Privacy Policy

Effective date: August 3, 2019

Please note that by using this website (the “Site”) or the services provided by SmartBridge Inc. (“Company”, “we”, “our” or “us”), you are accepting the practices described in this Privacy Policy.  If you do not agree to this Privacy Policy, please do not use the Site or Company’s services.

What is the purpose of this Privacy Policy?

This Privacy Policy discloses Company’s personal information gathering and dissemination practices with respect to the Site and our services.  Please read this Privacy Policy carefully.

We have also created this Privacy Policy to demonstrate our commitment to privacy.  We recognize that when you provide us with information about yourself that you trust us to act in a responsible manner with that information.  We are committed to making sure we earn that trust.

What information do we collect from users and how is it used?

The following describes the types of personal and other information the Company may collect about you, and how the Company may use and maintain that information, including, but not limited to:

Registration. Before you can utilize certain services that we offer on the Site or otherwise, we may ask that you register with the Site and provide us with your email address, a password, your first and last name and other contact information and personal details.  We request this information for identification purposes, to communicate with you regarding your account, and to facilitate the functioning of certain services.  We may keep this information indefinitely.

Forms. To fully utilize the services we offer, you may be required to fill out forms that will contain personal information such as your name, address, telephone number, social security number, account information, employment, health status and other personal information relevant to your health insurance coverage, diagnosis and treatment.

Medical Records. In order for the oncologists giving second opinions regarding your health, you may be required to provide us with past and current medical records, description of symptoms, a medical history and life-style descriptions.

Correspondence. If you correspond with us via email, we may gather in a file specific to you the information that you submit.  We may keep this information indefinitely.

URL and IP addresses. Like many other websites, Company collects information about users’ utilization and navigation of our Site.  This information helps us to design our Site to better suit our users’ needs.  For example, our Site will track the URL that you visited before you came to our Site, the URL to which you next go and your Internet Protocol (IP) address.  We use your IP address to help diagnose problems with our server and to administer our Site. Your IP address also is used to help identify you and to gather broad demographic information.

Information Collected With Cookies.  Like most major websites, Company uses cookies on certain pages of our Site.  Cookies make using the Internet easier by, among other things, saving your preferences for you.  For example, a cookie lets the Site remember that you’ve registered, which allows us to speed up your future activities at our Site, and which allows you to enter your registration information less frequently while visiting our Site.  We may also use cookies to deliver content tailored to your interests.  Our cookies may enable us to relate your use of our Site to personally identifying information that you previously submitted, such as calling you by name when you return to our Site.  If your browser is set to reject cookies, or if your browser notifies you that you are about to receive a cookie and you reject it, then your use of the Site may not be as efficient or as enjoyable as it would be if the cookie were enabled.  The information that we collect with cookies allows us to improve our marketing and promotional efforts, to statistically analyze Site usage, to improve our content and product offerings and to customize our Site’s content, layout and services.  However, we only use information collected with cookies on an aggregated basis without the use of any information that personally identifies you.

To whom does Company disclose information about you that we collect?

Company will not share, rent, sell or otherwise disclose any of the personally identifiable information that we collect about you, except when we have your permission or in any of the following situations:

  • We may disclose information that we collect about you to our third-party contractors who perform services for Company in order to provide certain services or to complete or confirm a transaction that you conduct with us.

  • We may disclose the results of aggregated data about you for marketing or promotional purposes (for instance, that a certain percentage of our Site’s users are living in the United States). In these situations, we do not disclose to these entities any information that could be used to personally identify you. Certain information, such as your password, is not disclosed to marketing advertisers at all, even in aggregate form.

  • We may disclose information about you as part of a merger, acquisition or other sale or transfer of its assets or business. Company does not guarantee that any entity receiving such information in connection with one of these transactions will comply with all terms of this policy.

  • We may disclose information about you for purposes such as to provide services available on the Site; to coordinate with insurance, reinsurance and excess or stop loss insurers; to enforce our members’ rights; to protect against actual or potential fraud; to resolve member inquiries or disputes; to receive payments; to carry out our business; to protect the confidentiality or security of our records; to administer preventive health and case management programs; to perform underwriting, auditing and ratemaking functions; to enable our service providers to perform marketing services on our behalf and inform Members about our own products or services; to comply with federal or state laws and other applicable legal requirements.

  • Moreover, we may be legally obligated to disclose information about you to the government or to third parties under certain circumstances, such as in connection with illegal activity on our Site or to respond to a subpoena, court order or other legal process. Company reserves the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.

If you use our Site or services outside of the United States, information that we collect about you will be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area.  By allowing Company to collect information about you, you consent to such transfer and processing of your data.

Your Rights Regarding Your Protected Health Information

You have certain rights regarding protected health information that we maintain about you.

  • Right to Access Your Protected Health Information. You have the right to review or obtain copies of your protected health information records, with some limited exceptions, including but not limited to X-rays, which we do not provide. Usually the records include enrollment, billing, claims payment and case or medical management records. Your request to review and/or obtain a copy of your protected health information records must be made in writing. We may charge a fee for the costs of producing, copying and mailing your requested information, but we will tell you the cost in advance.

  • Right to Amend Your Protected Health Information. If you feel that protected health information maintained by us is incorrect or incomplete, you may request that we amend the information. Your request must be made in writing and must include the reason you are seeking a change. We may deny your request if, for example, you ask us to amend information that was not created by us, as is often the case for health information in our records, or you ask to amend a record that is already accurate and complete.

If we deny your request to amend, we will notify you in writing.  You then have the right to submit to us a written statement of disagreement with our decision and we have the right to rebut that statement.

  • Right to an Accounting of Disclosures. You have the right to request an accounting of disclosures we have made of your protected health information. The list will not include our disclosures related to your treatment, our payment or health care operations, or disclosures made to you or with your authorization. The list may also exclude certain other disclosures, such as for national security purposes.

Your request for an accounting of disclosures must be made in writing and must state a time period for which you want an accounting.  This time period may not be longer than six years. Your request should indicate in what form you want the list (for example, on paper or electronically).  The first accounting that you request within a 12-month period will be free. For additional lists within the same time period, we may charge for providing the accounting, but we will tell you the cost in advance.

  • Right to Request Restrictions on the Use and Disclosure of Your Protected Health Information. You have the right to request that we restrict or limit how we use or disclose your protected health information for treatment, payment or health care operations. We may not agree to your request. If we do agree, we will comply with your request unless the information is needed for an emergency. Your request for a restriction must be made in writing. In your request, you must tell us: (i) what information you want to limit; (ii) whether you want to limit how we use or disclose your information, or both; and (iii) to whom you want the restrictions to apply.

  • Right to Receive Confidential Communications. You have the right to request that we use a certain method to communicate with you or that we send information about you to a certain location if the communication could endanger you. Your request to receive confidential communications must be made in writing. Your request must clearly state that all or part of the communication from us could endanger you. We will accommodate all reasonable requests. Your request must specify how or where you wish to be contacted.

  • Right to a Paper Copy of This Privacy Policy. You have a right at any time to request a paper copy of this Privacy Policy, even if you had previously agreed to receive an electronic copy.

  • Contact Information for Exercising Your Rights. You may exercise any of the rights described above by contacting our Privacy Office as follows:

SmartBridge Inc.
3400 Prospect Street NW
Washington, DC 20007
hua@smartbridgehealth.com
1-917-721-3644

What security measures does the Site employ?

To help protect the privacy of data you transmit through this Site, where personally identifiable information is requested, we also use technology designed to encrypt the information that you input before it is sent to us using Secure Sockets Layer (SSL) technology or similar encryption technology.  In addition, Company takes steps to protect the user data we collect against unauthorized access.  However, you should keep in mind that this Site and our services are run on software, hardware and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control.

Please also be aware that despite our best intentions and the guidelines outlined in this Privacy Policy, no data transmission over the Internet or encryption method can be guaranteed to be 100% secure.

How can you correct or update information that we collect about you?

You may correct or update information collected about you by managing your account profile or by contacting Company at the email or mailing address noted below.  We will use reasonable efforts to update our records.  For our records, we may retain original and updated information for reasons such as technical constraints, dispute resolution, troubleshooting and agreement enforcement.

What are the policies of linked Sites and other third parties?

This Privacy Policy only addresses the use and disclosure of information we collect from you. You should be aware that when you are on the Site, you can be directed to other websites that are beyond our control, and Company is not responsible for the privacy practices of third parties or the content of linked websites.  We encourage you to read the posted privacy policy whenever interacting with any website.

How will I know about changes in the Privacy Policy?

Company reserves the right to update this Privacy Policy from time to time.  Please visit this page periodically so that you will be apprised of any changes.

What is our policy on children users of our Site?

We do not knowingly collect or maintain personally identifiable information from persons under 13 years old, and no part of our Site is directed to persons under 13.  IF YOU ARE UNDER 13 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS OUR SITE AT ANY TIME OR IN ANY MANNER.  If Company learns that personally identifiable information of persons less than 13 years old has been collected without verifiable parental consent, then Company will take the appropriate steps to delete this information.  If you are a parent or guardian and discover that your child under the age of 13 has obtained a Company account, then you may alert Company at the address below and request that we delete that child’s personal information from our systems.

What law governs my use of the Site and Company’s services?

By choosing to visit this Site, use our services, or otherwise provide information to Company, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the law of Delaware.  You also agree to abide by any limitation on damages contained in our Terms of Service or other agreement that we have with you.

How to contact us?

If you have any questions about this Privacy Policy, or need to reach us for any other reason, you may contact us by e-mail at hua@smartbridgeheallth.com, phone at 1-917-721-3644 or by mail at:

SmartBridge Inc.
3400 Prospect Street NW
Washington, DC 20007

Additional Information About This Privacy Statement

The policies indicated in this Privacy Policy will remain effective, even if the Member’s coverage is terminated, to the extent we retain information about a member.  We may change this Privacy Policy at any time and will inform you of any changes as required by law or regulation.

Information about Particular Services

Analytics
The services contained in this section enable the Owner to monitor and analyze web traffic and can be used to keep track of User behavior.

Google Analytics (Google Inc.)
Google Analytics is a web analysis service provided by Google Inc. (“Google”). Google utilizes the Data collected to track and examine the use of this Application, to prepare reports on its activities and share them with other Google services.
Google may use the Data collected to contextualize and personalize the ads of its own advertising network.
Personal Data collected: Cookies and Usage data.
Place of processing: US – Privacy Policy – Opt Out

Display Advertising extension for Google Analytics (Google Inc.)
Google Analytics on this Application might use Google’s Interest-based advertising, 3rd-party audience data and information from the DoubleClick Cookie to extend analytics with demographics, interests and ads interaction data.
Personal Data collected: Cookies and Usage data.
Place of processing: US – Privacy Policy – Opt Out

Google Tag Manager (Google Inc.)
Google Tag Manager is an analytics service provided by Google Inc.
Personal Data collected: Cookies and Usage data.
Place of processing: US – Privacy Policy

Interaction with external social networks and platforms
This type of services allows interaction with social networks or other external platforms directly from the pages of this Application.
The interaction and information obtained through this Application are always subject to the User’s privacy settings for each social network.
This type of service might still collect traffic data for the pages where the service is installed, even when Users do not use it.

Facebook Like button and social widgets (Facebook, Inc.)
The Facebook Like button and social widgets are services allowing interaction with the Facebook social network provided by Facebook, Inc.
Personal Data collected: Cookies and Usage data.
Place of processing: US – Privacy Policy

Remarketing and Behavioral Targeting
This type of services allows this Application and its partners to inform, optimize and serve advertising based on past use of this Application by the User.  This activity is performed by tracking Usage Data and by using Cookies, information that is transferred to the partners that manage the remarketing and behavioral targeting activity.

Remarketing through Google Analytics for Display Advertising (Google Inc.)
Google Analytics for Display Advertising is a Remarketing and Behavioral Targeting service provided by Google Inc. that connects the tracking activity performed by Google Analytics and its Cookies with the Adwords advertising network and the Doubleclick Cookie.
Personal Data collected: Cookies and Usage data.
Place of processing: US – Privacy Policy – Opt Out

User database management
This type of services allows the Owner to build user profiles by starting from an email address, a personal name, or other information that the User provides to this Application, as well as to track User activities through analytics features.  This Personal Data may also be matched with publicly available information about the User (such as social networks’ profiles) and used to build private profiles that the Owner can display and use for improving this Application.

Some of these services may also enable the sending of timed messages to the User, such as emails based on specific actions performed on this Application.

Addendums

We are constantly seeking to improve the quality of care.  If you have requested a consultative service, an oncologist referral, or another service, we may at any time review your case, your medical records from prior to and after your interaction with the Site, and any records created as a result of services received.  We may request courtesy notices from your treating oncologist(s) and/or request additional medical records from them, including records pertaining to care you received after receiving the services.  We may review these records for, among other purposes, reviewing the quality of service you received, reviewing the quality of service provided by the physicians and medical professionals treating you (including the physicians and medical professionals to whom you may have received a referral), to better understand the course of treatment for your condition(s) including information regarding outcomes and costs, and to improve treatments and recommendations for people with similar or different conditions.  We will take care to minimize personally identifying information in this process.  We may also use anonymous information gathered, including information from your medical records (the “Data”), to generate conclusions about the healthcare process, particular conditions, and other matters (together, the “Purpose”).  We also work with collaborators, including pharmaceutical companies, hospitals, research laboratories, insurance companies, and investors (together, the “Researchers”), who may publish this anonymous information in journals, websites and other locations. Only Researchers that share our Purpose may use the Data with our prior permission. However, we will not publish your name or any identifying information about you; we will use only anonymous data for any public purpose.