MHMDA | HOPCo Digital Clinic

This notice is intended to supplement the HOPCo National MSK Specialty Network LLC, and its affiliates (“HOPCo Digital Clinic”) Privacy Policy and applies to personal data defined as “consumer health data” subject to the Washington State My Health My Data Act (“MHMD”).

Consumer Health Data We Collect

The data we collect depends on the context of your interactions with HOPCo Digital Clinic and the choices you make (including your privacy settings), the products and features you use, your location, and applicable law. Because consumer health data is defined very broadly, many of the categories of data we collect could also be considered consumer health data. As described in “Information We Collect” section of our Privacy Policy, the data we collect depends on the context of your interactions, but primarily comes from information you choose to submit to HOPCo Digital Clinic, information based on your privacy settings, and your location. Because consumer health data is defined very broadly, certain of the categories of data we collect could also be considered consumer health data.

Examples of consumer health data may include:

Information about your health-related conditions, injuries, symptoms, status, diagnoses, testing, medications, allergies, or treatments (including surgeries, procedures, medications, or other interventions). For example, if you are seeking information about musculoskeletal conditions, treatments, or appointments, we may collect some or all of this information to provide the services.
Precise location information that could reasonably indicate your attempt to acquire or receive health services or supplies. For example, we may collect certain location information when you use our Sites, such as your mobile device’s GPS signal, or information about nearby Wi-Fi access points and cell towers, which could reveal your location and your interest in receiving health care services.
Information that could identify your attempt to seek health care services or information, including services that allow you to assess, measure, improve, or learn about your or another person’s health. For example, we may collect information about information you viewed, which may indicate your attempt to learn more about certain conditions, treatments, or healthcare providers.
Other information that may be used to infer or derive data related to the above or other health information.
To provide healthcare services, including facilitating appointments, consultations, and treatment coordination;
To respond to your inquiries and requests, including through our Contact Us form;
To communicate with you about your care, including appointment reminders, treatment information, and follow-up messages;
To improve our Sites and services, including analyzing how users interact with our Sites;
To ensure the security and integrity of our Sites and protect against fraud and unauthorized access;
To comply with legal obligations and respond to lawful requests from government authorities; and
For other purposes disclosed to you at the time of collection or with your consent.
Authorized third-party vendors and service providers. We share consumer health data with third-party vendors and service providers for the purpose of enabling them to provide specialized services on our behalf, including billing, payment processing, customer service, email deployment, business analytics, marketing, performance monitoring, hosting, and data processing. These third-party vendors and service providers are bound by contract to use your information only for the specific purposes for which it was shared and may not use it for their own purposes.
Business transfers. We may share consumer health data for the purpose of facilitating a substantial corporate transaction, such as a merger, consolidation, asset sale, or in the unlikely event of bankruptcy.
Legal purposes. We may disclose consumer health data for the purpose of responding to subpoenas, court orders, legal process, law enforcement requests, legal claims, or government inquiries, and to protect and defend the rights, interests, health, safety, and security of HOPCo Digital Clinic, our affiliates, users, or the public.
With your consent or at your direction. We may share consumer health data for any purpose you authorize at the time we collect the information or pursuant to your specific consent or direction.
Other third parties. In certain circumstances, it may be necessary to provide data to other third parties, for example, to comply with the law or to protect our rights or those of our customers.
Affiliates. We may share consumer health data with our corporate affiliates for the purpose of providing coordinated services and operating our business. Affiliates receiving consumer health data are subject to this policy.
De-identified Data. We create and use de-identified and/or aggregated data about our users to help us and our partners evaluate and improve treatments, devices, digital health tools, and patient safety. Once data has been de-identified in accordance with applicable standards, it is no longer considered Personal Information or PHI.
Right to Confirm. You have the right to confirm whether HOPCo Digital Clinic is collecting, sharing, or selling consumer health data concerning you.
Right to Access. You have the right to access your consumer health data, including a list of all third parties and affiliates with whom HOPCo Digital Clinic has shared your consumer health data during the preceding 12 months, along with an active email address or other online contact information for those third parties.
Right to Delete. You have the right to request deletion of your consumer health data.
Right to Withdraw Consent. You have the right to withdraw your consent from the collection and sharing of your consumer health data at any time.

Sources of Consumer Health Data

As described further in the Privacy Policy, we collect personal data (which may include consumer health data) directly from you and from your interactions with our Services. We do not load any non-essential cookies, tags, pixels, analytics, or advertising technologies until you provide opt-in consent through our cookie banner. Only strictly necessary technologies required to operate the Sites run before consent. We never place advertising or analytics technologies on any page that collects, displays, or transmits health information.

Why We Collect and Use Consumer Health Data

We collect and use consumer health data for the following specific purposes:

We may use consumer health data for other purposes for which we give you choices and/or obtain your consent as required by law –for example, to respond to an inquiry through our Contact Us form. See the “Your Choices” and “Your Rights” sections of the Privacy Policy and the How to Exercise Your Rights section below for more details on the controls and choices you may have.

How We Share Consumer Health Data

We may share each of the categories of consumer health data described above for the purposes described in the How We Share Your Information section of the Privacy Policy. We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. In particular, we may share personal data, including consumer health data, with your consent, when you tell us to do so, or as reasonably necessary to deliver the Services or respond to an inquiry. We may disclose data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process. We do not sell your personal information or PHI, and we do not “share” PHI for cross-context behavioral advertising.

With Whom We Share Consumer Health Data

We provide certain health care providers and business partners with your consumer health data so that we can provide you with the services you requested. When you create an account with HOPCo Digital Clinic, you authorize us to collect and provide this information to these partners. We do not sell your consumer health data to other parties. As necessary for the purposes described above and to provide you with the Service, we share consumer health data with the following categories of third parties:

How to Exercise Your Rights

HOPCo Digital Clinic requires you to provide affirmative consent to (i) collection and (ii) sharing of your consumer health data as described in this Policy and the Privacy Policy when you first access the services.

MHMD provides consumers with the following rights regarding their consumer health data, subject to certain exceptions:

You can exercise any of these rights by emailing privacy@hopco.com. You may also opt out of cookies by clicking the “Manage Cookies” link at the bottom of the page or by adjusting the settings in your browser.

If you submit a rights request to privacy@hopco.com, we will acknowledge receipt of your request and respond within 30 days. If we require additional time to respond to your request, we will notify you of the need for an extension and the reason for the extension within the initial 30-day period. Any extension will not exceed an additional 30 days.

If your request to exercise a right under the MHMD is denied, you may appeal that decision by emailing privacy@hopco.com. If your appeal is unsuccessful, you can raise a concern or lodge a complaint with the Washington State Attorney General at www.atg.wa.gov/file-complaint.

Geofencing Prohibition

HOPCo Digital Clinic does not implement geofencing technology around any facility that provides in-person healthcare services where such geofence would be used to: (i) identify or track consumers seeking healthcare services; (ii) collect consumer health data from consumers; or (iii) send notifications, messages, or advertisements to consumers related to their consumer health data.