1. INTRODUCTION
The purpose of this Privacy Policy is to describe how Full Circle Health Network, Inc. (FCHN) collects, uses and shares information about you through our website located at www.fullcirclehn.org (the “Site”). FCHN respects your privacy and is committed to protecting it as outlined in this Privacy Policy. If you do not agree with our policies and practices, you may not use our services. By accessing or using our services, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our services after we make changes is deemed to be acceptance of those changes. Please read this notice carefully to understand what we do. If you do not understand any aspects of our Privacy Policy, please feel free to Contact Us as described at the end of this Policy.
Our Privacy Policy explains:
• Information That We Collect
• How We Use and Share Your Information
• Access to Your Information and Choices
• Security of Your Information
• California Privacy Rights
• Consent to Processing of Personal Data in United States
• Changes to Our Privacy Policy
• Questions and How Contact Us
Scope; Third Party Sites. This Privacy Policy applies only to information we collect at and through the Site. Our Site also contains links to third-party sites that are not owned or controlled by FCHN. Please be aware that we are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information.
2. INFORMATION WE COLLECT
Information You Provide to Us
We collect information you provide to us, for example when you create or modify your account, register to use our Site, purchase products or services from us or our clients, request information from us, contact customer support, or otherwise communicate with us or use our Site in commerce. This information may include:
Please note FCHN does not practice medicine or provide medical care. We do not provide or intend to provide answers to medical-related questions. Furthermore, if you are using our services, you may also be asked to submit certain confidential information during the sign-up process or with your consent your provider may share with us, certain demographic and other information relevant to diagnosis and treatment, such as lifestyle and general medical history (e.g. conditions, allergies etc.). You may be able to send confidential messages and communicate with a provider regarding your treatment. FCHN will keep these messages private and confidential.
Information We Collect Automatically Through Your Use of our Site
Google Analytics
We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/).
We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity.
Information Collected Through Cookies and Similar Technologies
We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site again, the cookie allows the Site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends and providing relevant advertising to you. (See, “Advertising” below.)
No Information from Individuals Under the Age of 18
If you are under the age of 18, please do not attempt to register with us at this Site or provide any personal information about yourself to us. If we learn that we have collected personal information from someone under 18, we will promptly delete that information. If you believe we have collected personal information from someone under the age of 18, please Contact Us as described below.
3. HOW WE USE AND SHARE YOUR INFORMATION
To Provide Products, Services, and Information. We collect information from you and use the information to: provide products and services that you order using the Site;
Disclosure at Your Request
We may disclose information when requested by you. This disclosure at your request may require a written authorization from you.
For Health Care Operations. We may use and disclose medical information about you for health care operations. These uses and disclosures are necessary for FCHNs operations. For example, we may use medical information to review our services and to evaluate the performance of our staff in caring for you.
Sharing with Third Parties.
Healthcare Providers. We share your personal information with various healthcare affiliates, doctors and relevant medical staff in connection with your diagnosis and treatment.
Vendors and Services Providers. We may provide information to third-party vendors and service providers that help us operate and manage our Site, process orders, and fulfill and deliver products and services that you purchase or request from us. These vendors and service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.
Corporate Affiliates. We may share your personal information with our corporate affiliates which are subject to this policy and applicable law.
Social Media. If you use third-party services, such as Facebook, Google, or Twitter, through the Site, to login to the Site, or to share information about your experience on the Site with others, these third-party services may be able to collect information about you, including information about your activity on the Site, and they may notify your connections on the third-party services about your use of the Site, in accordance with their own privacy policies.
Public Posts and Activities. If you choose to engage in public activities on the Site, you should be aware that any information you share there can be read, collected, or used by other users of these areas. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in these public areas. Any user posting in these public areas understands and acknowledges that there is no expectation of privacy for the information in these public areas.
Your Consent. In addition to the sharing described elsewhere in this Policy, we will share personal information with companies, organizations or individuals outside of FCHN when we have your consent to do so.
Text Message Campaigns. Full Circle Health Network sends text messages to members identified by its contracted Health Plans, with the goal of educating members about the services we provide, and linking members to providers so that they may begin receiving services. Members can opt out of our text campaigns by replying STOP to the thread or emailing us.
Legal Proceedings. We will share personal information with third-party companies, organizations or individuals outside of FCHN if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy unless you agree differently.
4. ACCESS TO YOUR INFORMATION AND CHOICES
You can access and update certain information we have relating to your online account by signing into your account and going to the Account section of our Site. If you have questions about personal information we have about you or need to update your information, you can Contact Us as described below.
5. SECURITY OF YOUR INFORMATION
We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that emails and other communications you send to us through our Site are not encrypted, and we strongly advise you not to communicate any confidential information through these means.
6. CALIFORNIA PRIVACY RIGHTS
Under California’s "Shine the Light" law, California residents who provide personal information in obtaining products or services for personal, family or household use are entitled to request and obtain from us once (1) a calendar year information about the customer information we shared, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year (e.g. requests made in 2020 will receive information regarding 2019 sharing activities).
To obtain this information, please send an email message to info@fullcirclehn.org with "Request for California Privacy Information" on the subject line and in the body of your message. We will provide the requested information to you at your email address in response. Please be aware that not all information sharing is covered by the "Shine the Light" requirements and only information on covered sharing will be included in our response.
7. CONSENT TO PROCESSING OF PERSONAL DATA IN UNITED STATES
This Site is intended for use only by residents of the U.S. If you are a citizen of the European Economic Area (EEA) or other jurisdiction outside of the U.S., please note that in order to provide our Site, products and services to you, we may send and store your personal information (also commonly referred to as personal data) outside of the EEA, including to the United States. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. We are committed to protecting the privacy and confidentiality of personal information when it is transferred. Where such transfers occur, we take appropriate steps to provide the same level of protection for the processing carried out in any such countries as within the EEA to the extent feasible under applicable law. By using and accessing our Site, users who reside or are located in countries outside of the United States agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, and that the protection of such information may be different than required under the laws of their residence or location.
8. CHANGES TO OUR PRIVACY POLICY
Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your consent in accordance with applicable law. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.
9. QUESTIONS AND HOW TO CONTACT US
If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, please Contact Us by email, phone, or by US postal mail at the following address:
Full Circle Health Network
2201 K Street, Sacramento, CA 95816
Toll Free: 888-749-8877
Fax: 916-471-0458
Email: info@fullcirclehn.org
LinkedIn: Full Circle Health Network
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