Last Revised: March 01, 2022
Laguna Health Inc. (“Laguna”, “we” or "us") is committed to protecting the privacy of Users (“User” or “you”) who access, visit, or engage with its website, located at https://lagunahealth.com; or any other website owned or operated by us (the "Site"), as well as our mobile application (the "Application"), collectively referred to as the "Services"). We believe that you have a right to know our practices regarding the information we may collect and use about you when you use our Services. Please read the following policy carefully to understand Laguna’s views and practices regarding your personal information.
2. What information do we collect about Users? We collect two types of data and information from our Users:
2.1. Non-personal Information. The first type of information is non-identifiable and anonymous information (“Non-personal Information”). We are not aware of the identity of the User from whom we have collected the Non-personal Information. Non-Personal Information is any unconcealed information that does not enable the identification of an individual User, and which is available to us when such User uses our Services. Non-personal Information which is being gathered consists of technical information, behavioral information, and aggregated information, and may contain, among other things, the activity of the User on the Services, type of operating system, device type, User's 'click-stream' on the Site, keyboard language, screen resolution, time spent on various screens of the Site, metadata, etc.
2.2. Personal Information. The other type of information we collect is individually identifiable information, or information that may, with reasonable effort, identify an individual (“Personal Information”). We gather the following types of Personal Information:
2.2.1. Personal Information that is provided voluntarily:
2.2.2. Personal Information collected via technology:
2.2.3. Personal Information collected via third parties: Subject to your consent, we may receive Personal Information about you from Medical Providers, your employer or insurer, as applicable. Such Personal Information includes your contact details, and information about your hospitalization and PHI, and will be provided to us for the purpose of providing our Services to you.
2.2.4. For the avoidance of doubt, any Non-personal Information connected or linked to or associated with any Personal Information shall be deemed as Personal Information as long as such connection, linkage or association exists.
3. How do we collect information about our Users? There are several methods we use to collect information:
3.1. We collect information through your entry, connection, access and/or use of the Services. In other words, when you are using the Services, we are aware of it and may gather, collect and store the information relating to such usage (such as the Non-personal Information detailed above and your IP address), either independently or through the help of our authorized third party service providers as detailed below.
3.2. We collect information that you provide us voluntarily. We collect Personal Information, or are exposed to Personal Information, as detailed in Section 2.2.1 above 3.3. We collect information we receive from third parties. Some Users may be referred to our Services via a Medical Provider, their employer or insurer. Other Users may authorize us to obtain Personal Information from such third parties. Depending on the circumstances and your permissions, the third parties mentioned above may provide us with your contact details and/or PHI, as detailed in Section 2.2.3.
3.3.1. We may gather, collect and store such information either independently or through the help of our authorized third party service providers as detailed below.
4. What are the purposes of the collection and processing of information?
4.1. Non-personal Information is processed in order to:
4.2. Personal Information is processed in order to:
5. Sharing Personal Information with Third Parties
5.2. In addition to using the information collected by us for the purposes described under Section 4 above, we may also share your information in the following cases:
Medical Provider Partners. Our Site and Services serve, among other things, as a platform that eases your communications with the applicable Medical Providers. If you are referred to us by a Medical Provider, you hereby acknowledge and agree that your Personal Information might be shared with such Medical Provider.
Please note that we are a HIPAA compliant company and require all third parties, including corporate and business affiliates, service providers, Medical Providers that are exposed to your PHI to sign a BAA agreement with us.
5.3. For the avoidance of doubt, Laguna may transfer and disclose Non-personal Information to third parties at its discretion including without limitation for statistical, analytical, and research purposes and for customization, development, and improvement of our Services.
6. Your Rights
Laguna acknowledges that data protection laws in certain jurisdictions provide Users with certain statutory rights to their Personal Information. Depending on the applicable jurisdiction, you may have the statutory right to take certain actions in regards to your Personal Information.
If you wish to exercise these rights, please email us at firstname.lastname@example.org and we will respond within a reasonable timeframe, and no later than permitted by applicable law.
Please note that terminating your Account will not necessarily delete Personal Information that is stored on our servers. If you wish to delete all Personal Information that we have collected about you, including PHI, please send a deletion request to email@example.com and we will delete your information within a reasonable timeframe. However, please note that we may be required by applicable laws and regulations to retain certain Personal Information for a longer period of time. Please note that aggregate and/or anonymous information derived from your Account and/or use of the Services may remain on Laguna servers indefinitely.
7. Location of Your Data
The Services are intended for Users over the age of majority (as determined under the applicable laws where the individual resides; “Age of Majority”). Therefore, Laguna does not intend and does not knowingly and directly collect Personal Information from minors and does not wish to do so. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Services. If we learn that we collected Personal Information from a minor, we will delete that information as quickly as possible unless we have a valid legal obligation or lawful basis in place. If you have reasons to suspect that Laguna collected Personal Information from minors, please notify us at firstname.lastname@example.org, and we will take action to delete that information as quickly as possible.
9. Links to third party Websites
10. Tracking Technologies
We may use various tracking methods or technologies, including cookies (“Tracking Technologies”) to store or collect your Usage Information across the Services. We use Tracking Technologies for a variety of purposes we believe to be necessary or helpful in improving or assessing the performance of the Services or in offering you enhanced functionality.
Cookies. When you access or use the Services, we and/or our third party service providers may use industry-wide technologies such as User persistent identifiers (or other similar technologies), which store certain local information on your device ("Local Storage") which may enable, inter alia, automatic activation of certain features and make the User’s experience and usage simpler, more relevant, convenient and effortless. Such information is locally stored in the User's device. Laguna and/or our 7 authorized third party service providers may access such information. Laguna and/or our authorized third party service providers may use both session cookies (which expire once you close the Site) and persistent cookies (which stay on the User’s device until they delete or block them). Such Local Storage used by the Site may store non-personal information, such as the different pages viewed by a User within the Site, as well as User persistent identifiers, which will be collected in accordance with the terms specified herein. Cookies may be disabled or removed generally by adjusting certain settings available as part of most browsers. In some cases, these tools can block those cookies in the future. These tools may not be effective for certain types of cookies. Your ability to limit cookies when you revisit our Site or Services is subject to your browser settings and technological limitations. Please note that, if you disable or remove cookies on your device, some parts of our Site or other aspects of our Services may not function properly.
Other third parties may use Tracking Technologies with our Services as well. We do not control those Tracking Technologies, and we are not responsible for them. To confirm how any third party collects or uses your information, please refer to that third party’s website.
We take reasonable measures to maintain the security and integrity of our Services and prevent unauthorized access or use thereof through generally accepted industry standard technologies and internal procedures. Please note, however, that there are inherent risks in the transmission of information over the Internet or other methods of electronic storage and we cannot guarantee that unauthorized access or use of your Personal Information will never occur.
To the extent that Laguna implemented the required security measures under applicable law, Laguna shall not be responsible or liable for unauthorized access, hacking, or other security intrusions or failure to store or the theft, deletion, corruption, destruction, damage, or loss of any data or information included in the Personal Information.
13. Contacting Us