Privacy Policy Effective Date: July 24, 2023
At TCARE Inc., we are committed to protecting the privacy of our users. This Privacy Policy outlines how we collect, use, disclose, and protect the information provided by users of our Software as a Service (SaaS) web solution. By accessing or using our solutions, you agree to the terms outlined in this Privacy Policy.
About this Privacy Policy and Our Commitment to Your Privacy
TCARE, Inc.("TCARE", "we”, “us", "our") provides online products and services (collectively, the “Services”) through our mobile applications and tcare.ai and/or mytcare.ai (collectively, the “Site”) that may, among other things, provide you with tools to engage in supportive care management for persons that require care assistance (for chronic illnesses and other situations). We provide this privacy policy (“Privacy Policy”) to outline the information TCARE collects from users of the Site (“Users”, “you”), TCARE Partners (defined below), and how we may use and disclose this information when the Site is accessed through any device. It also describes the choices available to you regarding our use of your information and how you can manage and update this information. Some online services offered by or affiliated with TCARE may be governed by a separate privacy policy. We suggest you review each of the privacy policies for the services you are wishing to receive.
Your Consent to this Privacy Policy by Using the Site
As described in this Privacy Policy, we may use and disclose your information to provide you with products and services and to improve your experience using those products and services. By using the Site, or any other website, online service, or mobile application where this Privacy Policy is posted, you agree to our collection, use, disclosure, and storage of information as described in this PrivacyPolicy.
Third-Party Advertising on Our Site
We do not allow third parties to advertise to Users on our Site unless you provide consent, which is not requested in this Privacy Policy.
How to Contact Us with Questions about this Privacy Policy
Please read this Privacy Policy carefully. If you have questions and/or complaints regarding our PrivacyPolicy or privacy practices, please contact us at Attn: Chief Privacy Officer,TCARE, Inc., 511 North Garrison Avenue, Saint Louis, MO 63103, or security@tcare.ai.
Information Addressed by this Privacy Policy
We want you to have a clear understanding of the information addressed by this Privacy Policy. We will collect information about you (“Information”) in a variety of ways, including directly from you, through automatic means, or from third parties.The information that is collected depends on how you use the Site.
Personal Information and Privacy
When you use our Services, you may be creating and maintaining a personal, private area of the application (“Individual Team”) on behalf of yourself and/or one or more persons within your care team (“Care Team”), or visiting and posting to an Individual Team created by someone else within your Care Team. By their very nature, theseIndividual Teams contain a great deal of personal information about the subject of the Individual Team and other Users on the Care Team. Our goal is to balance our Users' need to find each other and communicate information and support against our Users' desire for a measure of privacy. By establishing anIndividual Team, you represent that you have all consents and authorizations necessary to use the information relating to members of your Care Team necessary to establish an Individual Team.
Site Access
The Individual Team is accessible “By Invitation Only.” Once established, every member of a Care Team, including the creators of Individual Teams and all Users are responsible for maintaining the confidentiality of the Individual Team by the care recipient’s wishes.
Information You Provide Directly to TCARE
You may provide certain information directly to us when you use the Site. For example, without limitation, when you choose to register a user account, you will be required to provide, among other things, your e-mail address, name, and phone number. When you create a Care Team, we may collect identifying information about members of the Care Team and the caregiver, such as the caregiver’s work status and living situation. We also collect information about how the supporter can help the care recipient. We may use this information to suggest services that may be of use to the caregiver or care recipient. When you use our Resource Locator(Connect) or Assist Screener, we may collect information regarding your past and present medical history (i.e., diagnosis, medical events, medications, etc.). We may also collect financial information to determine eligibility for certain programs and benefits. Finally, we may collect information regarding your insurance coverage and benefits.
Certain Information in the Services is Visible to Other Users
Information regarding the care recipient’s needs and actions are taken, and updates may be shared among and be available to Care Team members but are not publicly visible to other Users outside of the Care Team.
Information that is Automatically Collected
We and third parties may use automated means to collect information about you, your computer, or another device that you used to access the Site and your use of the Site. These automated means include common technologies such as cookies or similar technologies. These technologies help us analyze trends, administer the Site, track Users’ movements around the Site, gather demographic information about our user base, and otherwise provide you with relevant content (e.g., by gathering your zip or postal code). We may receive reports on an individual as well as aggregated basis based on the use of these technologies by TCARE, and any third-party vendors acting on TCARE's behalf.
Information We Collect from Third Parties
TCARE enters into business relationships with business partners including healthcare providers and/or networks of healthcare providers ("Providers"), health plans or health insurers, including, without limitation, employer-sponsored health plans ("Health Insurers"), and companies that contract with Providers, Health Insurers, and/or TCARE ("Contractors") to makeTCARE’s products and services available to Users who are patients of suchProviders or enrollees, members, or participants of such Health Insurers orContractors. TCARE’s business partners such as Providers, Health Insurers, andContractors are collectively referred to in this Privacy Policy as "TCAREPartners." When you use the Services, we may collect information about you, directly or indirectly, from or through applicable TCARE Partners as well as other Users of the Services. With your consent, we may also collect Information from other third parties.
Cookies and Tokens
Cookies are files that websites send to your computer or another Internet-connected device to uniquely identify your browser or to store information or settings on your device. OurSite may use HTTP cookies, HTML5 cookies, Flash cookies, and other types of local storage (such as browser-based or plugin-based local storage, or application-based local storage on a mobile device). You may be able to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all the features of our Site. Our cookies, tokens, and similar technologies (collectively, "Tracking Technologies") also are used for administering the Site, including without limitation, for authentication, remembering Users’ settings, customizing the content and layout of the Site for Users, contact you about the Site, and to improve our internal operations, the content of our Site and our services. Users may be able to control the use of or reject or disable, some Tracking Technologies at the individual browser level. If you reject or disable Tracking Technologies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. We use Tracking Technologies to identify your device and keep track of your Internet session with our Site. Using these Tracking Technologies, we may automatically end your session on our Site after a period of inactivity (as determined by us in our sole discretion). We also use Tracking Technologies that allow us to recognize your device when you return to the Site within a certain period (as determined by us at our sole discretion)and automatically log you back into your account with us. UNLESS YOU AFFIRMATIVELY LOG OUT of your account before YOUR SESSION ENDING (whether by you or by us), YOU WILL BE AUTOMATICALLY LOGGED BACK IN THE NEXT TIME YOU ORANY USER OF YOUR DEVICE VISITS OUR SITE within the period determined by us. If you do not wish to be automatically logged back in when you (or someone using your device) next initiate a session with our Site (using the same device that is being used for your current session), you should log out of your account (i)before ending your session, or (ii) if you will be inactive on our Site for more than a few minutes.
Web Logs
In conjunction with the gathering of data through cookies, Web servers may log records such as your device type, operating system type, device advertising identifier, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The Web server logs also may record the address of the Web page that referred you to our Site, the IP address (and associated city and state or province for the IP address)of the device you use to connect to the Internet, and data about your interaction with our Site, such as which pages you visit.
Pixels/Web Beacons
To control which Web servers, collect information by automated means, we may place tags on our Webpages or in our app called "Web beacons" (or “pixels”), which are files that associate certain behavior with a session or user. We also may include Web beacons in e-mail messages to record whether an email has been opened or whether certain links in such email have been clicked. We or third parties may also send instructions to your device using JavaScript or other computer languages to store or gather the data described above and other details about your interactions with the Site. We may use third-party pixels on the Site’s registration and login pages. For example, we may use these pixels to assess your progress in registering for our Site. If you start but fail to complete the registration process, we may also use third-party pixels to deliver reminders to complete your registration. We may also use these pixels to deliver notices about new and existing features on our Site. These reminders and notices may appear on other websites, and third parties who provide the pixels may use the information obtained from pixels for their business purposes.
Online Analytics
We may use third-party web analytics services on our Site, such as those of Google Analytics. These service providers use the sort of technology described in this “Information that is Automatically Collected” section to help us analyze how Users use theSite, including by noting the third-party Web site from which Users arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Site.
Mobile Application Technologies
Our mobile applications may also collect information specific to the use of your mobile devices, such as unique device identifier and, with your consent, precise geolocation information, motion coprocessor data (e.g., recording information such as steps, distance, and elevation), accelerometer data (showing whether you're stationary or moving), and gyroscope data. We may also use third-party analytics, such as those Google Analytics. Collection ofInformation Across
Personal Devices and Applications
Sometimes, we (or our service providers) may use the information we collect—for instance, log-in credentials, IP addresses, hashed email addresses, and unique mobile device identifiers—to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, to better tailor content, features, and advertising(for TCARE on other sites), and provide you with a seamless experience across the devices you use to access our services.
Our Use of Information Use and Storage of Information to Provide You with the Site and Related Services
TCARE, and any third party vendors acting on TCARE's behalf, may use and store your Information to perform activities associated with providing you with the Site and related services such as: (i) registering you to use the Site and otherwise logging you into the Site, including the authentication of your identity, where applicable, and otherwise enabling your access to the Site; (ii) resolving disputes and/or troubleshooting problems including logging into your account to troubleshoot problems or otherwise help you navigate the Site; (iii) verifying your compliance with your obligations in our Terms of Service or other TCARE policies; (iv) improving the quality of the Site, (v) fulfilling any request you make; (vi) communicating with you; (vii) connecting you with and providing you with information about services, providers of services, resources or programs to which you may have access; (viii) providing you with Site content, including, without limitation, generating recommendations (such as recommendedSite activities or services), providing caregiver navigation services, creating action plans for caregivers, helping caregivers anticipate the needs of the care recipient, and processing your preferences and requests; (ix) analyzing, customizing, and personalizing the Site, including through the delivery of tailored content and communications; and (x) otherwise as directed by you or provided for herein. Except where prohibited by law, and only to the extent permitted by TCARE’s agreements with applicable TCARE Partners, we may also use your Information in connection with any other services we make available to you.
Additional Information Regarding Use of Information for Communications with You
If you choose to tell a friend about our Service or share an Individual Team through our Site, we will ask you for your friend's name and email address or phone number. We will automatically send your friend a one-time email or text message inviting him or her to visit the Site. We retain this information to identify the User as part of the care team when they sign in.TCARE, TCARE Partners, and any third-party vendors acting on TCARE's behalf may also use yourInformation to communicate with you (including, without limitation, via email and/or mobile push notifications) about the Site and/or our products and services (and related features and functionality) or those of any TCARE Partner that is providing services to you. Our communications to you will include, without limitation, contacting you by SMS text message or at the email address(es) that you use to register for our Site to communicate with you regarding the Site and actions that you take in connection with the Site. Your Choices
Regarding Our Communication with You
By applicable law, we will offer you the opportunity to opt-out of certain communications, such as, for example, communications that deal with any of our products or services you are not using but that we think might be of interest to you. Where applicable, you can opt-out by emailing us at info@tcare.ai. However, even if you opt-out of such communications, you may continue to receive other transactional, relationship, and/or administrative communications from or through TCARE that are important or related to your TCARE account or the products and services you are using (such as, for example, a notice that there has been a change in one of your services or a change to this Privacy Policy). Please also note that you, not TCARE, have control over certain settings for how communications such as emails and push notifications are displayed on your devices, and the settings you select will affect how TCARE’s communications are displayed.
Creation and Use of Combined Data, De-Identified Data, and Aggregated Data
As permitted by law and by TCARE’s agreements with applicable TCARE Partners, TCARE, and any third-party vendors acting on TCARE’s behalf, may aggregate and/or de-identify yourInformation and/or combine your Information with other information maintained or available to TCARE and use or disclose such information as follows: We may use aggregated or combined data to communicate with you about the Site and/or our products and services and disclose such aggregated or combined data to TCARE Partners in connection with providing the Site.We may also use and disclose de-identified data, de-identified aggregated data, and/or de-identified combined data for any business purpose, which may include, without limitation, improving our products and services, conducting analytics such as evaluating our Site and developing additional benefits, programs, and services, and disclosing to TCARE Partners for analytics purposes. Disclosure ofInformationWe may share yourInformation in the following circumstances:
· Disclosures to Service Providers and TCARE Partners
With the limited exceptions discussed below, we do not share your information with third parties, unless you tell us to. We will not share your personal information under any circumstance with any third parties to allow them to conduct direct marketing to you. In this section, we describe the potential uses of your information in greater detail.With Third Parties That Provide Requested Benefits: As stated above, we primarily share your information, including your personal information, with third parties to provide certain benefits that you request. Specifically, at your direction, we will submit your information to the appropriate third parties for purposes of filling your third-party service requests. For example, if you are interested in transportation or caregiver navigation services, then we will share your information, at your direction, with third parties that work withTCARE to provide transportation or caregiver navigation services, which may fit your particular needs. The third party, not TCARE, will evaluate your eligibility to obtain service from its program. The third party's use of your personal information will be governed by the third party's terms of service and privacy policy, not TCARE's; TCARE does not have any control over your information once it is submitted to a third party for receipt of benefits. While we work with reputable third-party service providers, we cannot represent how any of them will use your personal information in connection with their services and recommend that you review their terms of use and privacy policies before requesting their services. To Perform Services on Our Behalf: We may hire vendor companies to provide limited services on our behalf, such as payment processing, sending postal and electronic mail, providing technical support, and assisting us in providing the products and services that you request from us. We only provide those service providers with the information necessary to perform the requested service.
· Additional Disclosures with Your Consent
With your consent outside of this Privacy Policy, we may share your Information with third parties or allow them to collect information from the Site in some ways not specifically described in this Privacy Policy.
· Safety, Security, and Compliance with Law
Your Information and the contents of your communications through the Site may be disclosed to third parties as required by law, such as to comply with a subpoena or similar legal process, or when we reasonably believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, report improper or unlawful activity, or respond to a government request. · Subsidiaries and Affiliated CompaniesExcept where prohibited by law or precluded by contract, we may share your information with any subsidiaries or other affiliated companies under the control of, or under common control with, TCARE for the purposes set out in this Privacy Policy.
· Sale, Merger, or Similar Transaction
We may share yourInformation in connection with any proposed or actual merger, reorganization, sale of some or all our assets, financing or acquisition of all or a portion of our business by another company, or to a receiver, trustee, or successor in interest in bankruptcy, in which case such company may continue to process yourInformation as outlined in this Privacy Policy (except where prohibited by law)or otherwise with your consent.
We Do Not Control the Privacy Policies of Third Parties
Our Site may contain links that enable you to visit or use other third-party websites, resources, or programs. However, we do not have control over the other websites, resources, or programs that you choose to visit, so this Privacy Policy does not apply to information collected or that you provide while visiting such other websites, resources, or programs. You should refer to the privacy policies, if any, applicable to the other websites, resources, or programs. Data Security andIntegrityThe security of yourInformation is important to us. We follow security standards to protect theInformation submitted to us from loss, interference, misuse, unauthorized access, disclosure, alteration, or destruction, both during transmission and once we receive it. These safeguards vary based on the sensitivity of theInformation that we collect, process, and store and the current state of technology. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. We also maintain procedures to help ensure that such data is reliable for its intended use and is accurate, complete, and current. If you have any questions about data security and integrity on our Site, you can contact us at security@tcare.ai.
Be sure to Log Off When Using Public or Third-Party Computers
As described above, we use Tracking Technologies that automatically log you back into your account with us unless you affirmatively log out of your account before your session ends (whether you end your session or we end your session, for example, if our Site has "timed out" – i.e., we have ended your session automatically after a period of inactivity as determined by us in our sole discretion). If you log into the Site using a public computer or device, or a computer or device of that belongs to or is shared with another person, you should affirmatively log out of your account. Otherwise, the next computer or device user may be able to access your account and your information if your session has not ended. Your Use of Persistent
Login
The login in our application is persistent. We recommend that you log out after use of the application if you are concerned about the unauthorized use or disclosure ofInformation via persistent login.
Managing and Updating Information
To access, review, update and/or delete certain Information, you may contact us at info@tcare.ai, and you may update and/or delete certain Information by logging into the Site and updating your account. We will respond to your request within a reasonable and lawful timeframe under the circumstances of your request. Please remember, however, if we have already disclosed some of this Information to third parties, we cannot access that Information any longer and cannot force the deletion or modification of any such Information by the parties to whom we have made those disclosures. Additionally, if you modify certain Information on our Site that we received from a third party, we reserve the right but are not obligated, to share the updated information back to that third party. As a result, you will need to provide updated information to those third parties if you want to be sure they have your updates.Certain Information is necessary for us to provide the Site and our related Services; therefore, if you delete such necessary Information, you will not be able to use the Site or receive our Services. If you wish to have your account deactivated, you may contact us at info@tcare.ai. After we receive your request, within a reasonable timeframe under the circumstances of your request, we will deactivate your account; provided, however, that: 1) TCARE (and our third-party vendors acting on our behalf), our TCARE Partners, and any other applicable third parties may continue to use and share for any purpose de-identified data and aggregated or combined data developed using your Information that has been de-identified and 2) TCARE may continue to use Information in your deactivated account for compliance with applicable regulations. Also, please note that even though you may deactivate your account or request the deletion of your Information, we maybe required (by law or otherwise, such as to prevent fraud, resolve disputes, or troubleshoot problems) to retain this information, in case we will comply with your deletion request only after we have fulfilled such requirements. We may also keep a copy of your Information to protect our legal rights, such as in connection with your use of the Site or your agreement to our Terms of Service, as permitted or required by applicable law.
California Do-Not-TrackDisclosure Requirements (for California Users)
We are committed to providing you with meaningful choices about the information collected on our Site for third-party purposes. However, we do not recognize or respond to browser initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.
Your California Privacy Rights (for California Users)
California law permits customers of TCARE who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us:TCARE, Inc. 511 North Garrison Avenue, Saint Louis, MO 63103 or email: security@tcare.ai.We will provide a list of the categories of personal information, if any, disclosed to third parties during the immediately preceding calendar year for third-party direct marketing purposes, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or postal address specified above. You should put "California Privacy Rights" in the subject line and your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.
Children; Special California Notice
The Site and Services are not directed to children under the age of 18, and children under the age of 18 years of age are not eligible to use them. Protecting the privacy of children is very important to us. Through the Site and Services, we do not collect Information from people we know are under 18 years of age, and no part of the Site or Services is designed to attract people under 18 years of age. If we later learn that an individual has provided us with their information through the Site or Services and they are under 18 years of age, we will take steps to remove that User's Information from our databases and to prevent theUser from utilizing the Site or Services. If you are a California resident under the age of 18 and are a registered User of our Site, you may request that we remove from our Site any content you post to our Site that can be accessed by any other User (whether registered or not). Please note that any content that is removed from our Site may remain on our servers and in our systems. To request the removal of content under this provision, please send an email to info@tcare.ai and provide us with a description of the content and the location of the content on our Site, and any other information we may require considering your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Site by you.
Uses and Disclosures as Required or Permitted by Law, Including Research, Health Care Operations, and Public Health
To the extent not prohibited by law or precluded by TCARE’s agreements with the applicable TCARE Partner, TCARE, and any third-party vendors acting on TCARE’s behalf, may use and disclose your Information: (a) as required or permitted by law, including, where applicable, the Health Insurance Portability and Accountability Act of1996 (“HIPAA”), which may include disclosures to the applicable TCARE Partner;(b) for Research purposes; (c) for purposes of Health Care Operations of the applicable TCARE Partner; and (d) for Public Health, as each is defined and by HIPAA.
Retention of Personal Data
Personal data will be retained only for so long as reasonably necessary for the purposes set out in this Privacy Policy, considering criteria such as applicable rules on statute of limitations and at least the duration of your use of our Site and Services.Information may persist in copies made for backup and business continuity purposes for additional time.
Modifications to this Privacy Policy
From time to time, we may update this Privacy Policy to reflect changes to our information practices.If we make changes to this Privacy Policy, they will be reflected in an updated Privacy Policy that will be posted on the Site, and all changes will be effective upon such posting or upon any later date specified by us in writing.We encourage you to periodically review this page for the latest information on our privacy practices. You can determine when this Privacy Policy was last revised by referring to the "Effective Date" legend at the top of this Privacy Policy. By continuing to use the Site or any services following the effective date of any updated Privacy Policy, you are agreeing to be bound by the terms and conditions of such updated Privacy Policy.
About contact upload
Contact upload is an optional feature that allows us to check which of your contacts in your device's address book are also TCARE users. It also means we can update your TCARE contact list when your contacts who aren't using TCARE yet sign up later. We care about your privacy and we don't share your contact list with other Companies for their use, even when they provide us with services. When you use contact upload and grant TCARE access to your device address book,TCARE will access and upload the phone numbers in your address book typically daily, but this depends on various factors including how often a user usesTCARE, including those of TCARE users and your other contacts. We don’t collect any of the other information that could appear in your device address book including names, email addresses, etc. If any of your contacts aren’t yet usingTCARE, we protect their privacy by managing the phone number in a way that is designed to prevent those contacts from being identified by TCARE.
About gallery and photos upload
Photos and Gallery on both IOS and Android are the features that allow us to check the photos in the gallery when access is provided. It also means that the TCARE users have an option where the TCARE users can disable or enable the option. TCARE uses the photo and Gallery simply to upload a profile picture and is also used in the chat where share the scanned image from your photo gallery. Since all the chat is end-to-end encryption, the photos are not shared or used. We don’t share your gallery lit with other companies for their use.
Camera and microphone
In IOS, the user must explicitly grant permission for each app to access cameras and microphones.Before your app can use the capture system for the first time, IOS shows an alert asking the user to grant your app access to the camera, as shown below.IOS remembers the user’s response to this alert, so subsequent uses of the capture system don’t cause it to appear again. You will only need to request consent the first time your app accesses the camera. The user can change permission settings for your app in Settings > Privacy.
