Privacy Policy

In order to ensure transparency and give you more control over your personal information, this privacy policy (“Privacy Policy”) governs how we, TailorMed Medical Inc. (“TailorMed”, “we”, “our” or “us”) use, collect and store personal information we collect or receive from or about you (“you”) , through our website https://tailormed.co/ (the “Website”), the TailorMed Platform and other services (collectively, the “Services”).

We greatly respect your privacy, which is why we make every effort to provide a platform that would live up to the highest of user privacy standards. Please read this Privacy Policy carefully, so you can fully understand our practices in relation to personal data. “Personal Data” or “Personal Information” means any information that can be used, alone or together with other data, to uniquely identify any living human being.

Important note: Nothing in this Privacy Policy is intended to limit in any way your statutory right, including your rights to a remedy or means of enforcement.

Table of contents:

1. What information we collect, why we collect it, and legal bases for processing
2. How we protect and retain your Personal Information
3. To whom we disclose your Personal Information
4. International transfer
5. Your privacy rights
6. Use by children
7. Interaction with third-party products
8. Analytic tools
9. Additional disclosures for U.S. residents
10. Contact us

TailorMed’s mission is to harness technology to improve the financial performance of healthcare organizations and reduce the financial hardship for patients. This mission is achieved through a comprehensive software solution that helps organizations identify financially at-risk patients, maximize workflow efficiency, and capture more funding, at scale. Using data and advanced analytics, TailorMed Platform streamlines all steps of the process, from benefit investigation and out-of-pocket estimation to enrollment and management of approved programs. For the avoidance of doubt, for the purposes of this Privacy Policy, “Customer(s)” are entities, which executed agreements with TailorMed, including, hospitals and other healthcare-related entities.

If your Personal Data is provided to us as a result of our relationships with Customer (“Individual(s)”), please note that the Customer is the responsible party for obtaining the required consents and complying with any applicable laws and regulations with respect to the collection, processing, transfer and use of your Personal Data. Accordingly, we encourage you to read the privacy policy of the Customer.

This Privacy Policy can be updated from time to time and, therefore, we ask you to check back periodically for the latest version of this Privacy Policy. If we implement significant changes to the use of your personal data in a manner different from that stated at the time of collection, we will notify you by posting a notice on our Website or by other means.

1. WHAT INFORMATION WE COLLECT, WHY WE COLLECT IT, AND LEGAL BASES FOR PROCESSING

(i) We Process the Following Personal Information:

a. Information you provide directly to us. We collect Personal Information you provide directly to us, including Personal Information when you browse and make use of our Website, including, full name, business name & address, email address, phone number, employees information (including, without limitation, name, email address, phone number). When you communicate with TailorMed (via email, Website or telephone), we collect the contents of those communications, as well as feedback, and/or answers to surveys or questionnaires that you may submit. Additionally, if you choose to register an account with our Services, we collect your full name and phone number.

b. Sensitive personal health data. During your use of the Services you may choose to provide us with your Personal Health Data such as information pertaining to your particular medications, and insurance, medical conditions or other related information, so we can provide you with our Services and assist you in assessing your eligibility for locating a suitable assistance programs.

c. Information provided in the context of TailorMed Services. TailorMed may receive Personal Information in the context of providing its services to the Customers (including, without limitation, patients’ data, doctor details, patients’ health needs, insurance information), in such cases, please note that the Customer is the responsible party for of Personal Data. Please make sure that you contact the Customer for any inquiry.

d. Information from other sources. TailorMed may also obtain information (that in general will not contain Personal Data) about you from other sources, including private and publicly – or commercially – available information, and through third-party partners and service providers.

e. Automatic Data Collection. We may automatically collect certain information through your use of TailorMed Services, such as your Internet protocol (IP) address, cookie identifiers and other device identifiers that are automatically assigned to your device, browser type and language, geo-location information, hardware type, operating system, internet service provider and other information about actions taken through the use of TailorMed Services.

(ii) We Process Personal Information for the following purposes:

a. To provide you with TailorMed Services. TailorMed will use your Personal Data to provide TailorMed Services, including: (i) process your request; (ii) share your Personal Information with some of our partners and and/or third party insurance companies (to the extent provided under this Policy); (iii) communicate with you about the options that you may have for the requested insurance; (iv) fulfill any orders for services or products made by you; (v) track requests sent by you; (vi) provide you with information about our products or services or the products and services we offer jointly with or on behalf of other organizations; and (vii) to personalize your experience with TailorMed Services.

b. For administrative purposes. TailorMed may use your Personal Data (i) to respond to your questions, comments, and other requests for Customer support, or information, including information about potential or future services; (ii) to provide you with TailorMed Services; (iii) for internal quality control purposes; (iv) to establish a business relationship; (v) for testing, research, analysis, and product development, including to develop and improve our Website, and in connection with providing and maintaining our products, and services; and (vi) to generally administer TailorMed Services.

c. To market TailorMed Services. TailorMed may use Personal Information to market TailorMed Services. Such use includes (i) notifying you about offers and services that may be of interest to you that we offer and/or that we offer jointly with or on behalf of other organizations; (ii) tailoring content, advertisements, and offers for you, including, targeting and re-targeting practices; (iii) conducting market research; (iv) developing and marketing new products and services, and to measure interest in TailorMed Services; (v) other purposes disclosed at the time you provide Personal Information; and (vi) as you otherwise consent.

d. Security purposes. Some of the aforementioned Personal Data will be used for detecting, taking steps to prevent, and prosecution of fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.

e. De-identified and aggregated information use. In certain cases, we may or will anonymize or de-identify your Personal Data and further use it for internal and external purposes, including, without limitation, to improve the Services and for research purposes. “Anonymous Information” means information which does not enable identification of an individual user, such as aggregated information about the use of our services. We may use Anonymous Information and/or disclose it to third parties without restrictions (for example, in order to improve our services and enhance your experience with them). For the avoidance of doubt, use of Personal Data as a result of our relationships with Customer, including, without limitation de-identifying your Personal Data, is subject to and limited by the underlying Customer agreements.

f. Cookies and similar technologies. We, as well as third parties that provide content, advertising or other functionality on the TailorMed Website, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the TailorMed Website.

g. Integrity, security and compliance with applicable laws. Finally, please note that some of the aforementioned Personal Data will be used for detecting, taking steps to prevent, and prosecuting fraud or other illegal activity, to identify and repair errors, to conduct audits, and for security purposes. Personal Data may also be used to comply with applicable laws, with investigations performed by the relevant authorities, law enforcement purposes, and/or to exercise or defend legal claims.

(iii) Legal bases for processing

Where applicable, we rely on one or more of the following lawful bases for processing Personal Information:

a. You gave us your consent to the processing of your personal data (for one or more specific purposes) including through our website(s) cookie notice and consent management mechanism in order to implement Technologies.

b. Processing is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into a contract.

c. We process Personal Data about individuals in accordance with our legitimate interests, such as, as applicable, to improve and enhance our Services, to understand how our Services are used, to optimize our marketing, advertising, customer services and support operations, to maintain the security of our Services, to enforce any applicable terms and conditions of service, and to protect or defend the Services and our rights.

d. Processing is necessary for compliance with a legal obligation to which we are subject.

2. HOW WE PROTECT AND RETAIN YOUR PERSONAL INFORMATION

2.1 Security. We have implemented appropriate technical, organizational and security measures designed to protect your Personal Information. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers. As the security of information depends in part on the security of the computer, device or network you use to communicate with us and the security you use to protect your user IDs and passwords, please make sure to take appropriate measures to protect this information.

TailorMed maintains a Security Management Program (SMP) which complies with the Health Insurance Portability and Accountability Act of 1996, the Health Information Technology for Economic and Clinical Health Act (found in Title XIII of the American Recovery and Reinvestment Act of 2009), and their associated regulations.

2.2 Retention of your Personal Information. Your Personal Data will be stored until we delete the record and we proactively delete it or you send a valid deletion request, please note that in some circumstances we may store your Personal Data for longer periods of time, for example (i) where we are required to do so in accordance with legal, regulatory, tax or accounting requirements, or (ii) for us to have an accurate record of your dealings with us in the event of any complaints or challenges, or (iii) if we reasonably believe there is a prospect of litigation relating to your Personal Information or dealings.

3. TO WHOM WE DISCLOSE YOUR PERSONAL INFORMATION

We disclose your Personal Information as described below:

3.1 The Personal Information TailorMed gathers is shared within our affiliated companies and partners.

3.2 We may use third-party service providers to process your Personal Data for the purposes outlined above, including, without limitation, cloud service providers for hosting purposes; word press service providers in order to help us manage our Website; email providers, marketing, CRM and other similar tool providers; and analytic companies, in order to help us understand and analyze data we collect (which may include Personal Data) in accordance with this policy.

3.3 To the extent necessary, with regulators, courts, banks or competent authorities, to comply with applicable laws, regulations and rules (including, without limitation, federal, state or local laws), and requests of law enforcement, regulatory and other governmental agencies or if required to do so by court order, as well as for internal compliance procedures.

3.4 If, in the future, we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party, we will disclose your personal data to such third party (whether actual or potential) in connection with the foregoing events. In the event that we are acquired by, or merged with, a third-party entity, or in the event of bankruptcy or a comparable event, we reserve the right to transfer, disclose or assign your personal data in connection with the foregoing events.

3.5 We share your data with our external auditors, advisors and professional service providers (e.g. lawyers, accountants, insurers etc.) for ensuring our compliance with regulatory requirements and industry standards, auditing, managing disputes etc.

4. INTERNATIONAL TRANSFER

We are a US and Israeli based company, but we operate globally. Information that we collect, disclose or share, including (but not limited to) your Personal Data, shall be stored exclusively in the US, but could be otherwise processed in the US and Israel, for the purposes detailed in this Policy and pursuant to any signed agreement by us. Where required by applicable laws, we will transfer your Personal Data only after ensuring an adequate level of data protection, as required under these laws.

5. YOUR PRIVACY RIGHTS

Depending on the jurisdiction in which you reside, you may have certain rights under relevant applicable laws regarding the collection and processing of your Personal Data. To the extent these rights apply and concern you, you can exercise your rights by contacting us at [email protected].

5.1. Rights to access your Personal Data

You have the right to receive confirmation as to whether or not Personal Data concerning you is being processed, and access your stored Personal Data, together with supplementary information.

5.2. Right of data portability

You have the right to request us to move, copy and transfer your Personal Data easily from one IT environment to another, in a safe and secure way, without affecting its usability.

5.3 Right of rectification

You have the right to request rectification of your Personal Data in our control in the event that you believe the Personal Data held by us is inaccurate, incomplete or outdated.

5.4 Right of deletion/erasure

You have the right to request that we erase or delete Personal Data held about you at any time.

5.5 Right to restriction or objection to processing

You have the right to request that we restrict or cease to conduct certain Personal Data processes at any time.

5.6 Right to withdraw your consent

To the extent we process Personal Data on the basis of your consent, you have the right to withdraw your given consent at any time.

5.7 Right to limit use and disclosure of your sensitive Personal Data (applicable only in the US)

You have the right to request to limit the collection of your sensitive Personal Data, to that use which is necessary to perform our Services.

5.8 Right not to be subject to automated decision making

You have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects or similarly significantly effects to you.

5.9 Right to opt-out of the sale or share of Personal Data (applicable only in the US)

In the event that we sell or share your Personal Data for behavioral advertising purposes, you have the right to submit a request to opt-out of the sale or share of your Personal Data.

5.10 Right to non-discrimination (applicable only in the US)

You have the right to be free from any discrimination for exercising your rights, such as offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request.

5.11 Right to lodge a complaint and appeal our decisions

All requests, complaints or queries may be addressed to us to the following email address: [email protected]. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. We take our obligations seriously and we ask that any concerns are first brought to our attention, so that we can try to resolve them.

To the extent you feel unsatisfied with our response to your request to exercise your rights, you may choose to send us a request to appeal our decision. If you are unsatisfied with our response, you can lodge a complaint with the applicable data protection supervisory authority.

Subject to legal and other permissible considerations, we will make every reasonable effort to honor your request promptly in accordance with applicable law or inform you if we require further information in order to fulfill your request. When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes, before processing and/or honoring your request. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. In the event that your request adversely affect the rights and freedoms of others (for example, if it impacts the duty of confidentiality we owe to others) or if we are legally entitled to deal with your request in a different way than initial requested, we will address your request to the maximum extent possible, all in accordance with applicable law.

Authorized Agent

In some jurisdictions, you can use an authorized agent to make a request to exercise your right under applicable laws on your behalf if:

• The authorized agent is a natural person or a business entity; and
• You sign a written declaration that you authorize the authorized agent to act on your behalf. If you use an authorized agent to submit a request to exercise your right, please provide us with a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

The request must:

• Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Data or an authorized agent. We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you; and
• Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
• We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Please note that making a verifiable consumer request does not require you to create an account with us.

6. USE BY CHILDREN

We do not offer our products or services for use by children and, therefore, we do not knowingly collect Personal Information from, and/or about children under the age of 18. If you are under the age of 18, do not provide any Personal Information to us without involvement of a parent or a guardian. In the event that we become aware that you provide Personal Information in violation of applicable privacy laws, we reserve the right to delete it. If you believe that we might have any such information, please contact us at [email protected].

7. INTERACTION WITH THIRD-PARTY PRODUCTS

We enable you to interact with third-party websites, mobile software applications and products or services that are not owned or controlled by us (each, a “Third-Party Service”). We are not responsible for the privacy practices or the content of such Third-Party Services. Please be aware that Third-Party Services can collect Personal Information from you. Accordingly, we encourage you to read the terms and conditions and privacy policies of each Third-Party Service.

8. ANALYTIC TOOLS

We use the following analytic tools, including, without limitation:

Google Analytics. The Website uses a tool called “Google Analytics” to collect information about use of the Website. Google Analytics collects information such as how often users visit this Website and what pages they visit when they do so. We use the information we get from Google Analytics to maintain and improve the Website and our products. We do not combine the information collected through the use of Google Analytics with Personal Information we collect. Google’s ability to use and share information collected by Google Analytics about your visits to this Website is restricted by the Google Analytics Terms of Service, available at https://marketingplatform.google.com/about/analytics/terms/us/, and the Google Privacy Policy, available at https://policies.google.com/privacy. You may learn more about how Google collects and processes data specifically in connection with Google Analytics at https://policies.google.com/technologies/partner-sites. You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.

We reserve the right to remove or add new analytic tools.

For the avoidance of doubt, we do not disclose PHI (Protected Health Information, as this term is defined under HIPAA) to Google Analytics. 

9. ADDITIONAL DISCLOSURES FOR U.S. RESIDENTS

In addition to rights specified in section 5 above, this Section supplements the Privacy Policy and addresses specific disclosures requirements under US Privacy Laws.

Collection, disclosure and sharing of Personal Information

We do not “Sell” or “Share” Personal Information about you (in the meaning assigned to these terms under US Privacy Laws).

In the preceding 12 months, we have collected, disclosed or shared the following categories of Personal Information:

Sources of Personal Information

In the 12 preceding months, we have collected Personal Data from the following categories of sources:

• User directly (either actively or through monitoring of use of the Services);
• We may process business contact information about our partners which we receive from third parties as our marketing partners, internet service providers and data analytics providers.

Purposes for collection, use & sharing

In addition to the practices detailed in Sections 1 and 3 of the Privacy Policy, we also use and disclose the Personal Information we collect for the following commercial and business purposes:

• Auditing related to our interactions with you;
• Legal compliance;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;
• Debugging;
• Performing services (for us or our partners);
• Internal research for technological improvement;
• Internal operations;
• Activities to maintain and improve our services; and
• Other one-time or short-term uses.

California Privacy Rights. California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected]. Please note that we are only required to respond to one request per customer each year.

Our California Do Not Track Notice (Shine the Light). Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

10. CONTACT US

If you have any questions, concerns or complaints regarding our compliance with this notice and the data protection laws, or if you wish to exercise your rights, we encourage you to first contact us at [email protected].