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Privacy Policy

Health iPASS (“Health iPASS,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard personal information when you interact with us, including through our website, products, and services. This Privacy Policy applies to individuals who interact with Health iPASS, including patients,customers, website visitors, and business partners.

Information We Collect

We collect personal information that identifies, relates to, or could reasonably be linked to an individual (“personal information”). The categories of personal information we collect depend on how you interact with us.

Categories of Personal Information
We may collect the following categories of personal information:

  • Identifiers (e.g., name, email address, phone number, IP address)
  • Customer Records Information (e.g., address, financial information, insurance information)
  • Protected Classifications (e.g., age, gender, where required or permitted by law)
  • Commercial Information (e.g., services purchased or considered)
  • Professional or Employment Information (e.g., job title, employer)
  • Education Information (where applicable)
  • Inferences (e.g., preferences or interests derived from interactions)
  • Sensitive Personal Information (where applicable and permitted by law)

Not all categories apply to every individual, and the information collected depends on your
relationship with us.

Sources of Information

We collect personal information from:

  • Directly from you (e.g., forms, communications)
  • Our clients and partners (e.g., healthcare providers, service integrations)
  • Your use of our website (e.g., form submissions, analytics)
  • Third-party service providers supporting our operations
  • Patient interactions during scheduling, check-in, or payment processes

Cookies and Tracking Technologies

We use cookies and similar tracking technologies (such as pixels, web beacons, and analytics tools) to collect information about your interactions with our website and services. This information helps us:

  • Operate and maintain our website
  • Understand usage patterns and improve performance
  • Enhance user experience

We may use third-party analytics providers, such as Google Analytics, which may collect information about your online activities over time and across different websites. You can manage your cookie preferences through your browser settings. Depending on your location, you may also have the ability to manage cookie preferences through a cookie banner or similar tool on our website.

Depending on your location, the use of certain cookies and tracking technologies may be considered a “sale” or “sharing” of personal information under applicable law. You may have the right to opt out of such activities by adjusting your cookie preferences. Our website does not currently respond to “Do Not Track” signals from browsers.

How We Use Your Information

We use personal information for business and operational purposes, including to:

  • Provide and improve our products and services
  • Process transactions and deliver requested services
  • Communicate with you (including updates, alerts, and support)
  • Support healthcare-related administrative functions (e.g., billing, reminders)
  • Conduct research, analytics, and product development
  • Maintain security and prevent fraud
  • Comply with legal obligations
  • Evaluate or complete business transactions (e.g., mergers or acquisitions)

We may de-identify or aggregate personal information and use it for analytics, benchmarking, and product improvement purposes. Payment information is processed by secure, PCI-compliant third-party payment processors. Health iPASS does not store full payment card information.

Our Role in Data Processing

Depending on the context in which personal information is collected and processed, Health iPASS may act as either:

  • A Service Provider / Processor on behalf of healthcare providers and other clients, where we process personal information according to their instructions; or
  • A Business / Controller, when we collect and process personal information directly for our own purposes, such as through our website, marketing activities, or recruiting.

When we act as a service provider or processor, we process personal information on behalf of and under the direction of our clients, and their privacy policies may also apply.

Protected Health Information (HIPAA)

In certain circumstances, Health iPASS may receive, maintain, or process Protected Health Information (“PHI”) on behalf of healthcare providers and other covered entities. In those cases, Health iPASS acts as a Business Associate and processes PHI in accordance with the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and applicable Business Associate Agreements. PHI is not governed by this Privacy Policy. Instead, it is subject to the privacy practices of the applicable healthcare provider, including their Notice of Privacy Practices.

Sharing of Personal Information

We may share personal information with:

  • Service providers who support our operations (e.g., hosting, analytics, payment processing)
  • Affiliates within our organization
  • Business partners involved in delivering services
  • Regulators or legal authorities, when required by law

We do not sell personal information. However, we may disclose personal information to third parties for business purposes, which may be considered a “sale” or “sharing” of personal information under applicable law. You may have the right to opt out of such activities by adjusting your cookie preferences using the “Cookie Preferences” link available on our website.

Children’s Data Collection

Health iPASS does not provide services directly to children. However, we may process personal information, including information relating to minors under the age of 13, on behalf of healthcare providers in connection with patient care and related administrative services. In these cases, Health iPASS acts as a service provider to healthcare organizations, and the healthcare provider is responsible for obtaining any necessary consents and authorizations required by applicable law. If you believe that a child has provided personal information to Health iPASS outside of these contexts, please contact us using the information below.

Data Retention

We retain personal information for as long as necessary to fulfill the purposes described in this Privacy Policy, including to comply with legal, regulatory, and contractual obligations. Retention periods are determined based on factors such as the nature of the information, the purpose for which it was collected, applicable legal requirements (including HIPAA where applicable), and our contractual obligations. In some cases, we may retain and use de-identified or aggregated information for analytics, research, and product improvement purposes.

Your Privacy Rights

Depending on your location, you may have rights regarding your personal information, including:

  • The right to know what personal information we collect
  • The right to access or receive a copy of your data
  • The right to request deletion of your data
  • The right to correct inaccurate information
  • The right to opt out of the sale or sharing of personal information (where applicable)
  • The right to limit the use of sensitive personal information (where applicable)
  • The right to appeal decisions related to your privacy requests (where applicable)

To exercise your rights, please contact us using the information below.

Additional Information for California Residents

If you are a California resident, you have specific rights under the California Consumer Privacy Act CCPA), as amended by the California Privacy Rights Act (CPRA). These rights include the ability to request access to, deletion of, or correction of your personal information, as well as the right to opt out of the sale or sharing of personal information and to limit the use of sensitive personal information, as described above.

Health iPASS does not sell personal information. We may share personal information as described in this Privacy Policy. To exercise your rights, please contact us using the information provided below.

How to Submit a Privacy Request

You may submit a request by:

Please include “Health iPASS Privacy Request” in the subject line. We will respond within applicable legal timeframes.

 

Non-Discrimination

We will not discriminate against you for exercising your privacy rights.

 

Data Security

We implement reasonable administrative, technical, and organizational safeguards designed to protect personal information from unauthorized access, use, or disclosure. These safeguards include industry-standard practices and frameworks appropriate to our business, such as HIPAA  safeguards and, where applicable, SOC 2 and PCI-DSS aligned controls. However, no method of transmission over the Internet or electronic storage is completely secure, and we cannot guarantee absolute security.

AI and Automated Processing

Health iPASS may use artificial intelligence, machine learning, or other automated technologies to support and enhance our products and services, including for communications, workflow automation, analytics, and operational efficiency. These technologies are designed to assist healthcare organizations and improve user experience. Health iPASS does not use artificial intelligence to make clinical decisions or provide medical advice. Health iPASS does not use automated decision-making technologies to make decisions that produce legal or similarly significant effects on individuals without appropriate human involvement.

Changes to This Policy

We may update this Privacy Policy from time to time. When we do, we will revise the “Last Updated” date and post the updated policy on our website.

Contact Us

If you have questions about this Privacy Policy or our data practices, please contact:

Health iPASS
Attn: Data Privacy Officer

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.

Yes

B. Personal information categories

A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

Yes

C. Protected classification characteristics under state or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Yes

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

No

G. Geolocation data.

Physical location or movements.

No

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

No

I. Professional or employment-related information.

Current or past job history or performance evaluations.

Yes

J. Non-public education information

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Yes

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

Personal information does not include:

  • Publicly available information from government records.
  • De-identified or aggregated consumer information.
  • Information specifically excluded from the scope of applicable law, such as:
    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
    • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our clients and partners, customer order forms, integration with Electronic Medical Records (EMR) providers, practice management systems, and insurance clearinghouse.
  • Indirectly from our clients, and partners. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our website (www.healthipass.com). For example, form submissions or website usage details collected automatically.
  • From third-parties that interact with us in connection with the services we perform. For example, processing platforms or integrated service providers.
  • Data provided by patients during their scheduling, check-in, form submission, and bill payment processes.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To provide you with information, products, or services that you request from us.
  • To provide you with email or text alerts, and other notices concerning our products or services, or events or news, that may be of interest to you.
  • To provide you with information and updates concerning appointments, reminders, billing, and other notices related to your health care service.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
  • To improve our website and present its contents to you.
  • For testing, research, analysis and product development.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients, partners, sponsor banks, or others.
  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA and other applicable privacy laws.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:             Identifiers.
Category B:             California Customer Records personal information categories.
Category C:             Protected classification characteristics under California or federal law.

Category D:           Commercial information.
Category I:              Professional or employment-related information.

Category J               Non-public education information

Category K:             Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.
  • Service providers.
  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that Health iPass disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • The specific pieces of personal information we collected about you (also called a data portability request).
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
    • sales, identifying the personal information categories that each category of recipient purchased; and
    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

  1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.) or other applicable laws.
  6. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  7. Comply with a legal obligation.
  8. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights to Data Portability, Access and Deletion

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:

Only you or a person registered with the appropriate regulatory authority that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

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

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We attempt to respond to a verifiable consumer request within 45 days of its receipt.  If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.  We will deliver our written response by mail or electronically, at your option.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by applicable law, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Data Privacy Officer: Heather Randall, Chief Compliance Officer
Phone: 855-513-2671
Website: www.healthipass.com
Email: