Altura Health and its subsidiaries, divisions, and affiliates (sometimes referred to as “Company,” “us,” “we,” or “our”) adopted this privacy policy (“Policy”) to describe our policies and practices concerning the personal information we collect about individuals. We are committed to the privacy and security of personal information.
This Policy, more specifically, is intended to provide individuals with information about how we collect, use, disclose, retain, and safeguard certain of the personal information we gather about them such as through the:
Use of our websites, including mobile websites, applications (collectively, the “Site”).
Visits to our offices, properties, or attendance at one of our events.
Phone and email communications.
Social media interactions, such as through Facebook, LinkedIn, Instagram.
Viewing of our online content or emails.
It also describes options individuals may have concerning their personal information. Please read this Policy carefully before using the Site or submitting personal information to us. BY ACCESSING OR USING THE SITE, YOU CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR PERSONAL INFORMATION AS SET FORTH IN THIS POLICY AND THE SITE’s TERMS AND CONDITIONS OF USE. If you do not consent to the collection, use, disclosure, and retention of your personal information as described in this Policy, please do not provide us with such information. This Policy does not apply to third-party websites accessible through our Site or other applications

We prioritize protecting your privacy and are committed to handling your personal health information responsibly. This Privacy Policy outlines how we collect, use, and safeguard your protected health information (PHI) in compliance with the Health Insurance Portability and Accountability Act (HIPAA).

Our Responsibilities

• Safeguarding Your Privacy: We are required by law to keep your PHI private and will only use or share it as described in this policy or as permitted by law.
• Transparency: We provide this notice to explain how we protect and handle your health information.
• Compliance: Altura Health adheres to this policy and updates it as needed to reflect any changes in our privacy practices.

How We Use and Share Your Health Information

The following explains when and how we may use or share your PHI, either with or without your authorization:

1. Treatment: We may use and disclose your PHI to coordinate and manage your care with healthcare providers, such as specialists, pharmacies, or labs, involved in your treatment.
2. Payment: We may use and share your information to facilitate billing and payment for the healthcare services we provide, including communicating with insurance providers about your treatment plans.
3. Healthcare Operations: To improve the quality and efficiency of our services, we may use PHI in operational activities, such as staff training, quality assessments, and service enhancements.
4. Business Associates: We work with third-party vendors, known as business associates, who assist in our operations (such as IT support or billing services). These partners are required to maintain the privacy and security of your information.

Your Rights Regarding Your Health Information

You have the following rights regarding your PHI:

1. Access: You have the right to request and obtain copies of your health information. For electronic access or copies through our telehealth platform, please reach out to us.
2. Amendments: If you believe your health information is incomplete or inaccurate, you can request an amendment to your records.
3. Accounting of Disclosures: You may request a list of certain disclosures of your health information, excluding those made for treatment, payment, or healthcare operations.
4. Confidential Communications: You can request that we communicate with you in specific ways, such as by using encrypted emails or contacting you at a specific number.
5. Restrictions on Disclosures: You may ask us to limit the use or sharing of your health information for treatment, payment, or operational purposes. While we aim to honor reasonable requests, we may not always be able to agree.
6. Paper Copy of This Policy: You can request a printed copy of this privacy policy at any time, even if you agreed to receive it electronically.

Permitted Uses and Disclosures Without Your Consent

In certain situations, we may use or disclose your information without your explicit consent:

1. Legal Requirements: We may share information as required by law, such as for public health activities or reporting suspected abuse.
2. Health and Safety Concerns: We may disclose information to prevent or control disease, injury, or disability, or to protect against a serious threat to health or safety.
3. Legal Proceedings and Law Enforcement: We may share information in response to a court order, subpoena, or other lawful requests.
4. Research Purposes: In limited cases, your information may be used for research purposes, provided appropriate privacy safeguards are in place.
5. National Security and Intelligence Activities: We may disclose PHI to authorized federal officials for national security and intelligence activities.

Changes to This Privacy Policy

Altura Health reserves the right to modify this privacy policy at any time. Any changes will apply to all PHI we maintain, and we will update this policy to reflect any new practices. Significant changes will be communicated to you.

1. PERSONAL INFORMATION WE COLLECT

As described below, we may collect or have collected in the preceding 12 months the following categories of personal information (“PI” or “personal information”). We may add to the categories of PI we collect and the purpose(s) we collect and use it. In those cases, we will inform and update this section of the Policy.
Identifiers – such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, or other similar identifiers.
Other elements – such as name, signature, characteristics or description, address, telephone number, education, bank account number, credit card number.
Characteristics of protected classifications under Georgia or federal law – such as race, religion, and age.
Commercial information – such as products and services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Education information – such as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. section 1232g, Sec. 1232g; 34 C.F.R. Part 99).
Internet or other electronic network activity – such as browsing history, search history, a consumer’s interaction with an internet website, application, or advertisement.
Geolocation data – such as location information while using one of our apps.
Audio, electronic, visual, or similar information – such as identifiable information obtained about you from voicemail messages, while speaking with our service representatives, including on the telephone. At Altura Health, we are committed to protecting your Protected Health Information (PHI) with the highest standards of confidentiality and security. Your PHI is collected, used, and stored only as necessary to provide quality telehealth services and in strict compliance with applicable laws and regulations. You have the right to access, amend, and obtain a copy of your PHI, as well as request restrictions on certain uses and disclosures of your information. As a covered entity, we are legally obligated to safeguard your PHI and maintain its confidentiality and integrity. If you have questions or concerns regarding your privacy or how your information is handled, please contact our designated Privacy Official, Jason Jones, at jason@alturahc.com.
Professional or employment-related information – such as information on job applications, information needed during onboarding for payroll and benefits, and information needed for evaluating performance.
Sensitive Information. Sensitive information means a consumer’s social security, driver’s license, state identification card, or passport number; account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; precise geolocation; racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of a consumer’s mail, email, and text messages unless the business is the intended recipient of the communication; genetic data; the processing of biometric information for the purpose of uniquely identifying a consumer; personal information collected and analyzed concerning a consumer’s health.
Personal information does not include certain categories of information, such as publicly available information from government records, and deidentified or aggregated consumer information.
We retain your personal information for as long as necessary to provide you with services and in accordance with the Company’s data retention schedule, unless we have or deidentified or deleted your personal information in response to a request to delete. We may retain your personal information for longer if it is necessary to comply with our legal obligations or reporting obligations, resolve disputes, or as permitted or required by applicable law. We may also retain your Personal Information in a deidentified or aggregated form so that it can no longer be associated with you. To determine the appropriate retention period for your personal information, we consider various factors such as the amount, nature, and sensitivity of your information; the potential risk of unauthorized access, use or disclosure; the purposes for which we process your personal information; applicable legal requirements.
B. PURPOSES WE COLLECT AND USE PERSONAL INFORMATION
We collect and use your PI for the following business or commercial purposes. We may change or add to the purposes we collect PI. In that case, we will inform you and obtain your consent when required by law.
To provide you with information, products, or services you request from us.
To fulfill or meet the reason for which the information is provided.
To contact you and/or provide you with email alerts and other notices concerning services, events, or news that may be of interest to you. For example, we may send you announcements, surveys, and newsletters using any communications preferences you have expressed. We may provide these communications via email, postal mail, online advertising, social media, telephone, text message (including SMS and MMS), push notifications, in-app messaging, and other means. Of course, if at any time you no longer wish to receive such communications, you have the option of unsubscribing from our mailing list for that communication.
To process payments.
To communicate with you in social media concerning our services.
To ensure your information is accurate and to personalize our communications to you. For example, we may aggregate your personal information with data from various sources for purposes of keeping information up to date. If you connect your social media services or other accounts to our services, we may use this information to make your experiences with us more personal or share and use it as described elsewhere in this Policy.
To carry out our obligations and enforce our rights including those arising from any contracts entered into with you including for billing, payment, and collections.
To review, improve, and monitor our website, applications, online services, and overall consumer experience, including to provide customization to meet the specific needs.
To provide customer service and engage in quality control activities concerning our products and services.
For testing, research, analysis and service development. We may use data, including public feedback and surveys, to conduct research and for the development of the Site and the services, products, and information we provide.
To respond to law enforcement requests and as required by applicable law, court order, governmental regulations, or other lawful processes.
As described to you when collecting your personal information.
To manage our recruiting efforts and employment and workforce relationships. These activities include, for example, sourcing and processing employment applications, onboarding employees and contingent workers, and carrying out a range of employments activities relating to the employment relationship, such as compensation, benefits, promotion, discipline, termination, and certain post termination activities.
As necessary or appropriate to protect the rights, property, security, and safety of us, our employees, our consumers, our information systems, and the public.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.
C. SOURCES OF PERSONAL INFORMATION WE COLLECT
You. We may collect personal information that you provide during your interactions with us, such as through our Site, by email, or when you communicate with our associates by phone, or at one of our centers. We may also collect information when you attend an event, or participate in a program we sponsor. We collect information when you are an applicant for employment with us and employed by us. We also collect information through certain online tracking tools, such as browser cookies, flash cookies, and web beacons.
• Social media and related services.
• Service providers and contractors. When you obtain products and services from us, we may collect your PI from service provider and contractors who collected information about you that is needed to provide those products and services.
• Information Collected Automatically. As you navigate through and interact with our Site, we may compile statistical information concerning your usage of the Site through analytics services, such as those provided by Google Analytics. To do so, we may collect certain information about your equipment, browsing actions and patterns, including:
Details of your visits to our Site, such as traffic data, location data, logs and other communication data and the resources that you access and use on the Site
Information about your computer and internet connection, including your IP address, operating system, and browser type.
Information about the type of device you are using, mobile ad identifiers, the time and length of your visit, and the website that referred you to our Site.
Information about your preferences to make your use of the Site more productive, via the use of Cookies. For more information on Cookies, please see the Cookies and Other Tracking Technologies section. While all of this information can be associated with the IP address your computer had while you visited the Site, it will not be associated with you as an individual or with any other information you may submit through the Site or that we may store about you for any other purposes. We may use this information to generate aggregate statistics about visitors to our Site. Please check your web browser if you want to learn what information your browser sends or how to change your settings.
D. COOKIES, TRACKING, AND CERTAIN COMMUNICATIONS.
We use cookies and other web technologies to collect and store certain types of information when you visit the Site. A cookie is a small file consisting of letters and numbers that automatically collect certain information from you. This file uniquely identifies and recognizes your browser or device and transmits information back to the server. Depending on the cookie type, it may perform functions such as remembering your user preferences, improving the quality of your visit, recording the website pages you view, remembering the name or address you entered during a visit, or delivering ads that are targeted to your interests and browsing activity.
E. TYPES OF COOKIES. TYPES OF COOKIES INCLUDE:
First and Third-Party Cookies. First party cookies are generally placed on your computer or device by the website you are visiting. For example, we may use a first party cookie to improve website security. Third party cookies are placed on your computer or device by a source other than the website you are visiting in order to enable third-party features such as advertising, analytics, videos, or interactive content.
Essential or Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually set in response to actions taken by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. These cookies do not store any personally identifiable information.
Performance and Functionality Cookies. Although these are non-essential cookies, they help the website perform and function as designed. For example, performance and functionality cookies may help the website display videos, enable chat sessions, or recognize whether you visited the website before.
Analytics Cookies. These cookies track your usage of the website. The information these cookies collect can be used for various purposes such as understanding how visitors use the website, site and content customization, or advertising and marketing.
The Site uses essential, functional, and performance cookies to function and perform as designed; analytics cookies to understand how you use the Site, improve its functionality, and other related purposes; and advertising cookies to help us with our advertising and marketing activities. We and our third-party partners and service providers may collect and track information about your online activities over time and across different websites, applications, and devices.
Embedded Content and Social Media Widgets. The Site contains embedded content (e.g., videos) and Social Media Widgets (e.g., LinkedIn). Embedded content may place third party cookies on your device that track your online activity to enhance your experience or assess the success of their application. Social Media Widgets allow us to integrate social media functions into the Site. These widgets may place third party cookies on your device for tracking and advertising purposes. We have no direct control over the information these cookies collect; please refer to the applicable third party’s website privacy policy for additional information.
Controlling Cookies. You may control cookies, including preventing or stopping the installation and storage of cookies, through your browser settings and other tools. Most browsers will allow you to block or refuse cookies. However, you may need to manually adjust your preferences each time you visit a site. For more information, see the Help section of your browser. Please note that if you block certain cookies, some of the services and functionalities of our Site may not work.
IMPORTANT: BY USING THE SITE, YOU CONSENT TO THE PROCESSING OF ANY PERSONAL INFORMATION FOR THE PURPOSES AND FUNCTIONS DESCRIBED ABOVE.
Do Not Track. “Do Not Track” is a privacy preference that you can set in your Internet search browser that sends a signal to a website that you do not want the website operator to track certain browsing information about you. However, because our Site is not configured to detect Do Not Track signals from a user’s computer, we are unable to respond to Do Not Track requests.
Third Party Website Links. Some portions of our Site may contain links to other websites on the Internet that are neither under our control nor maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that we are providing these links to you only as a convenience, and you agree that we are not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites.
To the extent you voluntarily opt to have SMS notifications sent directly to your mobile phone, we receive and store the information you provide, including your telephone number or when you read a text message. You may opt out of receiving text messages at any time by texting “STOP” to our text messages. For more information about text messages, see our Site’s Terms and Conditions of Use.
F. DISCLOSURES OF PERSONAL INFORMATION.
We do not sell or share your personal information to third parties. We also do not use or disclose your sensitive personal information for purposes that, with limited exceptions, are not necessary in order to provide our products and services as are reasonably expected by an average consumer requesting those goods and services.
We may, however, disclose your personal information with services providers and contractors who help us provide services, such as, email, text and other communications, applications, sales, business and inventory support, photography, and website, software, platform, cloud, data storage and other technical services.
We may also disclose your personal information if necessary to: (1) comply with federal, state, or local laws; (2) comply with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities; (3) cooperate with law enforcement agencies concerning conduct or activity that we reasonably and in good faith believe may violate federal, state, or local laws; or (4) exercise or defend legal claims.
Lastly, we may transfer to a third party personal information as part of a merger, acquisition, bankruptcy, or other transaction in which the third party assumes control or acquires of all or part of the assets of our business.
G. SECURITY
We take precautions to protect data and information under our control from misuse, loss or alteration. Our security measures include industry-standard physical, technical, and administrative measures to prevent unauthorized access to or disclosure of your information, to maintain data accuracy, to ensure the appropriate use of information, and otherwise safeguard your personal information. However, no system for safeguarding personal or other information is 100% secure and, although we have taken steps to protect your personal information from being intercepted, accessed, used or disclosed by unauthorized persons, we cannot fully eliminate security risks associated with personal information.
H. APPLICABLE LAW
This Policy is governed by the laws of the State of Georgia without regard to its conflict of laws principles. Jurisdiction for any claims arising under or out of this Policy shall lie exclusively with the state and federal courts with Jurisdiction over Cherokee County, Georgia, as more expressly detailed within the Site’s Terms and Conditions of Use. If any provision of this Policy is found to be invalid by a court having competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect.
I. NOTICE TO SITE USERS LOCATED OUTSIDE THE U.S.
The Company operates in accordance with the laws of the U.S. When you access our Site from outside the U.S., we may transfer the PI that we collect from you to a location outside of your jurisdiction, including the U.S. The data protection laws in these jurisdictions may not provide you with the same protections as those of your jurisdiction. By using this Site, you acknowledge that these laws may provide a different standard of protection and you consent to the transfer of your personal data to other jurisdictions, including the U.S.
J. CONTACT US
If you have additional questions, you can write to us at: ask@alturahc.com
K. CHANGES TO THIS POLICY
We reserve the right to revise this Policy at any time. If we make any material changes, we will update the date noted above. We reserve the right to provide notice of any changes in other ways as well. Your use of this Site or submission of personal information after such changes constitutes your agreement to the Policy as amended. Except to the extent we receive your authorization, or as permitted or required by applicable law, we will handle your personal information in accordance with the terms of the Policy in effect at the time of the collection. Please check our Site periodically for updates.