Repisodic, Inc
PRIVACY STATEMENT
LAST REVISED: FEBRUARY 2021

Welcome to Repisodic. Formally, we are Repisodic, Inc. (“Repisodic,” “we,” “us,” and “our”). We provide free, accurate and unbiased information to patients and families to help them make informed healthcare decisions. We work with healthcare providers across the care continuum to ensure that this information is available, accurate, and actionable throughout the patient journey. As part of this effort, we provide our services online, including via our website at www.repisodic.com (the “Repisodic Site”), our Repisodic Choice services (the “Repisodic Platform”), and other forms of communications (collectively, the “Services”). Each person or entity who uses our Services is referred to as a “user” or “you” or “your”.

Each person or entity who uses our Services is referred to as a “user” or “you” or “your”. This Privacy Statement and our End User License Agreement (“EULA”) apply to each user.

This document is our statement of our privacy practices (“Privacy Statement”). Among other things, it explains how we and some of the companies we work with collect, use, share and protect the information you provide to us (“your Content” or “User Content”). The User Content may include any personally-identifiable information, including without limitation name, address, telephone numbers, electronic mail and postal addresses, health conditions, health history, and other sensitive information that identifies or is uniquely associated with an individual (collectively, “Personal Data”). This Privacy Statement also discusses your choices about the collection, storage and use of your Personal Data.

Any Content that is not Personal Data is referred to as “Non-Personal Data.” Non-Personal Data includes information about how users use the Services, what Services users select, how users respond to service offerings, how users share information with others, what users say they like and dislike, all of which we aggregate into larger data sets that do not identify individuals (“Behavioral Data”).

Among other services, Repisodic enables users to connect healthcare recipients with healthcare providers. Please note that this Privacy Statement does not apply to any other websites, mobile applications, or businesses. This Privacy Statement does not apply to any Personal Data or other Content collected via any means other than the Services.

By using our Services, you consent to the collection, transfer, analysis, transformation, storage, disclosure and other uses of your Content, including your Personal Data, as described in this Privacy Statement.

1. Information We Collect

As noted above, we collect Content from you while providing the Services. Some of the Content is Personal Data that we use to contact you and connect you with other users, and which is necessary to provide the Services. Other Content we collect from you, Behavioral Data and other Non-Personal Data that we aggregate, share, and use to improve our Services, and others in the industry.

We collect many different types of information from you, both directly and indirectly.

Information you provide us directly

We may collect the following information from you.

  • Profile information. You may provide us with your name, address and other profile information that you choose to make public or share with other users.
  • Health information. We may ask for your health history, health service utilization, healthcare preferences, healthcare or related service providers, insurance information and other related information.
  • Location Information. We may ask for your postal address or your geographic location information, especially if you place an order for Services in which your physical address is relevant. When you post User Content to our website or to social media, you may provide your location information, including global positioning system (“GPS”) data or other location information embedded in or accompanying the User Content (e.g., in tags or captions).
  • Communications between you and Repisodic. We may send you paper mail, electronic mail, SMS or text messages, push notifications to your mobile device, and other electronic communications for sales and delivery, notices of changes/updates to features of the Services, technical and security notices, and for other purposes. We may collect and store these communications.

Information we gather from your use of our Services

We collect the following information from your use of our Services.

  • Emails and Phone Numbers. We may save private emails sent to us by users, and we may share your emails with any third parties or other users for our business purposes (but not for their marketing use). Any public posts on Services may be viewed by any user and is public to anyone who visits the Services. You may elect to disclose certain Personal Data and Non-Personal Data. The information you submit in any public forums is not confidential or private, and Repisodic does not protect it. All information you choose to provide publicly, including information that identifies you or others, can be read, collected, or used by other users and by other third parties, and could be used to send you unsolicited messages and for other purposes.
  • Healthcare Preferences. Your interactions with the Repisodic Platform, such as your choice of specific healthcare providers, may be shared with the relevant healthcare providers. We may provide your Personal Data and Non-Personal Data to healthcare providers in order to facilitate your use of the Services.
  • Social Media. In addition to media that we control, you may post comments, photographs, drawings and other User Content on third party social media, such as YouTube, Facebook, Instagram and Twitter, each of which enforces its own terms of use and privacy policy for its service. As noted in the EULA, we may use and copy the User Content you post. More to the point, your User Content may contain Personal Data about you and other people in the form of names, email addresses, and location information. You should also be aware that a photograph or drawing of a person may be Personal Data to the extent the person may be recognized in and identified by the photograph or drawing, and medical or other healthcare information may be gleaned from any medical conditions, disorders or diseases are discussed or portrayed in the User Content, such as dietary restrictions. We may collect and use User Content and the Personal Data contained in the User Content to market our Services.
  • Analytics. We may use third-party analytics tools to help us measure traffic and usage trends and other Non-Personal Data for the Services. These tools collect information sent by your device or our Services, including the web pages you visit, add-ons, and other information that assists us in improving our Services. We collect and combine this analytics information with analytics information from other users so that it cannot be used to identify any particular individual user.
  • Metadata. Metadata is usually technical data that is associated with other data, including User Content. For example, metadata can describe how, when and by whom an item of User Content was collected and how that User Content is formatted. Repisodic may collect and store metadata, including about each user’s public posts on the Services.
  • Log Data. Our servers automatically record information ("log data”) created by your use of the Services. Log Data may include information such as your device (for example, a computer or mobile device), Internet Protocol (“IP”) address, browser type, operating system, the referring web page, pages visited, location, your mobile carrier, device and application IDs, search terms, and cookie information. We receive log data when you interact with our Services, for example, when you visit our website, sign into our Services or interact with our email notifications. Repisodic uses log data to review how we provide our Services and to measure, customize, and improve the Services.

2. How We Store Your Information

We currently provide the Services from within the United States, and we store all User Content, including Personal Data, that we currently collect and retain on servers inside the United States.

Certain types of User Content you submit to us might reveal your gender, ethnic origin, nationality, age, religion, sexual orientation, or other Personal Data about you or others.

By using our Services, or by submitting your personal Information to us, you consent to the collection, storage, processing and onward transfer of your personal Information as stated in the current version of this Privacy Statement and the current version of our other online documents, including the End User License Agreement.

3. How We Use Your Information

We share and use your Personal Data in the following circumstances:

  • Opt-in with Your Consent. We may ask for your permission to share your Personal Data with other people and organizations outside of Repisodic, including to provide you with services. As with any opt-in procedure, you are under no duty to agree to a request that you opt-in.
  • Mobile Push Notifications and Alerts. We may ask you for permission to send you push notifications and text messages on your mobile device. If you opt-in to this service, you can also deactivate this service in the future by changing the notification settings on your mobile device.
  • Partners and Affiliates of Repisodic. We may share your Personal Data with Partners to sell and provide the Services.
  • Cookies. Cookies are unique identifiers that we transfer to your device to enable our systems to recognize your device and to provide features and remember your personalization choices. We use cookies to make it easier to access and use our Services. The help feature on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Additionally, you can disable or delete similar data used by browser add-ons by changing the add-on's settings or visiting the website of its manufacturer. Because cookies allow you to take advantage of some of the Services’ essential features, we recommend that you leave them turned on. Cookies are also used to display particular Content and to set session identifiers for visitors who voluntarily join user areas.
  • Do not Track. We make reasonable efforts to honor the “do not track” settings on users’ devices.
  • Opt-out Email or Postal Address. If you supply us with your email address or postal address, you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not want to receive such mailings, please let us know by sending an email to us at the “opt-out” address, below. We will remove your name from the list we use internally. Opting-out of these emails does not mean we remove your email from our system entirely, because we still retain your email addresses for other purposes.
  • Required by Law. We may access, preserve and share your Personal Data in response to a legal request (like a search warrant, court order or subpoena). We may also access, preserve and share Personal Data when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.
  • Change of Control. If we sell or otherwise transfer part or the whole of Repisodic or our assets to another organization (e.g., a merger, acquisition, or reorganization), your Personal Data such as user name and email address, User Content and any other information collected through the Services may be among the items sold or transferred. You will continue to own your User Content, but the license you grant to us in the EULA may be transferred to others.
  • Non-Personal Data. We may share Non-Personal Data publicly and with publishers, researchers or connected sites. For example, we may share aggregated Non-Personal Data publicly to show trends about the general use of our Services. Non-Personal Data includes aggregated or collective information about multiple users that does not reflect or reference an individually-identifiable user.
  • Other. In addition to some of the specific uses of information we describe in this Privacy Statement above, we may use Personal Data that we receive to:
    • help you efficiently access your information after you sign in.
    • remember information so you will not have to re-enter it during your visit or the next time you visit the Services.
    • provide personalized Content and information to you and others, which, in the future, could include online ads or other forms of marketing.
    • provide, improve, test, and monitor the effectiveness of our Services.
    • develop and test new products and features.
    • monitor metrics such as total number of visitors, traffic, and demographic patterns.
    • diagnose or fix technology problems.

4. Your Right to Review, Request Changes, and Disclose Personal Data

Where required by applicable laws and regulations, each user may inspect and receive a copy of his or her Personal Data as stored in the Services. In rare circumstances, we may deny a request, and we may provide you with an explanation. If we deny your request, you may request a review by another professional, who will be chosen by Repisodic, and we will comply with the outcome of the review.

Subject to applicable laws and regulations, the Personal Data you provide to us remains completely under your control. If you believe the Personal Data we have is incorrect or incomplete, you may in writing request an amendment to your Personal Data. We will approve or deny each request, and notify you of our decision. If approved, we will amend the Personal Data. We will also make a reasonable effort to notify people to whom the Personal Data was released. In the case of a denial, we will provide the reason for the denial and instructions on how to appeal.

Any information or User Content that you voluntarily disclose for use of the Services, such as your user name, your Personal Data or your User Content, may become available to the public if you release it to other users or to the general public. Once you have shared your Personal Data or your User Content with other people, or otherwise made it public, that Personal Data and your User Content may be re-shared by others.

5. Children

On Repisodic, Minor Users (users under the age of 18 are not permitted to use the Services without the written permission of a parent or guardian

Repisodic respects the privacy of all participating Minor Users (including Minor Users under 13). We will not sell, rent, or purchase any Personal Information collected during the use of Repisodic Services.

Aside from sharing user information internally, Repisodic will only transfer or otherwise disclose the information it collects (including from Minor Users under 13) to employees and independent contractors of Repisodic, its subsidiaries, affiliates, and Service Providers if the information will enable that party to perform a business, professional, or technical support function for Repisodic, or if required to do so by law.

We will also transfer or otherwise disclose personal information in response to judicial process, to comply with legal requirements, and, as permitted under provisions of law, to provide information to law enforcement agencies or in connection with an investigation on a matter related to public safety. We may also use your information as permitted by law to protect our rights or property, Repisodic Services, or its users.

Our Service Providers provide support for the internal operations of Repisodic Services and are required not to disclose this information to any other third party who is not a Service Provider for any purpose.

We will do our best to obtain verifiable parental consent in compliance with the law and current regulations. If a Minor User’s parent or guardian contacts us and asks for changes to the Minor User’s account, or to close the Minor User’s account, we will do so.

6. Changes to this Privacy Statement

We may modify our Privacy Statement from time to time on prior written notice sent to the email address we have for you. For any user who has not provided us with an email address, the revised Privacy Statement will become effective ten (10) calendar days after posting on the Services. If you choose not to be subject to a revised version of this Privacy Statement, then you may terminate your use of our Services.

7. Different Locations, Different Laws

The laws and regulations that address privacy rights and responsibilities (collectively, “Laws”) are different from one to another. Indeed, some of the Laws do or do not apply depending on different factors, including:

  • Location or residence of the user.
  • Location or residence of the individual that is the subject of the Personal Data (“Data Subject”).
  • Location or residence of the person or organization that employs or contracts with the Data Subject.
  • Location of each server or other machine where the Personal Data is received, stored, processed or forwarded to.
  • Location of the relevant office of Repisodic.

Several of the Laws that concern users and Repisodic are discussed in this Section, but these are not all of the Laws that may apply. In addition, if there is any conflict or ambiguity between the statements made in this Privacy Statement and an applicable Law, then the Law will control.

7.1 United States Federal Laws

Several of the federal Laws in the United States may apply to the Personal Data collected by us.

Currently, all Personal Data of users resident in the United States is stored on servers and other machines physically located within the United States.

7.1.1 Health Insurance Portability and Accountability Act (“HIPAA”)

HIPAA protects our collection, storage and use of your personal information. We have signed Business Associate agreements with healthcare providers.

7.1.2 Children’s Online Privacy Protection Act (“COPPA”)

Our compliance with COPPA is explained in the "Children" section of this Privacy Statement (Section 5).

7.2 State Laws in the United States

Individual states in the United States have passed and enforce information privacy and security laws.

7.3 Your California Privacy Rights

7.3.1 California Consumer Privacy Act of 2018 ("CCPA")

The CCPA does not apply to Repisodic Services; however, there are other California laws that may apply to certain users.

7.3.2 Your Right to Opt-Out

If you are a California resident under age 16 who has informed us of your age, we will not sell your Personal Information. The parent or guardian of a California resident between the ages of 13 and 16 may contact us to affirmatively authorize the sale of the child’s Personal Information.

7.3.3 Rights of Minors

If you are a California resident under the age of 18, and a registered user of any site where this Privacy Statement is posted, 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 or letter with a detailed description of the specific content or information to the addresses provided in the section below titled “How to Exercise Your Rights”. 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.

By submitting any Personal Data or other User Content to us, or by using the Repisodic Site or Repisodic Platform, you consent to the storage, processing, use and onward transfer of your Personal Data and User Content to us in the United States.

7.3.4 How to Exercise Your Rights

If you would like to exercise any of your rights as described in this Policy Statement, please:

  • Submit your data subject request through the "Contact Us" form available on our website at www.repisodic.com;
  • Email us at info@repisodic.com; or
  • Write to us at Attn: Privacy, Repisodic, Inc, 3401 Market Street, Suite 200, Philadelphia, PA 19104, USA.

8. Use of Email Addresses and Other Contact Information

We collect the email addresses of those who voluntarily provide them to us. You may receive subscription, editorial and other messages from the Services or from us. If you do not want to receive email from us in the future, please let us know at info@repisodic.com.

9. Contact Us

If you have questions or concerns about this Privacy Statement, please contact us online at info@repisodic.com, or by postal mail addressed to:

Attn: Privacy, Repisodic, Inc., 3401 Market Street, Suite 200, Philadelphia, PA 19104, USA

10. Revision Date and History

This Privacy Statement was last revised February 23, 2021. Prior versions of this Privacy Statement are listed below:

  • May 2020

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