Effective Date: 12/29/2023
Emory Healthcare (“Emory”) is committed to protecting the privacy of all individuals (“you” or “your”) who utilize the App (as defined in the End User License Agreement). This statement explains how we and our service providers (“we” or “us”) collect, use, and safeguard the information you may provide via the App.
1. WHAT INFORMATION DO WE COLLECT FROM YOU?
We may collect certain information related to your use of the App. We collect personal information and non-personal information (collectively referred to as “information” throughout this Privacy Notice).
When we use the term “personal information” in this Privacy Notice, we mean information about you that is personally identifiable to you, including information that is considered “protected health information” under Federal law, if any. We collect the following personal information from you:
- Your precise geolocation within Emory’s facilities as of a specific date and time.
As stated above, we also collect information that does not identify you (“non-personal information”). When you access the App from a mobile device, we may collect non-personal information from your use of the mobile device, including:
- The date and time use of the App started and stopped;
- The route taken while using the App;
- Your mobile device manufacturer, model, and operating system and version;
- Any errors detected while using the App;
- Any wi-fi signal observed (if using an Android device); and
- The version of the App and map used;
In order to collect the above information, we utilize certain tracking technologies, such as Bluetooth beacons, WiFi, and geomagnetic positioning.
2. HOW YOUR INFORMATION IS USED
We collect, retain, and use your personal information for the following purposes:
- To provide you the services and products you requested;
- To operate and improve the App;
- To respond to an inquiry from you;
- To create aggregated, non-personal information, or to create de-identified information;
- To comply with applicable laws, regulations or legal process;
- To comply with requests of relevant regulatory and law enforcement and/or other governmental agencies or authorities; and
- To enforce our End User License Agreement; and/or to protect the rights, property, or safety of Emory and other users of the App.
We may use any non-personal information for any purposes as appropriate and subject to applicable law, since non-personal information cannot identify you as an individual. For example, we may use non-personal information collected to monitor visitor traffic patterns and App usage and to improve the App. We may also use non-personal information in the aggregate to create summary statistics that help us analyze App usage trends, determine technical design specifications, arrange the App in a user-friendly way, and identify system performance or problem areas. We also use non-personal information to protect the security and integrity of the App.
3. WHEN WE SHARE YOUR INFORMATION
We share your information in the following circumstances:
- Service Providers. We may share your information with affiliated and unaffiliated companies (such as Purple Wifi) that perform tasks on our behalf related to our business. Such tasks include analyzing usage data, fixing errors in the App, and protecting the security and integrity of the App. Third-party service providers receive your information as necessary to perform their role, and we instruct them not to use your information for any non-permitted purposes.
- As Required by Law. We will disclose your information as necessary or appropriate, including as required by law, regulation, subpoena, court order, legal process or government request; to enforce our End User License Agreement, including investigations of potential violations thereof; to detect, prevent or otherwise address fraud, security or technical issues; when we believe in good faith that disclosure is necessary to protect your safety or the safety of others; to protect our rights, to investigate fraud, or to respond to a government request.
- Business Transfers. We may, in the future, sell or otherwise transfer some or all of its assets to a third party. The information we obtain from you via the App may be disclosed to any potential or actual third-party purchasers of such assets and/or may be among those assets transferred in accordance with applicable law.
4. YOUR PRIVACY CHOICES
Depending on where you live, you may have the following rights with respect to your personal information, to the extent applicable to the App:
- Access
- Data portability
- Erasure
- Correction
- Opt out of sales of personal information
For a description of these rights, please see the applicable chart in Section 10 of this Privacy Notice. In addition, you may have the right to opt out of targeted advertising and profiling, to the extent that profiling makes decisions that produce legal or similarly significant effects concerning you. To exercise any of these rights available to you, see Section 12 below.
5. CHILDREN
The App prohibits children under 13 to become users, and we do not collect information from children. By using the App, you represent that you are not under the age of 13. Any information we receive from users we believe to be under the age of 13 will be purged from our database.
6. THIRD PARTY WEBSITES
Emory may reference or provide links to third party websites or Emory’s other websites. You should review the privacy notices posted on such sites, as those privacy notices will control once you are directed to those websites. Please be aware that Emory does not control, nor are we responsible for, the privacy notices or information practices of third parties or their websites.
7. RETENTION
We have policies and procedures relating to the retention of personal information based upon a classification scheme consisting of business functions and process areas, and the classification and types of data and records. We retain personal information for as long as we reasonably require it for business and legal purposes. In determining data retention periods, we consider contractual and legal obligations, and the expectations and requirements of customers, vendors, suppliers and others who disclose their personal information with us. When we no longer need personal information, we securely delete or destroy it.
8. SECURITY
We employ security systems designed to protect the personal information we receive from you from unauthorized disclosure. We make commercially reasonable efforts to keep your personal information secure using appropriate technical, physical and organizational measures to prevent against unlawful use, alteration, unauthorized access accidental destruction and loss. No transmission of data over the internet is guaranteed to be completely secure. Due to the nature of the internet, we cannot guarantee that information, during transmission through the internet or while stored on its system or otherwise in its care, will be absolutely safe from intrusion by others, such as hackers. Because security is important to both Emory and you, we will always make reasonable efforts to ensure the security of our systems.
9. UPDATES
Emory may update this Privacy Notice from time to time to reflect changes to our information practices. We will provide you with advance notice of a major change prior to your access of any portion of the App. For example, we may (i) require that you re-accept the updated version of this Privacy Notice, (ii) send you an electronic notification advising of the update to this Privacy Notice, or (iii) include a notice on the App. We do not ordinarily provide advance notice of a minor change.
We encourage you to periodically review this page for the latest information on our privacy practices. You can tell when changes have been made to the Privacy Notice by referring to the “Effective Date” legend on top of this page.
10. USERS FROM OUTSIDE THE UNITED STATES
This App is hosted in the United States and is governed by United States law. If you are using the App from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our (or our service provider’s) servers are located. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the App, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Privacy Notice.
11. QUESTIONS REGARDING THIS PRIVACY NOTICE
If you have any questions regarding this Privacy Notice please contact Emory at ehccompliance@emoryhealthcare.org or the following address and phone number:
Attn: Chief Privacy Officer, Emory Healthcare
2201 Henderson Mill Road, 1st Floor, Suite 150, Atlanta, GA 30345
Email: ehccompliance@emoryhealthcare.org
Phone: 404-778-2757