Mobile App Privacy Policy

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Revised and Effective August 2023

        PLEASE REVIEW IT CAREFULLY.

This Mobile App Privacy Policy applies to information about you obtained through the El Camino Health mobile application (the "App"), provided by El Camino Hospital (dba as El Camino Health) and its affiliated entities, including Silicon Valley Medical Development, LLC (collectively, "ECH", "we", "us", "our"). This Mobile App Privacy Policy describes how we may collect, use, disclose, or otherwise process personal information obtained through the App; your choices regarding our use of your information; and how we safeguard such information.

IMPORTANT! Note that the El Camino Health Notice of Privacy Practices is a separate document that governs how certain protected health information about you may be used and disclosed by ECH pursuant to the Health Insurance Portability and Accountability Act (HIPAA). Please take a moment to review this Policy, located in our Patient Services section.

By further downloading, using, or creating an account on the App, you agree to this Mobile App Privacy Policy and consent to the collection and use of your personal information as described in this Mobile App Privacy Policy.

Collection of Personal Information in Connection with the App

Personal Information You Provide

We, and our vendors, may obtain information that you voluntarily provide through the App. For example, when you use the myCare functionality within the App, we may collect certain personal information from you when you register an account. This information may include your name, address, email address or other information.

Information Collected Automatically

ECH and our vendors may use tracking technologies that automatically or passively collect information such as App usage, traffic patterns, App performance and related statistics based on our tracking of your interactions with the App. For example, we may use GPS (global position systems) software, geo-filtering, and other location-aware technologies to locate you, sometimes precisely, for purposes such as verifying your location and delivering or restricting content based on your location. The information we automatically collect may include the type of device you are using, your IP address, device ID or other unique identifier, and geolocation data.

We may combine certain automatically collected information with other information we obtain about you, which may include data we obtain from third parties.

We or third parties, including our vendors, may collect personal information about your online activities over time and across different online services when you use the App.

Information Collected through Your Device

When you download, access, or use the App, the App may (depending on your device or App permission settings) have access to certain information from your device, such as:

1. Location. The App may collect precise or approximate location of your device which can be determined by your Bluetooth connection or cell towers. We may use location data in order to locate the nearest facility to you.
2. Device Information. The App may collect information about your mobile device and Internet connection, including the model of device used and its operating system, and the version of our mobile app used. We may use this information to understand how our App performs when you use it.
3. Device ID. The App may use your device identifier (including your device's advertising identifier) to provide you a better experience. We use your device ID to recognize your mobile device.

These App permissions enable you to use certain features within the App. For example, in order to locate the nearest care facility to you, the App may need to access the location of your device.

Additionally, you may be able to log into the App using your device's login features such as using a passcode. These device login features are facilitated through your device, not ECH; we do not control these features, which you can change by accessing your device settings and preferences.

Information Collected by Third Parties

Our service providers or partners may disclose with us your personal information that you submit to them. When submitting information to a third party, you are subject to that third party's terms of use and privacy policies. ECH may combine information about you that we have with information we obtain from third parties.

How We Use Personal Information

ECH may use personal information that we or our vendors obtain through the App for various purposes including, but not limited to:

• administering the App;
• providing and improving our products and services,
• sending announcements and messages,
• processing your requests;
• improving the App; or
• for any other purpose, with your consent.

We will store your personal information for no longer than is necessary for the performance of our obligations or to achieve the purposes for which the information was collected, or as may be permitted under applicable law.

Disclosure of Personal Information

ECH may disclose your information, including your personal information, with our affiliates, business partners, and vendors. For example, ECH may use vendors to facilitate our services and provide operations for one or more aspects available through the App. To the extent we grant third parties access to information collected via your mobile device, they are expected to follow privacy practices no less protective than our practices to the extent allowed by applicable law. In addition, we may disclose personal information:

• to comply with legal requirements (for example, to respond to court orders, subpoenas, government or law enforcement agency requests, or other legal processes);
• in the event we sell or transfer all or a portion of our business assets (e.g., further to a merger, reorganization, liquidation, or any other business transaction, including negotiations of such transactions);
• to enforce our policies or protect legal rights, property, or safety; or
• with your consent or at your direction.

For details regarding disclosures of protected health information, please view our El Camino Health Notice of Privacy Practices.

Access to myCare

The App may include links or access to myCare, our online health management tool. For more information about our practices under HIPAA, please see our El Camino Health Notice of Privacy Practices.

myCare is powered by Epic. Learn more about Epic's privacy practices.

If you access myCare, we may request additional permissions from your device, including:

Microphone

The App may use your microphone to capture audio (sound) if you engage in video visits through the App. This information is not used in connection with the collection of COVID-19 related data.

Camera

You may choose to share a photo or video in a communication to a provide while you are using the App. You may select an existing photo or video from your device or take a new photo or video using the camera app on your device. This information is not used in connection with the collection of COVID-19 related data.

Phone

You may use your phone to call the numbers that are displayed in the App. The App will not store your call history or other call data. This information is not used in connection with the collection of COVID-19 related data.

Location Data & Background Location Access

With your permission, the App may provide you with turn-by-turn directions to help you get around the El Camino Hospital. The App will guide you to points of interest such as medical offices and centers. Without using the location data, the directions feature cannot properly locate you in a timely manner. These location-based features require access to your location even when the App is closed or in the background.

We do not use location data & background location access in connection with the collection of COVID-19 related data.

Wi-Fi Permission

The App may use your Wi-Fi permissions for more accurate location tracking while you are using the directions feature. This information is not used in connection with the collection off COVID-19 related data.

Bluetooth/BLE/BLE Admin

With your permission, the App may access your device's Bluetooth while you are using the directions. The App will not store your Bluetooth data. This information is not used in connection with the collection of COVID-19 related data.

COVID-19 Test Results and Your Privacy

You may have access to your electronic health record, managed by Epic's software, including medications, test results, and visit summaries. This App was not created specifically for the COVID-19 pandemic. It existed before the COVID-19 pandemic to allow you to access certain health information. You can use this App to access COVID-19-related vaccination information, laboratory test results, and documents with illness-related information using our App. The App does not perform any COVID-19 contact tracing or tracking.

Links to Other Websites

The App may contain links to other websites, mobile apps, or other online platforms. ECH is not responsible for these other websites, mobile apps, and online platforms and this Privacy Policy applies only to the App. We recommend that you review the privacy practices of these websites, mobile apps, and online platforms.

Your Choices

ECH strives to keep your information accurate, complete, and current. If you would like to update, correct, or delete certain personal information that you provide or convey through your use of the App, please click here.

With respect to App, you can stop all collection of data generated by use of the App by uninstalling the App. You may also be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g. location-based services, push notifications, accessing calendar/contacts/photos), by adjusting the permissions in your mobile device and/or the App's settings.

You may be able to enable or disable location tracking on the App by adjusting the permissions in your App account settings or through your mobile device settings. Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g. connecting to or proximity to Wi-Fi) may persist.

Note that uninstalling the App or changing the App permissions will not delete your user account or any information we previously collected via the App.

For more information on additional rights related to protected health information, please view our El Camino Health Notice of Privacy Practices.

Protecting Personal Information

We maintain appropriate security safeguards designed to help protect personal information collected or received through the App. Although we use reasonable efforts to safeguard information, transmission via the Internet is not completely secure and we cannot guarantee the security of your information collected through the App.

Children's Privacy

Our App is not intended for, nor targeted to, children under 13, and we do not knowingly collect personal information from children younger than thirteen years of age. If we learn that we have received information directly from a child who is under the age of 13, we will delete the information in accordance with applicable law.

Changes to this Privacy Policy

Please be aware that ECH reviews its privacy practices from time to time and this Privacy Policy is subject to change. We may provide notice of any such changes by updating the "Policy last updated" date.

Contact Us

You may contact us regarding this Mobile Privacy Policy through our Compliance Contact Form, or by postal mail to:

El Camino Hospital
Attn: El Camino Hospital Privacy Officer
2500 Grant Road
Mountain View, CA 94040