Twin Health, Inc. and its related companies (“We”, “Us”, “Twin Health”) take your privacy seriously, and we want you to know how we collect, use, share, and protect your information. This policy (the “Privacy Policy”) tells you what information we collect from you as a user of the Twin Health websites (the “Websites”) and the mobile application (the “App”), together the (“Services”), how we use that information, how we may share that information, how we protect your information, and your choices regarding your Personal Information (defined below). This Privacy Policy does not apply to information collected by us through any other means or any third party, including through any application or content that may link to or be accessible from or on the Services.
NOTE THAT ONCE YOU BECOME A TWIN MEMBER TWIN HEALTH MAINTAINS THE PRIVACY OF YOUR HEALTH INFORMATION IN ACCORDANCE WITH THE TWIN HEALTH MEDICAL GROUP NOTICE OF PRIVACY PRACTICES, AVAILABLE ON OUR SERVICES.
IF YOU DO NOT AGREE TO THE PRIVACY POLICY, INCLUDING ANY CHANGES THERETO, THEN YOU MUST NOT ACCESS AND USE THE SERVICES.
To utilize the Services, you are required to submit certain information to establish an account. We collect and utilize certain information as set forth below.
We collect several types of information from and about users of our Services (collectively “Personal Information”), including, specifically:
Personally identifiable information about you, which may include your name, date of birth, mailing addresses, telephone numbers, email addresses, contact or authentication data, contact preferences, health information, health insurance information, your medical history,and any other information you provide to us, or grant us access to; information that you provide by filling in forms via our Services, including at the time of registering to use the Services, using the Services, or requesting further Services; information when you report a problem with our Services; records and copies of your correspondence (including email addresses) if you contact us; and details of requests through our Services and the fulfillment of your requests.
We will process Personal Information collected through the Services in accordance with applicable law and with the agreements we have with your employer, health plan, or other applicable entity that may be sponsoring your access to and use of the Services (as applicable, the “Sponsor”), and as described in our Privacy Policies.
We may collect Personal Information about you from third parties, such as your Sponsor and our business partners and service providers (including, without limitation, the third-party distributors of the devices and sensors we provide to you). Your Sponsor may provide us with information so that we can provide our Services to you.
We may automatically collect certain information when you use the Services. This information may include device and usage information, such as your IP address, traffic data, logs, the location of your affiliated devices, affiliated device IDs, type of device and operating system you use to access our Services, information stored on your device as it relates to your use of the Services, browser and device characteristics, your activities within the Services including the length of time that you were logged in and the amount of time spent using the Services, language preferences, referring URLs, your network information, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.
Additionally, we may collect certain information automatically when you use the Services, including the following information through the below methods:
We may use analytic and tracking tools to better understand who is using the Services, how people are using the Services and how to improve the effectiveness of the Services and its content. Analytics may include technologies to collect and store anonymous information such as time of visit, pages visited, time spent using the Services, device identifiers, type of operating system used and other websites you may have visited. They might combine information they collect from your interaction with the Services with Personal Information they collect from other sources. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies.
Twin Health respects your privacy and will not sell your Personal Information to third parties.
We may use your Personal Information provided via the Services to: provide, improve, and administer our services to you, respond to your inquiries, provide information on products and services you request or have a representative contact you regarding our products or services that you may be interested in, carry out our obligations and enforce our rights arising from any contracts entered into between you and us or your Sponsor and us, including for billing and collection, notify you about changes to our Services or any products or services offered through them, fulfill any other purpose for which you provide it, and for any other purpose with your consent. Unless you have otherwise opted out of receiving email or text communication from us, you agree by using the Services, to allow us to use your email, mailing address, or telephone number for communication and provision of Services consistent with this Privacy Policy.
Some information Twin Health collects constitutes protected health information (“PHI”) under the U.S. Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). As set forth above, Twin Health will provide you with a Notice of Privacy Practices describing its collection, use, and disclosure of your health information. Twin Health will use and disclose PHI only as permitted in accordance with our Notice of Privacy Practices and we only collect the PHI we need to fully perform our Services and to respond to you.
Twin Health maintains a normative database, which includes de-identified information (as defined under HIPAA) on its book of business. The normative database is used for benchmarking, analysis, and research. All data in the normative database, if derived from your medical information, is fully de-identified to protect your confidentiality and will thereafter no longer constitute protected health information that is subject to HIPAA. Accordingly, Twin Health may use such de-identified data in any lawful manner including for our generative Artificial Intelligence (“AI”) tool that is used for providing individualized lifestyle recommendations.
We may combine or cross-reference your Personal Information with general information or other information we may have acquired about you or may acquire about you through other sources, including offline sources of information to help further customize the information, products, or Services we provide to you. We may also collect, aggregate, and maintain anonymous information about the visitors to our Services. We may further share such aggregate, non-identifiable information with business partners, sponsors and other third parties.
From time to time, we may use third parties to provide products, services or otherwise support our business or collaborate with third parties with respect to development, promotion or other business activities related to a particular product or service. These third parties may include service providers of your Sponsor or our own service providers we use to support our business and who provide IT and infrastructure support services, and marketing, and billing services. We will only disclose Personal Information that we collect or you provide to contractors, service providers, and other third parties to provide the Services as outlined above; provided such third parties have agreed to comply with this Privacy Policy or substantially equivalent terms. We may also disclose Personal Information to our affiliates (e.g. related or controlled companies). We may also release your Personal Information to third parties as required by law, when we believe disclosure is necessary to comply with legal or regulatory requirements, judicial proceedings, court orders or legal process served on us, to protect the safety, rights or property of patients, customers, the public or Twin Health or defend Twin Health and its officers, directors, employees, attorneys, agents, contractors and partners, in connection with any legal action, claim, or dispute. We may also disclose Personal Information to enforce or apply our Terms of Use and other agreements, and as otherwise permitted by law.
While you may be using personal fitness devices, internet-connected medical devices (such as blood sugar monitors), or similar devices to collect biometric and other data that constitutes Personal Information and thereafter send that data to us, your relationship with Twin Health does not impact your rights and obligations with respect to the companies that manufactured and/or supplied those devices (the “Device Manufacturers”). Your relationship with Twin Health is independent of your relationship with the Device Manufacturers, and Twin Health is not responsible for any uses or disclosure of your Personal Information by the Device Manufacturers. Please refer to any privacy policies, terms and conditions, and license agreements you may have with the Device Manufacturers.
Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any Personal Information we gather from you on our Services to third parties.
You may notify us, through the means listed below in the Contact Us section below, of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. You may also request for your profile in the App to be deleted. We may not be able to accommodate your request if we believe it would violate any law or legal requirement.
We strive to provide you with choices regarding the Personal Information you provide to us; however, we do not control the collection and use of your information collected by third parties described above. These third parties may aggregate the information they collect with information from their other customers for their own purposes. To opt out, please do not provide your Personal Information to us, or after providing your Personal Information to us, please send written notification to us at privacy@twinhealth.com that you no longer wish to receive information and communications from us or otherwise share your Personal Information. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. Because there is no standard for these signals at this time, we currently do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us. Please note that certain features of the Services may not be available when cookies are disabled. To learn more about how to manage cookies, visit http://www.allaboutcookies.org. You may opt-out of certain targeted advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.
We are committed to protecting the privacy of children. By using the Services, you represent that you are at least 18 years of age. The Services are not designed or intended for children and we do not knowingly collect Personal Information about children under 18 years old. No one under the age of 18 may provide information to or through the App. If you are under 18, do not use or provide any information on our Services or on or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn that we have collected or received Personal Information from a child under 18 years without verification of parental consent, we will take reasonable measures to promptly delete such data from our records. If you believe we might have any information about a child under 18, please contact us at privacy@twinhealth.com.
Please be aware that our Services may have links to third-party websites that may collect Personal Information about you. When you click on one of these third-party links, you are entering another website for which we have no responsibility. This Privacy Policy does not cover the information practices or policies of such third-party websites. We encourage you to read the privacy policies of all such websites since their privacy policies may be materially different from our Privacy Policy.
In addition, we may rely on third-party advertisers, ad networks and ad servers to promote our Services. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about our users. This may include information about users’ behavior on this and other apps to serve them interested-based (behavioral) advertising. No information you share within our Services will be shared with third-party advertisers. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.
We reserve the right to modify the terms of this Privacy Policy at any time and in our sole discretion, without notice. When the Privacy Policy is changed, modified, and/or amended, the revised Privacy Policy will be posted on our Services. Modifications will be effective immediately. You should visit this web page periodically to review the Privacy Policy. You accept any such modifications to this Privacy Policy by continued use of our Services after such modifications are made.
If you would like to update your Personal Information or change your preferences or have any questions or concerns about your privacy, you may contact us at privacy@twinhealth.com. Please note that some information may remain in our records after deletion of your account, including any information or records we are legally obligated to retain.
