Laso
Health Privacy
Policy
Effective Date: January 27, 2020
Last
Updated: September 6, 2023
1.
Introduction
This Privacy Policy (“Privacy Policy”)
is incorporated by
reference into Laso
Health, LLC’s (“Laso
Health,” “we,” or “us”)
Customer Terms of Use and
Healthcare Provider
Terms of Use (collectively “Terms
of Use”)
regarding Laso
Health’s use of the information you and third parties provide as part of your use of the Site and Services
(as such
terms are defined in the Terms of Use). Any capitalized term used but not defined in this Privacy Policy shall have the meaning
in our
Terms of
Use. BY USING OR OTHERWISE ACCESSING THE SERVICES, AND/OR
BY CREATING
AN ACCOUNT
WITH US, YOU ACKNOWLEDGE AND AGREE THAT YOU HAVE READ THIS PRIVACY POLICY,
UNDERSTAND ITS
TERMS,
AND AGREE
TO BE
LEGALLY
BOUND BY
ITS TERMS.
IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY,
YOU ARE
NOT PERMITTED
TO USE OR
ACCESS THE SITE OR THE
SERVICES IN ANY WAY. This Privacy Policy does not apply to any other website or digital
service that
you may be able to access through
the Services
or any
website
or digital
services
of Laso
Health’s business
partners, each of which may have data collection, storage and use practices and
policies that may differ from this Privacy Policy.
YOU HEREBY CONSENT TO THE COLLECTION,
USE, AND SHARING OF YOUR INFORMATION (INCLUDING INFORMATION THAT MAY
BE CONSIDERED PRIVATE OR SENSITIVE) AS DESCRIBED IN THIS PRIVACY POLICY. IF YOU
USE THE SERVICES ON BEHALF OF SOMEONE
ELSE (SUCH AS YOUR CHILD) OR AN ENTITY (SUCH AS YOUR EMPLOYER), YOU
REPRESENT THAT YOU ARE AUTHORIZED
BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH
INDIVIDUAL’S OR ENTITY’S
BEHALF.
Healthcare Providers
are subject to applicable federal and state laws and
regulations governing the use and disclosure of personally identifiable
information, including health information they create or receive, and most must
comply with the Health Insurance Portability and Accountability Act of 1996, as
amended from time to time (“HIPAA”). When we collect and process your
information, we may share that information with Healthcare Providers who have
entered into a [Healthcare Provider User Agreement] for the purpose of
providing you with the Laso Health services. We are committed to ensuring the
privacy and confidentiality of your information and, in doing so, use security
safeguards to protect such information. We do not ask Healthcare Providers to
share or send medical or health information to us from the services that they
provide to you.
2.
Information
We Collect
◦
Information We Collect
From You
As
a condition to receiving all or a portion of the App and/or Services,
we may
ask you to provide us certain information that personally identifies you or could be used to personally
identify you (“Personal Information”). Personal Information may
include (but is not limited to) the following categories of
information: (1) e-mail address,
mailing address, billing address, full name, phone number and other identifying information; (2) demographic data (such as your gender,
your date of birth and your zip code);
(3) information
regarding your past and present Healthcare Providers, such as the Healthcare
Providers you
have visited,
your reasons
for visit,
your dates of visit, your medical history,
and other
medical
and health
information you choose to share with us; and (4) other identifying
information that
you voluntarily
choose
to provide to us, including without limitation unique identifiers such as passwords.
Personal Information includes any information in the foregoing
categories that is sent via the App or
Site or as part of the Services as well as any applicable information that is
sent via emails, letters or text
messages. We may also collect additional information, as
otherwise described to you at the point of collection or pursuant to your consent.
◦
Information
We Collect Automatically
We
may automatically collect the following
non-personally identifiable information about your use of the App or
Site: domain name; browser type and
mobile operating system; IP address and/or cellular network device ID; and
features of the App used. In
addition, some features of the App require location services to be enabled on
your mobile device, meaning we may
temporarily collect location information as reported by your mobile device
(“Location Data”) in order to provide the features you requested. If you would
prefer not to send us Location
Data, you should disable
location services on your
mobile device before using the App or
Site, with the understanding that any features that require Location Data to
function will be disabled as a
result. Additionally, we may use the technologies described below (“Engagement
Tools”) to gather information
necessary to enhance and operate our Services in a number of ways, such as to
(i) save user preferences and information;(ii)
preserve session settings and activity; (ii) authenticate users; (iv) enable
support and security features; (v) tailor the delivery of informational messages,
media, advertising
and other
content;
and (vi)
analyze the
performance and
use of our Services
and its
various features
and content.
Device
Information. When you interact with our App and/or Services, we collect
information about your computer, mobile phone,
or tablet (“Device”) such as the URL of services your Device is requesting and
the referring web pages, your IP address,
Device type, operating system, browser type, application identifier, and, under
certain circumstances, the location information your Device sends to us.
Cookies
& Similar Technologies. We may also collect information about you and your
Devices through cookies, web beacons, and similar technologies. A “cookie” is a small data file sent from a website
and stored on your Device
to identify
your Device in the future and allow for an enhanced personalized user experience based on your previous activity
on the
website. A “session cookie” disappears after you close your web
browser, or may expire after a fixed period of time. A
“persistent cookie”
remains
after you
close your web browser and may be accessed every time you use our Services. We may use both
session and persistent cookies on our Services. You should consult your web
browser to modify your cookie settings. Please
note that if you delete or choose not to accept cookies from us, you may not be
able to use certain features
of our
Services.
◦
Billing,
Collection and Payment Information
When
you make a payment through our App or Services to a Healthcare Provider (as
further described in and subject to other
provisions of the Terms of Use and AUP), we may also collect your billing
information, including credit or debit card account information, or other forms of payment
(“Payment Card
Information”). By
submitting your
Payment Card
Information,
you expressly consent to the sharing of your information with third-party
payment processers and other third- party services
(including but
not limited to vendors who provide fraud detection services
to us and other third parties). These third
parties may store your Payment
Card Information for future use in our Services. We do not store your Payment Card Information, nor do we have direct
control or responsibility for your Payment Card Information. The third party
services
that we
utilize are
contractually obligated to keep your Payment
Card Information
secure
and confidential.
◦
Traffic
Data
We
also may automatically collect certain data when you use the Services, such as
(1) IP address; (2) domain server; (3) type
of device(s) used to access the Services; (4) web browser(s) used to access the
Services; (5) referring webpage or other
source through which you accessed the Services; (6) geolocation information;
and (7) other statistics and information associated with the interaction between
your browser
or device and the Services
(collectively “Traffic
Data”).
Some Traffic Data may be considered Personal Information.
◦
Information
Authorization
Laso Health may
only use and disclose your information in the ways permitted by law and in
accordance with applicable consent. To avoid any doubt, in order to receive
services from Laso Health, we require that you e-sign the Laso Health
Information Authorization. The Laso Health Information Authorization contains a
mechanism for opting out of marketing using your Health Information. The uses
and disclosures of Personal Information are further described in this Privacy
Policy.
3.
How We Collect
Information
We collect information (including Personal Information and
Traffic
Data) when
you use and interact with the Services, and in some cases from third party sources. Such means of collection include:
•
When
you use the Services’ interactive tools and services, such as searching for
Healthcare Providers, searching for available
appointments with
Healthcare Providers and completing medical history forms (“Medical History Forms”)
prior to Healthcare Provider
appointments;
•
When you voluntarily provide
information in
free-form text
boxes through
the Services
or through
responses
to surveys,
questionnaires and
the like;
•
If
you download and install certain applications and software we make available,
we may receive and collect information transmitted
from your computing device for the purpose of providing you the relevant
Services, such as information regarding
when you are logged on and available to receive updates
or alert
notices;
If you
download our
mobile
application or
use a
location-enabled browser, we may receive
information about
your location
and mobile
device,
as applicable;
•
Through
cookies, web beacons, website analytics services and other tracking technology
(collectively, “Tracking Tools”), as described below; and
•
When you use the “Contact Us” function on the Site, send us an email
or otherwise
contact
us.
4.
Tracking Tools and “Do
Not Track”
◦
Tracking
Tools
We
and third
parties
use cookies
and Tracking
Tools.
We use
first and
third
party Tracking
Tools to
collect
information including your
Personal Information, as well as usage and demographic information about you
over time. Third parties (e.g.,
advertising partners), collect such information, such as your name, address,
email address, gender, telephone number,
unique identifiers, preferences, etc., via these technologies. We and third
parties may
use browser
cookies
which are stored on your
computer in a file. In addition, we
and third parties may also collect and store your information
(including Personal
Information) via
web beacons,
remarketing pixel
tags,
and Flash
cookies
that are
placed
in the
code of a web page or email or which access your browsing activity. Where cookie
technologies may
not be
available (for
example in mobile applications), we and third
parties may use technologies that perform similar functions to cookies that
link identifiers
used for
advertising on
mobile applications
to an
advertising cookie
to coordinate
ads across
your mobile
apps and mobile
browser. We may use cross device tracking, Bluetooth low energy beacons,
ibeacons, audio beacons and digital fingerprinting to identify and track you when you use different devices. By using the
Site, you
consent
to the
use of
cookies
and Tracking
Tools described
in this
Privacy
Policy.
We may
use a type of advertising commonly known as interest-based or online behavioral
advertising. This means that some of
our partners use Tracking Tools to display Laso Health ads on other websites or
services based on information about
your use of the Services or your interests (as inferred from online activity).
Such partners may include third-party service
providers, advertisers, advertising networks
or platforms,
and agencies.
◦
Options
for Opting out of Cookies and Mobile Device
Identifiers
Some
web browsers
(including some
mobile web
browsers) allow
you to reject cookies
or to
alert you
when a
cookie
is placed on your computer,
tablet or mobile device. You may be able to reject mobile device identifiers by
activating the appropriate
setting on your mobile device. Although you are not required to accept Laso
Health’s cookies or mobile device identifiers, if you block or reject them, you may not have access to all features available through the Services.
Please note that even after opting out of interest-based advertising, you may still see Laso Health advertisements that are not interest-based (i.e., not targeted
toward you). Also, opting out does not mean that Laso Health is no longer using Tracking Tools — Laso Health still may
collect information about your use of the Services even after you have opted
out of interest-based
advertisements and
may still
serve advertisements
to you via the Services
based on
information it
collects
via the
Services.
◦
How
Laso Health Responds to Browser “Do Not Track” (DNT)
Signals
Some browsers have
a Do Not Track (“DNT”) feature that lets you tell websites that you do not want
your online activities tracked. When
you choose to turn on the DNT setting in your browser, your browser sends a
special signal to websites, ad networks,
plug-in providers, and other web services you encounter while browsing to stop
tracking your activity via cookies or other Tracking Tools.
Laso Health
does not
proactively monitor or respond
to DNT
signals.
5.
Laso Health’s Use of
Information
We
use the
information that
we gather
about you
for the
following
purposes:
•
To
provide our services to you, to communicate with you about your use of our
services, and for other customer service purposes.
We use information, including Personal Information, consistent with your Laso
Health Information Authorization, to
provide the Services and to help improve the Services, to develop new services,
and to advertise (for example,
to display
Laso Health
ads on
other websites).
•
To
tailor the content and information that we may send or display to you, to offer
location customization, and personalized help
and
instructions,
and
to
otherwise
personalize
your
experiences
while
using
the
App.
As part
of the
Services, you
may receive email, mobile phone notifications
and other communications from us, such as communications relating to your
account. Communications relating to your
account will only be sent for purposes important to the Services, such as
password recovery and expiring account
notices. By creating an account, you are, by default, opted in to receiving
promotional
email communications from us. Upon downloading our mobile application, you will be provided the option to opt in to receiving
push notifications
or in-app
notifications from
us on your mobile
device. We
may use
your name,
and email
address, or mobile device identifiers to send you email messages, text
messages, in-app messages or push notifications
regarding advertising new services offered by Laso Health and or the Healthcare
Providers. In addition, we may
present
offers to
you on
behalf of
third party
partners.
If you
engage with
such offers
or advertisements
(e.g.,
clicking on
a banner ad), we may share your
name, address, credit card information and other identifying information with
this third party;
•
To
better understand how users access and use our App, both on an aggregated and
individualized basis, in order to improve
our App and respond to user desires and preferences, and for other research and
analytical purposes. Our customer
service representatives may use your telephone number, e-mail address, mobile
device identifier and other identifying
information to contact
you. Laso Health reserves the right to use the information collected from the
Site to send pricing,
advertisements and
information about
Healthcare Providers on behalf of Healthcare Providers.
•
We
may use your information to fulfill our legally required obligations, such as
preventing, detecting and investigating security incidents and potentially
illegal
or prohibited
activities.
•
User
profile information including your username and other information you enter may
be displayed to other users to facilitate user interaction within
the Services.
6.
Disclosure of
Information
In certain
circumstances, consistent with your Laso Health Information Authorization, and
in order to perform the Services, we may disclose certain
information (including
Personal
Information) that
we collect
from you:
•
Healthcare
Providers. We
may
share your Personal Information with Healthcare Providers with whom you choose
to schedule through the Services. For
example, if you complete a Medical History Form using the Services in advance
of an appointment, we may share your
Medical History Form with such selected Healthcare Providers. We may also share
your Personal Information with your
Healthcare Providers to enable them to refer you to and make appointments with
other Healthcare Providers on your
behalf or to perform analyses on potential health issues or treatments, or to
provide you with treatment
in the event of an emergency.
•
Health
Information Exchanges. We
may share your Personal Information with Health Information Exchanges and
related organizations
that collect
and organize
your information
(such as
Regional
Health Information
Organizations).
•
Business
Affiliates. We
may share your Personal Information with our partners to customize or display
advertising. We may also share your
Personal Information and Traffic Data with our partners who perform operational
services (such as hosting, billing,
fulfillment, data storage, security, insurance verification, Website analytics,
or ad serving) and/or who make certain services, features
or functionality
available
to our
users.
•
Business
Transfers. If
we
are acquired by or merged with another company, if substantially all of our
assets are transferred to another
company, or as part of a bankruptcy proceeding, we may transfer the information
we have collected from you to the
other company. However, if we do so, their use and disclosure of your
personally identifiable information will be subject
to this Policy
•
In Response
to Legal
Process.
We may share your Personal Information or any other information we collect about you if we determine in good
faith that such
disclosure is needed to: (1) comply with or fulfill our obligations under
applicable law, regulation,
court order
or other
legal process;
(2) protect
the rights,
property
or safety
of you,
Laso Health
or another party;
(3) enforce the Agreement or other
agreements with you; or (4) respond to claims that any posting or other content
violates third-party rights.
7.
Public
Information;
Public Forums
You
agree that
any information
that you may reveal in a review posting or online discussion or forum is intentionally open to
the public and is not in any way private. Do not disclose information in these
public forums that might be considered confidential
or proprietary or that you do not wish to be publicly available or that you are
prohibited from disclosing. We strongly
recommend against sharing any personally identifiable, health, or other
sensitive information that could directly or
indirectly be
traced to
any individual,
including
themselves. We
do not
undertake
any review of posts or online discussions to determine if any Personal Information is included in such posts or online discussions; provided
that Laso Health will review
posts or
online discussions
that are
flagged
for inappropriate
content.
8.
Surveys,
Feedback,
Informational
Programs
From
time to time you may receive survey requests through emails or displays
within our
Services that
request feedback
on a
variety of
topics. These
programs may
be sponsored
or funded
by third
parties,
and may
include
branded or
unbranded
content about medical conditions, treatments and products,
or safety
and regulatory
information resources. If you choose to engage with or
use one of these
requests, you may be asked to provide information that may be used to supplement information that you submitted to our Services.
This information
may be
shared
with the
sponsor
of the
program.
9.
Changing Your
Information
HIPAA grants patients certain
rights
to access
and amend certain
health information, including Protected Health Information (“PHI”)
that their
healthcare providers
retain
about them. Patients should submit requests to access or amend this
health information directly to their healthcare
providers.
10.
Third Party
Analytics
We
may use
automated
devices and
applications to
evaluate usage
of our
App. We
also may
use other
analytic means
to evaluate the services provided via our
App. We use these tools to help us improve our services, performance and user experiences. We do not share your Personal Information
with these
third parties.
11.
Storage
and
Security
of
Information
We
have implemented
commercially reasonable precautions,
including, where
appropriate, password
protection, encryption,
SSL, firewalls,
and internal
restrictions on
who may
access data
to protect
the Personal
Information we
collect from
loss, misuse,
and unauthorized
access,
disclosure, alteration, and destruction. Please
be aware
that despite
our best
efforts, no data security measures can
guarantee 100% security. Accordingly, we cannot guarantee the security of
information stored
on or
transmitted to
or from
our Services.
You
should
take steps
to protect
against
unauthorized access
to your
username, password, and mobile device, by among other things,
signing out of the App or
Site once your session is complete, choosing a robust password that nobody else knows
or can
easily guess,
and keeping
your username
and password
private.
We are
not responsible
for any
lost, stolen,
or compromised passwords
or for any activity
on your account via unauthorized password activity. You should change your
password and contact us
immediately
if you believe your password has been compromised or there has been any
unauthorized access to your account.
12.
Controlling Your Information
& Notifications
If you have an
account, you can modify certain account information by logging in and accessing your account. If you wish to close your account,
please email
us at Support@LASOhealth.com. Laso
Health reserves
the right to retain information from closed accounts, including to comply with law, prevent fraud, resolve disputes,
enforce the
Agreement
and take
other actions
permitted by
law.
You must promptly notify us if any of your account
data is lost, stolen or used without
permission.
13.
California
Privacy Rights
For California
residents, we may share your personal information with third parties and
affiliated third parties (such as local, state, and regional affiliates and
affiliate alliances), for direct marketing purposes. As these third parties and
this category of affiliated third parties are considered an unaffiliated party
under California law, you may opt-out of our disclosure of personal information
to third parties for their direct marketing purposes. To opt out please contact
us at the contact information section provided below. Otherwise, we will continue
to provide your information to local, state, and regional affiliates and
affiliate alliances identified in your account.
The California
Consumer Privacy Act (CCPA), effective January 1, 2020, gives California
consumers enhanced rights with respect to their personal information that is
collected by businesses. First, California consumers may opt out of having
their personal information sold to other persons or parties. Second, they have
a right to know:
1.
What
specific pieces of information a business has about the consumer;
2.
Categories
of personal information it has collected about the consumer;
3.
Categories
of sources from which the personal information is collected;
4.
Categories
of personal information that the business sold or disclosed for a business
purpose about the consumer;
5.
Categories
of third parties to whom the personal information was sold or disclosed for a
business purpose; and
6.
The
business or commercial purpose for collecting or selling personal information.
In addition,
California consumers can request that the personal information a business has
collected about them be deleted from the business's systems and records.
Company may be considered a covered business under the CCPA as it collects and
processes the personal information of California consumers. This Privacy Policy
provides the required notices to California consumers. The CCPA also prohibits
covered businesses from providing discriminatory treatment to California
consumers if they exercise their rights under the Act. We do not rent or sell
your personally identifiable information (such as name, address, telephone
number and credit card information) to unaffiliated third parties for their
marketing purposes. We may share your information with third parties to provide
products and services you have requested, when we have your consent, or as
described in this Privacy Policy. To make a "request to know" or
request to delete your personal information, send us an e-mail at Support@LASOhealth.com
(Please put either "Request to Know" or "Request to Delete"
in the subject heading of your email.) We will use commercially reasonable
efforts to honor these requests whether or not you would qualify as a
California consumer under the CCPA. If and to the extent we are considered a
covered business under the CCPA: We will confirm receipt of your request within
10 days along with a description of what steps we will take to verify and
respond. We must provide the requested information or delete your personal
information within 45 days of receipt of your request but can use an additional
45 days, but we must let you know the additional time is needed.
When contacting
us, we may ask you to provide certain, limited personal information, such as
your name, email address and/or account login ID and/or password, to verify
your request and to match with our records and systems. This is also to protect
against fraud. We will not retain this personal information or use it for any
other purpose. Also please be advised that we need to search our records and
systems only for the preceding 12 months.
Residents of other
states may also have similar rights to request information about or delete
their personal information. To inquire about exercising these rights, please
contact us at Support@LASOhealth.com.
Pursuant
to California's "Shine The Light law (California Civil Code§ 1798.983),
California residents are entitled, once a year and free of charge, to request
the disclosure of certain categories of personal information to third parties
for their own direct marketing purposes in the preceding calendar year, if any.
Under the law, a business should either provide California customers certain
information upon request or permit California customers to opt out of this type
of sharing. You may request this information by contacting us at Support@LASOhealth.com
and indicate in the email subject line, "California Shine The Light
Request." Please include your mailing address, state of residence and
email address with your request.
14.
Information Provided on Behalf of Children and Others
The Services are
not intended for use by children and children are prohibited from using the
Services. Laso Health does not knowingly collect
any information
from children,
nor are
the Services
directed
to children.
By accessing, using and/or submitting information to or through the- Services, you represent that you are not younger than
age thirteen
(13). If we learn that we have received
any information
directly
from a
child under
age thirteen
(13) without
his/her parent’s written
consent, we
will use that information only to respond directly to that child (or his/her
parent or legal guardian) to inform the child that he/she cannot use the Services, and we will subsequently delete that
information.
If you are a
California resident under 18 years old and have an account, you can request
that we remove content or information that
you have posted to our website or other online services. Note that fulfilment
of the request may not ensure complete or
comprehensive removal. To request removal of content or information, please
email us using the contact information below.
If
you use the Services on behalf of another person,
regardless of
age, you
agree that
Laso Health
may contact
you for any communication made in connection with providing the Services or any legally required communications.
You further
agree to
forward
or share
any such
communication with
any person
for whom
you are
using the
Services on
behalf.
15.
Third Party
Websites
Our App or Site
may contain links to third-party websites. Any access to and use of such linked
websites is not governed by this Policy, but
instead is governed by the privacy policies of those third party websites. We
are not responsible for the information practices of such third
party websites.
A link to any third party site does not mean that we endorse
it or
the quality
or accuracy
of information
presented on
it.
16.
Updates and Changes to Privacy Policy
We may change this
Privacy Policy at any time, as we deem appropriate. Upon any such change, we
will post the amended Privacy Policy
on the Site; we may also attempt to notify you in some other way. Your
continued use of the Site and/or the Services following
such posting
shall constitute
your affirmative
acknowledgement of
the Privacy
Policy, the
modification, and agreement to abide and be bound by the
Privacy Policy, as amended. We encourage you to periodically review this
Privacy Policy. IF AT
ANY TIME YOU
CHOOSE NOT TO ACCEPT THIS PRIVACY POLICY, INCLUDING FOLLOWING ANY
SUCH MODIFICATIONS
HERETO,
THEN YOU
MUST STOP
USING THE
APP, SITE, AND THE
SERVICES.
17.
Contacts
If
you have any comments, concerns
or questions
about this
Privacy Policy,
please contact
us at Support@LASOhealth.com or
at:
Laso
Health, LLC.
215
N. San Saba
Ste 301
San
Antonio, Texas 78207 Phone: (866) 527-6757
Fax:
(210) 468-8001
© 2023 LASO Health, LLC. All rights reserved.