Leap Health Privacy Notice

Introduction

Leap Health ("Leap", "our", "we" or "us") respects your privacy, and we want you to be familiar with how we collect, use, share, or otherwise process your Personal Information. This Privacy Notice is intended to help you understand our privacy practices when you visit and interact with us online (for example, through our websites, emails and mobile applications), and when you participate in our programs, services, apply for employment or engage in other business interactions with us that reference this Privacy Notice, collectively referred to as our "Websites and Services."

Protected Health Information

In some cases, such as when providing services to healthcare providers, health plans, or other Covered Entities, Leap acts as a Business Associate, as defined by the Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). In those situations where Leap is processing your information protected under HIPAA, or Protected Health Information ("PHI"), as a Business Associate, our HIPAA obligations and applicable Business Associate Agreements govern those activities.

Collecting and Using Your Personal Information

When you interact with our Websites and Services, we collect information that alone or in combination with other data in our possession could be used to identify you ("Personal Information"). Information we may collect includes:

Information you provide to us directly
Information related to our Websites and Services
Information collected through tracking technology on our Websites
Sensitive information
Other types of information

The type of Personal Information we collect depends on the nature of your interactions with us and our Services. For example, we may collect:

Contact Information: First and last name, address, telephone number, email address, and other contact information you choose to provide to us
Demographic Information: Age, date of birth, location
Professional Information: Professional affiliations, specialty, resume, education details
Information collected through tracking technologies: IP address or other online identifiers
Inferences drawn from other Personal Information: social media profiles or other public records or websites
Other types of information as necessary to use our Services or to fulfill your requests

We may use this Personal Information to:

Recruit for employment purposes, new-hire onboarding, and other activities in the course of employment with Leap, which may include pre-employment screening, scheduling interviews, or communications regarding the application process, benefits administration, payroll, etc.
Respond to questions on recruitment or our patient care programs
Provide marketing information relating to our services
Operate, evaluate, secure, and improve our Websites and Services; analyze its use; and enhance or develop new features for our Services
Create aggregated analytics for research and reporting purposes
Fulfill our obligations to you under an applicable contract or to conduct business with you
Comply with applicable legal, regulatory, or auditing obligations related to our operations and Services
Conduct surveys, or polls and obtain testimonials
Tailor marketing programs, administer retargeting messaging and profiling activities, and send you promotional materials, (e.g., newsletters)
Protect against, identify, investigate, and respond to fraudulent, harmful, unauthorized, unethical or illegal activity
Conduct other legitimate business activities, as allowed by applicable law

Some of these activities may also involve the processing of Sensitive Personal Information, as described below.

Where permitted by law, we may also combine Personal Information collected through our Websites and Services with our offline records and information obtained from public or third-party sources. We use this consolidated information to improve our sites, enhance our marketing activities, and to facilitate other business functions. If necessary, or as required by applicable law, we will collect your consent or provide an opportunity for you to opt out of this type of processing.

Sensitive Personal Information

While offering our Websites and Services, and with your consent, where required by applicable law, we may also collect and process Personal Information that is of a sensitive nature, including, for example, the following categories of Sensitive Personal Information:

Precise geolocation
Disciplinary actions and/or criminal proceedings and/or sanctions
Identification information (identity card/passport number, Social Security or other taxpayer/government identification number like driving license details)
Financial information, such as your bank account number for employment credit checks
Information related to your health and medical condition(s), or Consumer Health Data which may include genetic data or biometric information; medical treatments, medications, and test results; and information about your insurance
Other protected characteristics, such as your race or ethnicity, should you choose to share this information with us

We may use this Sensitive Personal Information, as necessary, to:

Facilitate recruitment, evaluate candidates for employment purposes and conduct employee-related activities, such as payroll and benefits
Provide and manage patient care and other Services we offer
Conduct other legitimate business activities, as allowed by applicable law.

We will only process Sensitive Personal Information and Consumer Health Data when we have your express consent, or as required or permitted under applicable law, for example, when necessary to comply with applicable law, respond to legitimate requests from government authorities, including authorities that may be outside of your country of residence, to protect or defend our legal interests, and if necessary, to protect the safety of our employees and other stakeholders.

Read our Consumer Health Data Privacy Notice Supplement for additional information on the processing of Consumer Health Data as defined under US state laws.

You may request to opt out or limit the processing of your Sensitive Information or Consumer Health Data by clicking the link "Limit The Use Of My Sensitive Personal Information" on our Website(s) or contacting us using the details found in the "Contact Us" section of this Notice.

Please contact us at privacy@leaphealth.com to withdraw your consent or opt out of the processing of your Sensitive Personal Information, where applicable under law.

Use of Cookies and Other Similar Technologies

We use cookies and similar technologies (such as web beacons, tags, scripts and device identifiers) to collect and store analytics and other information when you use our Websites and Services. The cookies we use include both first-party (set directly by our website) and third-party cookies (set by other organizations, such as analytics or advertising providers) to help us understand site usage, improve our Services, and enhance your experience.

Cookies, or similar technologies, may provide us with the following information:

The type of web browser software you use
The name of the domain which you access the Internet (including client and server IP addresses, usernames, ports, queries, or other status-related information)
The Internet address of the website from which you linked directly to our Websites
The date and time you access our Websites
Which pages you have visited on our Websites

Please refer to our "Cookie Settings" link found at the bottom of our Website for a list of the cookies we use and for what purposes or to manage your cookie preferences for non-essential cookies. Non-essential cookies include:

Functional – for usability and social media features
Analytics – for usage metrics
Performance – for site optimization
Advertisement – for marketing and targeting

Information we share with third parties

We may disclose your Personal Information to third parties for business purposes as described in this Privacy Notice, including:

To service providers working on our behalf, or providing services such as information technology, website hosting, background screenings, and similar services in support of recruitment and employment activities.
Third parties to whom you authorize us to disclose your Personal Information in connection with our Services.
To authorized law enforcement, regulatory or other government authorities, where required by applicable law, or pursuant to a valid subpoena.
Third parties in connection with a business deal (or potential business deal) such as a merger, consolidation, acquisition, reorganization, or sale of asset(s), or in the event of bankruptcy, in which case we will make reasonable efforts to require the recipient to honor this Privacy Notice, but the information may be subject to the policies of the receiving organization

When we share data with third parties, we require that they use your Personal Information only for the purposes we've authorized, and for the limited reasons explained in this Privacy Notice. We also enter into agreements with these third parties to require them to protect your Personal Information appropriately.

Retaining Your Personal Information

We will retain your Personal Information for the time-period required or allowed by applicable law. Otherwise, we keep your Personal Information for as long as reasonably necessary to serve the purpose(s) for which it was collected.

Exercising Your Rights

Depending on your state of residence, you may have additional rights under applicable U.S. privacy laws in relation to the Personal Information we hold about you, such as rights to:

Request access to your Personal Information
Request corrections or updates to your Personal Information
Request deletion of your Personal Information
Request a copy (portability) of your Personal Information
Opt out of the sale or sharing of your Personal Information
Opt out of the use of your Personal Information for targeted advertising
Limit the use or disclosure of your Sensitive Personal Information

These rights are not absolute and may only apply in certain circumstances. To exercise your rights, contact us at privacy@leaphealth.com.

If you have provided consent for us to process your Personal Information, you may withdraw that consent at any time by contacting us at privacy@leaphealth.com. You may also unsubscribe from marketing emails using the "Unsubscribe" link in our communications.

Security

Leap implements reasonable technical, physical, and administrative security measures to protect Personal Information from loss, misuse, unauthorized access, disclosure, alteration, or destruction. Please note that while we take steps to secure Personal Information you share with us, the security of your Personal Information cannot be guaranteed. We encourage you to take special care in deciding what information you share with us via email or other Internet transmission.

Children

We are committed to protecting the privacy of children. Our Websites and Services are not directed to children who are under the age of 18 and we do not knowingly collect Personal Information from children under the age of 18. If we learn that we have collected Personal Information directly from a child under the age of 18 through our Websites and Services, we will delete that information.

Links to Other Websites

This Privacy Notice applies only to Leap Websites and Services. Our Websites may contain links to other websites that are not owned or controlled by Leap. Any materials and websites referenced and/or linked to from our Websites are provided for information purposes only. Please be aware that we are not responsible for the privacy policies of such other websites or how these websites operate or treat Personal Information. We encourage you to review their applicable privacy notices to understand how they collect, use and protect Personal Information.

Changes to this Privacy Notice

Our business, Website(s) and Services may change from time to time. As a result, we may change this Privacy Notice at any time. If we do make such changes, we will post an updated version on this page, unless another type of notice is required by the applicable law. Additionally, when required under applicable law, we will request additional consent to collect and process your Personal Information. We encourage you to visit this page periodically and to review our most current Privacy Notice and applicable effective date.

Contact Us

If you have any questions about our Privacy Notice or data practices, or if you wish to submit requests or exercise your rights regarding your Personal Information as provided for by applicable law, please contact us at:

Email: privacy@leaphealth.com