Effective date: June 28, 2018
ChronWell, Inc., a Delaware corporation, and its affiliated companies (collectively, “ChronWell”, “us”, “our” or “we”) respects
By clicking “I agree” as a part of your initial access to our mobile application, by your use of any ChronWell website, or
1. OUR SERVICES
ChronWell provides services designed to assist individuals and companies with the management of workers compensation claims,
including, without limitation, providing assistance related to health and medical care associated with injuries
2. WHOSE PERSONAL INFORMATION WE COLLECT
We collect personal information from and about a number of different types of individuals, as follows.
We will refer to you, your representatives, and other persons collectively as “users” and individually as a “user.” This
- Individuals who have been injured and either have or may have a workers compensation claim. In this Privacy
Policy, we refer to those persons as “you” or “your.”
- Individuals who interact with us on your behalf, such as a spouse, guardian, or adult child. In this Privacy
Policy, we refer to those persons as “your representatives.”
- Individuals who visit our website, your employer (which includes their employees or contractors), a workers
compensation insurance company (which includes their employees or contractors), healthcare providers
(which includes their employees or contractors), or those contractors of ours who provide services to
we refer to those persons as “other persons.”
3. HOW WE RECEIVE PERSONAL INFORMATION
A. Interactions with Our Access Channels
We receive or collect personal information about users in any manner in which they communicate with us and in which we communicate
with them, including, without limitation, automated collection of personal information. We receive this information
in many different ways, which includes (without limitation), the following:
We call these means through which personal information is collected “access channels.”
- through interactions with our websites (“our website”),
- by sending and receiving text and email messages,
- through a mobile device application that you or your representatives download to your mobile device (“our
- through our interactive telephone systems, and
- through telephone or videophone conversations with our personnel.
B. Personal Information About You
We may get personal information about you from yourself, from your representatives, and from other persons through any of
the access channels.
C. Personal Information about Your Representatives
We may get personal information about your representatives from you and from your representatives through any of the access
channels. We may also get personal information about your representatives from other persons.
D. Personal Information about Other Persons
We may get personal information about other persons from the other person himself/herself or those who engage those other
persons as an employee or service provider.
4. WHAT PERSONAL INFORMATION WE RECEIVE
A. Personal Information About You
As you will see below, we get a lot of information about you. After all, information about your health, your injury, your
treatment, your employer, your insurance, your recovery, and the like can result in our receiving a lot of
information about you.
Except for the uses of information described in Section 6, we only use this information to provide services to you, to your
employer, and the relevant workers compensation insurance company to assist with the management of workers
compensation claims, including, without limitation, providing assistance related to health and medical care
associated with injuries.
We believe that acquiring this information is useful to you, to your employer, and to your workers compensation insurance
company. We can do some really useful things with your information, such as:
The specific services we provide you will vary with the services that your employer or workers compensation insurance company,
or their contractors, contract with us to provide.
It is also important for you to know that it is not a good idea to lie to your employer or insurance provider about the status
of your injury or recovery. Some of the information we collect or receive can help determine whether you
are telling us—and more importantly your workers compensation insurance company or employer——whether you
are being truthful about your injury and recovery. For example, (i) if you are telling your insurance company
that you are bedridden, we may be able to tell whether you went to a baseball game or the grocery store;
(ii) if you are telling your employer or insurance company that you can’t raise your arm above the top of
your shoulder, we may be able to tell whether you can do that or not. As with many things in life, it is
important not to lie. Our services may allow us to catch you if you do. Misrepresentations to your employer
or insurance company may be criminal, result in civil liability, could result in the loss of insurance benefits,
or could result in your being fired by your employer.
- Helping you to find the healthcare provider that may be the best level of treatment for your injury.
- Helping you with transportation to your healthcare appointments.
- Helping you with assessing the scope of your injury.
- Helping you with exercises to help you recover.
- Helping make your insurance claim easier to process.
- Helping you to recover from your injury and get you back to work.
(2) Information We Receive About You
We may receive the following personal information from you, your representatives or other providers:
- Your name,
- Your home address,
- Your email addresses,
- Your phone numbers,
- Your employer, its contact information and where you work,
- What workers compensation carrier is involved in your workers compensation claim and its contact information,
- The status of your workers compensation claim,
- What health care professionals you either use or have been recommended to you,
- Information about your injury and the circumstances surrounding your injury,
- How you have been or are being treated for your injury, your health status, and how you are responding to
- Health insurance information,
- Information about your appointments with health care providers,
- Payment information (for example, information about where to send workers compensation claim money), and
- Other personal information that either is or may be relevant to your health, healthcare, or insurance claim.
(3) Location Information
If you download our app to your mobile device, we use information about your location. You can control whether and when we
collect that information by adjusting the location settings on your mobile device. For example, you can allow
us to receive location information at all times, only when your mobile device is running our app, or not
(4) Movement Information
Many mobile devices can detect movement. If you download our app, we will capture certain information related to your movements
(or, more accurately, the movement of your mobile device). We only collect movement information when our
app is active on your mobile device.
(5) Biometric Information
Biometric information is information about you that can be measured about you physically. Examples of biometric information
include heart rate, blood pressure, breathing rate, blood sugar levels, pictures of injuries, exercise and
exercise patterns, skin tone, skin temperature, weight, and anything else about you that can be captured
by the functionality of your mobile device or devices that communicate with your mobile device.
Some mobile devices, or other devices that communicate with mobile devices, collect biometric information. For example, if
you use an iWatch, an Android watch, a fitness tracker, or a similar device, we may capture biometric information
that can be captured by these devices. Our capture of this information is limited by the kinds of biometric
information that these devices capture. We receive this information from your mobile device if your mobile
device captures this information itself or receives this information from your iWatch, Android watch, fitness
tracker, or similar device. We may receive this information immediately or when our app syncs with the biometric
device information on your mobile device.
We only capture this information while you are using our app; however, while you use our app, we may receive biometric information
that has been stored on your mobile device.
B. Personal Information About Your Representatives
We collect personal information about your representatives to enable us to contact them about you. For example, we may obtain
name and contact information for your representatives and obtain information about their ability or willingness
to assist you in the future.
C. Personal Information About Other Persons
We collect personal information about other persons to enable us, and possibly other individuals, to contact them so that
we can perform our Services. For example, we may keep track of certain employees or contractors of your employer
who serves as our contact about your workers compensation claim.
For other persons who are our customers’ personnel, we also keep obtain and keep information about our business relationship
and our communications with their employees or services providers related to our business relationship or
proposed business relationship.
For visitors to our website, other than the automated personal information we receive, we only collect that personal information
that the visitor provides to us.
D. Automated Personal Information We Receive
In addition to the personal information described in A, B and C above, we also receive personal information automatically
when any user interacts with us using the Access Channels:
When a user visits our website, we collect personal information about the visit that does not identify the user personally.
We can tell the type of computer, browser, IP address, and web service the user is using. We also know
the date, time, length of visit, and pages visited and what website the user came from.
When any user connects with us using our app, we collect personal information from or about the phones or other mobile devices
on which our app is installed, depending on the permissions granted by the user. We may associate the
information we collect from the user’s different devices, which helps us provide consistent Services
across devices. Here are some examples of the device information we collect:
Device attributes, such as the operating system, hardware version, device settings, file and software names and types, battery
and signal strength, and device identifiers,
Location information, as described above, and
Connection information such as the name of your ile operator or ISP, browser type, language and time zone, mobile phone number
and IP address.
When a user communicates with us using a telephone, we collect the user’s telephone number and the date, time, and length
of the call. We will also normally record the telephone call, for training, quality assurance, and to
keep the information communicated during the call. We will tell the user at the time if we will record
When a user communicates with us using text messages or email, we collect the user’s email address, mobile phone number,
and other information that is generally provided by the user’s cellular telephone service, the user’s
mobile phone, the user’s web browser, or the text and email applications that the user uses. We also
may retain the messages users send to us.
5. DATA USE BY TYPE OF USER
A. How We Use Your Personal Information
We use the personal information we receive about you to provide services to you, to your employer, and to the applicable
insurance provider. Other than the use of personal information described Section 6 below, we do not use
personal information about you other than for the purposes of providing those services.
(1) Uses Generally
Here are a few examples of how we use your personal information. These are not our only uses of your personal information,
but we hope these examples will help you understand in a general way what we do with your personal information.
Our use of your personal information varies with the kinds of services that we have been engaged to provide,
so all of the examples below may not be applicable to you. Specific examples of how we use location,
movement, and biometric information are set out in separate subsections below these examples.
We may provide your personal information to your employer, the workers compensation insurance provider, or healthcare providers
(or employees or contractors of those entities):
We may provide the workers compensation insurance carrier or your employer information about the circumstances of your injury,
the nature of your injury, the treatments you are receiving or to receive, the efficacy of those
treatments, how you are recovering, etc.
We may be asked to assist you in identifying a healthcare provider. We may communicate with one or more healthcare providers
to find one for you, as well as provide information to the healthcare provider so that the healthcare
provider can determine whether they are appropriate to help you, such as the nature of your injury,
other health information and insurance information, and to schedule appointments for you.
We may be asked to assist with transportation to a doctor’s appointment, physical therapy appointment, etc. We will provide
the service provider who provides the transportation your name, address, location, and contact information,
as well as the name, address and contact information of the healthcare provider and whether you have
any special needs related to the transportation.
in the evaluation of your fitness to receive other services from us, your employer or the workers compensation insurance
in the evaluation of your workers compensation claim,
to determine our best guess as to the appropriate level of healthcare that you should receive based on your injury, other
medical conditions, and your progress,
in determining whether you have suffered a partial or permanent disability and if so, the nature of that disability, and
whether you are ready to return to work.
(2) Location Information
We use location information to assist with our providing services. Here are some examples, without intending this to be an
- To determine the appropriate healthcare professional to suggest you see for your injury.
- If we provide services to arrange for transportation, to determine where you are so that someone can
pick you up and take you to your appointment.
- To determine how far away you are from your appointment to determine whether you will be there on time.
(3) Movement Information
We use movement information to assist with our providing services. Here are some examples, without intending this to be an
- To determine whether you are doing certain physical therapy exercises or whether you are doing them correctly.
- To assess the nature of certain injuries, such as determining the range of motion of one of your joints.
- To determine how fast you are moving or how fast you can move a particular body pa
- To determine what healthcare professional is likely to be appropriate for you to visit based on your
(4) Biometric Information
We use biometric information to assist with our providing services. Here are some examples, without intending this to be
an exclusive list.
- To determine your health status to determine what healthcare professional is likely to be appropriate
for you to visit based on your injury.
- To determine how quickly you need to see that healthcare professional.
- To determine the effect on you of certain physical therapy exercises.
B. How We Use Your Representatives’ Personal Information
We use your representatives’ personal information to provide services to you, to your employer, and to the applicable insurance
provider. Other than the use of personal information described Section 6 below, we do not use personal information
about your representatives other than for the purposes of providing those services.
C. How We Use Other Person’s Personal Information
We use other person’s personal information to provide services to you, to your employer, and to the applicable insurance
provider. Other than the use of personal information described Section 6 below and as further described in
this Section, we do not use information about other persons other than for the purposes of providing those
For visitors to our website who provide us personal information, we use their personal information to respond to their requests
for personal information and to market our services.
6. DATA USE APPLICABLE TO ALL USERS
A. Who We Provide User Personal Information To
We provide personal information to those persons and organizations that have a need for the information so that we can provide
our services. User’s personal information may be shared with the injured person’s employer, the workers compensation
insurance provider, healthcare providers, and those persons and entities that provide services to the injured
person or those entities.
We do not control what those organizations do with user’s personal information.
While, under most circumstances, we do not try to control what is done with user personal information by those organizations,
we believe that the organizations receiving this personal information from us—the employer, the insurance
provider, healthcare providers, and those who provide services to those entities—should have certain legal
obligations to users, or commitments made to users, related to privacy and security that limits what they
can do with this personal information.
While this is our belief, you should get information about their use of personal information from them and not depend on
what we believe to be the case. Please contact those organizations for information about how those organizations
use and protect personal information.
We also provide other entities with user’s personal information as described in Sections 6.C, 6.D, and 6.E below.
A "cookie" is a small text file that is stored on a computer, phone, or other device and makes it easy for the applicable
user to move around a website or our app without having to continually re-enter the applicable user’s name,
Services, record user-specific information on what pages the user accesses or visits or information the users
receive, and customize web page and app content based on the user’s browser type or other information that
the user sends. These cookies do not access, read or modify any other data on the user’s device.
purposes, such as web beacons, clear gifs, pixel tags, single pixel gifs, and Flash cookies, although these
other technologies may not be controlled by the user’s web browser as otherwise described in the next paragraph
do not gather any information on the user through cookies, although some functionality of our website will
website or using our app.
C. Access by Law Enforcement
We share personal information about a user if we are required by law to do so for authorized law enforcement, homeland security,
and national security, or to comply with any court order, law or legal process, including responding to any
government or regulatory request.
D. Other Uses
We may also use a user’s personal information in connection with of the following:
- For any report of problems with our Services;
- To deliver information and support user requests, including receipts, technical notices, security alerts,
and support and administrative messages;
- To track and analyze trends and usage in connection with our Services;
- To protect our rights or property;
- To compare personal information for accuracy;
- To verify a user’s identity;
- To investigate and prevent fraud or other illegal activities;
- For any other purpose disclosed to you in connection with our Services;
https://legal.chronwell.com/terms-of-use/en, and other agreements;
- To retain an archived copy of user records as required by law or for legitimate business purposes;
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of ChronWell,
other users, other customers, or other third parties. This includes exchanging information with other
companies and organizations for the purposes of fraud protection and credit risk reduction; and
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution
or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy,
liquidation or similar proceeding, in which personal information about users is among the assets transferred.
E. De-identified or Aggregated Data
Data derived by us from our performance or operation of our services or input by users may be used for the purposes of analysis,
including, without limitation, statistical analysis, trend analysis, creation of data models, and creation
of statistical rules. The results of such analysis (“de-identified data”) may be used by us for any lawful
purpose, including, without limitation:
We may choose to disclose the results of these analyses, including, without limitation, selling those results for a fee.
Notwithstanding the foregoing, de-identified data shall not contain any information that identifies or can be reasonably
used to identify any user or any other individual person.
- determining future hardware and communications needs for our systems,
- identifying improvements to or problems with our Services and identifying new services,
- determining trends associated with use, operation, and efficacy of our Services, and
- identifying trends, information about certain occupations, industries, injuries, treatments, healthcare and
other service providers, and other statistical information that may be of use to us, to our customers,
or to third parties.
7. WHAT WE DO NOT DO WITH PERSONAL INFORMATION
While the services we provide are free to employees who have been injured, we are paid by your employer, workers compensation
insurance provider, or someone providing services to your employer or workers compensation insurance provider.
Accordingly, we do not advertise third party products or services on our website or through our app, text messages,
email messages, or personal phone calls. We do not sell, rent, lease, or otherwise provide user personal information
8. USE BY CHILDREN
Our services, including, without limitation, the use of our Access Channels are not intended for use by children. No one
under age 13 should provide any personal information to our website or through other Access Channels. If we learn
that we have mistakenly collected personal information from a child under age 13, we will delete that information
as soon as possible. If you believe that we might have personal information from or about a child under age 13,
please contact us at
9. LINKS TO OTHER WEBSITES
through links on our website. We encourage you to read the privacy policies of those other websites to learn
how they collect and use personal information about you.
10. UPDATING INFORMATION
You may seek to update or correct information about yourself by emailing us at
email@example.com. If you completely delete all such information, then your account may become deactivated.
11. CALIFORNIA USERS
California Users may have the right to request certain disclosure information annually from ChronWell. Such disclosure requests
should be directed to: 150 S Pine Island Rd. Suite 330 Plantation, FL 33324. For more information, please reference
the Cal. Civ. Code § 1798.83, available at http://oag.ca.gov/privacy/privacy-laws. In addition, if you are a
California resident, in accordance with Cal. Civ. Code §1789.3, you may report complaints to the Complaint Assistance
Unit of the Division of Consumer Services of the California Department of Consumer Affairs by contacting them
in writing at 1625 North Market Blvd., Suite N 112, Sacramento, CA 95834, or by telephone at (800) 952-5210.
12. INTERNATIONAL TRANSFER
By accessing and using the Services, you acknowledge and agree that ChronWell controls and operates all parts of the Services
from its offices in the United States of America and that the Services is intended for use by users located
in the United States of America. Unless expressly stated to the contrary, ChronWell makes no representation
that the Services is appropriate or will be available for use in other locations.
If you access the Services from outside the United States, you acknowledge and agree that your information may be transferred
to and maintained on computers and servers located outside of your state, province, country, or other governmental
jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. Your consent
to the Agreement followed by your submission of such information represents your agreement to the transfer
of such information to the United States and the collection, use, and disclosure of your information in accordance
A. Security Generally
We safeguard the security of user's personal information with industry-standard physical, electronic, and administrative
procedures. Unfortunately, the transmission of information via the internet is not completely secure. Although
we do our best to protect user‘s personal information, we cannot guarantee the security of personal information
transmitted to, through, or processed or stored by our Services. Any transmission of personal information
is at the user’s own risk. We are not responsible for circumvention of any privacy settings or security measures
contained on or within the Services. We will make any legally required disclosures of any breach of the security,
confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable
state statutes on security breach notification) to you via email or conspicuous posting through the Services
in the most expedient time possible and without unreasonable delay, as consistent with (i) the legitimate
needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore
the reasonable integrity of the data system.
B. HIPAA Compliance
For the kinds of services we provide and the kinds of information we store, we have agreed with our customers to comply with
the privacy and security requirements of the Health Insurance Portability and Accountability Act (“HIPAA”).
14. “DO NOT TRACK” DISCLOSURES
Some state laws require us to indicate whether we honor “Do Not Track” settings in your browser concerning targeted advertising.
15. CONTACT INFORMATION
16. GOVERNING LAW
to the principles of conflicts of law of that state or any other jurisdiction.
you through any other Access Channels. Your continued use of the Services or communications with us through the
18. HOW TO CONTACT US