Navigating Care Privacy Policy

Last updated January 26, 2022.

This online privacy policy describes the privacy practices for Navigating Cancer, Inc. (“Navigating Cancer” “our,” “we,” or “us”). Navigating Cancer considers the privacy and security of user information an important component of the Navigating Care service, including services offered on our websites, navigatingcare.com and nav.care (the “Sites”), email and text communications. Navigating Cancer is committed to the privacy and confidentiality of your personal information. The following information explains how Navigating Cancer collects and uses information obtained from its users in connection with our services (collectively, the “Services”).

By accessing the Sites or using the Services, you agree to the terms of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites or Services.

What this Privacy Policy Covers.

This Privacy Policy covers the personal information collected from you when you are on the Sites and when you use the Services and Navigating Cancer’s treatment of such personal information. Also, this Privacy Policy covers Navigating Cancer’s treatment of personal information that Navigating Cancer’s business partners and healthcare providers share with Navigating Cancer. This Privacy Policy does not apply to the practices of companies that Navigating Cancer does not own or control, or to individuals that Navigating Cancer does not employ or manage.

HIPAA Notice of Privacy Practices.

To access your healthcare provider’s HIPAA Notice of Privacy Practices please visit your healthcare provider’s website.

Personal Information Collected and How We Use It.

In order to provide users with a friendly, customized, and efficient experience, we collect personal information of several types. We also collect personal information received from your healthcare provider in order to provide Services to you and to your healthcare provider including but not limited to care management, health tracker, and patient portal solutions. We collect personal information from your device or browser, and directly from you. We may use personal information we collect in order to provide you with our Services, to address your questions, comments or requests, to develop and analyze our products and Services, to personalize your experience with our Services, comply with out legal and contractual obligations, and protect our rights, property, and safety (or the rights, property and safety of others). We have collected these categories of information within the last twelve months.

A) Information You Provide to Us:

We may receive and store information you enter on the Sites or otherwise provide to us through the Services, including information that we receive as a result of our back-office integration with your healthcare provider’s clinical systems.

  1. 1. Registration In order for you to use certain features of the Services, you may be required to complete a registration form which may ask for personal information.
  2. 2. Health Records. We work with your healthcare providers to provide you the Services. Your healthcare providers share personal information about you and your treatment with us, in order for us to provide you with the Services, and we share with your healthcare provider information that you input into the Sites (e.g., secure messaging). We recognize the sensitivity of your personal information and we will protect any information provided by your healthcare providers to us as required by HIPAA. As a user of Navigating Care, you can access and manage your health records and monitor and record your daily health information and disease symptoms and/or side effects. All of the health record pages on Navigating Care use Secure Sockets Layer (SSL) encryption to protect your personal information. Examples of the types of information stored in your Navigating Care health records include (this is not an exclusive list):
    • General demographic personal information including, but not limited to, your name, address, date of birth, gender and contact information
    • Diagnosis
    • Treatments including surgeries, radiation treatments, chemotherapy, complementary or alternative medicines
    • Lab results and clinical notes
    • Prescription medications, dietary supplements, herbal remedies, or other medications
    • Healthcare Provider team member’s contact information such as your doctor’s name, specialty, address, email and phone numbers
    • Clinic facility information, such as names, addresses and phone numbers
    • Daily Health Tracker information, including self-reported details about your general health and wellbeing, as well as self-reported disease symptoms and/or side effects of treatment
    • Medical appointment dates, times and physician information
    • Secure messaging with your healthcare providers
  3. 3. Your Communications with Us. We collect personal information from you such as email address, date of birth, zip code, phone number, or mailing address when you request information about our Services, sign up for communications, request customer or technical support, apply for a job or otherwise communicate with us.
  4. 4. Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.

B) Automatic Information:

We may receive and store certain types of information whenever you interact with the Sites or Services. Navigating Cancer may automatically receive and record certain "traffic data" on our server logs from your browser including your Internet Protocol (IP) address, geo-location, search history, browsing history, the uniform resource locator (URL), the website you linked from, Navigating Cancer cookie information, and the page you requested.

In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities. We may combine your information with information that other people provide when they use our Services, including information about you when they tag you. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services.

C) E-mail and SMS Communications:

We may communicate with you via email and text messaging (SMS), for example for registration purposes, to provide educational materials, and to notify you when your clinic has updated your patient portal. We may also send out emails with news or promotions. If you do not want to receive e-mail or other mail from us, please notify us by e-mail at unsubscribe@navigatingcare.com and include sufficient information for us to identify your account.

D) Information from Other Sources:

In order for us to develop a more personalized service offering, we may receive information about you from other sources and add it to our account information.

Sharing and Use of Information.

We do not sell any personally identifiable information to anyone without your consent, and within the last twelve months we have shared your information consistent with the statements below. We will not share your personal information (described above) except in the following circumstances:

A) Consent:

Navigating Cancer may disclose personal information when you have provided consent to do so.

B) Consistent with HIPAA:

Navigating Cancer may use and disclose personal information if it is required to do so by law, when it is permitted to do so consistent with HIPAA, or if Navigating Cancer has a good faith belief that such action is necessary to conform to applicable laws or comply with any legal, regulatory or similar requirement or investigation, to protect or defend the rights or property of Navigating Cancer or another user or to enforce Navigating Cancer’s Terms of Use.

C) Business Transfers:

Navigating Cancer may transfer your personal information to any successor to all or substantially all of its business or assets that concern the Services.

D) Government Entities/Security:

We may share personal information in response to a court order, subpoena, search warrant, law or regulation. We may also use personal information to comply with our legal, regulatory, security and risk management obligations, including defending legal claims. We may cooperate with law enforcement authorities in investigating and prosecuting activities that are illegal, violate our rules, or may be harmful to other visitors. We may share personal information, to address fraud, security or other technical issues. We may also share personal information to protect against harm to Navigating Cancer or other third parties.

E) Service Providers:

We may share any personal information we collect about you with our third-party service providers. The categories of service providers to whom we entrust personal information include IT and related services; information and services; services such as Google Analytics, customer service providers; and vendors to support the provision of the Services.

F) International Data Transfers:

You agree that all information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well.

G) Information You Share with Third Parties:

You should be aware that by providing third parties with your name (User ID) and password, you may inadvertently enable unauthorized persons to review, modify or delete your health records. If you provide a third party with your user credentials, Navigating Cancer cannot monitor their use of the Site or Services.

H) Information You Share with the Public:

The Sites will allow you to post information into a public forum. If you post personal information into a public forum, the public will have access to such information. Please note, once you make a public posting through the Sites, you may not be able to change or remove it.

THIS PRIVACY POLICY DOES NOT PROTECT YOU WHEN YOU USE OUR PUBLIC FORUMS OR PROVIDE INFORMATION (INCLUDING PERSONALLY IDENTIFIABLE INFORMATION) ABOUT YOURSELF THROUGH THESE PUBLIC FORUMS.

You should be aware that any information shared in a public forum such as a message board, posting, group, bulletin board, review posting or through Navigating Cancer public forums is public information and may be seen or collected by third parties that do not adhere to our Privacy Policy. You should think carefully before disclosing any information in any public forum. For example, you should not select a username that includes personally identifiable information.

Aggregation of De-identified Information and Statistics.

Navigating Cancer may de-identify your personal information, including your healthcare information. Navigating Cancer and its partners may use and disclose de-identified and or aggregated information gathered from your profile and your usage of the Sites and related statistics. If we are de-identifying personal healthcare information then, such de-identification will be in compliance with HIPAA requirements and such de-identified information will not include personally identifiable information relating to users such as name, email address, or address, but may include gender, height, weight, postal code, and medical information such as diagnosis and stage of illness. We will not attempt to re-identify the de-identified information, except we may attempt to re-identify the information solely for the purpose of determining whether our de-identification processes satisfy legal requirements. Aggregated information is information from multiple users that cannot be “re-identified,” or associated with any individual user or account. This de-identified data may also include data extracted on an anonymous basis from the health care information we receive from your physician or other care providers once you have agreed to the use of our Services. We will require any of our partners that receive de-identified data from us to agree to not re-identify the data.

Security.

Your Navigating Care account information is protected by a password for your privacy and security. You are responsible to protect against unauthorized access to your account and to your computer by logging off once you have finished using a shared computer, and to your mobile phone by enabling your device’s security features.

It is our policy to protect the confidentiality of Social Security numbers ("SSNs”) that we receive or collect in the course of business. We secure the confidentiality of SSNs through various means, including physical, technical, and administrative safeguards that are designed to protect against unauthorized access. It is our policy to limit access to SSNs to that which is lawful, and to prohibit unlawful disclosure of SSNs.

“Do Not Track.” Do Not Track (“DNT”) is a preference you can set in your web browser to let the websites you visit know that you do not want them collecting data about you. At this time, this Site does not respond to DNT or similar signals.

Third Party Sites.

The Services may contain links to other websites, and other websites may reference or link to our website or other Services. These other websites are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.

Cookies.

Cookies are alphanumeric identifiers that we may transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and tell us how and when pages in our Sites are visited and by how many people. Navigating Care cookies do not collect personal information, and we do not combine information collected through cookies with other personal information to tell us who you are or what your email address is.

Your internet browser may direct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. We strongly recommend that you leave the cookies activated, because cookies enable you to take advantage of some of the Services’ most attractive features.

Minors.

The Services are not directed to children under 18, and we do not knowingly collect or sell personal information from children. However, if requested by your healthcare provider, minor patients, parents or guardians may elect to establish a portal account, and, in doing so, expressly consent to Navigating Cancer utilizing such information as set forth in this Privacy Policy and the Terms of Use. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.

Changes.

Navigating Cancer reserves the right to change or update this Privacy Policy at any time by posting a notice at the Sites. Changes to the Privacy Policy will take effect immediately unless otherwise noted. Your continued access of the Services constitutes your agreement to this Privacy Policy and any updates or revisions.

Contact.

If you would like to make changes to your personal health information, please contact your healthcare provider directly. If you have any questions regarding this Privacy Policy or your dealings at this Sites, please contact Navigating Cancer at:

Attn: Privacy Officer
Re: Privacy Policy
1008 Western Avenue Suite 206
Seattle, Washington 98104
support@navigatingcare.com

Special Notice for California Residents:

In addition to the Privacy Policy above, California residents may be entitled to the following privacy rights under California law:

A) The right to know about personal information collected, disclosed or sold. You have the right to request that we disclose what personal information we collect, use, disclose and sell. Please note that we describe these practices above in our Privacy Policy.

B) The right to request deletion of personal information. You, or your authorized agent, have the right to request that we delete the Personal Information that we have collected about you. Subject to HIPAA, other laws, and our legal obligations (including contractual obligations) we may deny your request. There may be exceptions under California law that may allow Navigating Cancer to maintain and use your personal information notwithstanding your request for deletion. We will inform you of our reasons for denying your request.

C) The right to opt-out of the sale of personal information. Under California law, you have the right to opt-out of the sale of personal information; however, Navigating Cancer does not sell your personal information.

D) The right to non-discrimintation for the exercise of a consumer’s privacy rights. You have the right to not receive discriminatory treatment by Navigating Cancer for the exercise of your privacy rights conferred by California law. Please note that if you exercise certain rights you may not be able to use or access all of Navigating Cancer’s Services.

E) Submission of requests. You may submit requests by contacting support@navigatingcare.com. We may request identity verification before processing your requests (e.g. ensuring that your information matches the identifying information that we have within our system) and we will not process your request without sufficient information to reasonably verify your identity, or the identity of your authorized agent and their authority to submit this request.

F) The California “Shine the Light” law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed your personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.