Arc Life Health, Inc. (“Arclife,” “we,” “us,” or “our”) respects your privacy. This supplemental Consumer Health Data Privacy Policy (“CHD Privacy Policy”) describes how we collect, use, disclose, and otherwise process Consumer Health Data (“CHD”) as that term is defined under applicable U.S. state health-privacy laws, including Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law (SB 370), and similar laws as they take effect (together, “U.S. Health Privacy Laws”).

 

This CHD Privacy Policy supplements and should be read together with our Privacy Policy and Terms of Use. Capitalized terms that are not defined here have the meanings given in our Privacy Policy. If there is any conflict between this CHD Privacy Policy and our Privacy Policy with respect to Consumer Health Data, this CHD Privacy Policy controls.

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What Is Consumer Health Data

“Consumer Health Data” means personal information that is linked or reasonably linkable to a consumer and that identifies the consumer’s past, present, or future physical or mental health status. CHD includes medical conditions as well as non-medical information, such as biometric data, the use of non-prescription medication, or the use of health-related services, for example.

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Categories of Consumer Health Data We Collect

Arclife collects only the Consumer Health Data needed to provide the services you request or that you choose to provide to us. We collect the following categories:

• Medical, physical, and mental health conditions, and biometric information, such as blood pressure, weight, heart rate, or other related vitals, health metrics, or diagnoses;

• Approximate location or region derived from your mobile telephone number, for example, your area code, which we use to schedule reminders at appropriate times for your location or time zone;

• Health information you provide through our services, including the medications you take, medication reminders you set, your medical history, reports about how you are tolerating a medication, such as side effects or symptoms, and health-related questions you submit to us, or your experience with our services;

• Information you provide when responding to our surveys, including any of the above categories about physical or mental health, medical history, or other health-related information; and

• Any inferences of the above categories of consumer health data derived or extrapolated from non-health information, such as data analytics we may perform on the data you provide, such as medication adherence.

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Sources of Consumer Health Data

We collect Consumer Health Data from the following sources:

• Directly from you — when you enroll in or use our services, set medication reminders, report tolerance or side-effect information, or ask us questions; and

• From your interactions with our services — such as your responses to our text messages.

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We do not purchase or receive Consumer Health Data from data brokers, advertising networks, or marketing partners.

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How We Use Consumer Health Data

We use Consumer Health Data only for the following purposes:

• To provide the services you request, including sending medication reminders, collecting and responding to tolerance and side-effect reports, and answering your inquiries;

• To determine appropriate reminder timing, including based on your general location or time zone;

• To communicate with you about your care and the services (for example, transactional messages, reminders, and confirmations);

• To maintain the quality, safety, and security of our services, including service improvement, troubleshooting, fraud, and threat prevention; and

• For recordkeeping and auditing, and to comply with our legal and regulatory obligations.

 

We do not use Consumer Health Data to serve targeted advertising, and we do not sell Consumer Health Data. We do not use your Consumer Health Data to send you marketing for any third party’s products or services.

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How We Disclose Consumer Health Data

We disclose Consumer Health Data only as follows:

• Service providers and processors. We share Consumer Health Data with vendors that perform services on our behalf, for example, cloud hosting and text message delivery providers, who are contractually permitted to use it only to provide services to us and not for their own purposes.

• Healthcare and care management partners under a Business Associate Agreement. Where we provide services to or on behalf of a healthcare organization or care management partner, the related health information is handled as Protected Health Information under HIPAA and the applicable Business Associate Agreement.

• Legal, safety, and security. We may disclose Consumer Health Data: (i) with your consent; (ii) to protect your vital interests, such as in a medical emergency; (iii) to detect, prevent, or respond to security incidents, fraud, or illegal activity, or to preserve the integrity and security of our systems; (iv) to comply with applicable law or legal process; and (v) to an acquiring or successor organization in connection with a merger, acquisition, or sale of all or part of our business, subject to this CHD Privacy Policy.

• Affiliates. We may share Consumer Health Data with our affiliates — entities that control, are controlled by, or are under common control with Arclife — who are bound by this CHD Privacy Policy.

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Location Information

Today, we use only approximate location — generally the region indicated by your telephone area code — to schedule reminders at appropriate times. In the future, we may collect more precise location information. If we introduce that feature, we will collect precise location data only with your consent, use it only to provide the reminder service you have requested, and update this CHD Privacy Policy accordingly.

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We do not use geofencing around any healthcare facility, and we do not collect or use location information to identify, track, or infer your visits to healthcare providers or facilities.

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Consent and Withdrawal

We collect, use, and disclose Consumer Health Data only as necessary to provide the services you request or with your consent. Before collecting, using, or sharing Consumer Health Data for any purpose beyond providing the services you have requested, we will obtain your affirmative consent.

 

You may withdraw your consent at any time. For example, to stop text messages, reply STOP to any message, or contact us at support@arclifehealth.com. You may also withdraw consent or ask us to stop processing your Consumer Health Data by contacting us at that email address. Withdrawing consent will not affect processing that took place before your withdrawal.

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Your Privacy Rights

Subject to applicable law, you have the following rights regarding your Consumer Health Data:

• Right to confirm and access: To confirm whether we are collecting, using, or sharing your Consumer Health Data and to access that data, including a list of the third parties and affiliates with whom we have shared it;

• Right to correct: To correct your consumer health data. If your consumer health data we hold is inaccurate and you would like us to rectify it, you may submit a correction request to support@arclifehealth.com and indicate your request type as “Right of correction”.

• Right to withdraw consent: To withdraw consent to our collection or sharing of your Consumer Health Data;

• Right to delete: To request that we delete your Consumer Health Data; and

• Right to appeal: To appeal our refusal to act on any of the above requests.

 

Residents of certain states may have additional rights under our Privacy Policy or applicable law, such as a right to correct inaccurate information.

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How to Exercise Your Rights

To exercise any of these rights, contact us at support@arclifehealth.com and tell us which right(s) you wish to exercise. We will verify your request and respond within the time required by applicable law, generally 45 days, which we may extend as the law permits, with notice to you. We may ask for information to verify your identity and the validity of your request. An authorized agent may submit a request on your behalf; we may require proof of the agent’s written authority, such as a power of attorney. If we decline your request, we will explain why and tell you how to appeal.

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Changes to This CHD Privacy Policy

We may update this CHD Privacy Policy from time to time in response to changing laws, regulations, or our practices. If we make material changes, we will provide notice as required by U.S. Health Privacy Laws, including, where appropriate, by notifying you directly using your contact information. We will post the updated policy at www.arclifehealth.com before the changes take effect.

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Contact Us

If you have questions or concerns about this CHD Privacy Policy or our handling of your Consumer Health Data, contact us at support@arclifehealth.com.