Privacy policy
Our Principles
At Pluritem Health, we are committed to empowering you with a complete view of all of your health data in a private account that you control and providing easy communication with all of your healthcare providers and vendors.
Control. You are in control of the personal information you provide to us, which includes sharing, use, and retention.
Access. We endeavor to empower you with access to your data so that you may take charge of your health.
Transparency. We are committed to transparent collection, storage, sharing, and processing of your personal information and providing services to help you explore and understand your health.
Protection. The privacy and protection of your personal information is of the utmost importance to us. We are committed to strong security measures and providing you with choices about how we collect, process, and store your personal information.
Introduction
Pluritem Health, Inc. (“we, “us”, “our” or “Pluritem Health”) operates the pluritemhealth.com website and related services. At Pluritem Health, our goal is to empower you with control and sharing of your health information. To this end, we collect, process, use and store the personal information that you provide to us from your mobile applications, provider portals, activity trackers, devices, and services. Our Privacy Policy outlines:
what information we collect;
how we may process that information;
how we may use that information; and
choices about accessing and updating information.
This Privacy Policy applies to our website (“Site”) as well as to the API services and applications we provide, collectively known as the “Services.” This Privacy does not apply to information collected by us offline or through any other means, including on any other website operated by us or any third party and it does not apply to information collected by any third party, including any application or content that may link to or be accessible for or on our Site or Services.
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 Site or Services. By accessing or using our Site or Services, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Consenting to Use of Personal Information
By accepting our End User Terms of Service, you consent to the collection, use, storage, and disclosure of personally identifiable information as outlined therein and in this Privacy Policy.
Connecting Your Personal Information to our Services
We maintain your Personal Information, and in particular protected health information, in compliance with applicable health care privacy and security rules and our contractual obligations with our Customers. Currently we act as a conduit between (a) entities that collect and store health data (b) organizational Customers that use our Services to collect data from consumers, and (c) consumers such as you.
Through the Services, you can authorize us to access, collect, use, store, and disclose your Personal Information, including Sensitive Information that may relate to HIV and/or other sexually-transmitted diseases, mental and behavioral health conditions and treatment, substance abuse conditions and treatment, and other data, throughout the term of your use of the Services.
Important Definitions
The following definitions are provided to assist with understanding our Privacy Policy.
Service or Services. Our products, software, Services, and Site as accessed by a user whether or not a user has an account.
Personal Information. Personal Information is information that can identify you, either alone or in combination with other information. This includes Protected Health Information that is identified under HIPAA (Health Insurance Portability and Accountability Act of 1996). Please review the section “Information We Collect from You” for more details.
Anonymized (or De-identified) Information. De-identified or anonymized information does not identify you based on individual pieces of information or combinations of information. Your direct information (e.g., name) and indirect information (e.g., Device ID) are removed, such that you cannot be reasonably re-identified as an individual. This includes de-identified demographic information, de-identified location information, de-identified information about the computer or device from which you access the Pluritem Health or other online services, or other analyses we create.
Aggregate Information. Your individual information is combined and compiled with other individuals’ information for the purpose of analysis. The aggregation process involves de-identification of Personal Information such that you and other individuals cannot be reasonably re-identified as specific individuals.
Customers. Customers are business partners of Pluritem Health that may incorporate our Services as a component or feature of the Customer’s products (e.g., a chronic condition management platform that uses data from Pluritem Health to measure your nutrition levels) or may deliver features within our Services (e.g., a pharmacy that provides your prescription history).
Information We Collect from You
We collect Personal Information as part of providing Services to all of our users. Upon your becoming a user of our Services, we will only collect information, in connection with the Services, that you voluntarily authorize for submission. Personal Information may include information you report about yourself and/or information collected from devices or third parties. We vigorously believe in keeping confidential all personally identifiable information that identifies an individual, including your past, present, or future physical or mental health condition.
Account Information. We may collect Personal Information that includes, but is not limited to, identifying data such as name, email address, password, and address information. If our Services are provided by your employer or your employer’s service provider, your Personal Information may be forwarded to set up our Services for your use. Depending on the Services used, we may also collect Social Security number, date of birth, current benefit coverage, and other official identifiers, such as a driver license number.
Health Information. We may collect information such as personal activities, health and wellness data, medications, tests, medical records, and health issues submitted through the Services.
Sensitive Information. Certain information you provide is considered Sensitive Information and may include genetic information, HIV testing or status, mental health, race, ethnicity, and sexual orientation. This information may be recorded in information shared with us by a third party such as a doctor.
Device Information. For both users of our Services and Site, we may collect device identifiers such as serial number, device type, IP address and browser type, language preferences and location, operating system, date and time of your access, internet service provider or mobile carrier, internet domain and host name, and referral URL.
Profile Information. We collect the information that you voluntarily enter into a user profile. This may include pictures, nicknames, and other personal details. This information is available to third parties that you consent to sharing your Personal Information through our Services.
Research and Studies Information. Your Personal Information is collected when you voluntarily participate in research and studies through our Services.
Information from Your Use of our Site and Services. We collect information related to your use of our Services, such as which healthcare provider you search for, which menus you use, pages you view, or search results you click on. You may interact with our support team during the use of our Services, in which case, we would collect information about your communications.
As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized Site, including by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Site according to your individual interests.
Speed up your searches.
Recognize you when you return to our Site.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe's website.
Web Beacons. Pages of our Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Pluritem Health, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Some content or applications on the Site are served by third-parties, including content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
How We Use Your Information
We use your Personal Information to provide Services to you. Examples of how we use your information include:
Authenticating your identity and access to the Services so you can share your Personal Information with the third parties of your choice;
Restricting access to your Personal Information;
Collecting Personal Information entered by you, imported by you (e.g., from a device) or authorized by you (e.g., blood test results from a lab);
Transmitting information to a third party that you authorize to receive your Personal Information through our Services;
Creating an export of your Personal Information based on your authorization;
Sending you account notifications and updates about our Services;
Building new Services and improving existing Services;
Conducting scientific and statistical research and studies;
Troubleshooting our Services or enforcing our End User Terms of Service use; or
Detecting and protecting against error, fraud, malicious activity, or other suspicious or criminal activity;
To present our Site and its contents to you;
To fulfill any other purpose for which you provide your Personal Information;
To provide you with notices about your account, including expiration and renewal notices;
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
To notify you about changes to our Site or Services or any products or services we offer or provide through our Site or Services;
To allow you to participate in interactive features on our Site;
In any other way we may describe when you provide the information; and
For any other purpose with your consent.
My Pluritem Health Services. If you elect to create a My Pluritem Health account, we may use your Personal Information to tell you about or present to you products or services that we believe may be of interest to you.
We will not, without your express consent, provide your Personal Information to any third party for their or any other third party’s direct communications.
You can opt out of receiving these communications by following the instructions contained in each email we send you.
In addition, you can inform us at any time at inquiries@pluritemhealth.com if you no longer consent to these communications.
If you unsubscribe, you will no longer receive these communications but we will continue to contact you regarding our Services and to respond to your other requests.
Non-Personal Data Use
We may also use non-Personal Information to analyze data into useful information. This process of data analysis is done using Anonymized and Aggregate Information, is non-personal, and allows us to find correlations and patterns in the data.
How We Share Your Information
We do not sell, lease, or rent your individual-level information to any third party, including our Customers, without your consent.
In certain circumstances we may share your Personal Information with third parties without further notice to you, unless required by the law, as set forth below:
Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Information with vendors and service providers, including providers of hosting services, cloud services and other information technology services providers, email communication software services, access management services, data visualization services, and web analytics services. Pursuant to our instructions, these parties will access, process or store Personal Information in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Information.
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider, your Personal Information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction along with other assets.
Legal Requirements: We disclose personally identifiable information about you as required or permitted by law, including complying with legal process. We fully cooperate with law enforcement agencies in identifying those who use our Services for illegal activities and may, in our sole discretion, disclose personal information or other information to satisfy any law, regulation, subpoena, or government request. We reserve the right to release personal information or other information about users who we believe are engaged in illegal activities or are otherwise in violation of our End User Terms of Service, even without a subpoena, warrant or court order, if we believe, in our sole discretion, that such disclosure is necessary or appropriate to operate our Services or to protect our rights or property, or that of our affiliates, or our officers, directors, employees, agents, third-party content providers, or licensors. We also reserve the right to report to law enforcement agencies any activities we reasonably believe in our sole discretion to be unlawful. If we are legally compelled to disclose information about you to a third party, we will attempt to notify you by sending an email to the email address in our records unless doing so would violate the law or unless you have not provided your email address to us.
Other Purposes: We may also disclose your Personal Information to our subsidiaries and affiliates, to fulfill the purpose for which you provide such Personal Information, for any other purposes disclosed by us when you provide the information, with your consent, to enforce and apply our End User Terms of Use and other agreements and/or we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Pluritem Health, our Customers, or others.
Information You Share with Others:
You can share information through our Services by (i) exporting a copy of your Personal Information, (ii) sending your Personal Information to Customers, health care providers, or other third parties you authorize to receive your Personal Information through the Service, and (iii) other features that may be offered through our Services. Within our Services, sharing Personal Information with third parties such as a doctor requires your consent. You provide consent to sharing through the settings in our application. You may also participate in research or clinical studies by providing express consent.
When you decide to disclose your Personal Information to Customers, doctors, other healthcare professionals, family members, or other individuals, whether or not you are using our Services, these third parties may store, process or use your Personal Information differently than from what we describe in our Privacy Policy. Please review the section “Protecting Your Personal Information” and review the privacy policies of third parties with whom you share your Personal Information.
Customers may use the Personal Information you elect to share with them in accordance with your authorization and/or display your data to you in a more usable format. Depending on the service provided by the Customer, it may be integrated with data about you from one or more other sources as well (e.g., a dashboard showing exercise data together with test data extracted from personal health records).
Anonymized Data Sharing. Pluritem Health may use and share your anonymized or aggregated information for services improvements, public health, research, analytics and other legally permissible purposes.
Personal Information Security
As the shepherds of your health data, the protection of that data is of the utmost importance to us. We use all reasonable technical, physical, and administrative controls to protect your Personal Information from unauthorized access or disclosure and to ensure the appropriate use of information. We store your data in the United States. We maintain a high level of data protection via safeguards such as data backup, audit controls, access controls, and data encryption. Our Site and Services use Secure Socket Layer (SSL) technology to encrypt all connections to and from our Site and Services to enhance security of electronic data transmissions. However, no data transmission or storage system is guaranteed to be 100% secure. If you have questions about security or possible reason to believe that your interaction with our Site or Services is no longer secure (e.g., you feel that your account’s security may be compromised), please contact us immediately at inquiries@pluritemhealth.com.
Your Access and Choices
You are the owner of your health data. We help you move your data throughout the healthcare ecosystem, but you have the ultimate control over who has access to which information.
You can review your Personal Information that is stored and available within our Services at any time. You also have choices concerning the Personal Information you authorize to be stored within our Services and the export of your Personal Information. Please review the following options you have to control the management, use, change, and deletion of your Personal Information that is stored within our Services.
Your Personal Information with our Services
You authorize the Personal Information that is collected, stored, processed and used within our Services.
Deleting or De-authorizing Your Data
You may request to delete any Personal Information and to de-authorize the collection, use, storage, and disclosure of Personal Information in the future by sending us an email at inquiries@pluritemhealth.com. Any such deletion or de-authorization will have no effect on sharing of Personal Information before we receive and are able to act upon such a request.
During the use of our Services, you may authorize us to send your Personal Information to Customers or third parties who are providing you value. You will have full transparency regarding whom within the ecosystem you previously sent your Personal Information. To delete a copy of your records from these entities, you will need to follow their policies and procedures for data deletion.
Exporting a Copy of Your Data
You can export a copy of your Personal Information that is stored within our Services. If you have questions about exporting Personal Information from our Services, please contact inquiries@pluritemhealth.com.
Changes to Your Personal Information
We work with various medical and wellness providers to enable you to obtain and hold copies of your Personal Information. We may also provide tools for you to manually enter health data or collect data from devices. While we strive to collect complete and accurate information from the sources provided to us, we do not have control over the accuracy, completeness, or quality of information entered or sent to us. For example, you may identify incorrect, incomplete, or outdated information from a third-party provider. If you have questions or find issues with your Personal Information, it is your responsibility to identify issues and ensure corrections are made to the original source of information.
For manually entered information, you are responsible for reviewing information and making corrections.
For a device, you should contact the device’s manufacturer.
For a care provider, you should contact the provider who controls your original information.
Your Responsibility to Protect Your Personal Information
You are responsible for your handling, sharing, re-sharing and/or distribution of your Personal Information. We will have no responsibility or liability for any consequences that may result from your disclosure of your Personal Information. Moreover, if you forward Personal Information electronically to another person on or off the Site or Services, we are not responsible for any harm or other consequences from third party use or re-sharing of your information. We recommend sharing Personal Information only with individuals and other third parties that you know and trust.
In addition, we urge you to take precautionary measures in maintaining the integrity of your data. Please be responsible in making sure no one can see or has access to your personal accounts and log-in username and password information. If you use a public computer, such as the library or a university, or a shared device, always remember to log out of the Site or Services.
If you use our Site or Services through your employer’s computer network or through an internet café, library or other potentially non-secure internet connection, such use is at your own risk. It is your responsibility to check beforehand with the company’s privacy and security policy with respect to Internet use.
We cannot guarantee the identity of any other non-employee person with whom you may interact in the course of using the Site or Services, or the authenticity of any information that others may provide.
Third-Party Sites and Trusted Relationships
Our Site may contain links to other websites. We do not share your Personal Information with those websites except as authorized under the End User Terms of Service and are not responsible for their privacy policies and procedures. We encourage you to learn their particular privacy policies but we seek to work with trusted partners and organizations that will adhere to similar privacy and ethical standards.
Account Closure
You may close your account by sending a request to inquiries@pluritemhealth.com. We will close your account and delete the Personal Information within your account within thirty (30) days of our receipt of your request. Please note that deletion of Personal Information within our Services does not include any information that you previously provided to a third party through our Services or research that you consented to participate in. You must contact third parties separately regarding controls and choices for the personal information that you shared. We cannot remove personal information from ongoing or completed studies that use this information.
As stated in our End User Terms of Service, we may retain your Personal Information in backup copies as required by law or contractual obligations with third parties. We may also retain de-identified personal information, and limited account registration information needed for accounting, audit, and compliance purposes.
Other Important Information
Data Retention
Identifiable information about you is held no longer than necessary for our business purposes or to meet legal requirements.
Children
Our Site and Services are not intended for children under 13 years of age. No one under age 13 may provide any personal information to or on the Site or Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or through our Services or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at inquiries@pluritemhealth.com.
Changes to this Privacy Policy
We may amend our Privacy Policy in the future. In the event changes are made, we will be sure to post changes at the Site and at other places we deem appropriate. We will post an effective date when an update is published. If you object to any changes, you may delete your account by contacting us at inquiries@pluritemhealth.com.
Questions
If you have any questions or suggestions on ways we can improve our Privacy Policy with respect to Personal Information, please email us at inquiries@pluritemhealth.com.
This Privacy Policy was last updated on March 10, 2022