Last Updated Date: March 23, 2024
This Privacy Policy of Transplant Coach Inc. ( “Transplant Coach” or “we” or “our”) describes our personal data handling policies, including the following:
What personal information we collect, including from our online applications, services and our website at www.transplantcoach.com (the “Site”, and collectively with the foregoing, the “Services”);
How we use the information;
Retention and security of your information;
Children’s privacy;
Your privacy rights, choices and disclosures;
Changes to our privacy policy;
Users outside the United States;
Links to other sites;
Questions and contact information.
By using our Services you agree to the privacy practices described in this Privacy Policy. By continuing to use the Site and Services, you accept this Privacy Policy.
As used in this policy, the terms “using” and “processing” information include using cookies on a computer, subjecting the information to statistical or other analysis and using or handling information in any way, including, but not limited to collecting, storing, evaluating, modifying, deleting, using, combining, disclosing and transferring information within our organization or among our affiliates within the United States or internationally. As used below, the term “Personal Information” is used to indicate any piece of information or data that can be used to identify any individual. Personal Information may relate to you as a User, or it may relate to the individual that is the subject of any User Account that you create. Any other defined term that is not defined in this Privacy Policy has the meaning given that term in the Terms of Use.
The information we collect from you varies, depending on the way you use our Services. We collect information from or about you in the ways described below.
When you set up an account with Transplant Coach, you are creating a direct customer relationship with Transplant Coach that enables you to access and/or utilize the various functions of the Services as a user. As part of that relationship, you provide information to Transplant Coach, including but not limited to, your name, email address, and phone number, that we do not consider to be "protected health information" or "medical information".
However, in using certain components of the Services, you may also provide certain health or medical information that may be protected under applicable laws. Transplant Coach is not a "covered entity" under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments from time to time (collectively, "HIPAA"). It is important to note that HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to your transactions or communications with Transplant Coach. To the extent Transplant Coach is deemed a "business associate" however, and solely in its role as a business associate, Transplant Coach, may be subject to certain provisions of HIPAA with respect to "protected health information," as defined under HIPAA, that you provide to Transplant Coach ("PHI").
In addition, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, "Protected Information"), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified in accordance with applicable laws.
Your doctors’ Notices of Privacy Practices will describe how they use and disclose Protected Information.
By accessing or using any part of the Services, you are agreeing that even if HIPAA does apply to Transplant Coach, any information that you submit to the Services is not considered Protected Information and will only be subject to our Privacy Policy and any applicable laws that govern the privacy and security of such information. When you use our Services, we collect information that you choose to share with us. We collect several types of personal information from and about you when you use our Services. This information may include:
Name (required)
Email address (required)
Telephone number (required)
Date of Birth (required)
Gender (required)
Social Security Number (required)
Address
Credit or debit card information (required if you elect to use e-fax services)
Insurance information
Medical tests
Demographic information
Primary care physicians and other specialists
Medical history (including hospitalizations, cardiovascular history surgical history, immunizations and vaccinations)
Medications
Medical imaging
Lifestyle questionnaire
Psychological assessment
Required fields are needed to determine appropriate medical tests or address questions required when applying for a kidney transplant. Non-required fields assist in satisfying transplant center requirements for candidate evaluation.
If you use the option to log in with social media we will receive the information included in your public profile, such as your social media handle, and your name. Social media providers are unaffiliated with us, and we are not responsible for the content or privacy practices of social media providers. Social media providers have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit their websites or interact with their platforms. We also collect any information you choose to provide to us, including the information in non-required fields during the registration process.
You do not need to create an account or provide personal information in order to browse or use our Services. Our Site, however, collects certain information automatically about you and your use of our Site and Services, your interactions with us and information regarding the device you use to access our Services . This information includes:
device information, such as hardware setting, web browser type and language
IP address, MAC address
identifiers associated with cookies or other technologies that may uniquely identify your device or browser (e.g. device advertising ID)
times you have accessed pages
pages you have viewed
searches you have conducted
pages you visited before or after navigating to our Site
We and our research, technology, and marketing partners, affiliates, analytics, or service providers use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. Cookies are small amounts of data which are sent to your browser from a website’s computers and stored on your computer or device.
remembering your preferences and allowing you to enter your username less frequently;
uniquely identify each user session when you access the services;
compile aggregated statistics to analyze how the services are used;
measure the effectiveness of our site, services and content
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to disable cookies on your browser but doing so may prevent you from using the full features of the services. Third parties may use cookies, web beacons, and similar tracking technologies on our Services. They may collect information about how you use our Services and other websites and online services over time and across different services. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.
We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics may set cookies on your browser or mobile device or read cookies that are already there to collect information. Google Analytics may also receive information about you from apps you have downloaded that partner with Google. Google Analytics collects information such as how often you use our application. We use the information provided by Google to improve our Site and the Services. We do not combine the information collected through the use of Google Analytics with personally identifiable information. For more information regarding how Google collects, uses, and shares your information please visit http://www.google.com/policies/privacy/partners/. You can deactivate Google Analytics using a browser add-on if you do not wish the analysis to take place. You can download the add-on here.We use your information to provide, analyze, administer, enhance and personalize our Site and the Services we provide to you, including our marketing of our Services to you. We also use your information to communicate with you and to operate our business. More specifically, we may use your information to:
Deliver our Services to you, including providing transplant coaching services, providing access to our Site’s online features, such as fax submission, completing and processing your online purchases or engaging in other transactions with us
Communicate with you about the Services, including to respond to your customer service requests or respond to any other inquiry or correspondence you send to us
Analyze and improve the Site and Services, including developing and improving products and services, monitoring and analyzing trends and usage
Prevent, detect, investigate, or remediate security or other legal concerns, including fraud
To protect the rights, property, or safety of us our users, or any other person or the copyright-protected content of the Services
Comply with applicable laws, regulations, or industry requirements, or respond to subpoenas or government requests
Fulfill any other purpose for which your provide it or consent
Please note that the Information you provide through our Services may be shared with your health plan or health care provider with your consent. Please refer to your health plan’s or health care provider’s HIPAA-required notice of privacy practice for additional information as to how those parties may use or disclose your Personal Information. We may also share information collected about you in the following situations:
With third parties who perform services on our behalf to provide the Services, including without limitation the transplant coach, hosting and storage providers, electronic facsimile servicer, payment processors and professional advisors.
With third parties for legal or security reasons, including. We may share information about you if we reasonably believe that disclosing the information is needed to: comply with any valid legal process, governmental request, or applicable law, rule, or regulation; investigate, remedy, or enforce potential violations of our Terms of Use or Privacy Policy; protect the rights, property, and safety of us, our users, or others; and detect and resolve any fraud or security concerns.
With third parties as part of a merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company or, if we undergo liquidation or bankruptcy proceedings, we may share your information in connection with such transaction or proceeding before and or after the transaction closes or the proceedings are completed.
With your consent, we may share information in other ways if you give us consent or direct us to do so.
We do not share personal information with third parties for their direct marketing purposes.
We retain the personal data we collect for so long as reasonably necessary to fulfill the purposes for which the data was collected and to perform our contractual and legal obligations. Notwithstanding the generality of the foregoing, we store some types of data, such as contact information, until you request to be unsubscribed, have the information deleted or remove yourself through any self-service tools offered through the Services.
We do not store payment card information; rather we utilize a payment processor and store only an electronic receipt that sets forth confirming payment details, such as purchase date, the expiration date of the payment card and the payment ID, but not complete payment card information.
We take reasonable precautions to protect your information. This includes, when required or as we deem appropriate and feasible under the circumstances, encryption and written commitments from third parties that may have access to your data that they will protect the data with appropriate safeguards. Please keep in mind that the Internet is not a 100% secure medium for communication, and we cannot guarantee that the information collected about you will always remain private when using our Services. As a result, while we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us, and you do so at your own risk. We utilize the services of Rackspace and Amazon Web Services (AWS) for cloud-based hosting of information. Information about Rackspace’s security standards and certifications is available on their website and information about AWS’s security is available on their website.
This Site is not directed at or intended for use by children under 18 years old. We do not knowingly collect or solicit any information from anyone under the age of 18. If we are made aware of such a situation, we will delete such information.
We are committed to facilitate the exercise of your rights granted by the laws of your jurisdiction, which may include the right to request the correction, modification or deletion of your personal information and the right to opt out of the sale of your personal information (as applicable). We will do our best to honor your requests subject to any legal and contractual obligations.
If you would like to make a request, cancel your account or request we delete or no longer use your account information to provide you Services, contact us at irena@transplantcoach.com or make changes to any user profile information connected to your account. Subject to local law, you may have additional rights under the laws of your jurisdiction regarding your personal data, such as the right to complain to your local data protection authority.
You may be able to disable Cookies through your browser settings, but if you delete or disable cookies, you may experience interruptions or limited functionality in certain areas of the Services.
We do not respond to Do Not Track browser settings. California Consumer Privacy Act Disclosures. We are a non-profit entity and not subject to the California Consumer Privacy Act.
We may make changes to this policy from time to time, in our sole discretion. Your continued use of any of the Services after the changes have been made will constitute your acceptance of the changes.
The Services are controlled and operated from the United States. If you are an individual from the European Union, Canada or any other jurisdiction with laws or regulations governing personal data collection, use, and disclosure that differ from United States laws, please be advised that we may store the information we collect in the United States which is not deemed an “adequate jurisdiction” by the European regulatory authorities. Personal data may also be transferred from the country of your residence to other countries, including the United States.
Our Services may contain links to other websites for your convenience or information. These websites may be operated by companies unaffiliated with us, and we are not responsible for the content or privacy practices of those websites. Linked websites may have their own terms of use and privacy policies, and we encourage you to review those policies whenever you visit the websites.
Please contact us if you have any questions about our Privacy Policy. You may contact us by emailing us at irena@transplantcoach.com.