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The Aloha Health Network Privacy Policy was updated on April 11, 2019.

Your privacy is important to Aloha Health Network so we’ve developed a Privacy Policy that covers how we collect, use, disclose, transfer, and store your personal information.

In addition to this Privacy Policy, we provide data and privacy information imbedded in our products connected with our Data & Privacy Icon for certain features that ask to use your personal information.

You can review this information before enabling these features, in Settings related to those features and/or online at AlohaHealth.net/privacy. Please take a moment to familiarize yourself with our privacy practices and contact us if you have any questions.

Your California Privacy Disclosures

Information Regarding Commercial Electronic Messages in Canada

Collection and Use of Personal Information

Personal information is data that can be used to identify or contact a single person.

You may be asked to provide your personal information anytime you are in contact with Aloha Health Network or an Aloha Health Network affiliated company. Aloha Health Network and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you choose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of the types of personal information Aloha Health Network may collect and how we may use it:

What personal information we collect

  • When you create an Aloha Health Network account, purchase a product, download a software update, connect to our services, contact us including by social media or participate in an online survey, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information, credit card information and profile information where the contact is via social media.

  • When you share your content with family and friends using Aloha Health Network products, send gift certificates and products, or invite others to participate in Aloha Health Network services or forums, Aloha Health Network may collect the information you provide about those people such as name, mailing address, email address, and phone number. Aloha Health Network will use such information to fulfill your requests, provide the relevant product or service, or for anti-fraud purposes.

  • In certain jurisdictions, we may ask for a government issued ID in limited circumstances including when setting up a wireless account and activating your device, for the purpose of extending commercial credit, managing reservations, or as required by law.

How we use your personal information

We may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which Aloha Health Network is subject or when we have assessed it is necessary for the purposes of the legitimate interests pursued by Aloha Health Network or a third party to whom it may be necessary to disclose information.

  • The personal information we collect allows us to keep you posted on Aloha Health Network’s latest product announcements, software updates, and upcoming events. If you don’t want to be on our mailing list, you can opt-out anytime by updating your preferences in Account Settings.

  • We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes. We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users. Where we use your information for anti-fraud purposes it arises from the conduct of an online transaction with us. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services. For certain online transactions we may also validate the information provided by you with publicly accessible sources.

  • We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of Aloha Health Network account holders.

  • From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with Aloha Health Network, you may not opt out of receiving these communications.

  • We may also use personal information for internal purposes such as auditing, data analysis, and research to improve Aloha Health Network’s products, services, and customer communications.

  • If you enter into a sweepstakes, contest, or similar promotion we may use the information you provide to administer those programs.

  • If you apply for a position at Aloha Health Network or we receive your information in connection with a potential role at Aloha Health Network, we may use your information to evaluate your candidacy and to contact you. If you are a candidate, you will receive more information about how Aloha Health Network handles candidate personal information at the time of application.

Source of your personal information where they are not collected from you

We may have received your personal information from other persons if that person has shared their content with you using Aloha Health Network products, sent gift certificates and products, or invited you to participate in Aloha Health Network services or forums. We may also validate the information provided by you when creating an Aloha Health Network account with a third party for security and fraud prevention purposes.

If you are a potential candidate for employment with Aloha Health Network, we may have received your personal information from third parties such as recruiters or external websites. We will use the personal information we receive to contact you about a potential opportunity or in evaluating your candidacy. If you did not provide us your personal information directly, we will inform you of the source when we first contact you regarding your candidacy. For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person. When acquiring such datasets, we do so in accordance with applicable law in the jurisdiction in which the dataset is hosted. When using such datasets for research and development, we do not attempt to re-identify individuals who may appear therein.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

  • We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where an Aloha Health Network product is used so that we can better understand customer behavior and improve our products, services, and advertising.

  • We may collect information regarding customer activities on our website, the Aloha Health web and mobile applications and from our other products and services. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our website, products, and services are of most interest. Aggregated data is considered non‑personal information for the purposes of this Privacy Policy.

  • We may collect and store details of how you use our services, including search queries. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure the quality of our services over the Internet, such information will not be associated with your IP address.

  • With your explicit consent, we may collect data about how you use your device and applications in order to help improve our apps.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Cookies and Other Technologies

Aloha Health Network’s websites, online services, interactive applications, email messages, and advertisements may use “cookies” and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of our websites people have visited, and facilitate and measure the effectiveness of advertisements and web searches. We treat information collected by cookies and other technologies as non‑personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

Ads that are delivered by Aloha Health Network’s advertising platform may appear on our website and in our Aloha Health applications. If you do not wish to receive ads targeted to your interests from Aloha Health Network’s advertising platform, you can choose to enable Limit AdTracking on your mobile device so apps like ours cannot use the Advertising Identifier, a non-personal device identifier, to serve you targeted ads. You may still see ads on the website or in the app based on context like your search query or the channel you are reading.

Aloha Health Network and our partners also use cookies and other technologies to remember personal information when you use our website, online services, and applications. Our goal in these cases is to make your experience with Aloha Health Network more convenient and personal. For example, knowing someone using your computer or device has searched for information regarding a certain disease category helps us and clinical research partners make our communications more relevant to your needs. And knowing your contact information helps us personalize your experience and make it easy for you to request further information about your clinical research options.

If you want to disable cookies, check with your web browser provider to find out how to disable cookies. Please note that certain features of the Aloha Health Network website will not be available once cookies are disabled.

As is true of most internet services, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. Aloha Health Network may use this information in our marketing and advertising services.

In some of our email messages, we use a “click-through URL” linked to content on the Aloha Health Network website. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

Disclosure to Third Parties

At times Aloha Health Network may provide third parties with certain personal information to provide or improve our products and services, including to deliver products at your request, or to help Aloha Health Network market to consumers. When we do, we require those third parties to handle it in accordance with relevant laws. Personal information will never be shared with third parties for their marketing purposes. For example, when you choose to “Connect Me” with a clinical research opportunity, you are asked for your consent to authorize Aloha Health Network and our service providers to exchange the information you provide during the request for information process. If you are enrolled in a clinical research opportunity, your account will be governed by Aloha Health Network and the research sponsor’s respective privacy policies.

Service Providers

Aloha Health Network shares personal information with companies who provide services such as information processing, fulfilling patient requests, delivering products to you, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever Aloha Health Network operates.

Others

It may be necessary − by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence − for Aloha Health Network to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users.  This could include providing information to public or governmental authorities. Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Protection of Personal Information

Aloha Health Network takes the security of your personal information very seriously. Aloha Health Network online services such as the Aloha Health Network website and app protect your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by Aloha Health Network, we use computer systems with limited access housed in facilities using physical security measures. With the exception of public communication forums, data is stored in encrypted form including when we utilize third-party storage.

When you use some Aloha Health Network products, services, or applications or post on an Aloha Health Network forum, chat room, or social networking service, the personal information and content you share is visible to other users and can be read, collected, or used by them. You are responsible for the personal information you choose to share or submit in these instances. For example, if you list your name and email address in a forum posting, that information is public. Please take care when using these features.

The existence of Automated Decision-Making, Including Profiling

Aloha Health Network does not take any decisions involving the use of algorithms or profiling that significantly affects you.

Integrity and Retention of Personal Information

Aloha Health Network makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service specific privacy summaries. When assessing these periods we carefully examine our need to collect personal information at all and if we establish a relevant need we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

Access to Personal Information

You can help ensure that your contact information and preferences are accurate, complete, and up to date by signing in to your Aloha Health Network account page. For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if Aloha Health Network is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. Online tools for the exercise of access, correction, or deletion requests are available on a regional basis. Where the online tool is not currently available for access requests in your region, a request may be made directly to support@alohahealth.net.

Children & Education

We understand the importance of taking extra precautions to protect the privacy and safety of children using Aloha Health Network products and services. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own Aloha Health Network accounts, unless their parent provided verifiable consent. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible. If at any time a parent needs to access, correct, or delete data associated with their account or child’s Aloha Health Network account, they may contact us through one of the options provided at the bottom of this page.

Location-Based Services

To provide location-based services on Aloha Health Network products, Aloha Health Network and our partners and licensees, such as maps data providers, may collect, use, and share precise location data, including the real-time geographic location of your Aloha Health Network computer or device. Where available, location-based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices’ approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by Aloha Health Network and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.

Third‑Party Sites and Services

Aloha Health Network websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties.

Information collected by third parties, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties.

International Users

All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. Personal information, relating to Aloha Health Network services, regarding individuals who reside in a member state of the European Economic Area and Switzerland is controlled by Aloha Health Network Distribution International in Ireland, and processed on its behalf by Aloha Health Network Inc. Aloha Health Network uses approved Model Contractual Clauses for the international transfer of personal information collected in the European Economic Area and Switzerland. Aloha Health Network, as a global company, has a number of legal entities in different jurisdictions which are responsible for the personal information which they collect and which is processed on their behalf by Aloha Health Network Inc. For example, point of sale information in our Retail entities outside the U.S. is controlled by our individual Retail entities in each country. Aloha Health Network, Online Store and iTunes related personal information may also be controlled by legal entities outside the U.S. as reflected in the terms of each service.

Aloha Health Network abides by the Asia-Pacific Economic Cooperation (APEC) Cross Border Privacy Rules System. The APEC CBPR system provides a framework for organizations to ensure protection of personal information transferred among participating APEC economies. To learn more about the APEC Certification and Dispute Resolution, please click on the TRUSTe seal.

Our Company-wide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to Aloha Health Network employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have any questions or concerns about Aloha Health Network’s Privacy Policy or data processing, you would like to contact our European Data Protection Officer, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us.

When a privacy question or question about personal information received in response to an access/download request is received we have a dedicated team which triages your contact to address your issue. Where your issue may be more substantive in nature, we may request more information from you. All such substantive contacts receive a response within seven (7), days wherever possible – providing a response on the issue raised, requesting additional information where necessary or indicating that a response will require additional time. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

Where your complaint indicates an improvement could be made in our handling of privacy issues we will take steps to make such an update at the next reasonable opportunity.  In the event that a privacy issue has resulted in a negative impact on you or another person we will take steps to address that with you or that other person.

Aloha Health Network may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy. We will also contact you via your contact information on file, for example by email, notification or some other equivalent method.

Aloha Health Network Inc. 268 Bush St. Suite 1500, San Francisco, California 94104, United States