Privacy Policy

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Effective Date: June 25, 2020

Introduction

Welcome to Navigator Healthcare Inc. (“Navigator”)! We understand that the privacy of your Personal Information is important. This Privacy Policy describes how Navigator uses and shares the information we collect about you when you access or use the services offered by Navigator, including, but not limited to, this website (the “Website”) and our provision of information about, and referrals for, evaluation of substance use disorder conditions (together, the “Services”). In this policy, use of “we,” “our” and “us” refers to Navigator.

If you choose to use our Services, then you agree to the collection and use of Personal Information as described in this Privacy Policy. We primarily use the Personal Information that we collect for providing and improving the Services. We will not use or share your information with anyone except as described in this Privacy Policy. From time to time, we may supplement this Privacy Policy with additional information about our privacy practices related to a particular activity that Navigator undertakes. If there is any conflict between this Privacy Policy and an additional notice about our privacy practices, the terms of this Privacy Policy will control with respect to your Personal Information.

We collaborate with healthcare providers and health insurance plans to deliver the Services. If you are a patient of a healthcare provider or member of a health insurance plan with which we have contracted, then we will share your protected health information only as permitted by the provider or plan or as required by law. Further, you may have additional protections and rights under the Health Insurance Portability and Accountability Act (“HIPAA”) related to the protected health information the provider or plan collects about you. You can learn about these additional protections and rights by reviewing your provider’s or plan’s HIPAA Notice of Privacy Practices.

Information we collect

We may collect different types of Personal Information when you visit the Website, submit information to us through the Website or by telephone, or otherwise interact with our Services. We may also collect certain Personal Information from your healthcare provider, such as information that can be used to assess the effectiveness of the Services and facilitate reimbursements from health insurance plans. “Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you.

In particular, we may collect the following categories of Personal Information from or about you:

Direct identifiers, such as your name, postal address, email address, phone number, and date of birth;
Individually identifiable health information, including medical and health insurance information we receive directly from you, your healthcare provider, or your health insurance plan;
Information about your usage of the Website, such as your use and search history and information about your interactions with the Website;
Geolocation information of the device you use to access the Website, such as through your GPS and cellular network;
IP address and mobile device identifier;
Dependent information, such as the direct identifiers and individually identifiable health information of your dependents; and
Any other information you provide to us when requesting or using our Services.

How we use your information

We may use your Personal Information to:

Provide, maintain, and improve the Services you seek (e.g., providing you with information, referrals, and/or scheduling an evaluation appointment with a healthcare provider);
Send you follow-up communications as part of our Services, including responses to your inquiries;
Enhance your user experience on the Website by managing and recording your preferences;
Facilitate your health insurance plan’s reimbursement or payment for our Services;
Detect, investigate, and prevent fraudulent transactions and other illegal activities, and protect the rights and property of Navigator and others;
Maintain records for internal business purposes;
Carry out any other purpose described to you at the time we collect your Personal Information;
Send you marketing communications regarding our Services or third-party resources that may be of interest to you. You may opt out of receiving marketing communications from us by following the unsubscribe instructions included in the communication;
Assist you in the event you experience problems with the Website;
Develop reports on Website use and activity (aggregated data);
Enable certain functions or tools on the Website;
Track, monitor, and analyze usage of, and trends and activities related to, the Services and related resources;
Support our Website content development, marketing, or research efforts; and
Link or combine information we receive from others to help us understand your needs and provide you with a better experience.

How we share your information

We may share your Personal Information with the following types of third parties:

With your healthcare provider(s) and other individuals who participate in your healthcare;
With your health insurance plan for purposes of our reimbursement or payment for our services. We may also share aggregated information with your health insurance plan so that the plan may analyze how effectively your healthcare provider delivers care;
With your authorized or designated representative(s);
With vendors, consultants, and other third-party service providers who need access to such information to carry out work or perform services on our behalf;
Between and among Navigator and any current or future parent, subsidiary, and/or affiliated company; Public and governmental authorities that regulate or have jurisdiction over Navigator, such as regulatory authorities, law enforcement, public bodies, and judicial bodies; and
Other third parties, as reasonably necessary:
- In relation to a merger, sale, acquisition, divesture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control (whether in whole or in part);
- To: (i) comply with laws applicable to Navigator, a request from law enforcement, a regulatory agency, or other legal process; (ii) protect the legitimate rights, privacy, property, interests or safety of Navigator, our customers, business partners, personnel, or the general public; (iii) pursue available remedies or limit damages; (iv) enforce our Terms of Use; or (v) respond to an emergency;
- To establish, exercise, or defend our legal rights; and
- To prevent fraud and reduce credit risk.

Cookies and data collection technologies

We use technologies and analytics, including “cookies,” to gather information from our Website visitors such as which sections of the Website they visited and how frequently or for how long those visits occur.
Cookies are files with a small amount of data that is commonly used to establish a unique identifier for your computer. These files are sent to your browser from the Website that you visit and are stored on your computer's hard drive. Cookies may be “single-session” recording information for a particular visit and then erased or “persistent” which means the cookies are stored on your computer unless or until you delete them or until they expire.

Using your browser preference setting, you may

require notification when a cookie is sent giving the opportunity to decline, or
disable cookies at any time

Note that declining or disabling cookies may limit your use of some features on this Website. We may allow third-party service providers to use cookies and other technologies to collect information and to track browsing activity over time and across third-party websites to identify which web browsers are used to read our Website, which websites are referring traffic or linking to our Website, and to deliver targeted advertisements. Technologies used by third parties are governed by those third parties’ privacy policy. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit the Digital Advertising Alliance at www.aboutads.info/choices.

Finally, we may use analytics companies, such as Microsoft Bing Ads and Google Analytics, to gather Website visitor information as described above and aggregate that data to assess which pages are most visited. Google’s ability to use and share information it collects about your visits to the Site is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. To opt-out of Google Analytics, you may disable cookies on your browser or install the Google Analytics Opt-Out Browser Ad-On. To learn about Microsoft Bing Ads’ privacy practices, please visit Microsoft Bing Ads’ Privacy Policy.

Security

We value your trust in providing us your Personal Information. We have implemented reasonable security safeguards designed to protect your Personal Information. Please note, however, that no method of transmission over the Internet is 100% secure and reliable, and any information disclosed online can potentially be collected and used by persons other than the intended recipient. Accordingly, we cannot guarantee or warrant the security of any information you transmit using the Website.

Links to other sites

Our Service may contain links to other websites. If you click on a third-party link, you will be directed to that website. Note that these external websites are not operated by Navigator. Therefore, we strongly advise you to review the privacy policies of these websites. We have no control over, and assume no responsibility for the content, privacy policies, or practices of any third-party websites or services.

Do not track

Certain web browsers and other devices you may use to access the Website may permit you to submit your preference that you do not wish to be “tracked” online. We do not currently commit to responding to these submissions, in part, because no common industry standard for “do not track” has been adopted by industry groups, technology companies, or regulators. We will make efforts to monitor developments around Do Not Track browser technology and the implementation of a standard.

Your California privacy rights

California residents have a legal right to request organizations to tell them how their Personal Information has been shared, if at all, with third parties for the third parties’ direct marketing purposes. To make such a request, please reach us at the contact information listed below. This request may be made no more than once per calendar year, and we reserve our right not to respond to requests submitted other than to the contact information specified below.

Children's privacy

We recognize the importance of children’s safety and privacy. Neither this Website nor the Services are designed to attract children and are not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are under the age of 18, you should not use this Website or our Services.

Changes to this privacy policy

We may update our Privacy Policy from time to time to reflect changes in the law or our business practices. We will notify you of any changes by posting the new Privacy Policy on this page. Thus, we advise you to review this page periodically for any changes. Changes to the Privacy Policy are effective and will apply to the Personal Information collected starting on the date we post the revised Privacy Policy.

Contact us

If you have any questions, requests, or suggestions related to our Privacy Policy, do not hesitate to contact us by using our web-based messaging.