1 February 2021
Hint Inc., doing business as Opul (“us,” “we,” or “Opul”), is committed to respecting your privacy. This Privacy Policy applies to all Opul online or digital services activities, including, www.opul.com (the “site” or “website”), our other websites, mobile applications (“Apps”) and digital services in which this Privacy Policy is posted or linked (each a “Service,” and together the “Services”).
Our Services are provided only in the United States for use by Physicians and U.S. residents that are Patients of those Physicians or more minimally by Visitors. There are three kinds of users of our Services:
As a Physician or an employee or agent of a Physician, you create and are in control of the data and information stored in our Services. This Privacy Policy, along with the services agreements entered into by you and your practice, describes how we treat and can use the data and information we collect when you use or access our Services.
We are a service provider to your Physician, and your Physician is providing our services to you as a benefit of your relationship with that Physician. The records, data and information that are stored by our Services are usually controlled by your Physician and may be subject to HIPAA (described below).
The notices you have received from your Physician and any agreements you have entered into for use of these Services, describes how we treat and can use the data, records and other information about you that may be placed into your account by your Physician. It also describes the data we collect when you access our Services to check on or use your account, and how we treat and can use that data. This Privacy Policy also describes some of those uses and disclosures.
As a Visitor, you do not have an account and Opul does not have any directly identifiable personal information about you, unless you have voluntarily provided it through certain functions that may be offered from time to time on this site, for example if we provide a “contact us” function and you provide us your email address. However, we may collect other Personal Information about you as set forth below. This Privacy Policy describes the data, including Personal Information, we collect when you use this Site and/or access our other Services, and how we treat and can use that data.
Opul provides Services only within the United States of America to residents of the United States. When you use our Services, the information you enter will be sent to and stored in our servers in the United States.
If you are visiting our websites or accessing the Services you previously registered for from anywhere outside of the United States, including any part of the European Union, please note that you are expressly agreeing and consenting that your information will be transferred to, processed in and stored in the United States, where we will always treat it as described in this Privacy Policy.
If you are a Patient, our Services are being used by your Physician to store and process information that may include health information that can identify you (known as “Protected Health Information”). The Protected Health Information that we may store, use and disclose depends on what your Physician provides or what you provide as a Patient of your Physician and generally falls into one of these categories:
The use and disclosure of your Protected Health Information is governed by the notices provided to you by your Physician and any agreements you may have signed related to the Opul platform and the agreements we have signed with your Physician. This Privacy Policy describes some of those uses and disclosures. It is also possible that your Protected Health Information may be governed by a federal health privacy law called the Health Insurance Portability and Accountability Act (“HIPAA”), which provides you certain rights with respect to your Protected Health Information – all of which can be explained by your Physician.
If you are a Physician or a Visitor, we are not collecting Protected Health Information about you unless you are also a Patient with an account on the Opul Platform, in which case we would collect such information only in your capacity as a Patient.
Through our websites and mobile apps and our other Services, we also collect and store data that we use to provide and improve the functionality of our websites and mobile apps and provide the Services as well as to improve those Services. This section will give you more information about the kinds of information we collect, but the specific information we collect will depend on the type of user you are, and whether you are using our app or visiting our website.
Our goal in using and sharing information is to create better services for visitors, and for Patients and your Physician. Here is how we use and share, or not share, the different kinds of information we collect.
We will disclose your Personal Information as stated in this Privacy Policy — including to our service providers under appropriate contractual obligations to assist us in providing the Services. As discussed above, we use a service provider — a third-party payment processor — to process your payments that you may make on the Opul platform. We, and you, provide the payment processor with personal information for that purpose and subject to the payment processor’s privacy policy. We will also disclose and share your Personal Information as necessary to provide you with our Services or as we believe may be necessary to comply with the law.
If you are a Physician, you have the ability to access, modify, delete and/or add to the data you provide us, including Patient information.
If you are a Patient and would like to review or request changes to the information that we collect about you, please contact us at opulsupport@revance.com. Because your account may be a business record for your Physician, our ability to make changes to or delete account information may be limited by applicable law, including HIPAA, or as agreed to between you and your Physician.
The Services have security measures in place to prevent the loss, misuse, and alteration of the information that we obtain from you, but we make no assurances about our ability to prevent any such loss or misuse to you or to any third party.
Opul will retain Personal Information that you or a Physician input into our Services or Personal Information generated by the Opal platform or in certain circumstances by our other Services (i) for a minimum of seven years following the date it is entered or created; (ii) for such longer minimum time period as may be required by law for specific types of information; or (iii) as may be set forth in services agreements between us and/or your Physician or any specific agreements between you and us (the “Retention Period”). Opul may delete data after the Retention Period, but it is not obligated to do so. Subject to applicable law, Opul also may retain data for longer than the Retention Period, but it is not obligated to do so.
Our Services are used by you and your Physician. We do not input, electronically limit or control the input of any data by your Physician.
We understand and are committed to respecting the sensitive nature of children’s privacy online. We provide our Services for use by adults 17 years old and older and do not direct any of our content or Services specifically at persons under 17 years of age. Accounts for Patients under 17 years of age may only be accessed and used by the Patient’s legal guardian. If we learn or have reason to suspect that a Services user is under age 13, we will block that person’s access to the account until it can be verified that the user is over 13. If we learn or have reason to suspect that a Services user is under age 17, we may exercise our right to terminate the account.
If you have any questions about this Privacy Policy, our practices related to this Services, or to exercise any rights you believe you may have with respect to your personal information, please feel free to contact us at hello@OPUL.com.
Opul reserves the right to make changes to this Privacy Policy. If we make any material changes to this Privacy Policy, we will notify you in advance through the Services. If we decide to use Personal Information in a manner that is materially different from the uses described in this Privacy Statement or otherwise disclosed to you, you will have the choice to allow or disallow any additional uses or disclosures of your Personal Information. We will not make retroactive changes that reduce your privacy rights unless we are legally required to do so. Your continued use of the Services after the Effective Date constitutes your acceptance of the amended Privacy Policy. The Privacy Policy posted here supersedes all versions published or posted prior to the Effective Date of this Privacy Policy.