Twine Health Privacy Policy

Service

Twine Health, Inc. (Twine Health) owns and operates the website www.twinehealth.com (the Site). Twine Health also develops, operates and distributes certain software applications (Apps), which include hosted applications and applications for mobile devices. The Site and the Apps, together with the collaborative patient care services for coordination, management, coaching and communications by patients and health care personnel regarding medical conditions (including patient goal setting, care planning, compliance and outcome tracking), and the data collection, storage, analysis and reporting tools, functions and services, that are provided at the Site and/or via the Apps, are collectively referred to as the Service.

The following policy explains how Twine Health collects, uses and disseminates information obtained from or about you as a user of the Service. Capitalized terms used herein without definition will have the same meanings as defined in the Terms of Service applicable to the Service, which are available at www.twinehealth.com/terms-of-service.

Information Collected

When you visit the Site or otherwise access the Service, web servers collect general information about your visit (such as, for example, traffic data like time, date and the address of the website from which you entered the Site), which is stored as anonymous, aggregate data. Twine Health also collects more specific information about you and your use of the Service (such as, for example, demographic data, profile data and frequency or duration of use). Collecting such data (collectively, Traffic Data) may entail the use of software programs, web beacons, pixel tags, cookies, IP addresses or other numeric codes used to identify a computer.

The Service may be accessed: by visiting the Site directly; or by using an App that is downloaded from Twine Health (or a Channel Partner), which then communicates with Twine Health’s web servers.

Regardless of how you access the Service, to ensure the integrity of the Service, you must complete an account registration process and provide Twine Health with current, complete and accurate information, as more specifically required by then current registration procedures and operational prompts. If some or all of your registration information has already been provided to Twine Health by the Clinical Partner, then you will need to review and confirm, complete or correct your information.

By way of illustration and not limitation, you may be required to provide the following information in order to establish your account and register for and use the Service: name, address, telephone number, e-mail address, username, password and certain preferences and permissions.

Whenever you interact with the Service, a variety of technologies are employed to automatically or passively collect Service Data. The term Service Data means all data and information that are provided by you during registration and subsequent use of the Service (including messaging related to Healthcare Services), and all other data and information about you that are otherwise discerned or collected by Twine Health based on your access and use of the Service. For clarity, Service Data includes, but is not limited to: PII; PHI; browser or device type; operating system; time of day; identification of Site or App page views; use of particular Service features (such as, for example, report requests or viewing or responding to queries from Clinicians); geographic location. At no time will an App access, collect or store any of the personal contacts or photographs or any other information stored on your device without your permission.

Children

Twine Health will not collect personally identifiable information from any person who is actually known to us to be under the age of 13. If we become aware that a person under 13 has provided personally identifiable information, Twine Health will take steps to remove such information and terminate that individual’s account, access and use of the Service.

Use of Information

Except as set forth below, at no time will any of your Personal Data be shared with any third party by Twine Health. Your IP address is not linked to personally identifiable information, but is used to gather broad demographic data and to monitor statistics to improve the Service.

Twine Health uses Traffic Data to help diagnose problems with its web servers, to administer the Service and to analyze user trends and behaviors. Twine Health will share Traffic Data with certain third parties for the purposes of technical and customer support.

Twine Health collects, stores, processes and analyzes Service Data and produces Analytics. The term Analytics means user profiles and statistics, metrics, abstractions and other analyses that are based on or derived from the Service, Service Data or your use of the Service (including without limitation, measurements of Service usage and performance), which are developed in a manner that does not disclose the identity of the Clinical Partner or any Clinician or Patient (such as, in the aggregate with other data, results and measurements) and that does not disclose any specific Service Data (unless in aggregated or de-identified form).

Twine Health will use your Service Data and exploit Analytics in the manner and for the purposes described in the Terms of Service, including without limitation: to use Service Data to communicate with you and (as applicable) your Patients, Clinician(s) and Clinical Partner; to include, copy, disclose, distribute, transmit and display Service Data in communications between a Patient and his or her Clinician (and vice versa) that have been properly initiated via the Service; to access, record, collect, copy, store, process, analyze and use Service Data to provide the Service (including with regard to the use of PHI in messaging between a Patient and his or her Clinician); to develop, improve, extend and test the Service (and underlying technology platforms); to design, develop and produce Analytics; to market and promote Twine Health and the Service using Analytics; and to disclose, distribute and transmit Service Data and/or Analytics to Clinical Partners.

IP Addresses, Cookies and Local Storage

Twine Health uses your IP address to help diagnose problems with its web servers and administer the Service. Your IP address is used to help identify you and to gather demographic information. IP addresses are also used to provide an audit trail regarding use of the Service.

Cookies are pieces of information that a website transfers to your computer's hard disk for record-keeping purposes. Cookies in and of themselves do not personally identify users, although they do identify a user's computer.

At this time, the Service does not utilize cookies. However, Twine Health does use the local storage on your device to track whether or not you are logged in. We do not save any other information about you in local storage.

Do Not Track Policy

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities, over time and across different websites.

When you turn on the Do Not Track function in your browser, Twine Health stops collecting the information from your browser that allows us to tailor the Service specifically to you and to develop valuable Analytics. Do Not Track signals are set on a browser-by-browser basis, so you must set them on every browser you use if you do not wish to be tracked.

For clarity, this is just our Do Not Track policy. Twine Health cannot and does not make any promise about how third parties react when you set the Do Not Track signal on your browser. In addition, the Do Not Track signal does not apply to the use of information collected prior to such request.

Sharing of Personal Data

Currently, Twine Health will not share Personal Data with any third party for purposes that are not related to the Service or its arrangements with applicable Clinical Partners. Twine Health may, however, disclose Personal Data if (a) reasonably necessary for Twine Health (or its service providers) to operate the Service, including processing your queries, responses and other messages, (b) to communicate with Patients, Clinicians and Clinical Partners, (c) otherwise permitted under the Privacy Policy or elsewhere in the Terms of Service, (d) Twine Health reasonably believes that such action is necessary to conform or comply with any legal, regulatory, law enforcement or similar requirement or investigation, to protect or defend the rights or property of Twine Health or any third party or to enforce the Terms of Service or (e) otherwise authorized by you.

HIPAA

In operating the Service, and as it relates to PHI, Twine Health endeavors to comply in all material respects with HIPAA.

California Residents

Under California Civil Code Section 1798.83 (the "Shine the Light" law), California residents who provide personal information in obtaining products or services from Twine Health are entitled to request and obtain from us once a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g., requests made in 2015 will receive information regarding 2014 sharing activities). If you are a California resident and would like a copy of this information, please submit a written request to:

Twine Health, Inc. Attn: California/Shine the Light 1430 Massachusetts Avenue, 2nd Floor Cambridge, MA 02138

Business Transfers

Twine Health may transfer Traffic Data, Service Data (including Personal Data) and Analytics to any successor to all or substantially all of its business or assets that concerns the Service. In the event of any such transfer, the successor will have all of the rights and be subject to all of the obligations of this Privacy Policy, including, without limitation, the right to modify or replace this Privacy Policy, as provided herein.

Security

Information collected by Twine Health is stored in operating environments that are secured using commercially available tools and procedures, and which are not made generally available to the public. Unfortunately, no data transmission over the Internet and/or wireless networks can be guaranteed to be 100% secure. As a result, Twine Health cannot unequivocally guarantee the security of any information you provide, and you do so at your own risk. Once Twine Health receives your information, it will make reasonable efforts to ensure its security on Twine Health's systems.

Connections

You may be able to obtain an App, access the Service and/or communicate with the Service from, and you may be able to link or communicate from the Service to, applications, devices, distribution platforms and websites owned and operated by Channel Partners and Clinical Partners. These other applications, devices, platforms and websites are not operated or controlled by Twine Health. These other applications, devices, platforms and websites are not operated or controlled by Twine Health. Additional or different terms and conditions (including without limitation, privacy and security practices) apply when you access and use such other applications, devices, platforms and websites, which are not the responsibility of Twine Health.

Termination

If you terminate your registration and account for the Service, or if your registration or account is terminated for any reason by Twine Health, then Twine Health will remove your Service Data from the Service; provided, Twine Health may retain and use your Service Data in the manner described herein, but only in aggregated or de-identified form.

Non-US Users.

YOU EXPRESSLY CONSENT TO THE TRANSMISSION, COLLECTION, STORAGE, PROCESSING AND USE OF THE ANALYTICS AND YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. YOUR PERSONAL DATA MAY BE COLLECTED, STORED, PROCESSED, USED AND TRANSMITTED WITHIN, FROM AND TO THE COUNTRY WHERE IT WAS COLLECTED AND THE UNITED STATES. UNITED STATES LAWS REGARDING THE USE OF PERSONAL DATA MAY BE LESS STRINGENT THAN THE LAWS IN YOUR COUNTRY.

Updates

Twine Health reserves the right, at its sole discretion, to update, modify or replace this Privacy Policy, in whole or in part, at any time. Twine Health will use reasonable efforts to notify you of any material change in advance of the effective date of any change. Change notices may be communicated by postings at the Site, via the Apps, e-mail or otherwise. In any case, you should periodically check this Privacy Policy for changes. Continued access or use of the Service following any change to this Privacy Policy constitutes your acceptance of those changes. The Privacy Policy may not otherwise be amended, as they apply to you, except by a written agreement executed by you and Twine Health.

Information collected by the Service is subject to the Privacy Policy in effect at the time of use.

You may correct or otherwise change your registration data by contacting Twine Health, as provided below.

Contact

If you have any questions regarding this Privacy Policy or your dealings with the Service, please visit www.twinehealth.com/ or contact us at:

Twine Health, Inc. Attn: Privacy Policy 210 Broadway #201 Cambridge, MA 02139

E-mail: marketing@twinehealth.com