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Pathfinder Health Privacy Policy

Last updated 20 November 2023

 

1. Overview

Pathfinder Health, Inc. (“Pathfinder”) knows your privacy is important to you and takes its obligation to protect your confidential information very seriously. This Privacy Policy applies to the Pathfinder Website (“Website,” available at https://www.pathfinder.health/), Pathfinder Mobile Application (“Application”), and Pathfinder content, such as text, graphics, videos, images, information, and other material and data (“Content”). All of the foregoing may be collectively referred to as the “Services”.  It describes how we collect, use, secure, and share information provided by our users, as well as individuals whose payment details are used to register for the Website and Application.


This Privacy Policy covers how Pathfinder collects, receives, uses, retains, and discloses Personally Identifiable Information (“PII”) and Protected Health Information (”PHI”) via the Services. PII includes information about you that is personally identifying such as your name, email address, and phone number and which is not otherwise publicly available.  PHI includes information relating to your health, for example medical history, health conditions, test and laboratory results, physician referrals, insurance information and other data that a healthcare professional may collect to identify an individual and determine appropriate care.  PII and PHI may include other types of information depending on the legal definition that applies in your physical location. Only the definitions of PII and PHI that apply in your location will apply to you under this Privacy Policy. PII and PHI are referred to collectively in this Privacy Policy as “Personal Data.”  


This Privacy Policy does not apply to any products, services, websites, or content that are offered by third parties (“Third Party Services”), which are governed by their respective privacy policies and terms of use. 


PLEASE READ CAREFULLY PRIOR TO USING OUR SERVICES. BY ACCESSING AND USING OUR SERVICES, YOU AFFIRM THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO ABIDE TO THIS PRIVACY POLICY AND THE TERMS OF USE  (insert link here) . IF YOU DO NOT AGREE TO ABIDE TO THE TERMS OF USE AND THIS PRIVACY POLICY, YOU MAY NOT ENTER, ACCESS, OR OTHERWISE USE OUR SERVICES. IF YOU USE THE SERVICES ON BEHALF OF SOMEONE ELSE, YOU REPRESENT TO US THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL TO ACCEPT THIS PRIVACY POLICY AND YOU DO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL’S BEHALF.


WE ARE NOT PROVIDING ANY MEDICAL ADVICE OR SERVICES AND SHOULD NOT BE RELIED UPON AS A SUBSTITUTE FOR CONSULTATIONS WITH QUALIFIED PROFESSIONALS WHO ARE FAMILIAR WITH YOUR INDIVIDUAL NEEDS. PLEASE CONSULT YOUR DOCTOR AS NECESSARY.  


IN THE CASE OF A MEDICAL EMERGENCY, DO NOT USE THESE SERVICES AND PLEASE DIAL 911.

2. What information do we collect?

Information you provide. You are not required to create a Pathfinder account to gain access to our Website.  You are required to create an account to access our Application or Content or join our waitlist. When you create an account, we may ask for certain information to process your registration, including an email address, phone number, and password and billing information for our paid services. To help personalize your usage of the Application and Content, we may also ask for certain limited demographic information when you create an account, including your name, gender, race/ethnicity, zip code, children’s names, their gender, and their age. You may also have the option to upload a photo of your child(ren) and select your preferences for receiving email and text communications. If you sign in to or connect to our Website, Application, or Content using a third-party service, we may use that service to authenticate you. 


As you use the Application, you will have the option to provide additional information about your child(ren), including but not limited to milestones, behaviors, clinical data, and other information that you may choose to include in your child’s Pathfinder journal. 


You may also choose to upload video and audio recordings of your child for use with the SmartDetection product of the Application. These audio and video recordings will be used to assist you in determining whether your child is reaching the important development milestones at the correct times.  


Data we collect. In addition to the information you provide to us, when you use the Pathfinder Website, Application, or Content, we may also collect and store information about the computer, mobile device, or other devices you use to access our Website, Application, or Content and about how you use them. We may also collect and store information such as your browser type, IP address, language, operating system, unique device identifier, mobile network information including phone number, the date and time of your usage, the content and pages you view and the websites you visited immediately before and after visiting our Website. We may associate your device identifiers or phone number with your Pathfinder account.


We may also collect and store certain information in server logs, including in third-party logs. This may include: (i) details of how you used our Website, Application, or Content, (ii) Internet protocol address, and (iii) device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
We may collect and store information (including personal information) locally on your device using mechanisms such as cookies, browser web storage and application data caches.


Personal Health Information
Any PHI is collected via HIPAA compliant platforms.   Any third parties involved in collecting, storing, transferring, and/or deleting patient data maintain appropriate Business Associate Agreements with Pathfinder.

 

3. How does Pathfinder use your information?

We use the information we collect to operate and provide you with the Pathfinder Website, Application, and Content. This includes, but is not limited to:


- Authenticating your login and processing your payments;
- Personalizing your Pathfinder experience and customizing factual materials, recommended activities, and developmental screenings for your child;
- Allowing you to monitor your child’s progress in Pathfinder;
- Using the video recordings and the data therein to inform our machine learning algorithms;  
- Providing customer service and sending confirmations about your account;
- Sending push notifications to notify you of new screenings or remind you to log journal entries, if you elect to receive them;
- Protecting our intellectual property or other rights; 
- Communicating with your healthcare providers as applicable;
- Arranging for treatment, payment and health care operations and
- Managing and improving our business, Website, Application, and Content. 

 

4. When does Pathfinder share personal information with third parties? 

We may share your personal information in the following ways:


Healthcare providers and/or caregivers. As a Pathfinder user, you may elect to add your child’s healthcare provider and/or caregiver to their village and permit them to view the personal information that you have provided about your child. Only after being invited by you, the parent, and signing the Privacy Policy is your healthcare provider or caregiver permitted to view you or your child’s personal information. Please note that Healthcare providers are also bound by Health Insurance Portability and Accountability Act (HIPAA) restrictions that limit how they may use your personal information obtained from Pathfinder.


SmartDetection review.  The audio and video recordings you submit for use with the SmartDetection product will be reviewed by human reviewers as well as shared with machine learning technology.  The human and machine reviewers will use the audio and video recordings to perform the SmartDetection analyses.  


Service providers and agents. Pathfinder may share your information with certain third parties selected by us to help support our operations. These include, for example, services such as Adapty that help us process payments, analyze web traffic, send emails, and track customer service requests. 


Third-Party Sites.  The Services may include functionality that allows certain kinds of interactions between the Website and Applications and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we may provide links on the Services to facilitate sending a communication from the Services or we may use third parties to facilitate emails or postings to social media (like a “Share” or “Forward” button). These third parties may retain any information used or provided in any such communications or activities and these third parties’ practices are not subject to our Privacy Policy. We may not control or have access to your communications through these third parties. Further, when you use third-party sites or services, you are using their services and not our services and they, not we, are responsible for their practices. You should read the applicable third-party privacy policies before using such third-party tools on our Services. Please also see our Terms of Use for further information.


Compliance with law and law enforcement requests, and protection of our rights. We may disclose your information when we have a good faith belief it is reasonably necessary to (i) meet any applicable law, regulation, legal process, court order, governmental request or other legal mechanism, (ii) enforce applicable Terms of Service, including investigation of potential violations, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) protect against harm to the rights, property, safety of Pathfinder, our users, or the public.


Consent. We may disclose your information when we believe we have your consent to do so, such as when you contact customer service and ask us about your account, or when we have the consent of someone we believe is authorized to consent on behalf of you, such as the individual associated with the payment method for your account.


Except as stated above, Pathfinder does not give out, share, sell, rent, or otherwise disseminate personal information from users.

 

5. Aggregated information
We may aggregate, de-identify, and/or anonymize any information collected through the Website or Applications such that such information is no longer linked to your personally identifiable information. We may use and share this aggregated and anonymized information (non-personal information) for any purpose, including without limitation, for research and marketing purposes, to train our machine learning algorithms for the SmartDetection and other features, to improve user experience and make clinical improvements to the Website, Application, and Content.  We may also share such data with our affiliates and third parties, including advertisers, promotional partners and others. By agreeing to this Privacy Policy, you give your permission for such future use.

6. Accessing, Reviewing, and Deleting Your Information

If you are a Parent User, DayCare Provider or Physician or Healthcare Provider, you may review and update your user profile information by logging into the relevant portions of the Services where such information may be updated or by contacting us at info@pathfinder.health.com . You can see an electronic copy of information we have about you on your user account. If you would like a paper copy you can print your account page through your browser.


If you wish to close your account, please email us at info@pathfinder.health.com  We will delete your account and the related information at your request as soon as reasonably possible. Please note, however, that we reserve the right to retain information from closed accounts, including to comply with law, prevent fraud, resolve disputes, enforce the Terms of Use, and take other actions permitted by law.


Please notify us promptly if any of your account data is lost, stolen or used without permission.

7. Security of Personal Information

The security of your information while using the Pathfinder Website and Application is extremely important to us. We have implemented and maintain reasonable security practices to protect against the unauthorized access, use, modification, destruction, or disclosure of your personal information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed 100% secure. As a result, we cannot guarantee or warrant the security of any information you transmit to or from our Website and Application, and you provide us with your information at your own risk.

 

8. Children’s Privacy
We do collect information about children which you, as a parent or guardian, or health care professional provides. However, our We do collect information about children which you, as a parent or guardian, or health care professional provides. You agree, acknowledge and represent that you have the legal authority to provide us with information about your child, whether in your capacity as the parent or guardian or as a physician or other child care provider and that you have obtained the appropriate consent to do so.  However, our Website and Applications are not directed to children under 18 and we do not knowingly collect personal information from children under 18 from the child themselves. If you become aware that your child has provided us with personal information, without your consent, then please contact us using the details below so that we can take steps to remove such information and terminate any account your child has created with us.  We encourage you to spend time online with your children and to participate and monitor the online activities of your children.

9. Outside the United States Consent to Processing and Transfer of Information

Our Services are not available outside the United States.  If you do access the Pathfinder Website, Applications, or Content outside of the United States, you fully understand and unambiguously consent to the transfer of your personal information to, and the collection and processing of such personal information in, the United States.

 

 

10. Changes to Privacy Policy

Pathfinder may modify this Privacy Policy at any time, effecting upon its posting. Unless otherwise provided by applicable law, your continued use of the Pathfinder Website, Application, or Content means that you agree with, and consent to be bound by, the updated Privacy Policy.

 

 

11. Contact Information

We are committed to resolving questions or concerns about your privacy and our collection or use of your Personal Data.  If you have any questions about this privacy policy, you may contact Pathfinder at info@pathfinder.health.

 

If you feel we have breached your health information privacy rights, you are also entitled to file a complaint under HIPAA with the U.S. Department of Health and Human Services.

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