CHOOSE HEALTH
PRIVACY AND COOKIE POLICY
Last Updated: January 25, 2024
At Choose Health we take our responsibility for protecting your privacy seriously. This policy describes what information we collect and use when you use our website, ChooseHealth.io (our “Website”), Mobile Application, and Choose Health Products and Services (collectively, “Choose Health Services”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.
1. Information We Collect
The information we collect depends on what features of our Website, Mobile Application, or Choose Health Services you use and how you use them. We collect some information from you when you provide it to us directly or to our Accredited Laboratories and other service providers, including personal information—that is, information that can be used to uniquely identify or contact you, such as your name, address, phone number, e-mail address, response to specific questions, and certain health information.
We only offer our Choose Health Services to users who are 18 years of age or older. We do not collect or maintain information from people we actually know are under 18 years old. If we obtain actual knowledge that a user is under 18 years old, we will use our best efforts to remove that person’s information from our database. If you are not 18 years of age or older, you must not access or use our Website, Mobile Application or Choose Health Services. We do not knowingly disclose personal information about children under 18 years of age to independent third parties even with consent.
A. Information You Give Us Directly
We collect information you provide us, including:
Email address, shipping address, and telephone number; Registration information, including account name and password; Security questions and answers; Details you provide in response to surveys about our Choose Health Services; Information you provide when seeking help from us such as your name, telephone number and records of the issues you experience; Billing information, such as your name, payment card number and payment account details; and Certain health information, defined as “Protected Health Information”.
In addition, we may offer community features on our Website or Mobile Application. For example, you may have the opportunity to review our Services or share your experiences with other community member in our blogs or similar forums. If you participate in these or similar features, the information that you disclose may become publicly available and can be read, copied, collected or used by other users.
B. Other Information We Collect When You Use Our Website
We collect other information automatically when you use our Website or Mobile Application, including:
IP address;Mobile and other hardware or device identifiers;Browser information, including your browser type and the language you prefer;Referring and exit pages, including landing pages and pages viewed;Details about what Choose Health Services you browse and purchase as well as details about what Website features you utilize;
C. Cookies and Similar Technologies
Interest-based advertising. We engage advertising companies and social media companies that use cookies and similar technologies to collect information about your interactions over time across the Service and other websites, and use that information to serve online ads that they think will interest you. These include, but are not limited to:
Meta Platforms. We use Meta Platforms (including,Facebook and Instagram) (collectively, “Meta”), a web analytics and advertising service provided by Meta, on our website. The data from Meta is also saved and processed by Meta. Meta may connect this data with your Facebook or Instagram account and use it for its own and others advertising purposes, in accordance with Meta’s Data Policy which can be found at https://www.facebook.com/about/privacy/. You can control the information disclosed through your Meta accounts by visiting https://www.facebook.com/about/ads.·
Google Analytics and Google Ads. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our website. We also use Google Ads, an internet-based advertising service, to advertise our services and analyze the performance of our advertising campaigns. You can find out more about how Google uses data by visiting “How Google Uses Data When You Use Our Partners’ Site or Apps” located at
www.google.com/policies/privacy/partners/. For information on Google Analytics, please visit www.google.com/analytics/learn/privacy.html. You can control information disclosed via Google Ads by visiting http://www.google.com/settings/ads and also by installing Google Ads Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout. ·
Microsoft Bing Ads. We use Bing Ads, an internet-based advertising service, to advertise our services and analyze the performance of our advertising campaigns. You can find out more about how Bing uses data by visiting the“Microsoft Privacy Statement” located at https://privacy.microsoft.com/en-us/privacystatement.You can control information disclosed via Bing Ads and opt out of personalized Bing advertising by visiting https://account.microsoft.com/privacy/ad-settings.
Cookies are small text files stored on your Internet browser. We use cookies and similar technologies to help us understand things like what web pages, features or ads you view and what Choose Health Services you order. This information helps us keep track of your orders, measure the effectiveness of our advertising, make sure you don't see the same ad repeatedly and otherwise help enhance your user experience.
You can disable cookies, limit the types of cookies you allow, or set your browser to alert you when cookies are being sent. Please refer to guidance provided by your individual web browser if you'd like help in managing your cookie preferences.
D. Information Provided To Us By Third Parties
When you use third party services in connection with our Website or Mobile Application, like social platforms, we may receive information from these third parties.
We also may receive information from third parties to supplement the information we receive from you. We use information from these companies primarily to help us deliver relevant advertising to you. We also may use information from third parties, for instance, to help us understand your approximate geolocation via your IP address for tax purposes, or to customize certain services to your location, and for fraud and/or abuse prevention purposes.
We may also receive information about you when other Choose Health consumers choose to refer a friend or contact with us.
2. How We Use Your Information
We use your personal and non-personal information, both individually and combined together, in the following ways:
To operate our business and to enhance and personalize your experience including to:
Operate, protect, improve, personalize, customize, and develop our Choose Health Services, Website, and Mobile Application;Provide you with the information and Choose Health Services that you request from us;Maintain your account, payment information, your secure health portal, and to provide notices about your account and portal, including expiration and renewal notices;Bill you for the Choose Health Services you purchase from us;Enable you to refer Choose Health Services;Facilitate communication and sharing on our Website and Mobile Application;Serve and measure the effectiveness of advertising;Set up and maintain the contact and shipping information you provide us;Set up loyalty, discount and rebate programs;Identify, fix, and troubleshoot bugs and service errors;Adhere to your preferences and to deliver dynamic content;Resolve disputes, investigate and help curb fraud, spam, abuse, security incidents, illegal behavior, and other harmful activity; andComply with the law, and to enforce our agreements and policies, including our Terms of Service and this Privacy and Cookie Policy.
To provide you support, including to:
Help identify and troubleshoot problems with your order or use of our Website or Mobile Application;Survey your opinions through surveys or questionnaires;Communicate with you and respond to your specific requests or questions; andManage and send you confirmations and important information about your account, portal, orders, purchases, returns or cancellations, rewards, and Choose Health Services.
To personalize our communications with you, including to:
Present offers and/or information relating to Choose Health Services you might like; Make recommendations to you; and Personalize advertising for you and deliver targeted marketing, service updates and promotional offers.
3. Legal Basis for Processing
We rely on a number of legal grounds to process information about you. For example, we will process information about you where we have your consent, where we have a legitimate interest to do so, where the processing is necessary for the performance of a contract with you, and where we have a legal obligation to process your information. For example, we rely on our legitimate interests to serve targeted marketing and on contractual necessity to process information when you order an Choose Health Service on our Website or Mobile Application. To learn more about the legal grounds on which we rely to process your information for any particular purpose, please contact us via the options in Section 12 below.
4. Information We Share with Third Parties
With your Consent: For starters, we never sell your personal information or protected health information. Where you have instructed us and have provided consent, we share your information, including personal information, as described at the time of consent, such as when you authorize a third party application or website to access your order information or when you participate in promotional activities conducted by Choose Health or its partners.
Service Providers: We employ third parties, such as payment processors, Accredited Labs, and physician networks, located in and outside of your country of residence (including outside of the European Economic Area (EEA) to collect or process personal information on our behalf for various reasons, such as providing our services, operating our Website and Mobile Application, conducting market surveys, facilitating credit card processing, or sending emails. When our third party agents or service providers collect or receive personal information, we require that they use the data only on our behalf and for purposes consistent with this policy.
Compliance, Preventing Harm, and Protecting Our Rights: We do not share personal information that directly identifies you (such as your name, e-mail or postal address) with third parties for their own use without your consent, unless it is either required by law or we determine that disclosure is reasonably necessary to enforce our rights, comply with our legal obligations, or to protect our consumers or third parties.
Merger or Acquisition: In the event of a reorganization, divestiture, merger, sale or bankruptcy, we may transfer all information we collect to the relevant third party and will obtain your consent to do so if required by law.
Third Party Integration: When third party technologies or social tools are integrated into our Choose Health Services, those third parties may collect information when you use our Services. In addition, we may pass aggregate information on the usage of our Site to third parties, but this will not include information that can be used to identify you.
Aggregate Data: We may also share anonymous or aggregated information (information about our users that we combine together so that it no longer identifies or references an individual user) and other anonymized information for regulatory compliance, industry and market analysis, demographic profiling, marketing and advertising, and other business purposes.
5. Operating Globally
Personal information we collect may be stored and processed for the purposes set out in this Privacy and Cookie Policy in the United States or any other country in which Choose Health, its subsidiaries, or third party agents operate. In all cases, we will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this privacy policy by imposing on any such supplier obligations of security and confidentiality. By using our Website, Mobile Application, or Choose Health Service you agree to this transfer, storing or processing.
6. Security
The security of your information is a priority at Choose Health, and we take a range of measures to help protect it, including encryption of sensitive financial information and health information. The User Information made available through the services may be subject to protection under applicable privacy and security laws, including the Health Insurance Portability and Accountability Act ("HIPAA"), and in such instances shall be maintained, used and disclosed in accordance with such applicable laws to the extent required. If you authorize disclosure of your information by Choose Health to other third parties, different privacy and security standards may apply to the third party and their use and disclosure in that context Choose Health does not guarantee that its security measures or those of any third parties will not be circumvented or breached or that your User Information will not be accessed by a third party that is not authorized by Choose Health. Choose Health is not responsible, and assumes no liability, for any direct or indirect damages as a result of such circumvention or breach by any third party.
7. Your Choices and Controls
We give you meaningful choices when it comes to important uses and collection of information. For example, you can update your order information and preferences, choose to opt in or out of Choose Health marketing emails and choose whether to share your information with select Choose Health partners.
If you would like to opt out at any time after providing your consent, contact hello@choosehealth.io.
Note that Choose Health may retain information needed to complete our contractual obligations to you, resolve disputes, enforce our user agreements, protect our legal rights, and comply with technical and legal requirements and constraints related to the security, integrity and operation of our Website, Mobile Application or Choose Health Services. Otherwise, we will retain your personal information for as long as reasonably necessary to provide you services, create and improve our Choose Health Services, comply with the law, and to run our business.
You can access the personal information we hold about you. To request access, please contact hello@choosehealth.io. Before we process any request, we may ask you for certain personal information in order to verify your identity and protect your privacy.
You may adjust your browser settings to block certain online tracking, such as cookies, as further described in Section 1.
8. Third Party Services
Our Website may include advertising or third party services. If you click on those links, including an advertisement, you will leave the Choose Health Website and go to the site you selected. If you visit a third party website or use a third party service, you should consult that site's or service's privacy policy.
We do not control information sent from your browser to third parties, such as advertising networks and analytics companies that receive information in the normal course of your Internet activity.
You have both the right and choice to tell us to share health information with your family, health care providers, or others involved in your care.
Your ChoicesYou have both the right and choice to tell us to share health information with your family, health care providers, or others involved in your care.
Our Uses and DisclosuresFor starters, we never sell your health information.
We typically use or share your health information in the following ways:
Provide our ServicesWe can use or disclose your health information for providing our Choose Health Services. These uses and disclosures are necessary, for example, to obtain your laboratory test results, evaluate the quality of our laboratory testing partners, accuracy of results, accreditation functions and for Choose Health’s operation and management purposes. To do so, Choose Health will disclose your health information to its service providers. For example, Choose Health partners with specific labs to run the laboratory tests you request and obtain the results of those laboratory tests. All such service providers are required to maintain the privacy and confidentiality of your health information. Upon your request, Choose Health may disclose your health information to your health care providers or health insurance providers. For example, Choose Health may provide your health information to coordinate health care or health care benefits.
9. Artificial Intelligence-Enabled Tools
Choose Health’s website, mobile app, and services may feature tools enabled by artificial intelligence (“AI”) that are designed to enhance and support users’ experiences (“AI Tools”). Their function is limited to providing general information and assistance based on available data, and they do not provide medical advice. Use of these AI Tools is governed by Choose Health’s Terms of Service.AI Tools:
Choose Health’s Site, App, and Services may provide the following AI Tools:
Tools: Choose Health may provide the following AI Tools on the Site, App, and/or Services:
Intercom Fin AI-Powered Chatbot: This is a natural language chatbot on our website that is used to address customer support inquiries.
Health Buddy: This is a set of features in the webapp that provides suggestions and information to aid users on the health journey.
OpenAI: This is integrated into our Health Buddy tool to provide guidance and motivation on supporting users on their journey to better health.
Data sharing and protection: Information provided by you while interacting with the AI Tools is retained by Choose Health to analyze and improve the Services, and may be used to shape the tool's future output calculation (also known as “fine-tuning”). Information that you provide while interacting with the AI Tools may be transmitted to third-party APIs for the purpose of AI-enabled response generation in order to process user inquiries.
Data shared with third-party APIs is governed by data sharing and privacy agreements with the recipients, including:
Intercom Fin AI-Powered Chatbot: Intercom’s
Data Processing Addendum Health Buddy: OpenAI’s
Data Processing Addendum and
enterprise privacy commitments; DeepGram’s Data Processing Agreement (not publicly available)Consent and opt-out: Interacting with our AI-enabled tools implies that you consent to this use and sharing of your data. If you prefer not to share your information with third-party APIs for the purpose of AI-enabled response generation, please use alternative communication methods and tools available on our site and within our mobile app. Please contact hello@choosehealth.iofor more information.Policy updates
: We reserve the right to modify these practices, and will update this Policy accordingly.
11. Changes to our Policy
We may update this policy from time to time, so please review it frequently. We'll notify you of material changes via a notice on our home page (www.ChooseHealth.io) thirty days before they go into effect. If we are required by applicable data protection laws to give you enhanced notice or seek your consent to any such changes, we will do so. You can see when this policy was last updated by checking the "last updated" date displayed at the top of this policy.
12. Contacting Us
If you have a complaint or question about this policy, please send an email to hello@choosehealth.io. The controller of the personal information processed under this policy is Choose Health Services, LLC., hello@choosehealth.io.
