Scope or Applicability
Specific to patients who are using the platform in connection with a program sponsored by either a pharmaceutical manufacturer, hub, or specialty pharmacy.
We have the highest regard for your privacy and personal information and realize that the success of our service depends on the trust that users have in the way we handle their personal information. This policy sets out our commitments and explains the rights that you have with respect to your personal information.
Information Collection and Use
Use of the Platform requires registration. If you choose to register with us, you will be asked to provide Personal Information (as defined below) and may also be asked to input Personal Health Information. It is your voluntary decision whether to provide us with any such Personal Information or Health Information, but if you refuse to provide such information we may not be able to register you to use the Platform or your use of the Platform may be limited.
Collecting and Using Your Personal Information and Health Information (Actively Provided Information)
“Personal Information” means information that can be directly associated with a specific person(and can include Health Information that is directly associated with a specific person). When you register or update your information on our Platforms, we collect Personal Information including, but not limited to:
- first and last name;
- e-mail address;
- year of birth;
- geographic location, including your zip code;
- phone number;
- data used to recognize your face (for facial recognition, not a photo or video);
- disease state and disease progression;
- medication type;
- medication usage and adherence;
- side effects;
- self-reported wellness information, including weight, exercise, and nutrition;
stress or anxiety levels;
- other self-reported information relevant to your health, wellness, and disease management;
- other self-reported information asked during the course of a conversation, for purposes of providing a more engaging and personalized conversation.
During registration or subsequently, you may choose to use certain features of the Platform that will allow you to input Personal Information with respect to your health, such as the medications you take, the date of your prescription, the date you received your diagnosis, the number of refills you have made, how often you take your medication, the frequency you would like us to send you reminders to take your medication, whether you take your medication, and other information related to your treatment or your illness (“Health Information”). We will tailor our Platform to improve Mabu’s conversations with you and to improve our system for helping with your care management using this information.
Your use of the Platform is in conjunction a recent visit with a Partner for a healthcare condition, and/or in conjunction with medication you have been prescribed prior to enrolling in this Program and provided by a Partner. We are a business associate of the Partner we provide Personal Information to. We supplement care management services our Partners. The Partner will provide us Personal Information about you, such as your medication list, address, phone number, and other Personal Information. This is in order to send Mabu Wellness Companion Robot to the correct address and to ensure it provides you with information about your prescription so that we can personalize our service to you. We will also provide Partner with your Personal Information in order to help coordinate your care management and help manage your health.
We may provide aggregated, de-identified information to other Partners, such as pharmaceutical manufacturers. This information is not identifiable to you.
Ensuring the accuracy and completeness of the Personal Information and any other information that you provide in connection with your use of the Platform is important. Inaccurate or incomplete information will affect the functioning of the Platform, as well as the information you receive from us and our ability to contact you.
Automatic Data Collection
The Platform may automatically collect certain information about you when you utilize the Platform, such as what time(s) you use the Platform, data related to the cellular or WiFi connection you use to connect to the Platform, and when the Mabu Wellness Companion Robot is turned off or turned on.
Data collected automatically on the Platform may be used, for example, to help diagnose problems with our infrastructure, to make the Catalia Health Platform more useful, and to customize the Platform and personalize its content for you.
Sharing of Your Personal Information with Third Parties and Service Providers
We may share your Personal Information and Health Information with our Partners. Personal Information and Health Information is provided to them to improve the Platform, improve the efficacy of your treatment program, improve their marketing to persons with similar treatment issues, and to more be able to treat people with similar issues.
You have been provided specific information from the entity who provided the Mabu WCR to you about who will receive your Personal Information. Contact this entity, the company that opted you in to the Mabu WCR, to get further information about who receives your Personal Information from them and for what purpose.
We will not publish your Personal Information without your explicit consent.
We may ask for your consent to share your Personal Information with third parties, such as research institutes, healthcare systems or doctors, for research purposes and so that they can cross-check such information with other information that they have about you, for research purposes and for improvement of our services. We will first obtain your consent for the same.
Sometimes we may provide limited access to your Personal Information to the extent necessary to our contractors and consultants, who are bound by an obligation of confidentiality, including vendors and suppliers that provide us with development services, technology, services, or content for the operation, development and maintenance of our Platform or data and analysis on Platform use. Such access is limited to the information reasonably necessary for the contractor or consultant to perform its services to us. We also require that such contractors and consultants agree to protect the privacy of your Personal Information and agree not to use or disclose Personal Information for any purpose other than providing us with products and services and as required by law. We mitigate access to Personal Information by requiring specific access to systems that can be used to tie your de-identified information with information that identify you.
In addition, we may share your Personal Information with third parties, such as law enforcement authorities, courts and tribunals, to respond to law enforcement requests or other legal requests or pursuant to a requirement imposed by law, order, judgment or decree, as required by law.
We may also share your Personal Information with legal advisors, consultants, or courts in order to protect and defend our rights and property or those of Platform users. We may also transfer your Personal Information in the event of a merger, acquisition, or sale of all or a portion of our assets.
Use of Aggregated Data
We may analyze all information we receive and/or combine your Personal Information, including Health Information and information regarding your use of the Platform, with information from other users to create aggregated data that may be disclosed to and utilized by us, our affiliates and by third parties without restriction, on commercial terms that we can determine in our sole discretion for purposes of content marketing, for research purposes, in order to understand behavior patterns and in order to increase adherence to medication regimens, to lessen or reduce side-effects, and symptoms, and to improve disease management. Such aggregated data will not contain any information that could be used to contact or identify you.
Personal Information and/or Health Information (“PHI”) may be sent to you via SMS text from or on behalf of Catalia Health or the Partner who provided the Mabu WCR to you if you provide your consent to such texts. While the SMS texts we send are encrypted according to industry standards during transmission through our Platform, you should contact your cellular provider if you have questions about encryption through your cellular network.
You should be aware that PHI sent to your phone through SMS texts could be seen by other people who have access to your mobile phone or access to SMS texts to that number through other devices you may have set up.
If you change your telephone number, you agree to notify Catalia Health, the Specialty Pharmacy Partner, and other applicable parties promptly by calling your specialty pharmacy or the technical support number provided to you in one page setup insert provided with the Mabu WCR.
Personal Information and/or Health Information may be sent to you via email message if you authorize such usage. While the email message we send is encrypted according to industry standards during its transmission through our Platform, you should contact your email host if you have questions about its encryption through your email service.
Disabling the Service, Access, Corrections, and Deletion
At any time, you can stop the collection of your information by unplugging the Mabu WCR and refraining from using the Platform. You may also request that your Personal Information be deleted from our active databases. A separate request will have to be made with each Specialty Pharmacy Partners which are providing our Platform to you. We cannot restore information that we have deleted. We may retain any data in de-identified form, subject to applicable law.
You may contact us as specified below under “How to Contact Us” to access information that we keep about you or update or correct such information or ask for its deletion. We will retain your information for as long as you continue to use our Platform and for a reasonable period of time afterwards.
Links to Other Websites or Apps
We take reasonable steps to protect Personal Information as you transmit it to us and to protect such information from loss, misuse and unauthorized access, disclosure, alteration or destruction. However, you should keep in mind that no Internet transmission is ever completely secure.
We may transfer our databases containing your Personal Information if we sell our business or part of it.
Your Health Information is protected and secured under HIPAA (the Health Insurance Portability and Accountability Act of 1996) guidelines and other applicable law. Some Personal Information you provide to us (that which is not Health Information) is not protected by HIPAA. HIPAA protects health information held by or on behalf of your health care provider or health plan.
How to Contact Us
ATTN: Catalia Health Privacy Questions
629A Bryant St., San Francisco CA 94107