Privacy Policy

Last Updated: July 24, 2023

Background about Crescendo Health

Our mission at Crescendo Health is to accelerate medical innovation. Our technology provides an easy way for individuals to access and share their health information to support participation in an Institutional Review Board approved research study.  

Crescendo Health, Inc. (“Crescendo Health” or “we” or “our”) is committed to maintaining the security and privacy of the information of our users. Crescendo Health offers a platform and services to give patients access to their electronic health information and to enable medical researchers to understand the real world health of research participants. This Privacy Policy describes Crescendo Health’s information collection practices in connection with use by individual users on our platform, software we offer through our website, mobile applications, and web-based tools (collectively, our “Services”). Crescendo Health collects and uses information while our users (“you”) use our Services. This Privacy Policy covers information collected from individuals who have completed the Informed Consent Form for an applicable study. 

Use of our Services does not provide or replace the consultation, guidance, or care of a healthcare professional or other qualified provider. Our Services can provide information for informational and educational purposes only. Health care professionals and other qualified providers should continue to consult authoritative records when making clinical decisions.

Consent of use of Personal Information

You consent to the collection, use, storage, and disclosure of personally identifiable information as outlined in this Privacy Policy.

The information we collect from users

The information Crescendo Health collects from you depends on your activities and use of our Services. We comply with all local, state and federal privacy laws regulating the transmission, processing and storing of health information, including the Health Insurance Portability and Accountability Act of 1996, as amended from time to time, together with the regulations adopted thereunder (“HIPAA”). References in this Privacy Policy to “data” applies to all types of data, including de-identified, anonymized or pseudonymized data. Together, we refer to Personal Information and Health Information as “Your Information.”

Information you provide to us or provide us with permission to access and collect:
  • Profile, Account, and Other Identifying Information: When you register and use the Services, we may collect information about you such as your name, email address, phone number, address, social security number, photo identification, health insurance card, and similar information by which you may be personally identified (“Personal Information”). We may collect this information directly from you or from another user (such as a study administrator or other authorized person).
  • Health Information: You may also provide us with health information or authorize us to obtain your health information from third parties. This may include: Information about your health care providers and health care insurance coverage; Health information that might be included in electronic health or medical records (including medications) or insurance claims and encounter data, if you elect to have that information shared with us.
  • Account Connections: When you authorize us to access your healthcare accounts in connection with using our Services, where applicable, we may collect and use identifiers and login information required by the providers of your healthcare accounts, such as your username and password, a security token, or security questions and answers, to help verify your identity when connecting your accounts. Solely in connection with using our Services, you authorize us to act on your behalf to access and utilize such identifiers and login information for your healthcare accounts for the period in which you use our Services.  As noted in the ‘How we secure your information’ section below, Crescendo prioritizes the security and privacy of your information and safeguards that it may be used solely in connection with our Services.

Information we automatically collect from your use of our website
  • Crescendo Health and our third-party partners (such as analytics service providers) may automatically receive and record certain non-Personal Information from you using web logs when you interact with our website (such as your IP address, browser type, internet service provider, operating system, URLs, date/time stamps, and system configuration information). We also collect and store analytics (e.g., usage) information to help us improve our Services.
  • Crescendo Health uses various technologies to collect information about your use of our website, including cookies and other tracking mechanisms. We gather this information to allow you to access and use the website more easily and to improve our services to you more generally. For example, we use these tools to save user preferences, preserve session settings and activity, help authenticate users, allow users to auto-fill pages of websites they frequently visit, and debug and evaluate the performance of our website. 

Information we collect from third party sources
  • We may obtain information about you from health insurance companies, medical providers, and other sources you authorize and add it to information we otherwise have about you
  • We may use third party vendors or APIs to facilitate the collection of data. When we work with third party vendors or APIs, we require that they have appropriate policies and measures to safeguard the confidentiality and integrity of Your Information
  • We will specifically ask for your permission to get Your Information from a third party. You are responsible for determining uses and disclosures of your personal health information and the potential impact such uses and disclosures might have on your family members when it involves data regarding genetic and family health histories
  • We may use analytics providers to analyze how you interact and engage with our Services

 

How we use that information

We may use the information we collect for a variety of purposes, including to:

  • Provide, operate, maintain, improve, promote, and personalize our Services to you;
  • Send important information including technical notices, security alerts, changes in our terms and policies, or administrative information. 
  • Provide you with technical support for our services and respond to your inquiries
  • Investigate and prevent fraudulent transactions, unauthorized access to our Services, and other illegal activities;
  • For business purposes, such as data collection and analysis, developing new products, services, features, and functionality; and
  • Monitor and analyze trends, usage, and activities in connection with our Services to better understand how users access and use our Services and platform, both on an aggregated and individualized basis, in order to improve our Services, platform and our services to our customers, and for other research and analytical purposes. We may combine and compile Your Information with other individuals’ information for the purpose of analysis.

When we share information

We will not disclose any of the personally identifiable information that we collect about you, except when we have your permission or in the situations described below. We may share Your Information in the following ways:

  • With your consent: We will share Your Information with researchers, consulting independent clinicians, or other organizations outside of Crescendo Health when we have your prior proper consent to do so, except as otherwise specified herein.
  • Vendors and other third parties: We may share Your Information with third party vendors, service providers, contractors or agents who perform function or services on our behalf and require access to such information to do that work and perform our business. Examples include data analysis, hosting services, and user support functions. Such third-party service providers will only have access to Your Information as necessary to perform their functions and pursuant to agreements they enter into with us that require them to fully comply with our data protection policies and this Privacy Policy.
  • Compliance with laws and protection of our rights: We may use and disclose Your Information to a third party if: (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; (ii) to enforce our agreements, policies and terms of service; (iii) to protect our operations and the security or integrity of Crescendo Health’s products and services; (iv) to protect the property, rights, and safety of Crescendo Health, you, our customers or the public from harm or illegal activities; or (v) to investigate and defend ourselves against any third-party claims or allegations and to allow us to pursue available remedies or limit the damages that we may sustain.
  • Sale of the Business: We may share or transfer Your Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. In the event of such an event, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
  • For the avoidance of doubt, except as described above, we will not sell, license, or share your data in either identified or aggregated de-identified forms with or to third parties.

How we secure your information

Maintaining the privacy and security of Your Information is important to us. We apply reasonable and appropriate measures to safeguard the confidentiality, integrity, and availability of Your Information we store and process on behalf of you. Crescendo Health has implemented safeguards to prevent unlawful use or disclosure of information. These include administrative, physical, and technical security safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of information we receive, maintain, or transmit. Nevertheless, while security of information is of high importance to us, no data transmission (over the internet or any wireless network) or method of electronic storage can be guaranteed to be completely secure. In the event of a security breach, we will notify affected individuals, regulatory authorities, and others consistent with requirements under federal and state law or contractual obligations.

 

Information retention

Your information will be retained for the period of time defined by any study in which you consented to participate and for as long as you continue to use our Services. Where relevant, for additional information, review the section of your study’s Informed Consent Form on how long your data will be stored. 

Crescendo Health’s collection, use, and disclosure of information are generally governed by this Privacy Policy and by law. Information maintained to provide our Services to our customers is retained only for as long as we have a valid business purpose and in accordance with applicable law. Crescendo Health may retain Your Information as necessary to comply with legal obligations, resolve disputes and enforce our agreements and other authorized uses under this Privacy Policy. 

Your choices and access

If you prefer that your personal information no longer be collected, you can withdraw from the study you are participating in. For additional information, refer to the Informed Consent Form for the study.

If you withdraw from the study, we will not collect any new information within 24 hours of withdrawal.  We will furthermore delete your information stored on your behalf. However, information already requested, collected, processed, stored, and shared with the study up to the time your withdrawal request is received will not be deleted, and may continue to be used for study purposes. Furthermore, your Personal Information may persist in Backup Files for up to a year and in our Audit Files for longer periods of time consistent with federal and state laws as well as private organization guidelines that pertain to analogous categories of data and information. 

If you have any questions or concerns about your personal information or study participation, please contact support listed in the “Contacting Us” section below.

 

Access and changes to your information

You may modify Your Information that you have submitted by logging into your account and updating your profile information. You may discontinue use of the Services and Crescendo Health’s use of Your Information by contacting consent@crescendohealth.co.  In the event you withdraw consent for use of Your Information, Crescendo Health will not collect any new information within 24 hours of withdrawal.  We will furthermore delete the information stored on your behalf. However, where applicable as referenced in your Informed Consent Form, information already requested, collected, processed, stored, and shared with a research study up to the time your withdrawal request is received will not be deleted, and may continue to be used for study purposes. Furthermore, your Personal Information may remain in Backup Files for up to a year and in our audit files for longer periods of time consistent with federal and state laws as well as private organization guidelines that pertain to analogous categories of data and information. 

Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the site or application for a period of time. You may also contact us directly if you would like to review, correct, amend, delete or otherwise limit our use of Your Information that has been previously provided to us by contacting us at consent@crescendohealth.co. Although we will use reasonable efforts to do so, it may not be technologically possible to remove from our systems every record of Your Information. The need to back up our systems to protect information from inadvertent loss means a copy of Your Information may exist in a non-erasable form that will be difficult or impossible for us to locate or remove.

If you have used our Services to share information with another user or a third party, you will not be able to access, update, or delete that shared information. You will need to contact that other user or third party directly. Further, if another user of our website or services submits information that identifies you, you will not be able to access, update, or delete that information.

Certain users - such as health care providers - may be required under applicable laws or regulations to retain information about you for extended periods of time, even indefinitely. Additionally, we may have independent obligations under applicable laws or regulations to retain such information indefinitely. We also retain copies of data stored by our website for indefinite periods of time for disaster recovery and business continuity purposes.

Children’s privacy

Crescendo Health’s website, application, and Services are not intended for use by individuals under the age of 16. By using our services, you warrant that you are 16 years of age or older.

International users

Our website is hosted in the United States and our website and services are intended for users located within the United States. No one located outside of the United States should access our website, use our services, or provide us with individually identifiable information.

U.S. State Data Protection Regulations

We regularly evaluate and update practices based on state data protection regulations. California Civil Code Section 1798.83-1798.84 permits users of our website who 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 contact us at consent@crescendohealth.co

Third party websites

We are not responsible for the practices employed by websites linked to or from our website nor the information or content contained therein. Please remember that when you use a link to go from our website to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which have a link on our website, are subject to that website’s own rules and policies. The availability of, or inclusion of a link to, any such site or property does not imply endorsement of it by us or by our affiliates. 

Acceptance and Updates to this Privacy Policy

We may change this Privacy Policy. By using our website, you signify your acceptance of this Privacy Policy. If you do not agree to the terms of this Privacy Policy, please do not use our website or our services. We may update this Privacy Policy by posting changes on this website or otherwise notify you directly. Any Privacy Policy changes will be effective for all information that we maintain, even information in existence before the change. Your use of our website following any changes to the Privacy Policy signifies your acceptance of those changes.

Contacting Us

If you have any questions about the Privacy Policy or Crescendo Health, please email us at consent@crescendohealth.co or by mail at 18 Bartol Street #980, San Francisco, CA 94133