Policies

Last Updated 5/1/2023

Personix (also referred to as “we,” “our,” “us”) operates Personix.app (the “Site”) to provide an interactive portal by which patients and providers communicate, inform, and assess ongoing patient care. We are committed to protecting the privacy of all persons using the Site.

This Privacy Policy describes the information gathering and distribution methods for the Personix patient engagement platform. More information on the use of the Personix patient engagement platform is included in our Terms and Conditions which can be found above.

By downloading and using the Site, You understand and agree to the terms set forth in this Privacy Policy and the related Terms and Conditions.

While utilizing this site and associated application(s)s, Personix may integrate tags to provide patient-specific information and improve the user experience. Downloading the Personix patient application(s) will require a digital signature that will create a binding agreement of which the Privacy Policy and Terms and Conditions are a part. v policies may change. Changes shall be posted on this site and communicated via the application(s) while in use. Continuing to utilize the Personix platforms following notification of these changes shall infer acceptance of the changes.

General Privacy Notice

What Information Do We Collect?

We collect your personal data whenever you interact with us and when you visit our Site. Generally, we will collect and process the following information:

• Account registration information: When you create an account with us, you provide us with certain personally identifiable information, including but not limited to full name, address, email address and your telephone number. You may also voluntarily provide us with additional personal data that will enhance your user experience.

Interaction information

We collect information relating to our interactions with you make including information about procedures, health, demographics, and equipment usage.

Providing personal information for individuals other than yourself may violate the law. Personal information collected by the Personix application(s), including responses, recordings, and digital integrations, shall be considered protected. Content not identified as user specific may not be considered protected information.

Authorized Users and Authorized Providers.

Caregivers and family members (“Authorized Individuals”) may be permitted to access and view your information via Personix. Authorized individuals, including health care providers, may provide and view information via the Personix application(s).

We also automatically collect certain information when you access, use, or interact with us. We generally collect the following information:

• Device information: We collect your device ID; IP address; device type; operating system and version; general geographic location (from your IP address); browser type; screen resolution; device manufacturer and model; language; You may control some of this information through your device settings.
• Usage information: We collect information about your interaction with our Services.
• Log Information. While accessing Personix, certain information may be recorded that document the interaction. Information requests, features access, date, time, and other unique identifiers may be collected. Device information may also be collected… including type, operating system version, and device identification. Personal information as created via an IP address or identified device may be shared with third parties as expressed in this privacy policy.

What Do We Do With the Information We Collect?

We will ask you for personal data in certain fields on the Site or in the Surveys that we need for you to use the Services.  The personal data we collect is used only for the purpose we state at the time of collection or for purposes listed below.  For example, our uses may include, but are not limited to, the following:

• To manage internal business practices
• To provide support or other services
• To provide information based on your needs and respond to your requests
• To administer products and services
• To select content, improve quality, and facilitate the use of our Site and Services
• To assess usage of products and services
• To communicate with you about events
• To update you on relevant products, services, and opportunities
• To engage with third parties
• To protect our content and services from illegal or harmful activities
• To get feedback and input from you
• To protect our information assets as well as your personal data
• To assist in business sales or mergers
• To comply with Laws, Regulations, legal proves or other government or law enforcement requests
• To enforce our Terms of Use, including investigation of potential violations
• To detect, prevent, or otherwise address fraud, security or technical issues

To the extent that we collect certain demographic information about you, we may use this information in our market research, but we will do so only after we “anonymize” the data, i.e., remove information that would confirm your identity.  We will not use your personal data, however, to send commercial or marketing messages to you unless we have your continued consent for which you will have the ability to opt out by sending an email to privacyofficer@personix.app.

Who Can Use the Information We Collect and How?

Personix may share information with compliant partners necessary to complete information requests and maintain the functionality of the Personix application(s). Compliant partners may only use information for its intended purpose.

We may also provide your personal data to third parties, or third parties may collect personal data from you on our behalf if we have contracted with that third party to provide some part of the information or service that you have requested.  Other than those who act on our behalf, and except as explained in this Policy, personal data you provide to us will not be transferred to unrelated third parties, unless we have a legal basis to do so.  However, please note that the personal data you transmit to us may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders.

Authorized individuals and providers will have access to Personix for the management of your information. It is the primary user’s responsibility to designate and terminate each authorized user. Authorized providers will be provided access credentials for the primary user’s personal information. Personix is not responsible for how authorized individuals and providers manage the primary user’s information.

What Are Your Rights Regarding Your Personal Data?

We respect your right to access and control your personal data, and you have choices about the data we collect from you. If we request personal data from you that is not necessary for the purposes of providing you with our products and services, then you may decline to provide that personal data. However, if you choose not to provide personal data that is necessary to provide a particular service, you may not have access to certain features of that service.

Depending on where you live, you may have certain rights that you can exercise with regard to the collection, use, and transfer of your personal data. For more details, please see the relevant section of the privacy policy.

Regardless of where you live, you can always opt-out of marketing communications, correct or update your information, and implement technical measures to opt-out of targeted or behavioral advertising as outlines below:

Opt-Out of Email Marketing Preferences.

The e-mail communications we send you will generally provide an unsubscribe link, allowing you to opt-out of receiving future email or to change your contact preferences. E-mail communications may also include a link to directly update and manage your marketing preferences, if you have an online account with us. You can also change your contact preferences through your account. You can also request an opt-out by emailing privacyofficer@personix.app. Please remember that even if you opt out of receiving marketing emails, we may still send you important information related to your account and use of the Services.

Opt-Out of Targeted Advertising

You may opt-out of third party targeted advertising or data analytics in two ways:  (i) by directly notifying a Network Advertising service provider via its opt-out tools (see above), or (ii) by using your browser’s Do Not Track (DNT) settings to indicate that you do not wish to receive targeted advertising based on your overall internet usage.  For more information about DNT and how it works, please visit the Future of Privacy Forum’s website: http://www.allaboutdnt.com/.

We will make every reasonable effort to honor your DNT browser settings for opting out of receiving targeted third-party advertising based on your overall Internet usage.  Please note that various browsers frequently update their technology and / or change their settings and business practices without advance notice, thus we may not have the latest information on how to honor your preferences.  If you exercise either opt-out option—the cookie opt-out or the browser opt-out—you will continue to receive advertising, but such advertising may not relate to your specific interests, previous purchases, or search history.

Keep in mind, however, that you cannot opt-out of our contextual data analytics and advertising, which is based on your usage of only our Services. We will continue to serve you contextual advertising.  We will also continue to monitor your usage and search or transaction history to provide us with analytics on how well our Services, features, and activities are functioning and used. We will also share this information within our company in an aggregated or anonymized form (meaning that no one individual person can be identified).

How Do You Correct and Update Your Personal Data?

Our goal is to keep all personal data that we hold accurate, complete, and up-to-date. Please let us know if you change your contact details. If you believe that any of your information is incorrect, incomplete, or out-of-date, you can update your personal details through your account with us, or by contacting privacyofficer@personix.app.

How Do We Protect the Personal Data We Collect?

We are committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and / or electronic form. In either situation, we use technologies and procedures to protect your personal data. We review our strategies and methods update them as necessary to meet our business needs, changes in technology, and regulatory requirements.  We take our security obligations seriously and so should you.  While we are responsible for maintaining the security of our websites and Services, you must also access and use the Services in a manner that is responsible and secure.  In addition, we have implemented a series of policies, procedures, and training to address data protection, confidentiality, and security, and we update and review the appropriateness of these measures on a regular basis.

We will take reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data.  However, we cannot guarantee its absolute security or that unauthorized persons will not access or use your personal information for improper purposes.  In the event of a breach of security affecting personal information or data on our servers, we will take such notification and other steps as may be required under applicable law. You hereby agree that we may send you notices via email.

How Long Do We Retain the Data?

We retain personal data for as long as necessary to provide our Services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements.

Direct communications via phone, email, or fax may be retained to aid in our quality improvement efforts.  We are required by law to keep some types of information for certain periods of time (e.g., statute of limitations).  If your personal data is no longer necessary for the legal or business purposes for which it is processed, then we will generally destroy or anonymize that information.

What is Our Policy if You Are an Underage Child?

We understand the importance of protecting the privacy of all individuals, especially the very young.  Our services are intended for United States audiences over the age of 18.  Our Site and its Services are not directed to children, and you may not use our Services if you are under the age of 13. You must also be old enough to consent to the processing of your personal data in the country or state where you live (in some countries, parents or guardians may consent on your behalf). Using our Services is restricted to adults who are either 18 years of age or older or as otherwise legally defined by the country or state where you live.

What Happens When You Link to a Third-Party Web Site?

If you click on a link and go to another site, you will be subject to that website’s privacy policy.  We encourage you to read the posted privacy policy statement at any website before submitting any personal data.

What Happens When We Update Our Privacy Policy?

We may update our Privacy Policy from time to time to keep current with evolving legal requirements.  Your acceptance of any minor changes to this Privacy Policy is indicated by your continued use of our Services.  If we make any material changes to our Privacy Policy, we will post a notice about the change at a prominent location on our Site.  We encourage you to periodically review our Site and this Privacy Policy for any changes.

What If You Have Questions?

If you have questions or concerns regarding anything in this Privacy Policy, please feel free to send us an email at privacyofficer@personix.app.

Your California Privacy Rights

We have adopted the following disclosures to comply with the California Consumer Privacy Act of 2018, as amended, its implementing regulations (“CCPA”) and other California privacy laws. Any terms defined in the CCPA, other California privacy laws, or in our Privacy Policy have the same meaning when used in this Notice.

This California Privacy Notice (“Notice”) applies to “Consumers” as defined by the California Consumer Privacy Act (“CCPA”) as a supplement to other privacy policies or notices that we may issue.  In the event of a conflict between any of our other policies, statements, or notices and this Notice, this Notice will prevail with regard to California Consumers and their rights under the CCPA.

Consistent with the CCPA, job applicants, current and former employees and contractors, and subjects of certain business-to-business communications acting solely in their capacity as representatives of another business, are not considered Consumers for purposes of this Notice or the rights described herein.

Information We Collect and How We Use It

We collect personal data that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal data”).

Personal information tracking and collection will discontinue upon the termination of your use of Personix.

The following is a description of our data collection practices, including the personal data we collect, the source of that information, the purposes for which we collect information, and whether we disclose that information to external parties. We may use any and all of the information for any purposes described in this Privacy Notice.

PERSONAL IDENTIFIERS

• We collect your name, phone number, and email address when you create an account with us or providing to us through your Authorized Agent. We use this information to provide our Services, respond to your requests.
• We collect a unique numerical identifier, assigned to you by a first-party cookie, automatically when you use our Services in order to identify you, provide our services, prevent fraud, and provide you with targeted information.
• We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our mobile application(s), and measure the effectiveness of online services, application(s)s, and tools.
• We collect your Device ID automatically when you use our Services. We use this information to monitor your use and the effectiveness of our Services, and to identify you.

Personal DATA protected against security breaches (Cal. Civ. Code § 1798.80(e))

• We collect your name, phone number when you create an account with us or provided to us through your Authorized User. We use this information to provide our Services, respond to your requests.
• We collect health and other medical information directly from you when you respond via the survey and when you participate in therapy or other treatment with a provider. We use this information to provide you with the Service and to better calibrate our assessment tool.
• We may collect information about your health insurance from your employer if a referral to another provider is necessary.

PROTECTED CLASSIFIED INFORMATION

• We collect information about your age and date of birth when you create an account with us or when your employer provides us with this information. We use this information to provide you with the Service and to better calibrate our assessment tool.
• We collect information about current and potential physical disabilities that you may have. We use this information to provide you with the Service and to better calibrate our assessment tool.
• We collection information about your gender when you create an account with use or when your employer provides us with this information. We use this information to provide you with the Service and to better calibrate our assessment tool.

COMMERCIAL INFORMATION

• When you engage with us, we create records of your interactions with us and the Services provided. We use this information to measure the effectiveness of our Services and use this information to better calibrate our assessment tool.

INTERNET OR OTHER SIMILAR NETWORK ACTIVITY

• We collect information about your browsing history, search history, and information regarding your interaction with our Site.

GEOLOCATION

• As described above, we collect your IP address automatically when you use our Site. We can determine your general location based on the IP address.

AUDIO/VIDEO DATA

• If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We do not collect your image or any thermal, olfactory, or similar information.

EDUCATION INFORMATION

• We do not collect any information about the institutions you have attended. We may ask you for information regarding the level of education you have attained as part of marketing surveys or the level of education you have attained.

BIODATA

• We collect information about your physiological, biological, and/or behavioral characteristics for purposes of our outcomes algorithms and remote patient monitoring, such as pain scores, satisfaction scores, demographics, and app usage behaviors.

INFERENCES DRAWN FROM OTHER PERSONAL DATA

• We analyze all data and create profiles. We use this information to improve our Services and to better calibrate our assessment and engagement tools.

When we disclose personal data for a business purpose, we enter into an agreement that describes the purpose of the agreement and requires the recipient of the personal data both to keep it confidential and to not use it for any purpose except to perform the contract. The CCPA prohibits third parties who purchase the personal data we hold for you from reselling it unless you have received explicit notice and an opportunity to opt-out of further sales.

Either we or our Service Providers also may use your information for the following Business Purposes (as defined in the CCPA) on a day-to-day basis:

• Auditing related to a current interaction with the consumer and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging to identify and repair errors that impair existing intended functionality.
• Short-term, transient use, provided that the personal data is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction.
• Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider.
• Undertaking internal research for technological development and demonstration.
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by the business.

Do We “Sell” Your Personal Data?

We do not “sell” your personal data as currently defined under the CCPA, meaning that we do not rent, disclose, release, transfer, make available or otherwise communicate your personal data to a third party for monetary or other valuable consideration. We will not sell your personal data unless we modify this Privacy Policy and take the additional steps required under the CCPA.

How to Exercise Your Rights Under the CCPA

Under the CCPA you have the right to find out about the personal data that we have collected and how that information has been used or disclosed. You also have the right to request that we delete your personal data. If you wish to exercise any of the rights listed below, or if you would like additional information, please contact us at privacyofficer@personix.app. 

The Right to Access and Know About Personal Data Collected, Disclosed

You have the right to request that we disclose certain information to you about our collection and use of your personal data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• The categories of personal data we collected about you.
• The categories of sources for the personal data we collected about you.
• Our business or commercial purpose for collecting or selling that personal data.
• The categories of third parties with whom we share that personal data.
• The specific pieces of personal data we collected about you (also called a data portability request).
• If we disclosed your personal data for a business purpose, identifying the personal data categories that each category of recipient obtained.

For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

The Right to Request Deletion of Your Personal Data

Subject to certain exceptions, you have the right to request that we delete any or all of the personal data that we collected from you and retained over the past 12 months. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal data from our records, unless an exception applies. You may request that only a portion of your personal data be deleted.

We may deny all or part of your deletion request if retaining your personal data is necessary for us or our Service Providers to:

• Complete the transaction for which we collected the personal data, provide a service that you requested, take actions reasonably anticipated based on our ongoing business relationship with you, or otherwise perform our agreement with you;
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
• Debug products to identify and repair errors that impair existing intended functionality;
• Exercise free speech or ensure the right of another consumer to exercise their right of free speech or other right provided for by law;
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
• Comply with law or a legal obligation; or
• Otherwise use your personal data internally, in a lawful manner that is compatible with the context in which you provide the information.

The Right to Opt-Out of the Sale of Your Personal Data

We do not sell your personal data, so we do not offer an opt-out.

The Right to Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights, and will not engage in the following behaviors:

• Denying you goods or services
• Charging you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties
• Providing you a different level or quality of goods or services
• Suggesting that you may receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your Rights

When you exercise these rights and submit a request to us, we will verify your identity by asking for information about your relationship with us, such as your name, email address on file, billing or shipping address, phone number, or order number.

We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.

Any disclosures we provide will only cover the 12-month period preceding your verifiable request’s receipt. The response we provide will also explain the reasons we cannot comply with your request, if applicable.

Authorized Agents

You may authorize a natural person, or a business entity registered with the California Secretary of State, to act on your behalf to make a request to know about personal data collected or to delete your personal data.

To facilitate such an authorization, you must (i) verify your identity to us and provide that authorized agent written permission to make such a request or (ii) provide the authorized agent with power of attorney in your behalf pursuant to the California Probate Code sections 4000 to 4465.

The authorized agent must include those authorizations in your verifiable consumer request.

Notice of Financial Incentive

We do not offer any Financial Incentive (as defined by the CCPA) in exchange for your personal data.

Children Under the Age of 16

We do not knowingly collect, solicit, or share personal data from children under the age of 16. If we have knowledge that a child under 16 has submitted personal data in violation of this Policy, we will delete that information as soon as possible. If you believe we may have obtained information in violation of this Policy, please email us at: privacyofficer@personix.app or call us at: 734-426-0500.

Questions about the CCPA

If you have questions or concerns regarding this statement, you should first contact us via email at: c.

Changes to this Privacy Policy

We reserve the right to amend this Privacy Notice at our discretion and at any time. When we make changes to this Notice, we will post the updated Notice on the Site and update the Notice’s effective date. Your continued use of our Site following the posting of changes constitutes your acceptance of such changes. If we are required by applicable data protection laws to obtain your consent to any material changes before they come into effect, then we will do so in accordance with law.

California Shine the Light Law

If you are a California resident and have an established business relationship with us and want to receive information about how to exercise your third party disclosure choices, you must send a request to the following address with a preference on how our response to your request should be sent (email or postal mail).  You may contact us in two ways:

You may send an email to: privacyofficer@personix.app

You may contact us by mail at:
Personix
21223 Hilltop Road
Southfield, Michigan 48033
Attn:California Privacy Rights
c/o Privacy Administrator

For requests sent via email, you must put the statement “Your California Privacy Rights” in the subject field of your email.  All requests sent via postal mail must be labeled “Your California Privacy Rights” on the envelope or post card and clearly stated on the actual request.  For all requests, please include your name, street address, city, state, and zip code.  (Your street address is optional if you wish to receive a response to your request via email. Please include your zip code for our own recordkeeping.) We will not accept requests via the telephone or by facsimile.  We are not responsible for responding to notices that are not labeled or not sent properly, or do not have complete information.

If you are a California resident under the age of 18, and a registered user of any Site where this Privacy Policy is posted, California Business and Professions Code Section 22581 permits you request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or personal data to privacyofficer@personix.app. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.