Last Updated: July 8, 2021
Children’s Online Privacy Protection Act
Minors under eighteen (18) years of age, without parental consent, are prohibited from using the Prevail Health Services. If you are under 18 years old, please do not provide personally identifiable information of any kind whatsoever on the Prevail Health Services. We do not intentionally gather Personally Identifiable Information from visitors who are under the age of 13 or have any reasonable grounds for believing that children under the age of 13 are accessing the Prevail Health Services. If we learn that we have inadvertently collected personally identifiable information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under age 13, please contact us at firstname.lastname@example.org.
Types of Data We Collect
We collect “Non-Personal Information” and “Personally Identifiable Information.” Non-Personal Information includes information that cannot be used to personally identify you, such as anonymous usage data, general demographic information we may collect, referring/exit pages and URLs, platform types, preferences you submit and preferences that are generated based on the data you submit and number of clicks. “Personally Identifiable Information” means data that could allow someone to identify or contact you, including, for example, your name, address, telephone number, e-mail address, as well as any other non-public information about you that is associated with or linked to any of the foregoing data.
Personally Identifiable Information
We use your Personally Identifiable Information that you provide to us in order to provide the Prevail Health Services. The personally identifiable information we may collect includes the following:
- A home or other physical address, including street name and name of a city or town
- An email address
- A cell phone number
- Demographic information such as ethnicity, preferences and interests
- Other information relevant to product related surveys, personal well-being, intervention schedule and activity ratings
Prevail Health requires this information to understand your needs and provide you with better service, including for the following reasons:
- Internal record keeping
- Offering you certain products and services
- Improving our products and services and perform maintenance on the Prevail Websites
- Connecting you with third party service providers with whom we have partnered, when you specifically elect this option and affirmatively direct us to do so
- Send you notifications and reminders through text message and email
- Provide collaborating third parties with statistical information related to the Prevail Health Services gathered from the Prevail Website as well as publically available information about you. In some instances Prevail Health may share selected engagement and clinical improvement metrics with partners, when requested. The information will not be used to identify any individual participant without their consent and will be in compliance with our HIPAA notice where applicable.
- To notify you about changes to your usage or related services or to ask you to provide feedback.
- To enable you to partake in a prize draw, competition or complete a survey.
- To administer and protect our business and the Prevail Websites (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data).
- For those who apply for employment with Prevail Health, in order to process your employment application, including background checks and education and employment verification, as applicable.
- To comply with all applicable laws or legal processes, including providing information on individual users to the appropriate governmental authorities where required by law enforcement or judicial authorities.
- In matters involving a danger to personal or public safety, to protect the rights, property or safety of Prevail Health, our members, customers, or others, Prevail Health may voluntarily provide information to appropriate governmental authorities.
Prevail Health makes community boards, discussion lists, group discussions and moderated chats available to its users. Any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your Personally Identifiable Information. Although users are anonymous posting messages that contain personal information is prohibited, Prevail Health does retain a record of who posts all notes.
At times, the Prevail Health Services may use certain Personally Identifiable Information to make automated decisions about which programs and services to offer you, or may alter the programs and services based on those decisions. Information used to make automated decisions may include (but is not limited to), age, ethnicity, gender, location, clinical or other assessment scores, or other information supplied to us from you via your use of the services. Prevail Health does not share this information, or the automated decisions made from it, with any third party without your express consent.
Controlling Your Personally Identifiable Information
Access to Personally Identifiable Information you provided in your Account is readily available through the Prevail Websites profile editing tools. You may modify, update, correct, or delete your Prevail Health profile information at any time by logging into your account. Information will be updated immediately. We may retain all information you submit for backups, archiving, prevention of fraud and abuse, analytics, satisfaction of legal obligations, or where we otherwise reasonably believe that we have a legitimate reason to do so.
We will not sell or lease your non-aggregated personally identifiable information to third parties without your affirmative consent unless required to do so by law, including those situations set forth in our HIPAA Notice.
You may request details of Personally Identifiable Information which Prevail Health holds about you or request that Prevail Health delete your Personally Identifiable Information. If you would like a copy of the information Prevail Health holds about you, please email your request to: email@example.com with the email subject as “Personal Information Query.”
If you believe that any information Prevail Health is holding about you is incorrect or incomplete, please contact us as soon as possible at the email address above. We try to answer all inquiries within a reasonable time frame but may not always be able to do so, unless required by law.
You may decline to share certain Personally Identifiable Information with us, in which case we may not be able to provide to you some of the features and functionality of the Prevail Health Service. You may also request that you and your Personally Identifiable Information be removed from the Prevail Health system. Prevail Health account deactivation is handled by us. Please email firstname.lastname@example.org to have your account deactivated and removed, once this is completed your account will become immediately inaccessible, including any unclaimed reward points.
You may also request that you and your Personally Identifiable Information be removed from the Prevail Health system. Prevail Health account deactivation is handled by us. Please email email@example.com to have your account deactivated and removed, once this is completed your account will become immediately inaccessible, including any unclaimed reward points.
Protected Health Information
You expressly acknowledge that you have read and understood our HIPAA Notice, which provides important information to you about how we may use and disclose health information about you.
Disclosure of Personally Identifiable Information
We may share your Personally Identifiable Information with third-party service providers to: provide you with the Prevail Health Services that we offer you through the Prevail Websites; to send you reminders of appointments or notifications concerning your Account; to conduct quality assurance testing; to perform marketing; to run data analysis; to facilitate creation of accounts and our Rewards Program; to provide technical support; and/or to provide other services to Prevail Health.
We are committed to using commercially reasonable efforts to ensure that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place appropriate electronic and managerial procedures to safeguard and secure the information we collect. If you elect to register on the Prevail websites, you will create a unique username and password. Prevail Health does not have access to your password; if you lose or forget your password you will need to reissue yourself a new password. Passwords must include a minimum of 8 characters, contain capital and lowercase letters, and at least one digit to reach Prevail Health’s minimum-security standard.
The Prevail Websites have security measures equal to or better than those reasonably expected in the industry (such as firewalls, etc.) in place to protect against the loss, misuse and alteration of your Personally Identifiable Information under our control. While we cannot guarantee that loss, misuse or alteration to data will not occur, we take reasonable precautions to prevent such unfortunate occurrences. Certain particularly sensitive information, such as your credit card number, collected for a commercial transaction is encrypted prior to transmission.
You are ultimately responsible for the security of your Prevail Health login credentials. You may not share your Prevail Health login credentials with colleagues or friends so they can access content or features that are restricted to you. You should log out of your browser at the end of each computer session to ensure that others cannot access your Personally Identifiable Information and correspondence, especially if you share a computer with someone else or are using a computer in a public place like a library or internet cafe.
Potential Exposure of Prevail Health Protected Data or Sensitive Data
Data breaches are increasingly common occurrences. Prevail Health has a robust and systematic process for responding to detected or reported data security incidents or breaches. Our standardized processes and procedures help to ensure the security and limit exposure to the data collected. Prevail Healths goal is to act responsibly, respond effectively if an occurrence happens, and protect the information to the highest degree possible.
As soon as a theft, data breach, or exposure containing Prevail Health’s protected data or sensitive data is detected and identified, the process of removing all access to that resource will begin.
Prevail Health will begin immediate steps to protect and secure the data. Prevail Health has a specific action plan for the prevention, detention, and securing of all data.
If your data potentially may be affected by a data breach or theft, or exposure containing your Personally Identifiable Information, Prevail Health will notify you of the exposure and next steps.
How Long We Retain Your Data
We will keep hold of your data for no longer than necessary for business purposes. The length of time we retain it will depend on any legal obligations we have (such as tax recording purposes), the nature of any contracts we have in place with you, the existence of your consent or our legitimate interests as a business.
International Data Transfers
Please be advised that at this time Prevail Health does not comply with the U.S.-EU Safe Harbor Framework and the U.S.-Swiss Safe Harbor Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of Personally Identifiable Information from European Union member countries and Switzerland (http://www.export.gov/safeharbor/) and, as such, people residing in countries subject to such frameworks should not make use of the Prevail Health Services.
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We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic and improve the Prevail websites in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from our system.
Overall, cookies help us provide you with a better Prevail website experience, by enabling us to monitor which pages you find useful and which you do not. A cookie does not give us access to your computer.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the Prevail websites.
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Required Disclosure to California Residents.
If you are a resident of California and have used the Prevail Health Services, you have the right to request in writing, (1) a list of the categories of information, such as name, address, e-mail address, and the type of services provided to the customer, that we have disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. To request the above information, please email us at firstname.lastname@example.org with a reference to California Disclosure Information.