Witty Health Inc. was created to build a global ecosystem enabling personalized treatment and precise medicine for millions of cancer patients. "OncoPower", Witty Health Inc. connects patients and physicians for cutting edge cancer care.
Information That We Collect
Children’s Online Privacy Protection Act (“COPPA”):
This policy is in accordance with COPPA and outlines our practices in the United States and any other territories in which we operate regarding children’s personal information. For more information about COPPA and general tips about protecting children’s online privacy, please visit: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule. We do not knowingly or intentionally collect or maintain personally identifiable information from persons under 13 years old, and no part of our website or application is directed to persons under 13. IF YOU ARE UNDER 13 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS OUR SERVICES AT ANY TIME OR IN ANY MANNER. If Witty learns that personally identifiable information of persons less than 13 years old has been collected without verifiable parental consent, then we will take appropriate steps to delete this information. If you are a parent or guardian and discover that your child under the age of 13 has obtained a Witty account, then please alert us at firstname.lastname@example.org and request that we delete that child’s personal information from our systems.
Information Collected from Other Sources:
Witty collects publicly available information about physicians in a database to provide a directory and referral service to other healthcare professionals and create a profile for each (“Profile”). This Profile may include the physicians’ names, office addresses, office phone numbers and fax numbers, specialties, and the medical school and training institutions the physicians attended. We may also receive this information from other Application Programming Interface (“API”) partners, such as Doximity or LinkedIn. Almost all oncology doctors, and many other healthcare professionals, are included within our database. If a Physician registers and becomes a User (“Physician User”), you are agreeing that the information that we have collected about you in your Profile is accurate, so please verify your Profile.
Information Collected from You:
Information Gathering Process
When You Register as a User
- Phone number;
- Email address;
- Provider’s full name;
- Provider’s Email;
- Provider’s Phone Number;
When Physician Registers as a User
- Office phone,
- Email address and
- Clinical areas of interest,
- Maiden name,
- Languages spoken at Physician’s office, and
- Profile photo.
In order to secure your personal information, access to your data on Witty is password protected and you are responsible for keeping this password confidential and to protect the security of your login information. Please do not share your password with anyone.
Adding To Your Public Profile
Once you have completed the registration process, you may at any time provide additional information to your Profile. Depending on the type of User, such information may include the following: medical group, IPA and hospital affiliations, internship, residency program, fellowships, work history, presentations, publications, education, professional interests, memberships, and board certifications. Providing additional information is entirely optional for each User, however any additional information enables the User to better identify themselves and find new opportunities in the Witty Service to build and leverage their professional network. All of the information that is publicly available or that you voluntarily provide will be published on your profile, which is accessible to anyone browsing the Witty directory; EXCEPT (i) the year(s) you graduated from your internship, (ii) residency and/or (iii) fellowship programs. Any information you provide to us, whether during the registration process or as an update to your Profile, may be used in the same manner and extent to which other information is permitted to be used hereunder, including for the purpose of creating and serving advertisements through the Service.
When You Add a Private Profile
If you choose, you may create a private profile on Witty. The private profile can consist of back line, mobile phone, home phone, other phone, pager, inpatient and admit number, email address or other private mode of communication. Your private profile is visible only to those Users with whom you select to share it.
When You Invite Others to Join Witty
If you wish to invite other physicians, Clinicians (as defined below) or colleagues to join Witty, you can use our email invitation service to email their offices. In this case, no additional information about you is collected. Alternatively, you may enter their names and email addresses, which Witty will use to send your invitation, including a message that you may write to them. The names and email addresses of people that you invite will be used only to send your invitation and reminders.
When You Contact Customer Support
Witty may collect information through our website or through Customer Support in order to, among other things, accurately categorize and respond to your inquiries and deliver the appropriate Services.
Log files, IP addresses and information about your computer and mobile device
Consent to Witty Processing Information About You
Accessing and Changing Your Account Information
You can review the personal information you provided us and make any desired changes to the information you publish, or to the settings for your Witty account, including your email and contact preferences, at any time by emailing email@example.com. You can also make these changes on the Witty website by updating your Profile. Please be aware that even after your request for a change is processed, Witty may, for a time, retain residual information about you in its backup and/or archival copies of its database.
Use And Protection Of Personal Information
Witty is an online Service dedicated to helping medical professionals more effectively connect with one another and to assist patients with obtaining the best possible medical care no matter where they are located. The information you choose to provide about yourself on the Site is used to help you describe yourself to other Users; to provide you with the Services; to improve healthcare quality through the performance of quality reviews and similar activities; to notify you when site updates are available; to market and promote the Site and the Services to you; to fulfill any other purpose for which you provide us your personal information; and for any other purpose for which you give us authorization. Other information, that does not personally identify you as an individual, is collected by Witty from Users (such as, for example, patterns of utilization) and is exclusively owned by Witty. This information can be utilized by Witty in such manner as Witty, in its sole discretion, deems appropriate.
HIPAA & HITECH
Witty is a covered entity under the Health Insurance Portability and Accountability Act (HIPAA) of 1996 and the Health Information Technology for Economic and Clinical Health (“HITECH”) Act. Witty Health maintains personal health information in compliance with these rules and regulations.
Notice Of HIPAA Privacy Practices
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED, AND DISCLOSED, AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY AND REPORT ANY ISSUES, OR CONCERNS, TO US:
Witty HealthATTN: Legal Department5850 San Felipe Suite 500Houston, TX 77057
- TREATMENT means providing, coordinating, or managing health care and related services by one or more Clinicians, Physician Users and/or health care providers.
- PAYMENT means such activities as obtaining payment or reimbursement for services, billing or collection activities and utilization review.
- HEALTH CARE OPERATIONS include managing your personal health information to facilitate messaging and consultations with Clinicians, Physician Users and/or health care providers, as well as conducting quality assessment review and service improvement planning activities, auditing functions, cost-containment analysis, and customer service.
Witty HealthATTN: Legal Department5850 San Felipe Suite 500Houston, TX 77057
Business Associate Agreements
HIPAA generally requires that covered entities and business associates enter into contracts to ensure that the business associates will appropriately safeguard protected health information. A business associate contract serves to clarify and limit, as appropriate, the permissible uses and disclosures of protected health information by the business associate, based on the relationship between the parties and the activities or services being performed by the business associate. By using this Site and/or the Services, You and Witty agree to the terms provided in the Business Associate Agreement relating to any communications of electronic protected health information.
Medical Information used for treatment
We may use or disclose your medical information, (1) to provide you with access to Physicians as anticipated by the Services offered by Witty, (2) to share your medical information with others who provide care to you such as hospitals, nursing homes, doctors, nurses, physician assistants, technicians, emergency service and transportation providers, medical and nursing students, therapists, medical equipment providers, pharmacies, and others involved in your care that may not be listed. Within the scope of care provided by the Physicians, they may share your medical information to assist with filling your prescriptions, requesting lab work and x-rays along with other medical needs that may not be listed. We may use or disclose your medical information, (1) to facilitate payment for the services provided by Witty or the Physician Users or its network Physicians, vendors or providers, (2) to inform billing companies, insurance plan administrators, or others to acquire approval for anticipated care.
Witty's Communications to You
Witty will communicate with you through email and notices posted on the Witty website or through other means available through the Service, including text and other forms of messaging. If we send any communications to you via the carrier Service with which you have a mobile communications subscription or otherwise have access, you understand you will pay any Service fees associated with any such access (including text messaging charges for messages to your mobile device). Our communications to you include emails which help inform Users about various features of the Service. Witty may send you promotional information unless you have opted out of receiving such information. You can change your email and contact preferences at any time by sending a request to firstname.lastname@example.org or by updating your profile information.
Information provided to Witty (or to third parties with whom it offers combined Services) is also used to customize your experience on our website. For example, you can store “favourite” phone numbers for easy reference.
Sharing Information with Third Parties
Witty takes the privacy of Users very seriously. We do not sell, rent, or otherwise provide your private information to third parties for marketing or other purposes. We may provide data about the usage of our Services to third party Service providers with whom we contract to help us provide our Services. For example, we may work with vendors, consultants or other third parties to host and maintain our data and website properties, analyze our data, or provide marketing assistance. All contracted third parties must agree not to use your personal information and communications other than to fulfill their responsibilities to us and are bound by confidentiality agreements with regard to their use of such information. We may provide aggregated anonymous data about the usage of our Services to third parties for such purposes as we deem, in our sole discretion, to be appropriate, including to prospective investors in Witty. We may segment our Users by specialty, education, alumni groups, training, research, grants, trials, geographic location or other similar information and provide information from your public profile as part of our Services and product offerings. If you would like to be excluded from the aggregated research or products based upon aggregated or segmented data and Users’ activities on the site, please email email@example.com.
As part of our Services, we may share personal information with accredited Continuing Medical Education (CME) and Continuing Education (CE) providers who certify CME and CE activities, to process CME or CE activities you may choose to take through our Service. As part of our Services, we may also share public profile information with medical leading publications and ranking bodies, such as U.S. News and World Reports to increase the visibility of our Users. When you use the Witty Service through a Witty website, newsletter, mobile app or other medium, you may be presented with advertisements or opportunities to engage in informational programs consisting of sponsor-selected content. Examples of these programs include sponsored news alerts or branded or unbranded discussion groups. All sponsored programs will be labeled clearly as a sponsored program. When you choose to engage with a sponsored program, such as engaging with a commercial client’s sponsored news alert, we may provide our commercial clients with your identifiable information and information about the type of engagement (e.g., whether you viewed, interacted with or requested information about such promotional content). We will only share your identifiable information with clients who have agreed to use such information solely for authorized purposes. You may revoke your authorization to participate in these features of our Services at any time. If you would like to be excluded from the accredited bodies, leading publications or commercial features of our Services, please email firstname.lastname@example.org.
We use your information, including the addresses you import through our contact importers, to make suggestions to you and other Users on Witty. For example, if another User imports the same email address as you do, we may suggest that you add each other as clinicians (“Clinicians”). To help your friends find you, we allow other Users to use contact information they have about you, such as your email address, to find you, including through contact importers and search.
We offer search Services to help you find information and learn more about other Users (for example, you can search for Users with particular expertise, or that you may know from your medical school). We use information from User profiles and other contributions to Witty to inform and refine our search Service.
Surveys and Polls
As a User, you may receive requests to participate in market research including polls and surveys submitted by other Witty members. If you participate in surveys and polls offered through our website, the information you provide may be visible to others using the Witty website. You may opt-out of participating by emailing email@example.com to stop receiving these inquiries and requests.
Communications with Other Users
Disclosures of Information as Necessitated by Law
It is possible that we may need to disclose personal information when required by law, such as responses to civil or criminal subpoenas, or other requests by law enforcement personnel. We will disclose such information when we have a good-faith belief that it is necessary to comply with a court order, ongoing judicial proceeding, subpoena, or other legal process or request to Witty brought in any country throughout the world, or to exercise our legal rights or defend against legal claims.
Disclosures to Others
We may also disclose your personal and other information you provide, to another third party as part of reorganization or a sale of substantially all of the business of Witty. Any third party to which we transfer or sell Witty’s assets will have the right to continue to use the personal and other information that you provide to us.
Your Information And Account Choices
Rights to Access, Correct and Delete Personal Information About You
You have a right to access, modify, correct and delete the personal information about you, which has been collected pursuant to your decision to become a User. If you update any of your information, we may keep a copy of the information which you originally provided to us in our archives for uses documented herein. We take your rights seriously and encourage you to use them as you deem necessary. You may exercise these rights by emailing us at firstname.lastname@example.org or by contacting us at:
Closing Your Account
You can also close your account at any time by emailing email@example.com. If you close your Witty account, we will remove all of the information that you have provided to Witty from our publicly viewable database, as well as any private profile information that you have stored with us, EXCEPT THAT, we will retain all publicly available data in the database, including all of the information about you that was available on our database prior to your joining the Witty network. We may also retain certain data contributed by you if we believe it may be necessary to prevent fraud or future abuse, or for legitimate business purposes, such as analysis of aggregated, non-personally identifiable data, account recovery, or if required by law.
To request that we close your account and remove your information from the Witty website, please send your request to firstname.lastname@example.org. Please send your request using an email account that you have registered with Witty under your name. You will receive a response within five business days of its receipt.
If we learn that a User is deceased, we may memorialize the User's account. We may restrict profile access and remove messaging functionality. We close an account if we receive a formal request from the User's next of kin or another proper legal request to do so.
Insurance data on Witty is offered for informational purposes only, should not be relied upon, and Users agree to hold harmless Witty and its data suppliers for use of the data.
We have a number of security measures in place to protect your personal Information from unauthorized access, disclosure, alteration or destruction. Although no online service can guarantee the absolute security of your personal information, we are committed to implementing strong physical, technical and administrative safeguards. These procedures include the use of firewalls, secure connections on our websites, and the use of Secured Socket Layers (SSLs) to encrypt pages that collect personal information. Personal information is stored in limited access servers and physical access to our servers requires individual authorization and authentication. Only authorized Witty employees or contractors carrying out permitted functions are allowed access to personal information. In addition, each employee and contractor of Witty is required to sign a confidentiality agreement requiring him or her to keep confidential all Personal Information of Users and customers. We regularly train our employees and contractors on proper use and handling of personal information. Employees and contractors who violate these policies may be subject to disciplinary action, termination of their employment and legal action. Our service providers are also required to maintain security measures similar to Witty. However, for added protection, we ask that you keep your login information and passwords confidential. By using the Services or providing personal information to us, you agree that we may communicate with you electronically about security, privacy, and administrative issues relating to your use of the Services. If you have reason to believe that your interaction with Witty is no longer secure, please email us immediately at email@example.com or by contacting us at:
Witty Health Inc.ATTN: Security Issues5850 San Felipe Suite 500Houston, TX 77057
Operation in the United States and Cross Border Transfers
EU-U.S. and Swiss-U.S. Privacy Shield Frameworks
For questions or complaints regarding our participation in Privacy Shield, please contact us at firstname.lastname@example.org. For any complaints that cannot be resolved with Witty directly, Witty requires all complaints to be handled by binding arbitration, as set forth in the Terms and Conditions of Use.
Third Party Links/ Other Sites
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page. If you use the Witty Service or visit the Site after notice of these changes have been posted, you are providing your consent to the changed practices. If Users have questions or concerns regarding this statement, you may contact Witty by email at email@example.com.
Version: September 1, 2019