The following Additional Privacy Statements (the "Additional Statements") have been added by the Event Organiser and are specific and in relation to this Event ("Telehealth Innovation Forum") only. These set out additional Promotion and Insight activities that are being conducted by the Event Organiser and sets out additional data processing that they expect to do:
InTouch Technologies, Inc.®, D.B.A. InTouch Health® (“we, “us”, “our” or “Company”) operates the www.intouchhealth.com website (“Site”) as well as provides telemedicine services. This policy applies to our website as well as to the services and applications we provide, collectively known as the “Services.”
To adjust your email and data preferences or opt out of further communications, please visit our Email Preference Center.
PHI is information that includes, but is not limited to, identifying data such as name, social security number, address, contact information, as well as information about personal health issues and insurance submitted through our Services. InTouch Health collects PHI and other PII that you voluntarily submit. Privacy is of the utmost importance so we are committed to protecting and keeping confidential all PII and PHI that identifies an individual whether or not it relates to an individual’s past, present, or future physical or mental health condition.
As a Business Associate of healthcare providers that are Covered Entities under the federal healthcare privacy and security rules, the Health Insurance Portability and Accountability Act (HIPAA) and the Health Information Technology for Economic and Clinical Health (HITECH) Act, InTouch Health maintains PHI in compliance with these rules and our contractual obligations with healthcare providers.
Our main focus is providing a platform to allow individuals to receive telehealth Services from various healthcare providers. InTouch Health collects information solely for the purposes of providing the Services, marketing and promoting our Services to you, and for market research data. We use this information ourselves and share it as needed with our partners solely for their performance of contracted services for us. We may also collect PII for marketing, user experience monitoring and improvement, and related business purposes. We never sell PII that we collect.
InTouch Health maintains web logs to record data about all visitors who use the Site and interact with the Services and we will store this information. These logs may contain IP address information, type(s) of operating system(s) you use, the date and time you visited the site, and information about the type of device you use to connect to the Services and the Site pages you visited.
All web logs are stored securely and are accessible to a very limited number of employees and contractors as required. Those with access to this data adhere to strict guidelines regarding user data security and privacy.
Collecting IP addresses is standard practice and done automatically by many websites, applications, and other services. InTouch uses IP addresses to calculate usage levels of the Site, help diagnose problems with our servers, administer our Site, and monitor regions from which you navigate to our Site.
You may be asked to submit personal information if you sign up for a demo, register for an event, access our free content, or make similar requests. Examples of free content include webinars, case studies, videos, and white papers. We may collect your name, job title, email address, phone number, and certain information about your company. We use this information to contact you about your request (such as a demo request or submitting a form asking for more information on our products and services) or provide you with requested content.
If you sign up to receive marketing communications from InTouch Health, we will collect your name and email address in order to email you regarding products and services that you have indicated are of interest to you. You may also be added to our marketing list when you create an InTouch Health account or are issued one by your employer.
If you apply for a job at InTouch Health, you may provide us with certain personal information about yourself (such as that contained in a resume, cover letter, or similar employment-related materials). We use this information for the purpose of processing and responding to your application for current and future career opportunities.
SUBMIT, ACCESS, ADJUST, OR REMOVE YOUR INFORMATION
If you would like to access, correct, amend, remove, obtain a copy, or limit the use of any PII about you that has been collected and stored by InTouch Health, please notify our Data Protection Officer by emailing firstname.lastname@example.org or calling us at +1 805-562-8686 so that we may respond to your request.
For your protection, we may need to verify your identity before fulfilling your request to access, correct, amend, remove, obtain a copy, or limit the use of your PII. We will use the email address from your request to identify PII that InTouch has collected and stored. We will respond to your request at our earliest convenience and in compliance with in accordance with applicable law.
You have the ability to opt in to receiving messages from InTouch Health, to opt out of receiving direct marketing or market research information, or to adjust your specific email preferences.
To opt in to emails, adjust your email and data preferences, or opt out of further communications, visit our Email Preference Center.
By actively opting into emails from InTouch, you agree that your information may undergo processing including updating your record to reflect your affirmative request to receive emails and tracking within those emails such as when you open them and when you click on links. We use that data to determine which content resonates with you to personalize your experience with InTouch and for other marketing purposes, such as determining your interest in our Services. If you do not want to have your data processed in this manner, you can opt out of emails from InTouch Health or you can abstain from opting into communications. We include a link to change your email preference or opt out on all marketing communications.
Please note that you may continue to receive certain transactional and account-related messages from us after opting out, such as system outage alerts.
“COOKIES” AND INTERNET TAGS
InTouch Health may collect and process information about your use of the Services, such as the Site pages you visit, the website you came from and some of the searches you perform. We use this information to help improve the contents of the Site and the Services and to compile aggregate statistics about individuals using our Site and the Services for internal, market research purposes. In doing this, we may install “cookies” that collect the domain name of the user, your internet service provider, your operating system, and the date and time of access. A cookie is a small piece of information, which is sent to your browser and stored on your computer or other device. Cookies do not damage your device. You can set your browser to notify you when you receive a cookie. This will enable you to decide if you want to accept it or not. If you do not accept cookies, you may not be able to use all functionality of your browser software or this Site. We may obtain the services of outside parties to assist us in collecting and processing information collected through cookies.
InTouch Health may also use internet tags (also known as action tags, web beacons, single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) and cookies through the Services and may deploy these tags/cookies through a third-party advertising partner or a web analytical service partner which may be located and store the respective information (including your IP address) in a foreign country. These tags/cookies may be placed both on online advertisements that bring users to the Services and on different pages of the Site. We use this technology to measure the visitors’ responses to the Site and the Services and the effectiveness of our advertising campaigns (including how many times a page is opened and what information is consulted) as well as to evaluate your use of the Services. The third-party partner or the web analytical service partner may be able to collect data about visitors to the Site and other sites because of these internet tags/cookies, may compose reports regarding the Site’s activity for us and may provide further services which are related to the use of the Site and the internet. They may provide such information to other parties, if there is a legal requirement that they do so, or if they hire the other parties to process information on their behalf. If you would like more information about web tags and cookies associated with on-line advertising or to opt-out of third-party collection of this information, please visit the Network Advertising Initiative website https://www.networkadvertising.org. (We are not affiliated with the Networking Advertising Initiative in any way.) If you opt out, please be advised that your user experience will be affected.
When you download or use apps created by us (e.g., to deliver the Services), we may receive information about your location and your mobile device, including a unique identifier for your device. We may use this information to provide you with location-based services, such as search results and other personalized content. Most mobile devices allow you to turn off location services.
InTouch Health may use non-personal information to analyze data into useful information. This process of data mining is done in the aggregate, is non-personal, and allows the Company to find correlations and patterns in the data.
InTouch Health does not provide any personal information to third party sites that display our interest-based ads. However, third parties (including the ad networks, ad-serving companies, and other service providers they may use) may assume that users who interact with or click on a personalized ad or content are part of the group that the ad or content is directed towards (for example, users in the Northwest who have experienced allergies). Also, some third parties may provide us information about you (such as the sites where you have been shown ads or demographic information) from offline and online sources that we may use to provide you more relevant and useful advertising.
SHARING OF INFORMATION
InTouch Health employs third parties to perform functions on our behalf. Examples include technical assistance, analyzing data, and providing marketing assistance. They have access to anonymized and non-anonymized personal information needed to perform their functions, but may not use this information for other purposes. Access to this information will permit them to provide services more efficiently and effectively to you and to us.
For example: your IP address may be used to estimate your location and personalize your experience with the Services; we may share information such as IP address, user name, email address, and cookie and web beacon information with third parties in order to tailor advertising to our various market segments; your IP address and email address and the page you are viewing may be shared with a third party that operates the “chat” feature for our Services; and aggregate data about IP addresses, pages loaded, time to load pages and errors encountered may be used by third-party performance monitoring and improvement products.
These third parties may be required to disclose information, as described in the section below entitled “Disclosures in Accordance with Law.”
In some regions, InTouch Health partners with local resellers to offer our products and services. If you are located in those regions, we may share PII with those partners for customer relationship management or email marketing purposes.
SECURITY OF INFORMATION COLLECTED
InTouch Health uses account information in a password-protected environment as a security measure to protect your data. We use administrative, physical, and technical safeguards to protect data. We maintain a high level of data protection via safeguards such as data backup, audit controls, access controls, and data encryption. InTouch Health Services use industry standard SSL/TLS encryption to enhance security of electronic data transmissions. InTouch Health will maintain all applicable HIPAA and other regulatory requirements to the extent that it has access to, or otherwise stores, processes or transmits PHI or PII.
In addition, InTouch Health urges you to take precautionary measures in maintaining the integrity of your data. Please be responsible for making sure no one can see or access your account and log-in/password information.
If you use our Services through a potentially non-secure internet connection, such use is at your own risk. It is your responsibility to check beforehand on your employer’s or such other site’s privacy and security policy with respect to Internet use.
InTouch Health is not responsible for your handling, sharing, re-sharing and/or distribution of your PHI or PII. Moreover, if you forward PHI or PII electronically to another person on or off the Service, we are not responsible for any harm or other consequences from third party use or re-sharing of your information.
THIRD PARTY SITES/TRUSTED RELATIONSHIPS
As noted above, under HIPAA the Company may be a Business Associate of healthcare providers who use our Services. We may share information with healthcare providers who provide services to individuals, and they share information with us, for purposes related to treatment, payment and healthcare operations, and otherwise as agreed or authorized by you.
In some cases, our Site contains links to other sites, including links to relevant thought leadership articles in third-party publications that are not directly affiliated with InTouch Health. We do not share your PHI or PII with those sites (unless you specifically authorize such sharing) and are not responsible for their privacy procedures. We encourage you to learn their particular privacy policies.
DISCLOSURES IN ACCORDANCE WITH LAW
Our Site is not designed or intended to appeal to minors and we do not knowingly collect PII from children under the age of 13.
QUESTIONS OR SUGGESTIONS
 Pub. L. 104-191
 Pub. L. 111-5 Div. A Title XIII
HeySummit is not responsible for any part of the above Additional Statements and is only responsible for the Core Privacy Statements set out hereunder:
The following Core Privacy Statements (the "Privacy Statements"), together with the Core Terms of Service and any other documents referred to herein set out we will use the data you provide us at www.HeySummit.com and/or www.app.HeySummit.com (the "Platform") and what Insight activities are ongoing there too.
Please read these Privacy Statements carefully and ensure that you understand them. You will be able to change your Privacy Preferences at any time throughout your time using the Platform and thereafter.
HeySummit’s purpose in establishing this Privacy Statement is to give you information about how HeySummit collects and processes your personal data through your use of the HeySummit Services, including any data you may provide through the HeySummit platform. If you do not agree with the terms, do not access or use the HeySummit Services, websites or any other aspect of HeySummit’s business.
This Privacy Statement applies to all users of HeySummits Platform and associated technology. It is important that you read this Privacy Statement together with any other Privacy Statement or fair processing policy we may provide on specific occasions when we are collecting, or processing, personal data about You, so that you are fully aware of how and why we are using your data. This Privacy Statement supplements other notices and privacy policies and is not intended to override them.
Data protection law in certain jurisdictions differentiates between the “controller” and “processor” of information. HeySummit and Event hosts are independent controllers of certain types of your personal data, such as your registration data (like name and email) and attendance data (like Event name, date and time of Event, and Event sessions attended). Event hosts are the controller, and HeySummit is the processor of Event data, such as information and materials submitted to, or during an Event.
We keep our Privacy Statement under regular review and it may be updated periodically. Laws, regulations, and industry standards evolve, which may make those changes necessary, or we may make changes to our services or business. We will notify you by posting an updated, date-stamped version of this Privacy Statement on our website. If we make changes that materially alter your privacy rights, we will provide notice to you in accordance with applicable law. Notice may be by posting a notice on our website, by email to you at the email address that you most recently provided to us, or by other means, consistent with applicable law. Accordingly, please keep your account information, including email address, updated.
The HeySummit Services include links to third-party websites and applications as well as to partner providers of multiple different types of services associated with a particular Event.
Clicking on links to third party websites, content or applications may allow those third parties to collect or share data about you. We do not control those third-party websites or content and are not responsible for their privacy statements or the way in which they collect or use your data.
Where you access or use third party services provided by an Event organiser, advertiser, sponsor or any other party who participates in an Event, we encourage you to request details of and read the Privacy Statement of that party. We do not control those third parties and are not responsible for their privacy statements or the way in which they collect or use your data.
Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identifying information has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:
We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data as this data will not directly or indirectly reveal your identity.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of an agreement we have with you, and you fail to provide that data when requested, we may not be able to perform the agreement we have or are trying to enter into with you (for example, to provide you with access to the HeySummit Services).
We use different methods to collect data from and about you including through:
The legal basis for using your information as set out in this Privacy Statement are as follows:
Purposes for which we will use your personal data
We have set out below, in a table format, a description of the ways we plan to use your personal data, and which of the legal basis we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
|Purpose/Activity||Type of data||Lawful basis for processing including basis of legitimate interest|
|To register you as a user of the HeySummit Event Platform||
|Performance of a contract with you|
|To process any paid entry to an Event:
(a) Managing payments, fees and charges
(b) Verifying your identity and details of your payment method or credit card account
(c) Communicating with you, for example sending you confirmation of your attendance for an Event.
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary for our legitimate interests
To manage our relationship with you which will include:
(a) Providing access to Platform services
(b) Notifying you about changes to our terms or Privacy Statement
(c) Asking you to leave a review or take a survey
(d) Investigating complaints
(d) Marketing and Communications
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and to study how users use the HeySummit Event Platform and associated products/services)
|To administer and protect our business and our services (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)||
(a) Necessary for our legitimate interests (for running our business, administering our CRM, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)
(b) Necessary to comply with a legal obligation
|To deliver relevant Platform content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you||
(e) Marketing and Communications
|Necessary for our legitimate interests (to study how users use the HeySummit Event Platform and to grow our business and inform our marketing and growth strategy)|
|Share your information to support the Host or Event Organiser or Team Member(s) to create, manage and deliver the Event.||
(e) Marketing and Communications
|To provide our own services as per our collective agreements and support the Event Organiser to conduct their agreements with you.|
|To use data analytics to improve our Platform, products/services, marketing, user and Partner relationships and experiences.||
|Necessary for our legitimate interests (to define types of users for certain Platform services and to keep our services and web site updated and relevant, to develop our business and to inform our marketing strategy)|
|To make suggestions and recommendations to you about Events or other services available through the HeySummit Event Platform that may be of interest to you||
(f) Marketing and Communications
|Necessary for our legitimate interests (to develop the products and services available through the HeySummit Event Platform)|
We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. You may opt out of any non critical marketing communications but some communications are directly related to the provision of our Services.
Recommendations from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think may be of interest to you. This is how we decide which services and offers may be relevant for you. Subject to applicable law, we may send you information that we think may be of interest to you.
You can ask us or third parties to stop sending you marketing messages at any time. You can contact us or, where applicable, use the instructions located at the bottom of your email. Please note that regardless of your request, we may still use and share certain information as permitted by this Privacy Statement or as required by applicable law. For example, you may not opt out of certain operational communications, such as those reflecting our relationship or transactions with you.
We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us to improve the HeySummit Services and your experience, see which areas and features of our Services are popular and count visits. We may also collect information using web beacons (also known as “tracking pixels”). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon. Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.
Advertising and Analytics Services Provided by Others
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
We may share your personal data with the parties set out below for the purposes set out in the table “Purposes for which we will use your personal data” above.
Where third parties provide Events or support the provision of Services made available to you, these third parties may receive certain personal data about you. Whilst we are not in control of these third parties, we require all third parties to respect the security of your personal data and to treat it in accordance with the law.
To help constantly improve and tailor the service we provide to you, we may use aggregated information so that we can administer and improve our services, analyze trends, gather broad demographic information and detect suspicious or fraudulent transactions and most importantly monitor and improve our operations on a day to day basis. In carrying out this activity, we may pass some information to third parties in aggregate and anonymized format.
Your disclosure to third parties
Except as otherwise expressly included in this Privacy Statement, this document addresses only the use and disclosure of information we collect from you. If you disclose your information to others, different rules may apply to their use or disclosure of the information you provide to them. HeySummit does not control the privacy policies of third parties, and you are subject to the privacy policies of those third parties where applicable. We encourage you to ask questions before you disclose your personal information to others.
We may transfer your personal data outside your country of residence, including the European Economic Area (EEA), in our performance of services.
Whenever we transfer personal data out of the EEA, we ensure an appropriate degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:
Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.
We have put in place commercially reasonable security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instructions and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so. That said, no method of electronic transmission or storage is 100% secure and cannot guarantee absolute data security.
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint, if we reasonably believe there is a prospect of litigation in respect to our relationship with you, or as required or permitted by applicable law.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
If you provide personal data in connection with the submission of Event Content, we may process sensitive personal data as part of the HeySummit Services.
This includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data.
In some circumstances you can ask us to delete your data: see your legal rights below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
Under certain circumstances, you have rights under data protection laws in relation to your personal data. You have the right to:
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
Time limit to respond
We try to respond to all legitimate requests within one month or within the timeline provided by applicable law. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
If you have any questions about this Privacy Statement or our privacy practices, including any requests to exercise your legal rights, please contact us as follows:
You have the right to make a complaint at any time to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). You may also direct your complaint or concern to your applicable data protection authority. We would, however, appreciate the chance to address your concerns before you approach the ICO or another data protection authority.
Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract. In respect to HeySummit, that is the performance of our agreement with you to make the HeySummit Services available. We are not involved in the processing of your Personal Data during any engagement you enter into with our third party partners.
Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
External Third Parties
Requests to exercise your rights may be submitted by emailing us at email@example.com Please be prepared to provide your first and last name and email address that matches information we currently have on file. Where we are unable to verify your identity based upon this information alone, we may require additional details. We will respond to verifiable requests received from California consumers as required by law.