Pack Health, LLC Privacy Notice
Last Revised: September 29, 2021
Welcome to Pack Health! The staging.packhealth.com website (the “Website”) and the Pack Health mobile platforms (“Platforms”) are provided by Pack Health, LLC (“Pack Health,” “we,” “us,” or “our”), for your use in conjunction with the Pack Health program (the “Program”) and the Program toolkit (“Pack”). Collectively, our Website, Platforms, Program, and Pack constitute our “Services.”
The Website is also provided for general information purposes. Your access to and use of the Website is provided subject to our Website Terms and Conditions of Use (the “Terms”), available here.
This Privacy Notice explains the information that we collect about you and your health, the ways that we may use and share your information, and the steps we take to protect your privacy. We treat your “Protected Health Information” (as defined in the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations, as amended and supplemented from time to time (“HIPAA”)) in accordance with the requirements of HIPAA. This Privacy Notice applies only to the Services provided by Pack Health.
By submitting your information to us or using our Services, you consent to the terms of this Privacy Notice. If you do not agree to the terms of this Privacy Notice or the treatment of your information as outlined in this Privacy Notice, do not submit any information to us or use our Services
PERSONAL INFORMATION
In this Privacy Notice we use the term “Personal Information” to mean any information about you that would allow a third party to determine your individual identity.
COLLECTION OF INFORMATION
When you contact us through our Website (including to schedule a demo), we ask for your name, email address, phone number, and information related to how we can help you so that we can respond to your inquiry. We also may ask you to provide us with your name, email address, website, and comments when you submit a blog post. Any comment you post on our blog will be publicly available and your post will include your name.
When you connect with us (including to receive news, research, and insights via email), we may collect your name, email address, industry, and information related to anything you would like us to know.
When you provide member feedback, we may collect information related to your feedback or complaint and your relationship to Pack Health.
When you view a sample program or ask Pack Health a question through the Website, we may collect your email address and the contents of your message.
To order your Pack and activate your Program, you, your physician, or one of our third-party partners provide us with your name, mailing address, email address, phone number, contract number, and the condition for which we will be providing you with our Services. For some Programs, we will also ask you for your birth date and gender so that we can attempt to provide you with the best recommendations. You may need to provide additional types of demographic information if you respond to a survey, test a particular product or service for us, or enter a contest or promotional event. If you do not provide us with the information we request, we may not be able to provide you with some or all Services.
Other health condition management programs (e.g., diabetes, hypertension, etc.) may view, access, or contribute condition-related information to your account if you grant them permission to do so. Devices, such as scales, blood pressure cuffs, glucometers, etc. may contribute health, motion, and fitness data to your account directly through a manufacturer’s website if you grant them permission to do so. Subject to your prior approval, our business partners may share information connected with your use of their services with us.
When you interact with the Platforms, we may collect your email address, telephone number, password, contact preferences, responses to surveys, and information submitted through your day tracker (including information related to meals, glasses of water, hours of sleep, and exercise).
We may also collect information from payers and health insurance companies for the purposes of determining eligibility for enrollment and participation in the coaching program and eligibility for reimbursement, including name, address, date of birth, and contract number along with a BCBSAL unique identifier.
Pack Health automatically collects certain technical information when you use our Website or Platforms such as your IP address, device identifier, your browser type, which websites you were visiting before coming to our Website, which pages of our Website you visit, and how long you visit each page.
The information we collect automatically may include personal information. It helps us to improve our Services and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our content according to your individual interests.
- Speed up your searches.
- Recognize you when you return to the Services.
The technologies we use for this automatic data collection may include cookies, web beacons, and other tracking technologies.
COOKIES AND OTHER TRACKING TECHNOLOGIES
The Pack Health Website uses “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you.
You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Pack Health Services or Website you visit. The Website does not respond to “Do Not Track” signals.
Web Beacons. Pages of the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Pack Health, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES
Some content or applications on the Website are served by third-parties, including content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
USE OF INFORMATION
We use your Personal Information to determine your eligibility for Services, to provide the Services you have activated, to tailor our Services to you, and to understand how our users utilize our Services and make improvements to our Services. Those Services may include sending texts, emails, or regular mail, or making phone calls to you to provide reminders, educational or technical information, or respond to your questions. We may also use those methods to send you technical updates or notices regarding our Services or to improve our customer service. We may also use your information to (i) investigate, prevent or take action regarding illegal activities, (ii) comply with applicable laws, regulations and legal process, (iii) enforce our Terms, and (iii) protect our rights, the rights of our customers, employees, affiliates, or related third parties, or to take appropriate legal action to enforce our rights.
Pack Health may use your Personal Information to conduct research and facilitate our marketing efforts (including informing you of other products or services available from Pack Health or our affiliates or business partners and in accordance with applicable law). Pack Health may also use your information to process applications for employment, and contact you via surveys to conduct research about your opinion of current Services or of potential new Services that may be offered.
Pack Health may compile your Personal Information in aggregate form so that it becomes anonymized or de-identified and is no longer able to be tied to you, individually. We use aggregated data to help diagnose problems with our servers and systems and to gather broad demographic information, to market our Services, to analyze and improve our Services, and to help us develop new products and services.
We contract with a third party for the retail/e-commerce portion of our Services, and any information you provide directly to that third party will be treated in accordance with the privacy policies of that provider.
CONSENT TO USE OF INFORMATION
By providing us with certain information on or through the Website or other means or by using our Services, you consent to the following uses of such information:
| Information Provided | You expressly consent to: |
| Email Address | Receiving emails from us, our affiliates or agents related to medical services in general, information you have requested, related services, information updates, and similar information |
| Phone Number
(landline) |
Receiving calls from us, our affiliates or agents, through human-initiated calls or automated calls, including the use of artificial or pre-recorded messages |
| Phone Number
(mobile number) |
Receiving calls from us, our affiliates or agents, through human-initiated calls or automated calls, including the use of artificial or pre-recorded messages
Receiving text messages (for which normal text or data charges may apply) |
By providing us with your email address and phone number(s) when activating our Services, you represent that you have the authority to use and provide consent for us to contact that email address and/or phone number(s) for the purpose of providing Services to you.
SHARING OF YOUR INFORMATION
Pack Health may share your Personal Information: (i) with third party business partners and service providers to assist in the administration of our Website or the Services (including app store platforms, data analytics providers, marketing platforms, payment processors (Stripe processes transactions (including payment transactions) for us and may receive personal data from you), recruiting platforms, social networks (including Facebook, LinkedIn, and Twitter), technology providers, and video sharing platforms (including YouTube); (ii) with Pack Health legal advisors; (iii) with others as required by law; (iv) to comply with any court order, law, or legal process, including to respond to any government or regulatory request; (v) with our affiliates or subsidiaries; (vi) to enforce or apply our Terms of Use; (vii) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Pack Health, our customers, or others; and (viii) for other purposes with your consent. Where you have given us permission to do so, we may share your information with the physician(s) or caregiver(s), including, without limitation, those who prescribed or otherwise referred our Services to you, or with your insurance carrier. If you are under the age of majority in your jurisdiction, we may share health information with your parent/guardian, unless applicable law provides you with an opportunity to opt out of such sharing and you choose to opt out of such sharing by emailing privacy@packhealth.com.. When we share Personal Information with our service providers, we require them to comply with our privacy practices. Notwithstanding any other provision in this Privacy Notice, in the event someone buys or acquires Pack Health or substantially all of its assets, information about you and your use of the Services may be one of the assets acquired and such information will be disclosed to the purchaser.
SECURITY OF YOUR INFORMATION AND RETENTION
Pack Health uses commercially reasonable measures to secure your personal information from unauthorized access, use or disclosure. Nevertheless, no amount of security safeguard is guaranteed to be impenetrable, and we cannot guarantee the security of your data.
Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.
We retain your information for as long as needed: (i) to conduct business with you; (ii) as needed for the purposes outlined in this Privacy Policy; and (iii) as necessary to comply with our legal obligations, resolve disputes, and enforce any agreements.
CHANGES TO THIS PRIVACY NOTICE
Pack Health may occasionally update this Notice from time to time. The date this Privacy Notice was last updated will be reflected at the top of the Privacy Notice. Pack Health encourages you to review this Privacy Notice periodically so that you are informed of how Pack Health is protecting your information. Where changes to this Privacy Notice are material, we will alert you in compliance with applicable law. Use of our Services or the Website following a change in the Privacy Notice indicates your consent to the revised Privacy Notice.
THIRD-PARTY LINKS
The Pack Health Website may contain links to other websites (“Linked Sites”). The Linked Sites are not under the control of Pack Health and Pack Health is not responsible for the privacy practices or contents of any Linked Site, including without limitation any link contained in a Linked Site, or any changes or updates to a Linked Site. Pack Health is providing these links to you only as a convenience, and the inclusion of any link does not imply endorsement by Pack Health of the Linked Site or any association with its operators.
CHILDREN AND PRIVACY
We do not knowingly collect Personal Information from children under the age of thirteen (13) without parental consent. If you are a child under 13 years of age, you are not permitted to use our Services without your parent’s prior written consent and should not send any information about yourself to us.
In the event that we become aware that we have collected Personal Information from any child, we will dispose of that information. If you are a parent or guardian and you believe that your child under the age of 13 has provided us with information without your consent, please contact us using one of the methods set forth the end of this Privacy Notice, and we will take reasonable steps to ensure that such information is deleted from our files.
CALIFORNIA PRIVACY RIGHTS
Under California Civil Code Section 1798.83, California customers are entitled to request information relating to whether a business has disclosed personal information to any third parties for their direct marketing purposes. Pack Health will not sell your personal information to third parties for their direct marketing purposes without your consent and will only transfer or share your Personal Information as stated in this Privacy Notice. California customers who wish to request further information about our compliance with this statute or who have questions more generally about our Privacy Notice and our privacy commitments to our customers should not hesitate to contact us, as provided below.
For information about California resident privacy rights, including the rights of California residents under the California Consumer Privacy Act, click here.
YOUR CHOICES AND OUR CONTACT INFORMATION
We strive to provide you with choices regarding the Personal Information you provide to us. The following mechanisms provide you with control over your information:
- Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Website may then be inaccessible or not function properly.
Google Analytics collects personal data through the Website, including through the use of cookies. For information about how Google Analytics collects and processes data, please visit: https://policies.google.com/technologies/partner-sites. To opt out of having your information used by Google Analytics, please visit: https://tools.google.com/dlpage/gaoptout/. For more information, please visit Google’s privacy policy at: https://policies.google.com/privacy?hl=en&fg=1.
- Communications from Pack Health. We provide you with the opportunity to opt out of receiving any future communications from us and our business partners at any time (provided that you cannot opt out of receiving communications directly related to your account with us, but you may have the right to specify the method of such communications). If you want to remove your Personal Information from our database and not receive future communications or Services or if you want to change or update your Personal Information, please contact:
Colin Durham
Privacy Officer, Pack Health
privacy@packhealth.com
1-855-255-2362
By U.S. Mail:
Pack Health, LLC
c/o Colin Durham, Privacy Officer
110 12th Street North
Birmingham, AL 35203
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: enrollment@packhealth.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
CALIFORNIA CONSUMER PRIVACY ACT
The following disclosures are made pursuant to the California Consumer Privacy Act of 2018 (“CCPA”). These disclosures supplement any privacy notices we previously or contemporaneously provided to you. The below charts reflect the categories of personal information we have collected from California consumers over the past twelve months, the categories of sources from which the information was collected, the business purpose for which the information was collected, and the categories of third parties with whom we shared that information.
| Categories of Personal Information Collected | Sources of Collection | Business Purpose for Collection | Categories of Third Parties Receiving Personal Information |
| Personal identifiers, including your name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, telephone number, education, employment, employment history, physical characteristics or description, insurance policy number, bank account number, credit card number, debit card number, or any other financial information, medical information, health insurance information, or other similar identifiers. | You; Data analytics providers; Devices you use to access our Services ; Health Insurance Companies; Marketing platforms; Payers; Physicians; Technology providers; Third-party partners. | Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging to identify and repair errors that impair existing intended functionality; Providing you with our products and services and responding to your questions; Providing advertising or marketing services; Providing analytic services; Undertaking internal research for technological development and demonstration; Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Pack Health, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Pack Health; Collecting and processing applications for employment; Processing payments. | Affiliates; App store platforms; Caregivers; Data analytics providers; Insurance Carriers; Marketing platforms; Parents/Guardians; Payment processors; Physicians; Recruitment platforms; Social networks; Technology providers; Video sharing platforms. |
| Characteristics of protected classifications under California or federal law. | You; Data analytics providers; Devices you use to access our Services ; Health Insurance Companies; Marketing platforms; Payers; Physicians; Technology providers; Third-party partners. | Providing you with our products and services and responding to your questions; Providing advertising or marketing services; Providing analytic services; Undertaking internal research for technological development and demonstration; Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Pack Health, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Pack Health; Collecting and processing applications for employment. | Affiliates; App store platforms; Caregivers; Data analytics providers; Marketing platforms; Parents/guardians; Physicians; Recruitment platforms. Social networks; Technology providers; Video sharing platforms. |
| Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | You; Data analytics providers; Devices you use to access our Services; Health Insurance Companies; Marketing platforms; Payers. | Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Providing you with our products and services and responding to your questions; Providing advertising or marketing services; Providing analytic services; Undertaking internal research for technological development and demonstration; Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Pack Health, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Pack Health; Processing payments. | Affiliates; App store platforms; Data analytics providers; Insurance Carriers; Marketing platforms; Payment processors; Social networks; Technology providers; Video sharing platforms. |
| Biometric information. | You; Devices you use to access our Services; Technology providers. | Providing you with our products and services and responding to your questions; Providing analytic services; Undertaking internal research for technological development and demonstration; Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Pack Health, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Pack Health. | Affiliates; App store platforms; Caregivers; Data analytics providers; Parents/Guardians; Physicians; Technology providers. |
| Internet and other electronic network activity information including, but not limited to, browsing history, search history, and information about your interactions with internet websites, applications, or advertisements. | You; Data analytics providers; Devices you use to access our Services; Marketing platforms; Social networks; Technology providers. | Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging to identify and repair errors that impair existing intended functionality; Providing you with our products and services and responding to your questions; Providing advertising or marketing services; Providing analytic services; Undertaking internal research for technological development and demonstration; Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Pack Health, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Pack Health; Collecting and processing applications for employment; Processing payments. | Affiliates; App store platforms; Data analytics providers; Marketing platforms; Payment processors; Recruitment platforms; Social networks; Technology providers; Video sharing platforms. |
| Geolocation data. | You; Data analytics providers; Devices you use to access our Services ; Marketing platforms. | Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity; Debugging to identify and repair errors that impair existing intended functionality; Providing you with our products and services and responding to your questions; Providing advertising or marketing services; Providing analytic services; Undertaking internal research for technological development and demonstration; Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Pack Health, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Pack Health. | Affiliates; App store platforms; Data analytics providers; Marketing platforms; Social networks; Technology providers; Video sharing platforms. |
| Audio, electronic, visual, thermal, olfactory, or similar information. | You; Devices you use to access our Services; Technology providers. | Providing you with our products and services and responding to your questions; Undertaking internal research for technological development and demonstration; Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Pack Health, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Pack Health; Collecting and processing applications for employment. | Affiliates; App store platforms; Caregivers; Physicians; Technology providers; Video sharing platforms. |
| Professional or employment-related information. | You; Devices you use to access our Services. | Providing you with our products and services and responding to your questions; Collecting and processing applications for employment. | Recruitment platforms; Technology providers. |
| Inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | You; Devices you use to access our Services. | Providing advertising or marketing services; Providing analytic services; Undertaking internal research for technological development and demonstration; Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Pack Health, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Pack Health.
|
Affiliates; Data analytics providers; Marketing platforms; Social networks; Technology providers; Video sharing platforms. |
In the past twelve months, we have disclosed personal information to third parties for business purposes. The categories of personal information we have disclosed to third parties for business purposes are identified in the “Categories of Personal Information Collected” columns above. We have disclosed those categories of personal information to the categories of third parties identified in the “Categories of Third Parties Receiving Personal Information” columns above.
In the past twelve months we have not sold personal information to third parties. We have no actual knowledge of selling personal information of minors under 16 years of age. California residents have the right to opt out of the sale of their personal information. Because we are not currently engaged in “selling” personal information, within the meaning of the CCPA, we do not offer an opt out at this time.
Right to Know
California residents have the right to request that we disclose the categories and specific pieces of personal information we collected, used, disclosed, and sold during the past twelve months, the categories of sources from which their personal information was collected, our business or commercial purposes for collecting their personal information, and the categories of third parties with whom we shared their personal information. California residents or their authorized agents may submit a request by calling 855-255-2362 or by emailing info@packhealth.com. In order to process your request, we will need to verify your identity and residency by matching certain personal information you provide with information we have on file. We will ask you to provide your name, date of birth, and telephone number. The personal information that we use to verify your identity and residency will not be used for any other purpose.
Right to Delete
California residents have the right to request deletion of the personal information we have collected from them. California residents or their authorized agents may submit a request by calling 855-255-2362 or by emailing info@packhealth.com. In order to process your request, we will need to verify your identity and residency by matching certain personal information you provide with information we have on file. We will ask you to provide your name, date of birth, and telephone number. The personal information that we use to verify your identity and residency will not be used for any other purpose.
Non-Discrimination
California residents have the right to not receive discriminatory treatment by exercising CCPA privacy rights. We do not discriminate against California residents who exercise their CCPA privacy rights.
Questions?
Telephone (toll-free): 855-255-2362
Email: info@packhealth.com
Last Revised: September 28, 2021