Privacy Policy

Last Revised: 06/29/2022

Telegenixx, Inc. (“Telegenixx” or “we,” “our,” or “us”) respects your privacy and are committed to protecting it through our compliance with this Privacy Policy (“Policy”).

This Policy describes how we collect, use and disclose personal information (defined below) about you through the use of our website at www.telegenixx.com (the “Site”), any mobile application we may provide (“App”), through any platform and services we provide to assist you in managing your medical care and treatment (“Services”) and through e-mail, text, and other electronic communications between you and Telegenixx. We will refer to the Site, App and Services collectively as the “Services.”

Scope of the Policy

This Privacy Policy applies to information we collect through the Services, in e-mail, text, and other electronic messages between you and our Services; and when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

It does not apply to: information collected by us offline or through any other means, information collected by any third party, including any Health Care Provider (as defined below) or any application or content (including advertising) that may link to or be accessible from or on the Services, the collection and use of certain employment-related information or the practices of companies we do not control.

Personal Information

The term “personal information” used in this Policy means any information that relates to an identified or identifiable individual, and includes protected health information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

Acceptance of Policy

Please read this Policy carefully to understand our policies and practices regarding your personal information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using the Services, you agree to this Policy.

Changes

We reserve the right to change this Policy from time to time. We will post such changes on the Site. We may also notify you at the e-mail address provided in your account. Your continued use of our Services after we make and post or notify you of changes is deemed to be acceptance of those changes, so please check this Policy periodically for updates.

Health Care Providers

The Services allow you to upload your medical information and interact through telehealth with licensed physicians, medical care practices and other health care providers (“Health Care Providers”). Telegenixx does not own, employ or in any way supervise or control the Health Care Providers, and does not provide any medical care, treatment or advice. We are not responsible for the privacy practices of the Health Care Provider or their use of your personal information.

Telegenixx is not a covered entity subject to HIPAA. However, the personal information provided by Health Care Providers in connection with the Services may be protected health information that is subject to HIPAA and the Health Information Technology for Economic and Clinical Health Act of 2009 (“HITECH”). When we receive PHI, we may do so as a “business associate” of the Health Care Provider under an agreement that, among other things, prohibits us from using or disclosing the PHI in ways that are not permissible by the Health Care Provider itself, and requires us to implement certain measures to safeguard the confidentiality, integrity, and availability of the PHI. When we act as a Business Associate, we may be subject to certain laws and regulations, including certain HIPAA rules, that govern our use and disclosure of PHI and that may be more restrictive than otherwise provided in this Policy.

Information We Collect About You and How We Collect It

We collect personal information about you either directly from you or from Health Care Providers in which you interact through the Services. The personal information we collect may include the following:

Your name, postal address, billing address, shipping address, e-mail address, telephone numbers (home, work, and mobile), credit or debit card number (for payment purposes only), social security number, driver’s license or other governmental identification number and other personal information necessary to set up your account with us, to set up appointments, make payments for prescriptions and others and permit telemedicine with your Health Care Providers.
Your medical records and other health information (including applicable patient numbers) that you or your Health Care Providers may upload to the Services, which include information relating to the diagnosis and treatment of medical and health conditions and your prescriptions.
Information that you provide by filling in forms on the Services. This includes information provided at the time of registering to use the Services, completing a questionnaire, or requesting further Services.
Information that you provide when you report a problem with the Services.
Records and copies of your correspondence (including e-mail addresses) with us.
Your responses to surveys that we might ask you to complete.
Details of transactions that may be tracked through our Services.
Recordings of any telehealth consultations conducted through the Services (we will request your opt-in to such recordings before making them).

Information We Collect from Health Care Providers

Health Care Providers may also register to use our Services. If you are a Health Care Provider, we will collect the following information:

Your contact information, including your name, practice group name, license information, postal address, billing address, shipping address, e-mail address, telephone numbers (home, work, and mobile), and other personal information necessary to set up your account with us, to set up appointments, make payments for your services and prescriptions you provide, and to permit telemedicine with your patients.
Information that you provide by filling in forms on the Services. This includes information provided at the time of registering to use the Services, completing a questionnaire, or requesting further Services.
Information that you provide when you report a problem with the Services.
Records and copies of your correspondence (including e-mail addresses) with us.
Your responses to surveys that we might ask you to complete.
Details of transactions that may be tracked through our Services.

Health Care Providers may upload personal information, including protected health information, of their patients. Health Care Providers are solely responsible for ensuring (a) that the uploading and sharing of such personal information complies with all applicable laws, including, but not limited to, HIPAA and (b) that they have provided all required notices (including HIPAA Privacy Notices) and obtained all necessary consents and authorizations to collect, use, and share such personal information with Telegenixx and the Services.

Information Collected Through Automated Technologies

We also collect certain information when you access and use the Services or navigate our Site or App, including:

details of your visits to our Services, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Services, error information, clickstream data, and other communication data and the resources that you access and use on the Services; and
information about your computer, mobile device, and other equipment used to access our Services and your internet connection, specifically your IP address, operating system, device ID , and browser type.

We collect this information (a) directly from you when you provide it to us; (b) automatically as you navigate through the Services through cookies, web beacons, geo-location services, and other tracking technologies; and (c) from third parties, for example, our service vendors.

The information we collect automatically may include personal information or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve Services and to deliver a better and more personalized service by enabling us to: estimate our audience size and usage patterns; verify your location to ensure we can provide you with our Services; store information about your preferences, allowing us to customize our Services according to your individual interests; recognize you when you return to our Services.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting, you may be unable to access certain parts of our Services. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Services.

There are two types of cookies: session and persistent cookies.

Session Cookies. Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site.
Persistent Cookies. Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity. For example, our Services and e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to count users who have visited those pages, used those screens, or opened an e‑mail and for other related statistics (for example, recording the level of engagement with certain content and verifying system and server integrity).

Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies,” which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google AdWords or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics, please visit Google's website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.

How We Use Your Information

We use your Personal Data for various purposes described below, including to:

Provide Our Services

We use your information to provide the Services, facilitate interactions (including telemedicine) with Health Care Providers, communicate with you about your use of our Services, fulfill your orders and process transactions for purchases you make, respond to your inquiries, and provide customer service, track administration of care coordination transactions and initiation of Health Care Provider services you request, contact you in response to a request, notify you about changes, and provide you with notices about your account.

Provide Personalized Services

We use your information to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Services.

Improve and Develop Our Services

We use your information to ensure our Services are working as intended, operate our business, better understand how users access and use our Services, both on an aggregated and individualized basis, develop, maintain, protect and improve our Services, and perform research and analytics, including to analyze and report on usage and performance of our Services.

Offer Promotions

We use your information for marketing and promotional purposes. For example, we may use your information, such as your e-mail address, to send you news and newsletters, special offers, and promotions, to conduct contests and sweepstakes, or to otherwise contact you about products or information we think may interest you. We may use how you browse in order to show you ads that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. We also may use your information for us and our affiliates, business partners, and select third parties to target, offer, market, or advertise products, programs, or services. We will not, however, use any PHI subject to HIPAA for marketing purposes without your prior written authorization. For information on how to opt-out of such communications and marketing, please see Opting Out of Disclosure and Use of Your Information.

Compliance

We may use your information to detect, investigate, and prevent activities on our Services that may violate our Terms of Use, could be fraudulent, violate copyright, or other rules or that may be otherwise illegal, comply with legal requirements, carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for administration of care coordination transactions, defend or exercise legal claims, respond to law enforcement or governmental investigations or requests, and protect our rights and the rights and safety of our users and others.

Other Uses

We may use your information to fulfil any other purpose for which you provide, notify you about changes to our Site or any care coordination services, in any other way we may describe when you provide the information and for any other purpose with your consent.

Retention of Personal Information

We will keep your personal information for as long as it remains necessary for the identified purpose or as required by law, which may extend beyond the termination of our relationship with you. We may retain certain data as necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non‑personally identifiable data, account recovery, or if required by law. Unless otherwise set forth in the applicable Terms of Use or a separate agreement with you, if you cease using the Services, we may retain or destroy, at our discretion, all personal information and non-personally identifiable information we collect through your use of such Services. All retained information will remain subject to the terms of this Policy.

Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Policy. We disclose your Personal Data in the following cases:

to Health Care Providers that you designate to provide their services to you;
to contractors, service providers, and other third parties we contract with to support our business and perform functions on our behalf. The services provided by these organizations include but are not limited to, providing IT and infrastructure support services, marketing, and payment processing services. If any personal information is considered protected health information, it is only shared with contractors, service providers, and third parties who are required to contractually comply with applicable state and federal privacy laws.
to a buyer or other successor in the event of 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 personal information held by us is among the assets transferred;
to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to enforce our rights, exercise or defend legal claims, enforce or apply our and other agreements, including for billing and collection purposes; and
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our Health Care Providers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction to comply with our legal obligations; or
with your consent.

We may disclose aggregated and de-identified information about our users, and information that does not identify any individual, without restriction.

Opting Out of Disclosure and Use of Your Information

We have created mechanisms to allow users to control certain uses of their personal information as set forth below:

Tracking Technologies and Advertising. You can set your browser or operating system to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Site may then be inaccessible or not function properly.

Promotional E-mails. If you do not wish to have your e-mail address used by us to send you marketing and promotional e-mails, you can opt-out at any time by clicking the unsubscribe link at the bottom of any e-mail or other marketing communications you receive from us or logging onto your Account profile page. If you wish to opt-out of such communications, please change your preferences in your account page or e-mail us at [support@telegenixx.com].

Targeted Advertising. We may belong to ad networks that may use your browsing activity across participating websites to show you interest-based advertisements on those websites. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

Your Rights Regarding Your Personal Information

You may request access to, review and change your personal information by logging into the Services and visiting your Account profile screen or by e-mailing us at [support@telegenixx.com], except that you cannot change data that is entered into your medical record by your Health Care Provider. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate any request if we believe it would violate any law or legal requirement or cause the information to be incorrect. If you are a California resident, you may have additional rights under Your California Privacy Rights section below.

Requests Under HIPAA

You may have certain rights under HIPAA. Please note that any requests under HIPAA must be made to your Health Care Provider. If we receive a HIPAA request, we will forward it to your Health Care Provider for a response. We will comply with HIPAA requests only as directed by a Health Care Provider and as required in our role as a business associate.

Do Not Track Signals

Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such signal is broadcast or received.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we endeavor to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Services. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services or in your operating system.

Children Under the Age of 18

Our Services are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Services. We will remove any information about a child under the age of 18 if we become aware of it

Your California Privacy Rights

If you are a California resident, you may have additional rights under the California Consumer Privacy Act (“CCPA”). For example, you may have the right to:

request that we disclose what personal information we collect, use, disclose, or sell;
request that we delete the personal information we have collected from you, subject to certain rights we have to retain such information under the CCPA;
request that we not sell your personal information (please note that we do not sell your personal information as that term is defined the CCPA); and
not be discriminated against for exercising your rights under the CCPA.

You can exercise your rights under the CCPA by e-mailing us at [support@telegenixx.com].

We will need to verify your identity before we can respond to requests to know and requests to delete. If you have an account with us that is password-protected, we may verify your identity through our existing authentication practices for your account.

If you do not have an account with us, and your request concerns “categories” of personal information collected, we can request from you two data points of personal information to verify your identity. If you do not have an account with us, and your request concerns specific pieces of personal information, we can request from you at least three data points of personal information as well as a signed declaration with penalty of perjury to verify your identity.

As a California resident, you have the right to designate an agent to exercise these rights on your behalf. We may require proof that you have designated the authorized agent to act on your behalf and to verify your identity directly with us. Please contact us at [support@telegenixx.com] for more information if you wish to submit a request through an authorized agent.

We have not yet collected personal information from California residents such that we are required to provide a notice at collection. However, we anticipate collecting the following categories of personal information: identifiers, personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)), protected classification characteristics under California or federal law, commercial information, internet or other similar network activity, geolocation data, sensory data, professional or employment-related information, and inferences drawn from other personal information.

We expect to collect this information for the purposes described in this Policy from users, Health Care Providers and service providers, and to disclose such information to Health Care Providers and service providers, and as otherwise set forth in this Policy.

In addition, California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Services that are California residents and who provide personal information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. You may request this information once per calendar year. To make such a request, please send an e-mail to [support@telegenixx.com] or by using the Contact Information below.

Changes to Our Privacy Policy

We may change this Privacy Policy at any time. We will post any changes to our Policy on our Site. If we make material changes to our Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes. The date this Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable e-mail address for you, and for periodically visiting our Website and reviewing this Privacy Policy to check for any changes.

Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Site.

How to Contact Us: [support@telegenixx.com]

+1 (202) 979-9697

Privacy Policy