Kannact Health, Inc.
Last updated: April 1, 2023
Kannact Health, Inc. (“Kannact,” “we,” “us,” or “our”) respects your privacy, and we are committed to protecting your rights. We offer health coaching and other services to support members with chronic conditions and to promote whole health management for all members (“Program”).
This notice describes the types of information we may collect from or about you when you participate in our Program or otherwise use our website or mobile application (collectively, the “Service” or “Services”), whether as a registered member or an unregistered visitor, and our practices for collecting, using, maintaining, protecting and disclosing that information.
Information We Collect
We collect Personal Information about you to provide you with our Program and Services. “Personal Information” means any information, including personal and material circumstances, that allows a person to become identifiable. The Personal Information we collect includes, but is not limited to:
- Your contact information, including your first name and last name, home address, personal and business email addresses, and your phone number.
- Your email address.
- Your gender, date of birth and age.
- Your social security number or employee identification number.
- Biometric information such as your blood pressure or weight including such information you provide now or may provide in the future through devices synced with our Services, such as scales, glucometers, blood pressure cuffs and activity tracking devices.
- Information about your health.
- Information about your participation and performance in the Program.
- Information you voluntarily share about yourself during any calls you participate in with our health coaches.
- Information you voluntarily share with our Member Support team.
- Additional information you may provide as you submit requests.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
- To administer and present our Program to you.
- To provide you with information that you request from us.
- To identify you when you contact us or sign-in to our Services.
- To carry out our obligations and enforce our rights arising from any contracts between your Program Sponsor and us, including for reporting and billing purposes.
- To track your progress in our Program.
- To notify you about changes to our Program.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
Additionally, we may create “Anonymous Data” records by removing any Personal Information (including any contact information) that would allow the remaining data to be linked back to you. We may use the Anonymous Data for internal purposes, such as analyzing patterns and Program usage to improve our services. Additionally, we may use Anonymous Data to analyze and understand demographic trends, member behavior patterns and preferences, and information that can help us enrich the content and quality of our Program.
Information Collected from and Shared with Third Parties
We may receive and share information about you from various sources to support the Program and services included in it:
- Your Program Sponsor. If you are participating in the Program through a “Program Sponsor” (typically a health plan associated with your employer), then:
- The Program Sponsor may provide us with Personal Information to identify you as an individual who is able to join the Program.
- We may share anonymized and aggregated data with your Program Sponsor, and they will not be able to use such data to directly identify you. Your Program Sponsor may use the anonymized information at its discretion, including to evaluate the overall program and to provide additional benefits and services.
- In specific circumstances and for limited purposes, such as to ensure proper Program administration, we may share reports containing identifiable information with your Program Sponsor. In these circumstances, we limit the Personal Information to the least amount necessary to support the specific, necessary purpose.
- Third Party Administrators (TPAs). If you are participating in the Program through a Program Sponsor, they may engage a TPA, such as a broker or a wellness provider, to assist with managing its benefits programs. In such cases, we may exchange data with such TPAs as directed by your Program Sponsor.
- Other Benefits Providers Hired by your Program Sponsor. If you are participating in the Program through a Program Sponsor, they may offer benefits through other providers that integrate with our Program. At the direction of your Program Sponsor, we may exchange data, including biometric information and participation data, with these other providers to provide our services to you.
- Our Program Partners. You may have access to organizations through our Program that partner with us to provide you (a) biometric or lab testing services or (b) additional health and related services (Our Program Partners). If you use these services, the Program Partners may share information with us.
- Your Healthcare Provider. We may receive personal and family medical and clinical health information from your healthcare provider and any clinics or organized care facility with which your provider is associated.
- Your Insurance Provider. Your health insurance provider may share claims-related information with us. We may use this claims-related information (a) to generate aggregate reports to help the Program Sponsor customize an effective Program based on the specific needs of its member base, and (b) to help identify effective health and wellness objectives based on changes to your claim history. We may share information about you and your participation in the Program with your insurance provider to ensure you are provided access to any additional services or engagement opportunities and benefits that may be offered through your health plan.
- Health Information Exchange (HIE) Networks. We may participate in various regional or national HIE networks to access or disclose your Personal Information, including medical care records and prescription data. HIEs are intended to enable the doctors, hospitals, and other health care organizations that care for you to see a more complete picture of your health and make more informed treatment decisions for you.
- Public Databases. We may receive information about you from other sources including publicly available databases. We combine this data with information we already have about you. We may also combine publicly available aggregated census and demographic data with your Personal Information. This can help us analyze our records to better evaluate the effectiveness of our services.
- Health and Activity Tracking Devices. You may now or in the future connect health and activity tracking devices, such as smart watches, smart scales and other devices, to your account. If you choose to synchronize a tracking device with your Program, we will receive information about your health and activity. Tracking devices can track a wide number of different aspects of your daily activities, including, among others, your daily steps and fitness activity, your heartbeat and your sleep pattern. Depending on the brand and model of tracker you use, the data collected may vary. In general, companies selling tracking devices have specific privacy policies available, which outline what data the specific activity tracking device collects. We strongly suggest you review the right privacy notice to know what specific data points your health and activity tracking device collects about you.
Sharing Your Information - Other Third Parties
- Our Service Providers. We may share your information with third parties that help us provide the Services and operate our business, including in the areas of website and database hosting and maintenance, telecommunications, information security, fraud detection and prevention, email management, data analytics, marketing, advertising, member support, and identity and professional credential verification.
- Authorities. We may access, preserve, and share your information with third parties, as required or permitted by applicable law, if we believe it is reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us, which may involve disclosure to law enforcement, courts, or governmental authorities.
- Other Third Parties. We may access, preserve, and share your information if we determine it is reasonably necessary or appropriate to investigate, prevent or take action regarding suspected fraudulent, harmful, unethical or illegal activities, or any violation of our Terms of Service or to protect and defend our legal rights, safety, and property.
- With Your Consent. We also may share your personal information with a third party in a manner not addressed by this notice with your consent.
Information Collected Automatically When You Use Our Services
If you use our website or mobile application, we collect a variety of personal information automatically when you use our Services through the use of “cookies” and similar technologies (e.g., pixels, web beacons and device identifiers). Cookies include activity information such as the date and time that you access our site or app. We collect device information including your IP address (which is a unique numerical address that identifies your device when you access the Internet), your browser and device type and model, operating system, your ISP and mobile carrier, your advertising ID (which is a unique, user-resettable identification number associated with a mobile device), other unique identifiers associated with your computer or mobile device, and the URL of the site from which you access our site.
The use of these technologies helps us serve you better by understanding what you’re interested in, tracking trends, measuring the effectiveness of our content and saving your preferences. For information about how you can manage your cookie preferences, refer to the “Choices About How We Use and Disclose Your Information” section, below.
Children Under the Age of 13
Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from children under 13. If you are under 13, do not use our Program or provide any information to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at email@example.com.
We employ technical, administrative and physical safeguards designed to protect your personal information. However, no security measure can guarantee security and that data will not be accessed, disclosed, altered, or destroyed. If you use our website or mobile application, you should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a complex password that nobody else knows or can easily guess, and keeping your log-in credentials private. We are not responsible for any lost, stolen, or compromised passwords or for any unauthorized account activity.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Account and Profile Information. If you have registered an account, you may review and update certain personal information through your account settings. If you prefer to submit an update request to us directly, or if you wish to close your account, please contact us at firstname.lastname@example.org.
Accessing and Correcting Your Information
You can review and change your personal information by logging onto our site and visiting your account profile page.
You may also send us an e-mail at email@example.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Your California Privacy Rights
California’s “Shine the Light” law permits customers who reside in California to request, once per year, disclosure regarding how we share certain of their information with third parties and affiliates for those third parties’ and affiliates’ own direct marketing purposes. If this law applies to you and you wish to obtain further information about our sharing, you may make one request each year by contacting us at firstname.lastname@example.org or 425 SW Second Avenue, Suite 201, Albany, Oregon 97321.
We reserve the right to modify this privacy notice at any time and in our sole discretion. When we make a change, we will update the “Effective Date” and post the updated notice on or through the Service. We may, and if required by law will, also provide notification of changes in another way that we believe is reasonably likely to reach you, such as by e-mail (if you have an account where we have your contact information) or another manner through the Service. Any modifications to this privacy notice will be effective upon posting or as otherwise indicated at the time of posting. In all cases, by continuing to use the Service after posting of the updated notice, you are consenting to the changes. If you object to any changes, you may close your user account by contacting us at email@example.com.
To ask questions or comment about this notice and our privacy practices, contact us at: firstname.lastname@example.org.