Effective January 24th 2022
NextGate is the global leader in identity modernization and data transformation in healthcare and is revolutionizing the consumer care journey by resolving isolated, unstructured health and lifestyle data and establishing a trusted, single identity across the continuum.
Our Offerings not only include solutions to the healthcare industry, but also include our OneDID™ consumer application.
Please take a moment to familiarize yourself with our privacy practices below, and [contact us] if you have any questions. Click on the links below to jump to specific sections:
- What this Policy Covers
- Personal Information We Collect From You
- Information We Receive from Others About You
- Cookies and Similar Technologies
- How We Use Your Personal Information
- How We Share Your Personal Information
- Transfers of Personal Information Between Countries
- How Long We Keep Your Information
- Your Privacy Rights and Choices
- Contact Us
1. What this Policy Covers
Throughout this policy, we use the term “Personal Information” to describe information that can be associated with a specific person and can be used to identify that person. We do not consider Personal Information to include information that has been aggregated and/or anonymized so that it does not identify a specific user.
We also process Personal Information on behalf of our corporate clients who use our Offerings, including our corporate clients who you connect with when you use our Offerings. While there is a contract in place between us and our corporate client which sets out our data protection obligations, it is our corporate client who determines the use of that Personal Information. Please consult the corporate clients’ privacy policies and contact them if your Personal Information is being used by them and you wish to delete, amend, remove consent for processing, or take other action with respect to that information.
3. Personal Information We Collect From You
When you connect to our Offerings, contact us, or otherwise interact with NextGate, we collect a variety of information, including:
- Account Information. Text-enabled cell number, mobile device ID, and other similar information.
- Identifiers. Your name, email address, data of birth, and other demographic information.
- Contact Information. Your name, email address, title, company affiliation, phone number or other contact information.
- Log Information. We use log data, such as your Internet Protocol (“IP”) address, access times, browser type and language, Internet Service Provider (“ISP”), the web pages that you visit, the content you use and the URL of the web page you visited before navigating to the Offerings.
- Device Information. Data from which your device could be identified, and information about you from your mobile device or computer (e.g., your device type, machine or mobile device identification number, geolocation information, time zone, language setting, browser type, and IP address).
- Fraud Prevention Information. Data used to help identify and prevent fraud.
- Biometric Information. Biometric Information you provide, such as your selfie, when using our OneDID app, which you may store as part of your credential and share with your service providers.
- Usage Information. Data about your activity on and use of our Offerings, such as information about the applications and features you use, the sizes of the files or folders you upload, download, share or access while using the Offerings, performance and other diagnostic data, and generic information regarding the content you access and any actions taken in connection with the access and use of the Offerings.
- Medical Information. Some Offerings include the collection of medical information, patient medical records, medical facility information, medical provider information, and other information that may be related to or necessary to healthcare that we collect to support the Offerings.
- Other Information You Provide to Us. Details such as the content of your communications with NextGate, including when you complete any “contact us” forms or send us emails (e.g., professional or employment related information).
You are not required to provide your Personal Information. However, if you choose not to do so, in many cases we will not be able to provide you with our Offerings or respond to your requests.
4. Information We Receive From Others About You
We receive Personal Information about you from other sources, which we sometimes combine with Personal Information we collect either automatically or directly from you, to provide our Offerings and assist us in security and fraud prevention.
- Individuals. We may collect data about you from other individuals — for example, your professional colleagues at other organizations.
- At Your Direction. You may direct other individuals or third parties to share data with NextGate.
- Partners. We may receive Personal Information about you when you use the service of our corporate clients, marketing, and vendor partners. We may also validate the information you provide — for example, when creating a oneDID™ account, with a third party for security, for fraud-prevention purposes, or to validate your phone number or email address.
- Personal Information or other data collected online may also be combined with information you provide to us through other sources (e.g., in conjunction with events such as trade shows, training seminars, and conferences). Where permitted by applicable law, other information gathered from publicly available information such as from government records, social media platforms and other published sources may be used or added to the data you provide.
CATEGORY OF USE
PURPOSE OF THE USE
To help us remember your settings and preferences, like your preferred language or the country you are in, so that we can provide you with a more personalized experience.
Authentication and Security
To log you into the Services; enable us to show you your account data; and help us keep your data and the Services safe and secure.
Service Features and Performance
To provide you with functionality and optimize the performance of the Services.
Analytics and Research
To help us understand how you are using the Services so that we can make them better, faster, and safer.
For more information about the tracking technologies used in a mobile application, please review the information on the app store page and the content available in the mobile application itself, such as in the settings.
6. How We Use Your Personal Information
We use your Personal Information only when we have a valid legal basis to do so. Depending on the circumstance, we may rely on your consent or the fact that the processing is necessary to fulfill a contract with you, protect your vital interests or those of other persons, or to comply with law. We may also process your Personal Information where we believe it is in our or others’ legitimate interests, taking into consideration your interests, rights, and expectations.
- Provide Our Services. We collect Personal Information necessary to provide our Offerings, for example, to personalize or improve our offerings, for internal purposes such as auditing or data analysis, or for troubleshooting.
- Communicate with You. To respond to you (e.g., reach out to you about your transactions or account, market our Offerings, provide other relevant information, or request information or feedback).
- Security and Fraud Prevention. To prevent fraud, including to protect individuals, employees, and NextGate for the benefit of all our users.
- Comply with Law. To comply with applicable law — for example, to satisfy tax or reporting obligations, or to comply with a lawful governmental request.
- Where we obtain your consent. We may use your Personal Information for any other purpose with your specific consent.
- Business and Official Communications. We use the information we collect or receive from you to communicate directly with you in relation to our other services and technologies. We may also use the information to send you service-related notices, such as account verifications, technical and security notices, and billing or invoicing information. From time to time, we use your Personal Information to send important notices, such as changes to our terms, conditions, and policies. Because this information is important to your interaction with us, you may not opt out of receiving these important notices.
8. Transfers of Personal Information Between Countries
NextGate operates or obtains data hosting services for our clients primarily from the United States of America (USA) and our data collection and processing activities take place predominantly in the USA. If personal data collected outside the USA is transferred internationally, NextGate will rely on legally-provided mechanisms to lawfully transfer data across borders, as required under relevant data protection laws. Where appropriate, We may also rely on your consent for the transfer of your personal data for processing outside of your own country. Countries where we process data may have laws which are different from, and potentially not as protective as, the laws of your own country. By providing us with your Information, you acknowledge any such transfer, storage or use.
9. How Long We Keep Your Information
NextGate retains your Personal Information we collect from you for as long as the information is relevant to our business purposes. We will retain your Personal Information for as long as needed to fulfill the purpose for which we collected it and for a reasonable period thereafter in order to comply with audit, contractual, or legal requirements, or where we have a legitimate interest in doing so. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We may retain Personal Information preserved in automatically generated computer back up or archival copies generated in the ordinary course of our information technology systems procedures.
Information you have shared with others may remain visible to them after you close your account with us or delete the information since we are not the controller of that information.
Our Offerings are not for use by children under the age of 18 or the equivalent as specified by law in your jurisdiction (“Child” or “Children”). We might offer consumer applications which permit authorized guardians such as parents or conservators to set up and use accounts for their Children. We do not knowingly collect Personal Information from Children without the consent of the authorized guardian. If we learn that we collected or received Personal Information from a Child without authorized guardian consent, we will delete that information.
If you are under 18, do not use or provide any information to NextGate or through any of its Offerings, including your name, address, telephone number, email address, or any screen name or username you may use.
We recognize that your privacy is important to you, and therefore take security measures which are designed to keep your Personal Information and content confidential. We use appropriate technical, physical, and organizational security measures to safeguard your information across our computer systems, website and offices (e.g., we regularly monitor our systems for possible vulnerabilities and attacks). These safeguards (e.g., encryption) vary based on the sensitivity of the information that we collect and store. Visit our homepage for industry certification information.
12. Your Privacy Rights and Choices
We respect your ability to know, access, correct, transfer, restrict the processing of, and delete your Personal Information. You may have other privacy rights depending on the data protection laws which apply to you. If you choose to exercise these privacy rights, you have the right not to be treated in a discriminatory way nor to receive a lesser degree of service from us. NextGate does not sell your data including as “sale” is defined in Nevada and California.
There may be situations where we cannot grant your request — for example, if you ask us to delete your transaction data and NextGate is legally obligated to keep a record of that transaction to comply with law. We may also decline to grant a request where doing so would undermine our legitimate use of data for anti-fraud and security purposes, such as when you request deletion of an account that is being investigated for security concerns. Other reasons your privacy request may be denied are if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical.
To exercise your privacy rights and choices, or to contact our Data Protection Officer, you may contact us at [URL link to the Privacy Inquiry Form]. We will use reasonable efforts to promptly update your Personal Information and choices, or investigate and respond to you. You also have the right to go directly to your local data protection authority, but we encourage you to contact us so that we may resolve your concerns directly as best and as promptly as we can.
And remember, you can manage some of your oneDID™ Personal Information directly in your account settings at any time by logging in to your account.
13. Contact Us About Privacy Questions
NextGate Solutions, Inc., 3579 E. Foothill Blvd. Suite 587, Pasadena, California, USA, 91107