Wamberg Genomic Advisors, Inc
Last Updated: October 2020
THIS NOTICE DESCRIBES HOW PERSONAL, MEDICAL INFORMATION AND OTHER INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION.
COLLECTION OF YOUR INFORMATION
Information Collected: In order to provide you with the Services, WGA will collect certain categories of personal information, including, without limitation, information that could reasonably be used to identify you personally (e.g., such as your name, mailing address, e-mail address, birthdate, mobile number and credit card) (“Personal Information“). Your health or medical information may be collected and used by WGA to enable the provision of the Services to you (“Health Information”). This information may be collected at various times and from various sources, including, but not limited to, when you register to use the WGA website, when you subscribe to use the Services, and when you request certain Services. Additionally, WGA may collect information about your internet connection, the equipment you use to access our website and application. WGA may also automatically collect information through cookies, web beacons, embedded scripts and other tracking technologies as you navigate through the website and from your usage of any application, your computer, mobile or other device used to access the Services (any, a “Device“). All of the information collected by WGA about you, including Health Information and Personal Information shall be collectively referred to in this Policy as “Your Information”.
HOW WGA MAY USE AND DISCLOSE YOUR INFORMATION
Use of Your Information: Your Information is collected to provide you with a positive experience when using the Services. In addition to using your information for the purposes described above:
- For Services: We may use or disclose Your Information to provide you with the Services, and so may disclose it to, without limitation, specialists, nurses, doctors or other employees, subcontractors or agents’ personnel who are involved in providing you healthcare as part of the Services.
- For Payment: We may use and disclose Your Information so that the Services we provide may be billed to and payment may be collected from you, a third-party administrator (TPA) or a third party (if applicable).
- For Our Operations: We may use and disclose Your Information to facilitate our operations. For example, we may do this by monitoring which features of the Services are used the most, identifying your address, phone number and current location. We may share your information, including Your Information with our parent and subsidiaries, for internal and operational reasons. We may also use Your Information for troubleshooting and in some cases, internal marketing purposes. In addition, we may use Your Information:
- To review your history of Services;
- To determine if you have any restrictions on any type of Service that may be provided;
- To recommend certain products and/or Services;
- To provide you with information or services or process transactions that you have requested or agreed to receive, including to send you electronic newsletters, or to provide you with special offers or promotional materials on behalf of us or third parties;
- To process your registration with the Services, including verifying your information is active and valid;
- To improve the Services or our services, to customize your experience with the Services, or to serve you specific content that is most relevant to you;
- To enable you to participate in a variety of the Services’ features;
- To contact you about your use of the Services and, in our discretion, changes to the Services and/or the Services’ policies;
- For internal business purposes; and
- For inclusion in our data analytics.
- Appointment Reminders: We may use and disclose Your Information to contact you as a reminder that you have an appointment with a WGA specialist.
- Benefits and Services: We may use and disclose medical information to tell you about benefits or services that may be of interest to you.
- Contractors and Agents: In certain cases, we will provide your information to contractors, agents and other parties who need the information in order to perform a service for us, such as providing you with Services or obtaining payment for Services or carrying out business operations. However, you should know that in these situations, we require third parties to provide us with assurances that they will safeguard your information.
- Use of Your Information for Service-Related Information: We will send you service-related announcements on those occasions when it is necessary to do so. For instance, if our Services are temporarily suspended for maintenance, we might send you an email. You may opt-out of these communications, which are not promotional in nature.
DISCLOSURE OF INFORMATION TO OTHER THIRD PARTIES
- Disclosure of Non-Personally Identifiable Information: WGA may share non-personally identifiable (or “de-identified”) information, such as aggregated user statistics and log data, with third parties for industry analysis, demographic profiling, to deliver targeted advertising about other products or services, or for other business purposes.
- Administrative and Legal Reasons for Disclosure of Information: We cooperate with government and law enforcement officials and private parties to enforce and comply with the law. Thus, we may access, use, preserve, transfer and disclose your information (including, Your Information), including disclosure to third parties such as government or law enforcement officials or private parties as we reasonably determine is necessary and appropriate:
- To satisfy any applicable law, regulation, subpoenas, governmental requests or legal process court order, warrant, summons or similar process (We may release Your Information to authorized federal officials for intelligence, counterintelligence, and other national security activities authorized by law);
- To defend lawsuits and disputes arising from the Agreement;
- To protect and/or defend the Agreement or other policies applicable to any online and mobile Services, including investigation of potential violations thereof;
- To protect the safety, rights, property or security of WGA, our Services or any third party;
- To protect the safety of the public for any reason;
- To identify or locate a suspect, fugitive, material witness, or missing person;
- To detect, prevent or otherwise address fraud, security or technical issues; and
- To prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical, criminal or legally actionable activity.
- We may use IP address or other Device Identifiers, to identify users, and may do so in cooperation with third parties such as copyright owners, internet service providers, wireless service providers and/or law enforcement agencies, including disclosing such information to third parties, all in our discretion. Such disclosures may be carried out without notice to you.
REASONS FOR DISCLOSURE OF YOUR INFORMATION
We also reserve the right to disclose and transfer all such information:
- To public health reporting and other governmental healthcare oversight activities. Your health information may be disclosed to public health agencies as required by law;
- In connection with a corporate merger, consolidation, restructuring, the sale of substantially all of the outstanding stock and/or assets or other corporate change, including, during the course of any due diligence process;
- To comply with any court order, law or legal process, including to respond to any government or regulatory request;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of WGA our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
You may have certain rights under the state and federal privacy standards. These include:
- Right to Request Restrictions: You have the right to request restrictions on our uses and disclosures of Your Information.
- Alternative Communication Means: You have the right to reasonably request to receive confidential communications of Your Information by alternative means or at alternative locations.
- Right to Inspect a Copy: You have the right to inspect and copy your Health Information by submitting a written request detailing what information you want access to, whether you want to inspect it or get a copy of it, and if you want a copy, your preferred form and format. We will provide copies in your requested form and format if it is readily producible, or we will provide you with an alternative format you find acceptable. We may charge a reasonable fee which covers our costs for labor, supplies, postage, and if requested and agreed to in advance, the cost of preparing an explanation or summary, as allowed by applicable law. We may deny your request under limited circumstances;
- Right to Amend: You have the right to amend or submit corrections to your Health Information by submitting a written request including the reasons you believe the information is incorrect or incomplete. We are not required to change your Health Information and will provide you with information regarding our denial of such requested amendment. If we deny your request, you may submit a written statement of your disagreement with that decision, and we may, in turn, prepare a written rebuttal;
- Right to an Accounting: The right to receive an accounting of how and to whom your protected health information has been disclosed; provided, however, we are not required to provide to you an accounting of disclosures made for the purposes of information provided directly to you, information provided pursuant to your written authorization, and certain government functions; and
- Printed Copy. You have the right to receive a printed copy of this notice.
YOUR INFORMATION AFTER CANCELLING ACCOUNT
You are responsible for maintaining the accuracy of the information you submit to WGA, such as your contact information provided as part of account registration. If Your Information changes, or if you no longer desire to use the Services, you may correct, delete inaccuracies, or amend information by making the change on our member information page or by working with your employer and if direct services contacting us at 855-Wamberg (855-267-2374). We will make good faith efforts to make requested changes in our then active databases as soon as reasonably practicable. WGA will retain Your Information for as long as your account with the Services is active and as needed to provide you services. Even after your account is terminated, we will retain your Personal Information as needed to comply with our legal and regulatory obligations, resolve disputes, conclude any activities related to cancellation of an account (such as addressing chargebacks from your employer or credit card companies), investigate or prevent fraud and other inappropriate activity, to enforce our agreements, and for other business reason. After a period of time, your data may be anonymized and aggregated, and then may be held by us as long as necessary for us to provide our Services effectively, but our use of the anonymized data will be solely for analytic purposes.
If you believe your privacy rights have been violated, you may file a complaint with WGA. To file a complaint with WGA, please contact WGA at [email protected] or via US postal mail at the following address:
Wamberg Genomic Advisors, Inc.
4330 La Jolla Village Drive
San Diego, California 92122