Passel Privacy Policy

Last Updated: August 28, 2020

Passel LLC (“Passel”, “we” or “us”)enables healthcare professionals (“Treatment Providers”) to see and treat their patients (“Patients”) via video. This Privacy Policy applies to information we collect about you, including when you use our websites and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us. This Privacy Policy does not apply to aggregated or de-identified information that cannot reasonably be used to identify you.

This Privacy Policy does not apply to the storage, use, and collection of protected health information (“PHI”), which is governed by the Health Insurance Portability and Accountability Act (“HIPAA”) and therefore is covered by our Notice of HIPAA Privacy Practices (the “HIPAA Policy”). Any conflict between this Privacy Policy and the HIPAA Policy with respect to such PHI shall be resolved in favor of the HIPAA Policy. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service. Therefore, please make sure that you have read and understand our Terms of Service.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

Collection of Information

Use of Information

Sharing of Information

Transfer of Information to the United States and Other Countries

Your Choices

Your California Privacy Rights

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when you create an account, fill out a form, conduct meetings (“Meetings”), submit or post content through our Services, make a purchase, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, email address, country, profession, telephone number, payment information, and any other information you choose to provide.

The types of information we may collect include:

Basic user information:If you are a Patient, we will collect your name and may ask for your email address and contact information. If you are a Treatment Provider, we collect information necessary to create your account and provide you the Services such as your name, title, email address, postal address, phone number, profession, profile photo, username and password.
Financial information: We collect financial information to process your transactions through the Services such as your credit card information (although note that we do not store full credit card numbers as all payment transactions are processed by our third-party payment processors).
Meeting Data: We collect information about Meetings conducted through the Services. For example, Treatment Providers can take notes about Meetings and Patients can chat with Treatment Providers through the Services and Providers can send lab results and prescriptions to pharmacies and labs.
Background Check and License Information: While we are not required to, we may choose to verify any licensing or credentialing information you provide to us. We may request your name and National Provider Identifier (NPI). This information may be collected by a third-party vendor on our behalf.
Information You Provide to Us: We collect information that you provide to us about yourself and about others such as (a) if you are a Patient, emergency contact information including your emergency contact’s name, phone number, and relationship to you, (b) healthcare information that you choose to provide to us, such as medical history and symptoms, (c) if you are a Treatment Provider, information about other Treatment Providers, (d) any feedback or suggestions you provide to us about our Services, and (e) any other information you choose to provide to us in accordance with our Terms of Service, including any information you send, transmit, post, display, or upload in meeting session notes or through the chat function.

Other Information We Collect When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect information about your activities, including:

Activity Information: We collect information about your activity on our Services, such as the date and time you use our Services, number of times you use our Services, and Meeting recordings. If you are a Patient, we may collect information about you from your Treatment Provider and if you are a Treatment Provider, we may collect information about you from your Patients.
Transactional Information: When you conduct a transaction through the Services such as hosting or participating in a Meeting or paying for a Meeting, we collect information about the transaction, such as the amount paid or received and the date and time of the transaction.
Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, webpages viewed, links clicked, and the page you visited before navigating to our Services.
Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) may use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Collect from Other Sources

We may also obtain information about you from other sources. For example, we may collect information about you from Internet service providers, government entities, operating systems and platforms, social networks, customer feedback, business partners through which customers access our Services, insurance providers, and marketing service providers. Additionally, if you create or log into your Passel account through a third-party platform or social network, we will have access to certain information from that site, such as your name, birthday and profile picture, in accordance with the authorization procedures determined by such third-party platform.

Information We Derive

We may derive information or draw inferences about you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address.

USE OF INFORMATION

We use the information we collect to administer your account. We also use the information we collect to:

Provide, maintain, and improve our Services;
Process transactions and send you related information, including confirmations and customer experience surveys;
Send you technical notices, security alerts, and support and administrative messages and to respond to your comments, questions, and to provide you customer service;
Communicate with you about products, services, and events offered by Passel and others, and provide news and information we think will interest you (see Your Choices below for information about how to opt out of these communications at any time);
Monitor and analyze trends, usage, and activities in connection with our Services;

Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of Passel and others;
Debug to identify and repair errors in our Services;
Comply with our legal and financial obligations, including as required in accordance with HIPAA or related applicable local, state, or federal laws (please refer to the HIPAA Policy); and
Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

With vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, fraud prevention, customer service, payment processing, filling prescriptions, analyzing lab results, and marketing and advertising;
Publicly on our Services if you submit a product review or post content in another public area of our Services, like our virtual waiting rooms;

With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;
In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company;
[Between and among Passel and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership]; and
With your consent or at your direction.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Passel is headquartered in the United States and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR CHOICES

Account Information

You may update and correct certain account information you provide to us at any time by logging into your account or emailing us at support@getpassel.com. If you wish to deactivate your account, please email us at support@getpassel.com, but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you.

Cookies

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 removing or rejecting cookies could affect the availability and functionality of some of our Services. For more information about cookies and how to disable them, see the Your Choices section below.

Promotional Communications

You may opt out of receiving promotional emails or text messages from Passel by following the instructions in those communications or by managing your communication preferences in your account settings menu. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or “CCPA” (California Civil Code Section 1798.100 et seq.) [and the Shine the Light law (Cal. Civ. Code § 1798.83)] affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.

California Consumer Privacy Act

In the preceding 12 months, we have collected the following categories of personal information: identifiers, internet or other electronic network activity information (including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement), audio, electronic, visual, or similar information, commercial information, and professional or employment-related information. For examples of the precise data points we collect and the categories of sources of such collection, please see Collection of Information above. We collect personal information for the business and commercial purposes described in Use of Information above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients: service providers, data analytics providers, operating systems and platforms, and government entities (where required by law).

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at legal@getpassel.com or write to us at: Passel LLC located at 205 East 42^nd Street, 15^th Floor, New York, NY 10017.