Privacy Policy
Last Updated: November 13, 2024
PRIVACY POLICY This Privacy Policy describes how ReadyCareConnect, Inc. DBA CircleEngage ("CircleEngage," "we," "us," or "our") collects, uses, and shares personal information when you use our website, platform, and services (collectively, the "Services").
1. Information We Collect
We collect the following types of information:
Personal Information: This includes your name, address, email address, contact information, preferred language, gender, and information about your health care coverage needs. You provide this information directly to us when you use the Services.
Health Information: This includes information about your past, present, or future physical or mental health or use of health care services, such as your health care coverage, medications, doctors, and medical records or Medicare claims data. You may provide this information directly or authorize us to obtain it from third parties.
Technical Information: When you use our Services, we automatically collect certain technical information about your device and interaction with the Services. This may include:Internet Protocol (IP) addressDevice ID and typeBrowser type and versionOperating systemReferring URLs and pages visitedUser interactions (e.g., clicks, page views)Precise geolocation data (if you have enabled location services)
Cookies and Similar Technologies: We use cookies and similar technologies to collect information about your browsing activity and preferences. This helps us improve the Services and personalize your experience. You can manage your cookie preferences through your browser settings. However, disabling cookies may affect the functionality of the Services.
2. How We Use Your Information
We use your information for the following purposes:
Provide and Improve Services: We use your information to provide and improve the Services, such as offering recommendations on health care costs, providing tools for managing health care costs, and sending medication reminders.
Research and Development: We may use de-identified information for research and development purposes to improve our Services and develop new offerings.
Communication: We may use your email address to send you account updates, important notifications, and marketing communications (if you have opted in).
Legal Compliance: We may use your information to comply with applicable laws and regulations.
3. How We Share Your Information
We may share your information with the following types of third parties:*
Service Providers: We may share your information with third-party service providers who assist us in providing the Services, such as hosting providers, data analytics providers, and payment processors.
Affiliates and Subsidiaries: We may share your information with our affiliates and subsidiaries.
*Business Transfers: We may share your information in connection with a merger, acquisition, or sale of all or a portion of our assets.
Legal Authorities: We may disclose your information to legal authorities if required by law or legal process.We will obtain your consent before sharing your Health Information with third parties, except as required by law.
4. Your Rights
You have the following rights regarding your personal information:
Access: You can request access to your personal information.
Rectification: You can request correction of inaccurate or incomplete personal information.
Erasure: You can request deletion of your personal information, subject to certain exceptions.
Restriction of Processing: You can request restriction of processing of your personal information.
Data Portability: You can request a copy of your personal information in a portable format.
Objection: You can object to the processing of your personal information based on legitimate interests.To exercise your rights, please contact us at privacy@circleengage.ai. We will respond to your request within a reasonable timeframe.
5. Data Security
We take reasonable measures to protect your information from unauthorized access, use, or disclosure. These measures include:Encryption of data in transit and at rest using industry-standard encryption methods.Access controls to limit access to your information.Regular security assessments and audits.Employee training on data security and privacy.
6. Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law.
7. Children's Privacy
We do not knowingly collect personal information from children under the age of 13. If you are a parent or guardian and believe that your child has provided us with personal information, please contact us at privacy@circleengage.ai.
8. External Websites
The Services may contain links to third-party websites. We are not responsible for the privacy practices of these websites. We encourage you to review the privacy policies of those third parties.
9. Changes to this Privacy PolicyWe may update this Privacy Policy from time to time. We will post any changes on the Services and notify you as required by law. Your continued use of the Services after the changes take effect constitutes your acceptance of the updated Privacy Policy.
10. Contact UsIf you have any questions about this Privacy Policy, please contact us at: CircleEngageEmail: privacy@circleengage.ai
Mailing Address: CircleEngage, 60 Chelsea Piers, Suite 6020, New York 10011
The Information We Collect and/or Receive
1. Personal Information
When you use the services provided through this technology, you may provide us with a variety of information about yourself such as your name, address, e-mail address, contact information, the language you prefer to communicate in, your gender, and information to help us determine what type of health care coverage might be right for you. All information we collect and/or receive under this section is collectively called "Personal Information."
2. Health Information
You may also provide us with information that relates to your past, present, or future physical or mental health or use of health care services (collectively, "Health Information") or authorize us to obtain this information from third parties (we will specifically ask for your permission to get information from a third party). This may include:
- Your health care coverage
- Your medications and doctors
- Medical information that might be included in electronic health or medical records or Medicare claims data, if you elect to have that information shared with us.
3. Other information
In addition to the information noted above, we may collect additional information (collectively, the "Other Information"), based on your use of this technology. Such Other Information may include:
From Cookies. Information that we collect using "cookie" technology. Cookies are small packets of data that a website stores on your computer’s or mobile device’s hard drive so that your computer will "remember" information about your visit. We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them) to help us collect Other Information and to enhance your experience using this technology. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this and how to delete persistent cookies. However, if you decide not to accept cookies from us, the technology may not function properly.
Third-Party Analytics. We use third-party analytics services to evaluate your use of the technology, compile reports on activity, collect demographic data, analyze performance metrics, and collect and evaluate other information relating to the Services and mobile and Internet usage. These third parties, specifically Google Analytics, Google Tag Manager, and Inspectlet, use cookies and other technologies to help analyze and provide us the data and may have access to certain information related to your device, location, login credentials, unique application identifier, or other information collected or stored on your device in order to provide these services to CircleEngage.
For more information on these third parties, including how to opt out from certain data collection, please visit the sites below. Please be advised that if you opt out of any service, you may not be able to use the full functionality of the Services.
For Google Analytics, please visithttps://tools.google.com/dlpage/gaoptout
For Google Tag Manager, please visit https://www.google.com/analytics/tag-manager/use-policy
For Inspectlet, please visit https://www.inspectlet.com/optout
How We Use Your Information
(1) We use the Personal Information, Health Information and Other Information (collectively, "Information") to provide services to you through this technology. These services include, but are not limited to, providing recommendations to you on how to limit or reduce your health care costs, providing a tool to help you plan and manage your health care costs, and/or providing medication reminders.
(2) Also, we may use your Information, in connection with the information of other users of this technology, to:
- do research in order to improve the services we furnish,
- measure and improve the effectiveness of our services, and/or
- to develop and improve new and current products and services.
We will de-identify your information (this means that we take out the elements that could reasonably be used to identify you) before using it for these purposes. In all cases, we will only use the minimum information necessary for the purpose for which we are using it.
How We Will Disclose Your Information to Third Parties.
We may disclose your Information to our subsidiaries, affiliates, and/or other entities with which we have a subcontract to provide services to you or to us.
- With respect to your Personal Information, you have the right to tell us that you do not wish for it to be shared with third parties (your opt-out right).
- With respect to your Health Information, we will only share that information with third parties if you affirmatively give us permission to do so.
Even with your permission to share your Information, we will not disclose your Information to such entities until they agree in writing to only use and disclose such Information as set forth in this Privacy Policy and to implement safeguards to protect the privacy and security of the Information. In addition, we will provide them with the minimum necessary information needed to perform the service that we have requested.
We may disclose the Information if we are required to do so by law, court order, or other government or law enforcement authority or regulatory agency.
We will inform you in the case that our company is to be acquired by another company. If the use of user's data is changed in any way as a result of the acquisition, the acquiring company will be responsible for informing you of those changes before they take effect.
Selling Your Information
We will not sell any identifiable data about you. However, we may sell your de-identified data aggregated with the data of other users. We may also sell information derived through analyzing aggregated information of our users.
What you can do with the Information that we collect
You may access, share, or delete the Information we have about you by contacting privacy@trusty.care.
How we store your Information
We store your data through a third party in a highly secured shared server.
How we encrypt your Information
Your Information is encrypted, in storage and in transmission, in accordance with a U.S. Federal Information Processing Standard known as “SHA512”. This method is the industry standard.
What happens to your Information when your account is deactivated
If your account is deactivated/terminated by you or CircleEngage, your identifiable data is deleted after 30 days.
How we will notify you and protect your Information in case of an improper disclosure
If your unsecured identifiable Health Information is accessed without authorization, we will promptly notify you (or your next of kin if you are deceased) through written notice, by first-class mail at your last known address (unless you have opted to receive such notice by e-mail). In addition, for all of your Information, we make any and all breach notifications required by applicable law.
Children
We do not knowingly collect Personal Information from children under the age of 13 without their parents’ consent.
External Websites
The Websites, Platform and the Services may contain links to third-party websites ("External Sites"). We do not endorse such External Sites and we are not responsible for the privacy practices of such External Sites. Please refer to the privacy policies of those External Sites for more information on how the operators of those sites collect and use your Personal Information.
Changes to This Privacy Policy
This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time, and will post any changes on the Websites, Platform and the Services as soon as they go into effect. By accessing any of the Websites, Platform and/or using the Services after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.
How to Contact Us
If you have questions about this Privacy Policy, please e-mail privacy@circleengage.ai, "PRIVACY POLICY" in the subject line, or mail us at the following address:
CircleEngage, 60 Chelsea Piers, New York NY 10011
In the course of operating this technology and providing services to you, CircleEngage will collect, store, use, transmit, and/or receive the following types of information. You will provide this information to us, authorize us to collect and/or receive such information from other sources, or, for “other information,” we will obtain it based on your use of this technology.
