Effective Date: May 2020
Revision 1: 18th September 2022
Revision 2: 10th November 2022
Our mission is to drive better and more affordable healthcare through innovative software and information solutions for providers throughout the care continuum, their patients, and health researchers. Our solutions include our Patient appointment management solution, Practitioner digital visibility solution and Tele-Medicine (Video consulting) solution.
Some of our users - such as Medical Practitioners - are subject to laws and regulations governing the use and disclosure of health information they create or receive, including the Health Insurance Portability and Accountability Act of 1996, as amended from time to time, together with the regulations adopted thereunder ("HIPAA"). When we store, process or transmit "individually identifiable health information" (as defined by HIPAA) on behalf of a Medical Practitioner who has entered into a SPIRALS HEALTH TERMS AND AGREEMENT, we do so as its "business associate" (as also defined by HIPAA). Under this agreement, we cannot use or disclose individually identifiable health information in a way that the provider itself may not. We are also required to, among other things, apply reasonable and appropriate measures to safeguard the confidentiality, integrity, and availability of the individually identifiable health information we store and process on behalf of such providers. For this Policy, the term "Medical Practitioner" means any user who is a "health care provider" or “Doctor” (as defined by HIPAA) or any user who is a member of such health care provider's "workforce" (as also defined by HIPAA).
Collection of Information and Usage of Information:
SPIRALS Health will collect information from you when you:
We also collect information on your behalf when you authorize us to retrieve and import information from another user or other third party within our Service or as outlined in the Terms and Agreement.
Personal Data or Information:
Payment Information: Depending on the Services you use, we may also collect your billing information, including credit or debit card account information, or other forms of payment ("Payment Card Information"). By submitting your Payment Card Information, you expressly consent to the sharing of your information with third-party payment processors and other third-party services (including but not limited to vendors who provide fraud detection services to us and other third parties). These third parties may store your Payment Card Information for future use in our Services. We do not store your Payment Card Information, nor do we have direct control or responsibility for your Payment Card Information. The third-party services that we utilize are contractually obligated to keep your Payment Card Information secure and confidential.
Automatically Collected Information:
We and our partners automatically gather information whenever you visit, log in, or otherwise interact with our Services, including when you receive emails delivered via our Services. We and our partners use the technologies described below and similar technologies that may not be expressly described (which we collectively call " Engagement Solutions ") to gather this information to enhance and operate our Services in several ways, such as to:
Even if you do not register with us or submit any information on our Services, our Engagement Solutions will automatically receive information about, and the software running on, the computer, mobile phone, or tablet (each, a "Device") you use to interact with our Services.
Device Information: When you interact with our Services, we collect information about your Device such as the URL of services your Device is requesting and the referring web pages, your IP address, Device type, operating system, browser type, application identifier, and, under certain circumstances, the location information your Device sends to us.
Cookies & Similar Technologies: We and our partners collect information about you and your Devices through cookies, web beacons, and similar technologies. A "cookie" is a small data file sent from a website and stored on your Device to identify your Device in the future and allow for an enhanced personalized user experience based on your previous activity on the website. A "session cookie" disappears after you close your web browser, or may expire after a fixed period. A "persistent cookie" remains after you close your web browser and may be accessed every time you use our Services. We and our partners may use both session and persistent cookies on our Services. You should consult your web browser to modify your cookie settings. Please note that if you delete or choose not to accept cookies from us, you may not be able to use certain features of our Services.
Some of our partners deploy these technologies directly on our Services. These third parties may collect information over time about your use of our Services, as well as your online activities across other websites or online services. Some third parties may allow you to opt out of targeted advertising based on this information.
Information from Other Sources:
We may receive or proactively gather information about you from other sources and add it to information we otherwise have about you for any purpose described in this Policy. This may include situations where a third party seeks to communicate with you through the Services or establish an "Integration" (as more fully described below under the heading, Third Party Integrations).
How We Use Information
We may use the information we collect for the following purposes:
How our Services Allow Users to Share Information:
Our Services can be used to facilitate one-on-one communications between users and other persons. Examples include:
In any one-on-one communication, users are sending information to one another or to an individual or entity who may not be a user of the Services. Depending on the message, this could include the sharing of contact and other personally identifiable information.
Directories and Personal Website:
If you are a Medical Practitioner who has entered into a SPIRALS HEALTH TERMS AND AGREEMENT, you will have the ability to have your contact and directory information listed in one or more of our professional directories of Medical Practitioners on our Services that users and/or the general public may be able to view. These directories include profile information (e.g., contact, speciality and other information) and other features that allow users and/or the general public to locate and contact those listed in the directory.
SPIRALS Health provides a system-generated website for every Medical Practitioner on SPIRALS Health subdomain. These sites are renewable every year with service renewal by the Practitioner.
Medical Practitioners can add, update or remove content, photos, blogs, articles, clinical information, awards and recognitions, educational information and so on from the website by themselves through SPIRALS Health's provided simplified tool.
If you visit our Services seeking to contact or schedule an appointment with a provider listed in one of our directories, you may need to submit personally identifiable and other information.
Our Services include public forums that allow users to communicate with groups of users or the general public. Information, Blogs, Informative Videos and articles posted by any user in one of our communities may be available to a wide range of individuals and should be presumed public. We strongly advise users to exercise care in selecting what information they share with our communities or public forums, and strongly recommend against sharing any personally identifiable, health, or other sensitive information that could directly or indirectly be traced to any individual, including themselves.
Surveys, Feedback, and Informational Programs:
From time to time you may receive survey requests through emails or displays within our Services that request feedback on a variety of topics. These programs may be sponsored or funded by third parties and may include branded or unbranded content about medical conditions, treatments and products, or safety and regulatory information resources. If you choose to engage with or use one of these requests, you may be asked to provide information that may be used to supplement the information that you submitted to our Services. This information may be shared with the sponsor of the program.
Our Services allow users to store personally identifiable health information ("Records"), including Records that identify other individuals, including other users. Certain of our Services permit users to share all or portions of these Records at their discretion. Such Records are not mandatory and are at the discretion of the user to create or not to create.
You should be aware that this Policy covers only the information you submit through our Services. If you contact or exchange information with another user in person or through a means other than our Services, such activity is not covered by this Policy. Because our Services enable users to share information you share with them, you should take care in selecting with whom you share your Records and other information. Although our Services process such transmissions, we are not responsible for the actions of persons with whom you share your Records and other information.
Emails and Other Communications:
Our Services allow users to communicate with others through our in-product instant messaging services, Service-branded emails, and other electronic communication channels. Communications that are sent by or on behalf of a user are indicated as being "From" that user, such as when our Services send an appointment notification from, and on behalf of, a Medical Practitioner to his or her patient. Additionally, we may communicate administrative or Service-related announcements through email or other communications within our Services. These communications may be "real-time" communications triggered automatically upon certain events or dates, such as a repeated sign-in failure or an appointment notification. Please note that you may not be able to opt-out of receiving certain messages from us.
Emails and other communications from individuals who are not users of our Services, or that we send in connection with business agreements or subject matter other than the User Agreements, are not covered by this Policy. If, for example, you contact us regarding a job opening, that communication to us is not covered by this Policy even though that job opening may have been posted on our Services.
Sharing of Information
We may share the information you submit to us with third parties under the following circumstances:
To help prevent unauthorized access, maintain data accuracy, and protect against the inappropriate use of the information we collect, store, and transmit, we deploy a range of technical, physical and administrative safeguards. Under our SPIRALS HEALTH TERM AND AGREEMENT and applicable law, we are required to apply reasonable and appropriate measures to safeguard the confidentiality, integrity, and availability of individually identifiable health information residing on, and processed by, those elements of our Services that we operate as a business associate on behalf of Medical Practitioners. However, it is important to remember that no system can guarantee 100% security at all times. Accordingly, we cannot guarantee the security of information stored on or transmitted to or from our Services.
Permissions required by Mobile App (Android and iOS)
Users of SPIRALS Health are having apps for their simple usage. These Apps need certain permissions for the purposes mentioned here. SPIRALS Health Apps may request permissions as below:
To download and store the prescription/lab reports of the User
This Policy applies only to our Services. It does not apply to services offered by third parties, including websites and other online services that our Services may display links to or to advertisements appearing within the Services. When you click on such links or advertisements, you will be visiting websites or interactive services operated by third parties, who have their information collection practices and may also collect information through the use of Engagement Solutions. We do not have control over how any third party collects or uses information, so you should review their privacy policies to learn of their practices.
Changes to this Policy
We believe in continuous innovation, which, along with changes in our business, may require that we amend this Policy from time to time. We will post a revised Policy along with its effective date on this page. Because this Policy can change at any time, we encourage you to reread it periodically to see if there have been any changes, amendments, or updates. If you object to the changes or any terms within this Policy or the User Agreements, you should discontinue using our Services. Your continued use of our Services following the effective date means that you have consented to the Policy, as amended, changed, or updated.
Viewing and Updating Your Information
Our Services aim to provide you with access to the information you submit and the means to update it within our Services consistent with applicable law. This can be accomplished by logging into our Services and updating that information, or contacting a customer support representative, although please be advised of the important limitations described below. Under certain circumstances, we may ask you to verify your identity before your request is processed.
Please note that, unless you have administrative rights over another user's account under our SPIRALS HEALTH TERM AND AGREEMENT, you are not entitled to access, update, or delete the content of another user's account.
If you have used our Services to share information with another user or a third party, you will not be able to access, update, or delete that shared information. Further, if another user of our Services submits information that identifies you, you will not be able to access, update, or delete that information.
Certain users - such as Medical Practitioners - may be required under applicable laws or regulations to retain information about you for an extended period or indefinitely. Additionally, we may have independent obligations under applicable laws or regulations to retain such information indefinitely. Finally, for disaster recovery and business continuity purposes, we retain copies of data stored by our Services for indefinite periods.
HIPAA grants patients certain rights to access and amend certain health information that their Medical Practitioners retain about them. Patients should submit requests to access or amend their health information directly to their Medical Practitioners.
If you have questions regarding this Policy, please contact us at: