DrOwl Privacy Policy

Last modified: November 10, 2020

1.   Introduction

This Privacy Policy describes how DrOwl collects and uses Personal Data about you through the use of our Website, mobile applications, and through email, text, and other electronic communications between you, DrOwl Health Technologies, LLC.

DrOwl Health Technologies, LLC (  “DrOwl,” “we,” “our,” or “us”) respects your privacy, and we are committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit the websites DrOwl.com (our “Website”) and the DrOwl application (our “Application”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect: on our Website and Application;

in email, text, and other electronic messages between you and our Website and Application;

when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by DrOwl or any third party; any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website or Application.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website and Applications. By accessing or using our Website and/or Application, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). We will notify you by email to the email address specified in your account and through the Application’s home screen of any changes that we make to the privacy policy. Your continued use of our Website or Application after we make changes is deemed to be acceptance of those changes.

2.  Children Under the Age of 18

Our services (exclusive of the check in / screening tool) are not intended for children under the age of 18 years of age without receiving prior verifiable consent from a parent or guardian. No one under the age of 18 (whose parent or guardian has not provided DrOwl with prior verifiable consent) may provide any information to or through the Website or Application. We do not knowingly collect Personal Data from children under the age of 18 without prior verifiable consent from a parent or guardian. If you are under the age of 18, do not use or provide any information on our Website or in our Applications or on or through any of their features, including, without limitation, your name, address, telephone number, email address, or any screen name or user name you may use, unless we have received prior verifiable consent from a parent or guardian. If we learn we have collected or received Personal Data from a child under the age of 18 without parental or guardian consent, we will delete that information. If you believe we might have any information from a child under the age of 18 for telehealth services, please contact us immediately at help@drowl.com or call us at (505) 348-8700.

DrOwl does not knowingly collect, use, distribute or solicit any information from anyone under the age of 13 for our telehealth services without prior verifiable consent from a parent or guardian. In the event that we learn that we have inadvertently collected personal information from a child under age 13 without prior verifiable consent from a parent or guardian, we will delete that information immediately. If you believe that we might have any information from a child under age 13 without prior verifiable consent from a parent or guardian, please contact us immediately at privacy@drowl.com.

3.  Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies.

4.   Generally

We collect several types of information from and about users of our Website and Application (collectively, “Personal Data”), specifically information:

by which you may be personally identified, such as name, address, e-mail address, telephone numbers, date of birth, bank account numbers, credit or debit card number (for payment purposes only), images and video of you, Social Security Number, your medical history, your race or ethnicity, gender, age, health records and other health information;

about your Internet connection, the equipment you use to access our Website or use our Application and usage details, such as traffic data, logs, referring/exit pages, date and time of your visit to our Website or use of our Application, error information, clickstream data, and other communication data and the resources that you access and use on the Website or through our Application.

We collect this information:

directly from you when you provide it to us;

automatically as you navigate through the Website or use our Application. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and From third parties, for example, our business partners.

5.   Information You Provide to Us

The information we collect on or through our Website or through our Application is:

information that you provide by filling in forms on our Website or the Application. This includes information provided at the time of registering to use our Website or Application, using our services, integrating or granting us access to your health records, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Website or Application;

records and copies of your correspondence (including email addresses), if you contact us; and

details of transactions you carry out through our Website or through the Application and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website or Application.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website or Application or transmitted to other users of the Website or Application or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk.

Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website and Application with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

6.   Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website and Application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

  • usage details, such as details of your visits to our Website or Application, such as traffic data, location, logs, referring/exit pages, date and time of your visit to our Website or use of our Application, error information, 
  • clickstream data, and other communication data and the resources that you access and use on the Website or in the Application;
  • stored information, metadata, and other information associated with other files stored on the user’s device, including photographs, audio and video clips, personal contacts, and address book information;
  • Real-time location data, as in location information through Google Maps; or
  • information about your computer, mobile device, and Internet connection, such as your IP address, operating system, browser type, mobile network information, device’s telephone number, and Application version information.
  • The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Website and Application and to deliver a better and more personalized service by enabling us to:
  • estimate our audience size and usage patterns; develop and improve our products and services;
  • store information about your preferences, allowing us to customize our Website and our Application according to your individual interests or relevant information;
  • recognize you when you return to our Website and our Application. The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). We and our service providers may use cookies, and other technologies to receive and store certain types of information whenever you interact with our Website and Application through your computer or mobile device. A “cookie” is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Website or use certain parts of our Application. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website or use our Application.

Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Website. Google Analytics uses cookies to help the Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at google.com/policies/privacy/partners/).

7.   How We Use Your Information

We use your Personal Data for various purposes described below, including to:

  • provide our Website or Application to you; provide products and services to you;
  • provide you with information you request from us; enforce our rights arising from contracts;
  • notify you about changes; and
  • provide you with notices about your account.
  • We use information that we collect about you or that you provide to us, including any Personal Data:
  • to present our Website and its contents to you; to present our Application;
  • to provide our products and services to you;
  • to provide you with information, products, or services that you request from us or that may be of interest to you;
  • to provide you with notices about your DrOwl account; to contact you in response to a request;
  • to fulfill any other purpose for which you provide it;
  • to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
  • to notify you about changes to our Website, our Application, or any products or services we offer or provide though them;
  • in any other way we may describe when you provide the information; and for any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or by visiting your Account Preferences page. For more information, see Choices About How We Use and Disclose Your Information.

Some information DrOwl collects constitutes protected health information (“PHI”) under the U.S. Health Insurance Portability and Accountability Act (“HIPAA”). DrOwl may use your PHI to contact you to the extent permitted by law, to provide requested services, to provide information to you, or to respond to your inquiries and requests. We may combine your information with other information about you that is available to us, including information from other sources, such as from your Providers, insurers or benefits program, in order to maintain an accurate record of our participants. PHI will not be used for any other purpose, including marketing, without your consent.

8. Disclosure of Your Information

 We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

  • our affiliates and third party service providers that we use to support our business;
  • to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form;
  • to comply with our legal obligations;
  • to enforce our rights; and with your consent.
  • If there are any material changes to the ownership of DrOwl we will notify you by email to the email address specified in your account.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose Personal Data that we collect or you provide as described in this privacy policy:

  • to affiliates, contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, and ordering, marketing, and payment processing services. Our payment processor’s privacy policy is available here  https://www.paypal.com/us/webapps/mpp/ua/privacy-full;
  • to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy,
  • liquidation, or similar proceeding, in which Personal Data held by DrOwl about our Website and Application users are among the assets transferred;
  • to fulfill the purpose for which you provide it. For example, we may disclose your personal information another user and we will share your information with a third party who you invite to view your account and the information contained there on;
  • for any other purpose disclosed by us when you provide the information; with your consent.

We may also disclose your Personal Data:

  • to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
  • to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; and
  • if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of DrOwl, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
  • In the event you authorize or request that DrOwl share your Personal Data with a third party, you understand agree that the Personal Data associated with your use of the DrOwl products and services may be fully and completely available to such third party. You are solely and fully responsible for the appropriateness of sharing your Personal Data with such third parties, and DrOwl is not responsible for any actions or omissions of such third parties. You can revoke this authorization at any time by deleting the caregiver.

9.  Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in Disclosure

 of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

Tracking Technologies and Advertising. You can set your browser or operating to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website or Application may then be inaccessible or not function properly

Location Information. You can choose whether or not to allow the Application and Website to collect and use real-time information about your device’s location through the device’s privacy If you block the use of location information, some parts of the Application or Website may then be inaccessible or not function properly.

Promotional Offers from DrOwl. If you do not wish to have your email address used by DrOwl to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or logging onto your Account page. This opt out does not apply to information provided to DrOwl as a result your use of our services.

Targeted Advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative (NAI) websites (aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will

continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

10.   Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may review and change your Personal Data by logging into the Application or Website and visiting your Account Preferences page.

You can review and change your Personal Data by logging into our Website or Application and visiting the Account section of our Application or Website. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your personal information except by also deleting your account with us. You may delete your medical data at any time by going to Settings in the Application menu and selecting the Reset option. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

With respect to any PHI DrOwl may obtain, you have certain rights under HIPAA to access your data, to restrict use and disclosure of it, to request communication methods, to request corrections to your data, to receive an accounting of disclosures and to receive notice of any breach. See the Notice of Privacy Practices provided to you by your Provider for more information.

11.   Do Not Track Signals

We currently do not use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers.

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals, but we currently do not use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services (behavioral tracking).

12.    Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Website confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use multifactor authentication techniques and encryption technology for information sent and received by us.

The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website or Application, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we work diligently to try and protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website or on or through our Application. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, in your operating system, or in the Application.

13.    Changes to Our Privacy Policy

We will post any changes to our Privacy Policy on our Website. If we make material changes to our Privacy Policy, we will notify you by email to the email address specified in your account and through the Application’s home screen of such changes and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page or the Application’s home screen. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email to the email address specified in your account and through the Application’s home screen. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to- date active and deliverable email address for you, and for periodically accessing the Application or visiting our Website and reviewing this Privacy Policy to check for any changes.

14.   Contact Information

You may contact us through the contact information below.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact Us” page on our Website or in the Application.

How to Contact Us

 

DrOwl Health Technologies, LLC Attn: Becky Raichur

6501 Americas Parkway NE Suite 800

Albuquerque, NM 87110

Telephone: (505)-348-8700 Email: help@drowl.com