Information we collect
ZoCo collects the following information about you:
Personal Information. This is information that directly or indirectly identifies you, such as your name, email address, or other identifying information about you.
Protected Health Information ("PHI"). PHI is your Personal Information that is protected under the U.S. Health Insurance Portability and Accountability Act of 1996 ("HIPAA"). HIPAA and other laws closely regulate how ZoCo may handle, protect, and share your PHI. ZoCo may offer certain Services to you based on your relationship with employers, healthcare providers, insurance companies, or other entities (each an "Enterprise Organization") with an interest in your health ("Enterprise Programs"). ZoCo must comply with HIPAA when you receive Services from ZoCo as part of an Enterprise Program.
Other Information. Other Information is information that, by itself does not individually identify you, such as browser type, operating system, technical data, and usage. We may link together different types of Other Information or link Other Information to Personal Information.
How We Collect Information
We collect information in the following ways:
- Information Upon Registration. For example, many of our Services require you to sign up for a ZoCo Account. When you do, we'll ask for personal information, like your name, email address, telephone number or credit card. If you want to take full advantage of the sharing features we offer, we might also ask you to create a publicly visible ZoCo Profile, which may include your name and photo.
- Information from Your Employer or Health Plan. When you are eligible to participate in an Enterprise Program, an Enterprise Organization may provide us with PHI such as your name, date of birth, gender, mailing address, health coverage details, and health plan identification number, among other things. We use this information to provide services to you on behalf of your health plan or employer, in our capacity as a business associate under HIPAA.
- Information Provided to Us by Your Healthcare Provider or Third-Party Lab. When you participate in an Enterprise Program and are asked to obtain your health screening, we may receive information such as your biometric data and blood test data and results.
- Information from Other Sources. We may obtain information about you from affiliates, partners, and other third parties. This information may be used to provide services to you and to provide analysis about you in comparison to people who are demographically similar to you. We may combine the information we obtain from third parties with information that we have collected about you.
- Information We Get from Your Use of Services. We may collect information about the Services that you use and how you use them. This information includes:
- Computer, Tablet, or Mobile Telephone information. We may collect device-specific information such as your hardware model, operating system version, unique device identifiers, device sensors and mobile network information including phone number. ZoCo may associate your device identifiers or phone number with your ZoCo Account. We will comply with the usage/license restrictions and requirements applicable to the device from which the information comes.
- Information from Wearables: When you connect your wearable fitness tracker, heart rate monitor, pedometer or other wearable technology ("Wearable") with the Services, we may collect information about your steps, fitness activities, exercise frequency, sleep, and information about nutrition, such as calorie intake, nutritional statistics, blood pressure, and other biometric data. You may disable this integration through your device.
- Log Information. When you use our Services or view content provided by ZoCo, we may automatically collect and store certain information in server logs. This may include:
- details of how you used our service.
- Internet protocol address.
- device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
- cookies that may uniquely identify your browser or your ZoCo Account.
- Location Information. When you use a location-enabled ZoCo service, we may collect and process information about your actual location, like GPS signals sent by a mobile device. We may also use various technologies to determine location, such as sensor data from your device that may, for example, provide information on nearby Wi-Fi access points and cell towers.
- Unique Application Numbers. Certain Services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to ZoCo when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.
- Local Storage. We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
How We Use Information We Collect
To Provide Services To You. We use the information that we collect about you to provide, maintain, protect and improve the Services that ZoCo provides to you.
To Provide Enterprise Programs To You. We use the information that we collect about you to provide Services on behalf of an Enterprise Organization to you and the Enterprise Organization.
To Improve Our Services. We use de-identified, anonymous information that we collect about you for statistical and analysis purposes to improve our products and services, and to provide population statistical analysis and well-being trend information.
What Information We Share
We take your privacy seriously. We do not sell your Personal Information to any third parties and all information disclosed is the minimum amount necessary to fulfill the legitimate business purpose. We do not share Personal Information with companies, organizations and individuals outside of ZoCo except in the following circumstances:
- With Your Consent. We may share your Personal Information with companies, organizations or individuals outside of ZoCo when we have your consent to do so.
- Enterprise Organization. Under U.S. laws, we may share PHI with your health plan for the administration of your plan. If you receive Services through your relationship with a non-US-based Enterprise Organization, we will adhere to the applicable laws in your country.
- Healthcare Providers. We may share information with your healthcare providers and any clinics or organized healthcare organizations with whom they are associated, provided such sharing is allowable under HIPAA.
- Your Employer. We will not share your PHI with your employer for employment-related purposes. We may only share the information needed to for your employer to deliver Enterprise Programs. For example, we may share completion status of a wellness plan requirement but not the actual results of the required action.
- Third-Party Service Providers. We may disclose your PHI to our business associates who perform various functions on our behalf, but ZoCo requires these third parties to agree in writing to safeguard your PHI appropriately and in accordance with the law. ZoCo does not sell or rent your PHI to third parties. ZoCo does not use your PHI to market, sell, or otherwise promote goods or services that are not health-related benefits provided by your health plan, employer, or provider.
- For External Services. We may, from time to time, outsource some or all of the operations of our business to third-party service providers. In such cases, it may be necessary for us to disclose your data to those service providers. In some cases, the service providers may collect data directly from you on our behalf. We restrict how such service providers may access, use and disclose your data. We employ other companies and individuals to perform functions on our behalf. Examples include processing compensation, providing employee benefits, and performing legal and other professional services. These agents may have access to your data as needed to perform their functions, but they are not permitted to use it for other purposes.
- For Legal Reasons. We may disclose any data about you when, in our opinion, such disclosure is necessary to prevent fraud or to comply with any statute, law, rule or regulation of any governmental authority or any order of any court of competent jurisdiction.
- In a Transaction. As we continue to develop our business, we might sell or buy companies, subsidiaries, or business units. In such transactions, data generally is one of the transferred business assets but remains subject to the promises made in any pre-existing privacy statement (unless, of course, the person consents otherwise). Also, in the unlikely event that ZoCo or all of its assets is acquired, your data may be one of the transferred assets.
We may share aggregated, deidentified information publicly and with our partners to evaluate the effectiveness, value, and analytic trends of the Services. We may also disclose deidentified information with sponsor of Services provided to you in compliance with law and applicable confidentiality and security measures.
How We Protect Your Information
We work hard to protect ZoCo and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. ZoCo is committed to using industry-leading security practices such as ISO27001 and HiTRUST. In particular:
- We comply with HIPAA's security rule
- We encrypt many of our Services using SSL.
- We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
- We restrict access to Personal Information to ZoCo employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
We keep Personal Information housed on servers in the United States. If you are located outside of the United States, information we collect (including cookies) are processed and stored in the United States. By using the Services and providing information to us, you consent to the transfer to and processing of the information in the United States. The adequacy decision on the EU-US Privacy Shield was adopted on July 12, 2016 and the Privacy Shield framework became operational on August 1, 2016. This framework protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes.
We store Personal Information for as long as required under applicable law. Where there is no legal, fiscal, administrative, or contractual requirement to retain the data for a longer or shorter period, data will be destroyed within five (5) years of its collection.
Transparency and Your Choices
People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used. For example, you can:
- Manage your email preferences in your Notifications settings.
- Control who you share information with through your Privacy settings.
- Take information out of many of our Services by contacting ZoCo Customer Support.
Your Use After Termination of Enterprise Program. Upon termination by you or ZoCo of the relationship with your Enterprise Organization, you will have the opportunity, under certain Services, to continue to use your personal profile and to access information about yourself, including personal health information provided by an Enterprise Organization, in that profile. In order for you to continue to access the personal health information provided by your Enterprise Organization, you would need to execute a voluntary HIPAA Authorization allowing ZoCo to receive and use your personal health information. If you choose not to authorize ZoCo to receive such information about you, you may not be able to use some of the Services or features of the Services. Information that you were able to access as part of an Enterprise Program may no longer be available to you post-termination without such authorization. If you continue to use Services made available by ZoCo after termination of the relationship with your Enterprise Organization, your ZoCo account will continue to be governed by the ZoCo Terms and Privacy Policies.
Cookies. You may also set your browser to block all cookies, including cookies associated with our Services, or to indicate when a cookie is being set by us. However, it is important to remember that many of our Services may not function properly if your cookies are disabled. For example, we may not remember your location preferences.
Advertising. Unless you are receiving Services as part of an Enterprise Program, we also personalize your experience on our sites and mobile Services by showing you advertisements from ZoCo or our advertising partners that are tailored to your interests. ZoCo does not advertise, market, or promote products or services to patients, participants, or practitioners who receive Services as part of an Enterprise Program. In the event your health plan sponsor, employer, or health plan, through which you receive services, instructs us provide advertising content on this site, ZoCo would first obtain your valid authorization in compliance with applicable data privacy laws.
Information Shared By You. Many of our Services let you share information with others. Remember that when you share information publicly, it may be indexable by search engines. Our Services provide you with different options on sharing and removing your content.
Accessing and Updating Your Personal Information. Whenever you use our Services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request. Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our Services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our Services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems. Access, correction, or deletion requests can be made by contacting ZoCo Customer Support.
Other Helpful Information
Information of Children. The Services are not directed to or intended for use by minors. In compliance with laws, we will not intentionally collect any personal information from children under the age of 18. If you think that we have collected personal information from a minor child, please contact us.
Compliance and Cooperation with Regulatory Authorities
California Privacy Rights
Residents of the State of California may have additional rights as set forth in our Privacy Notice for California Residents.
Other jurisdictions, including but not limited to the European Economic Area, provide certain additional rights regarding personal information, including the ability to request erasure, to restrict processing of your personal information, or for a copy of your personal information. In order to exercise your rights under these jurisdictions, contact us and provide us with sufficient information such as your name, address, any other information necessary for us to verify your identity. We reserve the right to request additional information from you, such as a photocopy of your passport or other identification card in order to verify your identity.
Last modified: November 23, 2020