HealthPointe Solutions Privacy Policy

Protecting the security and privacy of your personal data is important to HealthPointe Solutions and this policy summarizes what personal information we may collect, how we may use this information, and other important topics relating to your privacy and data protection.

It is our policy to comply with all applicable privacy and data protection laws and applies to all Internet sites and mobile applications operated by or on behalf of HealthPointe Solutions. It also applies to personal information HealthPointe Solutions may otherwise collect: (i) through our products and services; (ii) when you interact with us by means other than a HealthPointe Solutions Internet Site or Application; and (iii) from our customers, distributors, suppliers, vendors, and other business partners (collectively “Business Partners”).

Collection, Use and Disclosure of Personal Information Principles

To the extent required by applicable law, whenever HealthPointe Solutions collects personal information, we will:

provide timely and appropriate notice to you about our data practices;
collect your personal information only for specified and legitimate purposes. The information we collect will be relevant, adequate and not excessive for the purposes for which it is collected;
process your personal information in a manner consistent with the purposes for which it was originally collected or to which you have subsequently consented;
take commercially reasonable steps to ensure that your personal information is reliable for its intended use, accurate, complete, and, where necessary, kept up-to-date;
not use your personal information for direct marketing purposes without giving you an opportunity to “opt-out”; and
take appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within HealthPointe Solutions.

Personal Information Collection Practices

HealthPointe Solutions collects the following type of information:

Information You Provide. HealthPointe Solutions collects personal information you provide us, which may include: (i) contact information, such as your name, company name, job title, address, e-mail address, and phone number; (ii) additional information about you to help us get to know you better, such as your gender, age, date of birth, nationality, professional associations and registration numbers, information about how you use our products, and demographic information; (iii) comments, questions, requests and orders you may make; (iv) health information needed to provide personal health guidance such as subscriber information, medications, or provider engagement; (v) log-in information, including, if applicable, social media account information for login purposes; and (vi) information about your preferences, such as your preferred methods of communication and product types in which you are interested.
Information Automatically Gathered from Your Device. Device and browser information. HealthPointe Solutions may collect technical information about your device, such as device type, browser type, IP address, operating system, and device identifier. HealthPointe Solutions collects this information automatically from your device and web browser through cookies and similar technologies.Information about how you interact with us. HealthPointe Solutions may collect technical data about your usage of Internet Sites and Applications, such as content viewed or downloaded, features used, links clicked, and dates and times of interactions. HealthPointe Solutions collects this information using cookies and similar technologies.Location information. HealthPointe Solutions may collect location information, including precise real-time location information from your device and imprecise location information derived from, for example, your IP address or postal code. Applications will NOT access precise-real time location information from your device unless you grant permission to do so.
Cookies and Similar Technologies. Detailed information can be found in our Cookie Policy.
Do Not Track Browser Settings. Some browsers may transmit “Do Not Track” (“DNT”) signals to the websites you visit. Because there is not common agreement about how to interpret DNT signals, HealthPointe Solutions currently does not take action in response to them.
Information from Business Partners and other Third Parties. HealthPointe Solutions collects personal information through our Business Partners. This information may include identity, demographic, biometric, physiological, clinical and prescription, social, lifestyle, nutrition, personal preferences or communication. HealthPointe Solutions may also obtain personal information from other third-party sources, including publicly and commercially available sources. We may combine the information we receive from our Business Partners and other third-party sources with information that we collect from you or your device, as described above.

Personal Information Uses

HealthPointe Solutions may use your personal information to:

Develop and manage our relationships with you and our Business Partners. This may include: (i) delivering services or carrying out transactions that you or our Business Partners have requested; (ii) providing information about HealthPointe Solutions products or services that may be of interest to you; (iii) providing you and our Business Partners a more consistent experience in interacting with HealthPointe Solutions, including by learning more about you and how you use and interact with HealthPointe Solutions Internet Sites, Applications, products, and services; and (iv) planning, managing, and performing under our contractual relationships with our Business Partners.
Communicate with you. This may include: (i) informing you of HealthPointe Solutions products and services that may be of interest to you; (ii) providing information about relevant HealthPointe Solutions products and services including, health and wellness coaching, clinical recommendations, lifestyle management, or information about product or service improvements; (iii) responding to questions or inquiries that you make, including customer service requests; and (iv) inviting you to participate in, or informing you of the results of, customer satisfaction or market research surveys.
Provide and improve our Internet Sites, Applications, products, and services. This may include: (i) customizing them to your preferences or interests, making them more compatible with your technology, or otherwise making them easier to use; (ii) maintaining the security of and otherwise protecting them; and (iii) and developing new HealthPointe Solutions Internet Sites, Applications, products and services.
Address legal issues. This may include: (i) complying with our obligations to retain certain business records for minimum retention periods; (ii) establishing, exercising, or defending legal claims; (iii) complying with laws, regulations, court orders, or other legal process; (iv) detecting, preventing, and responding to fraud, intellectual property infringement, violation of our contracts or agreements, violations of law, or other misuse of HealthPointe Solutions Internet Sites, Applications, products or services; and (v) protecting HealthPointe Solutions’ rights or property, or yours or others’ health, safety, welfare, rights, or property. HealthPointe Solutions may also use your personal information for other uses consistent with the context in which the information was collected or with your consent. HealthPointe Solutions may anonymize or aggregate any of the information we collect and use it for any purpose, including for research and product-development purposes. Such information will not identify you individually.

Personal Information Sharing

HealthPointe Solutions will not disclose your personal information except as described here:

HealthPointe Solutions may share your personal information with other HealthPointe Solutions entities, including those in different countries. When we do so, these other HealthPointe Solutions entities will use your information in a manner consistent with this Policy, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.
HealthPointe Solutions may also share your personal information with third parties we hire to perform support services for us. These third parties are required to use the personal information we share with them only to perform services on our behalf and to treat your personal information in compliance with all applicable privacy and data protection laws.
In some cases, HealthPointe Solutions may share your personal information with third parties who partner with us to provide products and services to our customers. If so, we will require our Business Partners to use that information in a manner consistent with this Policy, any applicable Specific Privacy Statements, and all applicable privacy and data protection laws.
HealthPointe Solutions may share your personal information with third parties when we have a good faith belief that disclosure is necessary: (i) to comply with a law, regulation, court order, or other legal process; (ii) to detect, prevent, and respond to fraud, intellectual property infringement, violation of our contracts or agreements, violation of law, or other misuse of HealthPointe Solutions Internet Sites, Application, products or services; (iii) to protect HealthPointe Solutions rights or property or yours or others’ health, safety, welfare, rights, or property; or (iv) under similar circumstances. If such an event occurs, we will take appropriate steps to protect your personal information.
HealthPointe Solutions may share your personal information with third parties in connection with the sale, purchase, merger, reorganization, liquidation or dissolution of HealthPointe Solutions. If such an event occurs, we will take appropriate steps to protect your personal information.
HealthPointe Solutions may share your information with your permission or at your request.
HealthPointe Solutions may share anonymized or aggregated information internally and with third parties for any purpose. Such information will not identify you individually.

Personal Information Security.

Your personal information will generally be stored in data systems (database or storage) operated by HealthPointe Solutions or maintained by our service providers. Many of these databases are stored on servers located in the United States but personal information may be localized to a specific region or country. HealthPointe Solutions takes appropriate measures, by contract or otherwise, to provide adequate protection for personal information that is disclosed to a third party or transferred to another country, including transfers within HealthPointe Solutions.

HealthPointe Solutions maintains reasonable safeguards to protect the confidentiality, security and integrity of your personal information. Although we use security measures to help protect your personal information against unauthorized disclosure, misuse, or alteration, as is the case with all computer networks linked to the Internet, we cannot guarantee the security of information provided over the Internet and will not be responsible for breaches of security beyond our reasonable control.

Links to Third Party Internet Sites and Plugins

HealthPointe Solutions Internet Sites and Applications may contain links to websites or mobile apps that are not operated by HealthPointe Solutions and plugins from social media platforms and other third parties. An example of a social media plugin is the Facebook “Like” button. We provide these links and plugins as a service and do not imply any endorsement of the activities or content of the related websites, apps, or social media platforms, nor any association with their operators. To learn about the information collected by these third-party websites, apps, and plugins, please visit their privacy policies. We encourage you to review the privacy policies for the websites, apps, and social media platforms you visit before using them or providing personal information.

Access to Your Personal Information

You may review, correct and update personal information you provide to us by contact HealthPointe Solutions using one of the following methods:

Sending an e-mail to privacy@healthpointe-solutions.com with a general description of your concern and a method for contacting you.
Calling our customer service center at +1 800 601 7114 and speaking with one of our representatives.
Sending a request to our corporate office located at: HealthPointe Solutions, Suite 110, 317 Grace Lane, Austin, Texas 78746, United States

Retention of Your Personal Information

How long we keep your personal information will vary and will depend on the purpose and use of information collected. There are legal requirements that we keep some types of data for specific periods. Otherwise, we will retain it for no longer than is necessary for the purposes for which the data was collected.

Minors

Most HealthPointe Solutions Internet Sites and Applications are not intended for children under 13 years of age. HealthPointe Solutions will not knowingly solicit or collect personal information from or about children under 13, or the relevant minimum age under applicable local legal requirements, except as permitted under applicable law.

Rights of California Residents

If you are a verified California resident, you may have, pursuant to the CCPA, the following rights with respect to your personal information with HealthPointe Solutions, which apply differently in different circumstances: right to access, right to information, and the right to deletion. HealthPointe Solutions does not and will not sell personal information. Most of these rights are not absolute. Below we describe these rights in more detail and provide information on how you can exercise them. If you are a verified California consumer and make a request to exercise your rights, we will respond within 45 days, but we have the right to extend this period by 45 additional days where necessary. If we extend the response period, we will let you know within 45 days from your request.

You can exercise your rights by:

Sending an e-mail to privacy@healthpointe-solutions.com with a general description of your concern and a method for contacting you.
Calling our customer service center at +1 800 601 7114 and speaking with one of our representatives.
Sending a request to our corporate office located at: HealthPointe Solutions, Suite 110, 317 Grace Lane, Austin, Texas 78746, United States

Right to Access. You have a right to ask HealthPointe Solutions to provide the categories and specific pieces of personal information that we retain about you through your account with us or, at your option, by mail or in a readily usable electronic format. HealthPointe Solutions is obligated to respond to no more than two Right-to-Access requests in a 12-month period. The Right to Access does not apply to information collected by HealthPointe Solutions for a single transaction.

Right to Information. You have the right to ask HealthPointe Solutions to disclose to you: (i) the categories of personal information that HealthPointe Solutions has collected about you in the 12 months preceding the request and the specific pieces of that personal information, (ii) the categories of sources from which the personal information was collected (iii) the business purpose or commercial purpose for collecting or selling the personal information, (iv) the categories of third parties with whom or which the personal information is shared, (v) the categories of personal information that HealthPointe Solutions has sold about you and the categories of parties to whom or which HealthPointe Solutions sold each category of personal information, and (vi) the categories of personal information that HealthPointe Solutions has disclosed about you for a business purpose.

Right to Deletion. You have the right to ask HealthPointe Solutions to delete personal information it has collected about you. The Right to Deletion does not apply when HealthPointe Solutions needs the personal information: (i) to complete a transaction with you, provide a good or service requested by you, or otherwise perform a contract with you; (ii) to detect or prevent security incidents or illegal activity; (iii) to identify and correct errors that impair existing functionality; (iv) for the exercise of a legal right or to ensure another person can exercise his or her legal right; (v) to comply with the California Electronic Communications Privacy Act; (vi) to engage in public or peer-reviewed scientific, historical, or statistical research in the public interest if deletion of the personal information is likely to make the research impossible or seriously impair it; (vii) solely for internal uses that are reasonably aligned with expectations based on your relationship with HealthPointe Solutions; (viii) to comply with a legal obligation; or (ix) for lawful internal uses that are compatible with the context in which HealthPointe Solutions obtained the information.

Additional Information for EU Residents

Data controller and contact information. The controller for personal data collected under this Privacy Policy is the relevant HealthPointe Solutions entity in your country, and, as applicable; HealthPointe Solutions, Suite 110, 317 Grace Lane, Austin, Texas 78746, United States

HealthPointe Solution’s lawful basis for processing your personal data. The lawful basis for HealthPointe Solution’s processing of your personal data will depend on the purposes of the processing. For most personal data processing activities covered by this Privacy Policy, the lawful basis is that the processing is necessary for HealthPointe Solution’s legitimate business interests. Where we process personal data in relation to a contract, or a potential contract, with you, the lawful basis is that the processing is necessary for the performance of our contract with you or to take steps at your request prior to entering into a contract. When we are required to share personal data with law enforcement agencies or other governmental bodies, we do so on the basis that we are under a legal obligation to do so. We will also use consent as the legal basis where we deem appropriate or to the extent required by applicable law, for example, before we collect precise location data from your mobile device.

Processing on the basis of legitimate business interests. When we process personal information on the basis that the processing is necessary for our legitimate business interests, such interests include: providing or improving HealthPointe Solutions Internet Sites, Applications, products, and services; (ii) communicating with current and potential customers, other Business Partners, and their individual points of contact; (iii) managing our relationships with our customers and other Business Partners, and their individual points of contact; (iv) other business development purposes; (v) sharing information within the HealthPointe Solutions, as well as with service providers and other third parties; and (vi) maintaining the safety and security of our products, services and employees, including fraud protection.
Processing on the basis of performance of a contract. Examples of situations in which we process personal information as necessary for performance of a contract include evaluating and providing recommendations to improve the health and well-being for a population of individual for an employer or health care system, delivered through a HealthPointe Solutions Internet Site or Application.
Processing on the basis of consent. Examples of processing activities for which HealthPointe Solutions uses consent as its legal basis include: collecting and processing precise location information from your mobile device; (ii) sending emails when consent is required under applicable law; and (iii) processing personal data on HealthPointe Solutions Internet Sites or Applications through cookies and similar technologies when consent is required by applicable law.
Processing because HealthPointe Solutions is under a legal obligation to do so. Examples of situations in which HealthPointe Solutions must processes personal data to comply with its legal obligations include: payment of taxes and other government levies; (ii) providing your personal data to law enforcement agencies and other governmental bodies when required by applicable laws; (iii) retaining business records required to be retained by applicable laws; and (iv) complying with court orders or other legal process.

To determine the period for which your personal data will be retained in accordance with this Policy, HealthPointe Solutions considers criteria such as: (i) any applicable legal requirements to retain data for a certain period of time; (ii) any retention obligations related to actual or potential litigation or government investigations; (iii) any retention requirements in relevant agreements with our Business Partners; (iv) the date of your last interaction with HealthPointe Solutions (including with HealthPointe Solutions Internet Sites, Applications, communications, etc.); (v) the length of time between your interactions with HealthPointe Solutions; (vi) the sensitivity of the data; and (vii) the purposes for which the data was collected.

Your rights with respect to your personal data. In accordance with the applicable laws in the European Union, you have the following rights with respect to your personal data, which apply differently in different circumstances: right of access, right to rectification, right to erasure, right to restriction of processing, right to data portability and right to object to processing. Most of these rights are not absolute. Below we describe these rights in more detail and provide information on how you can exercise them. If you make a request to exercise your rights, we will respond within one month, but have the right to extend this period by two additional months, where necessary. If we extend the response period, we will let you know within one month from your request. You can exercise your rights by completing the Data Subject Request Form and sending it to us at privacy@healthpointe-solutions.com.

Right of Access. You have the right to ask Healthpointe Solutions to confirm whether we process your personal data. If we do, you have the right to request access to your personal data that we process and the following information: (i) the purposes of the processing; (ii) the categories of personal data we process; (iii) the recipients or categories of recipients of your personal data; (iv) the envisaged retention period of the data where possible, or the criteria we use to determine the retention period; (v) your right to request rectification or erasure of your personal data, or restriction of the processing of such data; (vi) your right to file a complaint with a supervisory authority; (vii) if we have not collected the data from you, any information we have available about the source of the data; and (viii) whether we use your personal data to make any automated decisions that have legal or other similar significant effects on you. Right to rectification.You have the right to have HealthPointe Solutions correct your personal data if they are inaccurate. Taking into account the purposes of the processing, you may also have the right to have incomplete personal data about you completed, including by providing a supplementary statement to HealthPointe Solutions.
Right to object to processing for HealthPointe Solution’s legitimate business interests.You have the right to object to HealthPointe Solutions processing your personal data when that data is processed on the basis of HealthPointe Solution’s legitimate business interests. HealthPointe Solutions will honor your objection and stop processing the relevant personal data unless: (i) we have compelling legitimate grounds for the processing that override your interests, rights, and freedoms; or (ii) we need to continue processing your personal data to establish, exercise, or defend a legal claim.
Right to object to processing for direct marketing. If HealthPointe Solutions processes your personal data for direct marketing purposes, you have the right to object to this processing. If you exercise this right, HealthPointe Solutions will stop processing your personal data for direct marketing purposes.
Right to restrict processing.You have the right to request that HealthPointe Solutions restrict the processing our your personal data in the following circumstances: (i) for the period of time HealthPointe Solutions needs to verify the accuracy of your personal data when you contest its accuracy; (ii) when the processing of your personal data is unlawful and you oppose the erasure of the data, and instead request that HealthPointe Solutions restrict the use of the data; (iii) when Healthpointe Solutions no longer needs your personal data for the purposes of processing, but you need the data to establish, exercise, or defend a legal claim; or (iv) for the period of time Healthpointe Solutions needs to verify if it has compelling legitimate grounds for processing that override your interests, rights, and freedoms when you object to the processing of your personal data for HealthPointe Solution’s legitimate business interests.

If following your request HealthPointe Solutions restricts the processing of your personal data, HealthPointe Solutions will store your data, and otherwise process it only with: your consent; (ii) to establish, exercise, or defend a legal claim; (iii) to protect the rights of another natural or legal person; or (iv) for reasons of important public interest of the European Union or a Member State. HealthPointe Solutions will also inform you before lifting the restriction of processing.
Right to erasure. The right to erasure is also called the “right to be forgotten.” You may ask HealthPointe Solutions to delete your personal data. This right not absolute. HealthPointe Solutions is required to delete your personal data upon your request only in the following circumstances: (i) your personal data is no longer necessary for the purposes for which HealthPointe Solutions collected or processed them; (ii) if HealthPointe Solutions processes your personal data on the basis of consent, you withdraw your consent, and no other legal ground exists for Healthpointe Solutions to continue processing your personal data; (iii) if HealthPointe Solutions processes your personal data for its legitimate business interests, you object to the processing, and there are no overriding legitimate grounds for HealthPointe Solutions to continue processing your personal data; (iv) if HealthPointe Solutions has processed your personal data unlawfully; or (v) the personal data must be erased to comply with a legal obligation under European Union or Member State law to which HealthPointe Solutions is subject.

Healthpointe Solutions is not required to erase your personal data to the extent that HealthPointe Solutions needs to process them to: (i) exercise its right of freedom of expression and information; (ii) comply with a legal obligation under European Union or Member State law to which HealthPointe Solutions is subject; or (iii) to establish, exercise, or defend a legal claim.
Right to data portability. You have the right to receive personal data you provided to HealthPointe Solutions when: (i) the processing of the data is based on your consent or is necessary for the performance of a contract between you and HealthPointe Solutions; (ii) HealthPointe Solution’s processing of your personal data is carried out by automated means; and (iii) complying with your request will not adversely affect the rights and freedoms of others.

If you have the right to receive such personal data and request that HealthPointe Solutions provide it, HealthPointe Solutions will provide it to you in a structured, commonly used, and machine-readable format.
Right to lodge a complaint with a supervisory authority. HealthPointe Solutions will use its best efforts to address and settle any requests or complaints brought to its attention. In addition, you have the right to approach the competent data protection authority with requests or complaints. This can be the supervisory authority in the country or federal state where you live.

The overall competent supervisory authority for HealthPointe Solutions in Europe is: Commission for the Protection of Privacy, Rue de la Presse 35, 1000 Brussels. Telephone: +32 (0)2 274 4800. E-mail: commission@privacycommission.be. Website: www.privacycommission.be

Privacy Policy Inquiries

If you have any questions about this Policy or a Specific Privacy Statement or our use of your personal information, please contact us by clicking or by writing to us at:

Sending an e-mail to privacy@healthpointe-solutions.com with a general description of your concern and a method for contacting you.
Sending a request to our corporate office located at: HealthPointe Solutions, Suite 110, 317 Grace Lane, Austin, Texas 78746, United States

Policy and Privacy Statements Changes

Changes to this Privacy Policy will be posted on this site, along with information on any material changes. HealthPointe Solutions reserves the right to update or modify this Policy and any Specific Privacy Statements at any time and without prior notice. Any modifications will apply only to the personal information we collect after the posting.

This Policy was last revised in February 2020.