Statement of Data Privacy
Privacy Policy
This privacy policy governs your use of the software application Clinikly-Red for Rhode Island OHHS HIV Population (the “App”) for mobile devices. The Application is created by 360MedLink/MedClinik inc.
This Statement describes how Clinikly-Red App for RI OHHS and its subsidiaries and affiliates (collectively “RI OHHS,” “360Medlink/MedClinik,” “we,” “us”) collects, processes, uses, discloses, and secures Protected Health Information collected by us from you directly via the Clinikly-Red App and/or through your care provider’s input in the App.
The term Protected health information (PHI) under US law is any information about health status, provision of health care, or payment for health care that is created or collected by a “Covered Entity” (or a Business Associate of a Covered Entity), and can be linked to a specific individual.
This App does not require or collect personal identity data (name, address, e-mail….etc.). The process of de-identification and encryption shall be the sole responsibility of Rhode Island OHHS as your health service provider.
Information We Use/Share
Personal Health information submitted in the mobile App will be kept confidential and will only be used for the purposes specified in this privacy policy and in the consent form.
Your Personal Health Data may be used/shared with OHHS as your service provider:
- To administer and improve healthcare services
- To carry out surveys, studies and evaluations
- For all other purposes to which you have consented
- We do not sell or otherwise disclose personal information we collect about you, except as described in this Privacy Statement. We do not rent, sell, or share personal information about you with other people or non-affiliated companies for their direct marketing purposes, unless we have your permission.
- In addition, we may access, preserve, and disclose information about you (i) if we are required to do so by law or legal process, (ii) to law enforcement authorities or other government officials, (iii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity, and (iv) to protect your, our, or others’ rights, property or safety.
- In the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation), such assets likely will include the data we retain. We will use reasonable efforts to direct the transferee to use personal information you have provided to us in a manner that is consistent with this Privacy Statement. Following such a sale or transfer, you may contact the entity to which we transferred your personal information with any inquiries concerning the processing of that personal information.
Telehealth
The new Telehealth feature of the Clinikly-Red application (released November 1, 2021) falls under the same terms listed in this Privacy Policy.
Your Rights and Choices
We offer you certain choices in connection with the information we collect from you, such as how we use the personal health information and how we communicate with you.
You may request us, or any third party instructed by us to:
- Provide you with information on the Personal Health information that are being processed about you; the purposes of the processing; the categories of recipients of the data; and any available information as to the source of such data
- Correct, erase or block Personal Health information we or any third party instructed by us hold about you if these turn out to be inaccurate or misleading
- Discontinue the processing of Personal Health information relating to you
- At any time, you are also entitled to recall the consent you have given with respect to our use of your personal health information. If you have requested to receive information from us, e.g. newsletters etc., and do not wish to receive further information, you can easily opt out of receiving further information from us.
- You can stop all collection of information by the App by uninstalling the App. You may use the standard uninstall processes as may be available as part of your mobile device or via the mobile application marketplace or network. You can also request to opt-out by contacting us as indicated in the ‘How to Contact Us’ section of this Privacy Statement.
Data Sharing Confirmation
To facilitate secure sharing of data to a health professional, OHHS may contact you to confirm a request to do so. You have the ability to accept or reject those requests. If you wish to retract sharing of your data, please submit a request via the ‘How to Contact Us’ section of this Privacy Notice.
It is your health professional’s responsibility to ensure a sharing request is accepted by contacting you independently of any Company service.
Data Transfers
We may transfer de-identified health data we collect about you to countries other than the country in which the data originally was collected. Those countries may not have the same data protection laws as the country in which you initially provided the personal information. If you are located in the United States, your data will be maintained and processed in the United States. When we transfer your personal information to other countries, we will put in place measures to adequately protect that personal information as described in this Privacy Notice so that same level of protection is applied to that personal information as would be required were it processed in the country in which the personal information was originally collected.
How We Protect Personal Information
We maintain administrative, technical and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.
The use and sharing of data entered in this App is governed by The HIPAA Privacy Rule for protected health information, while the electronically used health information are protected by the HIPAA Security Rule.
The employees who have access to Personal Data have been trained to handle such data properly and in accordance with our security protocols and strict standards of confidentiality. Although we cannot guarantee against any loss, misuse, unauthorised disclosure, alteration or destruction of data, we try to prevent such unfortunate occurrences
Links to Other Websites and Applications
The Services may provide links to other websites and applications for your convenience and information. These websites and applications may operate independently from us. Linked sites and applications may have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked websites or applications are not owned or controlled by us, we are not responsible for the sites’ or applications’ content, any use of the sites or applications, or the privacy practices of the sites or applications.
Updates to Our Privacy Statement
This Privacy Statement may be updated periodically and without prior notice to you to reflect changes to our information practices. We will post a prominent notice on our Services to notify you of any significant changes to our Privacy Notice and indicate at the top of the notice when it was most recently updated. Where required by law, we will seek your explicit consent to specific changes. You agree that Clinikly-Red for RI OHHS will reserve the right to occasionally notify you via the App of any important changes to this Privacy Statement and/or Service agreements.
Data Retention Policy, Managing Your Information
We will retain User Provided data for as long as you use the Application and for a reasonable time thereafter. We will retain Automatically Collected information for up to 36 months and thereafter may store it in aggregate. If you’d like us to delete User Provided Data that you have provided via the Application, please contact us as indicated in the ‘How to Contact Us’ section of this Privacy Statement and we will respond in a reasonable time. Please note that some or all of the User Provided Data may be required in order for the Application to function properly.
Children
We do not use the Application to knowingly solicit data from or market to children and individuals under the age of 18. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us as indicated in the ‘How to Contact Us’ section of this Privacy Notice. We will delete such information from our files within a reasonable time.
Security
We are concerned about safeguarding the confidentiality of your information. We provide physical, electronic, and procedural safeguards to protect information we process and maintain. For example, we limit access to this information to authorized employees and contractors who need to know that information in order to operate, develop or improve our Service. Please be aware that, although we provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches.
Your Consent
By using the Application, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by us. “Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities will take place in the United States. If you reside outside the United States, your information will be transferred, processed and stored there under United States privacy standards.
How to Contact Us
If you have any questions or comments about this Privacy Statement, or if you would like us to update information we have about you or your preferences, please contact us by email at infoohhs@360medlink.com
You also may write to:
360MedLink/MedClinik Inc
1000 La Gauchetière W., Suite 2400,
Montréal. H3B 4W5. Quebec – Canada