The Circle of Health Privacy Policy
Last updated December 4, 2017
The Circle of Health (“TCOH”) understands how important the privacy of personal information is to our users. This Privacy Policy will tell you what information we collect about you and about your use of The Circle of Health and its services. We will explain the choices you have about how your personal information is used and how we protect that information. We urge you to read this Privacy Policy carefully.
The Shetland Group Inc. operates the website for The Circle of Health. TCOH does not provide medical advice and we urge you to contact your healthcare professional for any medical issues. The Circle of Health allows users to find resources from a variety of top health and wellness sites and “curate” those resources in one convenient list with powerful tools for bookmarking, sharing, and saving searches. In addition, TCOH’s unique metrics allow users to customize their searches to match their learning styles (visual vs text resources, more “popular format” (US Magazine, People) vs more academic material).
The Circle of Health does not create or promote any health and wellness materials, resources or point of view. All of the results patients will see on TCOH are retrieved from top health and wellness sites that we believe are medically vetted.
Use of TCOH does not require that you register with us and use is free to any user. Users can conduct a search without registering. Registration is entirely voluntary and there is no charge to register or use the site. Many users do register with us as this allows them to use helpful tools and links on the site - our Advanced Features. These Advanced Feature tools (“the Services”) including Sharing, Bookmarking, and Recent Search history are only available if you have registered with us.
We provide you this privacy policy (the "Policy") to help you understand the kinds of information we may gather about you when you visit TCOH or use any of our Services, how we may use and disclose the information, and how you can control, correct and/or update the information.
To be clear about the terminology we are using, when we use the phrase "Personal Information" in this Policy, we mean information that specifically identifies you as an individual, like a person’s full name, address, e-mail address, or phone number. When we use the phrase "Anonymous Information" in this Policy, we mean information that does not specifically identify an individual person, such as a user’s areas of interest, browsing history, demographic information, or a unique identifier (such as a cookie or IP address).
By visiting TCOH or using the Services, you are accepting the policies and practices described in this Policy. Each time you visit TCOH or use the Services, you agree and expressly consent to our collection, use and disclosure of the information that you provide as described in this Policy.
1. The Information We Gather
We collect information about you in the following ways:
A. Information you Voluntarily Provide us
We collect and maintain information that you voluntarily submit to us upon your registration on TCOH and also through your completion of “My Profile”.
When you register with us, you may provide us certain information including your name, email, address, password, demographic information and the health topics that interest you.
If you sign up to receive updates on topics you are interested in, you may provide us with contact information such as email or physical address.
B. Information We Collect Through Your Use of the Site
As you use TCOH, certain information may also be passively collected. Through cookies, pixels, beacons, log files, your device information and other technologies, we may collect information about how you use the Site and the Services. For example, we may determine through an IP address that a particular computer or device is located in New York City and we may use this information to deliver selected information or resources to you. In addition, we may use such passive collection tools to track your browsing and resource consumption preferences (ie what resources you click through to from a TCOH search result). This information allows us to deliver more helpful information.
C. Information We Receive From Third Parties
We may also combine online and/or offline information received from third parties with the information we have already collected from you via your use of TCOH. The third party information is used for a variety of purposes including to verify other information about you (e.g., verify your mailing address to send you requested information), to conduct research and to enhance the content we provide to you.
2. How We Use Your Information
We will use your Personal Information in the ways described below or described at the time that the information is collected.
A. To Provide the Site TCOH and enable and enhance your use of it.
In general, we use your Personal Information as necessary or appropriate for purposes including to:
- Administer your account
- Register you and provide you access to TCOH and our Advanced Features
- Respond to inquiries or requests that you direct to us
- Fulfill your requests for information
- Send communications and administrative emails about TCOH and our services
- Personalize and better tailor the features, performance and support of TCOH for your use
- Send you information including newsletter and updates on topics and functionality that we think would be of particular interest to you
- Improve the quality of TCOH and the User Experience for you and other users
- Analyze, benchmark and conduct research on user data and user interactions with TCOH
3. Cookies and other web tools
"Cookies" are small pieces of information that a website places on your browser when you visit that website. We may use cookies to provide you with a more personal and interactive experience with TCOH. For example, we may use cookies to control what resources you see, the sequence of resources and to make sure you don't see the same resources too many times. We do not store Personal Information in any cookies on your computer.
Cookies can be removed by following your Internet browser's directions usually within the help menu. In order to use certain Services offered through TCOH, your web browser must accept cookies. If you choose to disable cookies, some aspects of TCOH may not work properly, and you may not be able to access our Services.
We may also use cookies, pixels, web beacons (which are usually small, transparent graphic images), operating system and device information and navigational data like Uniform Resource Locators (URL) to gather information regarding the date and time of your visit, the features and information for which you searched and viewed, the email you opened, or on which resources you clicked. This type of information is collected to make TCOH more useful to you and to tailor the experience with us to meet your special interests and needs.
An "Internet protocol address" or "IP Address" is a number that is automatically assigned to your computer when you use the Internet. We, or our service providers, may use your IP Address when you access TCOH or use other means to assist with delivering geographically targeted resources.
4. How We Disclose Information to Third Parties
We may share your Personal Information with third parties as specifically approved by you or under the circumstances described below. If you do not want us to use or disclose Personal Information collected about you in the ways identified in this Policy, you should not use the Site or Services.
A. Disclosure for Legal Reasons.
We may disclose and release your Personal Information to third parties: (a) to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or (b) in special cases, such as a physical threat to you or others, a threat to homeland security, a threat to our system or network, or in any cases in which we believe it is reasonably necessary to investigate or prevent harm, fraud, abuse, illegal conduct or a violation or alleged violation of this Policy or other agreement we may have with you.
B. Agents and Contractors.
We may provide your Personal Information to service providers who work on our behalf or help us to operate our business, TCOH. Examples of such service providers include vendors and suppliers that provide us with technology, research, and/or marketing assistance; provide services and/or content for sending email and providing customer service; and analyze data on TCOH. Access to your Personal Information by these service providers is limited to the information reasonably necessary to perform its limited function.
C. Anonymous Information.
We may share Anonymous Information about you with third parties for any purpose. Personal Information that has been aggregated with the Personal Information of other users in a way that does not identify you as an individual shall be treated as Anonymous Information.
D. Third Party Health and Wellness Sites included in our Search Universe.
TCOH does not create any health and wellness information nor promote any point of view. Rather, we provide access in one place to many top health and wellness sites, allowing users the convenience of seeing many resources about a topic of interest in one place. When a user clicks on a link to a resource (for example an article about diabetes from WebMD) they are taken to a new window or tab that puts them directly into WebMD or the source of that link. When you are viewing and using such resources from third party health and wellness sites like WebMD you are subject to their privacy policy and terms of use.
TCOH may share limited Personal Information and anonymous information about users to third party sites for verification and market research purposes.
E. Private Label Model Health Care Organizations partnering with TCOH.
TCOH provides our Private Label Model services to many large health care organizations including large private practices, ACO’s (accountable care organizations), IPA’s (independent practice associations) and hospital and integrated health chains. We provide a link to the TCOH search function embedded in these partner’s practice web sites and patient portals. This allows the patients served by these partners to access TCOH directly through their providers. (SEE Private Label Model below). TCOH may from time to time share both Personal Information and Anonymous Information with Private Label Partners.
F. Marketing Partners
We may use your Personal Information to match it with other public and private data sources in order to enhance our records or enhance our ability to provide products and services, such as appending additional information to your profile. We may also share your Anonymous Information with other parties who already possess your Personal Information in order to enhance their records about you or enhance their ability to provide products and services.
G. Social Media Integration
We may provide you with the ability to interact with your existing social media accounts, such as Facebook or Twitter. These features (including “Sharing” an article or resource from TCOH) may enable integration and/or access to your social media accounts. We do not control those social media services, your profiles on those services, your privacy settings on those services or establish rules about how your information on those services will be used. You and the social media service providers are in control of those issues, not TCOH. You are encouraged to read all policies and information on the applicable social media services to learn more about how they handle your information before using any such features made available to you through TCOH. We are not responsible for any acts or omissions by any social media service provider or your use of features on their platforms.
H. Within Our Company; Changes to Our Company.
We may share your Personal Information with any of our subsidiaries, joint ventures, or other companies under common control. Additionally, in the event we go through a business transition such as a merger, acquisition by another company, initial public offering (“IPO”), sale of all or a portion of our assets or as part of a bankruptcy proceeding, your Personal Information may be among the assets transferred. You acknowledge that such transfers may occur and are permitted by this Policy.
5. Children's Information
TCOH is not directed or intended for children under 13 years of age. We do not knowingly collect Personal Information from individuals under 13 years of age. If you are under 13 years of age, you should not register or provide Personal Information on TCOH. If you are the parent or guardian of a child whom you believe has disclosed Personal Information to us, please contact us at privacy@tco-health.com so that we may delete and remove such child's information from our systems.
6. Updating and Control of Your Personal Information
We offer you choices regarding the collection, use, and sharing of your Personal Information. When you receive communications from us you will have the opportunity to "opt-out" by following the unsubscribe instructions provided in that e-mail or newsletter you receive or by editing your preference to receive these communications within the "My Account" or similar feature on TCOH when you are logged in as a registered user.
You can update or correct your Personal Information by logging in and clicking on “My Account” at the top of the Site to access the "My Profile” section. If you no longer wish TCOH to use or share your Personal Information in accordance with this Policy or you no longer desire to use or access this Site, you can also remove your Personal Information from the "My Profile” section of the Site. If you would like assistance disabling your account, please contact customer service at support@tco-health.com.
Keep in mind, however, that even if you delete information from your profile, we may retain your Personal Information in conformance with our data retention policy and Personal Information may remain within our databases, access logs, and other records. In addition, we are not responsible for updating or removing your Personal Information contained in the lists or databases of third parties who have been provided information as permitted by this Policy.
7. The Private Label Model and Co-Branded Sections of TCOH
TCOH provides our Private Label Model (PLM) services to many large health care organizations including large private practices, ACO’s (accountable care organizations), IPA’s (independent practice associations) and hospital and integrated health chains.
The PLM service allows partners to provide an intelligent tailorable internet search tool for their patients who may be searching for web based health and wellness resources. We provide a link to the TCOH search function embedded in these partner’s practice web sites and patient portals. This allows the patients served by these partners to access TCOH directly through their providers’ site.
Through the TCOH PLM model we do not require any PHI (personal health information) from partners. When a patient does a search through an embedded TCOH search box in a partner’s site or patient portal, they will be taken to what is essentially the search results page for TCOH. However, the “branding” of the page is that of the Partner, without heavy emphasis on TCOH. This allows Partners to provide patients with an enhanced web search experience and still help maintain the “brand identity” of the Partner.
8. Third-Party Links
TCOH will link users to websites operated by third parties that we do not control. We do not monitor, control, or endorse the information collection or privacy practices of any third parties. We encourage you to become familiar with the privacy practices of every website you visit and to contact them if you have any questions about their respective privacy policies and practices. This Policy applies solely to information collected by us through your use of TCOH and does not apply to these third party websites. The ability to access information of third parties from TCOH, or links to other websites or locations, is for your convenience only and does not signify our endorsement of such third parties, their products, services, websites, locations or their content.
9. Security
We place a priority on the security of Personal Information, and we undertake reasonable security measures to help protect the data that resides on our servers. However, no security system is impenetrable. We do not warrant the security of our servers, nor do we warrant that your information, including Personal Information, will be completely secure or not be intercepted while being transmitted over the Internet.
12. How to Contact Us
If you have any questions regarding privacy or this Policy, you may contact us as follows:
Telephone: 949-412-9179
Email: privacy@tco-health.comAddress: The Shetland Group Inc. 34145 Pacific Coast Hwy, Suite #246, Dana Point CA 92629
13. Privacy Policy Changes
We reserve the right to change, modify, add or remove portions of this Policy at any time and without prior notice, and any changes will become effective immediately upon being posted unless we advise you otherwise. Your continued use of TCOH after this Policy has been amended shall be deemed to be your continued acceptance of the terms and conditions of the Policy, as amended. We encourage you to bookmark this Web page and review this Policy regularly.