Last Updated: March 3, 2024
This Privacy Policy explains the privacy practices of Path Healthcare Systems Corp. (“Path”), Emerald Medical Practice, P.C. (“Emerald”) and their affiliates (collectively, “Nav Health,” "Nav", “Nile”, “we,” “us,” “our”) regarding personal information that we collect through our website, applications, and other interactions with us as described below (the “Services”).
Please note that as part of the Services, we may process information that is subject to the Health Insurance Portability and Accountability Act (“HIPAA”). When governed by HIPAA, this information is called “Protected Health Information” or “PHI.” We will provide you a separate HIPAA privacy notice that will govern our collection, use and disclosure of your PHI. To the extent there are inconsistencies between the HIPAA privacy notice you receive and this Privacy Policy, the HIPAA privacy notice will govern.
1. PERSONAL INFORMATION WE COLLECT
Personal Information You Provide to Us. We may collect personal information that you provide to us, as further described below:
- Contact Information, such as your name and email address when you contact us via our Services.
- Identification details such as your first and last name, email and mailing addresses, phone number.
- Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
- Account information, such as the username and password you use to access our Services.
- Subscription and payment information including your purchases, transactions, and billing information. We use a third-party payment processor to manage your payments, and we do not have access to your full payment card information.
Information we obtain from third parties.
- Social media information. We may maintain pages on social media platforms, such as LinkedIn, X, and Instagram. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information.
- Other sources. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources, and data providers.
Information Collected Automatically. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services and our communications, such as:
- Device Data, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, browser or device information, location information (including approximate location derived from IP address), and Internet service provider.
- Online Activity Data, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
We use the following tools for automatic data collection:
- Cookies, which are small text files placed in device browsers that store preferences and facilitate and enhance your experience. For example, Google Analytics collects information about how users use our website, which we then use to compile reports that disclose trends without identifying individual visitors, and help us improve our website. For more information on Google Analytics, click here.
- Pixel Tags/Web Beacons, which are used to record, for example, that a user has visited a particular web page, accessed or opened an email or clicked on a particular content.
2. HOW WE USE YOUR PERSONAL INFORMATION
To operate our Services:
- Provide, operate, maintain and secure our Services.
- Communicate with you about our Services, including by sending you announcements, updates, security alerts, and support and administrative messages.
- Respond to your requests, questions and feedback.
Improve, monitor, and personalize the Services, including by understanding your needs and interests, and personalizing your experience with the Services and our communications.
For research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and disclose it to third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.
Direct marketing. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.
Compliance and protection. We may use personal information to:
- Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
- Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
- Audit our internal processes for compliance with legal and contractual requirements and internal policies.
- Enforce the terms and conditions that govern our Services.
- Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION. We disclose your personal information to third parties for a variety of business purposes, as further set forth below:
- Service providers. Companies and individuals that provide services on our behalf or help us operate our business (such as hosting, information technology, customer support, email delivery, and website analytics services).
- Authorities and Others. We may disclose personal information to law enforcement, government authorities and private parties, as we believe in good faith to be necessary or appropriate to comply with applicable laws, lawful requests and legal process, and to defend us against legal claims or disputes.
- Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
4. PRIVACY CHOICES
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
- Opt Out of Marketing Communications. You may opt out of marketing-related communications by following the opt-out or unsubscribe instructions contained in the marketing communications we send you. Note that you will continue to receive non-marketing emails (e.g., communications regarding updates to this Privacy Policy).
- Limit Online Tracking. There are a number of ways to limit online tracking, which we have summarized below. Please note that these opt-out tools are not associated with us and we cannot guarantee that these tools work as their providers advertise them:
- Blocking Cookies on Your Device. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/. Use the following links to learn more about how to control cookies and online tracking: Firefox; Chrome; Microsoft Edge; Safari (Mac); Safari (Mobile/iOS).
- Using Privacy Plug-Ins or Browsers. You can block our website from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
- “Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
5. JOB APPLICANTS
When you apply for one of our open positions, we collect the information that you provide in connection with your job application. This includes but is not limited to business and personal contact information, professional credentials and skills, educational and work history, and other information that may be included in a resume or that you may provide during the interview process. This may also include demographic or diversity information that you voluntarily provide. We may also conduct background checks and receive related information. We also collect personal information from other sources where relevant for your application, such as employment research firms, recruiters, identity verification services, and information that you make publicly available on websites or social media platforms (for example, LinkedIn). Throughout the recruitment process, we may supplement your personal information in connection with the assessment of your application. For example, we may record the views of those considering your application about your suitability for the role for which you have applied and retain interview notes. If you accept an offer from us, your personal information will be incorporated into and used as part of your employee record.
We use applicants’ information to facilitate our recruitment activities and process employment applications, including evaluating candidates and monitoring recruitment statistics. We also use successful applicants’ information to administer the employment relationship. We may also use and disclose applicants’ information to improve our Service and for the compliance and protection purposes described above.
6. SECURITY OF YOUR INFORMATION. We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us.
- CHILDREN’S INFORMATION. Our Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it.
- THIRD PARTY SERVICES. Our Services may contain links to other websites/applications and other websites/applications may reference or link to our website. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications.
- CHANGES. We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our Services.
CONTACT US. If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: support@navhealth.co.