Hinge Health, Inc. ("Hinge Health") is committed to protecting the privacy and security of our customers' data. To that end, we operate in compliance with all applicable privacy and data protection laws including 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").
This policy applies to information we collect:
Through the Services
In email, text, or other electronic messages between you and any employee or agent of Hinge Health.
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 employ or manage.
Should you have any questions about this policy or our practices, please send an email to email@example.com
What Information We Collect
Hinge Health collects your personal information through the Services 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 Hinge Health to disclose your eligibility for and participation in the Services (ie. that you meet the enrollment criteria for the Services and that you have elected at your own discretion to take part) to others, including: Hinge Health senior management and administrators, your personal Hinge Health coach (“Hinge Coach”) and other users of Hinge Health’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 Hinge Health’s program. Moreover, based on Hinge Health’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 Hinge Health account holder, 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 firstname.lastname@example.org
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 Hinge 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 sites and our offerings;
Statistically analyze user behavior and activity;
Provide you with more relevant content;
Conduct research and measurement activities including publication or other public dissemination of those findings, provided that any information about you or other participants is aggregated and de-identified;
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 Hinge Health about you, and may combine this information with information from external sources.
(b) Disclosure of Personal Information to Third Parties
We will not disclose any personal information 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 make available to other participants your information, including PHI that you post and/or disclose in the course of engaging with the Services.
While we take considerable effort to protect your privacy, we cannot 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. Specifically, 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 choose to provide through the Services may be visible to your Peer Group and Hinge Coach. As such, you should only provide information you feel comfortable disclosing.
How We Protect Information Online
We exercise great care to protect your personal information. 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 Hinge Health's employees’ and contractors' access to personal information. Only those employees and contractors with a business reason to know have access to this information. We educate our employees about the importance of maintaining confidentiality of user information.
We review our security arrangements from time to time as we deem appropriate.
How can you help protect your information?
If you are using a Hinge Health website or mobile application for which you registered and choose a password, we recommend that you do not divulge your password to anyone. We will never ask you for your password in an unsolicited phone call or in an unsolicited email. Also remember to sign out of the Hinge Health website and close your browser window when you have finished your work. This is to ensure that others cannot access your personal information and correspondence if others have access to your computer.
We are committed to protecting the privacy of children. The Hinge Health sites are not designed or intended to attract children under the age of 13. The Hinge Health sites do not collect Personal Information from any person we actually know is under the age of 13.
Links to Other Sites
We want to provide site visitors valuable information, services and products. Featured programs and other site content within the Hinge Health site may link our users to third party sites. Hinge Health does not control and is not responsible for practices of any third-party websites.
California Civil Code Section 1798.83 permits users of the Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to us at email@example.com.
We do not share your personal information with other companies outside of Hinge Health, Inc. for direct marketing use unless you consent or otherwise direct us to do so.
If you are a California resident under the age of 18, and user of the Services, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to firstname.lastname@example.org. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.
From time to time, we may change this privacy statement. For example, as we update and improve our services, new features may require modifications to the privacy statement. Accordingly, please check back periodically.
Date: February 14, 2019