Notice of Privacy Practices

Your Information. Your Rights. Our Responsibilities.
This notice describes how medical (health and wellness) information about you or your child may be used and disclosed and how you can get access to this information. Please review it carefully.

If you have any questions about this notice or want information about exercising any of your rights, you may contact our Healthcare Compliance and Privacy Officer at privacy@kurbo.com. Throughout this notice, “you” refers to you and/or your child.

Your Rights & Choices
When it comes to the health and fitness information that we collect about you, you have certain rights. This section explains your rights and some of our responsibilities to help you.

Get an electronic or paper copy of your information

  • You can ask to get a copy of your information. Ask us how to do this.
  • We will provide a copy or a summary of your information, usually within 30 days of your request. We may charge a reasonable, cost-based fee.

Ask us to correct your information

  • You can ask us to correct information about you that you think is incorrect or incomplete. Ask us how to do this.
  • We may say “no” to your request, but we’ll tell you why in writing within 60 days.

Request confidential communications

  • You can ask us to contact you in a specific way (for example, home or office phone) or to send mail or electronic communications to a different address.
  • We will say “yes” to all reasonable requests.

Ask us to limit what we use or share

  • You can ask us not to use or share certain information. While we will try to honor all reasonable requests, we may say “no,” particularly if it would impact our ability to provide our services to you.
  • We are required to honor such requests for restrictions only when you or someone on your behalf, other than your health plan, pays service(s) in full. Such requests must be made in writing and signed by you.

Get a list of those with whom we’ve shared information

  • You can ask for a list (accounting) of the times we’ve shared your information for six years prior to the date you ask, with whom we shared it, and why.
  • We will include all the disclosures except for certain disclosures relating to the provision of our services, such as those made within the Kurbo program itself; payment for these services (for example, with a credit card company); and other operations. We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months.

Get a copy of this privacy notice

  • You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly.

Choose someone to act for you

  • If you designate someone or if someone is your legal guardian, that person can exercise your rights and make choices about your information.
  • We will make sure the person has this authority and can act for you before we follow that person’s instruction.

File a complaint if you feel your privacy rights are violated

  • You can complain if you feel we have violated your privacy rights by contacting us using the information above.
  • You can also file a complaint with the U.S. Department of Health and Human Services, Office for Civil Rights.
  • We will not retaliate against you for filing a complaint.

Tell us your choices about what we share

  • Unless you give us written permission:
    • We never share your information with third parties for their own marketing purposes
    • We never sell your information to third parties

Our Uses & Disclosures
How do we typically use or share your information? We typically use or share your information in the following ways.
Provide you services

  • We can use and share your information to provide you with quality service and coordinate your participation in the Kurbo program.
    • Example: We use your information to provide you with communications appropriate to you and to assist with your weight management.
    • Example: Coaches may share your information between themselves if you participate in different Kurbo offerings.

Run our organization

  • We can use and share your information to run our organization, improve our service, and contact you when necessary.
    • Example: We use information about you to manage your treatment and services, and to monitor and improve the quality and effectiveness of our programs
    • Example: We may allow our customer service provider to view your information in order to assist you.
    • Example: We may use your information to further our understanding of weight management.

Bill for your services

  • If applicable, we can use and share certain types of your information as needed to bill and receive payment from employers, health plans or other entities paying for your participation in full or in part.
    • Example: We may give information to your employer or group health plan so it will pay for all or part of our services.
    • Example: We may also disclose your information to additional vendors who provide services to your health plan to help you receive additional benefits.

Reminders and related benefits and services

  • We may use and share your information with service providers to contact you with important information.
    • Example: We may contact you to let you know about a change to a check in time.
    • Example: If you have opted in to receive communications from us, we may contact you about other Kurbo services or products that may be of interest to you.

Certain aspects of our services and offerings may be provided through other organizations. We disclose information to these service providers only as necessary to provide our services or with your authorization. We’ll require them to protect the privacy and security of your information.

How else can we use or share your information?
We are allowed or required to share your information in other ways – usually in ways that contribute to the public good, such as public health and research. We have to meet many conditions in the law before we can share your information for these purposes. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/index.html. Please note that we do not share personal information we collect from children under 13 for these purposes unless we have obtained consent from a parent or legal guardian or unless such disclosure is required by law or legal process.

Help with public health and safety issues

  • We can share information about you for certain situations such as:
    • Preventing disease
    • Helping with product recalls
    • Reporting adverse reactions to medications
    • Reporting suspected abuse, neglect, or domestic violence
    • Preventing or reducing a serious threat to anyone’s health or safety

Do research

  • We can use or share your information for certain health research if we follow certain requirements.

Comply with the law

  • We will share information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law.
    Address workers’ compensation, law enforcement, and other government requests
  • We can use or share information about you:
    • For workers’ compensation claims
    • For law enforcement purposes or with a law enforcement official
    • With health oversight agencies for activities authorized by law

Respond to lawsuits and legal actions

  • We can share health information about you in response to a court or administrative order, or in response to a subpoena.

Our Responsibilities

  • We are required by law and/or our own policies to maintain the privacy and security of your protected health and fitness information.
  • As required by law, we will let you know promptly if a breach occurs that may have compromised the privacy or security of certain protected information.
  • We must follow the duties and privacy practices described in this notice and give you a copy of it.
  • We will not use or share your information other than as described here unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind using the contact information above under the section titled “Your Information. Your Rights. Our Responsibilities.”

For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html

Changes to the Terms of this Notice
We can change the terms of this notice, and the changes will apply to all medical (health and wellness) information we have about you. If we make a material change to our privacy practices, the new notice will be available on our website.

Effective as of November 2, 2021