Privacy Policy – Managed Health Connections, Inc.
Effective date: January 31, 2025
This Managed Health Connections Privacy Policy relates to the collection, use, and disclosure of your Personal Data and PHI in your use of the Platform. You may disclose Personal Data and PHI in your use of the Platform and you consent to MHC’s collection, use, and disclosure practices related to such Personal Data and PHI specified in this Privacy Policy. You further agree to comply with Applicable Law related to the sharing of your Personal Data and your collection, use, and disclosure of Personal Data belonging any third parties. If you do not consent and agree to this Privacy Policy, you will immediately discontinue use of the Platform and uninstall all related downloads and applications.
If your use of the Platform is related to a Research Study, then in the event of any conflict or inconsistency between this Privacy Policy and the informed consent you provided in connection with the Research Study, the terms of such informed consent shall control.
SECTION 1 Definitions
(a) “Applicable Law” means all applicable (1) state, federal, and international laws and regulations, and (2) ethical, professional, and licensure requirements of your profession if you are a healthcare provider.
(b) “Appropos Health” means MHC’s web and mobile application that makes available a tool to be accessed by you to monitor use of alcohol or other substances.
(c) “HIPAA” means the Health Insurance Portability and Accountability Act of 1996 and associated regulations, as amended.
(d) “MHC” means Managed Health Connections, Inc., a Delaware corporation located at 203 N Washington St. Suite 302, Spokane, WA 99201
(e) “Neowithdrawal” means MHC’s web-based training platform that makes available a training program and tool to provide information and measurement related to conditions that may affect mothers and infant with specific conditions.
(f) “Personal Data” means any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, by referencing an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
(g) “PHI” means (i) “Protected Health Information” as that term is used under HIPAA, and (ii) “Patient identifying information” as that term is used under 42 CFR § 2.11.
(h) “Platform” means the Website, the Neowithdrawal web-based training platform, Appropos Health mobile application or related applications and all other products or services provided by MHC.
(i) “Privacy Policy” means MHC’s policy related to the collection, use, and disclosure of Personal Data and PHI as specified in this Managed Health Connections Privacy Policy, the Platform, and any additional privacy statements provided to you in writing.
(j) “Research Study” means any use of any portion of the platform which is covered by a study or clinical trial approved by an Institutional Review Board.
(k) “User Account” means the account created by you to access and use the Platform.
(l)“Website” means the portion of MHC’s website accessible by you located at www.managedhealthconnections.com, www.neowithdrawal.com, or www.approposhealth.com.
(m) “You” means the individual or entity visiting, installing, downloading, accessing, or otherwise using the Platform.
SECTION 2 Personal Data and PHI collected by MHC
(a) Information provided to MHC.
This may include your first and last name, birthdate, email, phone number, PHI, screening measures and surveys, professional license, and other information when you create a User Account to access the Platform. You may at any time update such information on your User Account once it has been created.
(b) Information MHC collects from you automatically when you use the Platform.
MHC and its partners and affiliates may automatically collect certain information about you when you use the Platform (“Usage Data”). Usage Data may include IP address, device identifier, browser type, operating system, information about your use of the Platform, and data regarding network connected hardware (e.g., computer or mobile device). The methods that may be used on the Platform to collect Usage Data include the following:
Information MHC collects from its partners and other sources.
MHC may collect Personal Data that you have provided to MHC and its subsidiaries, affiliates, business partners, and/or businesses related to MHC for purposes set out below. MHC is not responsible or liable for the accuracy of the information provided by third parties or for third party policies or practices. Generally, MHC collects Personal Data directly from you. If third parties hold information MHC requires, MHC will endeavor to ensure the information has been collected with your consent. MHC may collect and use Personal Data that is aggregated and anonymized (“Analytic Information”) from MHC subsidiaries, affiliates, business partners, and/or businesses related to MHC, for various business purposes, including enabling MHC to provide the Platform. Analytic Information, because it is aggregated and anonymized, is no longer Personal Data as it cannot be used, alone or in conjunction with other information, to identify an individual. MHC may use this Analytic Information in a variety of ways, including to help analyze site traffic, understand users’ needs and trends, and to improve MHC products and services.
MHC may use this information by itself or aggregate it with information MHC has obtained from others. MHC may use, transfer, lease, sell, or otherwise commercialize Analytic Information for any and all purposes without notice or obligation to you, provided that the Analytic Information does not indicate your identity and cannot be used, alone or in conjunction with other information, to determine your identity. You will not have any rights arising from the creation, collection, or use of the Analytic Information.
SECTION 3 Personal Data use
MHC collects Personal Data for purposes related to managing and developing its businesses and operations, including (a) establishing, managing, and terminating business relations with you, (b) reviewing the products and services that MHC provides to you, (c) communicating and sending curated healthcare related information of interest to you, including newsletters, alerts, and notifications, (d) informing you of MHC’s products and services other than those that you have specifically requested, (e) tracking and analyzing trends and patterns related to MHC’s businesses and operations for market research related purposes, (f) providing you with the Platform, (g) creating aggregated information or Analytic Information that does not individually identify you, (h) complying with Applicable Law, (i) any other reasonable purpose to which you consent, (j) for other purposes which MHC will disclose to you before the time of collection, (k) to investigate security breaches or cooperate with government authorities pursuant to a legal matter, or (l) sending you transactional or informational emails such as customer service communications in connection with the products you have registered to use or changes to the Platform or policies.
SECTION 4 Personal Data and PHI disclosure
Personal Data and PHI may be disclosed to third parties if there is a change in ownership of all or a part of MHC through some form of merger, purchase, sale, lease, or amalgamation or other form of business combination, provided that the parties are bound by appropriate agreements or obligations which require them to use or disclose your Personal Data or PHI in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you indicate otherwise,
(a) that are third party service providers, affiliates, and business associates, including an organization or individual retained by MHC to perform functions on its behalf,
(b) where you have provided your consent for such disclosure or where disclosure is required or permitted by Applicable Law,
(c) to whom you directed us to share Personal Data or PHI. Once you direct us to share your Personal Data or PHI with a third party, such Personal Data or PHI is governed by the third-party’s privacy policy,
(d) where MHC is permitted or required by Applicable Law, even without your knowledge or consent,
(e) when MHC shares or sells aggregated, de-identified data that does not identify you with partners and the public. When MHC provide this information, it ensure that the data does not identify you and cannot be associated back to you, or
(f) in connection with the performance of certain technological or administrative functions, such as data management. Prior to making this disclosure, MHC will take appropriate steps to ensure that the third-party service providers safeguard the Personal Data and use the Personal Data only for authorized purposes set out in this Privacy Policy and in accordance with Applicable Law.
(g) no personal data related to an IRB Study will be released under this section, the terms of any Informed Consent document will apply.
SECTION 5 Consent to collect, use, and disclose Personal Data and PHI
(a) It is important to MHC that it collects, uses, or discloses your Personal Data and PHI only where MHC has your consent to do so or as provided in this Privacy Policy. Depending on the sensitivity of the Personal Data or PHI, your consent may be express, implied, or deemed (using an opt-out mechanism). Express consent can be given electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction (e.g., when you accept this Privacy Policy, MHC will assume your consent to the collection, use, and disclosure of your Personal Data for purposes related to your acceptance and use of the Platform, or for other purposes identified to you at the relevant time). Deemed consent is consent MHC assumes if you do not exercise an opt-out mechanism offered to you.
(b) By submitting your Personal Data and PHI to MHC or obtaining its services via the Platform or otherwise, you consent to the collection of and use of your Personal Data and PHI in the manner described in this Privacy Policy. To the extent that MHC is required by Applicable Law to obtain your explicit consent for the collection, use, or disclosure of your Personal Data or PHI in accordance with this Privacy Policy, such consent will be requested at the appropriate time. If MHC plans to use or disclose your Personal Data or PHI for a purpose not previously identified (either in this Privacy Policy or separately), MHC will endeavor to advise you of that purpose before such use or disclosure. MHC may collect, use, or disclose your Personal Data or PHI without your knowledge or consent where MHC is permitted or required to do so by Applicable Law.
(c) You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by emailing the email address specified in Section 10(c). In some circumstances, a change or withdrawal of consent may limit MHC’s ability to provide products or services to you.
(d) In the case of personal contact information provided in conjunction with any newsletter or other marketing initiatives, you may withdraw your consent to receiving those communications and unsubscribe from any MHC subscriptions at any time by emailing the email address specified in Section 10(c). In addition, commercial electronic communications sent by MHC to which you have subscribed will further contain an unsubscribe mechanism.
(e) You can stop all collection of data generated by use of the MHC Mobile App by uninstalling it. You may also be able to exercise specific privacy choices, such as enabling or disabling push notifications, by adjusting the permissions in your mobile device.
SECTION 6 Personal Data and PHI storage and retention
(a) MHC endeavors to safeguard Personal Data using methods that are appropriate to the sensitivity of the information, including using industry standard methods for managing risks to the security of information, protecting the confidentiality of all Personal Data and PHI when doing business internally or externally with other organizations, and protecting all Personal Data and PHI with appropriate and effective security safeguards, including physical, administrative, and technology safeguards, against such risks as loss or theft, unauthorized access, disclosure, copying, use, or destruction, regardless of the format in which it is held. MHC collects and stores your information on secure servers meeting the requirements of Applicable Law.
(b) MHC retains your Personal Data and PHI for up to 3 years after you cease to be an active Platform user. You will be considered an inactive user after 1 year with no activity on the Platform, starting from the date of your last access. Once the Personal Data or PHI is no longer required to fulfill the purpose for which it was collected and no longer required or permitted to be retained for legal or business purposes, it is securely destroyed or made anonymous pursuant to MHC’s data retention schedule.
SECTION 7 Accessing your Personal Data and PHI
(a) Any Personal Data or PHI you provide to MHC can be accessed and modified from your User Account. If you remove Personal Data or PHI from your User Account, it will no longer appear to you on the Platform. Backups of that Personal Data or PHI will remain in association with your User Account and in MHC’s archive servers until deleted in accordance with MHC’s data retention schedule.
(b) You may also ask to see the Personal Data and PHI that MHC holds about you. If you want to review, verify, or correct your Personal Data or PHI, please email the email address specified in Section 10(c).
(c) When making an access request, MHC may require specific information from you to confirm your identity and right to access, as well as to search for, and provide you with, the Personal Data and PHI that MHC holds about you. If you need help in preparing your request, please email the email address specified in Section 10(c).
(d) For any Personal Data or PHI shared with your consent, you may ask MHC to provide you with a copy of such Personal Data or PHI in a commonly used and machine-readable format. You may also request of MHC, if technically feasible, to send this information to other data processors.
MHC may not be able to provide you with access to your Personal Data or PHI in situations where such refusal is permitted or required by Applicable Law. MHC will inform you of the reasons why, subject to any legal or regulatory restrictions, access has been denied.
(e) You must keep us informed of changes to your Personal Data. You can correct any inaccuracies by accessing and modifying the information provided in your User Account. You acknowledge and agree that MHC will have no liability associated with or arising from your failure to maintain accurate contact or other information, including your failure to receive critical information about the Platform or your User Account.
(f) When your User Account is deactivated or terminated for any reason, your Personal Data and PHI will be removed from the User Account. Backup copies of your Personal Data and PHI will be removed from MHC’s servers based on MHC’s data retention schedule, which means it may persist in MHC’s archive for up to 3 years, during which MHC may continue to use your de-identified data.
SECTION 8 Security
MHC values your trust in providing us your Personal Data and PHI. We use industry standard security measures intended to help protect against the loss, misuse, unauthorized access, or alteration of information under our control both during transmission and once the information is received. But remember that no method of transmission over the internet or method of electronic storage is 100% secure and reliable and we cannot guarantee its absolute security. MHC puts the following safeguards in place to ensure security of your data:
(a) MHC does not sell, rent, disclose, or use your Personal Data or PHI without your authorization or unless permitted or required by law;
(b) Personal Data and PHI is secured through password protection and can only be accessed by authorized users.
(c) Personal Data and PHI is firewall-protected and under electronic surveillance 24 hours a day, 7 days a week.
(d) Personal Data and PHI is only temporarily stored on tablets or mobile devices accessing the Platform until submitted before such Personal Data or PHI is immediately deleted. All temporarily stored data is encrypted so that if a session ends unexpectedly, or if a tablet or mobile device is lost or stolen, no Personal Data or PHI can be accessed.
(e) Personal Data or PHI transmitted between the Platform and MHC’s data centers is protected using industry-standard TLS (256-bit AES keys).
(f) Personal Data and PHI is stored in a highly-secured data center, protected by multi-layer protocols. This means:
SECTION 9 Disclaimers
(a) MHC does not assume any responsibility for your use or misuse of Personal Data or PHI, or your healthcare providers’ or patients’ use or misuse of Personal Data or PHI, as applicable, whether intentional or inadvertent, while using the Platform. MHC may amend or delete any content (along with the right to revoke any access rights to the Platform) that MHC determines in its sole discretion violates this section.
(b) All users of the Platform, including healthcare providers, are independent persons and not partners, agents, or employees of MHC. You acknowledge and agree that MHC has no control over the quality, knowledge, legality, or actions of such users. All information found on the Platform and recommendations or instructions to use the Platform are to be followed at your own risk. MHC is not liable for the acts, errors, omissions, representations, warranties, conditions, breaches, or negligence of any user of the Platform, including healthcare providers, or for any personal injuries, death, property damage, or other resulting damages or expenses.
SECTION 10 Miscellaneous
(a) Contacting MHC. To change or withdraw your consent or make a complaint, or direct questions or concerns about this Privacy Policy, please email the email address specified in Section 10(c).
(b) Updates to this Privacy Policy. MHC may update this Privacy Policy from time to time. Use of Personal Data or PHI MHC collects now is subject to this Privacy Policy in effect at the time such Personal Data or PHI is used. If MHC makes changes in the way it uses Personal Data or PHI, it will notify you by emailing the address in your User Account, or posting to the Platform. You are bound by any changes to this Privacy Policy when you use the Platform after you have been notified or such changes have been first posted.
(c) Notices. Notice from MHC to you will be given by email to the email address specified in your User Account. You acknowledge and agree that MHC will have no liability associated with or arising from your failure to maintain accurate contact or other information on your User Account, including your failure to receive critical information about this Privacy Policy or the Platform. Notice from you to MHC may be given by email to info@managedhealthconnections.com, or physical mail at Managed Health Connections, LLC, 203 N Washington St., Suite 302, Spokane, WA 99201.
Privacy Notice for California Residents
Definitions
Website
Managed Health Connections, LLC or http://managedhealthconnections.com/mesmerize
Owner (or We)
Indicates the natural person(s) or legal entity that provides this Website to Users.
User (or You)
Indicates any natural person or legal entity using this Website.
This Privacy Notice for California Residents supplements the information contained in the Website’s Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopted this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this notice.
Information We Collect
The Website collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”).
In particular, the Website has collected the following categories of personal information from its consumers within the last 12 months:
| Category | Examples | Collected |
| A. Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)). | A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. | YES |
| C. Protected classification characteristics under California or federal law. | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information. | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | YES |
| E. Biometric information. | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | YES |
| F. Internet or other similar network activity. | Browsing history, search history, information on a consumer’s interaction with a Website, application, or advertisement. | YES |
| G. Geolocation data. | Physical location or movements. | YES |
| H. Sensory data. | Audio, electronic, visual, thermal, olfactory, or similar information. | YES |
| I. Professional or employment-related information. | Current or past job history or performance evaluations. | YES |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)). | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | YES |
| K. Inferences drawn from other personal information. | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
Personal information does not include:
We obtain the categories of personal information listed above from the following categories of sources:
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the following business purposes:
We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
Sharing Personal Information
We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by either:
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Personal Information Sales
We will not sell your personal information to any party. If in the future, we anticipate selling your personal information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to info@managedhealthconnections.com.
Changes to Our Privacy Notice
We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on our Website and update the notice’s effective date. Your continued use of our Website following the posting of changes constitutes your acceptance of such changes.
Contact Information
If you have any questions or comments about this notice, the ways in which we collect and use your information described below and in our Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:
© 2025 Managed Health Connections, Inc. | Privacy Policy