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1-855-674-5333
Email
info@newwell360.com
Location
5201 Memorial Dr. Ste 529 Houston, TX 77007
NewWell360 offers an online communication platform for Providers and their patients to connect via the website through the use of synchronous and asynchronous telecommunications technologies. The Site facilitates communication between patients and Providers. NewWell360 does not provide medical advice or care. We use the information you share with us to help provide you with a customized experience from when you start interacting with us to providing you your own personalized treatment plan.
NewWell360, LLC and our provider entities (“NewWell360,” “we,” “us,” or “our”) take your privacy and trust in us seriously. We are committed to protecting the privacy and security of the information that you share with us.
The purpose of this Privacy Notice is to explain how we may collect, use, store, disclose, or otherwise process your personal information when you interact with us through the NewWell360 website located at https://NewWell360.com/, our mobile application(s), our products and services, and/or other communication channels under our control such as email, telephone, or social media that link to this Privacy Notice (collectively, “Services” or “Website”).
The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country, or territory other than that of the United States.
All capitalized terms not otherwise defined in this Privacy Notice have the same meaning as set forth in the NewWell360 Terms of Service, available here:
IF YOU DO NOT WISH TO ACKNOWLEDGE OR ACCEPT THIS PRIVACY NOTICE, PLEASE DO NOT USE THE SERVICES.
Collection of Information
Sources of Information
Use of Information
Sharing of Information
Security of Information
Retention of Information
California Privacy Rights
International Transfers
Updates
Contact Us
Medical group policy
NewWell360 collects and stores a variety of information when you use our Services. The specific types of information we collect will depend on the Services you use, but may include the following:
Personal Information:
Personal information means information associated with or used to identify or contact a specific person. Personal information we collect may include:
· Identifiers such as your first and last name, date of birth, sex or gender, physical address, email address, phone number, identification numbers, etc.
· Audio, visual, and other electronic information such as photographs and videos for purposes other than diagnosis or treatment
· Commercial information such as your order history, products purchased or considered, payment information, and shipping history
· Internet and network activity information such as IP address, geolocation information, device information, log data, and cookies and similar technologies
· Inferences drawn from any of the information collected about you such as your preferences, characteristics, and behavior, etc.
Health Information:
Health information is a type of personal information that includes any identifying information we collect relating to your medical history, including symptoms, diagnoses, treatment and outcomes.
Health information we collect may include:
· Audio, visual, and other electronic information such as photographs and videos for purposes of diagnosis or treatment
· Medical history such as medical conditions, medications, allergies, treatment options, prescriptions, and any other health-related information for purposes of diagnosis or treatment
· Commercial information such as your order and shipping history
Persons Under the Age of 18
Persons under the age of 18 are prohibited from using our Services.
You consent to verification of your identity to establish your age through use of NewWell360’s third-party identification service provider.
NewWell360 does not knowingly collect any information from persons under the age of 18.
If you are a parent or guardian of an individual under the age of 18 and believe your child has disclosed personal or health information to NewWell360 without your authorization, please contact us at:
We collect information about you from the following categories of sources:
You (Actively)
You may actively provide us information when you use our Services such as through our websites, emails, social media, surveys, sweepstakes and promotions, or any other online or offline interactions.
You (Passively)
You may also passively provide us information through your interactions and use of our Services such as your IP address, access times, hardware and software information, device information, device event information (e.g. crashes, unsuccessful logins, browser type), the web page you’ve viewed or engaged with before or after using the Services, and other relevant information. We may use cookies and other tracking technology to collect this information.
Third Parties
We may receive information from third parties such as affiliates, business partners, and service providers to operate our business and improve your experience and interactions with us.
Publicly Available Databases
We may receive information that is available publicly, either online or offline, to operate our business and improve your experience and interactions with us.
NewWell360 and our service providers may use information about you to:
· Prior to initiating the application questionnaire, you authorize NewWell360 to use information shared with us to verify your identification through the use of third party vendors before we create your account. The process is used to verify your identity as the holder of an account with us.
· Provide telehealth and related services;
· Verify your identity as the holder of an account with us;
· Administer your account, process payments, troubleshoot issues, and provide you with customer support;
· Communicate with you about the Services, and to deliver any administrative notices or alerts and communications relevant to your use of the Services;
· Allow you to participate in sweepstakes, contests, or other promotions;
· Market our services and those of third parties that we believe may be of interest to you;
· Tailor the features, performance and support of the Services to you and your preferences;
· Provide, operate, analyze usage of, and improve the Services, including performing product research and development;
· Investigate, detect, deter, prevent, report, defend against, or take other action regarding security incidents, abusive behavior, suspected fraud, malicious or illegal activities, or violations of our Terms of Service or other policies;
· Make sure our terms, policies, and agreements with you and any third parties are enforced;
· Comply with applicable laws and regulations.
NewWell360 may send you marketing emails or texts to let you know of the latest news on our products and services.
If you wish to stop receiving marketing emails from us, you can opt out by clicking the unsubscribe link in the footer of any marketing email or contact us at support@NewWell360.com.
Please be aware that you cannot opt out of transactional emails. Transactional emails are emails we send you relating to your account or in connection with providing you the Services such as emails changing your password, emails in response to your support request, and emails from your medical provider.
If you wish to opt out of all texts (including operational, promotional, or transactional texts), you can text the word “STOP” from the mobile device receiving the text messages.
We use third-party service providers such as Google Analytics by Google LLC (“Google”) to track and analyze Website traffic through the use of cookies and other tracking technology.
This allows us to show you advertisements and content that may be of interest to you based on your interactions with the Services, other online services, and/or information received from third parties.
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page:
policies.google.com/privacy
Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics, available at:
tools.google.com/dlpage/gaoptout
Certain web and mobile browsers allow you to send a signal to inform websites that you do not want your online activities tracked.
At this time, we do not currently respond to “Do Not Track” signals or similar mechanisms.
We understand the importance of protecting the confidentiality of your information and limit our disclosure of your personal and/or health information to the following possible scenarios:
· To licensed medical providers (including those who provide healthcare services, drugs, or medical devices) so that they may provide you with the telehealth and related products and services you request;
· To third-party service providers acting on our behalf or to entities with whom we may collaborate with to deliver the Services;
· In order to protect the safety and security of NewWell360, the Services, our operations, our systems, our properties, our customers, or any other related person or entity;
· In order to investigate, detect, deter, prevent, report, defend against, or take other action regarding security incidents, abusive behavior, suspected fraud, malicious or illegal activities, or violations of our Terms of Service or other policies;
· In order to establish, exercise, or defend our legal rights where it is necessary for our legitimate interests or the legitimate interests of others;
· In order to comply with applicable law or legal process such as a court order or subpoena;
· In connection with any reorganization, restructuring, merger, sale, acquisition, financing, dissolution, or other transfer of assets under the condition that the recipient agrees to respect your information in a manner that is consistent with this Privacy Notice.
NewWell360 understands the importance of securing your information. We are continuously implementing and updating our administrative, technical, and physical security measures to protect your information.
For example, we use firewalls to monitor and control our network traffic, encryption to secure our data transmissions, and cryptographic hash functions to store or share certain data.
Please be aware that using the Internet comes with inherent risks. No method of data transmission or method of physical or electronic storage can be guaranteed to be perfectly secure. There is some risk that an unauthorized third party may find a way to circumvent our security or that a transmission of your information over the Internet will be intercepted.
NewWell360 takes the measures stated above to provide a level of security appropriate to the risks of processing your information. You acknowledge and accept that we cannot guarantee the security of your information.
Aside from our efforts in securing your information, it is your responsibility to protect the security of your account credentials and keep your password confidential.
If you notice suspicious activity or believe that your account may have been compromised in some way, please contact us immediately at:
We may retain your information as required or permitted by applicable laws and regulations.
For example, if you are a resident of certain jurisdictions you may be able to request to have your personal information deleted. If your request is granted, we may still be required by medical laws to retain your health information for a period of time.
Your medical records will be retained by Company for a period of at least five (5) years, unless a longer period is required by state or federal law, after which they may be destroyed.
If you are younger than twenty-three (23) years of age on the date the records may potentially be destroyed, your records will be kept at least until you reach the age of 23 or as required by state or federal law.
“Shine the Light” Law (California Civil Code § 1798.83)
California law permits California residents to request certain details about how their information is disclosed with third parties for third-party direct marketing purposes. We do not share your information with third parties for their direct marketing purposes.
Privacy Rights for California Minors in the Digital World Act
If you are a California resident under the age of 18 and are a registered user of the Services, then you may request that we remove information you posted on the Services.
Please be aware that applicable state or federal law may prevent NewWell360 from deleting certain categories of information such as health information.
Request for removals should include a description of the specific posted information (including information that will allow us to confirm it was created and posted by you) and should be sent to support@NewWell360.com.
California Consumer Privacy Act of 2018 (CCPA)
If you are a California resident you have the following rights subject to certain exceptions:
· The right to know about what personal information in the last 12 months was collected, how it is used, and whether it is disclosed for a business purpose or sold to third parties;
· The right to request deletion of personal information;
· The right to opt-out of the sale of personal information; and
· The right to non-discrimination for the exercise of privacy rights.
NewWell360 does not sell your personal information within the normal meaning of the word, but we do use cookies, pixels, and similar technology to improve your user experience.
Like many websites, we share certain information, such as your IP address, device ID, click ID, or other similar online identifiers, with certain third-party advertisers in order to optimize our marketing activities and improve your user experience. This could be considered a “sale” under CCPA.
If you wish to opt out of this activity, you may do so here.
We will not discriminate against you for exercising your rights under the CCPA.
Please note that requests pursuant to the CCPA are limited to non-medical personal information as the CCPA does not apply to health information governed by the CMIA.
Before we approve your request(s), we will ask you to verify certain Personal Information that we have on file.
You may submit a request to access or delete your personal information by emailing support@NewWell360.com filling out our online form here.
You may designate an authorized agent to make a request on your behalf.
In order to designate an authorized agent, you or your authorized agent must provide written proof support@NewWell360.com that the agent has a valid power of attorney pursuant to California Probate Code sections 4000-4465 or by submitting a signed authorization form (available here).
The table below summarizes the categories of personal information we have collected in the last 12 months and the categories of third parties who we have disclosed personal information to for a business purpose.
The sources from which we collect personal information can be found in the above section entitled “Sources of Information.”
The purpose for collecting personal information can be found in the above section entitled “Use of Information.”
| Categories of Personal Information Collected (See Above Categories) | Categories of Third Parties (Disclosed to for a Business Purpose) |
|---|---|
| A. Identifiers | Affiliated Entities; Medical Providers; Service Providers (Customer Support/Feedback, Marketing Services, Payment Processing, Operating Systems, Website Optimization, Data Analytics) |
| B. Certain Personal Information (§1798.8) | Affiliated Entities; Medical Providers; Service Providers (Customer Support/Feedback, Marketing Services, Payment Processing, Operating Systems, Website Optimization, Data Analytics) |
| C. Certain Characteristics of Protected Classifications | Affiliated Entities; Medical Providers; Service Providers (Customer Support/Feedback, Website Optimization, Data Analytics) |
| D. Commercial Information | Affiliated Entities; Medical Providers; Service Providers (Marketing Services, Payment Processing, Operating Systems, Website Optimization, Data Analytics) |
| F. Internet or Network Activity Information | Service Providers (Customer Support/Feedback, Marketing Services, Operating Systems, Website Optimization, Data Analytics) |
| H. Certain Audio/Electronic/Visual/Similar Information | Affiliated Entities; Medical Providers; Service Providers (Operating Systems, Website Optimization, Data Analytics) |
| I. Professional/Employment-related Information | Affiliated Entities; Medical Providers; Service Providers (Talent Acquisition) |
| K. Inferences | Service Providers (Website Optimization, Data Analytics) |
Your information may be transferred to, and maintained on, computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.
If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including personal information, to the United States and process it there.
If you do not want your information transferred to or processed or maintained outside of the country or jurisdiction where you are located, you should not use the Services.
We may update this Privacy Notice from time to time and make changes to our information practices as permitted by law.
You can reference the date on the bottom to determine when this Privacy Notice was last updated.
Any changes will become effective when we post the revised Privacy Notice on the Services.
If you are registered for the Services, you will be notified of any material changes to this notice prior to them becoming effective.
Your use of the Services following this notice means that you acknowledge and accept the revised Privacy Notice.
If you have questions or concerns about this Privacy Notice, please contact us at support@NewWell360.com.
THIS NOTICE DESCRIBES HOW MEDICAL INFORMATION ABOUT YOU MAY BE USED AND DISCLOSED AND HOW YOU CAN GET ACCESS TO THIS INFORMATION. PLEASE REVIEW IT CAREFULLY.
This Notice of Privacy Practices (the “Notice”) tells you about the ways we may use and disclose your protected health information (“medical information”) and your rights and our obligations regarding the use and disclosure of your medical information.
“We” refers to, and this Notice applies to, [MD Integrations, Curexa Pharmacy], including, respectively, their providers and employees (“Medical Groups”).
(1) OUR OBLIGATIONS
We maintain the privacy of your medical information and notify affected individuals following a breach of unsecured medical information, in each case to the extent required by state and federal law.
We provide you this Notice explaining our legal duties and privacy practices with respect to medical information about you.
(2) HOW WE MAY USE AND DISCLOSE MEDICAL INFORMATION ABOUT YOU
The following categories describe the different ways that we typically use and disclose medical information, the purposes for such uses and disclosures, and the reasons for such uses and disclosures.
As noted below, we may contact you via different methods that you may approve, such as via text message, email, or through your NewWell360 account.
In most instances, your initial communication with the applicable Medical Group will be through an interaction with the Medical Group.
Specifically speaking, the applicable Medical Group may communicate with you in the following specific ways and for the following specific purposes:
Type & Purpose
· Email communications; To obtain information from you necessary to provide services to you, communicate with you about your diagnosis and treatment and provide you with information on special offers and deals
· Texts; To obtain information from you necessary to provide services to you and communicate with you about your diagnosis and treatment
· Customer Service Emails or text messages; To provide you with updates on problems with orders, late shipments, and other questions applicable to your provider visit(s)
· Tracking emails; To notify you when prescriptions have been shipped, will arrive, and other confirmations
· Order information; To provide information on content of orders (additional products or samples)
· Referral programs; To provide you with information on benefits you may receive if you refer another patient to the Medical Group.
Additionally, the applicable Medical Group may use and disclose your medical information for the following reasons. These categories are intended to be general descriptions only, and not a list of every instance in which we may use or disclose your medical information. Please understand that for these categories, the law generally does not require us to get your authorization in order for us to use or disclose your medical information.
· For Treatment. We may use and disclose medical information about you to provide you with health care treatment and related services, including coordinating and managing your health care. We may disclose medical information about you to physicians, nurses, other health care providers and personnel who are providing or involved in providing health care to you (both within and outside of the applicable Medical Group(s)). For example, should your care require referral to a pharmacy for the provision of prescription drugs, we may provide that pharmacy with your medical information in order to aid the pharmacist in his or her treatment of you.
· For Payment. We may use and disclose medical information about you so that we or may bill and collect from you, an insurance company, or a third party for the health care services we provide. This may also include the disclosure of medical information to obtain prior authorization for treatment and procedures from your insurance plan. For example, we may send a claim for payment to your insurance company, and that claim may have a code on it that describes the services that have been rendered to you. If, however, you pay for an item or service in full, out of pocket and request that we not disclose to your health plan the medical information solely relating to that item or service, as described more fully in Section IV of this Notice, we will follow that restriction on disclosure unless otherwise required by law.
· For Health Care Operations. We may use and disclose medical information about you for our health care operations. These uses and disclosures are necessary to operate and manage our practice and to promote quality care. For example, we may need to use or disclose your medical information in order to assess the quality of care you receive or to conduct certain cost management, business management, administrative, or quality improvement activities or to provide information to our insurance carriers.
· Quality Assurance and Utilization Review. We may need to use or disclose your medical information for our internal processes to assess and facilitate the provision of quality care to our patients. We may need to use or disclose your medical information to perform a review of the services we provide in order to evaluate whether that the appropriate level of services is received, depending on condition and diagnosis.
· Credentialing and Peer Review. We may need to use or disclose your medical information in order for us to review the credentials, qualifications and actions of our health care providers.
· Treatment Alternatives. We may use and disclose medical information to tell you about or recommend possible treatment options or alternatives that we believe may be of interest to you.
· Appointment Reminders and Information about Health Related Benefits and Services. We may use and disclose medical information, in order to contact you (including, for example, contacting you by phone and leaving a message on an answering machine) to provide appointment reminders and other information. We may use and disclose medical information to tell you about health-related benefits or services that we believe may be of interest to you. See also the specific types of communications noted above.
· Vendors. There are some services (such as billing or legal services) that may be provided to or on behalf of the Medical Groups through contracts with third parties, such as [MD Integrations, Curexa Pharmacy]. When these services are contracted, we may disclose your medical information to our vendor so that they can perform the job we have asked them to do. To protect your medical information, however, we require the business associate to appropriately safeguard your information.
· Individuals Involved in Your Care or Payment for Your Care. We may disclose medical information about you to a friend or family member who is involved in your health care, as well as to someone who helps pay for your care, but we will do so only as allowed by state or federal law (with an opportunity for you to agree or object when required under the law), or in accordance with your prior authorization.
· As Required by Law. We will disclose medical information about you when required to do so by federal, state, or local law or regulations.
· Other. Subject to applicable legal requirements, and where appropriate for your medical care or required by law, we may also use your medical information
(i) to avert an imminent threat of injury to health or safety,
(ii) for organ donation purposes, for research,
(iii) to appropriate military authorities if you are in the armed forces,
(iv) for workers’ compensation programs,
(v) for public health activities,
(vi) for health oversight activities,
(vii) for other legal matters,
(viii) for law enforcement purposes,
(ix) to coroners and medical examiners, or
(x) for marketing or fundraising purposes.
· Electronic Disclosures of Medical Information. Under the law of certain states, we are required to provide notice to you if your medical information is subject to electronic disclosure. This Notice serves as general notice that we may disclose your medical information electronically for treatment, payment, or health care operations or as otherwise authorized or required by state or federal law.
The medical information that you send to us via email or text message may not be secure. For this reason, we recommend that you communicate with us through the secure messaging feature within the NewWell360 platform.
If you choose to communicate with us via unencrypted email or text message, you acknowledge that there are risks associated with sending medical information through these communication methods. These risks include the possibility that your information may be intercepted by third parties.
By initiating communication with us via email or text message, you acknowledge and accept these risks.
Other uses and disclosures of medical information not covered by this Notice or the laws that apply to us will be made only with your written authorization.
If you provide us authorization to use or disclose medical information about you, you may revoke that authorization, in writing, at any time.
If you revoke your authorization, we will no longer use or disclose medical information about you for the reasons covered by your written authorization.
Please understand that we are unable to take back any disclosures that we have already made with your authorization, and that we are required to retain our records of the care that we provided to you.
You have the following rights regarding medical information we maintain about you.
You have the right to inspect and copy medical information that may be used to make decisions about your care.
Usually, this includes medical and billing records, but it may not include psychotherapy notes.
To inspect and copy medical information that may be used to make decisions about you, you must submit your request in writing.
If you request a copy of the information, we may charge a fee for the costs of copying, mailing, or other supplies associated with your request.
If you feel that medical information we have about you is incorrect or incomplete, you may ask us to amend the information.
You have the right to request an amendment for as long as the information is kept by or for the Medical Group.
To request an amendment, your request must be made in writing and submitted to the Medical Group.
In addition, you must provide a reason that supports your request.
You have the right to request an accounting of disclosures.
This is a list of the disclosures we made of medical information about you.
To request this list or accounting of disclosures, you must submit your request in writing.
Your request must state a time period which may not be longer than six years.
The first list you request within a 12-month period will be free.
For additional lists, we may charge you for the costs of providing the list.
We will notify you of the cost involved and you may choose to withdraw or modify your request at that time before any costs are incurred.
You have the right to request a restriction or limitation on the medical information we use or disclose about you for treatment, payment, or health care operations.
You also have the right to request a limit on the medical information we disclose about you to someone who is involved in your care or the payment for your care.
While we will consider your request, we are not required to agree to it unless the request meets specific legal requirements.
You have the right to request that we communicate with you about medical matters in a certain way or at a certain location.
For example, you may ask that we only contact you at work or by mail.
To request confidential communications, you must make your request in writing.
We will not ask you the reason for your request.
We will accommodate all reasonable requests.
You have the right to obtain a paper copy of this Notice.
You may request a paper copy of this Notice at any time.
To obtain a paper copy of this Notice, please contact us using the contact information provided below.
We reserve the right to change this Notice.
We reserve the right to make the revised or changed Notice effective for medical information we already have about you as well as any information we receive in the future.
We will post a copy of the current Notice on the NewWell360 website.
The Notice will contain the effective date on the first page.
If you believe your privacy rights have been violated, you may file a complaint with the Medical Group or with the Secretary of the U.S. Department of Health and Human Services.
To file a complaint with the Medical Group, please contact us using the contact information listed below.
You will not be penalized for filing a complaint.
If you have any questions about this Notice, please contact:
NewWell360
Email: support@NewWell360.com