Me2Health, LLC Privacy Policy
rev 06.10.2017

Me2Health, LLC d/b/a Hugo is an easy-to-use, cloud-based solution that enables the secure acquisition, harmonization, and utilization of health-related data on behalf of its users, from electronic health records, surveys, wearables, sensors and medical devices.

 

If you use our Services, you consent to this Privacy Policy.

 

 

 

If you use our Services after an update to this Privacy Policy, you consent to the changed policy.

 

 

 

 

 

You provide data to create an account and to connect to your various health data sources.

 

You create a Hugo profile.

 

You give other data to us, such as survey responses and data that is imported from patient portals.

 

We log your visits and use of our Services

 

 

To provide services to you.

 

 

 

 

 

 

 

 

To improve services or to develop new products.

 

 

 

 

 

For research purposes to promote better health and health care.

 

 

 

 

To help you and fix problems that occur.

 

 

We use data to generate aggregate insights.

 

 

We use data for security, fraud prevention and investigations.

 

 

 

We contact you to notify you of updates, service-related issues, promotions and reminders.

 

 

 

 

We may share/disclose your data to support our business activities.

 

 

We may share your data when our business is sold to others, but it must continue to be used in accordance with this Privacy Policy.

 

 

 

We may need to share your data when we believe it’s required by law or to protect your and our rights and security.

 

 

 

 

 

 

 

 

 

 

When a user specifically directs their data to be shared.

 

 

 

We continue to collect and retain your personal health record data for as long as your account is open.

 

 

 

 

 

Some of your data may remain with Hugo or with partners who you have shared with even after you close your account.

 

 

 

 

 

 

 

We take extensive precautions to secure and protect your information from unauthorized access, disclosure, or use.

 

 

 

 

 

 

Introduction

You are entering into a User Agreement with Me2Health, LLC, who will be responsible for your personal data provided to, or collected by or for, our Services.  

Services

This privacy policy applies to all services offered by Me2Health for Hugo. This includes the collection and aggregation of health data on behalf of our users. 

Consent

If you use our Services, you consent to the collection, use and sharing of your personal data under this Privacy Policy and agree to the User Agreement

Change

We may modify this Privacy Policy, and if we make material changes to it, we will provide notice through our Services, or by other means, to provide you the opportunity to review the changes before they become effective. If you object to any changes, you may close your account. Your continued use of our Services after we publish or send a notice about our changes to this Privacy Policy means that you are consenting to the updated Privacy Policy.

1. Information we collect

1.1 Information You Provide To Us 

Registration: To create an account you provide data including your name, email address and a password. To connect your health portals or wearable/wifi products you will provide your username and password.

Personal Profile: You may add additional information such as your date of birth, gender and phone number. Your profile is private and cannot be viewed by anyone publicly.

Personal Health Record Data (PHRD): Any information that is imported or personally reported via Hugo, for example health records imported from patient portals, device data and responses to surveys or other personally reported data.

1.2 Service Use

We log usage data when you visit or otherwise use our Service. We use log-ins, cookies, device information and internet protocol (“IP”) addresses to identify you and log your use.

2. how we use your data

2.1 To provide services to you in order to improve user experience and the overall quality of our services:

  • Providing you appropriate search results and personalized content
  • Verifying your identity
  • Recognizing you when you return to our Services
  • Providing you notices about your account
  • Notifying you about updates or changes to our Services or any services we offer or provide through it
  • Informing you of new features or opportunities in Hugo that let you make use of your data - unless you opt out
  • Informing you of opportunities to participate in clinical research - unless you opt out.

2.2 To improve our services to you or to develop new products and services we may use your information as follows:

  • to track your usage of our Services;
  • administer a survey;
  • perform quality control and quality improvement activities;
  • conduct data analysis about our audience size and usage trends;
  • monitor the success of our marketing activities

2.3 Research

Hugo's mission is to connect people to their health data. These data can help promote better health and health care.  We use the data available for these research purposes. In some cases, we work with trusted third parties to perform this research, under controls that are designed to protect your privacy. We publish or allow others to publish reports, presented as aggregated data only.

2.4 Customer Support

We use the data (which can include your communications) needed to investigate, respond to and resolve complaints and Service issues (e.g., bugs)

2.5 Aggregate Insights

We use your information to produce aggregate insights that do not identify you. For example we may use your data to generate statistics about our users, demographics or health care utilization.

2.6 Security and investigations

We use your data (including your communications) if we think it’s necessary for security purposes or to investigate possible fraud or other violations of our User Agreement or this Privacy Policy and/or attempts to harm our Members or Visitors.

2.7 Communications

We will contact you through email, text messages and push notifications. We will send you messages about the availability of our Services, security, or other service-related issues. We also send messages about how to use the Services, network updates, reminders, and promotional messages from us. Please be aware that you cannot opt out of receiving service messages from us, including security and legal notices.

3. how we share your data

3.1 To support our business activities

We may share your data with contractors, service providers and other third party vendors in order to support business activities. Important Note: Access to PHR data on Hugo is granted only to individuals who are bound by contractual obligations and HIPAA guidelines to keep personal information confidential and to use it only for the purposes for which we disclose it to them. 

3.2 Change in control or sale

To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Me2Health’s assets, in which personal information held by Hugo about our users is among the assets transferred. This Privacy Policy would continue to apply to information collected while it was in place.

3.3 Legal Disclosures

It is possible that we will need to disclose information about you when required by law, subpoena, or other legal process or if we have a good faith belief that disclosure is reasonably necessary to (1) investigate, prevent, or take action regarding suspected or actual illegal activities or to assist government enforcement agencies; (2) enforce our agreements with you, (3) investigate and defend ourselves against any third-party claims or allegations, (4) protect the security or integrity of our Service (such as by sharing with companies facing similar threats); or (5) exercise or protect the rights and safety of Me2Health LLC our Users, personnel, or others. We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand. 

3.4 When directed by the user

Users are encouraged to participate in clinical research, trials and other potential opportunities if they are interested and they meet certain enrollment criteria. Once a volunteer opts to enroll in a study, they will opt to share their health information. Hugo will facilitate this transaction. 

4. other important information

4.1 Data Retention

We retain all data you provide while your account is in existence or as needed to provide you Services. Even if you only use our Services one time, and connect to your data sources, the information will continue to populate your account until you disconnect or cancel your account. If you have shared your data for research or other purposes. the data will continue to be shared until the expiration date or you unenroll. 

4.2 Account Closure

If you choose to close your Hugo account, your personal data will generally stop flowing within 24 hours. We generally delete closed account information within 30 days of account closure, except as noted below.

We retain your personal data even after you have closed your account if reasonably necessary to comply with our legal obligations (including law enforcement requests), meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse or enforce our User Agreement. We may retain de-personalized information after your account has been closed.

Information you have shared with others (e.g., through research studies) cannot deleted. 

4.3 Security

We treat the privacy and security of your PHR Data with the utmost importance and respect. As such, we take extensive precautions to secure and protect your information from unauthorized access, disclosure, or use. We implement security safeguards designed to protect your data, such as HTTPS. We regularly monitor our systems for possible vulnerabilities and attacks. However, we cannot warrant the security of any information that you send us. There is no guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. Please visit our Security Policy for additional information.