What We Collect.
We collect and use the following information to provide, improve and protect our website (“Site”):
- Information you provide. We may collect the content and other information you provide when you use our Site, including information like your name, email address, or phone number when you submit them to us. You may also choose to provide feedback on our Site or contact us for support, and we will keep a record of that communication. To the extent that you disclose to us any personal information of another individual, you represent that you have obtained such individual’s consent for the disclosure of such personal information, as well as the processing of the same in accordance with the terms of this Policy. We may collect Personal Identification Information from you in a variety of ways, including, but not limited to, when you visit our Site, fill out a form, and in connection with other activities, services, features or resources we make available on our Site.
- If you are using our Site as an applicant for employment, we may also collect information you voluntarily submit pursuant to the requirements of the job posting, such as educational information and professional or career related information.
- Things you do. We also may collect information about how you use our Site or otherwise interact with us. We collect information from or about the computers, phones, or other devices you use to access the Services, depending on the permissions you’ve granted. Here are some examples of the device information we may collect: attributes such as the operating system, hardware version, device settings, file and software names and types, battery and signal strength, and device identifiers; device locations, including specific geographic locations, such as through GPS, Bluetooth, or WiFi signals; and connection information such as the name of your mobile operator or ISP, browser type, language and time zone, mobile phone number and IP address. By using our Site, you agree to the publication of your IP address on this Site. Our Site is a location-aware website. When using our Site we may ask you to share information about your location. If you voluntarily agree to share that information with us, we will collect that information from nearby wireless access points and your computer’s IP address
- Information from third-party partners. We may receive information about you and your activities on and off the Site from third-party partners, such as analytics from Google.
How We Use Collected Data.
We collect and use the data described above for the following purposes:
- To Personalize Your Experience. We may use information in the aggregate to understand how you and our other users as a group use the services and resources provided on our Site. For such purposes data are collected for traffic optimization and distribution, analytics, and interaction with external social networks and platforms.
- To Improve our Site. We continually strive to improve our website offerings based on the information and feedback we receive from you. We may also use this information to provide better services to you, such as providing tailored content.
- To Improve Customer Service. Your information allows us to more effectively respond to your customer service requests and support needs, to send you marketing communications, communicate with you about our services and to let you know about our policies and terms. We also use your information to respond to you when you contact us. We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and overall quality of our services.
- To Treat You. We can use your health information and share it with other professionals who are treating you.
- To Bill for Your Services. We can use and share your health information to bill and get payment from health plans or other entities.
- To Help with Public Health and Safety Issues. We can share health information about you for certain situations such as:
- Preventing disease
- Helping with product recalls
- Reporting adverse reactions to medications
- Reporting suspected abuse, neglect, or domestic violence
- Preventing or reducing a serious threat to anyone’s health or safety
- To Do Research. We can use or share your information for health research.
- To Comply with the Law. We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law. We can share health information about you in response to a court or administrative order, or in response to a subpoena.
How Protect Your Data.
We adopt appropriate data collection, storage and processing practices and security measures to protect against unauthorized access, alteration, disclosure or destruction of your personal information, username, password, transaction information and data stored on our Site. We restrict access to information about you to those employees who need to know that information as part of their job responsibilities. We also educate our employees about the importance of confidentiality and customer privacy through standard operating procedures, special training programs, and our Code of Conduct. We take appropriate disciplinary measures to enforce employee privacy responsibilities. We have developed precautions that comply with federal regulations to ensure the security and confidentiality of customer records and information, to guard against any anticipated threats or hazards to the security or integrity of such records, and to protect against unauthorized access to or use of such records or information which could result in substantial harm or inconvenience to our customers or our employees. In the unfortunate event of a data security breach, we will notify Users whose Personal Identification Information may have been breached.
Protected Health Information. When you interact with our website Site, you may choose to provide protected health information (“PHI’). We are committed to maintaining the confidentiality of your PHI pursuant to the Health Insurance Portability and Accountability Act of 1996 (‘HIPAA”). We are required by law to maintain the privacy and security of your protected health information. We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information. We must follow the duties and privacy practices described in this notice and give you a copy of it. We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind. Your provider’s responsibilities are further covered in the Practice Agreement, which would be provided to you if you start using one of our services.
With Whom We Share Data.
- Our service providers. Among other things, our services provide information about health and wellness professionals. If you request contact, we may share your information with one or more of the professionals in our community to contact you.
- With Your Consent. We may request your consent to share personal information about you with additional third parties.
- To Comply With Applicable Law. We may disclose your information to third parties if we determine that such disclosure is reasonably necessary to (a) comply with the law; (b) protect any person from death or serious bodily injury; (c) prevent fraud or abuse of SohoMD or our users; or (d) protect SohoMD's property rights.
- Aggregated and Non-Personal Information. We may also share with third parties information in a manner that does not identify particular individuals, for example, information that has been aggregated with other records.
The Rights of Data Subjects. Those persons to whom the data refer have the right, at any time, to know whether their data has been stored and can consult the data controller to learn about their contents and origin, to verify their accuracy or to ask for them to be supplemented, cancelled, updated or corrected, or for their transformation into anonymous format or to block any data held in violation of the law, as well as to oppose their treatment for any and all legitimate reasons. Requests should be sent to email@example.com.
Children's Privacy. We do not knowingly collect or solicit any information from anyone under the age of 13 or knowingly allow such persons to become our user. The Site is not directed and not intended to be used by children under the age of 13. If you're aware that we have collected personal information from a child under age 13 please let us know by contacting us and we will delete that information.
International Transfer. Your information may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction. Regardless of where your data is stored, it will be maintained securely as outlined in this policy.
Your Acceptance of These Terms. By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.
Contacting Us. You can contact our Data Protection/HIPAA Privacy Officer with questions, concerns or objections about this policy, or about your data by writing to:
Privacy Notice for California Residents
This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the SohoMD Privacy and its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.||YES|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||YES|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||No|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||YES|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Personal information does not include:
- Publicly available information from government records.
- De-identified or aggregated consumer information.
- Information excluded from the CCPA's scope, like:
- ohealth or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- opersonal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from our clients or their agents. For example, from documents that our clients provide to us related to the services for which they engage us.
- Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.
- Directly and indirectly from activity on our website. For example, from submissions through our website portal or website usage details collected automatically.
- From third-parties that interact with us in connection with the services we perform.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business or marketing purposes:
- To create your account on our Site and let you log in to your account and use the Site.
- To manage your account, provide you with customer support, and ensure you are receiving quality service.
- To contact you or provide you with information, alerts and suggestions that are related to the service.
- For billing-related purposes.
- To reach out to you, either ourselves or using the appropriate authorities, if either we or a Provider have a good reason to believe that you or any other person may be in danger or may be either the cause or the victim of a criminal act.
- To match you with a Provider.
- To enable and facilitate the Provider Services.
- To supervise, administer and monitor the service.
- To measure and improve the quality, the effectiveness and the delivery of our services.
- Market the Site and Provider Services to you.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- To provide, support, personalize, and develop our Site and Provider Services.
- To personalize your Site experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Websites, third-party sites, and via email or text message (with your consent, where required by law).
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosure of Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share the minimum necessary personal information with the following categories of third parties:
- Service providers that provide audit, legal, operational, technical or other services for us, such as:
- Customer service
- Technical maintenance
- Monitoring website activity
- Email management and communication
- Database management
- Billing and payment processing
- Reporting and analytics
- Marketing and advertising
- Provider who provide the Provider Services under your Practice Agreement
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
- Calling us at 212-369-6757
- Emailing us at firstname.lastname@example.org
Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.
If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:Data Protection/HIPAA Privacy Officer
104 West 40th Street, Ste 500
New York, NY 10018