Last Updated/Effective Date: January 9, 2024
OtisHealth, Inc. is committed to preserving the privacy of your personal and medical information. Our Privacy Policy explains what information we gather, use and share when you use our website adli-ad.com and the ADLi mobile application (collectively, “ADLi” or the “Platform”).
Acceptance of Privacy Policy
By using ADLi, you agree to the terms of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use ADLi. We may update our Privacy Policy from time to time, and your continued use of the Platform means that you agree to those changes.
Information We Collect and How We Collect It
As part of this Platform, we collect the below certain information from patients, caregivers, and healthcare providers as noted below.
Personal Information
For Healthcare Providers: We collect your name, mailing address, e-mail address, mobile phone number, your individual National Provider Identifier (NPI), your practice specialty, the name of your affiliated medical practice/organization, and your medical practice/organization NPI. We collect this Personal Information when you register as a Healthcare Provider on ADLi.
For Patients/Caregivers: We collect your name, mailing address, e-mail address, phone number, date of birth, your gender, and your relationship to the patient if you are a caregiver. We collect this Personal Information when you are enrolled as an ADLi patient or caregiver.
Health Information
For Patients/Caregivers: We collect your health information including your diagnoses, Activities of Daily Living, and information identifying your healthcare providers.
We collect your health information in the following ways:
- you may manually enter your personal and health information into the Platform such as your medical conditions, healthcare providers and medical institutions where you have received care,
- if applicable, you may direct the Platform to connect to the electronic record systems of your healthcare providers, laboratories, pharmacies, and health plans in order to request, retrieve, and share your electronic health records,
- you may directly upload electronic health records, files, and other health documents.
- you may provide permission for the Platform to access data and applications on your mobile device, such as your camera, photos, contacts, and health monitoring devices.
For Healthcare Providers: The information collected and processed regarding your patients will be governed by both this Privacy Policy and a Business Associate Agreement with OtisHealth.
Information Automatically Collected
Account Activity. We may collect data about how you use your online account and the Platform when you are logged into your account. We may use IP addresses to conduct website analyses and performance reviews and to administer our website.
Cookies & Other Tracking Technologies.
A cookie is a small text file that our Platform saves onto your computer or device when you use the Platform that provides us certain information about your activities. Other tracking technologies like web beacons/pixel tags are small graphics on a webpage that monitor your activity when viewing a webpage.
These tools (collectively, “Cookies”)
- allow the Platform: to remember your actions and preferences and recognize you or your browser, along with some information you provided.
- allow us to provide you with a more personalized experience.
Cookies may collect information such as your device’s IP address, location and pages visited. Most browsers automatically accept cookies, and you can manually delete Cookies through your browser settings. Also you can disable this function by changing your browser settings, but disabling cookies may impact your use and enjoyment of the Platform. Not all features or functions of the Platform may work properly if you disable Cookies. You cannot disable all Cookies, such as Cookies that are essential to the functioning of the Platform.
CALIFORNIA’S “DO-NOT-TRACK” REQUIREMENT. WE CURRENTLY DO NOT HONOR “DO NOT TRACK” REQUESTS.
Web Analytics. We use 3rd party web analytics tools and services to collect and process information about your use of OtisHealth. These tools and services set cookies on your browser or device, and then your web browser will automatically send information to us. We use this information to better understand and measure how users interact with the Platform.
Online Behavioral Advertising. We do not use third parties and/or service providers to provide interest-based advertising services.
How We Use Your Information.
We collect and use your identifiable data and information for the following purposes:
- To provide the primary service of the Platform.
- To verify your identity before we begin collecting your health information and records. For example, we use your phone number to send you text messages for multi-factor authentication and other security measures. Additional verification information may be required by healthcare providers before they release your electronic health records to you.
- To respond to your questions, comments, or complaints. We may also use personal information as requested or consented to by you.
- To locate your health records and assist healthcare providers with accurately verifying and sending us your correct health records for your account.
- To support company operations like quality control, fraud detection and developing new products and services.
- To notify you of new features, services or products.
- To conduct research, education and training.
- To fulfill internal business purposes such as data analysis, audits, identifying usage trends, and improving our services.
- To comply with any applicable legal or regulatory obligations.
Storage of Data
We store your data on your device. We also store your data outside the device at our company or through third party secure cloud storage services.
Encryption of Data
We automatically encrypt your data in the device or app. We automatically encrypt your data when stored on our company servers or with outside cloud computing service providers. We automatically encrypt your data while it is transmitted.
Retention of Information
Unless a longer retention period is permitted or required by law, when your account is deactivated/terminated by you or OtisHealth, your data will be deleted after 90 days so it is important that you download the records inputted by you (or in the case of healthcare providers, the records of your patients) for future use and retention.
Disclosure and Sharing of Your Information
We do not sell, rent or lease any of your identifiable or non-identifiable (data in which personal identifiers have been removed) personal information to any third party. We do not share your identifiable data. We may share personal information and data only after removing identifiers (note that remaining data may not be anonymous) for the purposes of providing the primary service of the app or technology, supporting company operations and developing and improving new and current products and services. Such identifier-removed information may be also be shared with the following parties, in compliance with applicable laws:
Client Partners. Though the underlying Platform has been developed by OtisHealth, the ADL Tracker itself is being delivered to users in collaboration with Eisai Inc. Accordingly, we may share personal information, de-identified health information, and de-identified and aggregated data with Eisai Inc. (together with its parents, affiliates and subsidiaries, collectively, “Eisai”). Eisai may use the information for the same purposes outlined above under “How We Use Your Information” and does not sell your information.
Employees and Affiliates. We may share personal information with our employees and affiliates who have a need to know the information for our business purposes.
Third-Parties and/or Service Providers. We may share personal information with third party contractors and/or service providers that provide services for us. For example, we may share personal information with cloud storage providers, e-mail marketing vendors, security vendors, and data analytics vendors.
Clinical Trial Organizations/Research Partners. We may provide your de-identifiable personal and health information to a clinical trial organization or research partner for the purpose of finding potential study candidates. If OtisHealth notifies you that you qualify for a specific clinical research opportunity, and you request to participate, with your permission, we will share your personal information, including necessary health information and records, with the sponsoring clinical trial organization or research partner to match you with a specific clinical trial or research study.
Government Officials/Law Enforcement. We will cooperate with law enforcement and other governmental agencies, and may disclose personal information: (i) if we believe in good faith we are legally required to disclose that personal information, (ii) if we are advised to disclose personal information by our legal counsel, or (iii) when necessary to identify, contact or bring a legal action against someone who may cause or be causing harm to, or interfering with the legal rights of, OtisHealth or any other party.
Professional Advisors. We may share personal information with our professional advisors, such as our attorneys, accountants, financial advisors and business advisors, in their capacity as advisors to OtisHealth.
Change in Ownership. In the event OtisHealth is the subject of a change of control or in the event the Platform changes ownership, in whole or in part, or in the event of a bankruptcy, receivership or a similar transaction, we may provide personal information to the subsequent owner(s).
Other. We may share personal information with third parties when explicitly requested by or consented to by you, or for the purposes for which you disclosed the personal information to us as indicated at the time and point of the disclosure (or as was obvious at the time and point of disclosure).
Social Media. This Platform does NOT allow you to share the collected data with your social media accounts, like Facebook.
Use and Disclosure of Non-Personal Information.
OtisHealth may collect, use, share, transfer and otherwise process de-identified and aggregated information that it receives or creates for any purposes in its sole discretion, in compliance with applicable laws. OtisHealth is the sole and exclusive owner of such de-identified and aggregated information, including if OtisHealth de-identifies personal information so that it no longer considered personal information under applicable laws.
Children’s Information. Our Platform is not directed at children under 18 years of age, nor is it intended to be used by users under 18 years of age. We do not knowingly collect, use, or share personal information from children under 18. If a parent or legal guardian learns that their child provided us with personal information without his or her consent, please contact us and we will make commercially reasonable attempts to delete such personal information.
Data Security
We use commercially reasonable technical and organizational measures to help secure personal information against loss, misuse, and alteration appropriate to the type of personal information processed. If a breach of your personal information occurs, Members affected by a data breach will be notified via secure message center and an email. Passwords for affected accounted will be invalidated and will require new passwords to be established. Any data deleted or corrupted by a bad actor (i.e. hacker or malicious software) will, if possible, recovered from secure back-up servers. Public disclosure of any data breach will be made as required by FTC Health Data Breach regulations.
YOU UNDERSTAND THAT NO DATA TRANSMISSION OVER THE INTERNET OR DEVICE CAN BE GUARANTEED TO BE 100% SECURE. WHILE WE STRIVE TO PROTECT PERSONAL INFORMATION, WE DO NOT GUARANTEE THE SECURITY OF PERSONAL INFORMATION AND YOU PROVIDE PERSONAL INFORMATION AT YOUR OWN RISK.
Access from Outside the United States
If you access the Platform from outside the United States, please be aware that personal information may be transferred to, stored in, and processed in the United States. Certain governmental authorities may not consider the level of protection of personal information in the United States to be equivalent to that required by the in other jurisdictions.
Third-Party Websites
The Platform may link to, or be linked to, websites not controlled by us. We are not responsible for third-parties’ privacy policies or practices. This Policy does not apply to any third-party websites or to any data that you provide to third parties. You should read the privacy policy for each website that you visit.
Access, Update or Delete Your Information
Consistent with the laws of your state, this platform allows you to access, edit, share or delete the data we have about you. Data sharing may only occur using the Platform and only to other users and individuals to whom you have authorized access. To access or update your personal information as it exists in our records, please visit your account or contact us using the information below.
Content Provided is NOT Medical Advice and is For Informational Purposes Only
All content found on the Platform including text, images, audio, or other formats were created for informational purposes only. The content is not intended to be medical advice or a diagnosis. The content is not a substitute for professional medical advice, diagnosis, or treatment. Always seek the advice of your physician or other qualified health provider with any questions you may have regarding a medical condition. Never disregard professional medical advice or delay in seeking it because of something you have read on this platform. Links to content not created by OtisHealth are taken at your own risk. OtisHealth is not responsible for the claims of external websites and education companies.
If you think you may have a medical emergency, call your doctor, go to the emergency department, or call 911 immediately. OtisHealth does not recommend or endorse any specific tests, physicians, products, procedures, opinions, or other information that may be mentioned on the website or app. Reliance on any information provided by OtisHealth, is solely at your own risk.
Use By Non-Residents
This Privacy Policy is intended to meet the laws and regulations of the United States, which may not necessarily be consistent with the laws and regulations of your home country. Any information that you provide OtisHealth will be treated in accordance with this Privacy Policy, the Terms and Conditions, and U.S. laws. The Platform is not intended for use outside the United States.
Contact Us
If you have questions or concerns regarding this Policy, contact us at:
OtisHealth, Inc.
21707 Stevens Creek Blvd. #1442, Cupertino, CA 95015 USA
Privacy Policy: www.adli-ad.com/privacy
Contact Form: www.adli-ad.com/contact
Email: privacy@adli-ad.com
Phone: (408) 320-6330