Your privacy is critically important to us.
Effective: November 21, 2022
Primary Diagnostics, Inc, (referred to as “Primary.Health,” “Primary,” “we” “us,” or “our”), owns and operates the website located at https://primary.health (the “Website”) and its accompanying mobile application (the “Mobile Application”). Through our Website we offer various online services that enable visitors to the Website (“you” or “Visitors”) to receive access to several types of healthcare information and information about our services (“Services”). If we are providing the Services on behalf of a third-party partner (such as your employer, health care provider or school) who has paid (in whole or in part) for you to use the Services, we will abide by the terms of our agreement with that third-party partner related to the use of the information we collect.
Our California Privacy Rights page includes definitions and content consistent with California law.
Primary understands that privacy of information is of great importance to our Visitors.
By accessing or using the Website after such changes are posted you agree to all such changes.
COLLECTION, USE AND DISCLOSURE OF INFORMATION
What we collect:
Information you give us.
We collect and store information you provide through our Services.
When you register on our Website and to receive our Services, the information we collect from you includes things such as:
- Postal address
- Email address
- Phone number
In certain situations, we may also collect things like:
- Driver’s license number
- Social Security Number
- Location information
- Demographic and lifestyle information
- Medical and health insurance information
- Survey responses
- Photographs which include but are not limited to test results, insurance cards, and vaccination records when permission is given in advance to Primary to access your device’s camera.
Information collected automatically online.
We collect information about your interactions with us including, for example:
- The type of device or browser you’re using
- Your IP address
- Your browsing behavior while on our Website
- The URLs of the Website you visited before visiting our site (these are called “referring URLs”)
- Device identifiers
- Mobile advertising identifiers.
Primary.Health and our partners use technologies such as cookies or similar technologies to analyze trends, administer the Website, track Users’ movements around the Website, and to gather demographic information about our user base as a whole.
Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.
We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services. Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
For COVID-19 data collected or stored in our app, Primary Health Pass, we only access your personal and sensitive data required to directly support the public health emergency.
Some areas of our Website may collect your location to, for example, help you search to receive our Services, use special mobile features, or provide you with helpful messaging in our Mobile Applications. We also may use this information to determine whether to provide you with content, information, and notices that may be required by law based on your location.
Mobile devices often provide users with the ability to adjust settings related to location. If you do not want us to collect specific location information, you may modify the location services on your mobile device’s settings. Primary.Health has no control over your device’s settings.
How we use the information we collect:
- To provide, maintain, improve, and enhance our Services;
- To personalize your experience on our Services such as by providing tailored content and recommendations;
- To understand and analyze how you use our Services and develop new products, services, features, and functionality;
- To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
- For marketing and advertising purposes, such as developing and providing promotional and advertising materials that may be relevant, valuable or otherwise of interest to you;
- To generate anonymized, aggregate data containing only de-identified, non-personal information that we may use to publish reports;
- To send you text messages and push notifications;
- To fulfill orders and requests for products, services, or other information;
- To process refunds, returns, and exchanges;
- To track and confirm online orders;
- To find and prevent fraud, and respond to trust and safety issues that may arise;
- For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
- For other purposes for which we provide specific notice at the time the information is collected.
For COVID-19 data collected or stored in our app, Primary Health Pass, we only use your personal and sensitive data collected to support COVID-19-related efforts or epidemiological research.
How we share your information.
We may combine or share information among current or future Primary.Health companies, including affiliates and subsidiaries.
We may share any information we received with vendors and service providers retained in connection with the provision of our Services.
We also may share personal information in connection with co-branded product or service offerings (including sharing personal information with business partners to validate offers).
We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.
We work with third-party advertising partners to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info). If you do not wish to receive personalized ads, please visit their opt-out pages to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.
Sometimes we may be required to share personal information for legal reasons, for example, if we are required to do so by a regulation, court order, subpoena or other legal process. We may also share information when we believe it is necessary to comply with the law or to respond to a government request, or when we believe disclosure is necessary or appropriate to protect Primary.Health, our customers, or others.
We may share personal information in the event of a corporate sale, merger, acquisition, joint venture, reorganization, divestiture, dissolution, liquidation, or similar event.
We may also disclose your information with your permission.
How we protect your information.
You also can do your part to help protect the information you provide to us, create a strong password, use that password only on our Website and Mobile Applications, and do not share your password with anyone – especially anyone claiming to work with us. We would never contact you and ask for your password – ever.
You may at any time:
- Unsubscribe from our marketing or promotional emails, direct mail, phone, and mobile marketing communications. However, even if you opt out of receiving promotional messages from us, you will continue to receive administrative messages from us.
- Update and correct your personal information
- Deactivate your account
- Request removal of information you post on our Website and Mobile Applications; in some cases, we may not be able to remove your content or personal information, in which case we will let you know if we are unable to do so and why
- Modify your device’s location settings, as described above.
To do any of these, let us know by one of these methods:
- To unsubscribe from marketing or promotional emails, follow the directions in a marketing email, direct mail, or mobile communication that you receive from us
- For other requests, provide your request and current contact information through one of the contact methods listed under “contact us” below
Protecting children’s privacy.
We do not knowingly solicit or collect personal information from children under the age of 13 without parental consent. If you believe that a child under age 13 may have provided us with personal information without parental consent, please contact us as specified in the “How to contact us” section of this policy.
Links to other Websites.
Text Message Alerts
- If you agree to opt in to our message alert service, you will receive messages regarding your appointment and test results.
- You can cancel the SMS service at any time. Just text “STOP” to the short code. After you send the SMS message “STOP” to us, we will send you an SMS message to confirm that you have been unsubscribed. After this, you will no longer receive SMS messages from us. If you want to join again, just sign up as you did the first time and we will start sending SMS messages to you again.
- If you are experiencing issues with the messaging program you can reply with the keyword HELP for more assistance, or you can get help directly at firstname.lastname@example.org or +1 (855) 970-0077.
- Carriers are not liable for delayed or undelivered messages
- As always, message and data rates may apply for any messages sent to you from us and to us from you. You will receive 5-6 messages per appointment. If you have any questions about your text plan or data plan, it is best to contact your wireless provider.
Our Services hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing.
HOW TO CONTACT US?
If you have questions regarding this policy, please submit them through this link: https://privacy.primary.health
Primary Diagnostics, Inc.
595 Pacific Ave Floor 4
San Francisco, CA 94133
Primary Diagnostics © 2022. All rights reserved.
Submit an access request or deletion request to https://privacy.primary.health.
This Statement uses certain terms that have the meanings given to them by the California Consumer Privacy Act.
Collection and Disclosure.
During the 12-month period prior to the effective date of this Addendum, we may have:
- Collected the following categories of personal information about you:
- Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as customer number, unique pseudonym, or user alias), email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers, physical characteristics or description, state identification card number, and signature
- Identifiers (Online): a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; other forms of persistent or probabilistic identifiers, and Internet Protocol address
- Other Financial, Medical, and Health Information: bank account number, credit card number, debit card number, insurance policy number, and other financial information, medical information, and health insurance information
- Information Related to Characteristics Protected Under California or Federal Law: characteristics of protected classifications under California or federal law, such as race, color, national origin, religion, age, sex, gender, gender identity, gender expression, sexual orientation, marital status, medical condition, ancestry, genetic information, disability, citizenship status, and military and veteran status
- Commercial Information: including records of personal property, products or services purchased, obtained, or considered, and other purchasing or consuming histories or tendencies
- Internet and Other Electronic Network Activity Information: including, but not limited to, browsing history, search history, and information regarding your interaction with Website, applications or advertisements
- Geolocation Data
- Professional or Employment-Related Information
- Education Information
- Profile Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
- Collected personal information about you for the following business or commercial purposes:
- Performing services you have purchased from or contracted for with us, including maintaining or servicing accounts (e.g., your Primary.Health account), as well as providing customer service, processing or fulfilling orders and transactions, verifying customer information, providing advertising or marketing services, providing analytics services, or providing similar services
- Auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance
- Short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction
- Detecting and responding to security incidents, protecting against and responding to malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity
- Debugging to identify and repair errors that impair existing intended functionality
- Undertaking internal research for technological development and demonstration
- Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
- Customizing your experience on our Website or Mobile Applications
- Processing liability claims
- Complying with and enforcing applicable legal requirements, relevant industry standards and our policies
- Shared your personal information with the following categories of third parties:
- Our affiliates
- Our joint marketing partners
- Our business partners
- Social media networks
- Third-party marketing partners
- Government entities, including law enforcement
- Sold (as defined under California law) the following categories of personal information:
- Identifiers (online) associated with a device used to interact with our Website, Mobile Applications, or advertisements (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology)
- Internet and other electronic network activity information associated with a device used to interact with Website, Mobile Applications, or advertisements
We do not sell the personal information of consumers under the age of 16 if we have actual knowledge of the individual’s age.
We do not sell personal information as the term is traditionally understood, versus the definition under the CCPA — for example, we do not exchange for money personal information to data brokers or third parties for their marketing purposes independent of us.
- Disclosed for a business purpose the following categories of personal information about you:
- Identifiers (Online)
- Other Financial, Medical and Health Information
- Information Related to Characteristics Protected Under California or Federal Law
- Commercial Information
- Internet and Other Electronic Network Activity Information
- Geolocation Data
- Sensory Information
- Professional or Employment-Related Information
- Education Information
- Profile Inferences
- Collected personal information about you from the following sources:
- Device(s) You Used
- Service Providers
- Information we share with third parties:
|3rd Party Categories|
|Personal Information Categories||Our Affiliates||Our Joint Marketing Partners||Our Business Partners||Social Media Networks||Third-party Marketing Partners||Government Entities, Including Law Enforcement*See Disclosure|
|Other Financial, Medical and Health Information||X|
|Information Related to Characteristics Protected Under California or Federal Law||X|
|Internet and Other Electronic Network Activity Information||X||X||X|
|Professional or Employment Related Information||X|
Primary.Health shares Personal Information with government entities, including law enforcement, only in the following circumstances: (1) when required to do so as a matter of law; (2) to assist in the investigation of a potential crime impacting Primary.Health, its employees, its customers, or the communities we serve; or (3) when required in response to legal process (e.g., subpoena, warrant).
California Consumer Privacy Rights.
You have certain choices regarding our use and disclosure of your personal information, as described below.
- Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information related to you we have collected during the past 12 months. This may include:
- The categories and specific pieces of personal information we have collected about you
- The categories of sources from which we collected the personal information
- The business or commercial purpose for which we collected or sold the personal information
- The categories of third parties with whom we shared the personal information
- The categories of personal information about you that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose
- Deletion: You have the right to request that we delete certain personal information we have collected from you. Exceptions apply.
- Opt-Out of Sale: You have the right to opt-out of the sale of your personal information.
How to Submit a Request.
- Submit an access request through this link: https://privacy.primary.health, or call us at 1-855-970-3223
- Submit a deletion request through this link: https://privacy.primary.health, or call us at 1-855-970-3223.
- To submit a Shine the Light Request, please submit them through this link: https://privacy.primary.health.
To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you have an account with us, we may verify your identity by requiring you to sign into your account. If you request access to or deletion of your personal information and do not sign into an account with us, we require you to provide the following information: name, email address, phone number, and postal address. In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we reserve the option to require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (1) we may require you to provide the authorized agent written permission to do so, and for access and deletion requests, we may require you to verify your own identity directly with us (as described above).
If you choose to exercise any of your rights under the CCPA, you have the right not to receive, and will not receive, discriminatory treatment by us. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request. Employees and contractors are provided notice via different statements.
This Statement is available in alternative formats upon request. Please submit a request through this link: https://privacy.primary.health or call 1-855-970-3223 to request this Statement in an alternative format.
Last Updated: August 15, 2022