Effective Date: March 2022
We’re Koa Health.
Your insurer has given us permission to use information about you and your health so that you can use Foundations.
We only collect the information we need to run and improve Foundations.
We collect your information to help you support and maintain your health and wellness. We may collect additional information with your permission or to comply with the law.
We share information about you with third-party service providers.
This helps us provide some parts of the service (such as notifications). We ask our service providers to keep your information safe.
You need to be 18 or over to use Foundations.
By using Foundations you are telling us that you are at least 18 years old.
We work hard to keep your information safe.
We work to protect your information from being lost, stolen or misused. Because no system is perfect, you can help by keeping your password and account details safe.
We use your information to contact you.
This helps us communicate with you and respond to your questions.
1. Personal Information We Collect
We receive information from your health care insurance carrier to verify your eligibility to access and use the App. We also collect information about you, directly or indirectly, when you use our App. Below is a summary of the information we collect.
- Profile information: We collect your (a) name, (b) email address, (c) date of birth, and (d) member ID number.
- Program and activity information: The App offers an interactive program designed to support and maintain your general health and wellbeing. You may participate in activities, quizzes or exercises and provide information using the App. Information we collect for the App may include:
Your goals for using the app, such as feeling overwhelmed, trouble sleeping, etc
- Information related to how you perceive your stress, such as a Perceived Stress Scale assessment with questions around how stressed or overwhelmed you have felt over the past week. We collect this information so that you can better understand your perceived stress and see how it might change over time. This information is used to determine the evolution of your perceived stress.
- Information related to the activities provided within the App, such as text you insert into the App within the journaling activities.
- Your opinion on the App and its functionality, if you choose to provide us feedback.
- Periodic information about how you feel and your mood e.g. stressed, happy.
Dates and times at which exercises or quizzes were performed.
- Device data: Our App will register information about the device you use to access the App. This includes fields such as device type, operating system and version, and IP address.
- App activity data: We collect data about how you interact with the App. This includes data about the length of your sessions in the App, how long you view specific screens, what App features you may click on or use, and what you search for in the App.
- Error and troubleshooting data: We collect data about problems users encounter while using the app, and suspicious uses of the App. This data includes suspicious activity alerts, crash reports, error reports, or similar reports.
A Note about Protected Health Information and HIPAA.
If you are receiving Foundations from your US health insurer, some of the information we collect about you is “Protected Health Information” (“PHI”) under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Generally speaking, the following information will be PHI: (a) the information we receive from your healthcare insurance carrier and (b) information you provide in the App that relates to your past, present, or future physical or mental health or condition; the provision of health care to you; or the past, present or future payment for the provision of health care to you.
Note that PHI can be deidentified in which case it is no longer considered PHI. This can be done by removing 18 specific types of identifier from the information pursuant to HIPAA regulations. We may de-identify PHI, in accordance with HIPAA, and use it as non-PHI for the purposes listed in Section 2.
2. How We Use Personal Information
We use personal information for the following purposes:
- Support service and communications: We use personal information to process any requests or inquiries from you or to otherwise communicate with you, including sending you email and/or notifications.
- Analytics and service improvement: We analyze how people use our App . We evaluate and improve our App, and develop new features or services.
- Personalization: We may use personal information to personalize your experience in the App, or to optimize notifications to you.
- Research: We may use personal information to conduct internal and scientific research. If our research results in a published study, it will contain only aggregated data that cannot be traced back to any specific individual.
- Maintaining integrity of the App and our systems: Personal information may be used to prevent fraudulent or suspicious activity, or otherwise protect the App, users, or our IT systems.
- Compliance and legal claims: We use personal information in connection with complying with applicable laws, regulations, policies, legal process, and agency requests. We also use personal information to carry out our obligations and enforce our rights arising from any contracts entered into between you and us. We may also use personal information in connection with establishing, exercising, or defending legal claims.
- Protection of rights and health: Personal information may be used to protect the health, safety, welfare, rights, or interests of you, us, any third party, or the general public.
- Other purposes: We may use personal information for other purposes but only with your direction or consent.
3. How We Share Personal Information
- Koa Health affiliates: We may share personal information with other companies in the Koa Health group.
- Our service providers and business partners: We may share personal information with companies that provide services to us, or otherwise help us operate our business or the App.
- Government authorities and law enforcements: We may share information with government authorities, law enforcements or other third parties in connection with: (a) compliance with applicable laws, regulations, policies, legal process, and agency requests; (b) establishing, exercising, or defending legal claims; or (c) protecting the health, safety, welfare, rights, or interests of you, us, any third party, or the general public.
- Third parties in connection with a sale of business: We may share or transfer information with another business in connection with a merger or sale of our business or assets to that business.
- Other third parties: We may share information for other purposes but only with your consent.
We maintain safeguards designed to protect personal information collected through our App and require our service providers to implement reasonable security measures to protect personal information. However, no security system is impenetrable, nor can we guarantee the security of the information you transmit to us over the Internet, including your use of e-mail. We ask you to take responsibility to safeguard your access credentials and the devices you use to access our App (such as laptops, tablets and mobile devices) and to use appropriate security settings on those devices.
Our App is not designed for or intended to be used by persons under the age of 18. In particular, if you think that we have collected personal information from a child under the age of 13 through our App, please contact us immediately at firstname.lastname@example.org.
7. Do Not Track
As there is currently no generally-recognized Do Not Track signal, our App is not designed to respond to Do Not Track signals or requests.
9. Contact Us