Who this policy covers

This policy is from Paradigm Health Research & Education Enterprise, LLC (“PHREE,” “we”). PHREE provides the electronic medical record service that Paradigm Health, PLLC and Paradigm Wellness, PLLC (“the practices”) use to care for their patients. PHREE also runs this website, publishes the Paradigm Health app in the Apple App Store and Google Play, and keeps the de-identified research database described below.

This website

This site does not use advertising trackers. If you join our email list, we collect the email address you enter and use it only to send PHREE updates. You can ask to be removed at any time by writing to research@phree.org. We do not sell or rent email addresses.

The Paradigm Health app

The Paradigm Health app is the practices’ member portal on your phone, and it is part of the electronic medical record service PHREE provides to them. PHREE publishes the app and stores the health information in it on the practices’ behalf, as their business associate under HIPAA. The practices remain responsible for that information. It is protected under HIPAA by their Notice of Privacy Practices, which covers the member portal and the app and explains your rights.

What you see in the app, and anything you send from it, travels to and from the secure servers PHREE operates for the practices. The only other companies the app talks to are the two named below, for notifications and for video visits.

What the app can use on your phone

• Your account. You sign in with your own credentials, and the app keeps you signed in on that phone until you sign out. Anything you send from the app becomes part of your medical record. If you lose your phone, tell the practices and they will help you secure your account.
• Notifications, if you allow them. Your phone gives the practices an anonymous delivery code so they can send notifications. On Android it comes through Google’s notification service. The code identifies the phone, not you, and is used for nothing else. Notifications never contain medical details: they say only that something is waiting, such as “New results are ready to view,” and you sign in to read it.
• Camera and microphone, only for video visits. The app asks to use them when you join a video visit with your care team, and uses them only during the visit. Video visits are delivered through Zoom’s video service.
• Health Connect on Android, only if you choose to connect it. The app can read, and never change, six measures from your phone’s Health Connect: steps, resting heart rate, heart-rate variability, blood oxygen, VO2 max, and exercise minutes. They are sent to the practices’ record, held on the secure servers PHREE operates for them, so they can appear in your record. Android asks your permission first, and you can change or withdraw it at any time in your phone’s settings.
• A profile photo, only if you add one. If you choose a photo, the app uses only the photo you pick.

The app does not use your location or your contacts. It has no advertising, no analytics, and no third-party tracking.

Health data from your phone: Health Connect and Apple Health

Android and Health Connect. The app reads the six measures listed above from Health Connect only if you choose to connect it. It only reads: it never writes to, or changes, anything in Health Connect. Android asks for your permission first, and you can withdraw it at any time in your phone’s settings or in Health Connect. Withdrawing stops the app reading new data; it does not remove readings the practices already received, which are handled as described under “Your choices, and deleting your account” below.

Why we ask. The readings are sent to the practices so your care team can see your activity and fitness trends next to your labs and testing, and so they can appear in your record and your Paradigm Plan. We ask for only these six measures because they are the ones used for that purpose.

Limited use. We use health data received from Health Connect only to provide those features to you and your care team. We do not use it for advertising or marketing. We do not sell it. We do not share it with advertising platforms, data brokers or information resellers, and we do not use it to decide credit, employment or insurance eligibility. It is sent over an encrypted connection to the servers PHREE operates for the practices. People at the practices can see it only where that is part of your care, where you ask, or where the law requires. People at PHREE can see it only where needed to operate, support and secure the service. The only other companies that handle it are those that host and secure those systems on their behalf, and each is bound by an agreement to protect it. The use of information received from Health Connect adheres to the Google Play User Data Policy, including its Limited Use requirements.

iPhone and Apple Health. The iPhone app does not read Apple Health today. If we add that, the app will ask your permission first and say exactly what it wants to read. We will not use Apple Health data for advertising, marketing or data mining, and we will not disclose it to third parties except as part of your care or as the law requires. We will update this policy before the feature is released.

Your choices, and deleting your account

You can turn off any of the permissions above at any time in your phone’s settings, and you can sign out of the app whenever you like.

To delete your account and your app data. This applies to the Paradigm Health app, published by Paradigm Health Research & Education Enterprise, LLC.

1. In the app, go to Account and choose Delete my account. Or email drdavid@phree.org with the subject “Delete my account,” from the address you use to sign in.
2. The practices will check that the request is from you and confirm within 30 days.

What is deleted. Your sign-in to the member portal and the app, and the app information held for that sign-in, including your app settings and your notification delivery code.

What is kept, and why. Your medical record, which may include information you sent from the app, is kept by law. Tennessee law requires a physician to keep your medical record for at least 10 years after your last visit. For a child, it is kept until at least 1 year after they turn 18, or for 10 years, whichever is longer. Immunization records, and the records of a patient who cannot make their own decisions, are kept indefinitely, and nothing connected to a service that is in dispute is destroyed until the dispute is settled. Federal HIPAA law does not set its own period for medical records. Billing records and records needed for legal or security reasons, such as preventing fraud, are kept for as long as the law or those reasons require. Information in the practices’ research and operational records that no longer identifies you is not part of your account.

Research data

PHREE’s research database contains no direct identifiers. It is created using the HIPAA Safe Harbor de-identification standard, described on our research page. We do not attempt to re-identify anyone, and the link between study numbers and real people is kept separately by Paradigm Health, under HIPAA.

Patients of Paradigm Health

This website is not a patient portal. Do not send medical questions or health information through this site or to the address above. Patients should contact their care team directly.

Your rights over your health information, including to see and get a copy of your record, to ask for corrections, and to complain, are described in the practices’ Notice of Privacy Practices. To use them, contact Paradigm Health’s Privacy Officer at 520 Duke Drive, Suite 200, Franklin, Tennessee 37067, or (615) 469-0703.

How long we keep information

Tennessee law requires a physician to keep your medical record for at least 10 years after your last visit. For a child, it is kept until at least 1 year after they turn 18, or for 10 years, whichever is longer. Immunization records, and the records of a patient who cannot make their own decisions, are kept indefinitely, and nothing connected to a service that is in dispute is destroyed until the dispute is settled. Federal HIPAA law does not set its own period for medical records. If you join the PHREE email list, we keep your email address until you ask to be removed. We keep other information on this website only as long as we need it for the reason you gave it to us.

How we protect information

The practices and PHREE use administrative, physical and technical safeguards to protect health information, including encrypted connections between the app and the servers, and they limit access to the people who need it for your care or to operate and secure the service. We keep the details of those safeguards private so as not to make them a target. If you have a security concern, contact the Privacy Officer using the details above.

Children

This website and the app are meant for adults, and we do not knowingly collect information from children through them. The practices care for adolescents as part of a family membership, with a parent or guardian involved, as their Notice of Privacy Practices describes.

Changes

If this policy changes, the date above will change with it. If we make a material change, such as reading a new kind of health data, we will post the new version here before it takes effect and, where the law requires, tell you directly.

Contact

Paradigm Health Research & Education Enterprise, LLC, research@phree.org. For questions about your health information or your care, contact Paradigm Health as described above.