Pine Park Health Privacy Policy

1. Who We Are

Pine Park Health is a value-based primary care practice that works with senior living communities to achieve better health outcomes for patients. Pine Park Health employs geriatric-focused physicians, nurse practitioners, physician associates, and other clinical and non-clinical professionals to deliver medical care to patients in their home.

2. Scope of Policy

This Privacy Policy explains how Pine Park Health Management, Inc., and its affiliates (“Pine Park Health,” "we," “our,” "us") collect, use, and share information collected through our technology, applications, platforms, websites, content, products, and services (the "Services"). This Privacy Policy applies generally to the information We collect about You as a: consumer; another person for whom You have the legal authority to represent, such as Your family member, friend, or client; Senior Living Professional; other employee; or partner (collectively “You,” “Your”).  

If your data is collected, used, or shared in connection with your status as an employee, Your use and access to Services are subject to the terms of the offer letter which you signed at hire and all employment policies, procedures, handbooks, rules, agreement(s) and written requirements, which will control in the event of any conflict.

Patient health information is subject to the linked Notice of Privacy Practices.

This Privacy Policy does not apply to any protected health information covered by the Health Insurance Portability and Privacy Act (“HIPAA”), and its implementing regulations.  

3. Policy Updates

This Privacy Policy may change from time to time.This Privacy Statement is in effect as of the date above. If we change this policy, we will post the revised version here and change the “effective date” to show the date from which the new policy will apply. We may also contact You directly where we deem appropriate to do so under applicable law. If you object to any changes, you must cease using the Services immediately.  We encourage You to check here regularly for the most up-to-date version.  

4. Consent 

By utilizing our Services or providing information about You, You acknowledge and consent to the terms of this privacy policy. You agree not to provide us with information about any other person unless You have that person’s consent or other legal authority. 

Your telephone communications with Us may be recorded or monitored for quality control purposes. By communicating with Us in this manner, You expressly consent to the recording for such purposes.

By providing Us with Your contact information, such as email or telephone number, You agree to be contacted by Us and by the providers we have contracted with to contact You on our behalf. 

You agree to be contacted by telephone call or text message at the telephone number You provided using automatic telephone dialing systems, even if You previously registered on a Do Not Call registry. Your consent is not a condition of purchase.

5. Cookies

Pine Park Health is a value-based primary care practice that works with senior living communities to achieve better health outcomes for senior patients. Pine Park Health employs geriatric-focused physicians, nurse practitioners, physician associates, and other clinical professionals to deliver medical care to patients in their home.

• to make our Services function properly;
• to provide a secure browsing experience during your use of our Services;
• to support our marketing campaigns, including to measure how you interact with our marketing campaigns;
• to help us improve our Services; and
• to remember your preferences for your convenience.

6. Data We Collect

7. Data You Provide

We collect data You provide to Us when You use our Services, including, but not limited to, communicating with Us over the telephone, through our mobile application(s), email, SMS, or complete a website form.  This includes personal information, which identifies, (whether directly or indirectly), a particular individual.  Personal information You provide includes the types of data listed below (with examples). 

• Identifiers: name, postal address, phone number, or email address.
• Customer Personal information under California. Civ. Code 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
• Personal characteristics of protected classes. Age, gender and other information You choose to provide, such as marital status, medical condition, physical or mental disability.
• Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
• Financial Information. Banking information, account numbers, routing numbers, revenue, payments, invoices, expenses.
• Profile. Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, abilities, engagement, skill and business acumen, referral source(s), schedule preferences, orientations and training completed, family, friends, relationships, habits, behaviors, opinions, feedback, living environment and conditions, service and customer service records, and inferences made from this data.
• Professional or employment-related information. We may receive employment-related information, including: current and past employer name, positions held, physical demands of positions held, and wage information; availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves, date of death; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military; and performance record, compensation history, disciplinary and grievance information (including related legal matters).
• Sensitive Personal Information. Information that reveals: a social security, driver’s license, state identification card, or passport number; a racial or ethnic origin, religious or philosophical beliefs, or union membership; information collected and analyzed concerning a consumer’s health; the contents of mail, email, and text messages.
• Website/Application interaction or similar network activity–information You provide Us in our website contact forms, applications or through any chat functionality.
• Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, body temperature, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data that can be used to identify an individual.
• Sensory data. Audio or similar information, such as recording phone calls for quality assurance.
• Health & Physical Characteristics. medical conditions, diagnosis, care needs, and other similar information You provide. In the case of injury, illness, or potential disability we may also collect doctor’s notes and assessments, work status reports, or other medical information to clear you for work or arrange alternative work.

Partner Data

Through working with senior living communities to provide Services, we may require access to data of such communities. We will handle any data accessed from senior living communities in accordance with its applicable privacy policy(ies). The Personal information we may access includes the types of data listed below (with examples).

• Identifiers. name, postal address, phone number, or email address.
• Customer Personal information under California. Civ. Code 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
• Personal characteristics of protected classes. Age, gender and other information You choose to provide, such as marital status, medical condition, physical or mental disability.
• Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
• Profile. Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, abilities, engagement, skill and business acumen. Information regarding family, friends, relationships, habits, behaviors, attitudes, preferences, opinions, feedback, living environment and conditions, service and customer service records, and inferences made from this data.
• Professional or employment-related information. We may have access to employment-related information, including: current and past employer name, positions held, physical demands of positions held, and wage information; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves, date of death; location of employment and workplace, job titles, work history, work hours, licensure and certification records, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military; and performance record, compensation history, disciplinary and grievance information (including related legal matters).
• Information that reveals: a social security, driver’s license, state identification card, or passport number; a racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of mail, email, and text messages; and information collected and analyzed concerning a consumer’s health.
• Health & Physical Characteristics. Medical conditions, diagnosis, care needs, and other similar information You provide so that we can connect You with the appropriate resources and Services.

Other Data Sources

• Identifiers: name, postal address, phone number, or email address.
• Customer Personal information under California. Civ. Code 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
• Personal characteristics of protected classes. Age, gender and other information You choose to provide, such as marital status, medical condition, physical or mental disability.
• Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
• Profile. Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, abilities, engagement, skill and business acumen. Information regarding family, friends, relationships, habits, behaviors, attitudes, preferences, opinions, feedback, living environment and conditions, service and customer service records, and inferences made from this data.
• Professional or employment-related information. We may receive employment-related information, including: current and past employer name, positions held, physical demands of positions held, and wage information; availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves, date of death; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military; and performance record, compensation history, disciplinary and grievance information (including related legal matters).
• Sensitive Personal Information. Information that reveals: a social security, driver’s license, state identification card, or passport number; a racial or ethnic origin, religious or philosophical beliefs, or union membership; information collected and analyzed concerning a consumer’s health; the contents of mail, email, and text messages.
• Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, body temperature, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data that can be used to identify an individual.
• Website/Application interaction or similar network activity–information You provide Us in our website contact forms, applications or through any chat functionality.
• Sensory data. Audio or similar information, such as recording phone calls for quality assurance.
• Health & Physical Characteristics. Medical conditions, diagnosis, care needs, and other similar information You provide.
• Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments and invoices.

Data Use

For each type of data we collect, we use such Personal Information for the business purposes set forth below:

• Communicating with You
• Verify and enhance quality of products and Services
• Administration of our business
• Anonymizing Your data for further internal and external use in a manner that does not identify You
• Enhancing security and preventing fraud or illegal activity
• Verification and onboarding of new employees
• Performing our contractual duties and obligations or entering into an agreement
• Ensuring compliance with legal obligations
• Facilitation of online or platform interactions
• Consumer engagement & customer service
• Identifying and testing business innovations
• Market research
• Providing educational resources/ learning management
• Advertising/marketing for employment, recruitment, products and Services

Use of data for advertising/marketing of our products and Services may also be a commercial purpose for which You may have the right and ability to opt-out.

We may use the information we collect about You in other ways, which we will tell You about at the time we collect it or before we begin using it for those other purposes.  In certain instances You will have an opportunity to limit our uses at the time Your Personal Information is collected. 

You may also have the right to request deletion of Your data, depending upon Your state of residence, as provided below.

We will retain and use Your Personal Information for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  Once data is aggregated, de-identified, or anonymized, it may be retained for a longer period as permitted by law.

Data Sharing

We may share information for the purposes described above under “Data Use,” with third-parties as follows: 

• Partners, Subsidiaries and Affiliated Medical Agencies: We may share Personal Information with our partners and affiliates such as physical therapy, home health, or hospice companies to provide you with clinical service. 
• Service Providers: We may share Personal Information with service providers to facilitate our business purposes, as identified above in “Data Use.” These may include, but are not limited to, disclosures to our auditors and advisors, or technology and software service providers who help us administer our business or provide data security. These also include providers of website and chat functionality. We generally require such providers to provide contractual assurances that they will safeguard data and limit their use of data to what is required to fulfill the purpose of our arrangement with them.
• Third-party Vendors: We may share Personal Information with third-party vendors to facilitate our own commercial purposes, as identified above in “Data Use.” These may include, but are not limited to, online marketing, advertising or analytics providers who help us understand trends and patterns among those who access our website and Services. When these vendors are not service providers described above or utilize non-essential cookies on our website, You may have the right and ability to opt-out of such sharing.
• Legal Purposes, Authorities, Officials and Courts: We may disclose Personal Information where we believe it is necessary to comply with the law in special cases when we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may have breached our Terms or who may be causing (whether intentionally or unintentionally) injury to or interference with our rights or property, other website or application users, or anyone else who could be harmed by such activities. We may also disclose Personal Information to law-enforcement personnel and agencies when requested to do so, as required by law, such as to comply with a subpoena.
• Business Transfers: We may disclose Personal Information as part of any merger, acquisition, debt financing, sale of company assets, or other business transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, provided that we inform such third parties that they must use Your Personal Information only for the purposes disclosed in this Privacy Policy.
• As Aggregated, De-identified, or Anonymized Information: We may disclose information that cannot reasonably be used to identify You, as permitted by law.
• Upon Your request.

We may otherwise disclose Your Personal Information to third-parties with Your consent or at Your direction, where permitted or required by law.

Exercising Your Rights Under Applicable Law