Doctor On Demand by Included Health Privacy Policy

Effective Date: April 15, 2022

We are pleased to announce that Grand Rounds, Inc., Doctor On Demand, Inc. and Included Health Communities are now part of Included Health, Inc.

We are in the process of integrating our terms and services to provide more options and help you find the care you need, when you need it, regardless of which services you use. 

The use of the Included Health, Doctor On Demand, Grand Rounds, and Included Health Communities affiliated websites, and any of the related Included Health products and services linked to this document or described below (“Services”) unless otherwise specified), is subject to all of the terms, agreements, statements of rights, consent forms, and policies referenced and linked here, which applied prior to the integration to the Grand Rounds, Doctor On Demand, and Included Health Communities applications and platforms. 

We encourage you to read these documents to understand the terms, policies, and more that apply to you when you use our websites, products, or services, including how we process your personal information and how you can update and manage that information.

As we further integrate, our plan is to continue to update and consolidate these documents in the coming months to make it easier for you to understand what to expect from us—and what we expect from you—as you use our Services.


Doctor On Demand by Included Health Privacy Policy

Purpose Of This Privacy Policy

Included Health, Inc. (“Included Health”, “Company”, “we”, “us”, or “our”) operates the websites located at includedhealth.com and doctorondemand.com, and other websites, products, services, and mobile applications with links to this Privacy Policy, including without limitation the Doctor On Demand webpages and secure applications (collectively, the “Sites” or “Websites”, unless otherwise specified). Users of the Sites or Services are referred below as “Users”, “Members”, “you”, “your”, or “yours”.

We offer online telehealth services enabling our Members to report their health history and engage independent healthcare professionals (“Healthcare Professionals”) to obtain medical and healthcare services, as well as provide behavioral health coaching from Coaches (“Coaches”) who do not provide professional or clinical services.

The Healthcare Professionals who deliver Services through Included Health are independent professionals practicing within several groups of independently owned professional practices (collectively, “Doctor On Demand Professionals”). Please refer to the Doctor On Demand Professionals Notice of Privacy Practices to learn more about these groups and how they’re organized. 

When we use the term “personal information” in this Privacy Policy, we mean information that on its own, or in combination with other information, could reasonably identify you. Moreover, the personal information we receive or obtain through your use of the Services may be subject to different state and federal privacy laws, including the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”). Descriptions in this Privacy Policy regarding our collection, use and disclosure of personal information may be subject to or further restricted by the requirements of these laws. In addition, where Included Health collects, creates, maintains, uses and discloses Protected Health Information (“PHI”), which is personally identifiable health information protected by HIPAA, we may be and likely are subject to certain agreements, including with health plans and health care providers. In those cases, our collection, creation, maintenance, use and disclosure of PHI will be in accordance with such agreements and the applicable Notice of Privacy Practices. 

With that in mind, all collection, use, and disclosure of your health information or PHI through the Sites are governed by the Doctor On Demand Professionals Notice of Privacy Practices. References otherwise throughout this Policy to HIPAA, PHI, and related is provided for informational purposes. For official notices concerning, or for more information or questions about, the use and disclosure of your PHI, please refer to the Doctor On Demand Professionals Notice of Privacy Practices, or where applicable your health plan’s Notice of Privacy Practices.

This Privacy Policy discloses how Included Health collects, uses, and discloses your other personal information, that is not health information, both on its own and on behalf of the Doctor On Demand Professionals with respect to the Sites, as well as any other websites, mobile applications, or other products and services provided by Included Health that link to this Privacy Policy. 

Please read this Privacy Policy carefully before using the Sites or Services. By visiting or using any of the Sites or Services, you are accepting the practices described in this Privacy Policy, as well as the Doctor On Demand Terms of Use and other terms, agreements, statements of rights, consent forms, and policies referenced above, where applicable. If you do not agree to this Privacy Policy, or any of the documents referenced above, please do not use the Sites or Services.

Personal Information We Collect or Maintain May Include

  • Sites Activity Information. We track certain actions you take on the Sites such as the content of searches performed on the Sites and information that you enter into the Sites (e.g. your name and email address when signing up for an email newsletter, requesting more information about us and our Services, etc.).
  • Access Device and Browser Information. When you access the Sites from a computer or other device, we may collect information from that device, such as your Internet protocol address, browser type, connection speed, device model, operating system version, and access times.  
  • Cookies. We may use both session Cookies (which expire once you close your web browser) and persistent Cookies to make the Sites and Services easier to use, to make our advertising better, and to protect both you and Included Health. For more information about our use of Cookies and to opt out of performance, functionality, or targeting cookies please visit our cookie preference center.
  • Analytics Tools. We use tools such as Google Analytics, AppsFlyer and Mixpanel to help analyze how individuals use the Sites. Such third parties may use Cookies, APIs, and SDKs in our services to enable them to collect and analyze user and device related data and information on our behalf.  Google Analytics, AppsFlyer, and Mixpanel use Cookies to collect information such as how often users visit the Sites, what pages they visit, and what other sites they used prior to coming to the Sites. We use the information we get to improve our Sites and Services.  Although Google Analytics plants a persistent Cookie on your web browser to identify you as a unique user the next time you visit the Sites, the Cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to the Sites is restricted by the Google Analytics Terms of Use and the Google Privacy Policy.  You may prevent your data from being used by Google Analytics by downloading and installing the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout/.  Mixpanel’s ability to use and share information it collects about your visits to the Sites is restricted by the Mixpanel Terms of Use located at https://mixpanel.com/terms/ and the Mixpanel Privacy Policy located at https://mixpanel.com/privacy/. You can opt-out of Mixpanel’s automatic retention of data collected through your browsers while on our Sites by clicking on this link https://mixpanel.com/optout/. To track opt-outs, Mixpanel uses a persistent opt-out Cookie placed on your devices.  You can find out the types of information AppsFlyer collects and how you can opt-out of AppsFlyer by visiting its website: https://www.appsflyer.com/optout or by emailing privacy@appsflyer.com.
  • Certain features of the Sites use GPS technology to collect real-time information about the location of your device so that the Sites can connect you to a Healthcare Professional who is licensed or authorized to provide Services in the state where you are located. Strictly necessary and functionality Cookies are used on our Sites to support Sites functionality and security. These Cookies collect crash analytics and Sites activity data, as well as provide security measures.
  • We may collect information from your mobile device or computer including the type of device used to access the Sites, operating system version, and mobile device carrier. This information is used to identify and fix bugs and otherwise improve the performance of the Sites.

In many circumstances, the information listed above is non-personal information. For example, the information collected through Cookies may not contain any identifiable personal information. We will still treat that information as personal information under this Privacy Policy if (a) an applicable local law considers it to be personal information or (b) we combine it with personal information.

De-Identified Information

Included Health may use de-identified information created by us without restriction. When we use the term “de-identified information,” we mean information that is neither used nor intended to be used to personally identify an individual.    

Children 

Included Health does not knowingly collect or maintain personally identifiable information from persons under 18 years old, and no part of our Sites is directed to persons under 18. IF YOU ARE UNDER 18 YEARS OF AGE, PLEASE DO NOT USE OR ACCESS OUR Sites AT ANY TIME OR IN ANY MANNER, except where allowed in accordance with our Terms of Use. Where permitted, any personal information relating to those children will be health information governed by the Doctor On Demand Professionals Notice of Privacy Practices

If you are a parent or guardian and discover that your child under the age of 18, or equivalent minimum age depending on jurisdiction, has obtained an Included Health account, then you may alert us at the contact information below under “Contact Us”, and request that we delete that child’s personal information from our systems. If we learn that we have collected the personal information of a child under 18, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible, except where prohibited by applicable law.

We May Use Your Personal Information For The Following Purposes:

  • To provide you with the Sites and full functionality on the Sites.
  • To notify you when Sites updates are available.
  • To market and promote the Sites and the Services to you.
  • To create de-identified information such as aggregate statistics relating to the use of the Sites.  
  • To fulfill any other purpose for which you provide us personal information.  

We may also disclose personal information that we collect or you provide:

  • To our subsidiaries, affiliates, and associated organizations.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential.
  • As required by law, which can include providing information as required by a court order.
  • When we believe in good faith that disclosure is necessary to protect your safety or the safety of others, to protect our rights, to investigate fraud, or to respond to a government request.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Included Health’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information maintained by the Sites is among the assets transferred.
  • For any other purpose disclosed by us when you provide the information.

Disclosure To Third Parties 

At times, Included Health may provide third parties with certain personal information to provide or improve our Sites or Services, including to help us market to consumers. When we do, we require those third parties to handle it in accordance with applicable laws. We do not sell personal information, and personal information will not be shared with third parties for their marketing purposes.

This Privacy Policy applies only to information we collect through the Sites. This Privacy Policy DOES NOT apply to information collected by any third party. When you click on links on the Sites you may leave our Sites. We are not responsible for the privacy practices of other sites, and we encourage you to read their privacy statements.

Modification Of Information

Members will be able to update some of their information through the Sites. Requests to modify any information may also be submitted to Included Health using the below contact information under “Contact Us”.

Limitations On Deletion of Information 

You may request deletion of your personal information by Included Health, however, we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete personal information, it will be deleted from the active database, but may remain in our archives (subject to applicable law) and we may also retain anonymous information about your use of our services. Once we disclose some of your personal information to third parties, we may not be able to access that personal information any longer and cannot force the deletion or modification of any such information by the parties to whom we have made those disclosures. After we delete personal information, we may retain de-identified information and will continue to use de-identified information as permitted under this Privacy Policy.

Steps We Take To Keep Your Information Secure

Included Health employs reasonable physical, electronic, and managerial security methods to help protect against unauthorized access to personal information, such as encryption. But please be aware that no data transmission over the Internet or data storage facility can be guaranteed to be perfectly secure. As a result, while we try to protect your personal information, we cannot ensure or guarantee the security of any information you transmit to us.

Right to Non-Discrimination

Included Health will not discriminate against you for exercising any of your privacy rights under law, or as set forth in this Privacy Policy.

California

In addition to the rights above, the California Consumer Privacy Act (“CCPA”) provides California consumers with the right to obtain from Included Health information about the personal information about you that we collect, use, and disclose. If you choose to exercise your privacy rights, you will not receive discriminatory treatment or a lesser degree of service from us.

At Included Health, member and consumer privacy are very important to us. As a result, before we process any requests we first must verify your identity and ensure we have enough information. To exercise rights described in this section or elsewhere in the Privacy Policy, you must submit to us a “verifiable request”, including by:

  • providing sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and
  • describing your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

With that in mind, at this time:

  • Requests from Members are considered verified if submitted using our Services. If you are an existing Member, please submit your request either by calling us and confirming your identity, or by submitting via the application (e.g., using the chat service, or via an open case). If, however, there is indication or suspicion of fraud or other malicious activity on the Member’s account, we may suspend reliance on these verification methods and defer to other methods to confirm authenticity. 
  • You may alternatively contact us via the information provided below under “Contact Us”. However, please note that emailed requests are not considered verified, and we may request additional information from you (that we would already have in our records) in order to confirm your identity. 
  • We may also recognize verified requests submitted on an individual’s behalf by “Authorized Agents”. To be valid, we must receive from the Agent a signed authorization from the individual on whose behalf the Agent is acting. We will also need to verify the authorization with the consumer.
  • For “household” requests subject to the CCPA, we will need to verify each household Member’s individual identity and current status as household members.
  • And we will not process any requests of children under 13 years of age without verifiable consents from their parents or legal guardians. 

You can submit a maximum number of 2 requests over a period of 12 months.

We will not respond to or process any unverified request.  This is all done to protect your confidentiality and ensure, to the best of our ability, that we only process such requests for the right persons. 

Changes To The Privacy Policy

Includes Health’s Sites are continually under development and changes to the Sites or Services may be made at any time. We reserve the right to revise or remove any part of this Policy in its sole discretion at any time and without prior notice to you by updating this posting, unless such notice is required by relevant law or regulation. Thus, you should visit this page periodically for changes. Any changes to this Policy are effective upon posting to the Sites, unless otherwise specified. If you disagree with the Policy, your sole remedy is to discontinue your use of the Sites and Services. Your continued use after a change has been posted constitutes your acceptance of the changes.

All capitalized terms in this Privacy Policy not defined herein shall have the meaning set forth in our Terms of Use.  

Contact Us

If you have questions or concerns about this Policy or our Privacy Practices, want to submit a request, or would like to report a violation, see the below contact options:

  • You may contact us by mail at:

Included Health, Inc., Privacy Officer
1 California Street, Ste. 2300
San Francisco, CA 94111

  • You may email us at privacy@includedhealth.com
  • If you are registered, you may submit a message through the “chat” experience once logged-in.
  • Or you may call our general support toll free line at (855) 431-5533.