This Health Data Privacy Policy (“Policy”) describes how Zelo Health Inc. (“Zelo,” “we,” “us,” or “our”) processes “Consumer Health Data” or any similar term as defined under state law (collectively “Health Data”), about consumers who reside in the states of Nevada, Washington, and any other applicable U.S. jurisdiction in connection with all Company operations as well as websites (including zelo.ai), mobile applications, and digital services where this Policy is linked or posted (“Services”). Please carefully read this Policy as it contains important information concerning your Health Data and how we use it.
This Policy describes how we process Health Data about you. This Policy does not apply to health information that is used to engage in public or peer-reviewed scientific, historical, or statistical research that adheres to all other applicable ethics and privacy laws. For more information about how we process personal data about you, please visit our Privacy Policy.
Health Data does not include other data that does not meet the definition of “Consumer Health Data” or any similar term under applicable law, such as aggregate or deidentified data. To the extent that we process deidentified data, we will maintain and use the data in deidentified form and will not attempt to reidentify the data unless permitted by applicable law. Deidentified data that is reidentified and otherwise qualifies as Health Data is subject to this Policy.
Please note that the Services are primarily intended for caregivers’ and patient representatives’ management of their loved one’s or patient’s care. This Policy describes Health Data collected about the subject of such care, referred to as “you” throughout the Policy.
Health Data We Collect
We collect the following categories of Health Data:
- Individual health conditions, treatment, diseases, or diagnoses
- Social, psychological, behavioral, and medical interventions
- Use or purchase of prescribed medications
- Bodily functions, vital signs, symptoms, or measurements
- Diagnoses or diagnostic testing, treatment, or medication
- Information that could identify your attempt to seek health care services
- Payment information that relates to your physical health (such as insurance details)
- Any other health-related information that you voluntarily disclose to us, including through any interactive tools or otherwise through the Services
- Any inferences based on the above categories or derived or extrapolated from non-health information that identify your past, present, or future physical or mental status
Sources of Health Data
We collect Health Data from the following categories of sources:
- Directly from you when you share it with us through the Services, including through any interactive tools
- From third-party sources, such as patient portals, health care providers, or other health care organizations or entities that you authorize
- Through our service providers that support the Services. This may include the use of cookies, pixels, web beacons, and similar technologies to collect information about you over time and across different websites, including the Services
How We Use Health Data
We collect, use, and disclose Health Data for the following business purposes. We may use AI/ML in whole or in part to help achieve these purposes:
- To provide, operate, maintain, and protect our Services
- To analyze and improve our Services, including developing new products or services (in accordance with applicable privacy law)
- To communicate with you, respond to your inquiries, and send you information by email, postal mail, telephone, text message, notifications, interactive tools or channels, or other means, including promotional content about our products and services
- To enhance and help us better understand your browsing experience, needs, and preferences and provide consistent, personalized services and experiences in our Services
- To protect the security or integrity of the Services
- To protect us, our users, and the public, and comply with applicable law, regulation, or legal process, including to validate user information for fraud and risk detection purposes, resolve disputes and protect the rights of users and third parties, respond to claims and legal process (such as subpoenas and court orders), fulfill our reporting obligations, and monitor and enforce compliance with our contracts, and otherwise detect, prevent, or stop any activity that may be illegal, unethical, or legally actionable
- To evaluate or conduct 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 Health Data held by us about our customers is among the assets transferred
How We Share Health Data
We disclose some or all of the above categories of Consumer Health Data for the purposes described above with the following third parties and affiliates:
- As legally required in relevant legal proceedings and otherwise to the extent required or explicitly permitted by applicable law, including cooperating with law enforcement investigations and requests
- Third-party providers that you authorize, like your health care team or other care related organizations at your direction
- Service providers that support the Services (such as providers of data hosting and analytics services, IT and security vendors, communications and customer service providers, and product fulfilment and delivery vendors) and professional advisors (such as attorneys, consultants, or accountants)
- Third parties within the context of a merger or similar business transaction
- Other third parties at your direction
How We Protect Your Health Data
Zelo has implemented necessary administrative, organizational, and technical measures and safeguards to ensure that your Health Data is protected as required by applicable federal and state privacy laws. We comply with all applicable federal and state data breach notification laws, including data breach notification requirements and as outlined in our data breach notification and reporting policy.
Your Privacy Rights
Depending on your place of residency, you may have some or all of the following rights regarding your Health Data, subject to applicable law and certain exceptions:
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Right to Confirm and Access
If you ask us, we will confirm whether we are collecting, sharing, or selling your Health Data. You may request that we provide you with a copy of the Health Data that we maintain about you. At your request, we will provide a list of all third parties and affiliates with whom we have shared or sold your Health Data.
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Right to Correct
If your Health Data that we maintain is inaccurate and you would like us to correct it, you may request that we make changes to it.
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Right to Withdraw Consent
Where we have relied on your consent or authorization for certain processing of your Health Data, you may withdraw that consent or authorization at any time, including if we requested your authorization to “sell” your Health Data.
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Right to Delete
You may request that we delete the Health Data we maintain about you.
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Right to Appeal
If we deny your request to exercise any of the above rights, you may request to appeal this decision.
To exercise any of the above rights, you or your authorized agent may do so by following the instructions in “Contact Us” below. To process your request, we may ask you to verify your identity by confirming your name, e-mail address, phone number, or other identifiable information that we have in our records, such as your most recent interaction with us, if applicable.
Updates to this Policy
We may update this Policy from time to time and notify you in accordance with law, which may include email or other notice posted to the Services. Any changes to this Policy will become effective when we notify you of the changes. Your use of the Services following any such updates will constitute your acceptance of such updates.
Contact Us
For questions about our Policy, to make choices about receiving promotional communications, or to request to exercise a right described in this Policy, you can contact us through any of the methods listed below:
Email: legal@zelo.ai
Mailing Address: Zelo Health Inc., 2810 North Church Street, PMB 735222, Wilmington, Delaware 19802, United States