This Consumer Health Data Privacy Policy (“Health Data Policy”) describes how Cylinder Health, Inc. (“Cylinder Health,” “we,” “us,” or “our”) processes “Consumer Health Data,” as that term is defined under applicable state privacy law, about consumers who reside in the states of Nevada, Washington, and any other applicable U.S. jurisdiction in connection with our proprietary mobile application and web-based platform at https://app.cylinderhealth.com (collectively, the “Digital Platform”) as well as our marketing website, https://cylinderhealth.com (the “Marketing Site”). Please carefully read this Health Data Policy as it contains important information concerning your Consumer Health Data and how we use it.
This Health Data Policy relates only to Consumer Health Data. This Health Data Policy does not describe how Cylinder Health processes your Protected Health Information (“PHI”) governed by the Health Insurance Portability and Accountability Act (“HIPAA”). Please see our HIPAA Notice of Privacy Practices to learn more about our collection, use, and disclosure of your PHI. This Health Data Policy does not describe how we process your personal information. For more information about our information practices with respect to personal information, please refer to our Privacy Policy.
We collect the following categories of Consumer Health Data:
- Individual health conditions, treatment, diseases, or diagnoses;
- Social, psychological, behavioral, and medical interventions;
- Health-related surgeries or procedures;
- Reproductive or sexual health information;
- Use or purchase of prescribed medications;
- Bodily functions, vital signs, symptoms, or measurements;
- Diagnoses or diagnostic testing, treatment, or medication;
- Genetic data;
- Information that could identify your attempt to seek health care services;
- Any inferences based on the above categories or derived or extrapolated from non-health information, such as cookies and other tracking technologies, that identify your past, present, or future physical or mental status.
We collect Consumer Health Data from the following categories of sources:
- Directly from you when you share it with us through the Digital Platform;
- From third parties (such as your employer, health plan, and health care professionals) that may be involved with your care or use of the Digital Platform; and
- Through our third-party service providers that support the Digital Platform. This may include the use of cookies, pixels, web beacons, and similar technologies to collect information about you over time and across different websites, including the Digital Platform. Please note that we do not “sell” Consumer Health Data as that term is defined under applicable law.
We collect, process, and disclose Consumer Health Data for the following business purposes:
- To provide, operate, maintain, and protect our Digital Platform, including determining your eligibility to use the Digital Platform;
- To analyze and improve our Digital Platform, including developing new products or services;
- To identify potential research opportunities and to facilitate and conduct research for potential publication;
- To communicate with you, respond to your inquiries, and send you information by email, postal mail, telephone, text message, notifications, or other means, including promotional content about our products and services;
- To enhance and help us better understand your browsing experience, needs, and preferences and provide consistent, personalized services and experiences in our Digital Platform;
- To protect the security or integrity of the Digital Platform, including to perform security analyses to verify that the Digital Platform is working properly;
- To protect us, our users, and the public, and comply with applicable law, regulation, or legal process, including to validate user information for fraud and risk detection purposes, resolve disputes and protect the rights of users and third parties, respond to claims and legal process (such as subpoenas and court orders), fulfill our reporting obligations, and monitor and enforce compliance with our contracts, and otherwise detect, prevent, or stop any activity that may be illegal, unethical, or legally actionable; and
- To evaluate or conduct 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 us about our customers is among the assets transferred.
We disclose some or all of the above categories of Consumer Health Data for the purposes described above with the following third parties and affiliates:
- Within our corporate family (PC Cylinder Medical Group and Cylinder Health Canada, Inc.);
- Your employer as necessary to facilitate your access to the Digital Platform, performance evaluation, quality improvement, and payment;
- As legally required in relevant legal proceedings and otherwise to the extent required or explicitly authorized by applicable law, including laws requiring the reporting of certain circumstances;
- To clinical research organizations, researchers, and healthcare institutions we collaborate with for research and development activities, in compliance with applicable law;
- Service providers that support the Digital Platform and similar advisors (such as attorneys, consultants, or accountants);
- Third parties within the context of a merger or similar business transaction; and
Other third parties at your express direction.
No information received through any texting communications will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
Your Privacy Rights
Depending on your place of residency, you may have some or all of the following rights regarding your Consumer Health Data, subject to applicable law and certain exceptions:
Right to Confirm and Access:
If you ask us, we will confirm whether we are collecting, sharing, or selling your Consumer Health Data. At your request, we will provide a list of all third parties and affiliates with whom we have shared or sold your Consumer Health Data. You may request that we provide you with a copy of the Consumer Health Data that we maintain about you.
Right to Correct:
If your Consumer Health Data that we maintain is inaccurate and you would like us to correct it, you may request that we make changes to it.
Right to Withdraw Consent:
Where we have relied on your consent or authorization for certain processing of your Consumer Health Data, you may withdraw that consent or authorization at any time.
Right to Delete:
You may request that we delete the Consumer Health Data we maintain about you.
Right to Appeal:
If we deny your request to exercise any of the above rights, you may request to appeal this decision.
To exercise any of the above rights, you or your authorized agent may do so by following the instructions in “Contact Us” below. To process your request, we may ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information that we have in our records, such as your most recent interaction with us, if applicable.
Updates to this Policy
We may update this Health Data Policy from time to time and notify you in accordance with law, which may include email or other notice posted to the Digital Platform or Marketing Site. Any changes to this Health Data Policy will become effective when we notify you of the changes. Your use of the Platform or Marketing Site following any such updates will constitute your acceptance of such updates.
Contact Us
For questions about our Health Data Policy, to make choices about receiving promotional communications, or to request to exercise a right described in this Health Data Policy, you can contact us through any of the methods listed below:
Mail: 2045 W Grand Ave Ste B, PMB 37767, Chicago, IL 60612-1577
Phone: (888) 200-5492
Email:
Web: https://cylinderhealth.com/contact
