Effective: August 20th, 2020
Healthy Together is a tool developed in coordination with epidemiologists and public health officials to help stop the spread of COVID-19. It uses information that you share through the app along with third-party data to help U.S. local, state and federal governments and public health organizations identify COVID-19 transmission networks and deploy testing and containment efforts to research and combat the pandemic.
If you choose to share information through Healthy Together, the data you share will help further COVID-19 response efforts by allowing public health workers to conduct contact tracing more accurately, more effectively and at a larger scale.
Your use of Healthy Together is voluntary. You can at any time direct us to delete your personal information by choosing to do deactivate your account within the app, or by emailing your request to firstname.lastname@example.org.
We may need to modify our privacy practices to comply with legal requirements, such as court orders, subpoenas or investigations.
When you use Healthy Together, we will ask you to share certain personal information with us. We will also receive information from U.S. local, state and federal government organizations, and collect certain technical, device and usage information from your device.
We may receive:
The State of Utah may also provide us with certain health-related information, including COVID-19 test results, which we may use, in conjunction with real-time location data that users choose to share, to alert individuals when they may have been exposed to individuals who have tested positive for COVID-19. If a user has been exposed to COVID-19, this information may be shared with government officials and healthcare workers to help augment contact tracing efforts or coordinate the COVID-19 public health response. However, we will never disclose to other Healthy Together users the name or phone number of individuals who have tested positive for COVID-19, or any other details that directly identify these persons
We are committed to putting people in control of their information:
Except as described below, we may only share your personal information:
We may share de-identified information with public interest organizations, health care organizations and researchers. We will prohibit these organizations from attempting to re-identify the information we share with them.
We may share personal information with government, law enforcement officials or private parties as required by law, when we believe such disclosure is necessary or appropriate (a) to comply with legal obligations, law enforcement requests or legal directives such as a court order or subpoena; (b) enforce the terms and conditions that govern the platform; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.
We may make available on Healthy Together, or link to, features that allow you to share information with third parties. Please be careful whenever sharing your personal information with third parties, and only share sensitive personal information with third parties whom you trust. We have no control over the use of your information by third parties with whom you choose to share your information.
We have implemented a number of security measures designed to protect your information, including encrypting all personal information in transit and at rest. Please note that we are not a healthcare provider or other “covered entity” that is subject to the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and are not bound by its requirements for handling protected health information. However, we have a security program in place designed to mitigate risk and to use reasonable and appropriate procedures and technologies to help protect the confidentiality of all personal information.
It is important that you protect and maintain the security of your account, and you should immediately notify us of any unauthorized use of your account. No website, mobile application or Internet transmission is completely secure, and therefore we cannot guarantee that unauthorized access, hacking, data loss, or other breaches or other type of misuse will never occur. Be careful where and how you share personal information—use public WiFi spots wisely and avoid clicking unfamiliar links or using unfamiliar devices.
We may post a notice via Healthy Together if a security breach occurs. We may also send you notice by the contact information you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive written notice of a data privacy or security breach.
Accessing and Updating Your Information. If you have an account with us, you can access and edit your profile information directly within the profile page of the app.
Deactivating Your Account and Deleting Your Information. You may deactivate your account at any time by following the instructions within the app settings. Deactivating your account deletes all of your personal information we maintain. Please note that you must follow these instructions to deactivate your account. Otherwise, your account will remain active, even if you delete or uninstall the app. We will delete any personal information we maintain on back-up media in the ordinary course of business.
Opting Out of Push Notifications. If you opt-in to receive push notifications within the app, we may send push notifications or alerts to your mobile device from time to time. You can deactivate push notifications and alerts at any time by deleting the app, changing your device settings or changing the push notification settings within the app.
Opting Out of SMS Communications. If you opt-in to receive SMS messages by providing your phone numbers, we may send you notifications and other SMS messages from time to time. You may opt out of receiving SMS communications at any time by responding to any SMS with the single-word command, “STOP.” In addition, if you have an account, you can opt out of SMS communications by changing the settings within the app. You may opt back in to SMS communications at any time by adjusting your account settings within the app. Please note we may not be able to determine if you delete or uninstall the app, or block the number that delivers the communications, and therefore may be unable to automatically stop you from receiving SMS communications unless you have specifically opted out of SMS communications by following the instructions above.
Opting Out of Location Tracking. While the information you share will be vital to contributing to our awareness and understanding of how the COVID-19 threat is spreading, ultimately you control what is shared. If you opt in to sharing your geo-location information through Healthy Together, you can subsequently stop sharing this information at any time by deleting the app or changing the preferences on your mobile device. Please note, however, that if you withdraw consent to the sharing of location information, you will no longer be able to use some features of Healthy Together.
Healthy Together is not intended for children under the age of 13, and we do not knowingly collect any personal information from children under 13. If you are between the ages of 13 and 17, you can only use Healthy Together if your parent or legal guardian has reviewed and agreed to the Terms of Service on your behalf.
If we become aware that personal information we maintain pertains to a child under the age of 13, we will promptly delete that information from our live systems and applications, unless we are prohibited by law from doing so. We will delete any personal information we maintain on back-up media in the ordinary course of business.
Please note that we do not sell personal information.
The California Consumer Privacy Act of 2018 (“CCPA”) grants California residents the following rights:
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain information we maintain for compliance in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
You are entitled to exercise the rights described above free from discrimination, as prohibited by the CCPA.
How to Submit a Request
To request access to or deletion of personal information:
Twenty Labs, LLC
c/o 280 Park Avenue
New York, NY 10017