Privacy Policy

Last updated February 16th 2023

1. Introduction and General Background

Peloton-Health Ltd. a company operating under the brand name SequelCare (“SequelCare”, “we” or “us”) presents this privacy policy, as may be amended from time to time (the “Privacy Policy” or “Policy”) in order to provide our Users (defined below) information about SequelCare’s privacy and data protection practices in relation to Personal Information that is collected, used and/or otherwise processed by SequelCare and/or third parties acting on its behalf, through its proprietary mobile application for End-Users called “MySequel” (the “App”) and its corresponding web platform for Care Providers and Peer Supporters called “SequelCare” (the “Platform”) intended for the enhancement of mental health caregiving through collaborative care.

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The App enables the collaboration between various Users involved in the management and support of an End-User’s Care Plan, including the End-User, the Peer Supporter and Care Providers. The End-User’s use of the Services provided through the App and Platform, is subject to the App’s Terms and Conditions which are available at: https://sequel.care/terms-of-use.

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In the United States, the core use of this app is governed by (as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”)). This Privacy Policy applies only to if and to the extent HIPAA does not apply.

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If the End-Users are using the Platform or App to communicate with a Healthcare Provider and manage and administer the Care Plan, SequelCare will collect and store Protected Health Information (“PHI”) (as defined by HIPAA) on behalf of the Healthcare Provider as a business associate. As a business associate, SequelCare cannot use or disclose PHI in a way that is prohibited by either HIPAA or the terms of SequelCare’s business associate agreement with the Healthcare Provider. For information on how the Healthcare Provider collects, uses, and shares your PHI, please refer to the Healthcare Provider’s notice of privacy practices.

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If the End-User decides to invite a Peer Supporter and/or Care Provider to collaborate and assist the End-User in the implementation of the Care Plan, such Users will use the Platform to collaborate with the End-User, subject to this Privacy Policy and the Platform’s Terms of Use; which are available at: https://sequel.care/care-provider-terms.

WE STRONGLY URGE YOU TO READ THIS PRIVACY POLICY CAREFULLY BEFORE YOU START TO USE OUR SERVICES.

2. Your Consent (applicable for Israel only)

2.1 By using the App, you hereby provide your informed consent to the collection, process and use of your Information by SequelCare (including the transfer of such Information to third parties, as set forth in the Privacy policy), all, for the purposes and the terms set forth in this Privacy Policy.

2.2 The Personal Information you provide will be stored in our Database(s) (as defined in the PPL), and will be processed by SequelCare (including, third parties acting on our behalf) for the purposes and the terms as specified in this Privacy Policy.

3. Definitions

For the purpose of this Privacy Policy, the following terms shall have the respective meanings set forth besides them:

3.1 “Account” means any User’s account on the App or the Platform.

3.2 “Care Plan” means the integrated treatment plan comprised of questionnaires, targets, goals and specific steps towards achieving those goals such as tasks or exercises, psycho-education content, any instructions given by your Care Provider.

3.3 “Data Protection Laws” means the Israeli Data Protection Legislation, HIPAA, and any other privacy and data protection laws applicable to SequelCare with respect to processing Personal Information, according to the terms of the Privacy Policy.

3.4 “Care Provider” means an individual who provides healthcare services to the End-User, at the End-User’s choice and participates in the End-User’s Care Plan; including but not limited to: i) a licensed medical practitioner such as a psychologist, psychiatrist, physician, nurse, social worker, occupational therapist, the Healthcare Provider’s Care coordinator, case manager and/or other relevant staff that are employed by or retained by or receive authorization from the Healthcare Provider including managers, health coach, psychotherapy, dietician and/or any other licensed therapist; ii) a professional caretaker such as a certified coach or counselor and iii) any other person who provides mental healthcare services to the End-User at the End-User’s choice.

3.5 “Healthcare Provider” means a legal entity that provides the End-User with mental healthcare services such as a clinic, community health center, medical practitioner, HMO, health system, or any other medical institution and/or provider with whom the End-User is treated and which may, in some cases, employ the Care Provider.

3.6 “HIPAA” means the US Health Insurance Portability and Accountability Act of 1996 as amended from time to time.

3.7 “Information” means Personal Information and Non Personal Information, together.

3.8 “Israeli Data Protection Legislation” means the Privacy Protection Law 5741-1981 (the “PPL”) and any regulations promulgated thereto, as amended, supplemented and superseded from time to time.

3.9 “End-User” means an individual who has downloaded the App, uses the App as a tool to support and manage the End-User’s Care Plan and who may also choose to allow a Care Provider or Peer Supporter to use the Platform in order to assist the End-User in the implementation of the Care Plan.

3.10 “Peer Supporter” means a family member, friend, coach, guide, mentor or any other individual who the End-User has authorized and invited to use the App in order to provide support in the implementation of the Care Plan.

3.11 “Care Information” means all Information processed through the App or on the Platform about an End-User, including information uploaded by the User, generated when the User interacts with the App, or information entered into the Platform by a Care Provider about the End-User.

3.12 “Personal Information” means any information processed on the App and/or Platform, that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular person, consumer or household, or as otherwise defined in the Data Protection Laws.

3.13 “User,” “you” or “your” (including any alterations thereof) means any individual (including, without limitation, End-Users, Peer Supporters and Care Provider) that Uses the App and/or Platform.

3.14 The term “Processing” shall have the meanings ascribed to it or to any essentially similar term in the Data Protection Laws.

3.15 “Services” shall have the meaning ascribed to it in the Terms.

3.16 “Terms” means any of the following, as relevant: for Users - the Terms and Conditions of the App which are available at https://sequel.care/terms-of-use, for Care Providers or Peer Supporters - the Terms of Use of the Platform available at https://sequel.care/care-provider-terms; both as may be amended and/or updated from time to time.

Terms which are not defined herein shall have the meaning ascribed to them in the Terms.

4. Collection of Personal Information – General Provisions

4.1 No legal requirement. You have no legal obligation to provide us with any Personal Information (or any other Information) when you Use the App, and the provision of it is solely based on your free will. However, you are aware that without the provision of your Personal Information, we will not be able to enable you to access and use the App and your Care Provider and/or Healthcare Provider will not be able to provide you with services through the Platform.

5. The Personal Information we process and the purposes of processing when you register for the App

5.1 We receive from your provider your personal identifiers (First name, Last name, Date of birth, Gender) and contact information) (Email, Mobile phone, and physical address (optional). We use this information to add you as a patient in the app.

5.2 Personal Information provided by End-Users through the App when you register for the App:

When you register for the App, we will collect from you the following information:

5.2.1 Your identifiers: your first and last name and telephone number and the password you choose. We use this information to set up your account in the App and contact you about the Services. We will use your email address or any other contact information you have provided us, to contact you by e-mail, with general or personalized service-related messages (such as system maintenance notices); to contact you by e-mail with updates messages (such new features and services, etc.) and respond to inquiries, and to transmit marketing and promotional communications regarding our Services. You can unsubscribe at any time from these marketing emails by clicking on the “unsubscribe” link in each email. Please note that we will continue to send you email notifications necessary to the Services or requested products or services. Our e-mail communications contain tracking technologies, to analyze whether a predefined action took place by a recipient, such as opening our communications, in order to better adapt and distribute our communications. You can disable tracking by disabling the display of images by default in your email program.

5.2.2 Optionally, you may (but are not obligated to) provide your identifiers (date of birth, address), and identifiers of a contact person: first and last name, relation to the End-User, telephone number. If you wish, we will use this information to set up the support relationship with your contact person’s account.

5.2.3 If you choose to respond to questionnaires that are selected by your therapist, we will collect your responses to questionnaires, such as, questionnaires on the following subjects: (a) symptoms, (b) functioning and satisfaction with life, (c) putative mechanisms of change (e.g., readiness to change), and (d) the treatment process (e.g., session feedback, working alliance). (e) social determinants of health ("Questionnaire Data"), which will contain health or medical information (health symptoms, treatment plan, diagnosis, mental health indicators). We analyze the information you provide using our proprietary algorithm, which attributes scores to the different types of information you provide to determine the effectiveness of the treatment. We share these determinations with the therapist for them to use in assessing and adjusting the treatment. If your provider decides to make these available to you, you would be able to access these determinations in the app on the “My Process” page and can choose that they be shared with a peer supporter.

5.2.4 If you choose to enter them, we collect from you your goals, including the following health information: personal goals, progress, a personal journal to document and monitor progress, Peer Supporter and Care Provider and/or Healthcare Provider’s details, your achievement dates. We factor this information into our proprietary algorithm and use it to assist your provider to improve your treatment, as well as monitoring your Use of the App and compliance with the Care Plan and providing you reminders (through push notifications) to promote your compliance with the Care Plan.

5.3 Personal Information provided by Peer Supporter through the App when you register for the App:

When you register to the App, we will collect the following information:

5.3.1 We will collect from the Peer Supporter your identifiers (Username (which is your phone number used for registration), password, email), relationship with the End-User. We use this information to set up your account in the App and contact you about the Services. We will use your email address or any other contact information you have provided us to contact you by e-mail with general or personalized service-related messages (such as system maintenance notices); to contact you by e-mail with updates messages (such new features and services, etc.) and respond to inquiries, and to transmit marketing and promotional communications regarding our Services. We may also contact you through the email you provide us in order to notify you about new Services, or any other information we think you will find valuable. You can unsubscribe at any time from these marketing emails by clicking on the “unsubscribe” link in each email. Please note that we will continue to send you notifications necessary to the Services or requested products or services. Our communications contain tracking technologies, to analyze whether a predefined action took place by a recipient, such as opening our communications, in order to better adapt and distribute our communications. You can disable tracking by disabling the display of images by default in your email program.

5.4 If you are a Care Provider(s) you may provide us the following Personal Information when you register for the App:

When you register to the App, we will collect from you the following information:

5.4.1 We collect your identifiers (username (which is your email used for registration), password, email, phone), employment information (if you are employed by a Healthcare Provider - the name of the Healthcare Provider employing you, position (Care Plan coordinator, associate, expert). We use this information to register you to the App and contact you about the Services. We will use your email address or any other contact information you have provided us to contact you by e-mail, with general or personalized service-related messages (such as system maintenance notices); to contact you by e-mail with updates messages (such new features and services, etc.) and respond to inquiries, and to transmit marketing and promotional communications regarding our Services. You can unsubscribe at any time from these marketing communications by following the instructions in our communication with you, or, in emails clicking the unsubscribe link. We may also contact you through the email you provide us with in order to notify you about new Services, or any other information we think you will find valuable. Please note that we will continue to send you notifications necessary to the Services or requested products or services.

6. The Personal Information we process and the purposes of processing when you utilize to the App or Platform

6.1 Personal Information we collect from Peers Supporters:

When you (the Peer Supporter) utilize the App or Platform, you may upload any information that you choose to upload to the Platform and information in response to questionnaires provided by SequelCare for the purpose of assisting in the Care Plan, meaning the Questionnaire Data.

6.2 Personal Information we collect from Care Provider(s):

6.2.1 When you (the Care Provider) utilize the App or Platform, you may upload any information that you choose to upload to the Platform, including health information (clinical diagnosis and information in response to questionnaires provided by SequelCare for the purpose of assisting in the Care Plan, meaning the Questionnaire Data).

6.3 Personal Information we collect from End-Users or generate:

6.3.1 When you utilize the Services, the Personal Information fields collected on the Platform may vary, at the discretion of the Healthcare Provider and some of them are transmitted to the App. Not all the Information collected on the Platform is transmitted into the App. Accordingly, the following health/medical information from the Platform may be transmitted to the App: Care Plan details, including medication protocol, Healthcare Provider instructions, tasks and task related data, status of the Care Plan, End-User’s physical and mental response to the Care Plan (such as sleep habits, End-User’s mood and activity level, End-User’s general condition and overall wellbeing), dates of commencement of the Care Plan, milestones and completion dates. We use this information to provide the Services through the App and to provide access to such Information to your Care Provider and Peer Support in order to improve your treatment.

6.3.2 As part of the Services, when the App syncs with the Platform, the following health information from the App may be transmitted to the Platform: achievement of goals, tasks performed, responses to questionnaires.

6.3.3 When you participate in Video calls and chat messages through the App we collect your sensory information accumulated in the video call (physical appearance and audio information of your voice) and anything you include in the chat functions on the App, which is collected through third party providers on our behalf whose services interface with the App, as further detailed in Section ‎8.4 below. To use these, you will need to create and account with the relevant provider and your use of these functions is also subject to the privacy practices of their providers, which are referenced when accessing the video or chat functions on the App. We use this information to facilitate communication with the User.

6.3.4 In some cases, the App may contain the End-User’s health information (main diagnosis, other mental health information connected to the main diagnosis and appointment summary notes).

6.4 Personal Information automatically collected or generated from the App, including Personal Information extracted by the App from the mobile device:

6.4.1 SequelCare collects statistical information about how Users locate and navigate the App, such as: your mobile device brand, device model, country, time zone, operating system type and version, settings used, session time. We use this information to (i) monitor and analyze your use of the App; (ii) develop, customize and improve the App; (iii) support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity; (iv) technical administration and troubleshooting of the App; (v) to enhance the positioning of App within Internet search engines and stores; and (vi) research and further development, analysis and statistics.

6.4.2 SequelCare collects statistical information about how Users locate and navigate the Platform, such as: browser type, operating system version, referring URL, session time. We use this information to (i) monitor and analyze your use of the App; (ii) develop, customize and improve the Platform; (iii) support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity; (iv) technical administration and troubleshooting of the Platform; and (v) research and further development, analysis and statistics.

6.4.3 In addition, we render Personal Information anonymous to create aggregated statistical data, or anonymized or pseudonymized data, which we or our business partners may use to provide and improve our respective Services, and create de-identified user profiles and compare Care Plans of different Users enabling us to improve the Care Plan and improve treatment for other Users with similar characteristics

6.4.4 When you are using the Services and allow the App to automatically collect information from the device on which it is installed, the App will collect Physical and behavioral parameters collected from your mobile device sensors (if such option is selected and specific permissions are granted by the End-User), including sleep habits, movements of your mobile phone including a pedometer and accelerometer; geolocation information (GPS location), and call and text log (strictly quantity and frequency of calls, not content). We use this information to assess whether you are following the Care Plan, tracking your goals, and provide access to such Information to your Care Provider and Peer Support in order to improve your treatment.

Please note that the information regarding End-User’s movements may be collected using a technology tool provided by a third-party service provider however it is stored on the App and then sent to the third-party provider as Non-Personal Information without personal identification.

6.4.5 Usage information. We use essential, performance, marketing, and analytics tracking technologies to collect information about your interaction with our Services, such as what you access, what you click on, the frequency of access, and how much time you spend on the Services. We use this information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; (iv) prevent fraudulent use of the Services; and (v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse.

6.4.6 Device information. We use essential, performance, marketing, and analytics tracking technologies to collect certain information about the device you use to access the Services, such as browser type, browser language, hardware model, operating system, and device preferences. We use this information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; (iv) prevent fraudulent use of the Services; and (v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse.

6.4.7 Location information. We use essential, performance, marketing, and analytics tracking technologies to collect information about your location, which may be determined through your IP address, GPS, or RFID signal. We use this information to: (i) track you within the Services; (ii) enhance user experience; (iii) conduct analytics to improve the Services; and (iv) prevent fraudulent use of the Services; (v) diagnosis and repair Services errors, and, in cases of abuse, track and mitigate the abuse.

6.4.8 Cookies are a commonly used web technology that allow websites and apps to store and retrieve certain information on a user’s system, and track users’ online activities. We and our service providers may collect Information about your use of our Services by such automated means, including but not limited to cookies, pixels, SDKs and other similar technologies.

6.4.9 Cookies and similar technologies can help us automatically identify you when you return to the Platform or App. Cookies help us review traffic patterns and improve the Platform and App, determine what Services are popular. We can also use such Information to deliver customized content.

6.4.10 If a User does not want Information collected through the use of cookies, most browsers will reject cookies, but if you choose to decline cookies, you may not be able to fully experience the full features our Services provide. We may share Non-Personal Information obtained via cookies with our advertisers and affiliates.

6.4.11 We currently use the following technological tools for the collection of Personal and Non Personal Information, as detailed in Section ‎7 above:

6.4.12 Mixpanel is used to analyze how users interact with our App.

6.4.12.1 For information about how Mixpanel uses the information it collects, see https://mixpanel.com/legal/privacy-policy/.

6.4.13 Twilio is used for chat and video chat. For information on how Twilio uses information it collects, see https://www.twilio.com/legal/privacy.

6.4.14 Auth0 - We use Auth0 (https://auth0.com/) for authentication of Users. Auth0 uses various cookies on the Platform and App in order to authenticate Users. We are not responsible for the privacy practices of Auto0 and their use of cookies. A list of Auth0 cookies stored in the browser can be found in the documentation here: https://auth0.com/docs/sessions-and-cookies/samesite-cookie-attribute-changes#browser-cookie-changes and the Auto0 privacy policy can be found here https://auth0.com/privacy.

6.4.15 In addition to the personal information identified above, when you use the App, we and our third-party provider collects your internet and other electronic network activity (IP Address, internet service provider, browser type and version etc.) via SDKs to make the Platform work as you expect it to and to provide enhanced functionality as described below. Some of the SDKs we use will store and retrieve information on your device, like a cookie or other similar tracker would.

6.4.15.1 Essential SDKs: We use essential SDKs which are necessary for the App to function. If you do not provide this information, we would not be able to provide the App.

6.4.15.2 Performance SDKs: When you use the App, we automatically collect, through our third-party SDK provider, your internet and other electronic network activity (IP Address, internet service provider, browser type and version etc.) regarding your device and use of the App. We use the information to test the performance of and improve the App for all users. This information is shared with our third-party SDK provider on an aggregated and anonymized basis.

6.4.15.3 For Users in the US: We do not respond to web browser-based DNT signals at this time, but we do not collect information about users’ online activities across third-party websites. For more information, visit: https://www.eff.org/issues/do-not-track.

6.5 We to exercise or defend our legal rights, resolve disputes, comply with any applicable law (including Data Protection Laws), or other requests from authorized authority(ies), and/or if you provide your consent to this use.

7. Retention: How long do we retain the Information

7.1 We retain the User's Personal Information for as long as such individuals are using our Services. If a User ceases to use our Services, we may continue to retain certain Personal Information of that User for the period required by our legal and regulatory obligations and/or for accounting purposes (i.e., as required by applicable laws regulating our Services, for bookkeeping purposes, and in order to have proof and evidence concerning our relationship with that User, should any legal issues arise following the User’s discontinuance of use of our Services).

7.2 Please note that except as required by applicable law, we will not be obligated to retain your data for any particular period, and we are free to securely delete it for any reason and at any time, with or without notice to you.

8. Who do we share Information with

We may share your Information (including Personal Information) with certain third parties, as detailed below:

8.1 Compliance with Applicable Laws, Legal Orders and Authorities. We may disclose or allow government and law enforcement officials access to certain Personal Information, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws. Such disclosure or access may occur with or without notice to you, if we have a good faith belief that we are legally compelled to do so, or that disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing.

8.2 Service Providers and Business Partners. We share the information with selected third-party companies and individuals we engage to perform the Services on our behalf (such as cloud vendors, data hosting services, data analytics services, IT services, e-mail distribution and monitoring services, chat and video services, research and development services and our business, legal, financial and compliance advisors). We only provide such service providers with Information so they can perform their required functions on our behalf.

8.3 With our Affiliates. Your Personal Information will be shared with our affiliates where we consider that it is in our legitimate interests to do so for internal administrative purposes (for example, ensuring consistent and coherent delivery of Services, corporate strategy, compliance, auditing and monitoring, research and development and quality assurance).

8.4 Enforce Our Rights. We may transfer Personal Data in order to take any action in case of dispute involving you with respect to the App and/or Platform; to establish, protect, or exercise our legal rights; as required to enforce the Terms or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights.

8.5 Business Transfer. We may share Information in connection with any proposed or actual financing, reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

8.6 In the preceding twelve (12) months, we may have shared your internet or other electronic network activity Information collected through cookies and other tracking technologies with our data analytics providers.

‍9. How We Protect Information

We endeavor to maintain appropriate administrative, technical and physical safeguards designed to protect the Personal Information we maintain against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Peloton Health Ltd. is certified to ISO 27001 and ISO 27799 global recognized information security standards in the medical industry. We have put in place physical, administrative, and technical policies and controls designed to help prevent unauthorized access and maintain data security and confidentiality such as: encryption in transit and at rest, periodical penetration tests, authentication and authorization controls, secure development life cycle process and security in our supply chain. However, although we make every effort to protect the Personal Information which you provide to us, we cannot completely ensure the security of any Information you transmit to us over the internet or that is stored on cloud-based services, or guarantee that this Information will not be accessed, disclosed, altered, or destroyed.

10. Children

The App is directed towards and designed for use by persons aged 13 and older. We do not solicit or knowingly collect Personal Information from children under the age of 13. If we nevertheless receive Personal Information from an individual who indicates that he or she is, or whom we otherwise have reason to believe is, under the age of 13, we will endeavor to delete such information from our systems. If you are an individual under the age of 13, you are required not to Use our App and/or Services, and de-install the App from your mobile device.

‍11. Changes to this Privacy Policy

This Privacy Policy may change from time to time. If we decide to change our Privacy Policy, we will post new privacy policy in our App and on the Platform accompanied with a notice indicating that some changes have been made. If there are any material changes to the Privacy Policy, we will notify you by prominently posting on the Mobile App and Website, and if necessary, obtaining your consent. The new privacy policy will be effective from the date mentioned at the top page of the new policy. Each version of this Privacy Notice will be identified by its effective date, which you can find at the top of this Policy. Your continued use of the App or Platform after we post such notice constitutes your agreement to any such changes.

‍12. Contacting us

If you have any questions about this Privacy Policy, or in the event that you wish to exercise certain rights you are eligible for with respect to your Personal Information, please contact us by email to support@sequel.care.

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The practices described in this privacy policy statement are current personal information protection policies, as of February 16th 2023.

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