​StrongPath Inc, a Colorado corporation (“StrongPath Inc,” “we,” “our,” or “us”) provides services that translate a consumer’s (“End User”) lifestyle health data from multiple sources, such as wearables, health and medical devices, and questionnaires, into a normalized format so that End Users can sync and track their lifestyle health data and we can share it with their healthcare provider (“Provider”) or multiple Providers (a “Care Team”) who are able to easily and quickly make better and more informed, data-driven decisions about their patients’ health; services that allow a Provider or Care Team to remotely monitor specially selected health metrics of their patients as part of medically necessary treatment. 

 

StrongPath is committed to protecting the privacy of all its users. This Privacy Policy is incorporated by reference into StrongPath Inc. Terms of Service and describes the information we collect, use of Services, how we use the information we collect and any disclosures of that information.

 

The term “you,” as used in this Privacy Policy, refers to an End User, a Patient or Provider of the Services. By using the Services, you agree to this Privacy Policy. This is our entire and exclusive Privacy Policy and it supersedes any earlier version. We may change this Privacy Policy by posting a new version through the Services, and it is your responsibility to review this Privacy Policy periodically. When we do change the policy, we will also revise the “last updated” date at the beginning of this Privacy Policy. Your continued use of the Services constitutes your agreement to this Privacy Policy and any updates.

 

INFORMATION WE COLLECT

 

Personal Information. As used in this Privacy Policy, “Personal Information” means any information that may be used to identify you. We receive and store any information you provide to us. For example, we collect Personal Information such as your first and last name, age, email address, browser information, third-party encrypted account credentials and phone number. If you provide your third-party account credentials to us, you understand some content and/or information in those accounts (“Third Party Account Information”) may be transmitted into your account with us if you authorize such transmissions, and that Third Party Account Information transmitted to our Services is covered by this Privacy Policy. You can choose not to provide us with certain information, but you may not be able to register with us or to take advantage of some of our features. We may anonymize your Personal Information so that you cannot be individually identified, and provide that information to our partners.

 

Technical Information. When you use the Services, we may track or collect information unique to you or the device(s) you use to access the Services (“Technical Information”). We may do this directly or through third party tools, services, stores, accounts or hosting platforms involved with or connected to the Services (including without limitation, anonymous usage statistics, by using cookies, server logs, analytics tools and ad serving technologies). This information may be used to improve the quality of our services, to administer the site and analyze its usage, to allow users to set up a user account and profile, to contact users and to fulfill your requests for certain products and services. Whenever you interact with the Services, we may automatically receive and record information on our server logs from your browser including your IP address, “cookie” information, and the page you requested. This information is not deemed by StrongPath Inc. to constitute Personal Information and while we will not use it in a way that associates such information with you, such information may be aggregated and used. StrongPath Inc. owns this information and may use it in any manner it deems appropriate.

 

Protected Health Information. By using the Services, we provide you the ability to store, upload information from third party tracking health devices and or platforms (such as heart rate monitors, blood pressure devices), and track protected health information (“PHI”) and allow you to connect with a Provider or “Care Team” (comprised of health and wellness Providers with whom there is a relationship for the provision of healthcare products and services). PHI is any information about your health status, provision of health care, or payment for health care that is created or collected by Providers or us and can be linked back to you. Some examples of PHI used by the Services are your medical history, health background and current health status information, age information, demographic information and information related to the diagnosis and treatment of health conditions, over-the-counter and prescription medications, laboratory test results, fitness status, nutritional and behavior information.

 

HOW WE USE AND DISCLOSE THE INFORMATION

 

Except as described in this Privacy Policy and in our Terms of Service, information that you provide or that we collect from you will be kept confidential and used to support use of the Services by End Users, Patients, and Providers and applications that interact with it.

 

StrongPath Inc. needs to ensure that we have your permission to utilize the information collected through your use of and interaction with the Services for the purposes that we envision. Because of that, we need your permission, or license, to use information collected either from you or any Provider in your Care Team. You hereby grant to StrongPath Inc. a non-exclusive, transferable, sublicensable, irrevocable, royalty free license to use the information in order to provide the Services to you, your Provider and your entire Care Team as necessary to monitor and improve the Services, and to provide treatment to or collect payment from you. The license is non-exclusive, fully-paid and royalty-free, sublicensable, transferable, irrevocable and worldwide. You also grant StrongPath Inc. a perpetual, non-exclusive, transferable, sublicensable, irrevocable, royalty free license to use such information and other data we collect from you via your or a Provider’s use of and interaction with the Services in order to collect, develop, create, extract or otherwise generate statistics and other information and to otherwise compile, synthesize and analyze such information and de-identified data. Notwithstanding anything to the contrary in this Privacy Policy, to the extent that StrongPath Inc. collects or generates de-identified data, such de-identified data will be owned solely by StrongPath Inc. and may be used for any lawful business purpose without a duty of accounting to you.

 

Except as described below, we will never rent or sell your information in a personally identifiable form to anyone:

 

Vendors, Agents, Contractors. Agents, technology vendors and/or contractors of StrongPath Inc. may have access to your information on a need-to-know basis for the purpose of performing services on behalf of StrongPath Inc. or providing or enabling elements of the Services. All such agents or contractors who have access to such information are contractually bound to keep the information confidential and not use it for any other purpose than to carry out the services they are performing for StrongPath Inc. or as otherwise required by law.

 

Your Provider Invitees and Providers. If you have a provider that you want to share your wellness journey with on the Services and said provider has not already invited you to use the Services, you may be able to send an invitation to the provider to connect with you.  In order to send an invitation to the Provider Invitee, we may ask you for information such as their name, their email address, and their relationship to you.

 

When you share the email address of a Provider Invitee, you are doing so under the full knowledge that if accepted, the Provider Invitee becomes a connected Provider for you and as such, will receive the Personal Information you have provided. The Provider will be provided reporting on all activity including viewing all your historical personal health information that is already in your account, adding personal health information for you, viewing and adding content including notes, images, etc., viewing and adding comments, making recommendations, etc. 

 

If, and only if, you connect with a Provider (either by inviting and the Provider accepting or  by you accepting a Provider’s invitation to connect), you acknowledge that your Personal Health Information will be disclosed without your written authorization to that Provider which has a legal commitment to maintaining the privacy and security of your Personal Health Information – and as otherwise permitted or required by law to any of the aforementioned parties. Again, we will never share your Personal Health Information with any Provider unless you are connected.

 

HIPAA- This Privacy Policy is designed to comply with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Providers, to the extent they are “Covered Entities” under HIPAA (as defined in HIPAA) have their own privacy and security obligations with respect to your Personal Information and PHI. StrongPath Inc. has agreements, called Business Associate Agreements, in place with Providers, which define our security and privacy obligations to them and their patients. Our Business Associate Agreement with Providers can be viewed HERE and is incorporated herein by reference as if fully set forth. We encourage you to contact each Provider with whom you interact with through the Services regarding their privacy and security practices. For more information regarding your rights under HIPAA, see http://www.hhs.gov/ocr/privacy/.

 

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of company assets, business collaboration or partnership or transition of service to another provider, your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.

 

As Required By Law and Similar Disclosures. We may disclose Personal Information and any other information to comply with the law, judicial proceeding, court order, subpoena or other legal process; to detect, prevent, or otherwise address fraud, security, emergency situations or technical issues; to enforce or apply our Terms of Service and other agreements, rights and remedies; or to protect the rights, property, or safety of us, our employees and contractors, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction purposes.

 

Customer support and troubleshooting. If you contact us with a question, our support team may view your data if doing so is necessary to solve your problem. We may also ask you follow-up questions requiring additional information. Access to your data is limited to the information reasonably necessary for the employee to perform the function needed to resolve the issue or to improve the service.

 

Scientific research. StrongPath Inc is committed to the pursuit of lifestyle care that will enhance people’s lives. We may use your de-identified, aggregated data from the Services to conduct and/or publish this research. These findings could be used for scientific and/or medical abstract, journals, oral presentations, poster presentations, journalism, or internal usage to better your and others’ experience. Depending on the situation and the purpose of the research investigation, we may or may not charge third parties for de-identified, aggregated information. We require medical facilities and research groups whom we share aggregate information to agree that they will not attempt to make this information personally identifiable, such as by combining it with other databases. Information we share with outside researchers will be de-identified (anonymous) and not associated with your name or any Personal Information you provided to us. By accepting this Privacy Policy and Terms of Service, you give consent to third-party medical facilities and research groups to use the de-identified, aggregate data provided by StrongPath Inc., our website or related apps and tools.

 

CONFIDENTIALITY AND SECURITY OF INFORMATION

 

We take steps to ensure that information provided to us is treated securely and in accordance with this Privacy Policy. We maintain physical, electronic, and procedural safeguards designed to protect the Information. These safeguards include, without limitation, encrypting all Personal Information and Protected Health Information. Unfortunately, the Internet is not 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

 

If you use our Services, your account is protected by a password for your privacy and security. You must prevent unauthorized access to your account and Personal Information by selecting and protecting your password and/or other sign-on mechanism appropriately and limiting access to your computer or device and browser by signing off after you have finished accessing platforms.

 

By using the Services or any StrongPath Inc. service you agree that we may communicate with you electronically regarding security, privacy and administrative issues relating to your use. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice in the Services, on our website or by sending an email to you. You may have a legal right to receive this notice in writing. To receive written notice of a security breach (or to withdraw your consent from receiving electronic notices), please notify us at info@strongpath.com.

 

CHILDREN’S PRIVACY

 

We do not knowingly collect or solicit personal information from anyone under the age of 18 or knowingly allow such persons to register for the Services. If you are under 18, please do not attempt to register for the Services or send any information about yourself to us, including your name, address, telephone number, or email address. If we learn that we have collected personal information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 18, please contact us.

 

INTERNATIONAL USERS

 

Please note, at this time the Services are not for use by any international users. If you access the Services in contravention of the previous prohibition, note that information collected from you will be stored and processed in the United States, in which StrongPath Inc. or its affiliates, subsidiaries, agents or contractors maintain facilities.  If you are accessing the Services from outside the United States, internationally with laws governing data collection and use, please note that you are agreeing to the transfer of your data to the United States and processing globally. By providing your Information you consent to any transfer and processing in accordance with this Privacy Policy and that any dispute over privacy or anything contained in this Privacy Policy will be governed by the laws of the United States and jurisdiction will lie in the state of Colorado.  

 

CALIFORNIA PRIVACY RIGHTS

 

To the extent that StrongPath Inc. may be subject to the California Consumer Privacy Act of 2018, as amended, and implementing regulations (“CCPA”), this section provides additional details about the personal information we collect about California consumers and the rights afforded to them under CCPA.

 

For more details about the personal information we have collected over the last 12 months, including the categories of sources, please see the “INFORMATION WE COLLECT” section above.  We collect this information for the business and commercial purposes described in the “HOW WE USE AND DISCLOSE THE INFORMATION” section above. We share this information with the categories of third parties described in the “HOW WE USE AND DISCLOSE THE INFORMATION” section above. StrongPath Inc. does not sell (as such term is defined in the CCPA) the personal information we collect (and will not sell it without providing a right to opt out).

 

Subject to certain limitations, the CCPA provides California consumers the right to request to know more details about the categories or specific pieces of personal information we collect (including how we use and disclose this information), to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights.

 

California consumers may make a request pursuant to their rights under the CCPA by contacting us at info@strongpath.com. We will verify your request using the information associated with your account, including email address. Government identification may be required. Consumers can also designate an authorized agent to exercise these rights on their behalf.

 

UPDATING YOUR INFORMATION; REPORTING A SECURITY INCIDENT; QUESTIONS

 

If you have any questions or concerns about this Privacy Policy or the use of your information, or to modify or update any information we have received, please contact us at info@strongpath.com 

 

You may request access to, correction of, or deletion of your Personal Information. For instructions on accessing your information, updating your information or for any privacy or data-protection-related question, please write to info@stongpath.com. 

 

If at any point you do not want your aggregated data used for research purposes, you must submit a written letter to StrongPath Inc’s main office located at the address set forth below with this request. StrongPath Inc. will have 60 days to respond to the request. Upon receiving your request, we will delete your Personal Information from our active databases to the fullest extent possible keeping in mind that it is technologically impossible to remove each and every record of the information you have provided to StrongPath Inc. or records saved by former and current Providers.

 

StrongPath Inc. takes security of data very seriously and works hard to protect the information you provide from loss, misuse, and unauthorized access or disclosure. These steps take into account the sensitivity of the information we collect, process and store, and the current state of technology. If you would like to report a security event or incident, please contact info@stongpath.com. 

 

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

 

We may update this privacy policy to reflect changes to our information practices. If we make any changes to our Privacy Policy it will be posted on this page. We encourage you to periodically review this page for the latest information on our privacy practices.

 

CONTACT US

 

For questions or comments about this Privacy Policy, please email us at info@strongpath.com.

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