Introduction

At Pathway Partners, LLC (“Company” or “we“), we respect your privacy and are committed to protecting it through our compliance with this policy as well as with all applicable laws, including the privacy and security rules and regulations of the Health Insurance Portability and Accountability Act of 1996, as amended (“HIPAA”)  Specifically, we maintain reasonable administrative, technical and physical safeguards which are designed to ensure the confidentiality, integrity and availability of the personally identifiable health information that we maintain on our website and related information systems.  However, no system is impenetrable and we cannot guarantee the confidentiality, integrity and availability of such personally identifiable health information.

This policy describes the types of non-health information we may collect from you or that you may provide when you visit the website pathwayhealthcare.com (the “Website”) or use a mobile application, if any, provided by us (collectively, with the Website, the “Pathway Technology”), and our practices for collecting, using, maintaining, protecting and disclosing that information. Our practices for collecting, using, maintaining, protecting and disclosing information on our users’ health, health care, providers of health care (including information on the names and addresses of hospitals or other health care providers) and payment for health care (including payments made by third parties, such as insurance companies), regardless of whether such information is or can be associated with any individual, (“Health Information”) are provided in the notice of privacy practices, which can be found here:

This policy applies to non-Health Information we collect:

  • On this Website.
  • In e-mail, text and other electronic messages between you and this Website.
  • Through mobile applications we provide.

It does not apply to information:

  • Collected by us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries);
  • Collected by any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website; or
  • which is Health Information.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Pathway Technology. By accessing or using the Pathway Technology, you agree to this privacy policy. This policy may change from time to time. Your continued use of the Pathway Technology after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 13

The Pathway Technology is not intended for children under 13 years of age. No one under age 13 may provide any information to the Pathway Technology. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information to or through any of the features of the Pathway Technology, or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name or user name you may use.

 

Information We Collect About You and How We Collect It

We collect several types of non-Health Information from and about users of the Pathway Technology, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address and telephone number (“Personal Information“);
  • about your internet connection, the equipment you use to access our Website or otherwise interact with the Pathway Technology (including information about health devices or fitness trackers you may choose to allow the Pathway Technology to communicate with), and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you use the Pathway Technology, such as by navigating through the Website. Information collected automatically may include usage details, IP addresses and information collected through cookies.

Information You Provide to Us

The non-Health Information we collect on or through the Pathway Technology may include:

  • Information, such as passwords, that you provide by filling in forms provided by the Pathway Technology, such as forms on our Website. This includes information provided at the time of subscribing to our service. We may also ask you for information when you report a problem with the Pathway Technology.
  • Records and copies of your correspondence (including e-mail addresses), if you contact us.

 

Information We Collect Through Automatic Data Collection Technologies

As you navigate through our Website or otherwise interact with the Pathway Technology, we may use automatic data collection technologies to collect certain non-Health Information about your equipment, browsing actions and patterns, including:

  • Details of your visits to our Website, including location data and other communication data and the resources that you access and use on the Website.
  • Information about your computer and internet connection, including your IP address, operating system and browser type.

 

California Do Not Track Disclosures

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. For information about Do Not Track, visit www.allaboutdnt.org. At this time, Pathway Healthcare does not respond to Do Not Track browser settings or signals. In addition, Pathway Healthcare may use other technology that is standard to the Internet, such as pixel tags, web beacons, and other similar technologies, to track visitors to pathwayhealthcare.com or one of our affiliated sites. Those tools may be used by us and by third parties to collect information about you and your internet activity, even if you have turned on the Do Not Track signal.

The non-Health Information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.

 

Third-party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, 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 interest-based (behavioral) advertising or other 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.  

 

How We Use Your Information

We use the non-Health Information that we collect about you or that you provide to us, including any Personal Information:

  • To estimate our audience size and usage patterns.
  • To store information about your preferences, allowing us to customize the Pathway Technology according to your individual interests.
  • To recognize you when you return to our Website.
  • To collect your address if applicable
  • To present our Website and its contents to you.
  • To provide you with information, products or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to the Pathway Technology or any products or services we offer or provide.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, you may opt out of the disclosure of your information for third party advertising, targeted advertising, and promotional offers from the Company as described in this policy under the heading

Choices About How We Use and Disclose Your Information

We may use the non-Health Information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personally identifiable non-Health Information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which Personal Information held by us about the Pathway Technology’s users is among the assets transferred.
  • To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

We may also disclose your Personal Information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • To enforce or apply any terms of service and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers or others.

 

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. 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 this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by emailing privacy@pathwayhealthcare.com
  • Promotional Offers from the Company. If you do not wish to have your Personal Information used by the Company to promote our own or third parties’ products or services, you can opt-out by emailing privacy@pathwayhealthcare.com

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s (http://www.networkadvertising.org/)

 

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please contact us privacy@pathwayhealthcare.com

 

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ Personal Information, we will notify you. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: privacy@pathwayhealthcare.com

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