Privacy Notice

Effective Date: 4/2021

Cooperative Health (CH) owns and operates the Cooperative Health app (“The App”) and www.cooperative.health (“The Website”). The App offers a private community for patients and caregivers who are invited to join by physician users. While access to the APP is restricted, other users may view information that you post in the App. The Website is publicly accessible and, except as addressed elsewhere in this Notice, does not collect information about you. Additionally, CH is not a healthcare provider, and, as a result, is not subject to the privacy regulations under the Health Insurance Portability and Accountability Act (HIPAA). We believe information sharing is important to help patients, caregivers and the broader healthcare community to help answer complex healthcare questions. With that in mind, we respect your right to share as much or as little as you would like. Your privacy is important to us, and we want you to know what information CH collects, how CH uses the information, and what information CH shares.

We reserve the right to update this privacy notice at any time without notice. The changes will be reflected in an amended privacy notice with a revised “Effective Date.”

What information does Cooperative Health collect from you?

We collect information from you when you register for an account and when you share information in the App.

Some information you enter in the App could be used to identify you or a patient, if you are a caregiver or physician. This data might include:

Username & password, which you create during registration (your password is encrypted)
Your name, which you provide during registration
Your email address, which you provide during registration and can edit in the Profile
Your phone number, which you can add to your Profile
Private Chats sent and received
Any other information you enter in the App

Other information you enter in the App may or may not be used to identify you or a patient, if you are a caregiver. This data might include:

Demographic information including your location, gender, race and age
Biographic information
Relationship to the patient
Diagnosis and disease information
Laboratory test results
Treatment information
Where you or a patient receives care and the doctors who provide the care
Photographs and other images
Connections to other CH APP users (your Connections)
Any other information you enter in the APP and Website

How is your information used by Cooperative Health?

The information you share in the Community and Chats is primarily meant to help you and the CH community, and, as addressed below, our partners, and vendors. We may use your de-identified data and combine it with other member data to help answer complex healthcare questions.

What information does Cooperative Health provide to others?

We may also share your de-identified data and combined data with vendors and partners in order to support the App and Website, and to understand how you use the APP and Website for the purpose of improving CH.

How long does Cooperative Health retain your personal information?

CH retains the data you enter in the App for up to 3 years after your account has been inactive (no log-in activity). In addition, you can delete your account, which means you can no longer access your account and all of your information will be deleted in accordance with CH’s data destruction procedure.

Your outgoing Chat data cannot be deleted. Recipients of your Chats can access anything you send to them even after your account is deleted for as long as they maintain an active account.

Does Cooperative Health use cookies or other passive data collection or tracking methodologies?

CH does not currently use cookies. Our partners help us analyze how users interact with the App and Website based on non-individually identifiable data. The data we share with them for this purpose is also combined with other user data so they can analyze it and provide APP and Website utilization trends, interaction statistics, and other data back to us. Additionally, our vendors may collect non-individually identifiable data from operation of the App and Website on CH’s behalf for use by CH and its vendors and partners.

For California Residents

The California Consumer Privacy Act of 2018 (“CCPA”) provides consumers California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

For identification of the categories of personal information we have collected in the preceding 12 months and the sources of this information, please see the “What information does Cooperative Health collect from you?” section above. For identification of the categories of personal information we have disclosed in the preceding 12 months, please see the “What information does Cooperative Health provide to others?” section above. CH does not sell any of your personal information.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

The categories of personal information we collected about you.
Our business or commercial purpose for collecting that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
Debug products to identify and repair errors that impair existing intended functionality.
Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
Comply with a legal obligation.
Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us at privacy@cooperative.health.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information, such as name, address, and date of birth that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against in pricing and services because you exercise any of your rights under the CCPA.

Amendments

We reserve the right to amend this notice at any time without notice. CH users will be notified by email when this policy is updated. Our policy amendment history is as follows:

April 2021

CH Privacy Policy Questions?

Send us an email at privacy@cooperative.health.