Privacy Policy

If you use the Navigate Maternity monitoring system (including related mobile applications) as a patient, we may collect protected health information (“PHI”) about you on behalf of your independent third-party health care provider (“Provider”) that is regulated by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (collectively, “HIPAA”). In this context, we act as a “business associate” of your Provider, and accordingly, your Provider’s HIPAA Notice of Privacy Practices and Navigate Maternity’s agreements with your Provider, and not this Policy, will govern the use and disclosure of your PHI. This Policy does not apply to and does not explain our collection and use of your information in connection with your use of the Navigate Maternity monitoring system (including related mobile applications) as a patient receiving medical care from a Provider. If you have any questions about your rights with respect to the access, use, and disclosure of your PHI, then please refer to your Provider’s Notice of Privacy Practices.

Additionally, if you have entered into a separate agreement with us that governs our collection and use of your personal information, that separate agreement shall control, and only those terms within this Privacy Policy that do not conflict with such separate agreement shall apply.

By accessing the Services, you agree to be bound by this Policy. If you do not agree to the terms of this Policy, please do not use the Services. Each time you use the Services, the current version of this Policy will apply. Accordingly, when you use the Services, you should check the date of this Policy (which appears at the top) and review any changes since you last reviewed it.

If you have any questions regarding this Privacy Policy, please contact us contact us at info@navigatematernity.com.

INFORMATION WE COLLECT

We collect two types of information from users of our Services: “personal information,” which is information that that can be used to identify you (such as your name or email address), and “aggregate information,” which is information that cannot be used to identify you (such as frequency of visits to our website and your browser type). We collect personal information and aggregate information in the contexts described below.

Information You Provide to Us — Your Account Information: When you use our Services, you may provide certain information directly to us for purposes of creating an account. For example, you may provide us with your contact information such as your email address, and your first and last name.

If you sign up for our newsletter or mailing list, we collect the information you submit and you are signing up to receive marketing and other communications from us.

Your Communication with Us: We collect information when you communicate with us. The specific types of information we collect will depend on the forum in which you communicate with us. For example, if you send us an email, we will collect your email address and the content of your email.

Location Information: With your permission, or if your device’s location settings are enabled to allow our app to collection this data, the Services may collect your precise geolocation data.

Information We Automatically Collect: As with most apps and websites, when you use our Services we automatically receive and collect information from your device. This information includes the following:

• Information about your device, such as the operating system, hardware, system version, the Internet Protocol (IP) address, device ID, and device language.
• The specific actions that you take when you use our Services, including but not limited to the pages and screens that you view or visit, search terms that you enter, how you interact with our Services.
• The time, frequency, connection type, and duration of your use of our Services.
• Information about your wireless and mobile network connections, such as mobile phone number, service provider, and signal strength.
• Information regarding your interaction with email messages, for example, whether you opened, clicked on, or forwarded the email message.
• Identifiers associated with cookies or other technologies that may uniquely identify your device or browser (as further described below).
• Pages you visited before or after navigating to our website.
• Device and telephone connectivity information such as your carrier, network type, network operator, subscriber identity module (“SIM”) operator, and SIM country.

Cookies and Analytics

Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser to help us identify you when you come to our website. You have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you may be unable to use those aspects of our website that requires registration in order to participate. You can learn more about cookies and how they work at www.allaboutcookies.org. You can always disable cookies through your browser settings. Doing so, however, may disable certain features on our website. You can opt-out from third party cookies that are used for advertising purposes on the NAI website at https://thenai.org/how-to-opt-out/.

We may use third parties, such as Google Analytics or other analytics providers, to analyze traffic to our website. Google Analytics does not create individual profiles for visitors and only collects aggregate data. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google at http://www.google.com/intl/en/analytics/privacyoverview.html.

We may also use cookies, pixels, beacons, or other web tracking technologies to track the amount of time spent on our Services and whether or not certain content, such as a video was viewed. We may work with a third party to collect and process this information for us, based on our instructions and in compliance with this Policy.

At the present time our Services do not respond to “Do Not Track” signals or similar mechanisms.

HOW WE USE YOUR INFORMATION

In general, we collect information from you so that we can provide our Services, operate our business, and provide information that you request from us. This includes the following uses and purposes:

• Create and administer your account.
• Provide, operate, improve, maintain, and protect our Services.
• Provide you with technical and other support.
• Communicate with you.
• Enable and facilitate acceptance and processing of payments.
• Send you Services and company updates, marketing communication, service information, and other information about Navigate Maternity and our Services, and products and services of third parties that we think you may be interested in.
• Conduct research and analysis, and monitor and analyze trends and usage.
• Enhance or improve user experience, our business, and our Services, including the safety and security thereof.
• Send you push notifications through our app.
• Personalize our Services to you by, for example, customizing content that you see.
• Communicate with you and respond to inquiries.
• Operate our business and perform any other function that we believe in good faith is necessary to protect the security or proper functioning of our Services.
• As necessary to comply with any applicable law, regulation, subpoena, legal process, or governmental request.
• Enforce contracts, including investigation of potential violations thereof.
• Detect, prevent, or otherwise address fraud, security or technical issues.
• Protect against harm to the rights, property or safety of Navigate Maternity, our users, customers, or the public as required or permitted by law.

HOW WE SHARE YOUR INFORMATION

Like most companies, we share information in certain circumstances with third parties through operation of our Services and our business. Below we explain when that happens.

Service Providers: We use third parties to assist us with operating our business and providing our Services, such as our technology vendors that help us maintain our Services and partners that assist us with our marketing and communication. These service providers will have access to your information in order to provide Services to us.

As Directed By You and With Your Consent: Except as otherwise provided in this Policy, we share information with companies, organizations or individuals outside of Navigate Maternity only at your direction or when we have your consent to do so.

Legal Proceedings: We may share information with third party companies, organizations, governmental authorities, or individuals outside of Navigate Maternity if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

• Meet any applicable law, regulation, subpoena, legal process or governmental request;
• Enforce a contract, including but not limited to any applicable Terms of Service, including investigation of potential violations thereof;
• Detect, prevent, or otherwise address fraud, security or technical issues; or
• Protect against harm to the rights, property or safety of Navigate Maternity, our users, customers or the public as required or permitted by law.

Sale or Merger: We may share information about you as part of a merger or acquisition. If Navigate Maternity or any of its affiliates is involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes. In such a case, unless permitted or otherwise directed by applicable law, your information would remain subject to the terms of the applicable privacy policy in effect at the time of such transfer.

Aggregate Information: We may de-identify or aggregate information so that you are not identified as an individual, and use and provide that information to third parties without restriction. We may also provide aggregate usage information to third parties (or allow third parties to collect that information from you), who may use such information to understand how often and in what ways people use our Services.

CHOICES ABOUT YOUR INFORMATION

Marketing: You may unsubscribe from Navigate Maternity marketing communications at any time by following the “unsubscribe” link at the bottom of any such communication.

If you do not wish to continue receives SMS/MMS mobile messages from us, reply STOP, END, CANCEL, UNSUBSCRIBE, or QUIT to any mobile message from us in order to opt-out. You may receive an additional mobile message confirming your decision to opt-out.

Deleting your account: you can delete your account, and the information we hold about you, at any time and without giving a reason. How to do it, and what happens to each kind of information, is set out under “HOW TO DELETE YOUR ACCOUNT AND YOUR INFORMATION” below.

HOW LONG WE KEEP YOUR INFORMATION

We keep information for as long as we need it for the purpose it was collected for, or for as long as the law or a contract requires us to keep it — whichever is longest. Because Navigate Maternity is a healthcare organization, some records cannot be deleted on request: federal and state law set a minimum period for which we must hold them, and our agreements with health plans and other payers require us to keep records of the care delivered under them. We also keep de-identified information, from which you cannot be identified, for research into maternal health outcomes. The periods below are the ones we apply.

• Account and profile information — your name, contact details, address, date of birth, pregnancy and due dates: kept for as long as your account is open, and erased when you delete your account.
• Health information you record in the app — blood-pressure and glucose readings, connected-device data, screening answers and scores, answers about food, housing, transport and other needs, baby tracker entries, photos you upload, and messages you send to your care team: kept for as long as your account is open, and erased when you delete your account, except where that information is also part of a medical or equipment record we must retain, part of a record we must keep under an agreement with your health plan or other payer, or has already been de-identified for research (each described below).
• Medical and equipment records — care documented by a clinician, and records of any breast pump, blood-pressure kit or other equipment we supplied to you: kept for the period required by federal law and by the law of the state in which the services were provided, and then destroyed. Where we hold these on behalf of your Provider, we keep them for the period set out in our agreement with that Provider.
• Insurance and billing records — claims submitted to your health plan and the records supporting them: kept for the period required by law and by your health plan, and then destroyed.
• Consent and agreement records — proof of what you agreed to, when, and which version of this Policy or our Terms you were shown: kept for at least six years, as HIPAA requires, because that record is itself a protection for you.
• Marketing and mailing-list information: kept until you unsubscribe. After that we keep only the minimum record needed to make sure we do not contact you again.
• Text-message opt-out records: kept for as long as we operate the text-message program, so that a STOP request continues to be honored.
• Device, usage and analytics information — log data, IP address, device identifiers, and how you use the Services: kept for as long as we need it to operate, secure, evaluate and improve the Services and to meet our reporting obligations, and then deleted or de-identified so that it can no longer be connected to you.
• Records held under a payer or health plan agreement — where a health plan, employer, health system or other payer contracts with us to deliver or pay for your care, that agreement requires us to keep records of the services provided under it, including for audit and for measuring the results of the program. We keep those records for as long as the agreement requires, and for the period it requires after the agreement ends. This is separate from, and may be longer than, the minimum the law sets.
• De-identified and aggregated information — information from which you cannot be identified, and which cannot reasonably be used to identify you. We keep this indefinitely and use it for research into maternal health outcomes, for quality improvement, and for reporting to payers, funders and public health partners on how our programs perform. Because it is no longer connected to you, it is not removed when you delete your account, and it cannot be used to identify or contact you.
• Backups: information you have deleted may remain in our encrypted, access-controlled backups for a short time after deletion. It is not used for any purpose, and it is removed as those backups expire on their normal rotation.

Records we keep after you leave are not used to contact you and are not used for advertising. We do not sell information that identifies you. When a retention period ends, those records are securely destroyed or de-identified. Where we use information for research, we use it in de-identified or aggregated form.

HOW TO DELETE YOUR ACCOUNT AND YOUR INFORMATION

You can ask us to delete your account, and the information we hold about you, at any time. You do not need to give a reason. There are three ways to do it.

From inside the app: open NavigateHER, go to Profile, and choose “Delete my account”. Deletion is immediate — your health information is erased straight away, your account is closed, and anyone you invited as a supporter loses access at once.

From the web, without signing in: go to https://www.mynavigatematernity.com/legal/delete-account and complete the deletion request form. Use this if you have uninstalled the app, cannot sign in, or never finished signing up. Because that page does not require a login, we confirm that the account is yours before anything is deleted — this is what stops someone else from deleting your records. Requests are normally completed within seven days of that confirmation.

By email or phone: write to info@navigatematernity.com or call (260) 585-6100 and ask us to delete your account. We will confirm your identity and then complete the deletion.

What deletion removes: your profile and contact details; blood-pressure, glucose and connected-device readings; screening answers and scores, including depression and anxiety screening; answers about food, housing, transport and other needs; baby tracker entries such as feeds, sleep, diapers, growth, milestones and immunizations; photos you uploaded, including your profile photo and insurance card images; and messages you sent to your care team through the app. Your account is closed and you can no longer sign in.

What deletion does not remove: the records described under “HOW LONG WE KEEP YOUR INFORMATION” that we are required to keep — medical and equipment records, insurance and billing records, consent records, and records we must retain under an agreement with your health plan or other payer. These are kept for the required period and then destroyed. Deletion also does not reach information that has already been de-identified or aggregated, because it is no longer connected to you and we cannot single it out to remove it; it can never be used to identify or contact you. If any of this applies to you, we will tell you when we confirm your deletion.

You can also ask us for a copy of the information we hold about you, or ask us to correct it, by writing to info@navigatematernity.com. Where we hold your information as PHI on behalf of your Provider, we will work with your Provider to answer your request under HIPAA.

INTERNATIONAL TRANSFER

We are based in the United States, and our Services are hosted there. If you are using our Services from another country, the laws governing our collection and use of information may be different from the laws of your country. If you decide to use our Services, or share your information with us, you are agreeing to be governed by the laws of the United States, and agree to the transfer of your information to the United States.

CHILDREN

Our Services are not directed at children under 13, and we do not knowingly collect information from children under 13. If you are under 13, please do not attempt to use our Services or send any information about yourself to us. If you are the parent of a child under the age of 13, and you believe he or she has shared information with us, please contact us at info@navigatematernity.com so that we can remove such information from our systems.

SECURITY OF YOUR INFORMATION

We use reasonable security measures, including measures designed to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage to your information. We also take certain measures to enhance the security of our Services, however, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information.

THIRD PARTY WEBSITES AND SERVICES

Our Services may contain links to other websites and Services operated by third parties, and may include social media features such as social media buttons or links. These third-party websites and services may collect information about you if you click on a link or visit those websites or services, and the social media sites may automatically record information about your browsing behavior every time you visit a website that has a social media button. Your interactions with these features and third parties are governed by the privacy policy of the third party, not by this Policy.

CHANGES TO THIS POLICY

We may make changes to this Policy from time to time. When we do, we will post the updated version on this page. We encourage you to read this page each time that you use our Services so that you will be aware of any changes, and your continued use of our Services shall constitute your acceptance of any such changes. Changes to this Policy take effect from the date of publication, unless stated otherwise.

CONTACT US

If you have any comments, questions, concerns, or suggestions about Policy, or about our privacy practices in general, please contact us at info@navigatematernity.com.