Effective as of March 2, 2022.
This “Privacy Statement” describes the privacy practices of Health Care Transformation, LLC and our subsidiaries and affiliates (collectively, “HCT”, “we”, “us”, or “our”) in connection with our white-labelled, digital asynchronous video technology and services made available on the websites, applications and other media properties of our healthcare organization customers (the “Services”, “HCT Clients Properties” and “HCT Client” respectively). The primary purpose of this Privacy Statement is to describe how we collect information through the “Videos” and the “HCT Platform” (as defined in the HCT Terms & Conditions) that appear on the HCT Client Properties, and how we use and share that information. We do this to assist HCT Clients in providing accurate and legally required privacy notices on their HCT Client Properties.
To be clear, this Privacy Statement does not describe our collection, use and sharing practices in connection with HCT branded websites and applications. Those privacy practices are described at https://hctdigitalcare.com/privacy-policy/.
What We Do
On behalf of HCT Clients, HCT creates, configures, and manages digital asynchronous videos (the “Videos”) that allow HCT Clients to achieve a financial ROI through standardization and automation. The Videos can be watched and rewatched by the target audience (“End Users” ) through the HCT Client Properties. The Videos are bespoke, created specifically for a particular HCT Client, branded with the HCT Client brand and displayed on the HCT Client Properties through the HCT Platform and using HCT technology. We collect data in connection with End User’s interactions with the Videos (“Analytics Data”), create related reports (“Analytics Reports”) and share the Analytics Data and the Analytics Reports with HCT Clients in order to further improve performance and achieve the desired financial and operational ROI.
Information We Collect
We collect Analytics Data from the HCT Platform. For example, we collect information about when and how many times a Video was accessed, how many times a Video was played, how much of the Video was watched, and how frequently an End User clicked on clickable links inside the Video. When collecting this information, HCT and/or its vendors:
- disable session and cookie tracking on an End User’s computer or mobile device
- mask the last digit of the Viewer’s IP address to reduce the likelihood of the Viewer being identified and
- expressly do not collect any device IDs
Through the HCT Platform, HCT and/or its vendors may also collect responses to surveys. The survey questions and responses can vary, including but not limited to multiple choice, ratings, yes/no, and open-ended. All the above collection policies still apply including disabled IP addresses and cookie tracking. End Users are not asked for personal information.
How We Use the Collected Information
HCT and its vendors use the collected information for the following purposes and as otherwise described in this Privacy Statement or at the time of collection:
To operate and improve the Services. We use the Analytics Data to:
- develop, provide, operate, maintain, and improve HCT products and services;
- to comply with law and prevent fraud
To create anonymous, aggregated, de-identified data. We may create anonymous, aggregated, de-identified data from the Analytics Data we collect. We may use this anonymous, aggregated, de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and to promote our business.
How We Share the Collected Information
We may share the information collected about a particular End User, group of End Users, or associated with an HCT Client as follows:
Affiliates. with our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Statement.
Service providers. with third party companies and individuals that provide services on our behalf or help us operate our business.
Professional advisors. to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
Business transfers. in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.
Regulatory. as necessary for compliance, fraud prevention and safety purposes.
Access your information. You may request to review your Analytics Data by contacting your HCT advisor.
Other Sites, Mobile Applications and Services
The Service may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages, in mobile applications or on online services that are not associated with us. We do not control third party websites, mobile applications or online services, and we are not responsible for their actions. Other websites, mobile applications and services follow different rules regarding the collection, use and sharing of personal information. We encourage you to read the privacy policies of the other websites, mobile applications and online services in use.
The Service may be directed to children under the age of 16 depending on the HCT Client. If an HCT Client becomes aware that his or her child has provided us with personal identifying information, the HCT Client should contact us. We will delete such information from our files as soon as reasonably practicable. We encourage parents with concerns to contact us.
Changes to this Privacy Statement
We reserve the right to modify this Privacy Statement at any time. If we make material changes to this Privacy Statement, we will provide notification of changes in a manner that is legally required and following the notification requirements set forth in the applicable agreement between the HCT Client and HCT.
How to Contact Us
Please direct any questions or comments about this Privacy Statement or privacy practices to firstname.lastname@example.org. You may also write to us via postal mail at:
Health Care Transformation, LLC
P.O. Box 49864
Los Angeles, CA 90049