GapCare Privacy Policy and Data Protection

Privacy Policy

Welcome to GapCare. Your privacy is important to us, and we are committed to transparency about how we collect, use, and share your personal information. Please read this Privacy Policy (the “Privacy Policy”) carefully, as it contains essential information about your legal rights and how we handle your data.

This Privacy Policy is part of the Terms of Use, which outline the binding terms between you and us. In this Privacy Policy, “GapCare,” “we,” “our,” and “us” refer to GapCare and its affiliates and subsidiaries. Any capitalized terms not defined in this Privacy Policy have the meanings assigned to them in the Terms of Use.

Scope of This Privacy Policy

This Privacy Policy applies to your access to and use of the following services, which we collectively refer to as the “Services”:

Our digitally delivered health care programs, including those for hypertension, diabetes, and weight management (the “GapCare Programs”).

Our mobile applications, including any current and future GapCare Apps (the “Apps”).

The websites we operate (e.g., www.gapcare.health) (the “Sites”).

All related features, services, and tools provided by GapCare.

Defined Terms

Throughout this Privacy Policy, we use specific terms to differentiate between individuals who engage with our Services:

“GapCare Members” refers to individuals who apply for, register for, and/or enroll in one or more GapCare Programs and interact with the Programs and/or Apps.

“Site Visitors” refers to individuals who visit our Sites or interact with the Services without registering as a GapCare Member.

By accessing or using any part of the Services, you agree to this Privacy Policy and consent to the collection, use, disclosure, and processing of your personal information as described herein.

Notice of Privacy Practices

If you are a GapCare Member, you also acknowledge that you have read and understood our Notice of HIPAA Privacy Practices. This notice details how we use and disclose health information collected during the delivery of care through GapCare Programs, including during the application process. This information is used for treatment, payment, and healthcare operations in compliance with applicable laws, including the Health Insurance Portability and Accountability Act of 1996 (HIPAA), as amended.

In the event of any conflict between this Privacy Policy and the Notice of HIPAA Privacy Practices, the Notice of HIPAA Privacy Practices will govern for GapCare Members.

State-Specific Privacy Information

For GapCare Members and Site Visitors located in California, Colorado, Connecticut, Utah, Virginia, and other states with specific privacy laws, additional details about our privacy practices and your rights are available here.

We are committed to protecting your personal information and maintaining transparency about our data handling practices. If you have any questions about this Privacy Policy or your privacy rights, please contact us at hello@gapcare.com.

What is the Purpose of This Privacy Policy?

At GapCare, safeguarding and managing your personal information is integral to how we operate. This Privacy Policy outlines how we collect, store, use, disclose, and process your personal information. This includes, but is not limited to, how we gather, evaluate, modify, store, share, and transfer your data.

We are committed to protecting your privacy:

No Renting or Selling of Personal Information: We will never rent or sell your personal information. Likewise, our business partners who assist in providing our Services are prohibited from renting or selling your data.
Limited Sharing with Third Parties: We will not share your personal information with third parties for their own purposes unless explicitly authorized, directed, or instructed by you. For GapCare Members, any disclosures will comply with our Notice of HIPAA Privacy Practices and applicable laws, such as HIPAA, which governs the use of Protected Health Information (PHI).
Business Transfers: In the event of a transfer of part of our business, we may transfer personal information to the successor entity. However, the successor must adhere to the terms outlined in this Privacy Policy.

In certain situations, you may instruct us to share your information with non-affiliated companies. For example, you might authorize us to share sensitive health information with third-party services like Apple HealthKit or Google Health services. When you choose to share information with non-affiliated companies or access their services, their privacy policies and terms will apply, not ours.

It is your responsibility to review and understand the privacy practices and terms of such third-party companies or services. GapCare is not responsible for how these entities use or protect your data. For more information, please refer to the applicable Terms of Use or the policies of these third parties.

What Does This Privacy Policy Cover?

This Privacy Policy explains how GapCare collects, uses, and discloses personal information starting from your first interaction with our Sites, Apps, or Services and continuing throughout your use of GapCare’s programs or related features. As a healthcare provider, GapCare is dedicated to safeguarding the privacy and integrity of the protected health information (PHI) we collect through online clinical assessments, program applications, or participation in our health management services, including data gathered from digital devices used in connection with these programs.

Personal Information – In General

In this Privacy Policy, “Personal Information” refers to any information that can be used to identify or contact you, as well as any identifiable information related to your use of the Services. Examples include your first and last name, contact details, profile information, and any submissions or data you share with us through the Services. This may include “personal information” as defined by state and federal laws, such as those in California, Colorado, Connecticut, Utah, and Virginia. Residents of these states can review additional information on their rights in our Supplemental State Privacy Notice.

Protected Health Information (PHI)

“Protected Health Information” or “PHI” refers to a specific subset of Personal Information created, received, or maintained in connection with your registration, participation in, or application for GapCare’s programs. This includes information shared through online health assessments or data collected via connected devices. PHI relates to:

Your past, present, or future physical or mental health conditions,
The provision of healthcare services to you, or
Payment for your healthcare services.

Federal and state laws, including the Health Insurance Portability and Accountability Act (HIPAA), provide additional protections and rights for PHI. For more detailed information on how GapCare handles PHI, please refer to our Notice of HIPAA Privacy Practices.

Our Commitment to Your Privacy

Your privacy is of the utmost importance to us. We are committed to responsibly managing and protecting your Personal Information as part of the Services we provide.

What Personal Information Do We Collect?

At GapCare, we collect Personal Information from you and certain devices you use, as detailed below. For GapCare Members, this includes information collected through health assessments, applications, registrations, eligibility checks (including those conducted on our Sites, Apps, or through our business partners), and your use of our Apps and health programs.

For Site Visitors, we collect Personal Information that you may provide through the Sites. Additionally, for both GapCare Members and Site Visitors, we automatically collect certain Personal Information, as further described below. We may also gather information from third-party sources, such as email service providers or other authorized data sources. The collection of this information begins when you first access our Services.

The information we collect helps us:

Provide you with the Services,
Manage GapCare Members’ accounts,
Communicate with you about the services we offer,
Respond to your inquiries,
Gather feedback to improve our Services,
Understand who uses our Services and assess their performance,
Review behavior and activity of GapCare Members and Site Visitors,
Personalize and enhance your experience with our Services,
Conduct research to improve our programs,
Manage the security of our systems, and
Comply with applicable legal and regulatory requirements.

Occasionally, we may acquire additional information about you from third parties and use it to supplement or update the Personal Information we already have. For instance, we may obtain contact information or verify your coverage eligibility for a GapCare Program through external sources. As a healthcare provider, we may also receive Personal Information from other entities in the healthcare system, such as other healthcare providers, your insurance company, or health data exchanges.

Below, we provide more detail on the types of Personal Information we collect from you, both directly and automatically:

Personal Information That You Provide to Us

Information You Provide Directly

We collect and store any information you provide through our Sites, Apps, or Services. This includes information provided during health assessments, applications, registrations, eligibility checks, communications via email or phone, or through your interactions with our Services. This information may include:

Full name, gender, username, and password,
Contact information (e.g., phone number, email address, postal address),
Health-related data (e.g., weight, pre-existing conditions, blood glucose readings, blood pressure, exercise habits, sleep patterns, and prior treatments),
Messages exchanged with our Care Teams,
Health insurance information,
User submissions (as outlined in our Terms of Use),
Payment details, if applicable, and
Any other details you voluntarily provide.

If you are a GapCare Member, you may participate in video consultations as part of our programs. Please note that we may record these sessions for training purposes, and by participating, you consent to this recording.

Information Collected via GapCare-Provided Devices

GapCare may provide you with digital devices to assist in tracking your health progress. These devices often send information automatically to our system and related programs. These “GapCare-Provided Devices” are pre-configured to share health data without requiring additional action from you. Examples of data collected through these devices include weight, blood pressure readings, and glucose levels. For more information, refer to our Terms of Use.

Information from Third-Party Data Sources

GapCare also allows you to share data with us from third parties you engage with. These are referred to as “Third-Party Data Sources” and may include:

Health devices you own (e.g., blood glucose monitors or fitness trackers),
External healthcare providers that share information at your direction, and
Wellness platforms, such as Apple HealthKit or Google Fit, that you authorize to share information with us.

Examples of data we may receive from these sources include weight, exercise logs, sleep patterns, and other health-related metrics. By using these sources, you agree to share your information with us in accordance with their terms.

Personal Information We Collect Automatically

In addition to the information you provide, we collect certain Personal Information automatically when you interact with our Sites, Apps, or Services. Examples include:

Device information (e.g., browser type, operating system, IP address),
Usage data (e.g., pages visited, clicks, time spent on our Sites or Apps), and
Device location (if enabled).

This information helps us improve your experience and ensure the security of our systems.

Your privacy and the protection of your data are of the utmost importance to us. We handle your Personal Information with care, ensuring it is used responsibly and in compliance with applicable laws.

How We Use Your Personal Information

We use the Personal Information you provide for the purposes outlined above, as well as for any other purposes directly related to the Services you utilize. This allows us to deliver a personalized and engaging experience. If you choose not to share certain Personal Information, we may be unable to provide access to some features or services.

Personal Information Shared with Us as Your Healthcare Provider

As a GapCare Member, we may receive Personal Information, including Protected Health Information (PHI), from other entities within the healthcare system that are legally permitted to share such data under HIPAA regulations. For example, your health insurance provider, healthcare professionals, or referral organizations may share relevant information with us, such as records of prior treatments or prescriptions. Additionally, we may receive PHI from health data exchanges, enabling us to provide better care and support your participation in GapCare Programs. For more details, refer to our Notice of HIPAA Privacy Practices.

Information Licensed or Collected from Third Parties

We may also obtain Personal Information, such as contact details or demographic data, from third-party sources like email database providers, event organizers, or content syndication platforms. If you receive email communications from us using this data, you may opt-out by following the instructions included in those emails. Additionally, if we combine information from third-party sources with the Personal Information or PHI collected through our Services, we treat the combined data in accordance with this Privacy Policy.

Automatically Collected Personal Information

In addition to the information you provide, we and our third-party service providers may collect certain information automatically when you interact with our Sites, Apps, or Services. This “Usage Information” may include:

Device Information: Details about your device, such as browser type, operating system, IP address, and mobile network information.
Activity Data: Information about your interactions with the Sites or Apps, such as pages visited, links clicked, or time spent on specific sections.
Location Data: Your device’s location, if enabled.

If this data is linked to identifiable Personal Information, we treat it as Personal Information. For GapCare Members, Usage Information that relates to your PHI is safeguarded in accordance with our Notice of HIPAA Privacy Practices.

Browser or Device Information

We automatically log certain Usage Information from your browser whenever you interact with our Sites or Apps. This data helps us provide support, recognize returning users, and enhance your experience. For instance, we use this data to track how frequently users visit specific sections or features to improve usability.

You can adjust your browser settings to disable data collection technologies like cookies, but doing so may affect your experience with the Services. For example, some features may not function properly if certain cookies are disabled.

Email Communications and Notifications

When you open an email or notification from us, we may receive a confirmation if your device supports it. This helps us assess the effectiveness of our communications and make them more relevant.

GapCare Members can adjust their email and notification preferences within the Apps or by changing the settings on their devices.
You can also opt out of promotional emails by following the “unsubscribe” link provided in our emails. However, please note that opting out of emails may limit certain program reminders and valuable updates.

Tracking Technologies

We use various tracking methods (“Tracking Technologies”) to collect Usage Information about your interactions with our Sites, Apps, and Services. These technologies allow us to improve performance, ensure security, and offer personalized functionality. Common tracking technologies include:

Cookies

Cookies are small files that are placed on your device to help us recognize you and understand how you use our Sites or Services. Cookies may track:

Which pages you visit,
How often you return to the Site, and
Your preferences and settings.

While you can disable cookies via your browser settings, doing so may limit the functionality of some features on our Sites or Apps.

Embedded Scripts

Embedded scripts are temporary pieces of code downloaded to your device to collect information about your interactions with our Services. They remain active only while you are connected to the Services and are automatically deleted afterward.

Web Beacons

Web beacons are small graphic images or snippets of code used to track:

How many users visit specific pages,
How many emails are opened, and
How users navigate the Services.

Web beacons provide valuable insights into how our users engage with our content.

Third-Party Use of Tracking Technologies

This Privacy Policy applies only to the use of cookies and other tracking technologies employed by GapCare. It does not cover tracking conducted by third-party advertisers or external sites. To understand how third parties collect and use your information, please review their respective privacy policies. As noted earlier, we do not rent or sell your Personal Information or share it with third parties for their independent use unless directed by you.

Ownership of Personal Information You Provide to GapCare

You retain all ownership and licensing rights over any User Submissions you provide to GapCare, including Personal Information and Protected Health Information (PHI). However, when you use our Services or direct, authorize, or instruct others to share your User Submissions with us, you grant us a license to use these submissions as outlined in our Terms of Use, this Privacy Policy, and, for GapCare Members, our Notice of HIPAA Privacy Practices.

When and How We Share Your Personal Information

Below, we outline the situations in which we may share your Personal Information:

Information Shared with Other GapCare Members

If you participate in any GapCare Program with group or community features, certain Personal Information you choose to share may become visible to other GapCare Members within the same group. These other members may include colleagues or acquaintances. By using these group-based features, you authorize GapCare to disclose information relevant to your participation in the Services, including your clinical eligibility, which may imply certain health conditions or risks.

If you create or update a profile as part of your GapCare Membership, you may include information such as:

Details about your health, symptoms, or treatments
Personal stories, photos, or videos
Progress summaries or activity streaks

This information may be visible to other GapCare Members. However, personal biometrics like your weight or device readings will remain private unless you explicitly choose to share them. You can select a display name (such as a nickname) and a profile image to represent you within the group, though your Care Team will always have access to your legal name.

Peer Groups and Online Communities

As part of your participation in a GapCare Program, we may place you in an online peer group. These groups may include interactive features such as:

Discussion boards
Chat rooms
Community pages
Blogs
Messaging platforms
Activities, polls, or games

Any text, images, or other materials you post in these groups may be visible to current and future group members. Your GapCare Member ID, profile photo, and relevant progress summaries may also be visible to other members when you send messages or participate in these groups.

Safeguarding Your Privacy

While GapCare takes extensive measures to protect your privacy, we cannot control how other group members use or disclose the information you share in these group settings. We encourage you to be cautious and mindful about the type of Personal Information, including health data, that you choose to share in group forums, on your profile, or elsewhere within the Services.

WE EXPLICITLY DISCLAIM ANY RESPONSIBILITY FOR HOW OTHERS MAY USE OR DISCLOSE ANY INFORMATION, INCLUDING PERSONAL INFORMATION, THAT YOU CHOOSE TO SHARE OR DISCLOSE ON YOUR GAPCARE MEMBER PROFILE, IN GROUPS, OR IN ANY PUBLIC-FACING FEATURES OF OUR SERVICES. THIS INCLUDES, BUT IS NOT LIMITED TO, DISCUSSION BOARDS, CHAT ROOMS, MESSAGING PLATFORMS, OR OTHER GROUP-BASED FEATURES DESCRIBED ABOVE. BY VOLUNTARILY SHARING YOUR INFORMATION THROUGH THESE FEATURES, YOU ACKNOWLEDGE AND ACCEPT ANY RISKS OR POTENTIAL CONSEQUENCES ASSOCIATED WITH THE DISCLOSURE OF SUCH INFORMATION.

COMMUNICATIONS IN RESPONSE TO USER SUBMISSIONS

As part of the Services, we may send you emails or other communications related to your submissions or interactions with our platform. By submitting content or information, you acknowledge and agree that we may contact you via email, text messages, phone calls, or other means, as deemed necessary to address or respond to your submissions.

INFORMATION SHARED WITH OUR AGENTS

We employ third-party service providers and partners to assist us in delivering the Services, which may require sharing your information with them. For example, when determining eligibility or assisting with applications for GapCare programs, our business partners may facilitate these processes on our behalf. By using the Services, you consent to GapCare disclosing your Personal Information to authorized personnel and administrators, including our Care Teams and third-party agents. These partners are contractually bound to maintain appropriate privacy and security measures, and we ensure that they only access the minimum amount of information required to perform their tasks. Additionally, agents are prohibited from selling, renting, or using your Personal Information for their own purposes without explicit authorization. For any Protected Health Information (PHI), we ensure compliance with HIPAA and other applicable legal standards.

INFORMATION SHARED WITH OTHER ENTITIES PERMITTED BY HIPAA, INCLUDING SPONSORS, THIRD-PARTY ADMINISTRATORS, AND HEALTHCARE PROVIDERS

If you are a GapCare Member, we may share certain Personal Information and PHI with entities authorized under HIPAA for legally permitted purposes. These entities may include sponsors, third-party administrators, healthcare providers, and their respective agents. Such sharing might occur in scenarios such as processing claims, coordinating treatment, or performing healthcare operations. For example, third-party entities covering your participation in GapCare programs may receive this information as necessary. Similarly, information may be shared with other healthcare providers involved in your care or through health information exchanges for purposes such as treatment and operations.

This sharing of information strictly adheres to HIPAA regulations and applicable legal requirements, as detailed in our Notice of HIPAA Privacy Practices.

PROMOTIONAL OFFERS AND COMMUNICATION PREFERENCES

From time to time, we may send promotional communications to inform you about new services, features, or offers. You can manage these communications by clicking the “unsubscribe” link at the bottom of our emails. We process opt-out requests promptly, in accordance with applicable laws, but you may still receive emails as we finalize your request. GapCare Members may also update their communication preferences in their profiles. Please note that transactional emails, such as updates regarding your account or changes to terms and conditions, cannot be opted out of.

We will never share your Personal Information with other businesses for their own purposes unless explicitly authorized by you, except as described in our Notice of HIPAA Privacy Practices. In some cases, when you register for events such as webinars, your Personal Information may be shared with third-party co-sponsors, and this will be clearly communicated to you. If you direct us to share information with non-affiliated companies, these third parties will not be governed by our Privacy Policy, and you are solely responsible for understanding their privacy practices.

INFORMATION SHARED WITH OTHER BUSINESSES WE DO NOT CONTROL

To enhance your experience, our Services may connect you with third-party businesses for related services or products. For example, GapCare Members may contact external healthcare providers for referrals or prescriptions through our platform. In other cases, we may offer services or products in partnership with affiliated businesses.

Sharing at Your Direction: You may direct us to share information with these businesses, and they will operate under their own terms of use and privacy policies. In such cases, you are solely responsible for understanding and agreeing to their terms.
Sharing When Permitted by Law: In situations where third-party businesses are authorized to receive PHI for purposes permitted under HIPAA, we may share this information as required. These businesses are then responsible for using and safeguarding your PHI in compliance with HIPAA.

In either scenario, these third-party businesses are not bound by the terms of GapCare’s Privacy Policy or Notice of HIPAA Privacy Practices.

REFERRALS TO FAMILY, COLLEAGUES, AND FRIENDS

Occasionally, we may invite you to refer our Services to family members, colleagues, or friends who may benefit from them. When doing so, we request that you only refer individuals in your personal network who are genuinely interested. If a referred individual declines further contact, we will honor their request promptly.

OUR BUSINESS TRANSFERS

We reserve the right to transfer or disclose all Personal Information in the event of a merger, acquisition, restructuring, or similar organizational change, provided the successor entity agrees to the terms of this Privacy Policy. Additionally, during due diligence processes related to such changes, your information may be shared securely with potential stakeholders.

PROTECTION OF GAPCARE AND OTHERS

We may disclose your Personal Information if required by law or to protect the rights, property, or safety of GapCare, its employees, its Care Teams, and others. This includes compliance with subpoenas, warrants, or legal orders. Furthermore, we may share information with other organizations for fraud prevention or credit risk reduction. If a security breach involving your Personal Information occurs, we will notify you promptly and take necessary actions to address the situation in accordance with legal requirements.

DE-IDENTIFIED DATA

In accordance with our Terms of Use, we may de-identify your Personal Information or otherwise process it to ensure it is no longer attributable to you without additional information (“De-identified Data”). This De-identified Data may be used without restriction for purposes such as improving our Services, conducting research, generating statistical reports, or collaborating with third parties. Where required by law, we will employ specific methods to ensure data is appropriately de-identified.

IS MY PERSONAL INFORMATION SECURE?

We prioritize the protection of your Personal Information by employing industry-standard administrative, physical, and technical measures to safeguard it against unauthorized access, use, or disclosure. Our processes and systems are designed to comply with the privacy and security requirements of applicable federal and state laws, including, for GapCare Members, adherence to HIPAA guidelines.

Your individual GapCare Member account is password-protected to ensure your privacy and security. To further enhance protection, we recommend safeguarding your password, restricting access to your devices and browsers, and logging out after completing any session involving your account.

If you are a GapCare Member, and your device supports push notifications from our Apps, we may send notifications that include Personal Information or, in limited cases, PHI that is not encrypted. Similarly, if you consent to receiving text messages, we may send such messages containing Personal Information or PHI. Depending on your device’s settings, these notifications and messages may be visible to others who access your device. You can adjust notification and visibility settings on your device to protect your information. By not modifying these settings, you accept responsibility for the security and confidentiality of information displayed on your device. We are not liable for breaches caused by unauthorized access to your passwords, devices, email accounts, browsers, or browser histories.

Our Services may include links to third-party offerings (as outlined in our Terms of Use). When accessing these offerings, you do so at your own risk. You are solely responsible for reviewing and understanding their terms of use and privacy policies. GapCare does not control or guarantee the privacy practices, availability, content, performance, or security of these third-party services.

While we exercise significant care in protecting your Personal Information, we cannot ensure the security or confidentiality of systems or connections you use to transmit information to us. For example, emails and text messages sent to us may not possess the same security features as our internal systems. Additionally, we cannot guarantee the security of your email, mobile devices, or any personal devices you use to access our Services. Please consult our Terms of Use for additional details on system and connection security.

Despite our commitment to safeguarding your information, no system is completely secure. Unauthorized actions, hardware or software failures, and other unforeseen circumstances could potentially compromise your data at any time.

If you believe your data or interactions with GapCare are no longer secure, or if you have concerns about privacy or data security, please contact us promptly using the methods detailed at the end of this Privacy Policy.

WHAT PERSONAL INFORMATION CAN I ACCESS AND CORRECT?

If you are a GapCare Member, you can access and, in certain cases, update specific information about yourself through the App or the GapCare Program. The details you may access and update include, but are not limited to, the following:

First and last name
Account and GapCare Member profile information (e.g., nickname and profile picture)
Email address
Mailing address
Phone number
Username and password
Communication preferences (e.g., email and push notifications)
Data related to your weight, activity, food tracking, blood glucose measurements, blood pressure measurements, or health goals (as applicable to the GapCare Programs you are enrolled in).

Please note, GapCare reserves the right to decline changes to certain clinical information if such changes would result in inaccurate or clinically inappropriate records. For further details about your right to correct or amend Protected Health Information (PHI), please refer to our Notice of HIPAA Privacy Practices.

Additionally, as a GapCare Member, you have the right to request and receive a copy of your PHI as outlined in our Notice of HIPAA Privacy Practices. If you are a Site Visitor who is not a GapCare Member, you can access certain information about yourself by contacting us through the methods provided at the end of this Privacy Policy or as required by applicable law, including those described in the Supplemental State Privacy Notice.

To help us maintain accurate and up-to-date records, we encourage you to promptly update your information whenever it changes or inform us through the contact methods outlined at the end of this Privacy Policy. Please note that when you update your information, we may retain a copy of the original information in our records as part of standard practice.

WHAT RIGHTS AND CHOICES DO I HAVE REGARDING MY PERSONAL INFORMATION?

Choosing Not to Disclose

You have the option to choose not to disclose certain information to us, even though some of this information may be necessary to access specific features of the Services. By withholding such information, you may limit your ability to fully utilize certain aspects of the Services.

Requesting Information

You have the right to request specific information regarding your Personal Information, including:

A copy of the Personal Information we have collected about you.
A description of the specific pieces of Personal Information we collect from you.
A breakdown of the categories of Personal Information we collect, as outlined in this Privacy Policy.
Details about the sources from which we collect your Personal Information (also described in this Privacy Policy).
An explanation of the purposes for which we collect and use your Personal Information, as outlined in this Privacy Policy and, for GapCare Members, in our Notice of HIPAA Privacy Practices.

GapCare Members also have additional rights regarding their Protected Health Information (PHI), which are fully detailed in our Notice of HIPAA Privacy Practices.

You may also request information about whether any of your Personal Information has been sold or shared with third parties for their purposes. For transparency and convenience, we clarify in this Privacy Policy that we do not rent or sell your Personal Information. Additionally, we do not share your Personal Information with third parties for their own purposes unless you provide explicit consent or unless such sharing is outlined in our Notice of HIPAA Privacy Practices (e.g., sharing Protected Health Information with other healthcare providers under HIPAA guidelines).

To make a request for this information or to learn more about exercising your rights, please contact us through any of the methods listed at the end of this Privacy Policy.

Unsubscribing from Communications

You can opt out of receiving communications from us. However, please note:

If you are a GapCare Member, opting out of communications may limit your ability to receive valuable program reminders and content essential to your experience with our Services.
Even if you choose not to receive communications, legal notices (such as updates to this Privacy Policy) will still govern your use of the Services, and it is your responsibility to review such notices for updates.

To unsubscribe, follow the instructions provided in the emails you receive from us. If you are a GapCare Member, you may also adjust your email preferences in the App. Additionally, if you prefer not to receive mail, phone calls, or text messages, you may indicate this by contacting us using the details provided at the end of this Privacy Policy. Requests will be processed within a reasonable time frame, but you may still receive emails while your request is being processed.

Deleting Your Account and/or Deleting Personal Information

As a healthcare provider, GapCare is required by law to maintain the Personal Information, including any PHI, we collect as part of our business records. As such, we cannot entirely delete User Submissions or other Personal Information from GapCare Members from our records. Certain requirements from app platforms like the Apple App Store or Google Play may necessitate a process for requesting account deletion.

While we can help you close your account and cease sharing your Personal Information, our regulatory obligations require us to retain your data for the legally required duration. Even if you are no longer using our Services, we will continue to protect any Personal Information or User Submissions in compliance with our Terms of Use, this Privacy Policy, and our Notice of HIPAA Privacy Practices.

If you are a Site Visitor, please refer to our Supplemental State Privacy Notice for further information on your rights regarding data deletion.

NOTICE TO RESIDENTS OF CALIFORNIA, COLORADO, CONNECTICUT, UTAH, AND VIRGINIA

If you reside in California, Colorado, Connecticut, Utah, or Virginia, the Personal Information we collect from you when you access or interact with our Sites may be subject to state-specific privacy laws. It is important to note that for the purposes of these laws, Personal Information does not include information classified as Protected Health Information (PHI) under HIPAA or similar state health privacy regulations. To learn more about your rights under these laws, please refer to our Supplemental State Privacy Notice.

HOW DO WE PROTECT CHILDREN’S PERSONAL INFORMATION?

If you are under the age of 18, you may not register or enroll in any GapCare programs. If you are under 13 years of age, you may not register or enroll in any GapCare programs at all. We do not knowingly permit or solicit individuals under these ages to independently participate in our Services. Additionally, our Services are not designed or intended for children under these age thresholds.

We do not knowingly collect Personal Information from children under the stated ages. If a parent or guardian becomes aware that a child under these ages has provided us with Personal Information, they are encouraged to contact us immediately. If we learn that a child under the applicable age limits has provided us with Personal Information without verified parental consent, we will take prompt action to delete that information from our records.

HOW CAN WE CHANGE THIS PRIVACY POLICY?

We reserve the right to change or replace any portion of this Privacy Policy at any time and for any reason, at our discretion. Any updates to this Privacy Policy will be posted on our Sites and in the Apps, and such updates will become effective as of the date of posting. The use of the information we collect is governed by the Privacy Policy in effect at the time the information is used or disclosed.

You are responsible for periodically reviewing this Privacy Policy to stay informed about any updates. If any changes or updates to this Privacy Policy significantly reduce your rights, we will provide notice and designate a reasonable time frame before the changes take effect. By continuing to access or use the Services after these changes become effective, you agree to be bound by the updated Privacy Policy. If you do not agree to the changes, you should discontinue your use of the Services.

HOW CAN YOU CONTACT US WITH QUESTIONS OR CONCERNS?

If you have any questions or concerns regarding this Privacy Policy or GapCare’s privacy practices, or if you wish to request access to or corrections of your Personal Information, you may contact us using the information below:

GapCare

Attn: Privacy Officer

P.O. Box 10981

Newport Beach, CA 92658

Phone: +1 (949) 620-3137

Email: hello@gapcare.com

We are committed to responding to your inquiries, concerns, and requests in a timely and comprehensive manner.

Effective Date: December 25, 2024