Privacy Policy

Last updated: April 02, 2021

Banty Inc, which shall hereafter be referred to as (“Banty”, “We”, “Us” or “Our”) is a telemedicine company that stores, transmits and analyses PHI on behalf of covered entity clients to improve patient care, generate insights and provide practice management tools. Banty is committed to protecting and respecting your (“Your” or “You”) privacy and personal information, meaning any information about You which is personally identifiable (“Personal Information”), that We may collect from or which You may submit to or through www.banty.org, the Banty mobile application or other Banty digital assets that directly link to this Privacy Notice (the “Website”).

This Privacy Notice (the “Privacy Notice”) describes how We may use Your Personal Information and how that information may be used or disclosed by Us.

Please read the following carefully to understand Our views and practices regarding Your Personal Information and how We will treat it.
This Privacy Notice applies only to Personal Information collected on Our website. It does not apply to Personal Information collected on any third-party site that may link to or be accessible to Our website over which We have no influence or control. The use of other sites, or the submission of Personal Information to other third-party sites is at Your own risk and is subject to their Privacy Notices and policies.

Collection of Personal Information
Generally, You can visit our website without revealing who You are and without disclosing any of Your Personal Information. However, there may be times when We require Personal Information about You or when You wish to disclose such Personal Information to Us. Such Personal Information is obtained when submitted by You and is subject to the provisions set out in this Privacy Notice.

We may collect and process the following Personal Information about You:

  • Information that You provide by filling in forms on Our website, such as Your personal details (e.g., Your name, date of birth, etc.) or contact details (e.g., telephone number, email address, postal address, etc.). This includes information provided at the time of registering to use the registration-only sections of Our website.
  • With respect to the use of the jobs section of this Website, Information You have provided as part of the job application and onboarding process (such as application materials, offer letter, etc.). Before using any of the services available on that section of the Website, You will be required to review and agree to specific terms of use.
  • We may also ask You for Personal Information (such as when You report a problem with the Website).
  • If You contact us, in writing, by email or other electronic means, We may keep a record of that correspondence.
  • Details of Your visits to the Website and information as You navigate through the Website together with details of the resources that You access. This information includes but is not limited to: usage details, IP addresses, location data and other communication data which will be used in accordance with this Privacy Notice.


Where required by law we may ask for Your explicit consent to collect information considered to be sensitive Personal Information (such as information about Your ethnicity or health information). You may withdraw Your consent at any time by contacting Us at the details below.
Feedback forms used in Banty correspondence specifically request that you not include personal information such as usernames, passwords, social security numbers, and private health information. Correspondence conducted via feedback forms is stored on a third-party server and then accessed by Banty personnel.
We may be required by law to collect certain Personal information about You or because of any contractual relationship We have with You. Failure to provide this information may prevent or delay the fulfillment of these obligations.

How Banty Uses Personal Information

Purpose of Collection
Banty will neither use nor disclose a Custodian’s personal health information, except as permitted or required by a business associate agreement or in writing by the Custodian or as required by law. Banty may not use or disclose a Custodian’s personal health information in a manner that will violate the Act.

Limiting Collection
Banty will, in its performance of the functions, activities, services, and operations specified above, make reasonable efforts to use, to disclose, and to collect only the minimum amount of the Custodian’s personal health information reasonably necessary to accomplish the intended purpose of the use, disclosure or request, except that Banty will not be obligated to comply with this minimum-necessary limitation if neither Banty nor the Custodian is required to limit its use, disclosure or request to the minimum necessary.

Permitted Uses and Disclosures
Banty is permitted to use and disclose personal health information that it receives on a Custodian’s behalf or directly from a Custodian; and to request personal health information on a Custodian’s behalf (collectively, “Custodian’s personal health information”) to perform services for the Custodian ONLY as designated by the Custodian.

Banty is permitted to use the Custodian’s personal health information for proper management and administration or to carry out legal responsibilities, provided that, with respect to disclosure of Custodian’s personal health information, either: (A) the disclosure is required by law; or (B) Banty obtains reasonable assurance from any person or entity to which Banty will disclose Custodian’s personal health information that the person or entity will:

  • hold Custodian’s personal health information in confidence.
  • use or further disclose Custodian’s personal health information only for the purpose for which the personal health information was disclosed or as Required by Law.
  • promptly notify a Custodian in accordance with the notification provisions) of any instance of which Banty becomes aware in which the confidentiality of the Custodian’s personal health information was breached.

Accuracy
Banty shall take reasonable steps to ensure that personal health information is as accurate, complete, and up-to-date as necessary for the purposes for which it is used and disclosed. Banty will exercise its judgment in deciding how accurate the information should be based upon the severity of the information (e.g. health treatment information vs. health administrative information) . Banty will also inform recipients of personal health information about any limitations on the accuracy of the information.

Retention
Banty privacy policies and procedures shall be documented and maintained for at least six years from the date last in effect. Policies and procedures must be changed as necessary or appropriate to comply with changes in the law, standards, and implementation specifications (including changes and modifications in regulations). Any changes to policies or procedures must be promptly documented.

Safeguards

Banty will establish the appropriate administrative, technical, and physical safeguards to prevent personal health information from intentionally or unintentionally being used or disclosed in violation of PHIPA’s requirements. Administrative safeguards include implementing procedures for use and disclosure of personal health information. Technical safeguards include limiting access to information. Physical safeguards include door locks, badges, keys, and physical device security.

Global Transfer of Personal Information
Your Personal Information may be transferred to, stored, and processed in a country that is not regarded as ensuring an adequate level of protection for Personal Information under European Union (EU) law. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements so that Your Personal Information is adequately protected. For more information on the appropriate safeguards in place, please contact Us at the details below.

Children’s Online Privacy (COPPA)
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of this Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@banty.com.

Third Parties
We may share Your Personal Information with agents, contractors, or partners of Banty in connection with services that these individuals or entities perform for, or with, Banty. These agents, contractors or partners are restricted from using this information in any way other than to provide services for Banty, or services for the collaboration in which they and Banty are engaged. We will not give, sell, rent, loan, or otherwise disclose any Personal Information to any third party, unless permitted or otherwise authorized to do so.

Banty reserves the right to share Personal Information in response to duly authorized information requests of any law enforcement agency, court, regulator, government authority, or other third party, where We believe such disclosure is necessary to comply with a legal or regulatory obligation, or otherwise to protect Our rights or the rights of any third party.

We may also provide Personal Information to a third party in connection with the sale, assignment, or other transfer of the business of this Website to which the information relates, in which case We will require any such third party to agree to treat Personal Information in accordance with Our Terms of Use.

We also may share aggregate, non-personal information about Website usage with unaffiliated third parties. This aggregate information does not contain any personal identifiable information about our users.

Violation of Privacy Agreement
We reserve the right to take appropriate legal action, including without limitation, referral to law enforcement, for any illegal or unauthorized use of this Website. We also reserve the right to take any action to prevent the unauthorized use of Our intellectual property rights.

We may cooperate with any law enforcement authorities or court order requesting or directing Us to disclose the identity of or locate anyone for the prevention or detection of crime or the apprehension or prosecution of offenders. There may be other circumstances in which We may be required by law to disclose information about You or Your use of this Website. You waive and hold Us harmless from any claims resulting from such disclosures and from any actions taken because of investigations by either Us or law enforcement authorities.

We may investigate any complaints or reported breaches of this Privacy Notice and take any action that We deem appropriate (which may include, without limitation, removing any of Your information, issuing warnings, suspending, restricting, or terminating Your access to this Website). We also reserve the right at Our discretion to suspend, restrict, or terminate Your access to this Website at any time without notice if We have reasonable grounds to believe that You have breached this Privacy Notice or Our Terms of Use.

Client Responsibilities
If You choose or are given a user identification code, password or any other information as part of Our security procedures for one of the registration-only sections of the Website, You are responsible for maintaining the confidentiality of Your password and username for the Website and You are responsible for all activities that are carried out under them.

We do not have the means to check the identities of people using the Website and We will not be liable where Your password or username is used by someone else. You agree to notify Us immediately at the contact information provided below of any unauthorized use of Your password or username of which You become aware. We have the right to disable any user identification code or password, whether chosen by You or allocated by us, at any time, if in Our opinion, You have failed to comply with any of the provisions of these terms.

Please be aware that while We take appropriate steps to safeguard the security of Your Personal Information, the transmission of information over the Internet is not completely secure and therefore You do this at Your own risk. Once We receive Your Personal Information, We will implement strict security procedures with the objective of preventing unauthorized access.

Financial information and payment data, including credit card numbers, that You provide to Us via the Banty internet bill payment link is encrypted by using secure socket layer (SSL) encryption technology. This information may be accessed only by Banty workforce members and service providers who maintain password and required access rights, and third-party vendors who support Banty’s billing operations.

We implement administrative, technical, and physical controls to maintain a level of security appropriate to the risk to the Personal Information We process. These measures are aimed at maintaining the on-going integrity and confidentiality of Personal Information. We evaluate these controls on a regular basis.

We will retain Your Personal Information in accordance with Our record retention policy, as updated from time to time, and if We have a relationship with You. To request that Your Personal Information be deleted from Our databases, please email us using the information below.

Cookies
Banty tracks visitors to our website by collecting data elements called cookies. Cookies collected from the Banty website are used to (1) enable certain functions and tools on this website, (2) assist in the navigation of the website, (3) track resources and data used on this site, (4) promote Banty’s products and services, and (5) remember computer settings. Banty also collects other forms of non-personal information, such as browsers used to access our website, search terms used to find the website, and traffic referrals and links to our website. Cookies are not permanently maintained within our tracking system. You may prevent your computer from accepting cookies by modifying the properties on your web browser; however, stopping your computer from accepting cookies may limit your web browser’s functionality on the Banty website.

If you wish to prevent the use of cookies or for your information to be included in aggregated data through Google Analytics, You must modify the properties on your web browser for both as described above.

Internet Links
As a convenience to our site visitors, the Banty website may contain links to several sites that may provide useful information. Links contained on the Banty website that transfer you to a non-Banty site are not maintained by Banty and may contain different information and/or different privacy policies from those of our Company. You may review the privacy policies of these websites and/or receive specific information regarding that site’s privacy policies and procedures after leaving the Banty site. Banty is not responsible for the content or privacy practices of a non-Banty website. Banty does not control, or have any input into, whether our business partners or internet-linked sites, use or accept cookies on their sites.

Updates and Changes
We may update this Privacy Notice from time to time. When We do update it, for Your convenience, We will make the updated Privacy Notice available on this page. Changes and additions to the Privacy Notice are effective from the date on which they are posted. Please review the Privacy Notice from time to time to check whether We have made any changes to the way in which We use Your Personal Information.

Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. Banty DOES NOT disclose your personal information to third parties for their direct marketing purposes.

Individual Rights
You have certain rights regarding Your Personal Information, subject to local law. These include the following rights to:

  • access Your Personal Information;
  • rectify the information We hold about You;
  • erase Your Personal Information;
  • restrict Our use of Your Personal Information;
  • object to Our use of Your Personal Information;
  • receive Your Personal Information in a usable electronic format and transmit it to a third party (right to data portability); and
  • lodge a complaint with Your local data protection authority if one exists in Your country.


We encourage You to contact Us to update or correct Your Personal Information if it changes or if the Personal Information, We hold about You is inaccurate. Please note that We will likely require additional information from You to honor Your requests.
Please note that should You request that Your Personal Information be deleted, You may continue to receive materials for a short period while We are updating Our lists. Your records will then be permanently deleted from Our systems.

How to Contact Us
Banty Inc. is based in the US and is the controller responsible for Personal Information that it collects and processes.
If You have any questions or concerns regarding the way in which Your personal information is used, please contact Us via email using the address below. Our Privacy Officer can be contacted at privacy@banty.com

This Privacy Notice was last updated April 2, 2021.

Right to Modify
Banty reserves the right to modify this privacy notice at any time. Changes and modifications will be effective when approved and redistributed.

Simone Leung

Privacy Officer

Marc Tytus

Chief Information Security Officer

Contact: security@banty.com