We have the highest regard for your privacy and personal information and realize that the success of our services depends on the trust that you have in the way we handle your personal information. By entrusting us with your information, we would like to assure you of our commitment to keep such information private. We have taken considerable steps to protect the confidentiality, security and integrity of this information. We encourage you to review the following information carefully.
“Service” or “MyCabinet Services” refers to the online platform which includes, but is not limited to, cabinet contents, medication management, caregiver engagement and communication, and drug interactions, provided through your MyCabinet Account access.
“Account” refers to the personal profile(s) and associated cabinet(s) You create after registering for access to the MyCabinet Services.
“Caregiver” is referred to herein as any individual responsible for, or who has limited or full access to another individual’s Account (profile and associated cabinet(s)), which includes but is not limited to: access to said individual’s medications, communications, drug interactions, refills and reminders.
We are required by law to maintain the privacy of your health information (“Protected Health Information” or “PHI”) and to provide you with this Notice of our legal duties and privacy practices with respect to your PHI. We are also obligated to notify you following a Breach of unsecured PHI. When we use or disclose your PHI, we are required to abide by the terms of this Notice (or other notice in effect at the time of the use or disclosure).
Processing of your Personal Information (meaning, any information which may potentially allow your identification with reasonable means; hereinafter “Personal Information”) is necessary for the performance of our contractual obligations towards you and providing you with our Service, to protect our legitimate interests, to ensure compliance with legal and financial regulatory obligations, or otherwise, subject to your consent.
TYPES OF INFORMATION WE COLLECT
- Personally Identifiable Information. We collect information by which you may be personally identified and traced back to you, such as name, postal address, e-mail address, telephone number, sex assigned at birth, date of birth, profile image/photo, known health characteristics and medical needs, or any other identifier by which you may be contacted online or offline (“Personal Information”). Personal Information may relate to you, or it may relate to the individual that is the subject of any profile that you create, if you create a profile for a child in which you are the parent or legal guardian, for example. If you are a healthcare provider, you may be asked to provide information regarding your professional qualifications as well as additional Personal Information.
- Protected Health Information (“PHI”). PHI is defined by the Health Insurance Portability and Accountability Act (definition available here: https://www.hhs.gov/answers/hipaa/what-is-phi/index.html ), and is subject to special rules under a federal law called the Health Insurance Portability and Accountability Act of 1996 or “HIPAA“, for shor You may choose to input your PHI with respect to your health, including but not limited to: the prescription and non-prescription medications you take, the medical devices you use, the date of your prescriptions, the number of refills, how often you take, skip or delay your medication, your dosages, your physical measurements, your vital readings, your health conditions and allergies, your doctors’ names, your insurance, the health services in which you partake, any information related to your health insurance, and the name of your pharmacies. PHI may relate to you, or it may relate to the individual that is the subject of any profile that you create, for example if you create a profile for a child, or dependent in which you represent and warrant that you are the parent or legal guardian with a right to provide us the Protected Health Information of said child or dependent.
- Caregiver Information. You may provide us with Personal Information of a third party Caregiver, to access your Account that you’ve created. If you elect to invite any third party to access your profile connected to your Account, we may ask you for the third party caregivers name, email address, phone number and/or their relation to you. We will send the third party emails inviting him or her to register for the MyCabinet Services. We store this information for the sole purpose of sending this one-time email. The third party may contact us at email@example.com request that we remove this information from our database. We cannot control whether such third party will elect to register for the MyCabinet Services.
- Geolocation and Technology Data. We may collect internet and network activity information such as IP address, device information, log data, cookies of similar technologies, date/time stamps associated with your usage, and geolocation information for transactional, pharmaceutical or telehealth purposes.
- Voluntary Information. Any information you provide voluntarily to us via communications, including but not limited to email, text, phone calls or free form text boxes.
- Site Usage Data. We collect information about the details of your visits to our Service such as your equipment, browsing actions and patterns, including but not limited to: traffic data, type of computing or mobile device you use, language of your operating system, location data, logs, IP address and the internet browser you are using.
HOW WE COLLECT INFORMATION ABOUT YOU
We may collect Personal Information and Protected Health Information using the following methods:
- Registering for MyCabinet Services. If you choose to create an Account or provide access to your account to another individual, all data entered will be collected by MyCabinet, which includes but is not limited to: personal information, medications, communications, pharmaceutical requests and refills, reminders, health alerts, drug interactions and any other information provided by you or authorized third parties.
- Information Submissions. If you submit any Personal Information or Protected Health Information to us through alternative means, including but not limited to telephone, mobile text or email communication with customer service, or information through a third party to whom you are affiliated with and is, was, or is in the process of partnering with MyCabinet in an effort to provide you with our Service.
- Third Parties. Through third parties we partner with or leverage through the MyCabinet Service platform, including but not limited to virtual care management services, pharmaceutical companies, employers, healthcare providers, and licensed medical professionals, in order to provide you with our Service.
- Business Partners and Vendors. We may collect your Personal Information or Protected Health Information with a limited number of partners, service providers, and other persons/entities who help run our business (“Business Partners”). We may enhance your information on MyCabinet with information from such Business Partners, including professional and contact information, medical information (such as conditions, prescriptions, medical device readings, health history), demographic information, interest information, information regarding any designated caretaker(s) including but not limited to personal and contact information for such caregivers. For healthcare providers who are participants in the MyCabinet Services we may also enhance your information through any means in which you have given permission to have your information shared with MyCabinet.
- Tracking Technologies. Automatically through tracking technologies such as cookies, web beacons (also known as pixels) and log files, including over time and across third-party websites or other online services. A cookie is a piece of information that your web browser stores on your device at the request of certain websites when you access the website. Cookies are useful because they allow a website to recognize a user’s device, navigate between pages efficiently, remember preferences and generally improve the user experience. They can also be used to tailor advertising to your interests through tracking your browsing across websites. If you do not agree to the use of certain cookies, you may choose whether to accept them by following the instructions for your browser
HOW WE USE INFORMATION ABOUT YOU
We do not sell your Personal Information or Protected Health Information. We may use your Personal Information and Protected Health Information for a variety of health and business activities, which may include:
- Website Functionality. To provide the functionality of the MyCabinet Services to you.
- Managing User Profiles and Accounts. We may use your information to create user profiles and accounts, or otherwise manage your account.
- Communicating with You. We may use your information to communicate with you on websites, mobile applications, and third-party platforms, as well as via text messages, emails, direct mail, and other forms of communication. This includes sending administrative information to you to fulfill the terms of any agreement you have with MyCabinet.
- Marketing Purposes. To provide you with newsletters, updates and/or other marketing materials, including marketing-related emails with information about MyCabinet Services, including for example the MyCabinet reward points.
- Aggregated Data. We may de-identify and aggregate Personal Information or Protected Health Information. Aggregated data will not contain any information that could be used to contact or identify you, which means it will no longer be considered Personal Information. We may analyze and/or combine all information we receive, including Protected Health Information and information regarding your use of the Service, with information from other users to create aggregated data that may be disclosed to and utilized by us, our partners and by third parties without restriction, on commercial terms that we can determine in our sole discretion, for purposes such as: content marketing, research purposes, in order to understand behavior patterns, in order to increase adherence to medication regimens, marketing strategies and for entering into commercial contracts in order to provide our users with the Service.
- Business Operations. We may use your information to understand your use of our Services in order to consider improving them, including to provide, change, market, or optimize our services and products, to perform analytics and to create new services and products. We also may use your information to determine whether applicable policies and terms are being violated.
- Security and Auditing. We may use your information to audit interactions with you, count ad impressions, detect security incidents, protect against fraud or other malicious activity, and identify and repair errors that may arise.
- Complying with Law. We may use your information to comply with applicable laws, including as required by judicial or administrative proceedings.
WITH WHOM WE SHARE YOUR PERSONAL AND PROTECTED HEALTH INFORMATION
In certain circumstances, we may share your Personal Information and/or your Protected Health Information with the following categories of service providers and other third parties for the indicated business purposes, as well as those to whom you choose to share your personal and protected health information:
- In the event that a Caregiver (or third-party) registers for access to the MyCabinet Services pursuant to an invitation issued by your Account, or accepts an invitation issues by your Account to view your Account and cabinets’ contents, we will provide them with access to the respective profile(s) related to such Account. We cannot control how any third party or Caregiver may use or disclose or otherwise exploit any Personal Information or Protected Health Information that you may elect to make available to such third party or Caregiver. You expressly release MyCabinet from any responsibility and liability resulting from any Caregiver or third party access to any Personal Information or Protected Health Information that you may permit. Any information you choose to provide and make available to such caregiver(s) or third parties for viewing, editing, modifying and sharing via the MyCabinet Services should reflect how much you want others to know about you and the information in your profile and cabinet, and to the degree with which you feel confident that such caregiver(s) or third party is capable and willing to manage your healthcare for safety and to ensure optimal health results.
- If you use the Services on your own behalf: You may send family members or friends an invitation to be your “Caregiver” by means of the Service, so that such person will receive alerts regarding your compliance with your medication regime. At your decision, your chosen Caregivers may also receive permissions to edit your information on the Services. By sending such invitation and granting such permissions, you represent that you have the right to appoint and provide the information of such person; that you consent to our disclosure of Personal Information about your medications and your compliance with your medication regime to such person; and, as applicable, that you allow your Caregiver to make changes to the Services including to your personal information, on your behalf. Sharing of your Personal Information and providing the editing permissions in this manner are solely at your responsibility.
- If you use the Services on behalf of your child or an incapacitated person: You shall be considered such person’s “Caregiver”, as applicable. In such event, you represent and warrant that you have the legal authority to act on behalf of that person; that you will keep confidential and only use the Personal Information made available to you through the Services for the purpose for which it was made available to you; that any permission and personal information provided to you through the Services will be used with due care and only for that person’s own good and best interests.
- Virtual Care Management Service Providers. As a patient of one or more virtual care management services (for example, remote patient monitoring services), you authorize MyCabinet to request and receive Personal Information and Protected Health Information from such Service providers that you may have seen in the past, are currently working with, or are in the process of registering information, to assist us in organizing and presenting your information to you. You also authorize MyCabinet to share your Personal Information and Protected Health Information with such Service provider(s) in an effort to provide you with the optimal healthcare experience. This information includes but is not limited to: collection of health data input into your MyCabinet; medication reminders and alerts; drug interactions; vitals tracking; communications with caretakers as designated within your Account; and response tracking of such communication between yourself and your caretakers to provide you with the best healthcare experience.
- Healthcare Providers and Licensed Medical Providers: You authorize MyCabinet to request and receive Personal Information and Protected Health Information from healthcare providers or licensed medical providers you may have seen in the past, or are currently working with, to assist us in organizing and presenting your information to you. You authorize MyCabinet to share your Personal Information and Protected Health Information to Providers with whom you choose to share such information from within the MyCabinet platform. For example, if you elect to share your medical and health history, forms or cabinet contents with a healthcare provider or licensed medical provider using the ‘Share’ or ‘Print’ features within MyCabinet Services.
- If you elect to receive pharmacy services through MyCabinet, we will share information from the applicable Account or cabinets to the pharmacy as requested by the pharmacy to perform its functions (including but not limited to: the name and dose of your medication, the name of the prescribing doctor and the identity of your pharmacy). Your registration to receive the pharmacy services through MyCabinet constitutes your express consent for us to make such disclosures to the pharmacy as an agent on your behalf. All information we disclose to the pharmacy is Personal Information and Protected Health Information contained within your Account and cabinet. In some cases, we will need to collect your credit card information for the pharmacy to process payments for any prescriptions. We do not retain your credit card data, unless such data is chosen by you as a preferred method of payment and saved within your account. Otherwise, we will not retain such data and will simply pass it through to the pharmacy.
- Business Partners and Vendors. We may share your Personal Information or Protected Health Information with a limited number of partners, service providers, and other persons/entities who help run our business (“Business Partners”). Our Business Partners are contractually bound to protect your Personal Information and to use it only for the limited purpose(s) for which it is shared. Business Partners’ use of Personal Information may include, but is not limited to, the provision of services such as data hosting, IT services, and customer services.
- Security and Fraud Prevention Consultants. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
- Research Partners. We may share your Personal Information with third parties, such as research institutes, healthcare systems and healthcare providers. They may associate it with other information that they have about you, for improved healthcare, research purposes and the improvement of our Service.
- Law Authorities. We may share your Personal Information to comply with applicable law obligations or requests to include but not be limited to law enforcement authorities, courts, legal advisors and consultants, as pursuant to a requirement imposed by law, order, judgment or decree, or courts in order to protect and defend our rights and property, or those of Service users.
MyCabinet understands the importance of securing your information. We have implemented administrative, technical, and physical safeguards to help prevent unauthorized access, use, disclosure, or loss of your Personal Information. Your information is stored on secure servers and isn’t publicly available. We limit access of your information only to those employees or partners that need to know the information in order to enable the carrying out of the agreement between us.
Please be aware however that the security of the information transmitted through the internet or other electronic means (such as text messages) comes with inherent risks. No method of data transmission or method of physical or electronic storage can be guaranteed to be perfectly secure. When disclosing any Personal Information or Protected Health Information, you should remain mindful of the fact that it is potentially accessible to the public, and consequently, can be collected and used by others without your consent. You acknowledge and accept that we cannot guarantee the security of your information.
In addition to the efforts made by MyCabinet to secure your information, it is your responsibility to protect the security of your account credentials and to limit access to your account (for example, by signing off after you have finished accessing your account). MyCabinet urges all of its users to be careful and responsible whenever they are on-line. If you notice suspicious activity or believe that your account may have been compromised, please contact us immediately at firstname.lastname@example.org.
THIRD PARTY SERVICES AND WEBSITES
Our Service may link to or refer to third party websites or services that we do not own or control. The fact that we link to a website is not an endorsement, authorization or representation of our affiliation with that third party, nor is it an endorsement of their privacy or information security policies or practices.
DISCLAIMER: The DrugBank Data is intended for educational and scientific research purposes only and you expressly acknowledge and agree that use of the DrugBank Data is at your sole risk. There is no warranty on the accuracy of the DrugBank Data, and reliance on the DrugBank Data shall be at your sole risk. DrugBank Data is not intended as a substitute for professional medical advice, diagnosis or treatment.
INTERNATIONAL AND BUSINESS TRANSFERS
The Services are only for users age 18 or older. Services are not directed to persons under 18, and we do not knowingly collect personal information from children under the age of 18.
If a parent or guardian becomes aware that their child has provided Personal Information without their consent, or that someone has been using the Service for or on behalf of your child without your consent, he or she should contact us at email@example.com. In such an event, we will take reasonable steps to delete the child’s information from our active databases. MyCabinet reserves the right to check its user base and remove or restrict users whom MyCabinet has grounds to believe are in fact minors, as MyCabinet deems appropriate.
If you have created a profile for a minor under the age of 18, you represent and warrant that you are the parent or legal guardian for that minor with a right to provide us the Personal Information of that minor, and that that any permission and personal information provided to you through the Services will be used with due care and only for that person’s own good and best interests.
CONTROLLING YOUR PERSONAL INFORMATION & NOTIFICATIONS
As a registered user of the MyCabinet Services, you can modify certain Personal Information or Account information, as well as communication preferences such as, but not limited to: email and/or text notifications; alerts; drug interactions; remote monitoring device readings; reminders; and reward notifications. This can be done by logging in to your Account and accessing your dashboard and/or cabinet. If you wish to delete your account, you may contact firstname.lastname@example.org (See ‘Requests to Delete’)
You must promptly notify us if any of your account data is lost, stolen, or used without permission.
REQUESTS TO DELETE
You have the right to request that we delete Personal Information about you that we have collected, subject to certain exceptions as outlined below (See ‘Retention of Information’). Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your Personal Information. And, as required under applicable law, we must take steps to verify your request before we can provide Personal Information to you, delete Personal Information, or otherwise process your request.
If you would like to close your Account or delete any Profile from your Account, please contact us at email@example.com
RETENTION OF INFORMATION
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.
We will retain the information you provide via our Services for as long as your Account is active or as needed to provide you with the MyCabinet Services. We will also retain and use the information you provide via our Services, as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
If you delete your Account or any Profile, any Personal Information associated with the same is moved out of our active databases, but may still be retained in our systems pursuant to our data backup and retention policies.
YOUR RIGHTS REGARDING YOUR PROTECTED HEALTH INFORMATION
If you would like more information about your privacy rights or if you are concerned that we have violated your privacy rights, you may contact our compliance officer at firstname.lastname@example.org. You may also file written complaints with the U.S. Department of Health and Human Services. Upon request, our compliance officer will provide you with the correct address. We will not retaliate against you if you file a complaint with us or the Director.
You have the following rights regarding health information we maintain about you:
Right to See and Obtain Copies of your Health Information
You have the right to see and obtain copies of health information used to make decisions about your care.
To view and copy your health information, you must submit your verifiable written request to email@example.com. We may charge a fee for the costs of copying, mailing or other supplies associated with your request. We may deny your request to see and obtain copies of your health information in certain very limited circumstances. You have the right to appeal the denial.
Right to Amend
If you think that your health and billing information is incorrect or incomplete, you may ask us to correct it. We may deny your request if:
The information was not created by us;
The information is not part of the records used to make decisions about your care;
We believe the information is correct and complete; or
You do not have the right to review parts of the medical record under certain circumstances.
We will tell you in writing the reasons for the denial and describe your rights to give us a written statement disagreeing with the denial.
If we accept your request to amend the information, we will make reasonable efforts to inform others of the amendment, as needed, including persons you name who have received information about you and who need the amendment. Your request must be in writing and include an explanation of your reason(s) for the amendment. The request must be submitted via email to firstname.lastname@example.org.
Right to an Accounting of Disclosures
You have the right to request an Accounting of Disclosures. This Accounting of Disclosures report does not include disclosures made for your treatment, payment, or health care operations. It also does not include disclosures made to or requested by you, or that you authorized.
You must submit your request for a report in writing to email@example.com. Your request must state a time period, which is limited to the previous six years from the date of the request. The first request for an accounting of disclosures will be provided free of charge. We may charge you for additional report requests made within a 12 month period.
Right to Request Restrictions
You have the right to request a restriction or limitation on the health information we use or disclose about you for treatment, payment or health care operations. If we agree with your request, we will comply unless the information is needed to provide emergency treatment, is required by law, or otherwise required to be disclosed as listed in this notice.
You must make your request for restrictions in writing to firstname.lastname@example.org. Your request must include what information you want to limit and how you want the limits to apply.
Right to Choose How We Communicate With You
You have the right to request that we communicate with you about health matters in a certain way or at a certain location. For example: you can ask that we only contact you at work or by mail. You must make your request for alternate communications in writing to email@example.com. We will not ask you the reason for your request and will accommodate reasonable requests.
Right to a Paper Copy of This Notice
You have the right to receive a copy of this notice from MyCabinet. You may obtain an electronic copy of this notice from our website at: www.mycabinet.com
Right to Breach Notification
You have the right to and will receive notification in the event of a breach of your unsecured protected health information, unless such notification is exempted by law.
How to Exercise Your Rights
By sending an email with your request to: firstname.lastname@example.org
By submitting a written request to:
19790 W Dixie Hwy Ste 302
Aventura, FL 33180
Your Privacy Rights Regarding Direct Marketing
California Civil Code Section 1798.83 permits individual California residents to request certain information regarding MyCabinet’s disclosure of personal information to third parties for the third parties’ direct marketing purposes. MyCabinet does not provide your personal information to third parties for their use in direct marketing.
California Consumer Privacy Act – Notice for California Residents
If you are a California resident, this section supplements the information above regarding the collection, use, and disclosure of personal information that is covered by the California Consumer Privacy Act of 2018 (“CCPA”).
The CCPA gives California consumers the right to know what personal information covered by the CCPA is collected about them, how it will be used and to whom it is disclosed. The CCPA gives California consumers the right to request: (1) access to such personal information, (2) deletion of such personal information, and (3) that such personal information not be sold to the extent applicable under the CCPA.
The purpose of this notice is to describe our practices regarding the collection, use, disclosure, and sale of personal information covered by the CCPA and instructions for submitting CCPA data privacy requests. Some of the personal information that we collect, use, and disclose may be exempt from the CCPA because it is regulated by other federal and state laws that apply to us.
We do not sell your personal information.
The CCPA provides you (as a California resident) with specific rights, subject to certain exceptions.
Right to Know. You have the right under the CCPA to request that we disclose what personal information we collect, use, disclose, and sell. The process for exercising this right is described below in the “How to Submit a Data Privacy Request” section. Please note that we may not be required to provide you access to the specific pieces of information we have collected about you if we are unable to verify your identity.
Right to Deletion. You have the right under the CCPA to request deletion of personal information about you that we have collected from you. The process for exercising this right is described below under the “How to Submit a Data Privacy Request” section. We may not be required to delete personal information under certain circumstances. Specifically, the CCPA includes exemptions that provide that we do not have to delete information that, for example, is necessary to comply with legal obligations including those pertaining to the quality, safety or effectiveness of a product or activity regulated by the Food and Drug Administration, complete a transaction, detect security incidents, or for certain other internal purposes.
Right to Non-Discrimination. You have the right under the CCPA not to be discriminated against for exercising your privacy rights.
How to Submit a Data Privacy Request
You may exercise your Right to Know and Right to Deletion by emailing us at email@example.com. To process your request to exercise your Right to Know and Right to Deletion, we must be able to verify your identity to a reasonable degree of certainty. To verify your identity, we will ask you to provide your contact information and relevant identifiers based on your relationship with us. Before we process your request, we will match these data points with data points we currently maintain to verify your identity and your relationship with us.
You may designate an authorized agent to make a request to exercise your Right to Know or Right to Deletion on your behalf. When you use an authorized agent to submit such a request, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us.
If we are unable to comply with all or a portion of your data privacy request, we will explain the reasons for declining to comply with the request.
We will deliver Personal Information that we are required by law to disclose to you in the manner required by law within 30 days after receipt of a verifiable request, unless we notify you that we require additional time to respond, in which case we will respond within such additional period of time required by law. We may deliver the Personal Information to you electronically or by mail at your option. If electronically, then we will deliver the information in a portable and, to the extent technically feasible, in a readily usable format that allows you to transmit the information from one entity to another without hindrance.
Children Under 16 Years of Age
We do not sell the personal information of minors under 16 years of age.