Privacy Policy for EliseAI for Healthcare 

Last Updated date: May 11, 2023 

Elise A.I. Technologies Corp., d/b/a “MeetElise” and “EliseAI” and our affiliates and subsidiaries (“we,” “us,” “ours” or “EliseAI”) provides healthcare professionals (each, a “Provider”) with artificial intelligence assistant services, including bots (“HC Services”). Providers communicate with patients, prospective patients and other individuals through our HC Services, including by email, phone, text message, and webchat. We record these communications and use them for the purposes stated in this Privacy Policy, including to provide and improve the HC Services.  

This privacy policy (“Privacy Policy”) explains how we collect, process, store and share personal information in connection with the HC Services. Please note that this Privacy Policy does not apply to our collection and use of personal information in connection with any of our other services, which are subject to separate privacy policies. This Privacy Policy also provides you with important information about your personal information rights and how to exercise them. 

By using, interacting with or accessing our HC Services, or by providing your personal information to us:

  • You acknowledge that you accept our privacy practices and policies outlined below;
  • You consent to us collecting, processing, storing and sharing your information as described in this Privacy Policy; 
  • You acknowledge that you are communicating with bots when you use the HC Services; and
  • You consent to us recording all of your communications made through the HC Services – including by email, phone, text message and webchat. 
  1. Notice at Collection of Personal Information 

Definition of Personal Information

We collect, process, store and share information that identifies, relates to, or could reasonably be linked, directly or indirectly, with a particular individual or household (“personal information”). Personal information does not include information publicly available from government records, or which is not personal, like anonymous, deidentified or aggregated data (even if it originally comes from personal information).

Categories of Personal Information We Collect

We collect, process and store, and may share with third parties, the following categories of personal information. 

  • Contact information, such as full name, postal address, email address and phone number
  • Account information, including username and password
  • Health and genetic information, including medical conditions, medical history, family medical history, treatments and prescriptions 
  • We collect protected health information (“PHI”) on behalf of Providers 
  • Commercial information, such as billing details, your billing and payment history, products or services you purchased, obtained or considered, or other of your purchasing or consuming histories or tendencies
  • Mail, email or text message contents not directed to us on behalf of Providers 
  • We collect mail, email, and text message contents not directed at us on behalf of Providers 
  • For example, you may transmit communications to a Provider through our HC Services
  • Additionally, in cases where a Provider uses an EliseAI virtual assistant, we may collect access credentials (for example, username and password) for email inboxes and calendars connected to the HC Services and, by authenticating to EliseAI in such manner, you are permitting EliseAI to make a copy of the contents of the applicable email inbox and calendar in order to provide our HC Services to Providers
  • Characteristics of protected persons, for example, age, race, national origin, citizenship, religion, and sex/gender
  • Professional or employment-related information, including information about a Provider’s practice, employees and contractors 
  • Government identifying numbers, for example, national provider identifiers, social security numbers, and driver’s license numbers 
  • Sensory data, for example, we may collect voice recordings of interactions with our HC Services or customer service team
  • Geolocation data, such as the city where your device is located   
  • Preference information, including your preferences related to marketing, privacy and communications, including consents for text message communications 
  • Other information you choose to provide when interacting with our HC Services
  • For example, you may provide us with information regarding appointment scheduling 
  • Additionally, you may provide us with information when you submit a customer service query, enter a promotion, provide feedback, or otherwise communicate with us, including by online form, email, text message, phone and webchat 
  • Other information Providers choose to provide when interacting with our HC Services, for example, regarding appointment history and scheduling availability  
  • Device information, such as type of device, operating system, device settings, application IDs, unique device identifiers and crash data 
  • Internet identifiers, such as domain name, Internet Protocol (IP) address and browser type and settings 
  • Internet activity and analytics, such as cookie data, webpage interactions, referring webpage/source through which you accessed the HC Services, non-identifiable request IDs and statistics associated with the interaction between your device or browser and the HC Services
  • HC Services usage data, such as your log-on activity, date and time of visits, search terms, views, clicks and downloads, including which Providers, people, features, content and links you interact with when using the HC Services 
  • Inferences drawn from any of the personal information listed in this section; for example, to create a profile of an individual’s preferences and characteristics

Categories of Parties Whom We Share Your Personal Information

We may share your personal information with the categories of parties listed in this section. 

Providers 

  • We collect and process certain personal information on behalf of Providers, including collecting personal information directly from users of the HC Services on behalf of Providers 
  • Providers are considered “controllers” of such personal information we collect on their behalf under applicable privacy law; and are not considered third parties under applicable privacy law or this Privacy Policy
  • If we collect your personal information on behalf of a specific Provider, we only share it with that specific Provider (or the Provider’s group or entity) or as directed by that specific Provider (or the Provider’s group or entity) 
  • This Privacy Policy does not control how Providers use your personal information, which may be different from the uses described in this Privacy Policy; please consult the applicable Provider’s privacy policy for more information on how the Provider uses your personal information

Categories of Third Parties Whom We Share Your Personal Information

  • Our Vendors who help us provide the HC Services or perform business functions on our behalf, including hosting, technology and communication providers; analytics and artificial intelligence providers; support and customer service vendors; our attorneys, advisors, auditors and accountants; and payment processors 
  • Parties You Access, Authorize or Authenticate, including third parties you access through the HC Services, such as identity verification service providers; information provided to such third parties are subject to such third parties’ privacy policies; please consult the applicable third party’s privacy policy before proving information to a third party 
  • Parties for Legal Purposes, including governmental authorities, law enforcement or other third parties in connection with any of the activities set forth in the bullet beginning with "Meet legal and compliance requirements” in the below section called, Our Business Purposes for Collecting and Sharing Personal Information
  • Parties for Business Changes, for example, your personal information that we collect may be shared with or transferred to a third party if we undergo a merger, acquisition, sale, equity or debt financing, bankruptcy or other transaction in which a third party invests in, finances, or acquires control of our business or assets (in whole or in part) 

Our Business Purposes for Collecting and Sharing Personal Information

This section details the business purposes for which we collect, process, store and/or share your personal information.  

  • Provide, improve and protect our HC Services, including to provide the HC Services to Providers and interact with other users (such as patients and prospective patients) through the HC Services on behalf of the Providers; improve or customize the HC Services; develop new services or products; prevent or address service errors, security or technical issues; analyze and monitor usage, trends or other activities; respond to requests and inquiries from, or otherwise communicate with, Providers, users and third parties 
  • Improve your user experience, for example, we use cookies and other device and internet information to track your search criteria or other usage data to provide content of interest to you or to store your information so that you do not need to re-enter it each time that you login
  • Create a profile of you, including “profiling,” which refers to the automated processing of personal information  to analyze or predict an individual’s preferences, interests, behavior, location, or certain characteristics
  • De-identify personal information, including de-identifying PHI so that it is no longer PHI and aggregating and anonymizing personal information so that it is no longer personal information
  • Support our everyday operations, including using third-party vendors and service providers for business purposes (such as hosting, technology and communications) 
  • Meet legal and compliance requirements, including to perform audits, monitoring and reporting; support information security and anti-fraud operations; investigate and respond to disputes; exercise and defend legal claims; protect the rights, property or safety of you, us, a Provider or a third party; respond to legal process (including subpoenas) and governmental, court or law enforcement requests, investigations or orders; and comply with and enforce applicable laws, regulations, policies, procedures and agreements  
  • Evaluate or conduct business changes, including a merger, acquisition, sale, equity or debt financing, bankruptcy or other transaction in which a third party invests in or acquires control of our business or assets (in whole or in part) 

We Do Not Sell or Share Your Personal Information for Targeted Advertising  

We do not sell personal information. For purposes of this Privacy Policy, “sell” means the disclosure of personal information to a third party in exchange for money or other valuable consideration.

We do not share personal information with third parties for third parties’ direct marketing purposes. 

We do not share personal information with third parties for cross-context behavioral advertising or targeted advertising.

Retention of Personal Information

We retain personal information about you for as long as we deem to be necessary or advisable for the purposes described in the above section called, Our Business Purposes for Collecting and Sharing Personal Information (such as providing the HC Services to Providers) or as directed by Providers. For example, upon the termination of our agreement with a Provider or upon a Provider’s written request, we delete certain personal information and PHI. We may maintain your personal information after you have stopped using or interacting with our HC Services; for example, we may retain your personal information to improve our HC Services, comply with legal obligations or resolve disputes or collect fees owed. 

  1. Applicability of this Privacy Policy 

This Privacy Policy covers how we treat personal information that we acquire from you or other sources related to our HC Services or other interactions with us. This Privacy Policy does not cover the policies or practices of Providers or third parties that you may access or be connected with through the HC Services. This Privacy Policy does not apply to our collection and use of personal information in connection with any of our other services, which are subject to separate privacy policies.

Sources of Personal Information

We collect personal information about you from the following categories of sources:

  • Directly from you, such as when you access or use our HC Services or when you communicate or interact with us in any way, including by mail, email, phone, text message, webchat, QR code or social media
  • Indirectly from you, for example, we collect cookie data and other information from your device, browser or activity on the internet or in our HC Services 
  • From our third-party vendors, for example, from our analytics providers 
  • From Providers or other users of our HC Services  

Providers and Third Parties 

This Privacy Policy does not apply to Providers’ use of personal information or PHI or to any third-party websites, applications or services that you access or connect with through the HC Services. We do not have control over the privacy practices or the content of Providers or third parties, or their websites, applications, products or services. As such, we are not responsible for the privacy practices employed by or content provided by Providers or third parties, including, websites, applications or services linked to or accessible from or in connection with our HC Services.

Please consult the applicable Provider or third-party privacy policy and terms of service for information on their privacy practices and uses of personal information and PHI.  Please also make any privacy requests directly to Providers or third parties with respect to personal information or PHI in their control. 

Personal Information of Others You Share with Us 

You may not disclose the personal information of another individual to us, or make it available on the HC Services, unless (1) you are the parent or guardian providing the personal information of your own children; or (2) you are providing the personal information of an individual who is 18 years of age or older and you have that individual’s prior written consent. To the extent that you provide another individual’s personal information to us or use it in the HC Services, you acknowledge and agree that you are responsible for compliance with all applicable laws concerning such personal information.

Protected Health Information

We collect and process “protected health information” (also called PHI) as that term is defined under the Health Insurance Portability and Accountability Act of 1996, as amended, and any and all rules and regulations promulgated from time to time thereunder (“HIPAA”).  In addition to this Privacy Policy, our use and disclosure of PHI is subject to HIPAA and our agreements with Providers (including business associate agreements).  

We de-identify PHI in accordance with HIPAA by removing specified personal information that could identify an individual (e.g., name, telephone number, email address and account numbers). Once PHI is de-identified, it is no longer PHI covered by HIPAA nor is it personal information covered by this Privacy Policy. 

Personal Information of Children

You must be 18 years of age to use the HC Services. By accessing or using the HC Services, you represent and warrant to us that you are at least 18 years of age. If you are a child under the age of 18, please do not attempt to access or use the HC Services or send us any personal information.

We do not knowingly collect any personal information directly from children under 18 years of age. As a parent or guardian, you may provide or make available personal information of your children to us, and, by doing so, you agree and consent to our collection and use of your children’s personal information.

If we learn we have collected personal information directly from a child under 16 years of age, we will delete that data as quickly as possible. If you believe that a child under 16 years of age may have provided personal information to us, please contact us at privacy@meetelise.com. 

To our knowledge, we do not sell or share for cross-contextual behavioral advertising or targeted advertising purposes the personal information of children under the age of 16. 

  1. Your Privacy Rights and Choices 

Notice of Your Personal Information Rights

With respect to personal information that we control, subject to exemptions and limitations provided by applicable law, if you are an individual you have the right to: 

  1. Request that we disclose certain information to you about our collection and use of your personal information (collectively, the following constitute the "right to know"):
  • Whether or not we are processing your personal information 
  • The categories of your personal information we have collected
  • The categories of sources for your personal information we have collected 
  • Our business purposes for collecting or sharing that personal information
  • The categories of third parties with whom we shared your personal information, identifying the personal information categories that each category of recipient obtained and the purposes for sharing your personal information
  • The types of personal data we shared with third parties for third parties’ direct marketing purposes and the identities of such third parties (the “right to know third-party marketing”);
  • The specific pieces of personal information we collected about you and access to that personal information (the “right to access”)  
  1. Request a copy of the personal information you provided to us in a portable, and, if feasible, readily usable format (the “right to data portability”)  
  2. Request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions under applicable privacy law (the "right to delete")
  3. Correct inaccurate or complete incomplete personal information (the “right to correct”) 
  4. Direct us not to share your personal information for the purposes of making automated decisions, including profiling, that produce legal or similarly significant effects concerning you (the “right to opt out of profiling with legal effects”)
  5. Limit the use or disclosure of your sensitive personal information to just those actions necessary to perform specific purposes outlined by law (the “right to limit use of sensitive information”)
  6. Be free from unlawful discrimination for exercising your rights under applicable privacy law 

Generally, we do not control personal information or PHI obtained from or on behalf of Providers; instead we are the processor, service provider or business associate with respect to such information.  Please make any privacy requests directly to Providers with respect to personal information or PHI in their control (Providers may offer different privacy rights than the ones listed above). 

How to Exercise Your Personal Information Rights 

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a written request (via one of the methods described below) that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected personal information, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may ask for information to verify your identity, such as name, phone number, email and address. We will only use personal information provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.

Please be aware that certain HC Services or features or functionality of the HC Services may be unavailable to you if we honor your requests with respect to certain privacy rights (such as rights to delete or limit).  

We will work to respond to your Valid Request promptly within the timeframes required by applicable privacy law (usually between 15 to 45 days depending on the type of Valid Request, with the right for us to extend the response time as necessary). We will not charge you a fee for making a Valid Request unless your Valid Request is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.

You may submit a Valid Request using the following methods:

  • Send an email to: privacy@meetelise.com
  • Call our toll-free number: +1 (844) 585-0920
  • Complete our Privacy Rights Form

You may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. 

In some instances, we may not be able to honor your request. For example, we may not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we may not honor your request where not required to do so under applicable privacy laws. For example, we may deny a deletion request if the information is necessary for us to provide the HC Services to you or comply with our legal obligations and compliance policies. We may deny a right to know request made more than twice in a 12-month period or for information collected and disclosed more than 12 months ago. We will advise you in our response if we are not able to honor your request.  

You have the right to appeal our decision to not honor your request or our refusal to take action on a request within a reasonable period of time by contacting us at the email listed above and clearly stating that the purpose of the contact is an “appeal of privacy rights.”   Within 45 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. 

  1. Our HC Services Use Bots; You Consent to Us Recording Your Communications 

Our HC Services use artificial intelligence and bots to communicate with you by email, phone, text message and webchat. You acknowledge that you are communicating with bots when using the HC Services. 

We monitor and record communications made through the HC Services, including email, phone, text message and webchat. This includes monitoring your keystrokes while you are using the HC Services. You consent to us monitoring and recording all of your communications made through the HC Services and to us using and sharing such recordings for all purposes described in this Privacy Policy. 

  1. Our Use of Cookies 

Our Use of Cookies and other Tracking Technology 

The HC Services use cookies and similar technologies such as pixel tags, web beacons, log files, local storage objects, clear GIFs and JavaScript (collectively, “cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our HC Services, analyze trends, learn about our user base and operate and improve our HC Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our HC Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own cookies on your devices through the HC Services or otherwise.  

We use the following types of cookies:

  • Essential cookies are required for providing you with features or services that you have requested. For example, certain cookies enable you to log into secure areas of our HC Services. Disabling these cookies may make certain features and services unavailable.
  • Functional cookies are used to record your choices and settings regarding our HC Services, maintain your preferences over time and recognize you when you return to our HC Services. These cookies help us to personalize our content for you.
  • Performance cookies allow us to understand how users use our HC Services. They do this by collecting information about the number of visitors to the HC Services, what pages visitors view on our HC Services and how long visitors are viewing pages on the HC Services. 
  • Marketing/Targeted Advertising cookies collect data about your online activity and identify your interests to provide marketing or advertising that may be relevant to you. We also allow third parties to set and collect Marketing/Targeted Advertising cookies through our HC Services. For more information, please see the below section called, Third-Party Resources about Cookies and to Opt-Out of Cookies and Targeted Advertising. 

Do Not Track

“Do Not Track” is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Our HC Services are not currently configured to respond to Do Not Track signals or other mechanisms that provide users the ability to exercise choice regarding the collection of personal information about a user’s online activities over time and across third-party websites or online services.

Disable or Delete Cookies and Tracking Technology 

Disable or Delete Cookies from Your Browser or Device 

You can decide whether or not to accept certain cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. To explore what cookie settings are available to you, look in the “preferences” or “options” section of your browser's menu. 

You can also delete all cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our HC Services and some of the HC Services and functionalities may not work. 

Third-Party Resources about Cookies and to Opt-Out of Cookies and Targeted Advertising 

We allow third parties to set and collect cookies through our HC Services. Please review such third parties’ privacy policies and other terms for information on their privacy practices and uses of personal information, including whether they use cookies to provide targeted and cross-contextual behavioral advertising and your options to opt-out. 

We use the following third-party cookies among others: 

  • Google, including Google Analytics (Performance cookies) and Google AdSense (Marketing/Targeted Advertising cookies).
  • LinkedIn, including Functional, Performance, and Marketing/Targeted Advertising cookies. 

To make choices about targeted advertisements from participating third parties, including to opt-out of receiving targeted advertisements from participating third parties, please visit the Network Advertising Initiative at http://www.networkadvertising.org/choices/ or the Digital Advertising Alliance at www.aboutads.info/choices.

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To find out more information about cookies, including information about how to manage and delete cookies, please visit http://www.allaboutcookies.org/. 

  1. Our Uses of Personal Information Collected for the HC Services in the Last 12 Months

The below chart summarizes the categories of personal information we have collected for the HC Services in the last 12 months and disclosed to the identified categories of third parties in the last 12 months. For more details on the categories of third parties, see the above section called, Categories of Third Parties with Whom We Share Your Personal Information.

Category of Personal Information


Collected in Last 12 Months

Disclosed for Our Business Purposes in Last 12 Months to Categories of Third Parties 

Identifiers (for example, name, postal address, email address, IP address, unique personal identifiers) 

Yes

Yes to Our Vendors, Parties You Access, Authorize or Authenticate and Parties for Legal Purposes

Personal Information (for example, name, address, telephone number, credit card number)

Yes

Yes to Our Vendors, Parties You Access, Authorize or Authenticate and Parties for Legal Purposes

Characteristics of protected persons (for example, age, race, national origin, citizenship, religion, sex/gender)

Yes

Yes to Our Vendors

Commercial information (for example, purchase history and consumer profiles)

Yes

Yes to Our Vendors, Parties You Access, Authorize or Authenticate and Parties for Legal Purposes

Biometric information (for example, fingerprints and voiceprints) 

No*

Not applicable

Internet or other similar network activity (for example, browsing history, search history, website interactions)

Yes

Yes to Our Vendors and Parties You Access, Authorize or Authenticate 

Geolocation data (for example, device location) 

Yes

Yes to Our Vendors and Parties You Access, Authorize or Authenticate

Sensory data (audio, electronic, visual, thermal, olfactory or similar information)

Yes

Yes to Our Vendors

Professional or employment-related information 

Yes

Yes to Our Vendors

Non-public education information

No*

Not applicable

Inferences drawn from other personal information to create a consumer profile 

Yes

Yes to Our Vendors

Government identifying numbers (social security, driver’s license, state ID or passport numbers)

Yes

Yes to Our Vendors

Complete account credentials (account log-in, financial account, debit card or credit card number in combination with any required security or access code, password or credentials allowing access to an account)

Yes

No

Precise geolocation

No*

Not applicable

Racial or ethnic origin, religious or philosophical beliefs or union membership  

No*

Not applicable

Mail, email or text message contents not directed at us

Yes

Yes to our Vendors

Genetic data

No*

Not applicable

Biometric information processing for the purpose of uniquely identifying an individual

No

Not applicable

Health, sex life or sexual orientation 

Yes

Yes to Our Vendors and Parties You Access, Authorize or Authenticate

Other information you choose to provide (for example, you may choose to provide information in any of the above categories even if we do not specifically collect it)

Yes

Yes to Our Vendors, Parties You Access, Authorize or Authenticate and Parties for Legal Purposes

*Not specifically collected by EliseAI, but may be included in the category of “other information you choose to provide.”  

We have not sold personal information collected for the HC Services or shared personal information collected for the HC Services for cross-contextual behavioral advertising (or targeted advertising) in the last 12 months. 

  1. Data Security and Processing

Security of Your Personal Information 

We will maintain reasonable technical and organizational safeguards for the protection of the security and confidentiality of personal information from unauthorized access, use, disclosure or transfer. Despite our efforts to ensure security, we cannot guarantee or warrant that your personal information will not be accessed, acquired, disclosed for an improper purpose, altered or destroyed by an unauthorized person or as a result of a breach of our security safeguards or those of our hosting provider or other vendors or service providers.  We cannot ensure the security of any data transmitted to us over the internet. To the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure of your personal information. Therefore, we urge you to take adequate precautions to protect your personal information as well, including, without limitation, choosing a strong password, never sharing your account username or password, and logging out of your account and closing your browser when no longer using or interacting with the HC Services on a shared or unsecured device. 

International Transfer, Storage and Processing

Our HC Services are available in the United States only. We operate from the United States and the personal information we collect or receive is stored and processed in the United States. You consent to the transfer, processing and storage of your personal information in the United States. You also consent to the transfer, processing and storage of your personal information by us, our affiliated entities, our vendors or other third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world subject to the provisions of this Privacy Policy. The United States and other jurisdictions to which we transfer or in which we process or store your personal information may not have the same data protection laws as your jurisdiction. 

  1. Changes and Amendments to Privacy Policy 

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we do, we will post the revised policy on our website with a new “Last Updated” date. Your continued use of our HC Services or your provision of personal information to us following the posting of changes constitutes your acceptance of such changes. We encourage you to visit this page regularly for any changes. 

  1. Contact; Disability Access 

Contact Us

You may contact us with questions or concerns related to this Privacy Policy and our privacy policies and practices as follows:

Disability Access 

If you have a disability, you may access this Privacy Policy in an alternative format by contacting us at: 

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