Pathfinder Health Innovations, Inc. (“Pathfinder,” “we,” “us,” “our”) knows that you care how information about you is used and shared. This policy describes what information we collect when you visit our site(s) and how that information is used.
1. Information We Collect
We collect three types of information at our site, and we collect it in two different ways.
The three types of information we collect are general information, personal information and performance data.
- General information includes non-personal information from visitors to the site (such as the time of day the site is accessed, the IP address of the visitor, the site from which the visitor comes or the site to which the visitor goes after leaving our sites, which pages of our site the visitor visits, etc.), information in aggregate form (such as statistics relating to the number and frequency of visitors, which pages are visited most frequently), and information in de-personalized form (such as the number of visitors of a certain gender or age, or the number of visitors from a certain region, etc.). If you have provided us with personal information, general information can be coupled with your personal information, or it can be de-coupled from your personal information.
- Personal information is specific to you and includes such things as your e-mail address, name, and mailing address. This type of information is sometimes called “personally identifiable information.”This may also include information that you provided via your registration to the Pathfinder services.
- Performance data refers to data input by users as they use services available on the site. For example, when you use materials from our site to teach a student, you may input performance data (such as the number of times the student performs an exercise correctly or incorrectly) about how a student performs when using our teaching materials. Performance data can be coupled with personal information provided about the user or student, or it can be de-coupled from that information.
The two ways in which we collect information are by you directly providing the information, or by us indirectly monitoring and collecting the information.
- Information you directly provide refers to any information that you actually input into the site and provide to us. For example, when you register to access various portions of the site, you are required to provide certain information (such as name, email address, username, password, content you post, etc.), and when you subscribe to various services on the site, you are required to provide certain additional information (such as credit card information, billing address, etc.). Additionally, when you use our services to provide therapy to children, you may input performance data regarding the child’s performance.
2. How We Use Information We Collect
a. Anonymous General Information and Performance Data
Pathfinder uses general information and performance data that has been de-coupled from any personal information for a broad range of purposes. For example:
- We may use de-personalized performance data to help assess the effectiveness of various training materials and may use the results of these assessments to improve those training materials;
- We may use de-personalized general data to determine characteristics of visitors to our site, which characteristics may be used to improve our site and services or to better market our services; and
- We may provide any of this data to unaffiliated third parties for the same or similar uses (e.g., we may provide de-personalized performance data to unaffiliated third parties, such as research institutions, universities, hospitals, physicians or clinicians, who may use that data for research and other purposes).
b. Personal Data
Pathfinder uses personal information we collect to provide you with information, products or services you order or subscribe to. Where the information, product or service is one that is offered on our site but provided by a third party, we will provide your personal information to that third party solely for the purpose of providing you the information, product or service that you ordered. Unless you authorize us to, as further discussed below, the third party will be instructed not to use your information for the purpose of offering you any other information, product or service.
We may also use personal information that is coupled with general information and performance data to improve your experience on our site by providing you with information that is relevant to you.
Pathfinder may also use personal information we collect (including any corresponding general information and performance data) to provide you information about other information, products or services offered by Pathfinder. If you do not wish to receive these kinds of communications, you can opt out by sending an email to privacy@Pathfinder.com, or by changing your profile on the site.
Pathfinder will not provide personal information we collect (excluding associated general data and performance data) to third parties, including our affiliates and including unaffiliated third party business partners, to enable them to provide you information about their information, products or services.
Note, Pathfinder may provide any of the above information to our service providers, but our service providers will be instructed not to use the information for their own benefit, they may only use the information as necessary to provide services to Pathfinder.
We may use your personal information (excluding patient name, but including demographic information) for the purposes of aggregating that information and providing data for medical research.
3. How We Use Publicly Posted Information
4. How We Use Feedback to Pathfinder
Pathfinder has feedback functionality on the site that allows you to submit comments, suggestions, or bugs found. Pathfinder may collect your name or username and email address to follow up with you or thank you for a suggestion.
Pathfinder cares about protecting the security and integrity of your personal information. To that end, we have put in place reasonable security procedures and practices to protect your personal information from unauthorized access, destruction, use, modification, or disclosure. We also attempt to follow the applicable provisions of the Health Insurance Portability and Accountability Act (HIPAA), along with any amendments, as related to the protection of protected health information (PHI). We have partnered with Microsoft to deploy our software in the Windows Azure environment. Azure provides security related to the handling of PHI.
- Key architecture elements of the Windows Azure security environment include:
- Filtering Routers
- Cryptographic Protection of Messages
- Software Security Patch Management
- Network Segmentation
If you sign up for a Subscription:
- You will receive a unique, secure URL that will give you access to a unique, secure database for your patients’ information and a secure, partitioned storage vault for documents.
- We will only have access for the purposes of troubleshooting any concerns brought to our attention.
- SSL is used for encrypted data transfer.
- We will maintain data in active electronic format for 90 days following termination of the Subscription. We may maintain certain data in storage for a longer period, to the extent required by applicable law. You should retrieve your data within the 90-day period following termination. If you request data after that 90-day period, you will incur hourly charges for the retrieval work performed by our team.
If you have any questions about the steps taken to protect the privacy of your data, or you wish to receive any additional information, please contact us.
6. Information Provided to Third Party sites Linked to Our Site
7. Correction/Updating of Personal Information
If you wish to change any personal information you have provided, you may do so via the site.
8. Business or Asset Transfer or Sale
Pathfinder’s business, or portions thereof, may be sold or otherwise transferred to third parties through various means (e.g., sale of stock, sale of assets, merger, etc.). In such transactions, Pathfinder may, and likely will, transfer information collected through the site, or give the acquirer a license to use that information. Pathfinder will make a reasonable effort to provide notice on the site.
9. Release of Information for Legal Reasons
Pathfinder may release information concerning your use of Pathfinder (including, but not limited to, posted Public Content, registration information, and network records) when it believes in good faith that such release is appropriate to comply with the law (for example, pursuant to a statutory demand, subpoena, warrant, or court order), to protect against fraudulent, abusive or unlawful use of the site, to protect Pathfinder’s rights or property, enforce any contract between you and Pathfinder, or if Pathfinder reasonably believes that a situation involving danger of death or injury to any person requires disclosure.
10. Protection of Minors
Use of this site is not intended for children under the age of 13. Children under the age of 13 are not permitted to register on this site or purchase subscriptions, or use any functionality for which registration or subscription is required. Pathfinder will not knowingly collect information from these children. If your child has submitted personal information and you would like to request that such information be removed, please contact us at privacy@Pathfinder.com. Any information submitted by a child under the age of 13 onto a public forum controlled by Pathfinder will remain public until we have been notified of such publication and have had reasonable opportunity to remove that information accordingly.
Revision Date: 2/6/2018
12. YOUR CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83 provides California residents with certain additional rights as it relates to their personal information.