Cisne Health, LLC (“Cisne Health” or “Cisne” or “we” or “us” or “our”) respects the privacy of everyone (“Sites’ visitor” “user” or “you”) that uses our website at cisnehealth.com, as well as other device or online applications related or connected thereto (collectively, the “Sites”).

The following Cisne Health Privacy Policy (“Privacy Policy”) is designed to inform you, as a user of the Sites, about the types of personal information that Cisne may gather about or collect from you in connection with your use of the Sites. It also is intended to explain the conditions under which Cisne uses and discloses that personal information, and your rights in relation to that personal information.

The Sites are hosted in the United States and is subject to U.S. state and federal law. If you are accessing our Sites from other jurisdictions, please be advised that you are transferring your personal information to us in the United States, and by using our Sites, you are agreeing to that transfer and use of your personal information in accordance with this Privacy Policy. You also agree to abide to the applicable laws of the State of Florida and U.S. federal law concerning your use of the Sites and your agreements with us. If your use of the Sites would be unlawful in your jurisdiction, please do not use the Sites.

HOW WE COLLECT AND USE YOUR PERSONAL INFORMATION

Cisne gathers personal information from users of the Sites. When you browse our Sites, subscribe to our services or contact us through various social or web forms you are voluntarily sharing personal information with us. This personal information also includes various data that we collect automatically. This may be the user’s Internet Protocol (IP) address, operating system, browser type and the locations of the Sites the user views right before arriving at, while navigating and immediately after leaving the Sites. It may also include various technical aspects of user’s computer or browser and users browsing habits that are collected through cookies. Cisne may analyze various mentioned personal information gathered from or about users to help Cisne better understand how the Sites are used and how to make them better. By identifying patterns and trends in usage, Cisne is able to better design the Sites to improve users’ experiences, both in terms of content and ease of use. From time to time, Cisne may also release the anonymized information gathered from the users in the aggregate, such as by publishing a report on trends in the usage of the Sites.

When we believe disclosure is appropriate, we may disclose your information to help investigate, prevent or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of Cisne, our users, our employees or others; to comply with applicable law or cooperate with law enforcement; to enforce our Terms of Use or other agreements or policies, in response to a subpoena or similar investigative demand, a court order or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us. We will notify you if permitted before undertaking such disclosures.

Cisne reserves the right to transfer all information in its possession to a successor organization in the event of a merger, acquisition, bankruptcy or other sale of all or a portion of Cisne’s assets. Other than to the extent ordered by a bankruptcy or other court, the use and disclosure of all transferred information will be subject to this Privacy Policy, or to a new Privacy Policy if you are given notice of that new Privacy Policy and are given an opportunity to affirmatively opt-out of it.

DO WE SHARE YOUR PERSONAL INFORMATION?

General Provisions

Cisne contractually prohibits its contractors, affiliates, vendors and suppliers from disclosing any personal information received from Cisne, other than in accordance with this Privacy Policy. These third parties may include advertisers, providers of games, utilities, widgets and a variety of other third-party applications accessible through the Sites. Cisne neither owns nor controls the third-party websites and applications accessible through the Sites. Thus, this Privacy Policy does not apply to personal information provided to or gathered by the third parties that operate them. Before visiting a third party, or using a third-party application, whether by means of a link on the Sites, directly through the Sites or otherwise, and before providing any personal information to any such third party, users should inform themselves of the privacy policies and practices (if any) of the third party responsible for those Sites or applications, and should take those steps necessary to, in those users’ discretion, protect their privacy.

Regulation and Security

Certain information provided to us may be Protected Health Information as that term is defined in the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), American Recovery and Reinvestment Act (“ARRA”), Health Information Technology for Economic and Clinical Health Act (“HITECH”) and in regulations promulgated there under and it may also be subject to regulation under state law (“PHI”). We offer and provide the Sites and our products and services in a manner that complies with all applicable laws and regulations we are aware of and/or become known to us and will continue to do so. As an example, we have Business Associates Agreements in place with our customers, partners and vendors that govern the disclosure and use of PHI that is required for us to provide them with the products and services they have requested. If you order services from us that require you to provide to us personal health information that is protected under any federal or state laws (including HIPAA), You grant to us a non-exclusive, perpetual, irrevocable, royalty-free right and license to use de-identified patient and administrative data (“De-Identified Use Data” as defined under 45 C.F.R. § 165.514) collected or provided through your use of the Sites for any lawful business purpose, provided that such data is not personally identifiable. We shall have the right to de-identify such patient and administrative data and then utilize the De-Identified Use Data for any lawful purpose, including but not limited to creating statistical norms and reports de-identified score cards, regional or national benchmarking, or to be used for research considerations, provided however that the data shall not include member identities and claims information that is unprotected. Personally identifiable patient, physician and your information shall remain confidential and shall not be released. Further, should we choose to place the De-Identified Use Data in its national database or in any way incorporate such data in studies and/or analyses conducted directly or indirectly by us, no such data shall be identified as originating from you, or your patients, members, or physicians. The De-Identified Use Data shall also not be utilized in any study, report or publication without first being integrated with a significant body of other data such that neither you or your patients or physicians can be identified, unless appropriate, advance and written consents to such identification are obtained. We use appropriate security measures to protect the information we obtain from unauthorized alteration, loss, disclosure, or use, including technological, physical and administrative controls over access to the systems we use to provide the Sites and our products and services. As an example, we restrict access to particular systems and information to those employees and independent contractors whose duties require them to have it. To obtain this access, employees and independent contractors are required to agree not to: (a) disclose that information; or (b) use their access or any confidential information except to exercise their rights or discharge their obligations under their respective agreements.

Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit the Sites. These companies may use information about your visits to the Sites that are contained in Cookies in order to provide advertisements about goods and services of interest to you. Using a tool created by the Network Advertising Initiative, you can opt out of several third-party ad servers’ and networks’ Cookies simultaneously. If you would like more personal information about this practice and to know your choices about not having this personal information used by these companies, please follow the following links: http://networkadvertising.org/managing/opt_out.asp, http://preferences-mgr.truste.com/, or http://www.aboutads.info/choices/.

Analytics

We may use third-party vendors, including Google, who use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on your past activity on the Sites, including Google Analytics for Display Advertising. The personal information collected may be used to, among other things, analyze and track data, determine the popularity of certain content and better understand online activity. If you do not want any personal information to be collected and used by Google Analytics, you can install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout/) and/or opt out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings (www.google.com/settings/ads).

Third-Party Service Providers

We may share your personal information, which may include your name and contact information (including email address) with our authorized service providers that perform certain services on our behalf. These services may include fulfilling orders, providing customer service and marketing assistance, performing business and sales analysis, supporting the Sites’ functionality and supporting contests, sweepstakes, surveys and other features offered through the Sites. We may also share your name, contact personal information and credit card personal information with our authorized service providers who process credit card payments. These service providers may have access to personal information needed to perform their functions but are not permitted to share or use such personal information for any other purpose. You can contact us to receive our current list of providers.

If you have opted in to receiving marketing communication from us then Cisne may provide your personal information to third parties, with your consent, so that those third parties may directly contact you about additional products and services. To cease having your personal information used for marketing communication purposes, you can:

Opt out by clicking on the unsubscribe button found in the footer of our emails

MOBILE DEVICE ADDITIONAL TERMS

•  Mobile Device. If you use a mobile device to access the Sites or download any of our applications, we may collect device personal information (such as your mobile device ID, model and manufacturer), operating system, version personal information and IP address.
•  Geo-Location Personal Information. Unless we have received your prior consent, we do not access or track any location-based personal information from your mobile device at any time while downloading or using our mobile application or our services, except that it may be possible for Cisne to determine from an IP address the geographic location of your point of connectivity, in which case we may gather and use such general location data.

•  Push Notifications. We send you push notifications if you choose to receive them, letting you know when someone has sent you a message or for other service-related matters. If you wish to opt-out from receiving these types of communications, you may turn them off in your device’s settings.

•  Mobile Analytics. We use mobile analytics software to allow us to better understand the functionality of our mobile software on your phone. This software may record personal information, such as how often you use the application, the events that occur within the application, aggregated usage, performance data and where the application was downloaded from. We do not link the personal information we store within the analytics software to any personal information you submit within the mobile application.

SECURITY

We take the security of your personal information seriously and use reasonable electronic, personnel and physical measures to protect it from loss, theft, alteration or misuse. However, please be advised that even the best security measures cannot fully eliminate all risks. We cannot guarantee that only authorized persons will view your personal information. We are not responsible for third-party circumvention of any privacy settings or security measures.

We are dedicated to protect all personal information on the Sites as is necessary. However, you are responsible for maintaining the confidentiality of your personal information by keeping your password and computer/mobile device access confidential. If you have an account with Cisne and believe someone has gained unauthorized access to it or your account please change your password as soon as possible. If you lose control of your account, you should notify us immediately.

CHILDREN

The Children’s Online Privacy Protection Act (“COPPA”) protects the online privacy of children under 13 years of age. We do not knowingly collect or maintain personal information from anyone under the age of 13, unless or except as permitted by law. Any person who provides personal information through the Sites represents to us that he or she is 13 years of age or older. If we learn that personal information has been collected from a user under 13 years of age on or through the Sites, then we will take the appropriate steps to cause this personal information to be deleted. If you are the parent or legal guardian of a child under 13 who has become a member of the Sites or has otherwise transferred personal information to the Sites, please contact Cisne using our contact personal information below to have that child’s account terminated and personal information deleted.

DO-NOT-TRACK NOTICE

Most web browsers and some mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. Because there is not yet a common understanding of how to interpret the DNT signal, the Sites currently do not respond to DNT browser signals or mechanisms.

GOVERNING LAW

Disputes over privacy issues contained in this Privacy Policy will be governed by the law of the State of Florida. You also agree to abide by any limitation on damages contained in our Terms of Use, or other agreement that we have with you.

PRIVACY POLICY CHANGES

Cisne may, in its sole discretion, change this Privacy Policy from time to time. Any and all changes to Cisne’s Privacy Policy will be reflected on this page and the date of the new version will be stated at the top of this Privacy Policy. Unless stated otherwise, our current Privacy Policy applies to all personal information that we have about you and your account. Users should regularly check this page for any changes to this Privacy Policy. Cisne will always post new versions of the Privacy Policy on the Sites. However, Cisne may, as determined in its discretion, decide to notify users of changes made to this Privacy Policy via email or otherwise. Accordingly, it is important that users always maintain and update their contact personal information.

CONTACT

If you have any questions regarding our Privacy Policy, please contact us at:

Cisne Health
2000 Ponce de Leon Blvd, Ste 600
Coral Gables, FL 33134
Email: support@cisnehealth.com