Privacy Policy

Definitions

Why we collect your information

We collect, use, disclose, and process Personal Data to provide the Services, improve your experience, and support technical assistance.

CircleHealth may use your Personal Data to contact you and respond to your questions, keep records of our communications with you, and perform safety backups of your data.

Personal Data may also be used to help you or your healthcare professional track Health Data, check whether a patient is eligible for a care program, record a patient's consent and enroll them in that program, generate anonymized and aggregated statistics, and improve the Software.

In addition, CircleHealth may use this information to develop new services and software features that better meet your needs.

CircleHealth does not use Personal Data or Health Data for advertising or marketing, and does not use it to determine creditworthiness or for lending purposes.

What information we collect

We collect Personal Data in different ways when you use and interact with our Services.

Active Personal Data Collection

You may choose to share information with us when you sign up for the Services, respond to us, or contact us directly. Depending on your choices, this may include information about you or others, such as your name, email address, mailing address, phone number, date of birth, gender, or a healthcare portal access key. You always decide what information you want to share with us.

Health Data Processing

If you use the Services as part of your medical care with a healthcare professional, you may share Health Data through the Services with that healthcare professional. In this case, CircleHealth acts only as a Data Processor for your Health Data.

Browser Extension Data Collection

When authorized clinic staff use a Browser Extension, it reads information from the patient chart or patient list that is open in their EHR, within the staff member's own logged-in session. Depending on the EHR and the extension, this may include the patient's name, patient or medical record number, date of birth or age, gender, insurance plan, contact details, diagnoses and ICD-10 codes, care gaps, and clinical chart information such as vitals, visits, medications, lab results and medical history. The Browser Extensions also collect the staff member's work email address and a one-time passcode to sign them in to their CircleHealth account, and they use the staff member's existing EHR session to read chart data. The "Browser Extensions" section below explains exactly how this data is used, stored, and shared.

Passive Information Collection

We also collect information about how you use the Services. This may include your IP address, pages visited, date and time of visits, referring website URL, and the device used to access the website or app. We may also collect usage details such as which features you use, how long you use them, and when, as well as technical error reports. In some cases, we may ask for demographic information such as age or gender. This information is used to improve the performance, reliability and appearance of the Services.

Third-Party Program Data

If you choose to connect third-party applications, devices, or apps to the Services ("Third-Party Programs"), CircleHealth may receive Personal Data collected by those programs in order to integrate them with the Services. These Third-Party Programs are not owned or controlled by CircleHealth. CircleHealth is not responsible for how those programs collect, use, or share your data, which is governed by their own privacy policies. If you connect Bluetooth devices that are directly supported by our Services, no third party is involved in collecting your data.

Necessary collection, use and disclosure

CircleHealth collects and uses your Personal Data only as needed to provide the Services. We do not use your Personal Data for any purpose other than the reason it was originally collected.

We keep your Personal Data secure, encrypted, and confidential. We do not disclose it except in the situations described below.

Law Enforcement

We may share Personal Data to comply with law enforcement requests, court orders, or other legal processes. We may also disclose information if we believe it is necessary to investigate, prevent, or respond to illegal activity, fraud, or threats to your safety or the safety of others, or as required by applicable law or regulation.

Bluetooth Devices

You may choose to connect the Services to health measurement devices using Bluetooth technology. These devices use Bluetooth Low Energy (LE) to allow real-time transfer of data. The Services do not use Bluetooth for any other purpose. If you do not want your data transmitted through Bluetooth, you can turn off Bluetooth on your device or disconnect any Bluetooth-enabled devices from the Software.

Employees and Authorized Contractors

CircleHealth employees and authorized independent contractors ("Authorized Personnel") may access your Personal Data only as needed to operate and support the Services. They may not use the data for their own purposes unless you give consent. All Authorized Personnel access data on a need-to-know basis and are subject to strict confidentiality and security obligations.

Service Providers

CircleHealth uses a small number of service providers (subcontractors) to run the Services. They may use Personal Data only to provide their service to CircleHealth, and they are contractually required to keep it confidential and secure. These service providers are:

• Cloud hosting providers, which store and run our servers and databases.
• SMS and email delivery providers, which receive a phone number or email address and the message content, only to deliver messages.
• Product analytics (Amplitude, United States), which receives feature-usage events from the Circle Health (Patient Enrollment) extension, such as "eligibility checked" or "enroll clicked", together with the signed-in staff member's user ID, work email address, role and organization ID, a random device identifier, the extension version and the EHR name. It does not receive patient names, patient identifiers or Health Data.
• Error monitoring (Sentry, on a CircleHealth-operated server), which receives technical error reports, browser and device information, IP address, and the signed-in staff member's user ID, name, email address and role, so we can find and fix problems. An error report may also contain the internal EHR identifier of the patient or visit being worked on and the address of the EHR page where the error happened. Because this server is operated by CircleHealth, this information is not shared with a third party.

Business Transfers

CircleHealth may be involved in a merger, sale, or transfer of some or all of its assets. If this happens, your Personal Data may be shared with the organization involved in the transaction, as permitted by law. Any such organization will be required to protect your Personal Data in a manner consistent with this Privacy Policy and applicable law.

Express Consent

CircleHealth may also disclose your Personal Data when you explicitly request or authorize us to do so.

Browser Extensions

CircleHealth's Browser Extensions are available only to authorized staff at healthcare practices that have an agreement with CircleHealth. They are not intended for patients or the general public. CircleHealth acts as a Data Processor for any patient data the Browser Extensions handle and, where HIPAA applies, as a Business Associate of the healthcare practice.

Circle Health (Patient Enrollment) Extension

Purpose. This extension lets clinic staff check whether the patient whose chart is open in their EHR is eligible for care management programs such as Chronic Care Management (CCM), see the patient's care gaps, and enroll that patient with their consent, without leaving the chart. It works in Practice Fusion, eClinicalWorks, Elation and MDland (iClinic).

Data collection. From the open patient chart, the extension reads the patient's name, patient or medical record number, date of birth or age, gender, insurance plan, and diagnoses with ICD-10 codes. In MDland (iClinic), it also reads the patient's demographics, vitals, visits, problem list, medications, lab results and medical history so they can be added to the enrollment record. In Practice Fusion, it also shows the patient's care gaps and the clinic's enrollment counts, which it receives from CircleHealth's servers. To sign in, it collects the staff member's work email address and a one-time passcode, and receives the staff member's name, role and organization ID from CircleHealth.

Data handling. The extension uses this data only to show the right patient, check program eligibility (for example, whether the patient has two or more chronic conditions), show care gaps, and enroll the patient. Patient data leaves the browser in these cases only:

• Eligibility and care gaps in Practice Fusion. When a staff member opens a patient's chart, the extension sends the patient's Practice Fusion ID, name and gender, together with the staff member's Practice Fusion session identifier, to the practice's CircleHealth account, so CircleHealth can return the patient's eligibility and care gaps. In the other EHRs, eligibility is checked in the browser.
• Enrollment.When the staff member clicks "Record Consent & Enroll", the patient's details, the chronic conditions and programs the staff member selected, and the consent record are sent to the practice's CircleHealth account.
• EHR session for Elation and Practice Fusion. To complete an enrollment from Elation, the extension includes the staff member's existing Elation session cookies, so CircleHealth's servers can load the patient's medications and allergies from Elation on the staff member's behalf. In Practice Fusion, the session identifier is used in the same way. These session credentials are used only for that request, are never used for any other purpose, and are never shared with third parties.

Data storage. The staff member's sign-in session (session token, user ID, work email address, name, role and organization ID) is stored in the browser's local extension storage until they sign out, the session expires, or the extension is removed. Feature-usage events waiting to be sent, and a random device identifier used to group them, are also kept in local extension storage until they are sent or the extension is removed. Temporary request IDs and cached eligibility results are kept in the browser's session storage and are deleted automatically when the browser closes. Patient data is not kept in the browser after it has been used. Enrollment and consent records are stored on CircleHealth's servers, as described under "Personal Data Hosting and Storing".

Data sharing. Patient data collected by the extension goes only to the practice's own CircleHealth account. It is never sold, never used for advertising, and never shared with third parties, except the service providers listed above as needed to run the Services, or as required by law. Feature-usage analytics never contain patient data.

Permissions. The extension asks for the following browser permissions, and uses each one only for the reason given:

• storage: to save the sign-in session and short-term working data in the browser.
• cookies: to read the staff member's existing Elation session cookies, so CircleHealth can load the open patient's medications and allergies within that staff member's own logged-in session when they enroll a patient, as described above. The extension does not read cookies from any other website.
• Access to the EHR websites (mdland.net, practicefusion.com, ecwcloud.com and elationemr.com): to show the enrollment card on the patient chart and read chart data in these EHRs only. The extension does not run on any other website.
• Access to CircleHealth's servers (circle.care): to send sign-in, eligibility and enrollment requests.

The extension does not read your browsing history, does not collect EHR passwords, and does not track your activity on other websites.

Patient Data Extraction Extensions

Purpose. These extensions, for Practice Fusion, Elation and eClinicalWorks, let authorized clinic staff export a list of their own practice's patients from their EHR into a CSV file, to identify patients eligible for care management programs and prepare outreach to them.

Data collection and handling. Within the staff member's own logged-in session, the extensions read patient identifiers, names, dates of birth, gender, insurance, diagnoses with ICD-10 codes, medications, contact details and recent visit information from the EHR, and use them only to build the export file, check program eligibility and prepare a personalized outreach call script.

Data storage and sharing. The CSV file is saved to the staff member's own computer. To prepare the call script, the patient's name, date of birth, gender, insurance, provider and a summary of recent visits are sent to the practice's CircleHealth account over an encrypted connection. Export progress is stored in the browser until the export finishes or the extension is removed. The data is not shared with any third party.

Permissions. storage (export progress), downloads (saving the CSV file), and access to the EHR website and to CircleHealth's servers. The eClinicalWorks extension also uses tabs and scripting (to run the export in the open eClinicalWorks tab), alarms (to run long exports in batches) and notifications (to tell the staff member when an export is finished).

Limited Use

The use of information received through CircleHealth's Browser Extensions complies with the Chrome Web Store User Data Policy, including the Limited Use requirements. CircleHealth uses this information only to provide and improve each extension's single purpose described above. We do not sell it, transfer it to third parties for any other purpose, use it for advertising, or use it to determine creditworthiness or for lending purposes. We do not allow humans to read this information unless the user has given consent, it is needed for security purposes or to comply with law, or it has been aggregated and anonymized for internal operations.

Removing a Browser Extension

You can remove a Browser Extension at any time from your browser's extensions page (chrome://extensions in Google Chrome). Removing it deletes all data it stored in your browser. To request deletion of data already sent to CircleHealth, contact us at hello@circle.care.

SMS and Text Messaging

CircleHealth provides a technology platform that enables healthcare providers and their care teams ("Clients") to send text messages (SMS) to their patients as part of care management services, such as appointment reminders, health check-ins, and program notifications. In these cases, CircleHealth acts solely as a technology service provider on behalf of the Client and does not independently initiate or control the content of such messages.

CircleHealth does not sell, rent, share, or disclose patient phone numbers or SMS opt-in consent data to any third party or affiliate for marketing or promotional purposes.

We do not share Personal Data, including SMS opt-in consent data processed on behalf of our Clients, with third parties or affiliates for marketing or promotional purposes.

SMS opt-in data and consent records are shared only with subcontractors or outsourced service providers (such as SMS delivery platforms) solely to the extent necessary to deliver messages on behalf of the Client. These providers are contractually prohibited from using such data for any other purpose.

Patients who wish to opt out of text messages may reply STOP to any message. For help, reply HELP. Message and data rates may apply.

Personal Data Hosting and Storing

CircleHealth stores your Personal Data in secure cloud infrastructure and compliant data centers, following applicable data protection and security standards. Personal Data is encrypted when it is sent between your device, the Browser Extensions and our servers, and when it is stored.

Except for anonymized or non-identifiable data, which may be stored indefinitely, CircleHealth retains your Personal Data for up to 12 months after you delete your account, request account deletion, or when your healthcare professional deletes your account.

Patient records received through the Browser Extensions on behalf of a healthcare practice are kept for as long as the practice's agreement with CircleHealth requires, and are then deleted or returned to the practice in accordance with that agreement and applicable law.

Technical error reports and feature-usage analytics are kept for up to 90 days. Data that the Browser Extensions store in your browser is kept only as described in the "Browser Extensions" section above.

After this retention period, CircleHealth may delete your Personal Data in accordance with applicable laws.

Your Personal Data may be stored or processed in locations outside your state or country, as permitted by applicable regional laws. These laws may include, but are not limited to, the General Data Protection Regulation (GDPR) of the European Union, the Health Insurance Portability and Accountability Act (HIPAA) of the United States, and the Personal Information Protection and Electronic Documents Act (PIPEDA) of Canada.

Access and Update

You have the right to access and receive a copy of your Personal Data.

You also have the right to review, update, correct, or request changes to any Personal Data that you believe is inaccurate or incomplete. You may also ask us to delete your Personal Data, subject to any records we are required to keep by law or by our agreement with your healthcare professional.

To exercise these rights, please contact us at hello@circle.care.

Withdrawal of Consent and Opt-out

If you do not agree with how we use your Personal Data as described in this Privacy Policy, you may withdraw your consent for the collection, use, and disclosure of your Personal Data.

To withdraw your consent, please contact us at hello@circle.care.

You may also opt out of receiving electronic communications from us at any time by using the "unsubscribe" or "opt-out" instructions included in those communications.

Generally not suitable for children under the age of 13

CircleHealth Services are not intended for children under the age of 13.

We do not knowingly collect Personal Data directly from children under this age through the Services.

However, we may collect information about children or babies when it is provided by their parents or legal guardians as part of the Services. Users are asked not to share information about a child or baby unless they have first obtained consent from the child's parent or legal guardian.

By providing Personal Data about a child or baby, you confirm that you are legally authorized to share that information.

We encourage parents and legal guardians to speak with their children about safe internet use and the information they share through the Services.

Third-Party Programs

CircleHealth is not responsible for the features, content, accuracy, or behavior of Third-Party Programs that are linked to, framed within, or shown as search results in the Services.

Your use of Third-Party Programs is at your own risk and is subject to their own terms of use and privacy policies.

CircleHealth does not endorse any product, service, or treatment that may be advertised or promoted through the Services.

CircleHealth is not liable for any loss or damage of any kind that may result from your use of Third-Party Programs.

Security

CircleHealth uses commercially reasonable physical, electronic, and administrative safeguards to protect the Personal Data we collect, including encryption in transit and at rest, one-time passcode sign-in, time-limited sessions, and access limited to Authorized Personnel on a need-to-know basis. In the Browser Extensions, sign-in tokens and EHR session credentials are handled only by the extension's background process and are never exposed to the web pages it runs on.

However, no method of storing or transmitting data over the internet is completely secure. As a result, CircleHealth cannot guarantee absolute security or eliminate all security or privacy risks related to Personal Data.

CircleHealth acts as a Data Processor and is not responsible for any data breach, unauthorized disclosure, or unlawful use of Personal Data or Health Data that, at the time of the incident, was under the control of your healthcare professional.

Security and Data Breach Notification

CircleHealth uses reasonable administrative, technical, and physical safeguards to protect Personal Data.

If a data breach or security incident involving Personal Data occurs, CircleHealth will notify affected users as required by applicable laws and regulations. Notification may be provided by email or through in-application messages, as appropriate.

Changes to This Privacy Policy

CircleHealth may update this Privacy Policy from time to time.

When we make changes, we will post the updated policy on this page and revise the "Last updated" date at the top. Where required by law, we will also notify users through in-application notices where this Privacy Policy is referenced.

Your continued use of the Services after the updated Privacy Policy becomes effective means that you accept the changes.

Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact us at hello@circle.care, or write to CircleHealth, 1800 Coastal Hwy, Lewes, DE 19958.