Project Seamless Privacy Notice

We, at Project Seamless, know you value your privacy. That is why we are committed to the confidentiality and security of your personal information. We maintain physical, administrative and technical safeguards to protect against unauthorized access, use, or disclosure of your personal information, including information we share internally either orally, electronically, or in writing. This policy applies specifically to Project Seamless’s use and disclosure of your data with regard to this mobile application (the “App”) or any service Project Seamless provides you including customer support.

HIPAA

The Project Seamless App is not a HIPAA covered entity.

Data we collect

We need some information from you so that you can create an account with the App, such as your name, email address, password, date of birth and phone number.

You have the choice to authorize your health plan and/or providers to send your data to Project Seamless. Additional features allow you to upload photos and post information. Once your data is provided to you through this App, we will use and share your data in the ways described below and it our Terms of Use.

Project Seamless will use other sources of data, including purchased data, to enrich and inform your consumer healthcare journey.

Use: How we use your data internally

Our App is used primarily to provide you with a clear picture of your care history, examine and draw conclusions based on your health information and provide you with insights and suggestions to better manage your health.

We collect and use your identifiable data (data, such as your name, phone number, email, address, or health services and conditions that can be used on its own or with other information to identify you) to:

  • Provide the primary service of the App

  • Communicate with you, make recommendations, and to send you alerts and notifications

  • Develop marketing materials for our products

  • Support company operations (e.g., quality control, fraud detection, training)

  • Develop and improve new and current products and services (e.g., analytics, build and test data science models, reporting)

Share: How we share your identifiable data externally with other companies or entities

We share your IDENTIFIABLE data to:

  • Provide the primary service of the App 

  • Provide additional services you choose to use

  • Develop marketing materials for our products

  • Support company operations (e.g., quality control, fraud detection, training)

  • Develop and improve new and current products and services (e.g., analytics, build and test data science models, reporting)

We will not share your identifiable data with employers.

If you choose to connect your account on the App to your account on another third-party service, we may receive information from that other service depending on the information available from that service.  You can stop sharing the information from the other service with us by removing our access to that other service.

You may choose to share your information on your account with caregivers or family members, who can then may be able to see the photographs you have uploaded or information you have posted to your account. You may remove shared access at any time.

We share your AGGREGATE or de-identified demographic, health, cost, utilization and engagement data with:

  • Employers

  • Third party partners

  • Affiliated companies

Third parties receiving aggregate and de-identified data will be obligated by contract to protect the data they receive, will not have permission to re-identify it and will not have permission to sell or share the data.

Sell: Who we sell your data to

  • We DO NOT sell your data

Store: How we store your data

  • We store limited data on your device in order to improve app performance.  We also store your data outside the device at our company or through a third party, including cloud-based providers.

Encryption: How we encrypt your data

Encryption means: a method of converting an original message of regular text into encoded text in such a way that only authorized parties can read it.

We encrypt your data in the App

  • Yes, automatically

We encrypt your data when stored on our company servers or with an outside cloud computing services provider

  • Yes, automatically

We encrypt your data while it is transmitted

  • Yes, automatically

Deactivation: What happens to your data when your account is deactivated

To stop sharing or delete information from your insurance carrier, you may go to the App settings and choose to stop sharing data.  When you stop sharing the data, you will not receive any new information from your carrier. The data already in the App will remain.

You may delete the data you have consented to share with Project Seamless (your claims data, health data, photographs, wearable device data, etc.) by contacting Customer Support, or where feasible in the App, by deleting the data via the App. When you request Project Seamless to delete your data, it will be deleted within 60 days after your request.

If you previously chose to share your data with other Project Seamless users or other third parties, your request will not affect data shared before Project Seamless received your request for data deletion.

Project Seamless will permanently retain the information used to create your account (name, email address, password, date of birth and phone number).

Deactivation means: an individual takes action or a company ceases operation or deactivates an individual’s account due to inactivity.

Device Data: How this App accesses other data

The Project Seamless App requests access to other device data or applications, such as your phone’s camera, photos, or contacts only with your permission.

It connects to...

  • Camera

  • Photos

  • Contacts

  • Location services

  • Microphone

  • Health monitoring devices

  • Device data (device and application identifiers, cookies, etc.)

You can check your settings, including permissions set as a default in your device’s “Settings” function. If you have any questions about the privacy settings of your device, please contact the manufacturer or your mobile service provider for help.

Social Media: How this technology interacts with Social Media

The Project Seamless App does not allow you to share the collected data with your social media accounts, like Facebook.

User Options: What you can do with the data we collect

The Project Seamless App allows you to access and share the data we have about you. If you have concerns about the accuracy of your data, send questions to projectseamless@cambiahealth.com 

You can also edit certain types of data such as entering in additional information about your care team and personal health history.

Policy Changes: How we will notify you if our privacy policy changes

We reserve the right to change our privacy practices and this notice at any time without advance notice.  We will notify you of any material changes to this policy and as required by law and give you an opportunity to review the revised policy before deciding if you would like to continue to use the App.

Breach: How we will notify you and protect your data in case of improper disclosure

Project Seamless complies with all applicable laws regarding breaches.  In the event of a breach (unauthorized disclosure that meets the definition of a breach), we will contact you by using the information you provided to create your account.

How to contact us

If you have questions about this policy, or about our use of your information, please contact us at projectseamless@cambiahealth.com or by writing Project Seamless, 100 SW Market Street, M/S E12B, Portland, OR  97201.

Effective Date of Policy: September 15, 2018