Last Updated May 17, 2022
1. Introduction
Responsum Health, Inc. (“Responsum”) is specifically designed to provide a free, online resource for patients, caregivers, and loved ones whose lives have been impacted by chronic disease. In order to provide this resource, we rely on information provided by users related to their health status and personal attributes.
In offering these services, Responsum will always respect its users’ privacy concerns. This Privacy Policy (the “Policy”) describes the type of information Responsum Health, Inc. (“Responsum”) collects from people who visit our website or use one of our mobile applications (“App”) (collectively “Services”) and how that information may be used and shared. In order to explore the Services beyond their landing page, visitors must create an account. If you do not create an account, the only information the Services will collect from you is the non-personally identified information collected through “cookies,” as described below in the section on cookies.
This Policy is designed to ensure that you understand our practices with respect to information we collect from you throughout our Services. By using the Services, you agree to the terms of this Policy, which are also incorporated by reference into the Terms of Use of our website, and the End User License Agreement of our mobile applications.
2. Changes to Our Privacy Policy
Note that Responsum may update this Policy at any time. Any changes will become effective upon the date of our posting of the revised Policy on the site and App. If we make a material change to the terms of the Policy, we will post a notice that it has been revised on the home page of the site and the App. If you use our Services after that date, you will be deemed to have accepted the Policy’s updated terms.
3. What Personal Information Do We Collect?
The information Responsum collects from users through the Services includes Personal Information, which is information that identifies an individual personally. Responsum may collect the following Personal Information:
- Name;
- Phone Number;
- Demographic or biographical information, such as age, gender, ethnicity, and location (city, state, country);
- Condition/disease information, including diagnosis, symptoms (e.g., frequency, duration, severity), family history;
- Course of treatment (e.g., medicines, surgeries, therapies, etc.), including side effects;
- Photographs or pictures;
- Laboratory or diagnostic test results;
- Electronic health records;
- Insurance Information;
- Information shared via free text fields;
- Your IP address; and
- Connections to other users of the site or App.
Responsum may collect this type of information from you when you voluntarily provide it through the Services, such as when you fill out a survey or if you post it in comments on the Services. The personally identifiable information that Responsum collects from users will never be made public or shared with others outside what is contemplated under this policy without explicit consent from the user. However, if you post Personal Information in the public areas of the Services (e.g., via chat rooms or comments), that Personal Information is generally accessible to and may be collected and used by others and may result in unsolicited messages or other forms of contact from others. You are therefore advised to exercise caution and discretion when posting Personal Information in such areas of the site. You are solely responsible for the information and other content you post on or through the Services.
Other information we collect when you visit the site may include:
- your approximate geographic location
- the operating system you are using
- the Internet browser you are using
- the Web page you requested to visit
Other information we collect when you use our Apps include:
- Your device’s operating system
- Your unique device identifier
- Your approximate geographic location
4. When Do We Collect Your Personal Information?
You may provide Personal Information to us in the following ways:
- By registering as a member on either our site or App and otherwise using the Services;
- By answering our intake survey;
- By sharing Personal Information when you post comments on our blog posts, such as your email address or Twitter handle;
- By responding to a pop-up question about your health on your Newsfeed or Community Chat pages; and
- By agreeing to allow third-party service providers, such as a patient assistance program, to provide us with your information.
5. How Is My Personal Information Used?
Depending on the portion of the service and site that you have subscribed to or interacted with, we may use your information in a number of ways:
- Responsum will use the information you provide to us to personalize your Newsfeed.
- Responsum will use the information you provide to us to customize the content that populates the Resources Page.
- If you comment on the site or App, and your comment violates our Terms of Use, we may use the contact information you provided in order to comment to notify you of the policy violation.
- To monitor site usage trends and improve the User experience.
- We may disclose your Personal Information if required to do so by process of law, or if necessary in order to investigate fraud, a violation of our Terms of Use, or in connection with any harm being caused to a third party or their rights.
- We may use Personal Information about you to respond to your requests, such as to answer your questions about using our Services, content you may have posted, your experience using our Services, and to provide you with clarifications, explanations, or perhaps the benefits offered by features in the site.
- Finally, we may use Personal Information about you for our internal business purposes, including, to determine use of our features, help improve our product and customize your experience.
6. Who Else Will Have Access To My Personal Information?
We may disclose personal data that we collect or you provide as described in this Policy:
- To Responsum staff in order to troubleshoot problems or resolve
- To contractors, service providers, and other third parties we use to support our business, including the below. All such third parties only receive data pursuant to a contractual relationship where the service provider is required to comply with all applicable privacy laws and to use the personal data only for the purposes for which it was disclosed.
- Google Analytics: We use Google Analytics to evaluate your use of the Website, analyze performance metrics, and compile reports on activity. More information on how Google uses data can be found here: https://policies.google.com/technologies/partner-sites.
- 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 data:
- To comply with any court order, law, or legal process, including responding to any government or regulatory request;
- To enforce or apply our Terms of Use and other applicable agreements including this Privacy Policy;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Responsum or others;
- To permit Responsum to pursue available remedies or limit the damages that we may sustain.
Responsum may share certain de-identified information from Responsum users to partners, such as pharmaceutical or medical device manufacturers and academic institutions that are researching and analyzing ways to better understand patient experience and improve treatment and patient outcomes. Before delivery or exposure of this information, Responsum will remove users’ private data to eliminate the risk of any partner identifying any particular patient.
We do not share Personal Information with unaffiliated third parties for their own marketing purposes. We also do not sell your Personal Information.
Responsum may contain links to Internet sites or third-party applications or widgets operated by other companies that we don’t own or control. These links might have been added by us or by a user, such as in a submitted comment. Regardless of who added a given link, Responsum cannot be responsible for the privacy practices of websites or other services operated by third parties. Once you leave the Responsum website via such a link or access a third-party application or widget, you should check the applicable privacy policy of that third party to determine how they will handle any Personal Information they collect from you.
In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Responsum, any affiliate, or its assets, we may transfer any and all information that we collect from site users to the acquiring party or assignee.
7. Legal Basis for Processing Personal Data
We will collect personal data from you for the following reasons:
- Where we need the personal data to perform a contract with you;
- Where the processing is in our legitimate interests and not overridden by your rights; or
- Where we have your consent to do so.
In instances where we collect your personal data to comply with a legal requirement or to perform a contract with you, we will inform you at the point of collection whether the provision of your personal data is mandatory or not, and of any possible consequences if you do not provide your personal data.
Our legitimate interests and those of any third party generally relate to:
- Operating our Services and communicating with you as necessary to provide our Services;
- Personalize your experience based on your preferences and device when using our Services;
- Responding to your queries;
- Provide you with service support;
- Improving our Services and resolving errors;
- Securing your account; and
- Detecting or preventing illegal activities.
We may have other legitimate interests and we will disclose those legitimate interests to you at the relevant time.
You may contact us if you have any questions or need further information concerning the legal basis on which we collect and use your personal data.
8. Cookies
Cookies are small bits of information that we might place on your computer. We would use cookies to identify your Internet browser, store users’ preferences, and determine whether you have installed sufficient enabling software needed to access certain parts of the service. Data in cookies may be read to authenticate user sessions or provide features of the service.
You can program your computer to warn you each time a cookie is being sent, block third-party cookies or block all cookies. However, by blocking all cookies you may not have access to certain features of the service.
You may at any time cancel the use of cookies on our website by modifying the configuration of the web browser used, as follows:
- Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
9. How Do I Edit My Personal Information?
If you have registered as a member on our site or in an App, you have access to all the information we have about you and retain the ability to edit your Personal Information at any time.
10. How Do I Delete My Membership Account and Data?
If you would like to delete your membership account and data, you have a few options. You could either,
- Contact us at usersupport@responsumhealth.com using the email address associated with your account. Please let us know your username in that email, so that we may complete your request accurately.
- From your mobile: Sign in to your account using the mobile app. Once you have signed in, click on ‘Settings’ in the lower right corner of your screen (the icon is three stacked horizontal lines). Once in Settings, scroll down and click on ‘Delete account’. A window will pop up asking if you are sure that you want to delete your account. If you are sure, then click ‘Delete’.
- From your desktop: Log in to your account from your desktop or laptop computer. Once you have logged in, look for your name in the lower-left corner of the screen. Click the ‘up arrow’ to see the menu. Click on ‘Delete account’. A window will pop up asking if you are sure that you want to delete your account. If you are sure, then click ‘Yes, delete’.
You should be aware that it may not be technologically possible to remove each and every record of the information you have provided to us from our servers. The need to back up our systems to protect information from inadvertent loss means that a copy of your Personal Information may exist in a non-erasable form that may be difficult or impossible for us to locate. In addition, we have the right to delete any account at any time if required to do so by process of law, or if necessary in order to investigate fraud, a violation of our Terms of Use, or in connection with any harm being caused to a third party or their rights.
11. How Secure Is My Personal Information?
We use state-of-the-art administrative, technical, personnel, and physical measures to safeguard your Personal Information against loss, theft, or unauthorized use, disclosure, or modification.
Responsum cannot guarantee the integrity or authenticity of any data that users provide about themselves. Although nobody can completely guarantee the security of anyone’s Personal Information, we make all legally required and commercially reasonable efforts to protect your Personal Information from loss, misuse, or alteration by any unauthorized user. You should be aware, however, that there is always some risk involved in transmitting information over the Internet.
12. Retention of Personal Data
We retain personal data we collect from you where we have an ongoing legitimate business need to do so for example, to provide you with a service you have requested, to retain your information for future marketing purposes, or to comply with applicable legal requirements.
When we have no ongoing legitimate business need to process your personal data, we will either delete or anonymize it or, if this is not possible (for example, because your personal data has been stored in backup archives), then we will securely store your personal data and isolate it from any further processing until deletion is possible.
Responsum does not collect or retain a user’s personal financial information, such as credit card data.
13. Children Under the Age of 18
Our services are not intended for children. We may allow for individuals under eighteen (18) to utilize our site with proper parental consent or other legal consent. If you are under 18, do not use or provide any information on this Website or on or through any of its features. If we learn we have collected or received personal information from someone under 18 without verification of parental or other legal consent, we will delete that information. If you believe we might have any information from or about a child, please contact us at usersupport@responsumhealth.com
14. Transfer of Personal Information
Our Services are operated in the United States. If you are located outside of the United States, please be aware that the information we collect may be transferred to and processed in the United States. Any such transfer of Personal Information shall take place under applicable law, such as Standard Contractual Clauses where applicable, and Responsum will ensure that transfers of Personal Information are subject to appropriate safeguards under such applicable laws.
15. Data Controller
Your personal data collected by your use of our Services is controlled by Responsum Health, Inc.
If you have any questions or concerns about our use of your personal data, please contact us at usersupport@responsumhealth.com or by mail to:
Responsum Health, Inc.
100 M Street, SE, Suite 750
Washington, DC 20003
16. European User Rights
If you are a resident of the European Economic Area, the UK, or in certain other situations, you have the following data protection rights, which you can exercise by contacting us using the details below:
- The right to access. You have the right to request copies of your personal data.
- The right to rectification. You have the right to request that we correct any information you believe is inaccurate. You also have the right to request that we complete the information you believe is incomplete.
- The right to erasure. You have the right to request that we erase your personal data, with exceptions provided by the GDPR.
- The right to restrict processing. You have the right to request that we restrict the processing of your personal data, with exceptions provided by the GDPR.
- The right to object to processing. You have the right to object to our processing of your personal data, with exceptions provided by the GDPR.
- The right to data portability. You have the right to request that we transfer the data that we have collected to another organization, or directly to you, with exceptions provided by the GDPR.
- The right to make a complaint to a data protection regulator. If you are a resident of the EEA, you can find your local regulator’s contact details here. If you are a member of the UK, you can make a complaint to the Information Commissioner’s Office (“ICO”).
You can withdraw your consent to our collection or processing of your personal data at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to such withdrawal, nor will it affect the processing of your personal data or your personal information conducted in reliance on lawful processing grounds other than consent.
17. Exercising Your Rights
To exercise any of the above rights, you must submit a request to us by email to usersupport@responsumhealth.com or by mail to:
Responsum Health, Inc.
100 M Street, SE, Suite 750
Washington, DC 20003
Only you, or a person that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. We cannot respond to your request if we are unable to verify your identity or authority. Your verifiable request must include the reference “Request for GDPR Privacy Information” in the subject line and the body of the message must:
- provide sufficient information that allows us to reasonably verify that you are the person whose personal information we have collected;
- describe your request with sufficient detail; and
- include an e-mail address or mailing address, as applicable, for us to send our response.
Our website and App generally provide you with a reasonable means to view and change your profile information and you can opt out of marketing communications at any time by clicking on the “unsubscribe” or “opt-out” link in the marketing emails we send you.
18. Contacting Us
If you have any questions or concerns related to this Privacy Policy or the information practices of our website or App, please send us an e-mail at usersupport@responsumhealth.com