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Our Privacy Policy

Effective Date: November 28, 2016

Welcome to Circulation! Circulation is a technology company that facilitates your access to non-emergency medical transportation offered by independent third party drivers and companies. This Privacy Policy is designed to inform users of the Circulation, Inc. (“Circulation”) website(s) hosted at app.circulation.com (the “Website”), and any of Circulation’s technology services (collectively, the “Technology Platform”) about how we gather and use personal information collected by us in connection with the Technology Platform.

This Privacy Policy covers how Circulation treats your personally identifiable information that could be used to identify you (“PII”) and Protected Health Information (“PHI”) (combined, “Personal Data”) that Circulation collects, receives, maintains, stores, or transmits, including information you and/or your healthcare provider transmit or submit through the Technology Platform. Your Personal Data includes information that individually identifies you or is information about you that can be traced back to you, your IP address, or your location. It may also include, but is not limited to your name, date of birth, home address, email address, phone number, and information about your health and/or other types of medical information.

Agreement:
By using the Technology Platform, you accept and hereby expressly consent to the terms of this Privacy Policy and you authorize Circulation to collect, use, and disclose your Personal Data for the limited purposes specified in this Privacy Policy. If you do not consent to this Privacy Policy, please do not use the Technology Platform.

Changes to Our Privacy Policy:
Circulation may modify or amend this Privacy Policy from time to time. If we make any material changes to the ways in which Personal Data is collected, used or transferred, as determined by Circulation, we will notify you of these changes by modification of this Privacy Policy, which will be available for your review through the Website and the effective date will be noted at the beginning of this Privacy Policy. You should review this Privacy Policy periodically so that you are up to date on our most current policies and practices. Your continued use of the Technology Platform after receiving notice signifies your acceptance of any such changes.

Your Personal Data We Collect and Use:
Circulation collects certain Personal Data and other non-personal information concerning your interactions with the Technology Platform. Circulation collects your Personal Data for the following purposes:

Registration:
We collect your Personal Data as part of the registration process for new users of the Technology Platform. For example, we may collect limited contact information from you and/or your healthcare provider, such as your name, date of birth, home address, email address, and phone number.
Provider-Reported Medical Information — We collect relevant medical information about you that is submitted to us by your healthcare provider, such as whether you require a wheelchair or oxygen tank when accessing third party transportation services.
Social Information:
We collect information that you provide to us pertaining to the people with whom you consent to share your Personal Data (such as a family member or caregiver).
Location Information:
We may use automated tracking methods such as GPS data to collect information regarding your pickup location, dropoff location, and travel route when using third party transportation services accessed through our Technology Platform.
Demographic Information:
We may also collect demographic information, such as age, gender and geographic location, as part of your profile in the Technology Platform.
Ride Notifications — While you are not required and/or prompted to respond to ride notifications (e.g., scheduling reminders sent to you by email, text message, and/or phone call), we collect any Personal Data you provide us in response to ride notifications.
User Feedback — From time to time, we may send you survey questions by email, text message, phone call, or other communication channels to provide us with feedback on third party drivers and/or our Technology Platform. We collect any responses that you provide.
Circulation reserves the right to authenticate your Personal Data for the purposes described above. We will not use your PHI for any other purpose without your written authorization, unless otherwise permitted or required by law.

Cookies and Web Beacons:
Our Website uses a software technology called "cookies." Cookies are small text files that we place in visitors' computer browsers to store their preferences. Cookies themselves do not contain any Personal Data.

"Web beacons" are small pieces of code placed on a web page to monitor the behavior and collect data about the visitors viewing a web page. For example, web beacons can be used to count the users who visit a web page or to deliver a cookie to the browser of a visitor viewing that page. We may use web beacons on our Website from time to time for this purpose.

Consent to Disclosure and Use of Personal Data in De-Identified Form:
Circulation may de-identify your Personal Data (“De-Identified Personal Data”) (i.e., remove all information that could be used to identify you, your relatives, employers, or household members) provided to us through the Technology Platform. In addition, Circulation may create “De-Identified Aggregated Data” from your Personal Data (e.g. De-Identified, aggregated analysis or summary obtained through processing your Personal Data). By agreeing to the terms of this Privacy Policy, you are authorizing Circulation to use and disclose your De-Identified Personal Data and De-Identified Aggregated Data (collectively, “De-Identified Data) for evaluation of the Technology Platform, quality improvement, reporting, analytics, research, studies, debugging, or any other lawful commercial purpose. You agree that: (a) you consent to such disclosures and uses of De-Identified Data; (b) Circulation is not obligated to pay any amount to you or otherwise compensate you or any other person in any way for such disclosures and uses; (c) Circulation is not required to furnish you with any other information of any kind regarding such disclosures and uses; and (d) to the extent that you have proprietary interest in any such De-Identified Data, you waive any right to such interest and you waive any right to seek compensation for such disclosures or uses.

How We Use Your Personal Data
  • We use your personal data to:
    • to provide you with access to the Technology Platform;
    • to provide you with information about other goods and services we offer that are similar to those that you have already signed up for or enquired about, except that we will not use PHI for marketing purposes without your prior written authorization;
    • to notify you about changes to the Technology Platform and/or this Privacy Policy;
    • to improve our Technology Platform and to ensure that content on the Technology Platform is presented in the most effective manner for you;
    • to administer our Technology Platform and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
    • to help keep our Technology Platform safe and secure.
You acknowledge that unless you request in writing otherwise, Circulation, in its sole discretion, has the right but not the obligation to store any information, whether Personal Data or otherwise, perpetually, to the extent permitted by law.

When We May Disclose Your Personal Data:
Healthcare Professionals — You acknowledge that we may share your Personal Data with your healthcare provider as necessary for you to access the Technology Platform and as otherwise permitted by federal and state privacy laws.
Third Parties Acting on Our Behalf:
As required by federal and state privacy laws, Circulation does not rent, sell, or share or use your Personal Data with nonaffiliated companies or persons, and Circulation does not otherwise disclose your Personal Data to nonaffiliated third parties without your prior written authorization, except that we may use and share your Personal Data with certain affiliated third parties to provide the Technology Platform to you on our behalf under confidentiality agreements, including, but not limited to, our current cloud host, Amazon Web Services. These third parties will not rent, sell, share or use your Personal Data for their own purposes.
Transportation Providers:
In order to facilitate your use of the Technology Platform, we may share your first name and/or pickup and dropoff GPS coordinates with independent drivers and companies that offer non-emergency medical transportation services.
Disclosure Required by Law:
We may be required to disclose your Personal Data in response to a legal process, for example, in response to a court order or a subpoena to comply with its applicable legal and regulatory reporting requirements. We also may disclose your Personal Data in response to a law enforcement agency's request, or where it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of our Terms and Conditions, or to verify or enforce compliance with applicable laws, or as otherwise required or permitted by law. In addition, we may transfer your Personal Data to an entity or individual that acquires, buys, or merges with Circulation, or our other business units.
Disclosure With Your Authorization:
Circulation may disclose your Personal Data in accordance with your prior written authorization.
Additionally, we may license, sell or otherwise share your De-identified Data with institutional clients, partners, investors and contractors for any purposes related to our marketing, business, and/or research practices.

Confidentiality and Security:
We take reasonable and necessary steps to ensure that all Personal Data collected will remain secure and in its original form, i.e., free from any alteration. We have put in place reasonable and appropriate physical, electronic, and administrative procedures in compliance with federal and state law in an effort to safeguard and help prevent unauthorized access, maintain data security, and correctly use the Personal Data we collect. We cannot, however, ensure or warrant the security of your PHI or any electronic Personal Data you transmit to us by phone call, email, and/or text message, which are unencrypted and insecure channels, and you do so at your own risk. Once we receive your transmission of information, we use commercially reasonable efforts to ensure the security of our systems. However, please note that this is not a guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards.

Circulation is not responsible for and will not be a party to any transactions between you and a third party provider of products, information or services accessed on third party websites. Circulation does not monitor such interactions to ensure the confidentiality of your Personal Data, including credit card information. Any separate charges, data records or obligations you incur in your dealings with third parties linked to or in conjunction with Circulation's Technology Platform are solely your responsibility. You acknowledge and understand that should you choose to provide any Personal Data to such third parties, the recipients of such personal information may not be subject to the same obligations under federal and state privacy regulations and may use or re-disclose the information so that it is no longer subject to privacy and security protections.

Confidentiality of Health Information:
Your healthcare providers may be subject to laws and regulations governing the use and disclosure of health information they create or receive. Included among those laws is the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Health Information Technology for Economic and Clinical Health of 2009 (“HITECH”), and the regulations adopted thereunder. When we store, process or transmit PHI (as such term is defined by HIPAA) on behalf of such a healthcare provider, we do so as its “business associate” (as also defined by HIPAA). When we operate as a business associate, we are also subject to such laws and regulations governing the use and disclosure of PHI, and we are prohibited from, among other things, using PHI in a manner that the healthcare provider itself may not. We are also required to, among other things, apply reasonable and appropriate measures to safeguard the confidentiality, integrity and availability of PHI we store and process on behalf of such healthcare providers.

General Information:
Links — Our Website may contain links or deep links to other websites, open search results, public feeds, or curated channels. Circulation generally reviews all content linked through third party websites, but is not responsible for such content, the privacy practices, or any advertisements on third party websites. Users should be aware of this when they leave our Website and are encouraged to review the privacy statements of each third party website. Moreover, Circulation is not responsible for any disclosures to third parties to whom you may disclose your Personal Data directly, including family members, caregivers and/or friends. This Privacy Policy applies solely to information collected by Circulation in relation to the Technology Platform.
Children — Circulation does not knowingly collect Personal Data from children under the age of 13, and our Technology Platform is not directed at users under the age of 13. If we find that Personal Data has inadvertently been collected for an individual under the age of 13, we will immediately delete it.
Data Storage Within USA — All of your Personal Data will be stored and processed within the United States of America.
Opt Out
You may affirmatively opt-out of receiving future messages and announcements from Circulation and may remove your name from our mailing lists. The opt-out provisions do not apply to information collected by cookies or used internally to recognize you and/or facilitate your use of the Technology Platform, or information we may retain to comply with legal requirements.

If you no longer consent to us collecting, using and sharing your Personal Data in accordance with this Privacy Policy, you should discontinue using our Technology Platform, and may dis-enroll by following the procedure described in our Terms and Conditions.

Questions and Suggestions:
If you have questions or suggestions about this Privacy Policy, or you believe that Circulation has violated your privacy rights, please email Circulation at info@circulation.com or write to us at Circulation Inc., 71 Commercial Street, Suite #90, Boston, MA 02109.