HealSkill Privacy Policy
HealSkill provides web and mobile delivery of traditional health, wellness, and other services designed to allow you to manage all of your health information in one place. HealSkill’s digital platform and services may be offered through your employer, health plan, or other program sponsor, always on a voluntary basis.
HealSkill is a U.S. based corporation, organized under the laws of the State XXX, and is headquartered at XXX.
HealSkill values your trust, and protecting your information is our highest priority. HealSkill is committed to your privacy. This Privacy Policy explains what information HealSkill and its affiliates (collectively, “HealSkill” or “We”) collect, how information is collected, how we use that information, what information is shared with whom, and how HealSkill protects your information when you use our products and services (“Services”), including the following:
Please visit our terms page for additional terms and conditions applicable to the Services.
Information we collect
The information HealSkill collects is highly variable based on the type of Services you use and the manner in which you access them. Depending on these factors, HealSkill may collect the following information about you:
Personal Information. This is information that directly or indirectly identifies you, such as your name, email address, or other identifying information about you.
Protected Health Information (“PHI”). PHI is your Personal Information that is protected under the U.S. Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). HIPAA and other laws closely regulate how HealSkill may handle, protect, and share your PHI. HealSkill may offer certain Services to you based on your relationship with employers, healthcare providers, insurance companies, or other entities (each an “Enterprise Organization”) with an interest in your health (“Enterprise Programs”). If such Enterprise Organizations are Covered Entities as defined by HIPAA, HealSkill must comply with HIPAA in connection with the corresponding Enterprise Program.
Other Information. Other Information is information that, by itself, does not individually identify you such as browser type, operating system, technical data, and usage. We may link together different types of Other Information or link Other Information to Personal Information.
How We Collect Information
We collect information in the following ways:
How We Use Information We Collect
To Provide Services To You. We use the information that we collect about you to provide, maintain, protect and improve the Services that HealSkill provides to you.
Analytics. We use analytics tools and other third-party technologies, such as Google Analytics, to collect non-Personal Information in the form of various usage and user metrics when you use our site. These tools and technologies collect and analyze certain types of information, including cookies, IP addresses, device and software identifiers, referring and exit URLs, onsite behavior and usage information, feature use metrics and statistics, usage and demographics, and other similar information. You can deactivate Google Analytics using a browser add-on if you do not wish the website analysis to take place. You can download the add-on here: tools.google.com/dlpage/gaoptout.
To Improve Our Services. We use de-identified, anonymous information that we collect about you for statistical and analysis purposes to improve our products and services, and to provide population statistical analysis and well-being trend information.
For Certain Data and User Types, for Advertising. In certain limited scenarios, we may use certain information for advertising as set forth in the “Advertising” section below.
Legal Grounds for Processing Your Personal Data
We rely on the following legal grounds to process your Personal Information:
Consent. We may use your Personal Information as described in this Privacy Policy subject to your consent. To withdraw your consent for any uses of Personal Information described above, please review the section titled “Privacy Rights, Choices, and Account Termination” or contact us at info@HealSkill.com.
Performance of Services. We may need to collect and use your Personal Information to enter into and perform under an agreement with you or an Enterprise Organization.
Legitimate Interests. We may use your Personal Information for our legitimate interests, including but not limited to marketing, to provide our Services and to improve our Services and the content on our sites.
What Information We Share
We take your privacy seriously. We do not sell your Personal Information to third parties as part of any Enterprise Program and all information disclosed is the minimum amount necessary to fulfill the legitimate business purpose. We do not sell anyone’s sensitive data to data miners or data brokers. We do not share Personal Information with companies, organizations and individuals outside of HealSkill except in the following circumstances:
How We Protect Your Information
We work hard to protect HealSkill and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. HealSkill is committed to using industry-leading security practices such as ISO27001 and HITRUST. In particular:
We keep Personal Information housed on servers in the United States. If you are located outside of the United States, information we collect (including cookies) are processed and stored in the United States. By using the Services and providing information to us, you consent to the transfer to and processing of the information in the United States, which currently lacks an adequacy decision with the European Commission.
We store Personal Information for as long as required under applicable law. Where there is no legal, fiscal, administrative, or contractual requirement to retain information for a longer or shorter period, information will be destroyed within five (5) years of its collection.
Transparency, Privacy Rights and Choices, and Account Termination
People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used.
Subject to your specific use of the Services, your privacy rights include:
Terminating Your Account. You may terminate your account with us at any time through the account settings in your HealSkill account, by contacting our Customer Service, or emailing info@HealSkill.com. Terminating your account will revoke any applicable consents or opt-ins but will be subject to any data retention requirements as described below.
Retention of Collected Information. Except as otherwise permitted or required by applicable law or regulatory requirements, we will retain your Personal Information only for as long as we believe it is necessary to fulfill the purposes for which the Personal Information was collected (including for the purpose of meeting any legal, accounting or other reporting requirements or obligations). You may request that we delete the Personal Information about you that we hold, as described above.
Cookies. You may set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set by us. However, many of our Services may not function properly if your cookies are disabled. For example, we may not remember your location preferences. See our Cookie Policy for more information.
Advertising. We also personalize your experience on our sites and mobile Services by showing you advertisements from HealSkill or our advertising partners that are tailored to your interests. Learn more about interest-based advertising, including how to opt out. Use the AdChoices icon in the footer below to opt out of interest-based advertising from HealSkill.
HealSkill does not advertise, market, or promote products or services to patients, participants, or practitioners who receive Services as part of an Enterprise Program. In the event your Enterprise Organization, through which you receive Services, instructs us to provide advertising content on this site, HealSkill would first obtain your valid authorization in compliance with applicable data privacy laws.
Information Shared By You. Many of our Services let you share information with others. Remember that when you share information publicly, it may be indexable by search engines. Our Services provide you with different options on sharing and removing your content.
Accessing and Updating Your Personal Information. Whenever you use our Services, we aim to provide you with access to your Personal Information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your Personal Information, we may ask you to verify your identity before we can act on your request. Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our Services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our Services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. Access, correction, or deletion requests can be made by contacting HealSkill Customer Support or info@HealSkill.com.
Information of Children. The Services are not directed to or intended for use by minors. In compliance with laws, we will not intentionally collect any Personal Information from children under the age of 18. If you think that we have collected Personal Information from a minor child, please contact us.
When This Privacy Policy Applies
Our Privacy Policy applies to all of the Services offered by HealSkill Inc. and its affiliates, including Services offered on other sites, but excludes Services that have separate privacy policies that do not incorporate this Privacy Policy, and Services that you may receive as a result of your participation in an Enterprise Program that expressly supersedes this Privacy Policy.
Our Privacy Policy does not apply to Services offered by other companies or individuals, including products or sites that may be displayed to you in search results, sites that may include HealSkill Services, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.
Compliance and Cooperation with Regulatory Authorities
We regularly review our compliance with our Privacy Policy. When we receive a formal written complaint, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of Personal Information that we cannot resolve with our users directly.
California Privacy Rights
Residents of the State of California may have additional rights as set forth in our Privacy Notice for California Residents. To opt of any potential sale of your Personal Information, click here: DO NOT SELL MY PERSONAL INFORMATION.
Other Jurisdictions
You may choose to use our services if you reside outside of the U.S. We comply with any applicable laws and regulations based on the geographical location you select during your registration. Other jurisdictions, including but not limited to the European Economic Area (“EEA”), provide certain rights regarding Personal Information, including the ability to request erasure, to restrict processing of your Personal Information, or for a copy of your Personal Information. Nothing in this Privacy Policy limits or attempts to limit your rights under applicable laws, including your ability, depending on your country of residence, to file a complaint with your local Data Protection Authority.
It is necessary for us to perform our obligations in accordance with any contract or engagement that we may have with you. It is in our legitimate interest or a third party’s legitimate interest to use Personal Information in such a way to ensure that we provide the Services in the best way that we can.
HealSkill is located in the United States. When you submit Personal Information to us, or when others provide Personal Information to us, we will receive it and process it in the United States.
As detailed above, we sometimes provide Personal Information to third parties to perform services. If we transfer Personal Information received from the EEA to a third party, the third party’s access, use, and disclosure of the Personal Information must also be in compliance with our Data Processing Addendum, including but not limited to the Standard Contractual Clauses contained therein.
Without limiting any other rights contained in this Privacy Policy, privacy rights under European Data Protection law, which may be exercised by all users, include:
If you reside or otherwise find yourself outside of the U.S., we are committed to facilitating the exercise of your rights granted by the European Data Protection law and/or the laws of your country. If you have any inquiries or complaints about our handling of your Personal Information or about our privacy practices generally, please contact us (including our Data Protection Officer) at: info@HealSkill.com. We will respond to your inquiry promptly.
Our EEA representative is HealSkill Debrecen, Csucs utca 9.
We may require you to provide us with sufficient information such as your name, address, or any Other Information necessary for us to verify your identity. We reserve the right to request additional information from you, such as a photocopy of your passport or other identification card in order to verify your identity.
Changes to this Privacy Policy
Our Privacy Policy may change from time to time. This Privacy Policy is not intended to and does not create any contractual or other legal rights in or on behalf of any party. If we change this Privacy Policy, we will post any privacy policy changes on this page and, if the changes are material, we will provide a more prominent notice by sending you an email and/or posting a notice in the Services. HealSkill reserves the right to modify this Privacy Policy at any time, so please review it frequently.
Last modified: August 29, 2022