Security and Privacy
Effective: March, 25 2020
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally.
As used below, the term “Personal Information” is used to indicate any piece of information or data that can be used to identify any individual. Personal Information may relate to you as a Member, or it may relate to the individual that is the subject of any Profile that you create, if you create a Profile for a child, parent or other loved one.
THE INFORMATION WE COLLECT
- You may browse the Site and download the Genus App without expressly providing us any Personal Information that expressly identifies you, however, in order to make full use of the Genus Services as made available via the Site and/or the Genus App, you will be required to register with us. When you register with us to create an account and become a member, we will ask you for certain Personal Information. In order to set up your account, you need to provide your email address and you will need to select a password. If you elect to add any other Personal Information to your Account we will collect that information and use it and share it as set forth below.
- As a Member, you may also set up one or more Profiles within the Genus Services. The Profile may be personal to you and your healthcare or the subject of the Profile may be a child, parent or other loved one. When you set up a Profile, you will be asked to provide Personal Information about the individual that is the subject of the Profile, whether yourself or your child, parent or other loved one. When you set up a Profile in the Genus Services. we will collect and store any Information that you may elect to provide to us as part of the Profile Content, which may include but is not limited to medication information, gender, date of birth, personal contacts, photographs and files, notes on your symptoms and other journal information, medical treatment instructions, medical appointments, insurance information, your doctor’s address information, advance directives, and prescription information. In the event you set up a Profile that relates to someone other than yourself, you are solely responsible for ensuring that you have any and all consents and permissions to share that Personal Information with us and to use that information as part of the Genus Services.
- With regard to recording care conversations; you are responsible for who you choose share the recorded conversation. The care partner who is party to the conversations is entitled to a copy of the recording between them and you.
- With regard to sharing a recorded conversation; when a recording is shared, it is stored on a secure server. Only those a link is shared with will be sent an authorization code (token) allowing recording to be played. While we make ‘best efforts’ to prevent unintended audiences for listening to shared recording, it is not a guarantee of privacy.
We also collect the following information any time you visit our Site or the GenusConnect App, as applicable. This information may not necessarily identify you, but if we have your Personal Information, or you otherwise set up an Account with us, we may link any of the below non-personal information with your Personal Information in our records.
- Browser Log Data.When you visit the Site, whether as a Member or a non-registered user just browsing the Site, our servers automatically record information that your browser sends whenever you visit a website (“Browser Log Data”). This Browser Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, operating system or the webpage you were visiting before you came to our Site, pages of our Site that you visit, the time spent on those pages, access times and dates, and other statistics. We use this information to monitor and analyze use of the Site and for the Site’s technical administration, to increase our Site’s functionality and user-friendliness, and to better tailor it to our visitors’ needs. For example, we use this information to verify that visitors to the Site meet the criteria required to process their requests. We do not treat Browser Log Data as Personal Information or use it in association with other Personal Information, though we may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
- Google Analytics. Our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses “cookies” (discussed below), which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Site, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.
- App Usage Data.When you use the Genus App, whether as a Member or a non-registered user, our servers automatically record information that your mobile device sends whenever you use an Internet service. (“App Usage Data”). This App Usage Data may include information such as your mobile device’s IP address, device model and version, device identifier, operating system, time zone, name of your mobile operator or ISP, application performance measurements, and error conditions. It may also include a record of when specific features of the Genus App or Genus Service are used. We use this information to monitor and analyze use of the Genus App and Genus Service and for their technical administration, to increase their functionality and user-friendliness, and to better tailor them to our visitors’ needs. For example, we use this information to measure the popularity of different features and to more effectively resolve customer issues. We may aggregate, analyze and evaluate such information for the same purposes as stated above regarding other Non-Identifying Information.
HOW WE USE YOUR INFORMATION
- We do not sell your Personal Information.
- We will use any Personal Information in your Account as well as information in your Profile to provide the Genus Services, complete your transactions, administer your inquiries, and present you with offers for products and services that we think may be of use or interest to you. We may contact you in various ways including but not limited to, via email, Inbox in the app, telephone, cell phone, and SMS/text messages.
- If you set up input medical, legal or financial information into a Profile and you have elected to share your location with us, we can help you locate the contact information and/or address of the prescribing physician, practice, pharmacy, attorney, financial planner or other related service which you can then elect to add to the applicable Profile.
- If you add Personal Information about medical conditions and/or health goals into a Profile, we may use that information to present you with information and/or offers that might relate to such medical conditions or health goals. If you register to receive any Genus Service, we may need additional Personal Information for the applicable Profile, which you may not have elected to provide us previously. We will use all Personal Information as necessary to provide you the Genus Services for which you have registered. By registering for such Services, you consent to receive emails or other communications from us pertaining to such Services and related care.
- We have a team of Genus Advisors to facilitate use of the site and Genus app. These Advisors may use your name, address, email, phone number, gender and birthdate (“Contact Information”), insurance information and App Usage Data to contact you about various health, legal or wealth management related products and service.
- We may aggregate and combine all Personal Information that we receive through your Member Accounts and your Profiles with the information of other Members and Profiles. We use this anonymous information to attempt to provide you with a better experience, to improve the quality and value of our services and to analyze and understand how our Site, Genus App and Genus Services are used.
INFORMATION SHARING AND DISCLOSURE
- In the event that a third party Caregiver registers for access to the Genus Services pursuant to an invitation issued by your Account, we will provide them with access to all Profiles related to such Account. We cannot control how any Caregiver may use or disclose or otherwise exploit any Personal Information or other Profile Content that you may elect to make available to such third party. You expressly release Genus from any responsibility and liability resulting from any third party access to any Personal Information or Profile Content that you may permit. Any information you choose to provide and make available to third parties via the Genus Services should reflect how much you want others to know about you and the individual(s) whose information is in your Profile.
- Genus Services.If you elect to receive any of our Genus Services, we will share information from the applicable Profile as needed to provide the requested service. Your registration to receive any Genus Service constitutes your express consent for us to make such disclosures. If you share with us your credit card information in order to provide a Service, we will not retain your credit card data but simply pass it through to the party requiring payment.
- Other Third Parties.If you elect to use or otherwise take advantage of some of the other third party services that we may provide and make available to you, we will share certain of your information with such third party and will disclose to you at the time what information would be necessary to share with such third party.
- Aggregate Information and Non-Identifying Information.We may share aggregated information that does not include Personal Information and we may otherwise disclose non-Personal Information with third parties for industry analysis, demographic profiling and other purposes.
- Service Providers.We will disclose Personal Information to the third party service providers that we engage to assist us in making the Site, Genus App and Genus Services available. These service providers include, but are not limited to, our datacenter provider, storage provider, customer support system provider, email service providers, and software development contractors. These third parties have access to your Personal Information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
- Compliance with Laws and Law Enforcement.While Genus maintains information regarding your health on your behalf, Genus is not a covered entity under the Health Insurance Portability and Accountability Act (HIPAA). However, we take the protection of your private health information very seriously. In the event that we receive any subpoena or similar request from a court, government or law enforcement official, we will only disclose any Personal Information about you or other information in our custody or control as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Genus or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, illegal, unethical or legally actionable activity. Given the sensitivity of the Personal Information within your Profiles, it is our policy to carefully review any such request for information in our systems and we will decline to comply with any such request in our discretion.
- Business Transfers.Genus may sell, transfer or otherwise share some or all of its assets, including your Personal Information and related Account, Profiles and Profile Content, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.
CHANGING OR DELETING YOUR INFORMATION
All Members may review, update, correct or delete their Account information and any associated Personal Information or Profile Content by contacting us or by accessing the Genus Services. If you would like to close your Account or delete any Profile from your Account, you can do so by logging into your account and following the online instructions for closing you account. We will retain an archived copy of your records as set forth below please contact us at firstname.lastname@example.org.
We will retain the information you provide via our Site or the Genus App for as long as your Account is active or as needed to provide you with the Genus Services. We will also retain and use the information you provide via our Site or Genus App, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. If you delete your Account or any Profile, any Personal Information associated with the same is moved out of our active databases, but will still be retained in our systems pursuant to our data backup and retention policies.
DO NOT TRACK SIGNALS AND AD NETWORKS
Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
SECURITY – HOW WE PROTECT YOUR DATA
All communications between you and the Site, and between the App and the Site, are encrypted using the highest level encryption supported by your device. Data stored in the app and on the Site is encrypted at rest using industry-standard AES encryption.
Identity theft is of great concern to Genus. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your credit card information, your login information, or national identification numbers in a non-secure or unsolicited e-mail or telephone communication. For more information about identity theft, visit the Federal Trade Commission’s website at www.ftc.gov.
The Site, Genus App and Genus Services rely on the Internet and mobile networks, which are not always secure. We use commercially reasonable efforts to maintain the confidentiality, availability and integrity of any information we collect, but we cannot assure that the use of the Site, Genus App or Genus Services are secure or that your Personal Information or any other data that we may have will be secure. In the event we become aware of a security incident, we will notify you to the extent required under applicable law.
REPORTING A PROBLEM
If you feel your account may have been compromised, or you discover abuse or misuse of Genus Services, the Site or the Genus App, please report it immediately to email@example.com and we’ll investigate.
If you’re a security researcher who’s discovered an issue, please email firstname.lastname@example.org to report the issue.
LINKS TO OTHER WEBSITES
Our Site may contain links to other websites. If you choose to click on a third party link, you will be directed to that third party’s website. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit personal information from you. Other websites follow different rules regarding the use or disclosure of the personal information you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.
OUR POLICY TOWARD CHILDREN
The Site and Genus Apps are not directed to persons under 13. We do not knowingly collect personally identifiable information from children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information without their consent, he or she should contact us at email@example.com. If we become aware that a child under 13 has provided us with Personal Information, we will delete such information from our files. If you have created a Profile for a minor under the age of 18, you represent and warrant to us at Genus that you are the parent or legal guardian for that minor with a right to provide us the Personal Information of that minor.