we will only disclose your Personal Information with that affiliated business to the extent that it is necessary for the delivery of the transaction or service.

 

We may receive a confirmation when you open an email from us. This confirmation helps us make our communications with you more interesting and improve our services. To the extent permitted by law, and if you have provided your contact information to us, we may store and use that information to contact you about the coordination of your care by various means, including regular mail, email, or telephone, including voicemail or SMS (text message). To the extent you voluntarily opt to have SMS notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number. You can adjust the types of notifications you receive and when you receive them by editing your SMS notification settings. We may also use your information to notify you about appointments and/or to communicate with you about your Account. You will have the ability to opt out of any marketing or advertising communications, but we may still send you communications relating to your Account for purposes important to the Services, such as password recovery.

Sources of information and purposes of collection

The following is intended to describe the various sources through which we may collect personal information and the purposes for which we collect it:

Sources of personal information

Categories of personal information from source

Purposes of collection and disclosure

Applications and forms
We may collect personal information from you, your authorized representatives, your healthcare provider and health plan, or your healthcare provider’s partners and affiliates during the intake and/or registration process, through other forms or applications, or through discussions we have with you, your authorized representatives, your healthcare provider, or your healthcare provider’s partners and affiliates.

  • Identifiers
  • Personal information
    categories listed in the
    California Customer Records  statue
  • Protected classifications
    under applicable law
  • Professional or
    employment-related
    information
  • Provide and perform the
    Services
  • Protect against
    unauthorized access,
    security incidents, fraud,
    and other malicious or
    illegal activity
  • Comply with legal and
    regulatory obligations

Communications and interactions with us
We may collect personal information from you or your authorized representative communication with us, including when you contact customer support, submit inquiries, request information from us, or participate in a promotion, contest, or survey.

  • Identifiers
  • Personal information
    categories listed in the
    California Customer
    Records statue
  • Protected classifications
    under applicable law
    Internet or similar network
    activity
  • Geolocation data
  • Professional or
    employment-related
    information
  • Provide and perform the
    Services
  • Enhance the Services
  • Market, advertise, and promote the Services
  • Protect against
    unauthorized access,
    security incidents, fraud,
    and other malicious or
    illegal activity
  • Comply with legal and regulatory obligations

Social media, online forums, and advertisements
We may collect personal information from third-party social media platforms and sites, when you engage with our social media pages, online communities and forums, and when you mention us on your own or other social media pages, online communities, or forums, or when you interact with advertisements related to our services. Please note that online forums may be publicly accessible and other users may view information you post in the forums. We encourage you to exercise care in deciding what information and content you wish to disclose on the areas of the Website that are accessible to the general public.

  • Identifiers
  • Internet or similar network
    activity
  • Geolocation dataProfessional or
    employment-related
    information
  • Provide and perform the
    Services
  • Enhance the Services
  • Market, advertise, and
    promote the Services
  • Comply with legal and regulatory obligations

Business partners and service providers
We may collect personal information from our business partners (such as insurance carriers and healthcare providers) and service providers. We may also collect personal information from other third parties who are authorized to act on our behalf.

  • Identifiers
  • Personal information
    categories listed in the
  • California Customer Records
    statue
  • Protected classifications
    under applicable law
  • Geolocation data
  • Professional or
    employment-related
    information
  • Provide Services
  • Market, advertise, and
    promote the Services

Government entities
We may collect personal information from government entities and databases, such as anti-fraud databases and regulators.

  • Identifiers
  • Protected classifications
    under applicable law
  • Professional or
    employment-related  information
  • Provide Services
  • Protect against
    unauthorized access,
    security incidents, fraud,
    and other malicious or
    illegal activity
  • Comply with legal and
    regulatory obligations

Publicly-available sources
We may collect personal information from government entities and databases, such as anti-fraud databases and regulators.

  • Identifiers
  • Personal information
    categories listed in the
  • California Customer Records
    statue
  • Protected classifications
    under applicable law
  • Geolocation data
  • Professional or
    employment-related
    information
  • Provide Services
  • Enhance the Services
  • Market, advertise, and
    promote the Services
  • Comply with legal and
    regulatory obligations

How we may disclose information

We may disclose personal information as described in this Privacy Policy, including with the following categories of third parties:

Categories of Third parties with whom we disclose personal information

Categories of personal information we disclose

Healthcare providers
We may disclose personal information with healthcare providers that treat and/or schedule appointments with individual users through our Services. Sharing this information enables healthcare providers to submit referrals and schedule appointments with other healthcare providers on behalf of the individual user, or to perform analyses on potential health issues or treatments, provided that the user chooses to use the applicable Services. We may also disclose personal information with healthcare providers in the event of an emergency.

  • Identifiers
  • Personal information categories listed in the California Customer
    Records statue
  • Protected classifications under applicable law
  • Professional or employment-related information

Insurance providers
We may disclose personal information with a user’s insurance provider associated with an individual user’s account for the purposes of care coordination, determining eligibility and cost­sharing obligations, or otherwise obtaining benefit plan information.

  • Identifiers
  • Personal information categories listed in the California Customer
    Records statue
  • Protected classifications under applicable law
  • Professional or employment-related information

Technical and operational service providers and business partners
We may engage third parties to perform certain functions on our behalf. To do so, we may disclose personal information to our third-party business partners and service providers in order to maintain and operate the Website and provide, improve, and personalize the services, including to fulfill requests for the Services, to administer your account and information in connection with providing the Services, and for other technical and processing functions, such as sending e-mails on our behalf and technical support. We may also disclose personal information to service providers or other third parties to detect, protect against, and respond to security incidents or other malicious, deceptive, illegal or fraudulent activity or other threats and for legal compliance purposes or pursuant to legal process.

  • Identifiers
  • Personal information categories listed in the California Customer
  • Records statue
  • Protected classifications under applicable law
  • Geolocation data
  • Professional or employment-related information

Marketing, advertising, and analytics providers
We may disclose personal information with third-party providers for marketing, advertising, and analytics purposes.

  • Identifiers
  • Internet or similar network activity
  • Geolocation data
  • Professional or employment-related information

Government Entities
We may disclose personal information with government entities and agencies, regulators, law enforcement, and other third parties, including to comply with applicable laws and regulations, to respond to a subpoena, search warrant, or pursuant to legal process, and to establish or exercise our legal rights or for fraud- or crime-prevention purposes.

  • Identifiers
  • Personal information categories listed in the California Customer
  • Records statue
  • Protected classifications under applicable law
  • Geolocation data
  • Professional or employment-related information

Professional service firms
We may disclose personal information with professional service firms in connection with our legal and regulatory obligations and to establish or exercise our rights and defend against claims, including, for example, auditors, law firms, and consultants.

  • Identifiers
  • Personal information categories listed in the California Customer
  • Records statue
  • Protected classifications under applicable law
  • Internet or similar network activity
  • Geolocation data
  • Professional or employment-related information

Changes of control
We may transfer information about you, including your personal information, to another company in connection with a merger, sale, acquisition or other change of ownership or control by or of Quartet (whether in whole or in part). When one of these events occurs, we will use reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

  • Personal information categories listed in the California Customer
  • Records statue
  • Protected classifications under applicable law
  • Internet or similar network activity
  • Geolocation data
  • Professional or employment-related information

We do not rent or sell your personal information. We may disclose your personal information with third parties as described in this section.

We may de-identify Personal Information so that a user is not identified as an individual, and provide that information to our partners. We may also provide aggregate usage information to our partners (or allow partners to collect that information from our users), who may use such information to understand how often and in what ways people use our Services, so that they, too, can provide an optimal online experience.

We will retain a user’s information for as long as the Account is active or as needed to provide our services to the user, in accordance with applicable law. Notwithstanding any provision to the contrary, we will retain, access, use and disclose information as we believe is necessary to comply with our legal obligations, resolve disputes, enforce our Terms of Use and other agreements, or to protect the rights, property or safety of Quartet, our employees, our users or others.

Disclosures and sales of personal information for business or commercial purposes

We may disclose the following types of personal information to third parties for a business or commercial purpose, as further described in the chart above:

 

  • Identifiers
  • Personal information categories listed in the California Customer
  • Records statue
  • Protected classifications under applicable law
  • Internet or similar network activity
  • Geolocation data
  • Professional or employment-related information

Use of cookies and similar technologies

The Website’s use cookies and similar technologies to improve user experience, for performance and analytics, and to improve our content, products, and services.

 

A “cookie” is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to the server (for example, when requesting a web page from the same domain that created the cookie). The purpose of cookies is to remember the browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may serve to track personal information previously entered by a web user on the Website. Most browsers allow you to control cookies, including whether or not to accept them and how to remove them. Cookies can remember login information, preferences, and similar information.

 

Cookies, as well as other tracking technologies, such as HTML5 local storage, and Local Shared Objects (such as “Flash” cookies), and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data. We may also use web beacons or “pixels,” and in certain circumstances may collect IP address, screen resolution and browser software and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data.

 

If you want to block the use and saving of cookies from the Website on to the computer’s or other electronic device’s hard drive, you should take the necessary steps within your web browser’s settings to block all cookies from the Website and external serving vendors, or use the cookie control system, if available upon first visit, which is available here. Please note that if you choose to erase or block your cookies, certain parts of our Website may not function correctly. For information on how to disable cookies, refer to your browser’s documentation.

 

We may also use what is known as “client-side page tagging,” which uses code on each page to write certain information about the page and the visitor to a log when a page is rendered by your web browser. This technique is also commonly used on commercial websites. “Tagging” does result in a JavaScript program running on your computer, but it is limited to providing information about the page that you are requesting and the configuration of your browser. It will not read any of your data files, or execute any additional programs. It does not extract any personal information about you, such as your name or address. You can prevent tagging by disabling JavaScript in your browser, but that may prevent you from using all of our Website’s functions.

Children under 18

We do not knowingly collect information from individuals under the age of 18 years without parental consent. We do not have actual knowledge that we “sell”, as that term is defined in the California Consumer Protection Act, the personal information of minors under 16 years of age.

 

If you become aware that an individual under 18 years of age has provided us with personal information without parental consent, please contact us at [email protected] or at (877) 258-4010. If we become aware that an individual under 18 years has provided us with personal information without parental consent, we will take steps to remove the data as required by law.

Email confidentiality

We welcome your comments or questions about our Website and Services. You can email your comments to our customer support center at [email protected]. We will share your comments and questions with our customer support representatives and those employees most capable of addressing your questions and concerns. Please note that your email, like all non-encrypted Internet email communications, may be accessed and viewed by other Internet users, without your knowledge and permission, while in transit to us. For that reason, to ensure privacy, please do not use email to communicate information to us that you consider confidential. If you wish, you may contact us instead by telephone at (877) 258-4010.

How can you stop receiving emails?

Each marketing or other commercial email we send to you contains an unsubscribe link through which you may easily opt-out of receiving future commercial emails from us. If you do not wish to receive additional commercial emails from Quartet, simply click the unsubscribe link and follow the instructions to unsubscribe your email address. If you have unsubscribed but continue to receive email from us or from one of our customers, you may report this to us by calling (877) 258-4010 or emailing us at [email protected]. Please note that unsubscribe requests may take up to 7 – 10 days to process. You will have the ability to opt out of any marketing or advertising communications, but we may still send Account related communications for purposes important to the Services, such as password recovery, or other issues relevant to your Account.

Linking to other sites?

From time to time, Quartet may provide links to other websites that we think might be useful or interesting – these are not owned or controlled by Quartet and may be subject to separate terms of use and privacy policies. While we try to be proactive and ensure that appropriate protections are in place, we cannot be responsible for the privacy practices used by other website owners or the content or accuracy of those other websites. Links to various non-Quartet websites do not constitute or imply endorsement by Quartet of these websites, any products or services described on these sites, or of any other material contained in them.

Account security

For registered users, your Account is protected by a password for your privacy and security. You must prevent unauthorized access to your Account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser. We endeavor to protect the privacy of your Account and other Personal Information we hold in our records, but unfortunately, we cannot guarantee complete security. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

What personal information can users (you) access?

Registered users will be able to change their password and update the information provided to us, such as address, contact information and health information, by going to the Account Settings page accessible by logging in at patient.quartethealth.com or careteam.quartethealth.com. Registered and unregistered users can access and delete cookies through their web browser settings.

 

The information individual users can view, update, and delete may change as the Services change. If you have any questions about viewing or updating information we have on file about you, please contact us at [email protected].

What choices do I have?

You can use certain features of the Services without registering, thereby limiting the types of information that we collect. You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

 

If you have registered for the Services, you may be able to add, update, or delete information in your Account as explained above. When you update information, however, we may maintain a copy of the unrevised information in our records in accordance with applicable law. You may request deletion of your Account by emailing us at [email protected] or by calling us at (877) 258-4010.

Do-Not-Track

Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third-parties as defined by the initiative. Please note that the Website does not alter its behavior or use practices when we receive a “Do-Not-Track” signal from browser software.

Your privacy rights

Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information (as defined by California law) the business discloses to third parties for those third parties’ direct marketing purposes, and the identities of the third parties with whom the business has disclosed such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at [email protected] with “Request for California Privacy Information” in the subject line and in the body of your message. Please be sure to provide in the request sufficient information to properly identify you and/or the members of your family.

Changes to this privacy policy

Quartet may change this Privacy Policy from time to time. When material updates are made, the Privacy Policy version date will also be updated to reflect that a revision occurred, and we will alert you to changes by placing a notice on www.quartethealth.com, by sending you an email, and/or by some other means. We encourage you to periodically reread this Privacy Policy to see if there have been any changes that may affect you. A user is bound by any changes to the Privacy Policy when using the Website or Services after such changes have been first posted. This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party.

Contact us

If you have any comments, concerns or questions about this Privacy Policy, please contact us at [email protected] or at:

 

Quartet Health, Inc.
114 West 41st Street, 5th Fl
New York, NY 10036