RPM Healthcare (“RPM”), the owners of My Westmed Connect would like you to be familiar with how we collect, use and disclose information and data. This Privacy Policy explains our practices in connection with information that we collect through My Westmed Connect (“App”) and any services we provide you either through the App or through our customer service practices (“Services”). By downloading, accessing or using the App, or providing information to us in connection with the App, you agree to the terms and conditions of this Privacy Policy.

Modification Of Privacy Policy
We reserve the right to update or modify this Privacy Policy at any time without prior notice. This Privacy Policy was last updated on 31 March 2021. Your continued use of the Services after any changes or revisions to this Privacy Policy shall denote your agreement with the terms of such a revised Privacy Policy.

How We Use Your Personal Information
We may collect Personal Information from you, such as:

  • Name
  • E-mail address
  • Phone Number
  • Gender
  • Date of Birth
  • Next Doctor’s Appointment


You may decline to provide us with some or all of your information that personally identifies you, however, restricting information will materially reduce and diminish the value of the App to you.

In addition, when you contact us with customer service queries or other queries relating to the App, Terms and Conditions or this Privacy Policy, we may collect personal information you provide for purposes of addressing your queries and retain this information in accordance with our retention policy.

We may use your Personal Information:

  • To respond to your inquiries, comments and posts on different platforms such as social media or to send newsletters/push notifications/texts to you in order to inform you of our present and upcoming services.
  • To send to you marketing communications that we believe may be of interest to you.
  • To allow you to post or comment on the post of a friend through the App
  • To personalize your experience on the App


As we deem appropriate:

  • under applicable law, including laws outside your country of residence;
  • to comply with legal process;
  • to respond to requests from public or government authorities, including public or government authorities outside your country of residence.


Information We Collect From Other Sources
RPM, either directly or through its authorized third-party service providers, also collects aggregate information about the use of the App, including information about your access and visits to the App, such as internet protocol addresses, browser type, browser language, referring/exit pages and URLs, other browser history, platform type, number of clicks, domain names, landing pages, pages viewed and the order of those pages, the amount of time spent on particular pages, geolocation, and the date and time, some of which may uniquely identify your browser or your account. We collect this information in a variety of ways, including from web forms, technologies like Google Analytics, cookies or other anonymous identifiers, web logging and software on your computer or other devices. When you visit the App, we store information based on your usage history. We also use cookies and anonymous identifiers when you interact with the services we may offer to our partners, such as advertising services or certain RPM features that may appear on other sites and in any other manner that we deem necessary for our business purposes.

Either directly or through our authorized third-party service providers, we may also collect non-personal information about your use of the App and produce and use aggregated and anonymized information derived from your personal information. This may include de-identified search results and information collected by cookies and similar technologies as described below.

While, as noted above, we collect personal information in connection with our App and for purposes of performing our services, we do not collect any more information than reasonably needed to offer our services as described on the App.

How We Use Your Data
By using, accessing and inputting information in the App you agree that any and all data that you have entered or may enter at a future time, into the App as well as any data you may enter into related features or Services of the App which are not present at the moment within the App but which may be introduced at any time in the future, you consent to the compilation, processing, analyzing as well as anonymous disclosure and sale of the aforementioned data to a third party.

The main objective of data collection is to improve and quantify our Services. In addition to these objectives, the above mentioned compilation, processing, analysis, and anonymous disclosure of data may be conducted with the purpose of:

  1. Developing anonymous aggregated reports
  2. improving RPM Healthcare’s algorithms
  3. quantifying how RPM Healthcare’s services are utilized and
  4. to consequently develop related new products, services and features which may be used to improve the App or may be sold to you or a third party.


All and any health related data you enter into the App shall be treated with absolute anonymity and any information that is sold to a third party in that form, including but not limited to aggregated statistical reports shall not include any personal information, including first name, last name, email, phone number, date of birth of a person who has downloaded, accessed and used the Services in connection to the App (“User”).

RPM reserves the right to use such aggregated and de-identified non-personal information collected from its users for any reason in our sole discretion, including but not limited to performing statistical analysis of the aggregated information, including analysis about the behavior of visitors to our App on an aggregated, anonymous basis, or to share such information with third parties.

Disclosing Data To A Third Party
Your data may be disclosed to a third party in the following instances:

  1. As we develop our business, we might sell or buy businesses or assets. In the event of a sale, merger, reorganization, dissolution or similar event relating to all or a portion of our business or assets,your personal information and data may be part of the transferred assets.
  2. We may also disclose your data if required to do so by law or in the good faith belief that such action is necessary to:
    • comply with a legal obligation,
    • protect and defend our rights or property,
    • act in urgent circumstances to protect the personal safety of users of the Services or the public.


California Online Privacy Protection Act (“CalOPPA”)

CalOPPA requires a person or company in the United States that operates websites collecting personally identifiable information from individual consumers residing in California to post a conspicuous privacy policy stating exactly the information being collected and those individuals with whom it is being shared, and to comply with this policy. See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf

California Customers may request further information about our compliance with California’s privacy law, and may request to review and request changes to their personal information collected and stored by RPM by e-mailing CustomerCare@RPMHealthcare.com or contacting us as stated below.

Special Note For EU Individuals
The information we collect through the App is controlled by RPM Healthcare, which is headquartered in the United States at 360 Central Avenue, Suite 800, St. Petersburg, FL 33701. We also act as a service provider (or data processor) on behalf of and in accordance with our customer’s instructions. When we act as a service provider, if you have questions about the processing of your information or to exercise any applicable legal rights, please contact us via the means to do so provided below.

The legal bases for using your personal information

We collect, use, and share your personal information where we are satisfied that we have an appropriate legal basis to do this. This may be because:

  • You have affirmatively given us consent;
  • Our use of your personal information is in our legitimate interest as a commercial organization (for example in order to make improvements to our products and services and to provide you with information you request); you have a right to object to processing as explained in the section below titled Your legal rights;
  • Our use of your personal information is necessary to perform a contract or take steps to enter into a contract with you; and/or
  • Our use of your personal information is necessary to comply with a relevant legal or regulatory obligation that we have (for example, where we are required to disclose personal information to a court or tax authority).


If you would like to find out more about the legal bases on which we process personal information, please contact us using the details below.

Your legal rights

Subject to certain exemptions, and in some cases dependent upon the processing activity we are undertaking, you have certain rights in relation to your personal information:

Right to access, correct, and delete your personal information: You have the right to request access to the personal information that we hold about you and:(i) the source of your personal information; (ii) the purposes, legal basis and methods of processing; (iii) the data controller’s identity; and (iv) the entities or categories of entities to whom your personal information may be transferred.

You also have the right to request that we delete your information.

We are not required to comply with your request to erase personal information if the processing of your personal information is necessary for compliance with a legal obligation or for the establishment, exercise, or defense of legal claims.

Right to restrict the processing of your personal information: You have the right to restrict the use of your personal information when (i) you contest the accuracy of the data; (ii) the use is unlawful but you do not want us to erase the data; (iii) we no longer need the personal information for the relevant purposes, but we require it for the establishment, exercise, or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests verification as to whether we have a compelling interest to continue to use your data.

We can continue to use your personal information following a request for restriction, where:

  • we have your consent; or
  • to establish, exercise or defend legal claims; or
  • to protect the rights of another natural or legal person.


Right to data portability:
 To the extent that we process your information (i) based on your consent or under a contract; and (ii) through automated means, you have the right to receive such personal information in a structured, commonly used, machine-readable format, or you can ask to have it transferred directly to another data controller.

Right to object to the processing of your personal information: You can object to any processing of your personal information which has our legitimate interests as its legal basis, if you believe your fundamental rights and freedoms outweigh our legitimate interests. If you raise an objection, we have an opportunity to demonstrate that we have compelling legitimate interests which override your rights and freedoms.

Right to obtain a copy of personal information safeguards used for transfers outside your jurisdiction: You can ask to obtain a copy of, or reference to, the safeguards under which your personal information is transferred outside of the United States.

File a complaint if you feel your rights are violated: We ask that you please attempt to resolve any issues with us first, although you have a right to contact supervisory authority at any time.

  • You can complain if you feel we have violated your rights by contacting us at CustomerCare@RPMHealthcare.com.
  • You can file a complaint with the U.S. Department of Health and Human Services Office for Civil Rights by sending a letter to 200 Independence Avenue, S.W., Washington, D.C. 20201, calling 1-877-696-6775, or visiting https://www.hhs.gov/ocr/privacy/hipaa/complaints/.
  • We will not retaliate against you for filing a complaint.


How to Exercise Your Rights:
 If you would like to exercise any of the rights described above, please send us a request at CustomerCare@RPMHealthcare.com. In your message, please indicate the right you would like to exercise and the information that you would like to access, review, correct, or delete.

We may ask you for additional information to confirm your identity and for security purposes, before disclosing the personal information requested to you. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive.

We may not always be able to fully address your request, for example if it would impact the duty of confidentiality we owe to others, or if we are legally entitled to deal with the request in a different way.

Cross-border Transfer of Information
RPM Healthcare generally maintains servers and systems in the United States hosted by third party service providers. We also may subcontract the processing of your data to, or otherwise share your data with, other third parties in the United States or countries other than your country of residence. As a result, where the personal information that we collect through or in connection with our Website is transferred to and processed in the United States for the purposes described above, we will take steps to ensure that the information receives the same level of protection as if it remained within the United States, including entering into data transfer agreements, using the EU Commission approved Standard Contractual Clauses, or by relying on certification mechanisms such as the EU - US Privacy Shield. You may have a right to details of the mechanisms under which your data is transferred outside the United States.

Contact Us
If you have any questions or concerns regarding this Privacy Policy, you should contact us at CustomerCare@RPMHealthcare.com.

RPM Healthcare
360 Central Avenue, Suite 800
St. Petersburg, FL 33701
888-672-8436

We offer you choices about how to manage how we communicate with you.

  • Email/Direct Mail. You may opt out of receiving marketing emails from us at any time by sending an email to CustomerCare@RPMHealthcare.com or by clicking on the unsubscribe link in our emails. You will continue to receive service-related emails (e.g. order status). To opt out of direct mail, please send your request to CustomerCare@RPMHealthcare.com and include your postal address in the body of the email.
  • Targeted Advertising. If you do not want information about your activity on our App to be used for tailored advertising, please visit the page hosted by the Network Advertising Initiative and follow the instructions there.
  • Updating Your Profile. You may update or correct your personal information related to your account through your dashboard of your account or by contacting Customer Support at CustomerCare@RPMHealthcare.com. If you wish to request deletion of your personal information, then please contact us at CustomerCare@RPMHealthcare.com . We will respond to requests within a reasonable timeframe.
  • Request Confidential Communications. You can ask us to contact you in a specific way (for example, home or office phone) or to send mail to a different address.

We retain and use your information as necessary to comply with our legal obligations, contractual statute of limitations, resolution of disputes, and enforcement of our agreements. Please note that we may not be able to delete all of your data upon request depending on the reasons above and the nature of your interactions with the App.

Exclusions To Privacy Policy
This Privacy Policy does not and shall not apply to any unsolicited information you provide to us. This includes, but is not limited to, information posted to any public and social media forums, such as the My Westmed Connect’s social media pages and websites (collectively, “Public Platforms”), including any ideas for new products or modifications to existing services, and other unsolicited submissions (collectively, “Unsolicited Information”). All such Unsolicited Information shall be deemed to be non-confidential and we shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.

Please also note that any personal information you provide to be displayed in publicly available parts of My Westmed Connect, including your anonymous Profile, will be displayed for those who you have added or will add as Friends to see and thus will not be subject to the terms of this Privacy Policy. We cannot and will not be responsible for i) who you add as a Friend within the App and ii) what those Friends do with any personal information or other forms of information, such as but not limited to personal data, that you choose to make publicly available.

This Privacy Policy will also not be applicable to any information you share on Community Tab in the App, though your identity within that function of the platform is anonymous. Therefore, we advise that you exercise great caution when adding a Friend within the app and what information you choose to make publicly available through our Services.

Children
If you are under thirteen, please do not submit any Personal Data and Information through the App or our website without consent from a parent or guardian. Parents who are using the App and our website for their children who are under 13 will be responsible for any data and Personal Information they enter into the App.

PLEASE NOTE:
My Westmed Connect is, under no circumstances, meant to make a diagnosis or provide treatment for any health condition. For a proper diagnosis of your medical condition and the treatment that may stem from such a diagnosis, consult a doctor or related health care professional.

RPM Healthcare
Contact us at:
CustomerCare@RPMHealthcare.com