Noho Medical, Inc. (“Noho”) is deeply committed to protecting the privacy and security of our customers’ data.
This policy applies to information we collect:
- Through the Services; and
- In email, text, or other electronic messages between you and any employee or agent of Noho.
This policy does not apply to the actions of any company or entity that we do not control and to individuals who we do not directly employ or manage.
Some of the information we collect may constitute protected health information (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), as amended by the Health Information Technology for Economic and Clinical Health Act of 2009 (“HITECH”). To the extent other state or local privacy and data protection laws apply to your data, we will comply with those requirements as well.
Should you have any questions about this policy or our practices, please send an email to firstname.lastname@example.org.
What Information We Collect
Noho collects your personal information through the Services only when you voluntarily provide it to us. If you choose to go through our screening process and/or register for the Services we ask you to provide personal information, including but not limited to: your name, address, telephone number and/or email address, height, weight, and health information in connection with the use of our products or services. We also collect information that will allow you to establish a username and password. You may choose not to provide us with certain information, but that may result in our inability to provide you access to the Services.
What Information We Disclose
By using the Services you consent to and authorize Noho to disclose your eligibility for and participation in the Services (i.e. that you meet the enrollment criteria for the Services and that you have elected at your own discretion to participate) to others, including: Noho senior management and administrators, your personal Noho coach and other users of Noho’s Services. In particular, these entities may be able to access a range of information about you, such as your first and last name, picture and participation in Noho’s program. Moreover, based on Noho’s deployment model, you may be placed into a group of users with similar characteristics who may be co-workers or acquaintances (your “Peer Group”) who will be able to view such information. Only information you explicitly consent to be visible to the peer group will be shared. By default, only your first name is shared, and you may choose to use a pseudonym instead of your real first name.
How to Review and Change Your Personal Information
If you become a Noho account, you may review your personal information by visiting the Noho mobile applications and accessing the “Settings menu.” To change or remove any information, please contact us through the application, or at email@example.com.
How We Use Personal Information That We Collect Online
(a) Internal Uses - We may use information we collect about you to:
- Administer your account, including your assignment and enrollment in your Peer Group;
- Allow your Noho Coach to personalize your experience;
- Provide you with access to particular tools and services;
- Respond to your inquiries and send you administrative communications;
- Obtain your feedback on our websites and our offerings;
- Statistically analyze user behavior and activity;
- Provide you with more relevant content;
- Conduct research and measurement activities;
- Send you personalized emails or secure electronic messages pertaining to your health information; or
- Contact you about the products and services that we offer.
We may combine personal and non-personal information collected by Noho about you, and may combine this information with information provided by external sources.
(b) Disclosure of Personal Information to Third Parties
We will not disclose any personal information about any of our users to any third-party (excluding our contractors to whom we may provide such information for the limited purpose of providing services to us and who are obligated to keep the information confidential), unless: (1) you have authorized us to do so; (2) we are legally required to do so, for example, in response to a subpoena, court order or other legal process and/or, (3) it is necessary to protect our property rights related to this website. We also may share aggregate, non-personal information about website usage with unaffiliated third parties. This aggregate information does not contain any personal information about our users.
(c) Disclosure of Information by You
Through your use of the Services, you may choose to make your information, including PHI that you post and/or disclose in the course of engaging with the Services, available to other participants and users. While we take considerable efforts to protect your privacy, we cannot take and expressly disclaim responsibility for whether and how other users, including your Peer Group, will use or disclose information disclosed by you through the Services. As discussed above, the Services provide you the ability to share personal information, including regarding your medical condition and history to your Peer Group. Any information you voluntarily choose to provide through the Services may be visible to your Peer Group and Noho Coach. As such, you should only provide information you feel comfortable disclosing to other members of your Peer Group and Noho Coach.
Personal Information does not include “aggregate” information. Aggregate information is data we collect about a group or category of services or users, from which individual customer identities have been removed. In other words, information about how you use a service, or the results of such use, may be collected and combined with similar information others, but no Personal Information will be included in the resulting data. Noho can extract statistical data from your content in order to provide it to other users or partners without connecting it to any personal data such as name or e-mail address. Aggregate data helps us understand trends and user needs so that we can better consider new products and services, and tailor existing products and services to customer desires. You understand that we may commercialize aggregate information by any and all means, and that you will receive no payment or other consideration in respect of such use. We will not use or disclose to third parties user data gathered from the HealthKit API or from health-related human subject research for advertising or other use-based data mining purposes other than improving health, or for the purpose of health research.
How We Protect Information Online
We exercise great care to protect your personal information through various administrative and physical safeguards. This includes, among other things, using industry standard techniques such as firewalls, encryption, and intrusion detection. However, while we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us or receive from us. This is especially true for information you transmit to us via email since we have no way of protecting that information until it reaches us since email does not have the security features that are built into our websites.
In addition, we limit Noho’s employees’ and contractors’' access to personal information. Only those employees and contractors with a business reason to know have access to this information, and then may only access or use the minimum necessary for the task at hand. We educate our employees about the importance of maintaining confidentiality of user information.
We also periodically review our security arrangements and safeguards.
How can you help protect your information?
If you are using a Noho website or mobile application for which you registered and choose a password, we recommend that you do not share your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited email. Always remember to sign out of the Noho website and close your browser window when you have finished using the Services. This is to ensure that others cannot access your personal information and correspondence to us if others have access to your computer or mobile device.
We are committed to protecting the privacy of children. The Noho websites are not designed to be used by or intended to attract children under the age of 18. Individuals who we actually know are under the age of 18 are not permitted to use the Noho websites and we will not collect their personal information.
Links to Other Websites
We want to provide website visitors valuable information, services, and products. Featured programs and other Noho website content may link our users to third-party websites. Noho does not control and is not responsible for privacy or security practices of any third party websites.
December 3rd, 2019