Last updated on December 1st, 2016
• We use Patient Data (including messages) only to provide our Service in compliance with law.
• Our Service helps Healthcare Providers manage communications with their own Patients through
text messages or the Wellpass Platform.
• We handle each Patient’s Data only as permitted by his or her Healthcare Provider.
communicates with its Patients through our Service. This could be an individual healthcare provider
(like a doctor), or a larger organization (such as a health center, or a health system). If a Patient is
part of a research study (for example, a test of an experimental medicine), the Healthcare Provider
may also be a clinical researcher.
The word Patient means the Healthcare Provider’s individual patient or that patient’s
While providing our Service, Sense Health collects Patient Data, which can include:
• A Patient’s name and telephone number;
• The communications the Patient and his or her Healthcare Provider send each other through our
Service (such as text messages); and
• Notes or other information regarding the Patient supplied by the Healthcare Provider.
If the Patient uses our app, then his or her Patient Data may also include:
• Information about the Patient’s mobile device, such as device ID and IP address; and
• Information about usage of the app, such as the way the Patient navigates through the app.
2. How We Use Patient Data
We use each Patient’s Data only to provide our Service in compliance with law, and then only as
permitted by our contract with that Patient’s Healthcare Provider. Depending on that contract and
applicable legal requirements, we may use Patient Data as follows:
• To allow Healthcare Providers to manage communications with their Patients;
• To create aggregated or de-identified information (for example, to help Healthcare
Providers understand which communication strategies have been most successful);
• For the proper management and administration of our business (for example, to troubleshoot our
• As required by law; and
• For other purposes authorized by the Healthcare Provider to whom the data pertains.
3. Disclosure of Patient Data
We may disclose a Patient’s Data only to provide our Service in compliance with law, and then only
as permitted by our contract with that Patient’s Healthcare Provider. Depending on that contract
and applicable legal requirements, we may disclose Patient Data as follows:
• To the Relevant Healthcare Provider. When a Healthcare Provider hires us to facilitate
communications with their Patient, our technology permits that communication. The Healthcare
Provider’s use and disclosure of any such Patient Data (such as sharing within its organization) is
subject to its own policies and procedures.
• To Agents & Subcontractors. In compliance with applicable law and our contractual obligations,
we may share Patient Data with third parties that help us operate our business and provide our
Service (or contract with them to collect the data directly), such as a data storage provider.
• If Required by Law. We may disclose Patient Data in response to a mandate that is enforceable in a
court of law (such as a search warrant, court order or subpoena).
• Changes in the Structure or Ownership of the Sense Health or its Assets. To help facilitate
continuity of communications and of healthcare, we may transfer Patient Data when we sell or
transfer all or a portion of our business or assets (such as in connection with a merger, acquisition,
reorganization, dissolution or liquidation), consistent with applicable law.
• Aggregated or De-identified Information. We may share appropriately aggregated or de-identified data with third parties who cannot identity the Patients or Healthcare Providers to which the original data pertained. For example, we may publish a statistic about which communications strategies are most
• At the Healthcare Provider’s request. At the request of a Healthcare Provider client, we may make
other disclosures of Patient Data we hold for that Healthcare Provider.
4. Data Security
We comply with the Security Rule issued by the U.S. Department of Health and Human Services
under the Health Insurance Portability and Accountability Act (HIPAA) and other applicable legal
and contractual data security requirements.
5. A Note about Data Submitted by Healthcare Providers About Themselves.
When a Healthcare Provider or its personnel use our system, they may provide us with their own
contact details. We protect this data, and all other data they submit, in compliance with our
agreement with the Healthcare Provider. To analyze current and potential Healthcare Providers’
use of our website, and to facilitate our efforts to market to the Healthcare Providers, we may
arrange for third-party analytics and advertising companies to use technologies such as cookies on
the Providers’ browsers. To learn more about interest-based advertising generally, including certain
opt-out options offered by some of our current ad service partners, click here. We do not provide
these analytics and advertising service partners with Patient Data or any other information about
Patients. We also don’t use their services or permit them to operate on the part of our website
directed to patients: app.wellpass.com.
on wellpass.com. Although this Policy may evolve, we will continue to protect Patient Data in
compliance with law and our agreements with the relevant Healthcare Providers
7. Contacting us
821 Broadway, Floor 5
New York, NY 10003