Pine Park Health Privacy Policy

(Effective December 5, 2022)

1. Who We Are

Pine Park Health is a value-based primary care practice that works with senior living communities to achieve better health outcomes for patients. Pine Park Health employs geriatric-focused physicians, nurse practitioners, physician associates, and other clinical and non-clinical professionals to deliver medical care to patients in their home.

2. Scope of Policy

This Privacy Policy explains how Pine Park Health Management, Inc., and its affiliates (“Pine Park Health,” "we," “our,” "us") collect, use, and share information collected through our technology, applications, platforms, websites, content, products, and services (the "Services"). This Privacy Policy applies generally to the information We collect about You as a: consumer; another person for whom You have the legal authority to represent, such as Your family member, friend, or client; Senior Living Professional; other employee; or partner (collectively “You,” “Your”).  

If your data is collected, used, or shared in connection with your status as an employee, Your use and access to Services are subject to the terms of the offer letter which you signed at hire and all employment policies, procedures, handbooks, rules, agreement(s) and written requirements, which will control in the event of any conflict.

Patient health information is subject to the linked Notice of Privacy Practices.

This Privacy Policy does not apply to any protected health information covered by the Health Insurance Portability and Privacy Act (“HIPAA”), and its implementing regulations.  

3. Policy Updates

This Privacy Policy may change from time to time.This Privacy Statement is in effect as of the date above. If we change this policy, we will post the revised version here and change the “effective date” to show the date from which the new policy will apply. We may also contact You directly where we deem appropriate to do so under applicable law. If you object to any changes, you must cease using the Services immediately.  We encourage You to check here regularly for the most up-to-date version.  

4. Consent 

By utilizing our Services or providing information about You, You acknowledge and consent to the terms of this privacy policy. You agree not to provide us with information about any other person unless You have that person’s consent or other legal authority. 

Your telephone communications with Us may be recorded or monitored for quality control purposes. By communicating with Us in this manner, You expressly consent to the recording for such purposes.

By providing Us with Your contact information, such as email or telephone number, You agree to be contacted by Us and by the providers we have contracted with to contact You on our behalf. 

You agree to be contacted by telephone call or text message at the telephone number You provided using automatic telephone dialing systems, even if You previously registered on a Do Not Call registry. Your consent is not a condition of purchase.

5. Cookies

Pine Park Health is a value-based primary care practice that works with senior living communities to achieve better health outcomes for senior patients. Pine Park Health employs geriatric-focused physicians, nurse practitioners, physician associates, and other clinical professionals to deliver medical care to patients in their home.

Cookies are used:
  • to make our Services function properly;
  • to provide a secure browsing experience during your use of our Services;
  • to support our marketing campaigns, including to measure how you interact with our marketing campaigns;
  • to help us improve our Services; and
  • to remember your preferences for your convenience.
Types of Cookies on Our Services 
We use the following types of cookies on our Services:
  • Strictly Necessary Cookies - These cookies are essential because they enable you to use our Services. For example, strictly necessary cookies allow you to access secure areas on our Services. Without these cookies, Services cannot be provided. These cookies do not gather information about you for marketing purposes. This category of cookies is essential for our Services to work and they cannot be disabled.
  • Functional Cookies - We use functional cookies to remember your choices so we can tailor our Services to provide you with enhanced features and personalized content. For example, these cookies can be used to remember your name and location. We do not use functional cookies to target you with online marketing. While these cookies can be disabled, this may result in less functionality during your use of our Services.
  • Performance or Analytics Cookies - These cookies collect passive information about how you use our Services, including webpages you visit and links you click. We use the information collected by such cookies to understand our users better and to improve and optimize our Services. We do not use these cookies to target you with online marketing. You can disable these cookies.
  • Social Media Cookies--These cookies are set by a range of social media services that we have added to the site to enable You to share our content with Your friends and networks. They are capable of tracking Your browser across other sites and building up a profile of Your interests. This may impact the content and messages You see on other websites You visit.  If You do not allow these cookies You may not be able to use or see these sharing tools.
  • Third-Party Cookies - These are cookies that are provided by third-party service providers and belong in one of the cookie categories described above. These third-party providers process your Personal Information on our behalf pursuant to our instructions and obligations consistent with this Policy.
How to Manage Cookies
Depending on whether you would like to manage a first-party or third-party cookie, you will need to take the following steps:
  • First-Party Cookies - If you prefer not to receive cookies while browsing our website, you can set your browser to warn you before accepting cookies and refuse the cookie when your browser alerts you to its presence. You can also refuse all cookies by changing the settings in your browser. You do not need to have cookies turned on to use and navigate through many parts of our website, although if you block or disable the cookie functions, you may not be able to access all portions or features of the website and the Services. Please follow instructions provided by your browser (usually located within the "Help", "Tools" or "Edit" settings) to disable first-party cookies. You can find more information about how to change your browser cookie settings here.
  • Third-Party Cookies - Some third-party services providers that we engage (including third-party advertisers) may also place their own cookies on your device. Note that this Policy covers only our use of cookies and does not include use of cookies by such third parties. Modern browsers also allow you to block third-party cookies, please see section above to learn how to do that.
Web Beacons
Web Beacons, also known as web bugs, pixel tags or clear GIFs, are tiny graphics with a unique identifier that may be included on our website to deliver or communicate with cookies, in order to track and measure the performance of our website and Services, monitor how many web visitors we have, and to monitor the effectiveness of our advertising. Unlike cookies, which are stored on the user’s device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
Analytics Technologies
Users of our Services who have JavaScript enabled are tracked using analytics technologies, including Google Analytics. Unless the Analytics feature is blocked, it collects the following types of information from the user: type of user agent (web browser) used, software manufacturer and version number; type of operating system; network location and IP address; country, city, state, region, county, or any other geographic data; hostname; bandwidth (internet connection speed); time of visit; pages visited; time spent on each page of the website; referring site statistics; the website (URL) the user came through in order to arrive at our website; search engine query used (example: typing in a phrase into a search engine, and clicking on a link from that search engine). The data collected by the analytics technology is primarily used to optimize the Service experience for our users. We also use this data for our own business purposes, for example, to analyze how many users we have, where visitors come from, and understand how they interact with us.
Interest-Based Advertising
We use information collected about a user’s use of our Services to arrange for advertisements about our Services to be served to the user on third party’s websites. To do so, our advertising service providers place or recognize a unique cookie on the user’s browser and use other techniques, such as pixel tags. Please visit the Network Advertising Initiative for more information about this practice and to learn about your choices.

Users may opt-out of receiving interest-based advertising. The opt-out may be provided through specific opt-out cookies. Please visit the following Your Ad Choices and the Network Advertising Initiative to learn more.
Mobile Applications
Depending on your permissions, we may receive your Personal Information from your internet service and mobile device providers. Users of mobile devices who do not want to receive interest-based advertising may opt-out in several ways. Learn more about your choices for mobile devices by visiting Your Ad Choices. To end all targeting on a mobile device immediately, turn on “Limit Ad Tracking” in the device settings. To limit Ad Tracking on an Apple device, please see here. To limit Ad Tracking on an Android device, please see here.
Social Media
Depending on your permissions, we may receive your Personal Information from your social media accounts. You can edit or remove Personal Information usage permissions by using privacy settings on your social media account. Click below for instructions on how to change or remove third party access on each platform:

6. Data We Collect

There are four main ways we collect personal information

  • Data You Provide: Data You provide to Us;
  • Automated Data: Data collected through electronic/automated means; and
  • Partner Data: Data we are authorized to access as an senior living partner.; and
  • Other Data Sources: Data from other sources (such as our service providers or public sources).

7. Data You Provide

We collect data You provide to Us when You use our Services, including, but not limited to, communicating with Us over the telephone, through our mobile application(s), email, SMS, or complete a website form.  This includes personal information, which identifies, (whether directly or indirectly), a particular individual.  Personal information You provide includes the types of data listed below (with examples). 

  • Identifiers: name, postal address, phone number, or email address.
  • Customer Personal information under California. Civ. Code 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
  • Personal characteristics of protected classes. Age, gender and other information You choose to provide, such as marital status, medical condition, physical or mental disability.
  • Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
  • Financial Information. Banking information, account numbers, routing numbers, revenue, payments, invoices, expenses.
  • Profile. Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, abilities, engagement, skill and business acumen, referral source(s), schedule preferences, orientations and training completed, family, friends, relationships, habits, behaviors, opinions, feedback, living environment and conditions, service and customer service records, and inferences made from this data.
  • Professional or employment-related information. We may receive employment-related information, including: current and past employer name, positions held, physical demands of positions held, and wage information; availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves, date of death; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military; and performance record, compensation history, disciplinary and grievance information (including related legal matters).
  • Sensitive Personal Information. Information that reveals: a social security, driver’s license, state identification card, or passport number; a racial or ethnic origin, religious or philosophical beliefs, or union membership; information collected and analyzed concerning a consumer’s health; the contents of mail, email, and text messages.
  • Website/Application interaction or similar network activity–information You provide Us in our website contact forms, applications or through any chat functionality.
  • Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, body temperature, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data that can be used to identify an individual.
  • Sensory data. Audio or similar information, such as recording phone calls for quality assurance.
  • Health & Physical Characteristics. medical conditions, diagnosis, care needs, and other similar information You provide. In the case of injury, illness, or potential disability we may also collect doctor’s notes and assessments, work status reports, or other medical information to clear you for work or arrange alternative work.

Partner Data

Through working with senior living communities to provide Services, we may require access to data of such communities. We will handle any data accessed from senior living communities in accordance with its applicable privacy policy(ies). The Personal information we may access includes the types of data listed below (with examples).

  • Identifiers. name, postal address, phone number, or email address.
  • Customer Personal information under California. Civ. Code 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
  • Personal characteristics of protected classes. Age, gender and other information You choose to provide, such as marital status, medical condition, physical or mental disability.
  • Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
  • Profile. Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, abilities, engagement, skill and business acumen. Information regarding family, friends, relationships, habits, behaviors, attitudes, preferences, opinions, feedback, living environment and conditions, service and customer service records, and inferences made from this data.
  • Professional or employment-related information. We may have access to employment-related information, including: current and past employer name, positions held, physical demands of positions held, and wage information; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves, date of death; location of employment and workplace, job titles, work history, work hours, licensure and certification records, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military; and performance record, compensation history, disciplinary and grievance information (including related legal matters).
  • Information that reveals: a social security, driver’s license, state identification card, or passport number; a racial or ethnic origin, religious or philosophical beliefs, or union membership; the contents of mail, email, and text messages; and information collected and analyzed concerning a consumer’s health.
  • Health & Physical Characteristics. Medical conditions, diagnosis, care needs, and other similar information You provide so that we can connect You with the appropriate resources and Services.

Other Data Sources

  • Identifiers: name, postal address, phone number, or email address.
  • Customer Personal information under California. Civ. Code 1798.80(e). name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
  • Personal characteristics of protected classes. Age, gender and other information You choose to provide, such as marital status, medical condition, physical or mental disability.
  • Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
  • Profile. Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, abilities, engagement, skill and business acumen. Information regarding family, friends, relationships, habits, behaviors, attitudes, preferences, opinions, feedback, living environment and conditions, service and customer service records, and inferences made from this data.
  • Professional or employment-related information. We may receive employment-related information, including: current and past employer name, positions held, physical demands of positions held, and wage information; availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves, date of death; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military; and performance record, compensation history, disciplinary and grievance information (including related legal matters).
  • Sensitive Personal Information. Information that reveals: a social security, driver’s license, state identification card, or passport number; a racial or ethnic origin, religious or philosophical beliefs, or union membership; information collected and analyzed concerning a consumer’s health; the contents of mail, email, and text messages.
  • Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, body temperature, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data that can be used to identify an individual.
  • Website/Application interaction or similar network activity–information You provide Us in our website contact forms, applications or through any chat functionality.
  • Sensory data. Audio or similar information, such as recording phone calls for quality assurance.
  • Health & Physical Characteristics. Medical conditions, diagnosis, care needs, and other similar information You provide.
  • Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments and invoices.

Data Use

For each type of data we collect, we use such Personal Information for the business purposes set forth below:

  • Communicating with You
  • Verify and enhance quality of products and Services
  • Administration of our business
  • Anonymizing Your data for further internal and external use in a manner that does not identify You
  • Enhancing security and preventing fraud or illegal activity
  • Verification and onboarding of new employees
  • Performing our contractual duties and obligations or entering into an agreement
  • Ensuring compliance with legal obligations
  • Facilitation of online or platform interactions
  • Consumer engagement & customer service
  • Identifying and testing business innovations
  • Market research
  • Providing educational resources/ learning management
  • Advertising/marketing for employment, recruitment, products and Services

Use of data for advertising/marketing of our products and Services may also be a commercial purpose for which You may have the right and ability to opt-out.

We may use the information we collect about You in other ways, which we will tell You about at the time we collect it or before we begin using it for those other purposes.  In certain instances You will have an opportunity to limit our uses at the time Your Personal Information is collected. 

You may also have the right to request deletion of Your data, depending upon Your state of residence, as provided below.

We will retain and use Your Personal Information for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.  Once data is aggregated, de-identified, or anonymized, it may be retained for a longer period as permitted by law.

Data Sharing

We may share information for the purposes described above under “Data Use,” with third-parties as follows: 

  • Partners, Subsidiaries and Affiliated Medical Agencies: We may share Personal Information with our partners and affiliates such as physical therapy, home health, or hospice companies to provide you with clinical service. 
  • Service Providers: We may share Personal Information with service providers to facilitate our business purposes, as identified above in “Data Use.” These may include, but are not limited to, disclosures to our auditors and advisors, or technology and software service providers who help us administer our business or provide data security. These also include providers of website and chat functionality. We generally require such providers to provide contractual assurances that they will safeguard data and limit their use of data to what is required to fulfill the purpose of our arrangement with them.
  • Third-party Vendors: We may share Personal Information with third-party vendors to facilitate our own commercial purposes, as identified above in “Data Use.” These may include, but are not limited to, online marketing, advertising or analytics providers who help us understand trends and patterns among those who access our website and Services. When these vendors are not service providers described above or utilize non-essential cookies on our website, You may have the right and ability to opt-out of such sharing.
  • Legal Purposes, Authorities, Officials and Courts: We may disclose Personal Information where we believe it is necessary to comply with the law in special cases when we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may have breached our Terms or who may be causing (whether intentionally or unintentionally) injury to or interference with our rights or property, other website or application users, or anyone else who could be harmed by such activities. We may also disclose Personal Information to law-enforcement personnel and agencies when requested to do so, as required by law, such as to comply with a subpoena.
  • Business Transfers: We may disclose Personal Information as part of any merger, acquisition, debt financing, sale of company assets, or other business transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, provided that we inform such third parties that they must use Your Personal Information only for the purposes disclosed in this Privacy Policy.
  • As Aggregated, De-identified, or Anonymized Information: We may disclose information that cannot reasonably be used to identify You, as permitted by law.
  • Upon Your request.

We may otherwise disclose Your Personal Information to third-parties with Your consent or at Your direction, where permitted or required by law.

Links to Other Websites and Social Media
Our Site may offer links to websites that are not run by us but by third parties. If You visit one of these linked websites, Any information You give to those organizations is subject to their privacy policy, terms and conditions, and other policies.  We are not responsible for the policies and practices of third parties.  You understand and agree that by clicking on a link to a third party site You have left the Site, and this Privacy Policy is no longer in effect.
Our Social Media Usage
We have accounts on social media platforms through which we may post information or conduct promotional activities. If you use social media to follow us or interact with us, we may collect Personal Information you choose to share with us. Please understand your use of the social media services may result in the collection or sharing of information about you by those social media services. We have no control over, and decline all responsibility for, the use of your personal data by these third parties. Your use of social media, including your interactions with us on social media, are at your discretion. We encourage you to review the privacy policies and settings on the social media services with which you interact to make sure you understand how your information may be collected, used, and shared by those social media services.
Opt-Out or Unsubscribe
You may choose to have Your name taken off of our registration list, cease marketing communications or newsletters from us by using the opt-out option in any marketing emails or text messages You receive from us or contacting us using the information provided at the bottom of this Privacy Policy. We will respond to Your request within 10 days or as otherwise required by law.
Opting out of one form of communication does not mean You have opted out of other forms as well. For example, if You opt-out of receiving marketing emails, You may still receive marketing text messages if You have opted-in to receiving them.  However, if You submit a general opt-out request on this Site, we will take action to unsubscribe You based upon the information provided.  For example, if You provide Your name, email address, and phone number we will unsubscribe You from any lists linked to either Your name, email address or phone number.  
Security
In order to prevent unauthorized access or disclosure we have put in place physical, electronic and managerial procedures to safeguard and secure Your Personal Information. 

We use standard Transport Layer Security (TLS) certificates to secure pages used for inputting users' Personal Information. However, unless we expressly advise You otherwise, the functionality on our Site does not provide a means for completely secure and private communications between us. Due to the open communication nature of the Internet, we cannot guarantee that communications between us will be free from unauthorized access by third parties. 

If You believe that the Personal Information You have provided us has been compromised, or if You become aware of a potential security vulnerability in our Platform, please contact us using the contact Information provided below.
International Transfer
Your information is stored on controlled servers with limited access and may be stored and processed in the United States or another country where our service providers are located. We offer our Services only to individuals located in the United States, and we do not advertise our Services outside the United States. If you are located outside the United States and choose to provide your Personal Information to us, please note that we may transfer your Personal Information to the United States or another country where our service providers are located, and such countries may not provide the same data protection. Those who choose to access and use the Services from outside the United States do so on their own initiative, at their own risk, with this understanding.
Children and Privacy
We do not specifically collect information about children nor market our products or Services to children. We have no reason to believe that the Site will attract children, or that children will access the Site or provide Personal Information.
Nevada Resident Privacy Rights
Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell Your personal information to third parties as defined in Nevada law, and will not do so in the future without providing You with notice and an opportunity to opt-out of such sale as required by law.
California Rights
These rights are not absolute and in certain cases are subject to conditions or limitations as specified in California privacy law. We will not unlawfully discriminate against You because You exercised any of Your rights under California privacy law.
Right to Know
Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell Your personal information to third parties as defined in Nevada law, and will not do so in the future without providing You with notice and an opportunity to opt-out of such sale as required by law.
  • categories of Personal Information collected about You;
  • categories of sources from which we collected Your Personal Information;
  • business and/or commercial purposes for collecting and disclosing Your Personal Information; 
  • categories of service providers and/or third parties with whom Your Personal Information has been shared, including for a business purpose; and
  • the specific pieces of Personal Information collected about You.
We are specifically prohibited from disclosing highly sensitive information in response to a request, including Your: social security number, driver’s license number or other government-issued identification number, financial account number, any health insurance or medical identification number, an account password, security questions and answers, or unique biometric data generated from measurements or technical analysis of human characteristics.

We will, however, inform You if we have collected such information and identify the type of information with sufficient particularity.

We will respond to Your request within 45 days, unless we notify You of a 45-day extension, or other period as required or permitted by regulation.
Right to Delete
California residents have the right to request the deletion of Your Personal Information We have collected from You. This right may be subject to certain conditions and limitations under the law.We will respond to Your request within 45 days, unless we notify You of a 45-day extension, or other period as required or permitted by regulation.
Right to Opt-Out of “Sale” of Data
California residents have a right to opt-out of the “sale” of data. Pine Park Health does not sell its clients’ health information to third parties or exchange Your data for financial gain and has not done so in the past 12 months. We do not do not knowingly sell any personal information of children under age 16.

Exercising Your Rights Under Applicable Law

Verification Process
To protect Your privacy, we will verify Your identity prior to responding to a request for data.  The request form will require some initial contact information that we will compare against our records.  Upon submission of the form You will be required to confirm Your request via email.  You may receive an email from “On Behalf of Our Privacy Team” to which You must respond in order to verify Your identity and access our response(s).  If You request disclosure of specific pieces of personal information, we may take additional steps as permitted or required by law.  For example, we may call You to verify Your request, in addition to matching at least three pieces of personal information You provide with information we maintain, and require a signed declaration, under penalty of perjury, that You are requesting Your own personal information.

If an authorized agent is submitting on Your behalf, we will require submission of either 1) a written authorization, signed by You, that authorizes that agent to make the specific request on Your behalf; or 2) other valid legal authorization.

Any personal information collected from You in connection with verification of Your request will be used solely for the purposes of verification.
Contact Information
If You have any questions about this Privacy Policy, the practices of the Site, or Your dealings with the Site, please contact us via the following methods:

Pine Park Health Management, Inc.
Attn: Privacy Team
1144 65th Street, Suite F
Oakland, CA 94608

Toll-free: 1-888-512-1208

We will not retaliate against any person for filing a privacy complaint. Your privacy and confidence in our abilities is of utmost importance to us