Last Updated: July 22, 2024
This Privacy Policy & Notice of California and Other State Privacy Rights, together with our Terms of Service and any other document referenced (whether by means of a hyperlink or otherwise) in this Privacy Policy or our Terms of Service, governs your access to, and use of, the websites, mobile applications and other products and services (collectively, the “Services”) that are provided by Simpl Healthcare, Inc., a Delaware corporation, and its affiliates and subsidiaries (“Simpl,” “we” or “us”).
We are committed to maintaining the privacy of information that you provide to us when using the Services. We aim to simplify healthcare processes while committing to the protection of your data and personal information. This Privacy Policy describes how we treat information we receive or obtain about you when you visit our websites, use our Services, or otherwise interact with us. We are focused on optimizing patient care and providing healthcare professionals with comprehensive data for informed decisions and streamlining communication among patients, providers and payers through the use of our proprietary platform.
If you are a patient using the Services, please also refer to the “Patient Facing Terms of Use” in our patient portal. If any provision in this Privacy Policy conflicts with any provision in the Patient Facing Terms of Use accepted by a patient, the provision in your Patient Facing Terms of Use will control to the extent of such conflict.
We have a limited relationship with the patients of our provider customers. If we receive inquiries or requests from our customers about your Personal Information (as defined below), we will honor those requests as required by applicable data privacy laws. We will also direct patients to our customers, the controller of their personal information.
We may make content or services from other Web sites, including our affiliated or co-branded Web sites, available to you from links located on the Services. These other Web sites are not subject to this Privacy Policy. We recommend that you review the privacy policy at each such Web site to determine how that site protects your privacy. We have no control over these Web sites and are not responsible or liable for the policies and practices followed by these other Web sites. The personal data you choose to provide to or that is collected by these other Web sites is not covered by this Privacy Policy.
General: When you use the Services, sign up to receive emails from us, and at other times, we may ask you to provide us with certain categories of personal information, including health information. Personal information is information that could reasonably be used to identify you personally, such as your name, date of birth, age, gender, occupation, industry, interests, e-mail address(es), physical address, telephone number(s), profession, facts about your computers and other devices through which you access the Services, health information, such as diagnoses, treatments, prescriptions, and other healthcare-related information relating to you and your providers, any information we receive from the applicable third parties when you register or otherwise interact with the Services by means of such third parties, and similar information (collectively, to the extent we collect it from time to time, and together with Survey Information (as defined below) and Usage Information (as defined below), “Personal Information”). We may collect this information through various forms and in various places, including account registration forms, contact us forms, or when you otherwise interact with us.
Credit card information: If you use a credit card to sign up for the Services, the credit card information you provide for the Services is stored and used by our third-party credit card processors in order for them to process your payments.
Usage Information: We automatically collect IP addresses, Web site usage information and other technical information regarding your interaction with the Services (“Usage Information”). This information helps us evaluate how our users access and navigate our Web sites on an aggregate basis, including the number and frequency of users to each Web page, the length of their visits, the web browser version they use, and any publications or other information that they download.
Testimonials: We may display personal testimonials of satisfied users on our Web sites from time to time. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, please contact us at contact@simplhealthcare.com.
Technical Information: We also collect certain technical information, as described below under the heading “Additional Technical Information We May Collect.”
Our primary goal in collecting your Personal information is to provide you with an enhanced experience when using the Services. We may use information about you, including Personal Information in the following ways:
We may use information about you for the purposes for which you specifically provided the information including, for example: to enable us to process, validate and verify subscriptions; to send you e-mail notifications about our new or existing products and services, special offers, or to otherwise contact you; to send you e-mail notifications, through companies who work on behalf of we, about certain approved third-party products and services (unless we tell you differently, these companies do not have any right to use the Personal Information we provide to them beyond what is necessary to assist us); to enhance existing features or develop new features, products and services; to provide advertisers and other third parties with aggregate information about our user base and usage patterns; to allow us to personalize the content and advertising that you and others see based on personal characteristics or preferences; to enable you to participate in drawings or other special offers.
We may combine the information that we collect from you with information that you provide to us in connection with our other products, services and Web sites, including marketing those products, services and sites to you.
We use web analytics services (which may include, but are not limited to, Google Analytics) to analyze how users use our Web sites. These services may use javascript, cookies or other tools that include cookies that we place on your computer or mobile device. We and our service providers use these tools to collect information about your usage of our Web sites, such as your IP address, the name of your internet service provider, your operating system and other computer or mobile device information and statistics, the URL for the Web pages you visit and how long you spent on those pages, how you arrived at our pages, and the date and time you visited. The information generated about Web site usage may be transmitted to Google Analytics or other service providers and used for a variety of purposes, including, without limitation, to improve our Web sites, prevent fraud, evaluate users’ use of our Web sites, complete statistical reports on Web site and user activity, provide other related services, and enable, improve and support our marketing programs. This information may be stored on servers located in the United States or elsewhere. For more information about Google Analytics or the Google Analytics opt-out browser add-on, go to https://tools.google.com/dlpage/gaoptout.
You are responsible for maintaining the accuracy of the information you submit to us, such as your user preferences and contact information provided as part of subscription registration. If your Personal Information changes, you may correct, delete inaccuracies, or amend information by making the change in your profile on-line, or by contacting us by email at contact@simplhealthcare.com . We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable.
We will retain your Personal Information for as long as your account with the Services is active and as needed to provide you the Services. Even after your account is terminated, we will retain your Personal Information as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account (such as addressing chargebacks from your credit card companies), investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reasons as we deem appropriate.
At times we may use third party network advertisers to deliver ads to you on our behalf. We may also use third-party service providers to contact you on our behalf, or facilitate some aspects of the Services or fulfill your purchase requests. These network advertisers and service providers may be supplied with or have access to your Personal Information solely for the purpose of providing these services to us or on our behalf, to the extent permitted by applicable law.
We may disclose and use Personal Information at our discretion without notice for any reason that we have previously disclosed to you or with your consent, unless such disclosure is prohibited by law. We may disclose and use Personal Information in special circumstances where it is necessary to enforce our contracts or our Terms of Service (for example, when necessary to protect our intellectual property rights).
We may also disclose or use your Personal Information when we believe that the law requires us to do so. For example, we may be obligated to release your Personal Information pursuant to judicial or other government subpoenas, warrants, or other orders. We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your Personal Information, including disclosure to third parties such as government or law enforcement officials or private parties, as we reasonably determine is necessary and appropriate: to satisfy any applicable law, regulation, subpoenas, governmental requests or legal process; to protect the safety, rights, property or security of we, the Services, or any third party; to detect, prevent or otherwise address fraud, security or technical issues; and to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, or legally actionable activity. Further, we may use IP addresses or other unique identifiers for computers, tablets, smartphones or other devices used to access the Services, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion.
We contract with other companies to provide services on our behalf, including credit card and billing processing, ad serving, email distribution, list processing and analytics or promotions management. We provide these companies only with the information they need to perform their services. These service providers are restricted from using your Personal Information in any way other than to provide services for us, except for certain anonymized, aggregated statistical data.
We may share your information, including your Personal Information, with our parent company, subsidiaries and affiliates for internal reasons. We also reserve the right to disclose and transfer all such information to a subsequent owner, co-owner or operator of the Services, or in connection with a corporate merger, consolidation, restructuring, the sale of all or substantially all of our membership interests, equity interests, shares and/or assets or other corporate change, including during the course of any due diligence process.
Any and all of the foregoing disclosures may be carried out without notice to you.
If you are located anywhere outside of the United States, please be aware that information we collect, including Personal Information, will be transferred to, processed and stored in the United States and possibly other countries. The data protection laws in the United States or those other countries may differ from those of the country in which you are located (and may be less protective of your Personal Information than the country in which you are located). Your Personal Information may be subject to access requests from governments, courts, or law enforcement in the United States or those other countries according to laws of the United States or those other countries. By using the Services or providing us with any information, you consent to this transfer, processing and storage of your information in the United States or those other countries.
We are committed to achieving and maintaining customer trust. Integral to this mission is providing a robust security and privacy program that carefully considers data protection matters.
We are subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). We also commit to cooperate with European Union (EU) data protection authorities (DPAs) with regard to customer data and human resources data transferred from the EU.
We are required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. To the extent permitted by applicable law, we commit to inform our users in the event of an information request regarding their Personal Information.
We commit to resolve complaints about our collection or use of your personal information. Persons with inquiries or complaints regarding our Privacy Policy should first contact us by email at contact@simplhealthcare.com.
We do not currently have a mechanism in place for responding to browser “do not track” signals or other similar mechanisms.
Device Information: We may collect non-personal information about the computer, mobile device or other device you use to access the Services, such as IP address, geolocation information, unique device identifiers, browser type, browser language and other transactional information.
Analytics, Log Files and Reading History: We may gather certain information automatically and store it in log files. This information may include Internet protocol (IP) addresses (the region or general location where your computer or device is accessing the Internet), browser type, operating system and other usage information about the use of the Services, including a history of the pages you view.
Cookies: We may employ cookies or other technology to help users move faster through our Web site and for the other purposes described above. When you sign on to our Web sites or take advantage of several key features, we may pass cookies to your computer. A cookie is a string of information that is sent by a Web site and stored on your hard drive or temporarily in your computer’s memory (please read our Cookie Disclosure Statement below for more information on our use of cookies).
Security: The Personal Information we collect about you is stored in limited access servers. We will maintain commercially reasonable safeguards to protect the security of these servers and your Personal Information. However, no security technology or system is impenetrable. We cannot guarantee the security of our systems or databases, nor can we guarantee that your Personal Information will not be intercepted while being transmitted to us over the Internet or wireless communication.
Other Information: We (directly, or through third parties that support our distribution of emails and related matters) use a variety of technical means, which may include, but are not limited to, pixels, cookies or transparent GIF files, to help manage online advertising. These files may be provided by one or more of our advertising management partners. These files enable we and those partners to recognize a unique cookie or other script associated with or on your Web browser, which in turn enables us to learn which advertisements bring users to our Web sites. The information that we collect and share through such means is anonymous and not personally identifiable. It does not contain your name, address, telephone number or email address.
We employ cookies at we to, among other things, allow you to move quickly through the Services. Below you’ll find information describing our most common uses of cookies, which are an inherent part of our production, communication and distribution processes and have enabled us to better serve our users.
What’s a cookie? A cookie is a small file that is sent to your computer by a site’s server. A cookie can be a record of your visit to our Web sites, including information such as your user name, registration information, time of last visit, pages viewed, etc. Cookies created by the servers of one site can be retrieved only by that site’s servers.
We use cookies for a variety of purposes, including, without limitation, to allow you to move quickly through the Services, and to evaluate users’ use of our Web sites, complete statistical reports on Web site and user activity, provide other related services, and enable, improve and support our marketing programs. We accomplish this in many ways, using several different cookies. When you first enter one of our Web sites or otherwise access the Services, for example, we may use a test cookie to confirm your browser’s ability to retain cookies. Other cookies that you might receive are from we or our third-party service providers or third-party network advertisers. These network advertisers may use their own cookies in order to serve ads on our Web sites, to reduce the likelihood that you see the same ads over and over again.
Some of the advantages of cookies include:
Will the cookies we send to your devices go away? Some cookies are long term. Some cookies expire after a short period of time. Cookies are small files (just a few hundred bytes) and should not pose any significant disk-space concerns. You are, of course, free to clear cookies from your devices at any time.
Can you set your browsers to not accept cookies or to alert you each time you receive one? Most browsers can be set to alert users each time a cookie is passed to the applicable device.
We incorporate this section to identify additional consumer protections that were recently established under California law.
When you use the Service, we may automatically collect personal information such as technical data about the device that you are using and your browsing patterns. We collect this information by using cookies, server logs and similar technologies. You may choose to give us additional personal information, such as your name, employer, address, email and telephone number. We also collect the following information from you when you provide us with video responses: (1) your video and audio likeness, (2) the city and state in which you live, (3) information you voluntarily provide to us in your video responses, and (4) inferences made based on items (1), (2) and (3).
We use this personal information in several ways, including providing our services to our customers, monitoring website activity, and enabling you to communicate with us and request information.
We disclose (which may constitute a “sale” under California law) the following information to our customers: (1) your Personal Information, including healthcare information, (2) the city and state in which you live, (3) other information you voluntarily provide to us, and (4) inferences made based on items (1), (2) and (3). Other than according to the foregoing sentence, we do not and will not sell the personal information that we collect from you through the Service, as described in this Privacy Policy.
We will not charge or penalize you for requesting information and otherwise exercising your rights as described in this Privacy Policy, but we may reasonably limit the number of requests you may make and impose appropriate charges as permitted by law.
In some instances, you may request that we delete your personal information, consistent with your general right to request that we, as a business, delete any of your personal information that we have collected from you. We will comply with your requests to the fullest extent allowed by applicable law.
If you use an authorized agent to request information or exercise your rights, that authorized agent must meet the same authentication requirements that apply to the requests that we may receive directly from you. We may verify requests made by authorized agents to ensure security and comply with regulations and our internal policies.
Mandatory California Privacy Disclosures
We also make the following disclosures for the purpose of complying with California law:
Your California Privacy Rights
To exercise any of the rights list below, please email us at contact@simplhealhcare.com.
Colorado law provides Colorado residents with the following rights. To exercise any of these rights, please email contact@simplhealthcare.com.
Connecticut law provides Connecticut residents with the following rights. To exercise any of these rights, please email contact@simplhealthcare.com.
Right to Opt Out of Targeted Advertising and Sale of Personal Data. You have the right to “opt out” of “targeted advertising” and the “sale” of your “personal data” (as each of those terms is defined by Connecticut law).
Utah law provides Utah residents with the following rights. To exercise any of these rights, please email contact@simplhealthcare.com.
Right to Opt Out of Targeted Advertising and Sale of Personal Data. You have the right to “opt out” of “targeted advertising” and the “sale” of your “personal data” (as each of those terms is defined by Utah law).
Virginia law provides Virginia residents with the following rights. To exercise any of these rights, please email contact@simplhealthcare.com.
We may change this Privacy Policy from time to time. We will post any changes here and revise the “Last Updated” date accordingly, so be sure to check back periodically. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of Personal Information you have provided to us, we will attempt to obtain your consent before implementing the change. Except as stated in the preceding sentence, any changes will be effective when we post them here, and your use of the Services after we post any changes means you consent to those changes.
We provide our users the opportunity to opt-out of receiving communications from us and our business partners. To remove your information from our database, please send an e-mail request to contact@simplhealthcare.com.
You can change or modify information you previously provided to us by sending an email to contact@simplhealthcare.com.
If you have any comments or questions about this Privacy Policy, our privacy practices, the Services, or your dealings with us, you can contact us at contact@simplhealthcare.com.
