By electronically clicking on the “I Agree” button adjacent to the Policy on the App or installing, otherwise using or accessing the App or our presence on various social networking platforms in any manner, you agree that you acknowledge receipt of the terms of this Policy as it may be amended from time to time.
Here are a few general principles to keep in mind as you read through this Policy:
- The Services are owned and operated by Robin EB, Inc. and its corporate affiliates (referred to collectively in this Policy as “Robin,” “we,” “us,” “our” and other similar pronouns).
- The App may use GPS and other locator capabilities to identify, display and share your device’s precise location, as further described in Section 1 below.
- As our business evolves, this Policy may change, so check back to this page periodically to make sure you understand how your personal information will be treated.
- The App is intended for users who are located in and travel within the United States. The information you provide to us is being transmitted to us and processed in the United States, or other countries where our affiliates and/or service providers and/or employees and officers reside, and will be protected subject to this Policy and United States laws.
- What information is collected through the Services (as described below, “Information”)?
We obtain information you provide to us directly yourself or through the Primary Member or other Family Members authorized by you (as such terms are referred to in the Robin App). For example, we obtain information when you download and register on the App; enter payment information; search for service providers; add an appointment; conduct a transaction for yourself or others on your healthcare plan using your RobinCard; upload receipts and medical information; provide feedback and/or ratings on a service provider; update your profile information, including profile photos; or submit a comment or question to us using a “contact us” or similar feature on the Services. Registration with us is mandatory in order to be able to use the App. “Personal Information” is information that can be used to identify you as an individual or allow someone to contact you, as well as information attributed with such information.
When you register with us and use the App, you may, for example, provide, for yourself or others on your healthcare plan, Personal Information, such as:
- name ; Social Security Number; date of birth; address; phone numbers; email address; username; passwords (including log-in pattern); employee ID number; healthcare plan ID number; credit card, HSA account and other payment information (including billing addresses); photographs; health and medical information (for example, diagnosis or treatment information); location information; contact information and other details for service providers not already included in our database (including office address and specialties); ratings and/or reviews for service providers; and any additional information of your choosing that you may enter into a free-form field, such as when you add personal notes to an appointment (the “Free Form Field Content”); and
- transaction-related information, such as your downloading and registration of the App; your uses of the App; your appointment details and history (including services provided and related payment history, such as uploaded receipts); and your responses to our correspondence with you.
We and our Service Partners (as defined in Section 4) disclaim any responsibility for the Free-Form Field Content. You understand and agree that we and our Service Partners (a) have the right but not the obligation to monitor Free-Form Field Content and (b) shall not be liable to you or anyone else for any action or inaction related to any Free-Form Field Content.
If you have consented using your device’s user interface, the App will allow you to log-in using the fingerprint and/or face recognition information stored on your device. Robin does not receive any information about your fingerprints and/or face features, which remain on the device and are not transmitted to our servers. If you have consented using your device’s user interface, the App will have access to your device’s calendar, photos and contacts. Robin does not receive any information about your calendar, contacts or photos, other than those photos you use to upload to the App, which remain on the device and are not transmitted to our servers. You may at any time opt-out from further allowing the App to have access to the fingerprint and/or face features information, photos, contacts and calendar information stored on your device by accessing the App’s settings on your device and setting your device not to share such information with the App; however, if you opt-out of such sharing, some or all of the App’s functionality may be limited. For more information, please see Section 7.
The App collects information about the precise geographic location of your device. If your device is equipped with GPS or can connect with wireless access points or hot spots, or if your device is also a phone that communicates with cell towers or satellites, then your device is able to use these features to determine its precise geographic location and transmit it to us.
If you have consented using your device’s user interface, the geographic location of your device will be transmitted to our servers in real time (even if you are not actively using the App or it is minimized on your device). Once you set your device to transmit its location information to us, your device will continue to transmit its location information to us (even when the App is minimized on your device or closed) unless you set your device to no longer do so.
You may at any time opt-out from further allowing us to have access to your device’s location information by accessing the App’s location settings on your device and setting your device not to share its location with us; however, if you opt-out of location sharing, some or all of the App’s functionality may be limited. For more information, please see Section 7.
Automatically Collected Information and Site Usage Information
The App may collect certain information automatically. We may work with analytics companies to help us understand, among others, how the App is being used, by how many users, for how long and how frequently. Using analytics, we may receive counts of the screens and features of the App that are used, device language settings, the types of devices, operating systems, software, carriers, IP addresses and wireless connections our users are using, and their settings. We may also pull aggregated information that does not identify you or any other individuals about doctors, location, diagnoses, treatments, and cost, to better understand how these individual factors may be related. In addition, the App assigns a unique alpha-numerical identifier to your account that is associated with your other Information.
As is the case with many websites, our servers may automatically collect your IP address when you visit the Site, and we may associate that with your domain name or that of your Internet access provider. We may also capture certain “clickstream data” pertaining to your Site usage. Clickstream data includes, for example, information about your computer or device, web browser and operating system and their settings, the referring page that linked you to the Site, the pages, content or ads you see or click on during your visit and when and for how long you do so, items you download, the next website you visit when you leave the Site, and any search terms you have entered on the Site or a referral site. Among other things, this information enables us to generate analytics reports on the usage of the Site. To opt-out of your Site usage being included in our Google analytics reports, you may follow the instructions on the following link https://tools.google.com/dlpage/gaoptout
In addition, we may deploy various tracking technologies on our Site and App to collect additional information about your Site visits. For example:
- Cookies are small data files stored on your computer or device at the request of a website. A cookie assigns a unique numerical identifier to your web browser, and may enable us to recognize you as the same user who was at the Site in the past, and relate your use of the Site to other information about you, such as your Site usage information and Personal Information. Cookies may also be used to enhance your experience on the Site (for example, by storing your username so you can log in easily or keeping you logged into the Site after you have provided your password) or to collect general usage and aggregated statistical information and detect and prevent fraud. Most browsers can be set to detect cookies and give you an opportunity to reject them, but refusing cookies may, in some cases, inhibit or preclude your use of the Site or its features.
- A pixel tag (also known as a “clear GIF” or “web beacon”) is a tiny image – typically just one-pixel – that can be placed on a web page or in our electronic communications to you in order to help us measure the effectiveness of our content by, for example, counting the number of individuals who visit us online or verifying whether you have opened one of our emails or seen one of our web pages.
These tracking technologies, and others, may be deployed by us and/or by our service providers on our behalf. These technologies enable us to assign a unique number or identifier to you, and relate your Site and/or App usage information to other information about you, including your Personal Information and social media credentials and information. These technologies also enable us to recognize you when you access the Site using different web browsers and different computers or devices. By using the Site, you consent to our use of these tracking technologies as described above.
Third Party Information
We may also obtain information about you from other third parties. This may include, for example, information from your healthcare plan about your treatments, plan benefits, and payment details, as well as information from other companies and/or social media platforms, that help us supplement our records with up-to-date and complete information.
- How is your Information used?
We or our service providers may use the information we collect from and about you to perform the following business functions:
- enabling users to use the Services and their features
- processing and fulfilling your transactions with service providers
- administering the Services and your account with us
- Administering your health plan, your out of pocket accumulators, assessing reasonable and/or allowed costs for medical services
- Research of medical treatments, expected cost of care, medical care quality
- remembering information so you will not have to re-enter it during your use or the next time you use the Services
- responding to your requests, questions, and concerns
- internal research and improvement and development of the Services and other software and services
- contacting you or sending you emails or other messages, possibly using automated technology, in response to service-related triggering events and other issues
- protecting our rights and property
- recovering debt and preventing fraud
- customizing the Services to your interests and history with us
- other purposes disclosed when personal information is submitted to us
To perform the above functions, we may match information collected from you through different means or at different times, and use such information along with information obtained from other sources (including third parties) such as demographic information and updated contact information. We or our service providers may also use your information to assess the level of interest in, and use of, the Services, our e-mails and our other messaging campaigns both on an individual basis and in the aggregate.
- Social Networking
We maintain presence on social networking and blogging platforms, such as LinkedIn. This Policy applies to our use of information you submit to us there, but it does not apply to what those third party platforms do with your information. Those platforms have their own privacy policies, and we encourage you to read them.
- Do we share Information with others?
Yes. We may share the information we collect through the Services and the various social networking platforms that we use with others for a variety of reasons. However, we do not disclose nonpublic Personal Information about customers or former customers to affiliates or nonaffiliated third parties except as permitted by law.
If you are the Primary Member, you may elect, subject to applicable laws, whether or not to share certain information, such as treatment information, activities, and payment details, with your spouse, both at registration and by logging in to App and navigating to the “Settings” or similar area of the App.
If you are the spouse of the Primary Member, you may elect, subject to applicable laws, whether or not to share certain information, such as treatment information, activities, and payment details with your Primary Member, both at registration and by logging in to App and navigating to the “Settings” or similar area of the App. If you choose not to share information with your Primary Member, you will be prompted to enter a credit card or other form of payment different from the one(s) used by the Primary Member. If you choose not to enter a different credit card or other form of payment, your Primary Memberwill continue, subject to applicable laws, to pay for your treatments, and may see the date, time, provider and amount of the charges made on your behalf, but no other details.
If you are neither the Primary Membernor their spouse, and you are 18-years-old or older, or an emancipated minor, you may elect, subject to applicable laws, whether or not to share certain information, such as treatment information, activities, and payment details, with either your Primary Member, their spouse, both, or neither. You may make this election both at registration and by logging in to App and navigating to the “Settings” or similar area of the App. If you choose not to share information with anyone who can provide payment information on your behalf, you will be prompted to enter a credit card or other form of payment different from the one(s) used by the Primary Member and/or their spouse. If you choose not to enter a different credit card or other form of payment, your Primary Member or their spouse will continue, subject to applicable laws, to pay for your treatments and see the date, time, provider and amount of the charges made on your behalf, but no other details.
In addition to the above examples of information sharing, and other kinds of information sharing you might expect, we may share your information:
- With different companies, individuals and government entities to provide you with the Services, which include, for example and without limitation: app stores, telecommunications providers, wireless service providers, call center service providers, and any other person or entity who provides any service, equipment, content, feature or facilities in connection with the App and/or the Services (collectively, “Service Partners”). We share your Information with Service Partners, or they collect it directly from you or your device.
- To cooperate with requests from law enforcement.
- We may disclose Information regarding our users and user behavior as a measure of interest in, and use of, the Services to third parties, including, for example, aggregate data, such as overall patterns or demographic reports.
- When we believe in good faith that disclosure is necessary to protect our rights or property, protect your safety or the safety of others, investigate fraud or respond to a government, judicial or other legal request, or to comply with the law.
- In connection with a corporate change or dissolution, including for example a merger, acquisition, reorganization, consolidation, bankruptcy, liquidation, sale of assets or wind down of business.
- Do Not Track Disclosures
Some web browsers may transmit “do-not-track” (“DNT”) signals to the online services with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not change our tracking practices (which are explained in more detail under “Automatically Collected Information and Site Usage Information” above) in response to DNT settings in your web browser. Our third party partners, such as web analytics companies, collect information about your online activities over time and across the Services and other online properties. We utilize Google Analytics for our web analytics and you can opt out of your Site usage data being included in our Google Analytics reports by visiting this link. https://tools.google.com/dlpage/gaoptout
- Communications with you
We and our Service Partners may communicate with you by calling or messaging you through your device or to the phone number, email address or other contact information for you that we have on file, possibly using automated technology or prerecorded messages. You hereby agree to this. However, we may require additional consent from you for us to transmist to you, by unencrypted means (such as by email), certain sensitive Personal Information, for example regarding your treatments or payment for health care. We and our Service Partners may also use your email address, your phone number or device to send you notifications and updates relevant to the Services, as well, to the extent permitted by applicable law, communications about promotions related to the Services. Each communication you receive from us for offers will provide a link to unsubscribe to all future communications about offers from Robin. Please understand that it may take us a few days to process any opt-out request and that even if you opt-out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, Services, activities, transactions and communications with us.
If you have consented using your device’s user interface, we may send you notifications and updates relevant to the Services, the RobinCard and the Robin App directly on your device using your device’s notification system. You may at any time opt-out from further allowing us to notify you using your device’s notification system; however, if you opt-out of notifications, some, or all, of the App’s functionality may be limited. For more information, please see Section 7.
- Opt In and Opt Out
There are four opt-out options for users of the Services:
- Opt-out of all Information collection by uninstalling the App. You can stop all collection of Information by the App easily by uninstalling the App. You may use the standard uninstall processes available as part of your mobile device or via the mobile application marketplace or network.
- You may opt-out from further allowing us to have access to your device’s location data by accessing the App’s location setting on your device and setting your device not to share its location with us. However, if you opt-out from location sharing, the App’s functionality may be limited in part or in full.
- You may opt-out from further allowing the App to have access to, among others, the fingerprint information, face recognition information, contacts, photos and calendar information on your device by setting your device not to share such information with the App. However, if you opt-out from such sharing, the App’s functionality may be limited in part or in full.
- You may opt out of any promotional communications by clicking on the opt-out link within the communication you receive. Please understand that if you opt out of receiving promotional correspondence from us, we may still contact you in connection with your relationship, Services, activities, transactions, and communications with us.
- Your Access Rights
You may review certain Personal Information that is stored in your user account on the App by logging in to App and navigating to the “Profile” or similar area of the App. You may update or modify some of this Personal Information directly in the App, but you may update or modify other Personal Infornation that is also stored in your user account on the App by calling us. We may ask you to verify your identity and to provide other details before we are able to provide you with any information, correct any inaccuracies, or delete any information. Your right to delete your information is subject to our records retention policies. Please note that we may decline your request to correct your personal information, as permitted by applicable laws.
- Data Retention
We may retain information gathered through your use of the Services and the various social networking platforms that we use for so long as is commercially reasonable for a legitimate business purpose.
We have security practices and procedures in place to help protect the confidentiality of your sensitive Personal Information in accordance with this policy, and limit access to such Personal Information to employees on a need-to-know basis, such as employees who need to access such Information in order to provide you with proper customer service and improve our Services.
However, while we endeavor to protect the security and integrity of sensitive Personal Information collected through the Services, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.
Because we provide the App through wireless networks, your communications may be intercepted by others. We and our Service Partners cannot and do not guarantee (and we and our Service Partners expressly disclaim) the security and privacy of wireless transmissions, and we and them will not be liable for any lack of security relating to the use of the App by you. You agree that you will not hold us or any of our Service Partners liable for any damages resulting from any loss of privacy or security occurring in connection with any communications over such networks.
If you correspond with us by e-mail, text message, or using Web forms like the “contact us” feature on the Services, you should be aware that your transmission might not be secure. A third party could view the information you send in transit by such means. We will have no liability for disclosure of your information due to errors or unauthorized acts of third parties during or after transmission.
You are responsible for maintaining the strict confidentiality of your account passwords, and you shall be responsible for any activity that occurs using your account credentials, whether or not you authorized such activity. Please notify us of any unauthorized use of your password or account or any other breach of security.
If we believe that the security of your Personal Information in our care may have been compromised, we may seek to notify you of that development. If a notification is appropriate, we will endeavor to notify you as promptly as possible under the circumstances. If we have your e-mail address, we may notify you by e-mail to the most recent e-mail address listed in your account profile, although we may also send notices by other means, such as by United States Postal Service first-class mail. Please keep your e-mail address and mailing address in your account up to date by calling us to make any changes. If you receive a notice from us by e-mail, you can print it to retain a copy of it. To receive these notices by e-mail, you must check your e-mail account using your computer or mobile device and email application software. You consent to our use, at our option, of e-mail as a means of such notification. To elect alternative approaches to be contacted in this situation, please call us. You can make this election any time, and it will apply to notifications we make after a reasonable time thereafter for us to process your request. You may also use these means to request a print copy, at no charge, of an electronic notice we have sent to you regarding a compromise of your Personal Information.
- “Linked-To” Web Sites
Subject to applicable law, the Services may contain links, banners, or widgets that lead to other web sites. We are not responsible for these other sites, and so their posted privacy policies (not this Policy) will govern the collection and use of your information on them. We encourage you to read the privacy statements of each web site visited after leaving the Services to learn about how your information is treated by others.
- HIPAA Privacy Protections
In furnishing the Services, we may be subject to additional requirements under the Health Information Protection and Portability Act of 1996 and associated regulations at 45 C.F.R. Parts 160-164 (“HIPAA”). Specifically, we may be furnishing the Services in our capacity as a “Business Associate” of healthcare plans that are HIPAA “Covered Entities.” HIPAA regulates certain Personal Information, known as “Protected Health Information,” which generally relates to your treatment or payment for treatment, provided that we have obtained access to that information in our capacity as a HIPAA business associate of a healthcare plan. HIPAA not only regulates how this Protected Health Information may be used and disclosed, how you can get access to this information, and how you will be notified in the event of a breach of unsecured protected health information, but also requires, among other things, that the healthcare plans provide you with a HIPAA notice of privacy practices that describes these uses, disclosures and access rights and duties (a “HIPAA Notice of Privacy Practices”), and follow the terms of the HIPAA Notice of Privacy Practices.
If we are a Business Associate of a HIPAA-regulated healthcare plan, HIPAA requires that we have a written contract with the healthcare plan that requires us to also protect the privacy of your Protected Health Information in compliance with HIPAA standards, including as described in the healthcare plan’s HIPAA Notice of Privacy Practices. This Policy does not apply to what your healthcare plan does with your Protected Health Information or other Personal Information, and each healthcare plan maintains its own HIPAA policies, including its HIPAA Notice of Privacy Practices, may vary in certain respects. We encourage you to familiarize yourself with your healthcare plan’s HIPAA policies, including by reading your healthcare plan’s HIPAA Notice of Privacy Practices.
Among the HIPAA protections applicable to your protected health information are your rights to: get a copy of your health and claims records, correct your health and claims records if you think they are incorrect or incomplete, request confidential communication (for example, in a specific way or to send mail to a different address; and get a list of certain persons with whom your information has been shared.
Generally, certain steps, outlined in your healthcare plan’s HIPAA Notice of Privacy Practices, will apply to your exercise of those rights. In addition, HIPAA limits the purposes for which your Protected Health Information may be used or disclosed. For example, HIPAA will generally permit your Protected Health Information to be used and disclosed in connection with treatments received from a health care provider, a healthcare plan’s payment for such treatment, for certain general administrative and business functions, and as required by law. Subject to certain conditions, additional permitted purposes would include, for example, certain public health and public safety purposes, and in connection with certain legal proceedings or research purposes. In contrast, a use or disclosure of your Protected Health Information for paid marketing activities, or the sale of your protected health information, will require your prior written authorization.
For more information about your rights under HIPAA see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html.
Federal and state laws may provide additional privacy protections that exceed the protections available under HIPAA, for certain Protected Health Information that is highly sensitive, such as genetic information, HIV-related information, alcohol and substance abuse treatment information, and mental health information. If you have questions about this, or any other aspect of how HIPAA may apply to your Personal Information, please contact the Robin Privacy Officer at:
Robin Research and Development Ltd.
8 A Hatzoran st. Netanya Israel
We may change this Policy from time to time. When we do, we will let you know by posting the changed Policy on this page or in the App with a new “Effective Date.” In some cases (for example, if we significantly expand our use or sharing of your Personal Information), we may also tell you about changes by additional means, such as by sending an e-mail to the e-mail address we have on file for you or creating a notification in the App. In some cases, we may request your consent to the changes.
- Contact Us
If you have any questions or comments regarding our privacy practices, you may contact us at:
Robin Research and Development Ltd.
8 A Hatzoran st. Netanya Israel
Effective Date: June October 1st, 2018.