Legal

Effective October 13, 2022

This Privacy Policy explains how Healthy Together (“Healthy Together,” “we,” “us,” or “our”) may collect, use, disclose, and otherwise process your personal information through our digital properties that link to this Privacy Policy, including our website and mobile application (the “Service”).

Healthy Together has developed different initiatives in coordination with epidemiologists and public health officials to increase the reach and efficacy of the public health response related to COVID-19, improve health equity, improve health and human services, and reduce cost. This Privacy Policy is designed to describe our privacy practices in a comprehensive manner. Because there are a number of different modules available through the Service, depending on the module(s) you are using, we may collect fewer types of personal information—or disclose information in fewer ways—than described in this Privacy Policy. If a module you are using collects more information than described in this Privacy Policy, we will provide a supplementary notice at or before the point of collection.

Your use of Healthy Together is voluntary. You may deactivate your account at any time from within the Service and direct us to delete your personal information.

HOW WE COLLECT YOUR PERSONAL INFORMATION

When you use the Service, we will ask you to share certain personal information with us. We will also receive information from U.S. local, state, and federal government organizations, as well as other entities that you authorize, and collect certain technical, device, and usage information from your device.

Information You Provide To Us. Personal information you may provide to us through the Service or otherwise includes:

Registration and Profile Information. You may provide certain personal information when you register to use Healthy Together, including, among other things, your full name, zip code, phone number, email address, billing and mailing address, date of birth, biographical details, username and password that you may set to establish an online account, and other information that you add to your account profile.

User-Generated Information. You may provide information regarding your non-medical needs and other content or information that you generate, transmit, or otherwise make available on the Service.

Health-Related Information. Through your use of the Service, you may choose to submit personal information about yourself, such as your age, reported height and weight, your pre-existing conditions, and other health-related information.

Vaccination Records and Health Test Results. You may choose to upload a photo of your vaccination records and/or health test results (including for COVID-19), as well as details such as the type of test, test date, and location, so they can be stored and easily accessed from your account. Healthy Together cannot access your camera or stored photos without your permission. We will never access or upload stored photos from your device unless you have selected them for upload.

Demographic Information. You may provide information regarding your race, ethnicity, preferred language, and state and county of residency.

Relationship Information. You may provide information about your family members or other third parties.

Transactional Information. You may provide information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.

Financial and Related Information. You may provide information regarding your finances, such as your stated income and economic standing, as well as your EBT information.

Identification Number Information. You may share your identification number information, such as national identification number (e.g., Social Security Number, tax identification number, passport number), state or local identification number (e.g., driver’s license or state ID number), student ID number, employee ID number, or other forms of identification, and an image of the relevant identification card.

Communications Data. We may collect communications data from our exchanges with you, including when you contact customer support personnel through the Service, social media, or otherwise.

Scans of QR Codes. You may choose to use your device camera to scan a QR code to connect test results to your account or to verify symptom information to a third-party entity, such as a school, employer, or other party. We cannot access your camera without your permission.

Information about Selected Contacts. With your consent, we may receive the name and phone number of individuals from your device’s contact list for case interview purposes if you test positive for a local, state or nationally notifiable disease. We only receive the specific contacts you choose to share with us whom you believe may have been exposed to a communicable disease (“Selected Contact”). If you choose to share a Selected Contact, we may share this information with U.S. state and local government organizations in order to assist them with case interview activities.

Other Information. You may provide other information not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Third-Party Sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:

Public Sources. We may receive information about you from our government or school partners to offer health or benefits-related services. For example, if we partner with your state of residency to administer applications for public benefits, or to display your medical test results through the Service, then we may receive your contact information and related information in order to provide these services. You may also choose to connect your Healthy Together account with your government or school accounts.

Marketing Partners. We may receive information about you from joint marketing partners.

Third-Party Services. We may combine personal information we receive from you with personal information we obtain from third-party services that you use to log into, or otherwise link to, your Service account. This data may include your username and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:

Device, Technical and Usage Information. When you access the Service, we collect information about your mobile device or computer system, including MAC address, IP address, and mobile device ID. We also generate usage statistics about your interactions with the Service. This information is typically collected through the use of server log files or web log files, mobile device software development kits and tracking technologies like browser cookies to analyze certain types of technical information. Some of the cookies the Service places on your computer are linked to your user ID number. When you respond to communications we send you, we may use automated technology to understand how you interact with the communications. You can usually remove or reject browser cookies through the settings on your browser or device. At this time, we do not recognize automated browser signals regarding tracking mechanisms, which may include “do not track” instructions. We may also use local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications. We may also use web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

HOW WE USE YOUR PERSONAL INFORMATION

We may use your personal information for the following purposes or as otherwise described at the time of collection:

Service delivery and business operations. We may use your personal information to:

provide, operate and improve the Service and our business;
establish and maintain your user profile on the Service;
facilitate your invitations to friends who you want to invite to join the Service;
facilitate features of the Service, such as by providing chat or messaging functionality
enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
connect you with certain U.S. state and local government organizations within your state, county, or city;
understand your needs and interests, and personalize your experience with the Service and our communications; and
provide support for the Service, and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing. We may collect and use your personal information for marketing purposes. We may send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

Compliance and protection. We may use your personal information to:

comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
audit our internal processes for compliance with legal and contractual requirements or our internal policies;
enforce the terms and conditions that govern the Service; and
prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

To create aggregated, de-identified and/or anonymized data. We may create aggregated, de-identified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into de-identified and/or anonymized data by removing information that makes the data identifiable to you. We may use this aggregated, de-identified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business. We may also share de-identified information with public interest organizations, health care organizations, and researchers. We will prohibit these organizations from attempting to re-identify the information we share with them to the extent practical.

Cookies and similar technologies. In addition to the other uses included in this section, we may use the cookies and similar technologies described above for the following purposes:

Technical operation. To allow the technical operation of the Service, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password protected areas of the Service.

Functionality. To enhance the performance and functionality of our services.

Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we may use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout?hl=en.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

We may share your personal information with third parties where you have instructed us or provided your consent to do so. With your consent, we may share your personal information with U.S. local, state, and federal government organizations and public health organizations for the purposes we have set out in this Privacy Policy relating to public health efforts. For example, a government or public health organization may request your checkup data or your test results if you have tested positive for a communicable disease (e.g., COVID-19) to assist with its case interview efforts. We may also share your personal information with other third parties relating to public health intervention and response efforts, such as your university or employer, if you have authorized us to do so.
If you log into the Service with, or otherwise link your Healthy Together account to a third-party service, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy and the settings associated with your account with the third-party service.

Other Disclosures

We may share personal information with third-party service providers that perform services on our behalf, including: to help operate the Service; to conduct quality assurance testing; to facilitate the creation of accounts; to optimize the performance of the platform; to provide technical support; and/or to provide other related services. We may also share your personal information with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

We may share personal information with government, law enforcement officials or private parties as required by law, when we believe such disclosure is necessary or appropriate (a) to comply with legal obligations, law enforcement requests or legal directives such as a court order or subpoena; (b) enforce the terms and conditions that govern the platform; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

We may share your personal information with acquirers and other relevant participants in connection with business transactions (or negotiations of or due diligence for such transactions) such as a merger, consolidation, acquisition, spinoff, reorganization or sale of assets or in the event of bankruptcy. We will notify you of any change in ownership that affects your personal information so that you may decide whether to keep your account active or delete your account.

We make commercially reasonable efforts to verify that the parties with whom we share personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

Please note that we do not sell personal information.

Your Sharing

We may make available on the Service, or link to, features that allow you to share information with third parties. Please be careful whenever sharing your personal information with third parties, and only share sensitive personal information with third parties whom you trust. We have no control over the use of your information by third parties with whom you choose to share your information.

RETENTION OF YOUR INFORMATION

We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.

When we no longer require the personal information we have collected about you, we may either delete it, anonymize it, or isolate it from further processing. You may also choose to delete your personal information and deactivate your account, as described below under Your Choices.

SECURITY OF YOUR INFORMATION

We have implemented a number of security measures reasonably designed to protect your personal information. It is important that you protect and maintain the security of your account, and you should immediately notify us of any unauthorized use of your account. No website, mobile application, or Internet transmission is completely secure, and therefore we cannot guarantee that unauthorized access, hacking, data loss, or other breaches or other types of misuse will never occur. Be careful where and how you share personal information—use public WiFi spots wisely and avoid clicking unfamiliar links or using unfamiliar devices.

In the unlikely event that Health Together experiences a security breach affecting your personal information, we will notify you as required by applicable law. This notice will include information about what happened and the data involved, what steps we have taken to address the incident, and what steps you can take to further protect yourself.

YOUR CHOICES

Accessing and Updating Your Information. If you have an account with us, you can access and edit your profile information directly within the profile page of the Service.

Deactivating Your Account and Deleting Your Information. You may deactivate your account at any time by following the instructions within the Service settings. If you deactivate your account, we will delete all of your personal information within 45 days, except to the extent we are required to retain the information by law or record retention policies of the governmental authority on whose behalf we provided the Service to you.

Opting Out of Push Notifications. If you opt-in to receive push notifications within our mobile applications, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by deleting the mobile app, changing your device settings, or changing the push notification settings within the mobile app.

Opting Out of SMS Communications. If you opt-in to receive SMS messages by providing your phone numbers, we may send you notifications and other SMS messages from time to time. You may opt out of receiving SMS communications at any time by responding to any SMS with the single-word command, “STOP.” In addition, if you have an account, you can opt out of SMS communications by changing your settings within the Service. You may opt back into SMS communications at any time by adjusting your account settings within the Service. Please note we may not be able to determine if you delete or uninstall the mobile app, or block the number that delivers the communications, and therefore we may be unable to automatically stop you from receiving SMS communications unless you have specifically opted out of SMS communications by following the instructions above.

AGE REQUIREMENTS

Healthy Together is not intended for children under the age of 13, and we do not knowingly collect any personal information from children under 13. However, we do have certain features where we request information from a parent or guardian about their dependent(s).

If we become aware that an individual under the age of 13 has used the Service, then we will promptly delete their information, unless we are prohibited by law from doing so.

ADDITIONAL NOTICE TO CALIFORNIA RESIDENTS

This section describes how we collect, use, and share Personal Information of California residents in our capacity as a “business” under the California Consumer Privacy Act (“CCPA”) and their rights with respect to that Personal Information. For purposes of this section, the term “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA. In some cases, we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

We collect the types of Personal Information from you as described above (How We Collect Your Personal Information). We use this Personal Information for the business purposes described above (How We Use Your Personal Information). We share personal information as described above under How We Share Your Personal Information.

Your California privacy rights. California residents have the rights listed below under the CCPA. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law. Please note that we do not sell your personal information.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:

The categories of Personal Information that we have collected.
The categories of sources from which we collected Personal Information.
The business or commercial purpose for collecting and/or selling Personal Information.
The categories of third parties with which we share Personal Information.
The categories of Personal Information that we sold or disclosed for a business purpose.
The categories of third parties to whom the Personal Information was sold or disclosed for a business purpose.

Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.

Deletion. You can ask us to delete the Personal Information that we have collected from you.

Nondiscrimination. You are entitled to exercise the rights described above free from discrimination as prohibited by the CCPA.

Exercising your right to information, access and deletion. You may submit requests to exercise your right to information, access or deletion by emailing us at support@healthytogether.zendesk.com or by mailing your request to:

Twenty Labs, LLC, 382 NE 191st, St PMB 42782, Miami, Florida 33179-3899

We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity to process your information, access, and deletion requests and reserve the right to confirm your California residency. To verify your identity, we may require government identification, a declaration under penalty of perjury, or other information.

Your authorized agent may make a request on your behalf upon our verification of the agent’s identity and our receipt of a copy of a valid power of attorney given to your authorized agent pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent with written and signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with confirmation that you have given the authorized agent permission to submit the request.

CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy from time to time. We will notify you if we make material changes to our Privacy Policy by either posting the changes on the Service or by contacting you directly using the contact information you have on file with us. The notification will also state when the changes will become effective.

By continuing to use the Service after the Privacy Policy is updated, you will have agreed to the new Privacy Policy.

CONTACTING US

If you have any feedback, questions, comments, or concerns about this Privacy Policy or our privacy practices, please send an email to support@healthytogether.zendesk.com or write to us at the following address:

Twenty Labs, LLC

382 NE 191st St

PMB 42782

Miami, Florida 33179-3899

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