Personal Information Provided by You
Clutch collects your personally identifiable information (“PII”) through the Clutch Services when you choose to provide such information, such as when registering to become a Clutch member so that you may receive information and updates regarding the Clutch Services. PII can include your name, prescription and over-the-counter medications, address, telephone number, e-mail address, Social Security number, date of birth, healthcare coverage, pharmacy, and physician.
Clutch’s Collection of Your Publicly Available Personal Information
Clutch may request publicly available personal information about you that is maintained by the consumer data companies Acxiom and/or LexisNexis or other similar services. This publicly available personal information is used by Clutch to verify your identity in online transactions and to aid in tailoring the Clutch Services to your needs.
Clutch’s Use of Personal Information
Providing the Clutch Services. Clutch will use your PII only to address your requests for information, products or services or in connection with providing you the Clutch Services. Specifically, Clutch may use your PII to provide the following Clutch Services: (i) obtaining your medical information, including PHI, from your physicians, pharmacies, healthcare coverage providers and pharmacy benefit managers (collectively, “Healthcare Providers”), (ii) finding lower prices for your healthcare, or (iii) contacting Healthcare Providers, including physicians or pharmacies, on your behalf to request information necessary to provide the Clutch Services, including, but not limited to, your medical and healthcare coverage information, your medication history, and your billing information and history.
Assisting You in Managing Your Healthcare. Clutch may use your PII to assist you in managing your prescriptions. To do so, Clutch may contact you by phone, email or text to (i) find out if you wish to request a prescription refill, (ii) remind you to request a prescription refill, (iii) confirm that a refill request has been submitted, or (iv) ask if you wish to transfer a prescription to a different pharmacy.
Marketing by Clutch. Clutch may also use your PII to deliver advertisements and marketing communications to you that we believe may be of interest. These advertisements and marketing communications will be delivered solely by Clutch. Marketing communications that you receive from Clutch may include (i) advertisements for the Clutch Services, and (ii) advertisements for prescription drugs
Disclosure of Personal Information
Disclosures Related to Providing the Clutch Services
You acknowledge that any and all information that you provide to Clutch may be disclosed to Healthcare Providers in order to provide the Clutch Services. Clutch is not responsible for protecting the privacy of your information when it is in the possession of a Healthcare Provider.
Disclosures to Third Parties Assisting In Our Operations. Clutch may share your PII under confidentiality agreements with other companies that work with, or on behalf of, Clutch to provide products and services. These companies may use your PII to assist Clutch in its operations. However, these companies do not have any independent right to share this information.
Disclosures Under Special Circumstances. We may provide information about you to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. We believe it is necessary to share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, or as otherwise required by law.
Automatically Collected Information and Anonymous Information
Each time a visitor uses the Clutch Services, Clutch collects some information to improve the overall quality of the visitor’s online experience.
Aggregated Data. Clutch collects aggregate queries for internal reporting and may also count, track, and aggregate the visitor’s activity into Clutch’s analysis of general traffic-flow on the Websites. To these ends, Clutch may merge information about you into aggregated group data. In some cases, Clutch may remove personal identifiers from PII and maintain it in aggregate form that may later be combined with other information to generate anonymous, aggregated statistical information. Such anonymous, group data may be shared on an aggregated basis with Clutch’s affiliates, business partners, service providers and/or vendors; if it does so, Clutch will not disclose your individual identity.
Web Server Logs and IP Addresses. An Internet Protocol (“IP”) address is a number that automatically identifies the computer/machine you have used to access the Internet. The IP address enables our server to send you the web pages that you want to visit, and it may disclose the server owned by your Internet Service Provider. Clutch may use IP addresses to conduct analyses and performance reviews and to administer the Clutch Services.
Clutch understands that storing our data in a secure manner is essential. Clutch stores PII and other data using industry standard physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification. Although Clutch is neither a covered entity nor a business associate subject to HIPAA legal requirements, Clutch has implemented data security measures that are consistent with the standards of the HIPAA security regulations. Please note, however, that while Clutch has endeavored to create a secure and reliable website for users, the confidentiality of any communication or material transmitted to or from the Clutch Services or via e-mail cannot be guaranteed.
Your Role in Protecting Your Privacy
Response to “Do Not Track” Signals
Some Internet browsers include the ability to transmit “Do Not Track” signals. Since uniform standards for “Do Not Track” signals have not yet been adopted, Clutch does not process or respond to “Do Not Track” signals.
Children’s Privacy Protection
Under Age 13
Clutch understands the importance of protecting children’s privacy in the interactive online world. The Clutch Services, including the Mobile App, are not designed for, or intentionally targeted at, children under 13 years of age. It is not our policy to intentionally collect or maintain information about anyone under the age of 13. No one under the age of 13 should submit any PII to Clutch and/or the Mobile App.
Under Age 18
Minors under 18 years of age may have the PII that they have provided to Clutch through the Clutch Services, including the Mobile App, deleted by sending an email to email@example.com requesting deletion. Please note that, while we make reasonable efforts to comply with such requests, deletion of your personal information does not ensure complete and comprehensive removal of that data from all systems.
At certain locations on the Mobile App where information about you may be requested, you are offered the opportunity to opt-out of receiving communications from Clutch. You may also review and request changes to your PII that Clutch has collected, including the removal of your PII from Clutch’s databases in order to prevent receipt of future communications or to halt receipt of the Clutch Services, using any of the following options:
You can send your request via email to: firstname.lastname@example.org
You can mail your request to the following postal address:
Clutch Health LLC
438 Porsche Ave
Atlanta, GA 30354
Attn: Chief Privacy Officer