PWNHealth Notice of Privacy Practices and Privacy Policy

Effective Date: October 15, 2019

This notice describes how health information about you may be used and disclosed, and how you can get access to this information. Please review it carefully.

How We May Use and Disclose your Health Information. PWN Remote Care Services, P.A., PWN Remote Care Services, P.C., PW Medical Professional and certain other affiliated professional entities and PWNHealth, LLC (the administrative services provider of the professional entities (collectively, "PWNHealth", "we" or "us") may use your health information and disclose it to appropriate persons, authorities and agencies, as allowed by federal and state law. Please be aware that state and federal law may have more requirements on how we use and disclose your health information. If there are specific, more restrictive requirements, even for some of the purposes listed above, we may not disclose your health information without your written permission as required by such laws. We may also be required by law to obtain your written permission to use and disclose your information related to treatment for a mental illness, developmental disability, or alcohol or drug abuse. We may do this without your written permission for the following limited purposes:

  1. Treatment.
  2. Payment.
  3. Required by Law.
  4. Public Health.
  5. Reporting Victims of Abuse or Neglect.
  6. Health Care Oversight.
  7. Legal Proceedings & Law Enforcement.
  8. Death.
  9. Serious Threats to Health or Safety.

We may also disclose any information that you provide to use or that is provided on your behalf. You have the right to request a restriction or limitation on the disclosure of such information as set forth below.

Your Health Information Rights. You have the right to:

  1. Read and copy your health information.
  2. Request to correct your health information.
  3. Request to restrict certain uses and disclosures of your information. You have the right to request in writing that we restrict how your health information is used or disclosed. For most requests, under the law, we are not required to agree to your request. In some cases, we may not be able to agree to your request because we do not have a way to tell everyone who would need to know about the restriction. There are other instances in which we are not required to agree with your request. We will inform you when we cannot find a way to carry out your request.
  4. Receive a record of how we disclosed your information.
  5. Receive notification of a breach and obtain a paper copy of this notice.

Contact us at info@pwnhealth.com or PWNHealth, 123 W 18th Street, New York, NY 10011, Attn: Privacy Officer with any questions or concerns regarding the above.

PWNHealth Terms of Use

Effective Date: October 15, 2019

This Privacy Policy ("Privacy Policy") describes the data collection practices of PWNHealth, LLC (the administrative services provider of the professional entities), PWN Remote Care Services and certain contractually affiliated professional entities (collectively, "PWNHealth", "we" or "us") and how we use, disclose, and protect your personal information. This Privacy Policy applies to the information we collect through your use of the services relating to clinical oversight of testing, including genetic counseling support tools (such videos, webinars, "Ask a Genetic Counselor a Question" and other messaging tools), genetic counseling and any other related services provided by PWNHealth or its service providers (the "PWNHealth Services") in connection with Ancestry.com, LLC's ("Ancestry") AncestryHealth services (the "Ancestry Services") on the Ancestry website.

As part of the Ancestry Services and the PWNHealth Services, you will interact with certain website pages that are hosted by Ancestry or by PWNHealth. Ancestry's privacy policy, terms and conditions of use and other related policies (the "Ancestry Policies"), which are located on each Ancestry page or otherwise provided by Ancestry, govern your interactions with the website pages hosted by Ancestry ("Ancestry Website") and the Ancestry Services and they describe what information Ancestry collects about you when you use Ancestry's Services and how that information is used, disclosed, and maintained by Ancestry. If the Ancestry Policies appear on a website page (and not this Privacy Policy), then website page is governed by the Ancestry Policies. As part of the PWNHealth Services, including in connection with the PWNHealth genetic counseling support tools, you will interact with website pages hosted by PWNHealth. If this Privacy Policy appears on any website page, then the website page is governed by this Privacy Policy.

In addition, our Notice of Privacy Practices above describes how health information about you may be used and disclosed by PWNHealth and its service providers, and how you can get access to this information. In the case of any differences between the Notice of Privacy Practices and this Privacy Policy, the Notice of Privacy Practices will govern. Except as otherwise expressly provided herein, all references to this Privacy Policy include the Notice of Privacy Practices.

  1. Consent. By accessing, using, or viewing the PWNHealth hosted web pages (the "PWNHealth Website") and/or receiving the PWNHealth Services, you agree that you have read and understood this Privacy Policy and unconditionally agree to be bound by it. Further, you consent to the collection and use of your information in the manner we describe in this Privacy Policy. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY, PLEASE DO NOT USE THIS PWNHEALTH WEBSITE OR PWNHEALTH SERVICES.
  2. Changes to our Policy. We reserve the right to modify or amend this Privacy Policy at any time. All changes to this Privacy Policy will be effective immediately upon their posting to the PWNHealth Website. We will notify you of material changes to this Privacy Policy by posting the modified Privacy Policy on the PWNHealth Website. Continued use of the PWNHealth Website and/or the PWNHealth Services after the effective date of a modified Privacy Policy will indicate your agreement to any modified terms.
  3. Personally Identifiable Information We Collect. In your use of the PWNHealth Website and PWNHealth Services, we may collect any information that you voluntarily share with us. This information may be collected when you (i) send us emails or other messages, (ii) submit information through the PWNHealth genetic counseling support tools, such as messaging in connection with a webinar or the “Ask a Genetic Counselor a Question” messaging feature, (iii) otherwise submit information to us via the PWNHealth Website, such as through the “Contact Us” feature, (iv) provide information during genetic counseling sessions, or (v) otherwise provide information in connection with the PWNHealth Services. This information may also be collected by third party service providers or partners on our behalf. In addition, we receive from Ancestry the personal information you provided to Ancestry that is required to perform the PWNHealth Services, such as your contact information, biographical information, personal and family health history information and purpose or reasons for taking the test. Certain information in the PWNHealth genetic counseling support tools, such as certain “Ask a Genetic Counselor” messaging, will be collected on the Ancestry Website and provided to PWNHealth. We also receive your test reports from the applicable laboratory and Ancestry.

    We may use third party service providers to assist us in collecting and maintaining this personally identifiable information. However, we require such service providers to maintain the confidentiality of such information.

  4. How we use Personally Identifiable Information we Collect. We will use personally identifiable information: (i) to provide the PWNHealth Services to you; (ii) to send messages to you and otherwise communicate with you in connection with the PWNHealth Services, (iii) as otherwise may be disclosed at the point of collection, and/or (iv) as described below or in the Notice of Privacy Practices.

    In addition, we may use your personal information in the aggregate in a non-identifiable way in order to better understand the PWNHealth Services being provided, to improve the PWNHealth services, to improve the PWNHealth Website and for any other lawful purpose.

  5. Other Information Collected On the PWNHealth Website. When you visit the PWNHealth Website, we (or a third party service provider on our behalf) may passively collect the following non-personal information about you and your usage of the PWNHealth Website.

    1. IP Address. Your IP address may be collected. Your "IP address" is usually associated with the network location and physical location from which you enter the Internet. We log IP addresses for systems administration purposes. This information helps us determine how often different areas of our site are visited and we also use this information to personalize the content that is displayed to you on the PWNHealth Website based on your previous visits and the ads that you access. We do not link IP address to any information that is personally identifiable.
    2. Cookies. We use cookies to track the use of the PWNHealth Website and to facilitate and enhance your experience on the PWNHealth Website and to statistically analyze trends and other user behavior on the PWNHealth Website. The term "cookies" refers to electronic data stored by your computer browser. The cookies enable us to facilitate your access to different aspects of the PWNHealth Website. Cookies can also help us to improve your enjoyment of the PWNHealth Website, for example, by remembering your address or other information when you request information or services on the PWNHealth Website.

      Most web browsers automatically accept cookies, but you can disable this function so that your browser will not accept cookies. Please be aware that if you disable this function, it may impact your use and enjoyment of the PWNHealth Website.

    3. Web Beacons and Pixel Tags. The term "web beacons" and "pixel tags" refer to Internet tools, such as transparent images on the PWNHealth Website or in emails that we may send to you that help us to determine whether a page has been viewed or an email opened. A pixel tag is a type of web beacon embedded in an image on the website. In general, any electronic image viewed as part of a web page can contain a pixel tag or other web beacon. We may also use these Internet technology tools to allow us to track the internet browser most commonly used to access the PWNHealth Website and other statistics that assist us in making the PWNHealth Website more user-friendly and accessible.
    4. Statistical Identifiers and Device Recognition. We (or our service providers on our behalf) may employ statistical identifiers, also known as device recognition tools. These tools may be used to assist in managing the content on the PWNHealth Website by informing us (without using cookies) of the content that you use and view on the PWNHealth Website. These tools collect various information about your device, such as your screen resolution, browser type, and operating system. Many devices have unique, or near unique, device profiles such that collecting this information allows us and our service providers to determine with a reasonable level of statistical accuracy information on your engagement with the PWNHealth, as well as your device when you interact with the PWNHealth Website. We do not tie this statistical information to your personal information.
    5. Surveys. We may also ask that you participate in anonymous surveys, which allow us to collect additional data to help us improve the PWNHealth Website and PWNHealth Services. Participation in such surveys is voluntary and is not connected to any of your personal information.
    6. Analytics. We use non-personally identifiable information in the aggregate to determine how much traffic the PWNHealth Website receives, to statistically analyze PWNHealth Website usage, to improve our content, and to customize the PWNHealth Website's content, layout and services. In addition, we may use your IP address to help diagnose problems with our server, to manage the PWNHealth Website and to enhance the PWNHealth Website and PWNHealth Services based on the usage pattern data we receive.
  6. How we Disclose the Information we Collect. We may disclose aggregated information about our users, and information that does not identify any individual, in compliance with applicable law.

    In addition, you agree that we have the right to disclose personal information that we collect or you provide:

    • to Ancestry (please note, for any information disclosed to Ancestry, the use and disclosure of such information by Ancestry will be governed by the Ancestry Policies);
    • to the laboratory that performed or will perform the genetic tests relating to the PWNHealth Services;
    • to any member of our group, which means our subsidiaries and affiliates, including our ultimate holding company and its subsidiaries and contractually affiliated, professional corporations as needed to provide the PWNHealth Services;
    • to analytics providers that assist us in the improvement and optimization of the PWNHealth Website and PWNHealth Services;
    • to fulfill the purpose for which you provide it;
    • for any other purpose disclosed by us when you provide the information or with your consent;
    • to third-party service providers specifically involved in the processing of your information received via the PWNHealth Website and as otherwise necessary to manage the PWNHealth Website and provide the PWNHealth Services you request;
    • to resolve disputes, investigate problems, and enforce the PWNHealth Website terms of use or any other agreement with PWNHealth;
    • to investigate and disclose information from or about you if we have a good faith belief that such investigation or disclosure is (a) reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) helpful to prevent, investigate, or identify possible wrongdoing in connection with the PWNHealth Website; or (c) protect our rights, reputation, property, or that of our users, affiliates, or the public;
    • if we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, reorganization, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership; and
    • in connection with a commercial transaction where we are seeking financing, investment, support or funding.
  7. Handling and Retention of Information; Backup. In general, we will retain all information collected through the PWNHealth Website and PWNHealth Services for, at a minimum, the length of time permitted by applicable law. We maintain backup files as a protection against natural disasters, equipment failures, or other disruptions. Backup files protect you and us because they lower the risk of losing valuable data. Backup files may contain records with your personal information. Removing a record from our active files and databases does not remove that record from any backup systems. Such backup data will eventually be passively deleted as backup records are erased through the normal recycling of backup files. In the meantime, as long as backup records exist, they receive the same security protections as our other records.

    If you request that Ancestry delete your information held by Ancestry, such request will not result in the deletion of information held by PWNHealth. Such information will be retained by PWNHealth in accordance with applicable law and this Privacy Policy.

  8. Security. Communications between your browser and portions of the PWNHealth Website containing personally identifiable information may be protected with various forms of encryption. This encryption is to help protect your information while it is being transmitted. Once we receive your information we strive to maintain the physical and electronic security of your personal information using commercially reasonable efforts.

    HOWEVER, NO DATA TRANSMISSION OVER THE INTERNET OR ANY WIRELESS NETWORK CAN BE GUARANTEED TO BE PERFECTLY SECURED. AS A RESULT, WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION USING COMMERCIALLY AVAILABLE AND INDUSTRY STANDARD TECHNOLOGY, WE CANNOT ENSURE OR GUARANTEE THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO US, AND YOU DO SO AT YOUR OWN RISK.

    We have implemented measures designed to secure your personal information form accidental loss and from unauthorized access, use, alteration, and disclosure. As you access your personal information in connection with the PWNHealth Services by logging on to your Ancestry account, you are responsible for keeping your password confidential.

  9. Security Breach. If we determine that your personal information has or may reasonably have been disclosed due to a security breach of our systems, we will notify you to the extent required by applicable state and federal law, using your information that we have on file.
  10. Third Party Privacy. This Privacy Policy applies only to the PWNHealth Website and the PWNHealth Services provided by PWNHealth. PWNHealth is not responsible for the privacy practices of any third party website you access from this PWNHealth Website. You should review the privacy policy of every website before using the website or submitting any information to the website.
  11. California Privacy Rights. California's "Shine the Light" law (Civil Code Section § 1798.83) permits users of the PWNHealth Website and PWNHealth Services that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. PWNHealth does not disclose any personal information to third parties for their direct marketing purposes.