Effective January 1, 2023
HIPAA Notice of Privacy Practices
Protecting our consumer and customer information is very important. We safeguard the information of those we serve. AbleTo handles and safeguards Personal Information (as defined below), and we understand the information we hold represents real people and life events.
If you have questions about the AbleTo Privacy Program, please go to our Contact Us section below to connect with us.
We recognize that the privacy of your Personal Information is important. The purpose of this policy is to let you know how we handle the information collected through the use of this website. Portions of this website may describe privacy practices applicable to specific types of information or to information provided on specific web pages.
This policy does not apply to information collected through other means such as by telephone or in person, although that information may be protected by other privacy policies. As used in this policy, terms such as “we,” “us,” “our,” and “Company” refer to AbleTo and its current and future affiliated and associated entities.
Cookies and Tracking
The Company may use various technologies, including cookies, tokens, tags, web logs, web beacons, scripts, and web server logs to gather automatically collected information and may aggregate this information from our website visitors or to enable certain features of our website. This information may include demographic data, technical information about the technology (e.g., phone, computer) used to connect to our website, web browser information, your IP address, and browsing behavior such as pages visited and how often they are visited (“Activity Information”). We may also use third-party analytics companies to provide these services.
Your Personal Information
We may use Personal Information for a number of purposes such as:
- To respond to an email or particular request from you.
- To personalize the website for you.
- To administer surveys and promotions.
- To provide you with information that we believe may be useful to you, such as information about health products or services.
- To perform analytics and to improve our products, websites, and advertising.
- To comply with applicable laws, regulations, and legal process.
- To protect someone’s health, safety, or welfare.
- To keep a record of our transactions and communications.
- As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law.
We may use Personal Information to contact you through any contact information you provide through this website, including any email address, telephone number, cell phone number, text message number, or fax number. Please see the section below titled “Our Online Communications Practices.”
We may also share Personal Information within the Company, and we may combine Personal Information that you provide us through this website with other information we have received from you, whether online or offline, or from other sources such as from our vendors. For example, if you have purchased a product or service from us, we may combine Personal Information you provide through this website with information regarding your receipt of the product or service.
In our capacity as a HIPAA “Business Associate” we may share your Health Information to various health plans. As a HIPAA Business Associate, AbleTo may only collect, use and disclose your Health Information in the ways permitted by HIPAA and health plan partners that we are performing work for.
Sharing Personal Information
We will only share your Personal Information with third parties as outlined in this policy, the Notice of Privacy Practices (as applicable), and as otherwise permitted by law.
We may share Personal Information if all or part of AbleTo is sold, merged, dissolved, acquired, or in a similar transaction.
We may share Personal Information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting activities that are illegal, violate our rules, or may be harmful to other visitors.
We may also share Personal Information with other third-party companies that we collaborate with or hire to perform services on our behalf. For example, we may hire a company to help us send and manage email, and we might provide the company with your email address and certain other information in order for them to send you an email message on our behalf. Similarly, we may hire companies to host or operate some of our websites and related computers and software applications.
We may permit you to view your profile and related Personal Information and to request changes to such information. If this function is available, we will include a link with a heading such as “Profile” or similar words. Clicking on the link will take you to a page through which you may review your visitor profile and related Personal Information.
We will not disclose, share, sell, or otherwise disclose your information to unaffiliated third parties for their own marketing unless so authorized by you, your employer or association, group or benefit program sponsor.
Our third-party affiliates, service providers and successors to whom we disclose information are required by law and/or contractual requirements to keep your personal information confidential and secure. These parties may not use or disclose it except as reasonably necessary to provide services to you, on our behalf, or on behalf of your employer or association, group of benefit program sponsor, or to comply with or as permitted by applicable law.
We may disclose De-Identified Information. “De-Identified Information”, means information that is neither used nor intended to be used to personally identify an individual.
Website and Information Security
We maintain reasonable administrative, technical and physical safeguards designed to protect the information that you provide on this website. However, no security system is impenetrable and we cannot guarantee the security of our website, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet, and we are not liable for the illegal acts of third parties such as criminal hackers.
Our Online Communication Practices
We may send electronic newsletters, notification of account status, and other communications, such as marketing communications, on a periodic basis to various individuals and organizations. We may also send email communications regarding topics such as scheduling reminders, service announcements, privacy notices, administrative notices and other general health topics. We offer you appropriate consent mechanisms, such as opt-out, for marketing and certain other communications. As examples, you may opt out as provided for in a specific email communication or contact us as described below in the section “Contact Us.” Please be aware that opt-outs may not apply to certain types of communications, such as account status, website updates, or other communications.
Information for Children Under 13
We will not intentionally collect any Personal Information from children under the age of 13 through this website without receiving parental consent. If you think that we have collected Personal Information from a child under the age of 13 through this website, please contact us as described below in the section “Contact Us”.
State Consumer Privacy Notice
Depending on which AbleTo product or service you use, and your state of residency, you may have rights as outlined in this Notice.
PI We Collect and Disclose for Business Purposes
In the preceding twelve (12) months, depending on the product or service you have used we may have collected the following categories of PI and have disclosed/shared it for the business purposes described as follows:
(Some Personal Information included in the categories below may overlap with other categories.)
|Category of PI||Examples||Collected||Categories of Third Parties to Which We Disclose PI for Business Purposes||Shared for Advertising Purposes||Categories of Third Parties with Which we Share PI for Advertising Purposes|
|Identifiers||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, or other similar identifiers.||Yes||Contracted Service Providers, Employers, Health Care Providers, Vendors, Insurance Carriers, and other third parties at your request||Yes||Contracted Service Providers|
|Personal information categories||A name, signature, Social Security number, physical characteristics or description, address, telephone number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.||Yes||Contracted Service Providers, Employers, Health Care Providers, Vendors, Insurance Carriers, and other third parties at your request||No||Not applicable|
|Protected classification characteristics||Age, race, color, ancestry, national origin, citizenship, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth, and related medical conditions), veteran or military status, genetic information (including familial genetic information).||Yes||Contracted Service Providers, Employers, Health Care Providers, Vendors, Insurance Carriers, and other third parties at your request||No||Not applicable|
|Sensitive personal data categories||Government-issued identification number, financial account information and account login credentials, precise geolocation information, genetic data, racial or ethnic origin, biometrics data, health data, mental or physical health condition or diagnosis, data concerning sex life or sexual orientation.||Yes||No||Not applicable|
|Commercial information||Products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes||Contracted Service Providers, Employers, Health Care Providers, Vendors, Insurance Carriers, and other||No||Not applicable|
|Biometric information||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No||Not applicable||No||Not applicable|
|Internet and/or network activity||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||Yes||Yes||Contracted Service Providers|
|Geolocation data||Physical location or movements.||No||Not applicable||No||Not applicable|
|Sensory data||Audio, electronic, visual, thermal, or similar information.||No||Not applicable||No||Not applicable|
|Professional or employment-related information||Current or past job history or performance evaluations.||No||Not applicable||No||Not applicable|
|Education information subject to the Family Educational Rights and Privacy Act||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student discip||No||Not applicable||No||Not applicable|
|Inferences drawn from other personal information||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes||No||Not applicable|
We will retain the foregoing categories of PI consistent with our internal record-retention policies and for as long as is necessary to provide products and services to you or as required by law.
PI does not include:
- De-identified or aggregated consumer information
- Publicly available information from government records
- Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996
- (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data
- PI covered by other privacy laws, including: The Fair Credit Reporting Act (FCRA), the Gramm-Leach-Bliley Act (GLBA), the California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994
Categories of Sources of PI
We obtain the categories of PI listed above from:
- You or your authorized agent
- Service providers
- Publicly available information
- Organizations with which you are employed or affiliated, or
- Activity on our apps and websites
Collection from these sources may occur online, in person, via paper or other electronic means, and may occur automatically where state law permits such profiling absent an explicit request to opt-out.
Why We Collect PI
We collect your PI for one or more of the following business purposes:
- To respond to an email or particular request from you
- To communicate with you
- To personalize services for you
- To process an application as requested by you
- To administer surveys and promotions
- To provide you with information that we believe may be useful to you, such as information about products or services provided by us or other businesses
- To perform analytics and to improve our products, websites, and advertising
- To comply with applicable laws, regulations, and legal processes
- To protect someone’s health, safety, or welfare
- To protect our rights, the rights of affiliates or related third parties, or take appropriate legal action
- To keep a record of our transactions and communications
- To detect and protect against security incidents
- To debug to identify and repair errors
- As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law
Sharing Your PI
At times, some of our products or services may share your PI with third parties to display advertisements to you based on your activities, preferences, or interests. If we do this, we will provide that you may opt-out of this activity using our cookie management tool on our website.
In the preceding twelve (12) months, we have not sold any PI.
Third parties are not allowed to use or disclose your PI other than as specified in our contract and as permitted by law.
If we seek to use your PI for a materially different purpose than we previously disclosed in this notice, we will notify you and will not use your PI for this new purpose without your explicit consent.
Sensitive Personal Data
We only process Sensitive Personal Data to render services or offer products to you.
- You have the right to request that we disclose certain information to you about our collection and use of your PI. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- What PI we collect about you
- Where and from whom we collect PI about you
- Our business purpose for collecting PI about you
- The types of third parties with whom we share your PI
- The specific pieces of PI we collect about you, in a readily-usable format—note that we will not disclose your actual Social Security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, or security questions and answers
- The types of PI that we disclosed about you for a business purpose, and the categories of third parties to whom we disclosed your PI
- You have the right to be informed about the PI that we collect about you at the time or before we collect it. This is that notice
- You have the right to request that we delete any PI about you that we have.
- You have the right to request a correction of any inaccurate information in the PI we collect about you.
- You have the right to stop us from sharing your PI to display advertisements to you based upon your activities, preferences, and interests.
- If we use your sensitive PI for purposes other than to render services or offer products to you, you will have the right to request that we limit the processing of your sensitive PI.
- You will not be discriminated against or penalized for exercising your rights to your PI, and we will honor your rights by not:
- Denying you services
- Charging you different prices or rates for services
- Imposing penalties, or
- Providing you with a different level or quality of services
- Applicable law may require or permit us to decline your request. If we decline your request, we will tell you why and you may appeal this decision (see additional information in the Appeals section below).
How to Exercise Your Rights
- You may exercise your rights by emailing us at firstname.lastname@example.org or writing us at:
320 West 37th Street, 5th Floor
New York, NY 10018
Attn: Chief Privacy Officer
- If we do share your PI, you may opt-out of the sharing of your PI by using our cookie management tool on our website
- You may be required to submit proof of your identity for these requests to be processed.
- We will not be able to comply with your request if we are unable to confirm your identity.
- You may designate an authorized agent to make a request on your behalf subject to proof of identity and authorization.
- We will acknowledge receipt of your request within 10 days of receipt of your submission. You will receive our response to your request within 45 days of your request unless we provide you with notice that it will take more than 45 days to respond (in that case, we won’t take more than 90 days to respond).
- If the business denies any of your requests, you may appeal by emailing us at email@example.com or writing to us at the address above.
- We will respond to your appeal within 45 days of receipt unless we notify you that we will require an additional 15 days to respond.
- If you remain concerned about the result of that appeal, you may contact the attorney general in your state of residency.
We may change this policy. If we do so, such change will appear on this page of our website. We will also provide appropriate notice and choices to you, on this website and in other appropriate locations, based on the scope and extent of changes. You may always visit this policy to learn of any updates.
Social Security Number Protection Policy
Protecting Personal Information is important to AbleTo. It is our policy to protect the confidentiality of Social Security numbers (“SSNs”) that we receive or collect in the course of business. We secure the confidentiality of SSNs through various means, including physical, technical, and administrative safeguards that are designed to protect against unauthorized access. It is our policy to limit access to SSNs to that which is lawful, and to prohibit unlawful disclosure of SSNs.