INTRODUCTION

Gemini Health, LLC¹ respects the privacy of every person who receives our services. Therefore, Gemini Health has developed this Privacy Policy in accordance with industry standards and state and federal laws and requirements.

Our Policy explains what information Gemini Health collects and how we use that information. It also outlines how you can verify the accuracy of this information, and how you can request that we delete, change or update your information. We want to assure you that Gemini Health has a strong commitment to protect your information and that we are always held to the highest standards to safeguard that data. Thanks for allowing us the opportunity to serve you.

WHO WE ARE

Gemini Health is the leader in Drug-Cost Decision Support Services. We provide drug cost transparency, based on patient-specific benefit information, as well as therapeutically-equivalent, lower-cost drug alternatives to help provide lower drug cost choices for patients, provider groups, and payers.

We are based in the United States, with offices, employees, and operations across the country. Contact information for our Corporate Office is listed below. The services that Gemini Health provides are provided as a Business Associate of companies that are mainly considered Covered Entities. In some instances, Gemini Health may redirect any inquiries about individual data to that Covered Entity.

INFORMATION WE COLLECT

Our primary goal in collecting personal data is to provide decision support to prescribers by sharing the present cost of chosen or existing medications and at the point of prescribing, providing lower-cost, therapeutically-equivalent drug alternatives, based on patient-specific benefits.

Personal Data

To determine patient costs of chosen or existing drugs and to find lower-cost, therapeutically-equivalent drug alternatives, Gemini Health uses patient identifiers that include:

Name (last, first)
Date of birth
Address
Telephone numbers
Prescribing Provider
Preferred Pharmacy
Prescription medication history
Medical benefit IDs
Pharmacy benefits IDs
Medical record IDs
Pharmacy Benefit Manager IDs

Patients may opt out of providing any or all of this data at any point-in-time, however, they will be unable to receive the benefits of our services.

HOW WE USE PATIENT INFORMATION

Personal Data

We use personal data about our clients’ patients to deliver decision-support services to prescribers in an effort to lower drug costs for patients, for provider groups, and for payers.

Aggregate and Statistical Data

Gemini Health may use patient data in an aggregated and in a de-identified² manner for marketing our services to clients.

LEGAL BASIS OF PROCESSING

We collect and process personal data where we have a business need and follow all lawful state and national requirements.

In a majority of the cases, processing personal information is based on:

Consent

Collecting and processing patient data for clients with whom the patient has provided their consent

Contractual obligations

We collect only the minimum information needed to conduct contracted obligations to our clients.

Legal compliance

In certain circumstances we may be required by law to share personal information with legal authorities. In such cases the patient will be notified.

Legitimate interest

In some situations, we may require patient data to pursue our legitimate interests in a way that might reasonably be expected as part of conducting our business that does not materially impact patient rights, freedom or interests and is in accordance with state and federal laws.

HOW WE PROTECT PATIENT INFORMATION

Gemini Health is committed to keeping the data clients provide us secure and will take all reasonable and required precautions to protect patient personal data from loss, misuse or alteration.

Vendors, contractors, and business associates of Gemini Health who have access to patient personal data are bound by the same standards as Gemini Health’s and in accordance with federal and state laws.

HOW LONG WILL WE RETAIN PATIENT PERSONAL DATA?

Gemini Health will only keep patient information as long as necessary to complete the purpose for which it was collected or as long as required by federal or state laws.

At the end of that retention period, patient data will either be destroyed or rendered unrecognizable as required by federal or state laws.

HOW WE MAY SHARE PATIENT DATA

Gemini Health will not share, trade or sell personal data of patients for use by any business, except for the purposes stated herein. However, aggregated and statistical patient data may be shared with our partners in a manner that does not identify patients personally.

We may share personal data with service providers or contractors that perform services for us and act at our direction. The services they provide may include such activities as direct mailing, fulfillment services, or e-mail campaigns. Only when a patient has agreed to receive such services, we also may share personal data with our business partners that provide joint offerings with us. When we do so, such business partners are restricted in using patient data to provide only the services patients have agreed to.

Gemini Health may share patient personal data with any person or company that acquires Gemini Health’s business or any portion of the Gemini Health business to which patient personal data relates. Gemini Health will ensure that any person or company to which patient personal data is transferred agrees to abide by the same privacy obligations as Gemini Health.

Gemini Health also reserves the right to share personal data to respond to duly authorized information requests of governmental authorities or where required by Federal or State law. We may also share personal data in responding to requests from law enforcement officials, government bodies or judicial authorities to address matters of personal or public safety, national security, litigation, investigations (including data security incident investigations), and other legal matters where the data is pertinent.

CROSS-BORDER DATA TRANSFERS

Gemini Health has developed global data privacy and security practices designed to ensure that patient personal data is appropriately handled and protected. Please note that personal data may be transferred, accessed and stored globally as necessary for the uses and disclosures stated above in accordance with this policy, and any Federal, State or International laws.

WHAT ARE PATIENTS RIGHT OVER PERSONAL DATA?

Patients have a right to change patient data and a right to change data use privileges given to any provider of services.

For further information around these rights, please consult Health Information Privacy at:

https://www.hhs.gov/hipaa/for-individuals/guidance-materials-for-consumers/index.html

You can send Gemini Health a request to exercise these rights to access, correct, or remove patient personal data by contacting us at any time at PrivacyOfficer@Gemini.Health. If you send us a written request to access, correct, or remove patient personal data or to remove you from a database, we will respond to these requests within 30 days.

CONTACT INFORMATION

Patient privacy is very important to Gemini Health.

If you have any questions that we have not answered in this policy, please contact our Privacy Officer who will be pleased to help you:

• Email us at PrivacyOfficer@Gemini.Health
• Or write to us at:

Gemini Health
Attn: Privacy Officer
2 Alexander Ave.
Sausalito, CA 94965

UPDATES

We may update this Privacy Policy from time to time. When we update this Privacy Policy, we will post the changes on our website and applications. We encourage you to check this Privacy Policy regularly for changes.

Unless otherwise noted, any changes we make to this Privacy Policy will become effective immediately once posted.

Please note the effective date indicated below for the latest revision. Continued use of the Services following any changes to this Privacy Policy indicates consent to the practices described in the revised Privacy Policy.

Date of Last Update: 15-May-2019

¹ Refers to Gemini Health, LLC heretofore Gemini Health or Gemini

² De-identification is the process used to prevent a person’s identity from being connected with information. For example, data produced during human subject research might be de-identified to preserve research participants’ privacy.

Version 1.0
EFFECTIVE DATE: June 1, 2016

This Privacy Policy outlines how Gemini Health, LLC and its affiliated entities (“Gemini Health“, “we“, “us” or “our“) collects, uses and secures information from individuals and businesses in connection with Gemini Health’s Website. It describes how Gemini Health handles information collected via our websites including  http://www.geminihealth.net and any other websites Gemini may host now or in the future that link to Gemini Health Websites.

Visiting the Gemini Health Website indicates your acceptance of this Privacy Policy.

SITE OWNERSHIP, SCOPE, APPLICABILITY OF THIS PRIVACY POLICY

This Privacy Policy applies when anyone is within the Gemini Health-branded environment and only to information that Gemini Health collects. The Gemini Health Website may provide direct links to various sponsors, marketing partners and other third party websites.

This Privacy Policy does not describe the practices or privacy policies of these third parties or third party sites.

Before disclosing information to any third party, please read the privacy policy associated with that website, as Gemini Health takes no responsibility for information submitted to, or collected by any third parties.

None of our sites or services are directed at minors, and to our knowledge we do not collect any information about minors.

INFORMATION THAT WE COLLECT

Information Requests

To request more information about Gemini Health please provide contact information including your Full Name, Company Name, Phone Number and E-mail address.

Gemini Health will contact you with the information requested.

Communications

Certain communications are recorded and maintained by Gemini Health.

Gemini Health considers these communications to be personal and private and will not use or disclose any information within these communications except as provided for in this Privacy Statement, where required by law, or unless agreed to in writing by both parties involved.

Log Files

As is true of most websites, Gemini Health automatically collects and stores in log files the Internet Protocol (IP) address of the computer accessing the site; the name of the domain and host from which the Internet is being accessed; the browser software being used and the operating system; the date and time the service was accessed; and the Internet address of the Web site from which was directly linked to Gemini Health.

HOW WE USE INFORMATION COLLECTED

In general, we use information collected to respond to your requests for information.

OPTING-OUT OF COMMUNICATIONS

Gemini Health will always respect client’s preferences about receiving communications.

End users of the Gemini Health Web Sites may change communication preferences at any time by:

(1) opting-out of e-mails, or specific types of e-mails, by using the “unsubscribe” feature on any e-mail communication from Gemini Health
(2) contacting us using the “Contact Us” section of our website and requesting to “opt-out” of specific communications

(3) contacting us using the “Contact Us” section of our website and requesting that your information not be shared with any affiliates or Third Parties

ACCESSING AND UPDATING INFORMATION

Personal Information may be updated by using the “Contact Us” section of the website. Please provide as much detail as possible about the information to be changed.

COOKIES AND WEBSITE INFORMATION

Gemini may use forms of technology to track visitors to our site. Please contact us if you require any additional information about how we do this.

GEMINI HEALTH MAY DISCLOSE INFORMATION TO COMPLY WITH CERTAIN LEGAL REQUIREMENTS

Gemini Health may need to disclose certain information collected for legal reasons, or to comply with a law, regulation, court order, subpoena, or search warrant…

(i) in response to a law enforcement agency request or a regulatory or client audit

(ii) when we believe it is necessary to protect and/or enforce rights, property or safety interests

(iii) when we deem it necessary to resolve disputes, troubleshoot problems, prevent fraud and otherwise enforce our Privacy Policy

If there is a change of control in Gemini Health’s business (whether by merger, sale, or otherwise) or a sale or transfer of its assets, any information collected may be transferred as part of that transaction but any such use remains subject to this Privacy Policy unless and until it is changed in writing.

Gemini Health is located in the U.S. and will process and store information in the U.S., and is subject to state and federal government regulations.

CHANGES TO THIS PRIVACY POLICY

All changes to this Privacy Policy, will be posted to our Website with the date the changes will become effective. Gemini Health encourages visitors to periodically review our Privacy Policy for the latest information on our privacy practices.

HOW TO CONTACT US WITH ANY QUESTIONS OR FEEDBACK

If there are have any questions about this Privacy Policy or interactions with Gemini Health, or if there are any comments, please contact us using the “Contact Us” section of this website.

LEGAL DISCLAIMER; GOVERNING LAW

While Gemini Health takes every reasonable effort to protect information as described throughout this Privacy Policy, we cannot ensure or warrant our ability to control errors in transmission or unauthorized acts of parties outside of our control.

Use of Gemini Health Websites is at your own risk.

Gemini Health disclaims any liability for disclosures of information due to errors in transmission or unauthorized acts of third parties.

This Privacy Policy, and any transactions or disputes to which it applies, will be governed by the laws of California without regard to any conflicts of laws.

PATIENT PROTECTION AND AFFORDABLE CARE ACT COMPLIANCE COVERAGE