MSO Privacy Policy
This Privacy Policy has been adopted by Hinge Health MSO, Inc. and each of the professional service corporations, organizations, associations, subsidiaries and affiliated entities (collectively, “Hinge Health Professional Organizations”) within its national network that may be formed, incorporated, or operating in your state and on behalf of independently-contracted telehealth physicians, physical therapists and/or other clinicians that provide professional healthcare and clinical services (collectively “Hinge Health MSO, Inc.”, “Hinge Health MSO” and “We”, “Us”, or “Our”).
Hinge Health MSO, Inc. is not a health care entity and does not provide clinical services, but is a management service organization that performs marketing, business, and administrative services including data security and privacy management under various state and federal laws on behalf of the licensed health care providers. This reference does not, and is not intended to, imply that any licensed health care provider is an employee of Hinge Health MSO, Inc. or that Hinge Health MSO, Inc. is providing or intends to provide clinical or healthcare services in any form. All clinical and healthcare services are exclusively provided by the appropriate affiliated professional entity, and provided in the healthcare provider’s sole and exclusive discretion.
Hinge Health MSO is deeply committed to protecting the privacy and security of our customers’ data. This Privacy Policy applies to the telehealth services, telehealth website or mobile application (the “Services”) provided by Us.
By consulting with, or soliciting treatment from, the licensed healthcare providers you acknowledge that you accept the practices and policies outlined in this Privacy Policy. “You”, “your”, or similar terms refer to you as a user of the Services. Hinge Health, Inc.’s Privacy Policy governs the use of your information on the Hinge Health, Inc. platforms and websites.
This policy applies only to information Hinge Health Professional Organizations collect as part of the provision of Services. The Services are provided using telehealth, which means that we use electronic communications to enable the Hinge Health Professional Organizations providers to exchange health and medical information from one site to the other for the purpose of treatment or patient care. Before you use the Services, you will be asked to affirmatively provide informed consent for telehealth services. If you do not agree to this informed consent, you are not authorized to access the Services or use our website, and you must promptly exit our website or application.
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.
As used in this Privacy Policy, the terms “using” and “processing” information may include, amongst other things, subjecting such information to analysis, using cookies or web beacons, and managing information in a number of ways, including but not limited to: collection, storing, evaluating, modifying, deleting, using, combining, and/or disclosing.
Hinge Health MSO, Inc. and its affiliated clinical entities are an Affiliated Covered Entity under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Some of the individually identifiable information we collect or that you provide us for purposes of obtaining medical care through the Services may constitute protected health information (“PHI”). PHI is subject to special protections under HIPAA. For more information about your rights under HIPAA, please refer to Hinge Health MSO’s Notice of Privacy Practices. The Notice of Privacy Practices does not apply to information that is not PHI. This Privacy Policy supplements the Notice of Privacy Practices for PHI. If there is ever any conflict between this Privacy Policy and the Notice of Privacy Practices, the Notice of Privacy Practices will apply. 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 privacy@hingehealth.com.
Telephone Consumer Protection Act
Hinge Health MSO, Inc. may provide you with notices, including those related to your enrollment or use of the Services, including but not limited to by email, postal mail, SMS, MMS, text message, or other reasonable means now known or hereinafter developed. By providing Hinge Health MSO, Inc. with your telephone number, this gives Hinge Health consent to send you text messages regarding your purchase(s), or for other non-telemarketing purposes, made by an automatic telephone dialing system.
You understand that you may receive email as part of using the Services, and while Hinge Health encrypts all email communications, your email server may not guarantee encryption. If your email provider does not encrypt email, you accept the risk that some PHI could be acquired by someone else.
You understand that you may receive text messages (SMS) as part of using the Services, such as a reminder about an upcoming appointment. SMS messages are encrypted by Hinge Health MSO, Inc. in transit to your cell phone provider, but cell providers do not guarantee encryption of SMS messages that are stored on your behalf. By using the Services you accept the risk that some PHI could be intercepted by someone else targeting your SMS communications or seen by individuals who have access to your mobile device.
Types of Information Collected
Hinge Health MSO, Inc. collects the following types of information about our website users: automatically collected information and personal information.
Automatically collected information may include the name of the domain used to access the internet; an internet protocol (IP) address, which can reveal geographic information; the date and time of a website visit; URLS of pages visited on Hinge Health’s website; if present and available, the internet address of the website visited before; and characteristics of devices (such as operating system, web browser, and screen resolution).
Personal information includes identifying information such as your name, e-mail address or other contact information, and whether you are enrolled in your employer sponsored group health plan. Hinge Health MSO, Inc. collects other personal information about you through the Services, including when you voluntarily provide it to us, such as your diagnosis, previous treatments, general health, the names of your other health care providers, and any other information you provide to us for purposes of the Services. In connection with your treatment, we may also collect or access medical records from your past, current, and future health care providers. This may include information about your existing or past diagnoses, previous treatments, general health, laboratory or pathology test results and reports, social histories, family medical history, and records about phone calls or emails related to your health or test results. 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.
How to Review and Change Your Personal Information
If you become a patient of a Hinge Health Professional Organizations, you may review your personal information by visiting the Hinge Health mobile applications and accessing the “Settings menu.” To change or remove any information, please contact us through the application, or at privacy@hingehealth.com.
How We Use and Disclose Information That We Collect Online
By using the Services you consent to and authorize Hinge Health MSO, Inc. and its affiliates 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) among themselves and to others, such as to Hinge Health MSO senior management and administrators or your personal Hinge Health, Inc. health coach. 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 Hinge Health MSO’s program. Those entities are required by law to protect your information to the same level that Hinge Health MSO, Inc. does, and we will only share the minimum necessary information with them in order to ensure that you have a great user experience.
Other uses include:
(a) Internal Uses - We may use information we collect about you to:
Administer your account
Allow your health care professional 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 users about the products and services that we offer.
We may combine personal and non-personal information collected by Hinge Health MSO 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 unaffiliated third-party (excluding our vendors or 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, or via scientific research papers regarding our Services. This aggregate information does not contain any identified personal information about our users.
(c) Disclosure of Information by You
Through your use of the Services, you may choose to make certain elements of your information, including PHI that you disclose in the course of engaging with the Services or the services provided by Hinge Health, Inc., available to other participants and users.
Cookies and Web Beacons
Certain Hinge Health MSO, Inc. websites, like many other commercial websites, may use standard technologies called “cookies” and “web beacons” to collect information about how our website is used. Cookies were designed to help a website operator determine that a particular user had visited the site previously and thus save and remember any preferences that may have been set. This information also allows us to statistically monitor how many people are using our website and for what purpose. We may also make use of “persistent” or “memory based” cookies, which remain on your computer’s hard drive until you delete them. You have the ability to modify your browser to either accept all cookies, notify you when a cookie is sent, or reject all cookies, but it may not be possible to utilize our Services if you reject all cookies.
Web beacons are small pieces of code (also called pixels) that are embedded on the pages of websites and that can report your visit or use to a third party. We use web beacons to collect automatic information about our visitors but not personal information. Hinge may use these tools for the purposes of web analytics, marketing, and error management. You may modify your browser to prevent web beacons from collecting automatic information about you.
How We Protect Information Online
We exercise great care to protect your personal information through various administrative, technical and physical safeguards. This includes, among other things, using industry standard techniques such as firewalls, encryption, and intrusion detection for information stored on our systems. 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 while that information is in transit. 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 our 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 Hinge Health MSO, Inc. 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 Hinge Health MSO, Inc. 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.
Children
The Hinge Health MSO, Inc. websites and Services are not designed to be used by or intended to attract children under the age of 13. Individuals who we actually know are under the age of 13 will not be permitted to use the Hinge Health MSO, Inc. websites and Services and we will not collect their personal information. If you are a parent or guardian and you are aware that your child who is under the age of 13 has provided us with identifiable personal data, please contact us. If we become aware that we have inadvertently collected data from children under the age of 13 without verification of parental consent, we will timely remove that information from our servers to the extent permissible by law.
Links to Other Websites
We want to provide website visitors valuable information, services, and products. Featured programs and other Hinge Health MSO, Inc. website content may link our users to third-party websites. Hinge Health MSO, Inc. does not control and is not responsible for privacy or security practices of any third party websites.
Do Not Track
Do Not Track is an optional setting that enables you to express your preferences regarding the collection of information about your online activities over time and across third-party websites. Your browser sends Do Not Track signals to the websites you visit expressing your preference not to be tracked. However, because there is no industry-standard approach to responding to Do Not Track signals, we do not process or respond to Do Not Track signals.
California Residents
If you are a California resident, California law provides you with additional rights regarding our collection, use, and disclosure of your personal information under the California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.), Shine the Light law (Cal. Civ. Code § 1798.83), and Do Not Track law (Cal. Bus. & Prof. Code BPC § 22575). To learn about the personal information we collect, use, and disclose along with information regarding your additional California privacy rights, visit the CCPA Privacy Notice. Please note that the CCPA does not govern medical information or PHI that is collected by a covered entity or business associate that is governed by HIPAA.
Employment Information
This Privacy Policy does not apply to any collection or utilization of employment-related information. If you are a current or former job applicant, employee, owner, director, officer, or contractor of Hinge Health, Inc. or any of the Hinge Health affiliated organizations please contact legal@hingehealth.com for more information.
Note
As we continually update and improve our services, we may periodically make changes to this Privacy Policy. Or, we may modify this Privacy Policy to reflect new changes in laws or regulations. Accordingly, please check back and review this Privacy Policy periodically.
Last updated on December 21st, 2021