General Privacy Notice

Rightway Healthcare, Inc. (“Rightway,” “we,” “us,” or “our”) provides best-in-class concierge healthcare navigation for employees at over 150 leading organizations. Rightway also contracts with RW Health FL, PC, and its associated medical practices (collectively, the “Medical Group”) to make its technology available for the performance of online medical consultations and secure messaging (“Telehealth Services”) between Medical Group healthcare professionals (individually the “Provider” and collectively the “Providers”) and their patients.  This Privacy Policy describes our practices concerning the data we receive or collect when you visit our website, https://rightwayhealthcare.com/ (our “Site”), or install or use our mobile application (the “App”) (collectively, the “Services”). If you have questions regarding our Privacy Policy, please direct such questions to info@rightwayhealthcare.com.  

This privacy notice does not apply to information that is protected health information (“PHI”) under the Health Insurance Portability and Accountability Act (“HIPAA”). Any collected information that constitutes PHI is governed by, and will be used and disclosed solely as permitted under, the business associate agreement between Rightway and the Medical Group. The collection and use of your PHI by the Medical Group through the Telehealth Services is governed by the Notice of Privacy Practice provided to you by the Medical Group through the Services.

1.  HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

Registration Information

When you sign up for our App, you provide us with your email address and hashed password.

Contact Forms, Chats & Demo Requests

When you contact us at info@rightwayhealthcare.com, or by calling (305) 851-7310, or by chatting with us through the App, you may choose to provide us with certain personal information. In addition, if you request a demo of our services, we collect the contact information needed to get in touch with you. If you decide to sign up with us, we will collect information that will help us present you with information relevant to your interests.

Questionnaires & Surveys

On occasion upon entering our Site, you may be asked to complete an online survey or questionnaire. These surveys and questionnaires may seek information about your opinions, attitudes, interests, and online activities.

Cookies

Cookies are small packets of data that a website stores on your computer’s hard drive so that your computer will “remember” information about your visit. We use a combination of first-party and third-party cookies on our Site. First-party cookies are served from the rightwayhealthcare.com domain and are used as technically necessary to provide the Site and to enable certain features, such as to remember your log-in details. For use of third-party cookies (and related “tracking technologies,” such as pixel tags), please see “Third-Party Tracking Technologies” below. If you do not want us to place a cookie on your hard drive, you may be able to turn that feature off on your computer or mobile device. Please consult your Internet browser’s documentation for information on how to do this. However, if you decide not to accept cookies from us, the Site may not function properly.

Third-Party Tracking Technologies

We use different third-party service providers that utilize tracking technologies, such as cookies and pixel tags. They are as follows: Google Analytics: General statistics about the usage of our Site. Google Analytics collects your IP address as part of its tracking functionality. This information is reported only in aggregate and your individual IP address is not reported.

Other Automatically Collected Information

To assist visitors with technical problems, we may collect local web configuration information, including browser type, operating system, and various other browser settings. In addition, our web servers automatically collect limited information about your computer when you visit our Site. This information may include the type of browser software you use, the operating system you’re running, the IP address assigned to your computer or Internet connection, and the IP address of the website, if any, that referred you to our Site. Our technical staff may also use this information to assist customers with technical problems.

Data Received from Employers

Employers may provide us with the following personal information about employee health plans and records in order for us to provide our Services:

  • Your full name

  • Your date of birth

  • Your social security number

  • Your email address

  • Your health plan(s) and provider(s) (e.g., medical, dental, and vision)

  • The full name, date of birth, social security number, employer, and email address of your dependent(s)

2.  HOW WE KEEP YOUR PERSONAL INFORMATION SECURE

We maintain administrative, technical, and physical safeguards in an effort to protect against unauthorized disclosure, use, alteration, or destruction of any personal information you may provide to us through the Site. However, please be aware that regardless of any security measures used, we cannot guarantee the absolute protection and security of any personal information stored with us or with any third parties.

3.  DISCLOSURES OF YOUR PERSONAL INFORMATION

We may share your personal information with third parties including third-party service providers, regulatory bodies, and under valid court orders. We may also share personal information when we believe that disclosure is necessary or appropriate to prevent physical harm or financial loss in connection with an investigation of suspected or actual illegal activity. We reserve the right to transfer any information we have about you in the event we sell or transfer all or a portion of our business or assets. Should such a sale or transfer occur, we will use reasonable efforts to direct the transferee to use the personal information you have provided through this Site in a manner that is consistent with this Privacy Policy.

4.  RETENTION OF YOUR PERSONAL INFORMATION

We will only retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including for the purposes of satisfying any legal, regulatory accounting, or reporting requirements. In some circumstances, you may ask us to delete your personal information: see the Your Privacy Rights section for further information. In some circumstances, we may anonymize your personal information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

5.  YOUR PRIVACY RIGHTS

You may send us an email at info@rightwayhealthcare.com to request access to, correct, or delete any personal information that you have provided to us. However, we may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

6.  CALIFORNIA RESIDENTS

California residents may have additional personal information rights and choices under the California Consumer Privacy Act (CCPA). Please see our CCPA Privacy Notice for more information. We do not monitor, recognize, or honor any opt-out or do not track mechanisms, including general web browser “Do Not Track” settings and/or signals.

7.  THIRD-PARTY LINKS

Our Site may contain links to third-party websites that are not subject to this Privacy Policy. If you visit these websites, we encourage you to read their privacy policies before providing them with any personal information.

8.  CHILDREN

We do not knowingly collect personal information from children under the age of 13 through the Site. If you are under 13, please do not give us any personal information. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children to never provide us personal information. If you have reason to believe that a child under the age of 13 has provided personal information to us, please contact us, and we will endeavor to delete that personal information from our databases.

9.  CHANGES TO THIS PRIVACY POLICY

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. By accessing and using the Site after we notify you of such changes to this Privacy Policy, you are deemed to have accepted such changes. Please refer back to this Privacy Policy on a regular basis.

10. CONTACT US

If you have questions regarding this Privacy Policy, please direct such questions to info@rightwayhealthcare.com. You may also write to us at: Rightway Healthcare Inc. 55 Hudson Yards, Floor 29 New York, NY 10001 

RW Health Notice Of 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.

1. Who We Are

This Notice describes the privacy practices of RW Health FL, PC and members of its Affiliated Covered Entity (collectively, “RW Health”, “we” or “us”) in our provision of remote care services through the Rightway Healthcare Service, including: 

  • All healthcare professionals allowed to enter or access information in your medical record

  • All employees and with access to your medical or billing records or health information about you (“Protected Health Information”).

2. Our Privacy Obligations

We understand that your health information is personal and we are committed to protecting your privacy. In addition, we are required by law to maintain the privacy of your Protected Health Information, to provide you with this Notice of our legal duties and privacy practices with respect to your Protected Health Information, and to notify you in the event of a breach of your unsecured Protected Health Information.  When we use or disclose your Protected Health Information, we are required to abide by the terms of this Notice (or other notice in effect at the time of the use or disclosure).  

3. Permissible Uses and Disclosures Without Your Written Authorization

In certain situations, which we will describe in Section IV below, we must obtain your written authorization in order to use and/or disclose your Protected Health Information.  However, unless the Protected Health Information is Highly Confidential Information (as defined in Section IV.B below) and the applicable law regulating such information imposes special restrictions on us, we may use and disclose your Protected Health Information without your written authorization for the following purposes:

  • Treatment.  We use and disclose your Protected Health Information to provide treatment and other services to you--for example, to provide telehealth consultations or to consult with your physician about your treatment plan.  We may use your information to direct or recommend alternative treatments, therapies, health care providers, or settings of care to you or to describe a health-related product or service. We may also disclose Protected Health Information to other providers involved in your treatment. 

  • Payment.  We may use and disclose your Protected Health Information to obtain payment for health care services that we provide to you--for example, disclosures to claim and obtain payment from Medicare, Medicaid, your health insurer, HMO, or other company or program that arranges or pays the cost of your health care (“Your Payor”) to verify that Your Payor will pay for the health care.  We may also disclose Protected Health Information to your other health care providers when such Protected Health Information is required for them to receive payment for services they render to you.

  • Health Care Operations.  We may use and disclose your Protected Health Information for our health care operations, which include internal administration and planning and various activities that improve the quality and cost effectiveness of the care that we deliver to you.  For example, we may use Protected Health Information to evaluate the quality and competence of our health care professionals.  We may disclose Protected Health Information to our Customer Success Managers in order to resolve any complaints you may have and ensure that you our satisfied with our services.

  • Disclosure to Relatives, Close Friends and Other Caregivers.  We may use or disclose your Protected Health Information to a family member, other relative, a close personal friend or any other person identified by you when you are present for, or otherwise available prior to, the disclosure, if: (1) we obtain your agreement or provide you with the opportunity to object to the disclosure and you do not object; or (2) we reasonably infer that you do not object to the disclosure. If you are not present for or unavailable prior to a disclosure (e.g., when we receive a telephone call from a family member or other caregiver), we may exercise our professional judgment to determine whether a disclosure is in your best interests.  If we disclose information under such circumstances, we would disclose only information that is directly relevant to the person’s involvement with your care. 

  • As Required by Law.  We may use and disclose your Protected Health Information when required to do so by any applicable federal, state or local law.

  • Public Health Activities.  We may disclose your Protected Health Information: (1) to report health information to public health authorities for the purpose of preventing or controlling disease, injury or disability; (2) to report child abuse and neglect to a government authority authorized by law to receive such reports; (3) to report information about products under the jurisdiction of the U.S. Food and Drug Administration; (4) to alert a person who may have been exposed to a communicable disease or may otherwise be at risk of contracting or spreading a disease or condition; and (5) to report information to your employer as required under laws addressing work-related illnesses and injuries or workplace medical surveillance.  

  • Victims of Abuse, Neglect or Domestic Violence.  We may disclose your Protected Health Information if we reasonably believe you are a victim of abuse, neglect or domestic violence to a government authority authorized by law to receive reports of such abuse, neglect, or domestic violence.  

  • Health Oversight Activities.  We may disclose your Protected Health Information to an agency that oversees the health care system and is charged with responsibility for ensuring compliance with the rules of government health programs such as Medicare or Medicaid.  

  • Judicial and Administrative Proceedings.  We may disclose your Protected Health Information in the course of a judicial or administrative proceeding in response to a legal order or other lawful process. 

  • Law Enforcement Officials.  We may disclose your Protected Health Information to the police or other law enforcement officials as required by law or in compliance with a court order. 

  • Decedents.  We may disclose your Protected Health Information to a coroner or medical examiner as authorized by law. 

  • Organ and Tissue Procurement.  We may disclose your Protected Health Information to organizations that facilitate organ, eye or tissue procurement, banking or transplantation. 

  • Health or Safety.  We may use or disclose your Protected Health Information to prevent or lessen a serious and imminent threat to a person’s or the public’s health or safety. 

  • Specialized Government Functions.  We may use and disclose your Protected Health Information to units of the government with special functions, such as the U.S. military or the U.S. Department of State under certain circumstances. 

  • Workers’ Compensation.  We may disclose your Protected Health Information as authorized by and to the extent necessary to comply with state law relating to workers’ compensation or other similar programs.

4. Uses and Disclosures Requiring Your Written Authorization

For any purpose other than the ones described above in Section III, we only use or disclose your Protected Health Information when you give us your written authorization.  

  • Marketing. We will obtain your written authorization prior to using your Protected Health Information for purposes that are marketing under the HIPAA privacy rules. For example, we will not accept any payments from other organizations or individuals in exchange for making communications to you about treatments, therapies, health care providers, settings of care, case management, care coordination, products or services unless you have given us your authorization to do so or the communication is permitted by law. We may provide refill reminders or communicate with you about a drug or biologic that is currently prescribed to you so long as any payment we receive for making the communication is reasonably related to our cost of making the communication. In addition, we may market to you in a face-to-face encounter and give you promotional gifts of nominal value without obtaining your written authorization. 

  • Sale of Protected Health Information. We will not make any disclosure of Protected Health Information that is a sale of Protected Health Information without your written authorization.

  • Psychotherapy Notes. We will not use or disclose psychotherapy notes about you without your authorization except for use by the mental health professional who created the notes to provide treatment to you, for our mental health training programs or to defend ourselves in a legal action or other proceeding brought by you. 

  • Uses and Disclosures of Your Highly Confidential Information.  Federal and state law requires special privacy protections for certain health information about you (“Highly Confidential Information”), including Alcohol and Drug Abuse Treatment Program records and other health information that is given special privacy protection under state or federal laws other than HIPAA.  However, in order for us to disclose any Highly Confidential Information for a purpose other than those permitted by law, we will obtain your authorization.  

  • Revocation of Your Authorization.  You may revoke your authorization, except to the extent that we have taken action in reliance upon it, by delivering a written revocation statement to the Privacy Office identified below.

5. Your Individual Rights

  • For Further Information; Complaints.  If you desire further information about your privacy rights, are concerned that we have violated your privacy rights or disagree with a decision that we made about access to your Protected Health Information, you may contact our Privacy Office.  You may also file written complaints with the Office for Civil Rights of the U.S. Department of Health and Human Services.  Upon request, the Privacy Office will provide you with the correct address for the Director.  We will not retaliate against you if you file a complaint with us or the Director.  

  • Right to Request Additional Restrictions.  You may request restrictions on our use and disclosure of your Protected Health Information (1) for treatment, payment and health care operations, (2) to individuals (such as a family member, other relative, close personal friend or any other person identified by you) involved with your care or with payment related to your care, or (3) to notify or assist in the notification of such individuals regarding your location and general condition.  While we will consider all requests for additional restrictions carefully, we are not required to agree to a requested restriction unless the request is to restrict our disclosure to a health plan for purposes of carrying out payment or health care operations, the disclosure is not required by law and the information pertains solely to a health care item or service for which you (or someone on your behalf other than the health plan) have paid us out of pocket in full.  If you wish to request additional restrictions, please obtain a request form from our Privacy Office and submit the completed form to the Privacy Office.  We will send you a written response.

  • Right to Receive Communications by Alternative Means or at Alternative Locations.  You may request, and we will accommodate, any reasonable written request for you to receive your Protected Health Information by alternative means of communication or at alternative locations.  

  • Right to Inspect and Copy Your Health Information.  You may request access to your medical record file and billing records maintained by us in order to inspect and request copies of the records.  Under limited circumstances, we may deny you access to a portion of your records.  If you desire access to your records, please obtain a record request form from the Privacy Office and submit the completed form to the Privacy Office.  If you request copies, we may charge you a reasonable copy fee.

  • Right to Amend Your Records.  You have the right to request that we amend your Protected Health Information maintained in your medical record file or billing records.  If you desire to amend your records, please obtain an amendment request form from the Privacy Office and submit the completed form to the Privacy Office.  We will comply with your request unless we believe that the information that would be amended is accurate and complete or other special circumstances apply.

  • Right to Receive an Accounting of Disclosures.  Upon request, you may obtain an accounting of certain disclosures of your Protected Health Information made by us during any period of time prior to the date of your request provided such period does not exceed six years.  If you request an accounting more than once during a twelve (12) month period, we may charge you a reasonable fee for the accounting statement.

  • Right to Receive Paper Copy of this Notice.  Upon request, you may obtain a paper copy of this Notice, even if you agreed to receive such notice electronically.  

6. Effective Date and Duration of This Notice

  • Effective Date.  This Notice is effective on 4/14/2021.

  • Right to Change Terms of this Notice.  We may change the terms of this Notice at any time.  If we change this Notice, we may make the new notice terms effective for all your Protected Health Information that we maintain, including any information created or received prior to issuing the new notice.  If we change this Notice, we will post the new notice in our waiting room and on our Internet site at www.rightwayhealthcare.com.  You also may obtain any new notice by contacting the Privacy Office.

7. Privacy Office

You may contact the Privacy Office at:

  • Privacy Office: Rightway Healthcare Inc, 228 Park Ave S PMB 42634 New York, NY 10003

  • Telephone Number: (646) 450-8026 E-mail: info@rightwayhealthcare.com