This Consumer Health Data Privacy Notice (“Notice”) provides information about how Freedom Care LLC (“FreedomCare,” “we,” “our,” or “us”) collects, stores, and uses consumer health data (defined below) that we may collect from visitors to and users of our websites, including www.freedomcare.com and all related websites (the “Sites”), FreedomCare mobile applications (the “Apps”), and web-based services (collectively with Sites and Apps, our “Services”).

This Notice applies to Connecticut or Nevada residents about whom we collect Consumer Health Data, and is intended to provide notices in compliance with the Connecticut Data Privacy Act (“CTDPA”) and Nevada SB 370.  Please note that this Notice does not apply to our employees or prospective employees.  We encourage you to review our Privacy Policy to learn more about our privacy practices and our commitments to you.

Some of the information we collect, use, and disclose is done so for purposes of providing healthcare and are regulated by the federal Health Insurance Portability and Accountability Act (HIPAA) and similar federal and state laws, including the privacy and security protections of those laws (collectively, “protected health information” or “PHI”).  This Notice does not apply to PHI, and any overlapping coverage of PHI in this Notice is incidental and provided to enhance your understanding of our data collection and use practices, and should not be construed as an acknowledgement of the applicability or inapplicability of certain privacy laws, including HIPAA and/or the state and other privacy laws that may apply to FreedomCare.  You can find more information about our collection and use of PHI in our Notice of Privacy Practices.

This Notice also does not apply to third-party websites, mobile applications, products, or services, even if they may link to our Services or our Services may link to them.  We recommend you review the privacy practices of those third parties before accessing third party websites and sharing any personal data.

1. Consumer Health Data We May Collect

For the purposes of this Notice, “personal data” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with an identifiable individual.  “Consumer health data” means personal data that is linked or reasonably linkable to you and that identifies your past, present, or future health status or mental health status, as may be applicable.  Please note that consumer health data does not include “protected health information” covered by HIPAA.

We may collect, or have collected, the following categories of consumer health data about you:

● Individual health treatments, conditions, treatment, diseases, or diagnosis
● Social, psychological, behavioral, or medical interventions
● Health-related surgeries or procedures
● Use or purchase of prescribed medication
● Diagnosis or diagnostic testing, treatment, or medication
● Biometric data
● Vital signs, symptoms, or measurements of the above categories
● Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies
● Data that identifies you seeking health care services
● Any information that we or our service providers process to associate or identify you with the above information that is derived from non-health information (such as inferred data).

2. Categories of Sources of Consumer Health Data

We may collect consumer health data from the following categories of sources:

• Directly from you, through your interactions with us, such as when you use our Websites, complete electronic forms, or otherwise contact us via chat, email, or phone.
• From third party service providers, in accordance with applicable law and the context in which you provided the data.

[Please note that although we generally use cookies and analytics services for tracking activity on and gauging the effectiveness of our Sites, as well as for third-party advertising purposes, our Sites implement measures to help ensure that we do not use cookies for individuals accessing our services from Connecticut or Nevada.

OR

Additionally, our Sites use cookies and other tracking technologies such as web beacons, embedded scripts, and tags (“Cookies”), which collect information from you automatically as you use our Sites, including:

• Browser and device data, such as IP address, device identifier, device type, operating system and Internet browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the Sites you are visiting; and
• Usage data, such as geolocation data, browsing history, time spent on the Sites, pages visited, links clicked, language preferences, patterns of use, and the pages that led or referred you to our Site.

We may use third-party cookies, scripts, or pixels to collect and analyze website usage data and/or track user interaction to provide better customer experience and improve our product offerings.  For example, we may use Google Analytics or other service providers for analytics services.  These analytics services may use cookies to help us analyze how users use the Service.  Information generated by these services (e.g., your IP address and other usage information) may be transmitted to and stored by Google Analytics and other service providers on servers in the U.S. (or elsewhere) and these service providers may use this information for purposes such as evaluating your use of the Services, compiling statistic reports on the Service’s activity, and providing other services relating to Services activity and other Internet usage.  You may exercise choices regarding the use of cookies from Google Analytics by going to https://tools.google.com/dlpage/gaoptout or downloading the Google Analytics Opt-out Browser Add-on.

We do not share consumer health data with any third-party advertisers.]

3. How We Use Consumer Health Data

We use the consumer health data we collect about you for the following purposes.

• Providing you with customer service and support, and to facilitate other communications that you request or that are required to render Services to you.
• Providing you with information about new Services and other opportunities that we believe may be of interest to you, and to personalize, measure, and improve such offers.
• Protecting the legal rights, safety, privacy, and property of us, you, and others.
• Preventing fraud; and creating and maintaining a trusted, secure, and reliable online environment.
• Evaluating or conducting 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 data held by us about the users of our Sites or Services is among the assets transferred.
• Complying with our legal obligations; responding to subpoenas, court orders, or legal process; or exercising our legal rights or defending against legal claims.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

4. To Whom We Disclose Consumer Health Data

We will only disclose your consumer health data with your consent.  Under certain circumstances, we may disclose your data if required to do so by law or in response to valid requests by public authorities.

5. Consumer Health Data Privacy Rights

Connecticut residents have the following rights in relation to your consumer health data, subject to certain exceptions:

• Right to know and access. You have the right to know what consumer health data we collect, use, disclose, and/or sell or share as those terms are defined under applicable law. You may ask us to provide you a portable copy of this information up to two times in a rolling twelve-month period.
• Right to delete and erase. You have the right to request under certain circumstances that we, as well as our service providers and contractors, delete the consumer health data that we collect about you.
• Right to correct inaccurate consumer health data. You have the right to request the correction of inaccurate consumer health data.
• Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.
• Right to opt out. You have the right to opt-out of targeted advertising, the sale of your personal data, and profiling decisions that could produce legal or similarly significant effects concerning the consumer.
• Rights concerning sensitive personal data. If you are a Connecticut resident, we cannot process your consumer health data, or use your consumer health data for certain purposes without your affirmative consent.

Nevada residents have the following rights in relation to your consumer health data, subject to certain exceptions:

• Right to know. You have the right to know what consumer health data we collect, share, or sell, as those terms are defined under applicable law.  You also have the right to obtain a list of all third parties and affiliates with whom we have shared or sold your consumer health data, and an active email address or other mechanism that you may use to contact these third parties.
• Right to withdraw consent. You have the right to withdraw consent from the collection and sharing of your consumer health data.
• Right to delete. You have the right to request that we, as well as our service providers and contractors, delete the consumer health data that we collect about you.
• Right to non-discrimination. You have the right not to receive discriminatory treatment for the exercise of the privacy rights described above.

How to exercise your rights. If you wish to exercise any of the rights listed above, please send your request(s) using one of the following methods:

• Webform: [LINK]
• Email: [EMAIL]
• Mail: [ADDRESS]

We do not charge a fee to process or respond to your verifiable consumer request unless it’s excessive, repetitive, manifestly unfounded, or in accordance with applicable law.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

How we verify and respond to requests.  We will respond to your request within forty-five (45) days after receipt and we reserve the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.  As described below, in some jurisdictions, an authorized agent may submit a request to exercise your rights on your behalf.

If you have an account with us, we will deliver our written response to that account or via electronic mail.  If you do not have an account with us, we will deliver our written response by electronic mail.

However, we cannot respond to your request or provide you with personal data if we cannot verify or authenticate your identity or authority to make the request and confirm that the personal data relates to you.  Generally, a rights request must include:

• Sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative, which must include, at a minimum, your first and last name and email address.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request.

You are not required to create an account with us to submit a verifiable or authenticated consumer request.  However, we do consider requests made through your password-protected account sufficiently verified when the request relates to personal data associated with that specific account.  We will only use personal data provided in a verifiable or authenticated consumer request to verify your (or your authorized agent’s as applicable) identity or authority to make the request.

Depending on applicable law, you may be limited in how many verifiable or authenticated consumer requests you make within a twelve (12) month period.  If we have collected information on your minor child, you may exercise the above rights on behalf of your minor child.  Additionally, in some jurisdictions, you may designate an authorized agent to submit a request on your behalf, and if so, we may require proof of the agent’s authorization by you and/or verification of the agent’s own identity.

How to appeal decisions about your rights. 

• Connecticut.  If you are a Connecticut resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision.  If your appeal is not successful, you may submit a complaint with the Connecticut Attorney general at here.
• Nevada.  If you are a Nevada resident and your request is denied, you may appeal our decision and we will provide the steps to appeal as part of responding to your request. Within forty-five (45) days of receipt of an appeal, we will inform you in writing of any action taken or not taken, including an explanation of our reasons in reaching the decision.  If your appeal is not successful, you may submit a complaint with the Nevada Attorney General here.

6. Changes to this Notice

We may change this Notice from time to time to reflect new services or changes in our data practices or relevant laws.  We will let you know via email and/or a prominent notice on our Sites, prior to the change becoming effective, and update “effective date” at the top of this Notice.  We recommend periodically reviewing this Notice for any changes.  Changes to this Notice are effective when they are posted on this page.

7. Contact Us

If you have any questions about this Notice or our Services, please contact us by emailing us at [email protected], or calling us at 866-260-4445, or writing us at 1979 Marcus Ave, Suite C115, New Hyde Park NY 11042.