OncoHealth Privacy Policy
v1.0.0

Last revised: March 3, 2022

Your Information. Your Rights. Our Responsibilities.

1. Introduction

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

Oncology Analytics, Inc., d/b/a OncoHealth (“OncoHealth,” “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 website www.oncohealth.us (our “Website”) and the OncoHealth Iris 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, phone conversation, video interaction 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 OncoHealth 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.

Note, OncoHealth is not a medical group. Any telemedicine consults obtained through our Website or Application are provided by independent medical practitioners including, but not limited to, OncoHealth Medical Group, P.A., (collectively, “OncoHealth Medical”), which are independent medical groups with a network of United States based health care providers (each, a “Provider”).  OncoHealth Medical (or your own medical provider if you do not use a OncoHealth Medical Provider) is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not OncoHealth. If you do not agree to be bound by those terms, you are not authorized to access or use our Website, and you must promptly exit our 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, you should elect not to use our Website or Application. By accessing or using our Website or Application, you agree to this Privacy Policy and accept our privacy practices as described in this Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Website or Application after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

2. Children Under the Age of 18

Our Website and Application are not intended for children under the age of 18 without parental consent.

If you are under the age of eighteen (18) and wish to create an account with OncoHealth, your parent or legal guardian must create the account, submit your personal information, and agree to this privacy policy on your behalf. If we learn that we have collected personal information from someone under the age of 18 that was not provided with the supervision and consent of the minor’s parents or legal guardian, we will promptly delete that information. If you believe we have impermissibly collected personal information from someone under the age of 18, please contact us using the information below to request that it be deleted.

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.

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, home, work, and mobile telephone numbers, date of birth, credit or debit card number (for payment purposes only), audio (including recordings and transcripts), images and videos of you, gender, Social Security Number, your medical history, health insurance subscriber information, and 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.

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, and videos, images and recordings when interacting with a Provider on our Website or the Application. This includes information provided at the time of registering to use our Website or Application as well as information provided when using our Provider consultation services, 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.

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:

  • details of your access to and use of the Application and website, including traffic data, location data, logs, and other communication data and the resources that the end user accesses and uses on or through the Application and Website;

  • information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number; and

  • real-time information about the location of your device.

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.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies)

    We and our service providers may use cookies, web beacons, 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 may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) that uses cookies, web beacons, web pixels and/or similar technology to collect and store certain information relating to your use of the Website and anonymous information about you. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as 

    www.google.com/analytics/learn/privacy.html.

  • Other Third Party Cookies

    We encourage you to review the privacy policies of the other third party cookies deplored on our Website and Application, including Adobe’s (https://www.adobe.com/privacy/policy.html). Our Site may use Adobe's analytics and on-site personalization services, which use cookies, web beacons, web pixels and/or similar technology to collect and store information about you or your device or browser. Your browser settings also may allow you to transmit a "Do Not Track" signal when you visit various websites. Some of the Websites may not be configured to respond to "Do Not Track" signals received from browsers. If you have further questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

4. 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 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 provide and improve our Website, Application, products, and services. For example, we may convert our recordings to text and perform machine learning on data we receive;

  • to provide you with information, products, or services that you request from us or that may be of interest to you;

  • for purposes of quality, improvement of health status, customer and patient experience, customer and patient engagement and/or behavior modification, efficiency, cost effectiveness and/or other purposes relating to the provision of telehealth services;

  • to process, fulfill, support, and administer transactions for products, activities and services requested by you;

  • to provide you with notices about your OncoHealth account;

  • to contact you in response to a request;

  • to conduct research on user demographics, interests and behavior based upon information provided during use of our Website and Application;

  • to anonymize and aggregate information for analytics and reporting;

  • to notify you about changes to our Website, our Application, or any products or services we offer or provide though them;

  • to maintain the security of the Website and Application including authenticating and detecting potential fraudulent use;

  • 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 e-mailing: support@irisoncology.com

Some information OncoHealth collects constitutes protected health information (“PHI”) under the U.S. Health Insurance Portability and Accountability Act (“HIPAA”). As set forth above, OncoHealth Medical Group, P.A. (or your own medical provider if you do not use a OncoHealth Medical Provider) will provide you with a Notice of Privacy Practices describing its collection and use of your health information, not Oncology Analytics, Inc. OncoHealth will use PHI only for the purpose for which it was collected and we only collect the information we need to fully perform our services and to respond to you or your Provider. We may use your PHI to contact you, to provide requested services, to provide information to your Providers and insurers, to obtain payment for our services, to respond to your inquiries and requests, and to respond to inquiries and requests from your Providers and benefits program. 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.

We may de-identify or aggregate your Personal Data so that it no longer reasonably identifies you. In this case, we may use this de-identified data without restriction and for any purpose, including to improve our Website, Application, and products and services.

5. 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 may 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.

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;

  • 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 OncoHealth 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 to a Provider;

  • 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 OncoHealth, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

6. 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

  • Promotional Offers from OncoHealth

    If you do not wish to have your email address used by OncoHealth to promote our own products and services, you can opt-out at any time by emailing: support@irisonology.com. This opt out does not apply to information provided to OncoHealth as a result of a product purchase, or your use of our services.

  • Location Information

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

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

You may review and change your Personal Data by logging into the Application. 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. 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 OncoHealth 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.

8. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. 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. You can help protect your Personal Data and other information by keeping your password to our Website confidential. You are responsible for keeping this password confidential. We ask you not to share your password with anyone.

9. California Privacy Rights

At this time, OncoHealth has determined that it is not subject to the California Consumer Privacy Act of 2018 (CCPA).

At this time, OncoHealth has determined that it is not subject to the California Consumer Privacy Act of 2018 (CCPA). The CCPA expressly excludes personal information collected, processed, sold, or disclosed pursuant to certain sector-specific privacy laws, including medical information governed by the California Confidentiality of Medical Information Act (CMIA), protected health information collected by a covered entity or business associate governed by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), or a provider of health care governed by the CMIA or covered entity governed by HIPAA to the extent the provider or covered entity maintains patient information in the same manner as medical information or protected health information under the CMIA or HIPAA, respectively. As the information collected by OncoHealth falls under these exclusions, the information we collect is generally exempt from the CCPA. The CCPA also does not apply to publicly available information from government records, and de-identified or aggregated consumer information.

Further, note that information regarding OncoHealth job applicants, employees, owners, directors, officers, or contractors, emergency contact information from the same, and information necessary for OncoHealth to administer benefits to the same, and information OncoHealth obtains from a consumer acting on behalf of a company and whose communications with OncoHealth occur solely within the context of OncoHealth conducting due diligence regarding, or providing or receiving a product or service to or from another company, are generally exempt from much of CCPA. If you have questions about any of the foregoing, please contact us using the information set forth below.

10. 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 may notify you of such changes through your contact information 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. 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.

11. 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” (https://irisoncology.com/contact-us/) or the "Compliance" (https://irisoncology.com/compliance/) page on our Website or in the Application.

How to Contact Us:

OncoHealth

Attn: Chief Compliance Officer 7000 Central Parkway, Suite 1750 Atlanta, GA 30328

Or via e-mail to: support@irisoncology.com