THIS NOTICE DESCRIBES HOW PERSONAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN OBTAIN ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
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Introduction
This Notice of Privacy Practices describes the ways in which we may use and disclose your personal information and sets forth your rights and our obligations regarding such uses and disclosures.
Obtaining Your Written Authorization for Uses or Disclosures
In general, we will obtain a written authorization from you before using or disclosing personal information about you. You may be able to revoke any such authorization in writing at any time, except to the extent that we have taken in reliance on the authorization.
Your Sharing of Information with Us
1. Participation in Gathers
As a part of our services, we will give you the opportunity to participate in weekly Gathers, which are virtual guided meetings with other participants, first in a large group and then in small breakout groups for structured discussions of goals. Participants will have an opportunity to share personal information, including health information, in these sessions with other participants and with staff providing guidance to the group. By participating in Gathers, you are agreeing to share such information with other participants and staff.
2. Online Website Forums
We will provide online forums on our website where people with registered accounts can chat, add pictures, and share whatever information they may choose to share.
3. Pictures and Testimonials
If participants post pictures on our website, we ask for written permission before using the images that have been posted for marketing or other external purposes. Similarly, we will ask for written permission before using any written statements by participants for testimonial or similar purposes.
Uses and Disclosures Without Your Written Authorization
In addition, we may use or disclose your personal information without any specific written authorization from you in the following situations:
1. Provision of Our Services
We may use personal information about you in order to provide our services to you as described in our website. For example, we will give you the opportunity to fill out questionnaires at the beginning of the program for our internal use in tracking participants’ progress in order to aid us in evaluating the program, assessing user engagement, and conducting future research to demonstrate the impact of our program on participants.
2. Payment for Our Services
We may use information about you, including personal information, to bill for our services and to collect payments from you or any third party. For example, a family member may require specific information about your condition to pay us or reimburse you.
3. Improving Our Operations
We may use and disclose personal information about you in order to measure and improve the quality and scope of our services or operations. For example, we may use personal information to review the quality of our programs by measuring your progress based on your answers to questionnaires collected over time.
4. Consultants and Contractors
We may use and disclose information about you, including personal information, to consultants and contractors who perform services on our behalf. Any such consultant or contractor must agree in writing to protect the confidentiality of the information. For example, we may share your personal information with a company that helps us analyze personal information and produce reports.
5. Health-Related Benefits and Services
We may use and disclose your personal information to tell you about health related benefits or services that may be of interest to you.
6. Required By Law
We will disclose personal information about you when required to do so by federal, state or local law.
7. To Avert a Serious Threat to Health or Safety
We may use and disclose personal information about you in order to prevent a serious threat to your health or safety or to the health or safety of the public or another person. Any such disclosure, however, would only be to someone able to help prevent the threat.
8. Public Health Risks
We may disclose personal information about you for public health activities. These activities include the following:
- To prevent or control disease, injury or disability; and
- To report reactions to supplements or problems with products.
9. Abuse or Neglect
We may disclose personal information about you to the appropriate government authority if we believe you have been the victim of abuse, neglect or domestic violence. We will only make this disclosure if you agree or when required or authorized by law.
10.Law Enforcement
We may release information about you, including personal information, if asked by a law enforcement official for the following reasons:
- In response to a court order, subpoena, warrant, summons, or similar process;
- Limited information to identify or locate a suspect, fugitive, material witness, or missing person;
- About the victim of a crime if, under certain limited circumstances, we are unable to obtain the person’s agreement;
- About a death we believe may be the result of criminal conduct; and
- In emergency circumstances, to report a crime, the location of the crime or victims, or the identity, description, or location of the person who committed the crime.
Your Rights Regarding Your Personal Information
You have the following rights regarding personal information that we maintain about you:
1. Right to Inspect and Receive Copy
You may inspect and request copies of the personal information that we maintain about you. To inspect and receive copies of such information, you must submit your request in writing to LiveWell@TrueMedicineMS.com. We may deny your request in certain circumstances. If we do so, you may request that the denial be reviewed a by wellness educator chosen by us. The person conducting the review will not be the person who denied your request, and we will comply with the outcome of the review.
2. Right to Amend
If you feel that personal information that we have in your record is incorrect or incomplete, you may ask us to amend the information. You may request an amendment for as long as the information is kept by or for us. To request an amendment, you must submit your request in writing to LiveWell@TrueMedicineMS.com. In addition, you must provide a written reason that supports your request. We may deny your request for an amendment if it is not in writing or does not include a reason to support the request. In addition, we may deny your request if the information is (i) not created by us; (ii) not in our records; (iii) not part of the information that you would be permitted to inspect and copy; or (iv) already accurate and complete.
3. Right to Request Accounting of Disclosures
You may request an accounting of our disclosures of your personal information. You should submit any such request in writing to LiveWell@TrueMedicineMS.com. We will not charge you for such an accounting. However, we will charge you for any second accounting that you request within one year of the initial accounting.
4. Right to Request Restrictions
You may request a restriction or limitation on the personal information we use or disclose about you for purposes of securing payment for our services or improving our operations. We will honor your request to the extent practicable. You should submit any such request in writing to LiveWell@TrueMedicineMS.com. We endeavor to honor your request to the extent practicable.
5. Right to Request Confidential Communications
You may request that we communicate with you about your personal information in a certain way or at a certain location. For example, you can ask that we contact you only at a particular email or by regular mail to a particular address. You should submit any such request in writing to LiveWell@TrueMedicineMS.com. We will endeavor to accommodate all reasonable requests.
6. Right to a Paper Copy of this Notice
You may request and receive a paper copy of this Notice at any time. To obtain a paper copy, you should submit your request to LiveWell@TrueMedicineMS.com. In addition, you may review this notice at this website, LiveWell@TrueMedicineMS.com.
Security Breaches
In the event of a security incident that leads to a security breach of your personal or health information, we will provide timely notice to you in accordance with all legal requirements, including identifying the time and extent of the breach and the data involved, together with mitigation measures that we are taking to lessen the adverse effect of the breach on program participants.
Complaints
If you believe your privacy rights have been violated, you may file a complaint with us. To do so, you should submit your complaint in writing to LiveWell@TrueMedicineMS.com.
Children
We do not knowingly collect or maintain personally identifiable information from persons under 18 years of age, and no part of our services are directed at persons under 18. If you are under 18 years of age, then please do not use this website. If we learn that personally identifiable information of persons less than 18 years of age has been collected without verifiable parental consent, then we will take the appropriate steps to delete this information. To make such a request, please contact us at LiveWell@TrueMedicineMS.com.
Changes to this Notice
We may change the terms of this Notice at any time and to make the revised effective for all personal information that we already have, as well as any information that we receive in the future. We will post any revised Notice on this website.
Contact
If you have any questions about this notice, you may contact the TRUE Medicine Privacy Officer via email at LiveWell@TrueMedicineMS.com or by mail at 3182 Campus Drive #193, San Mateo, CA 94403.
