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Privacy Statement

Overview

We at Greenway Health, LLC™ (“Greenway”) want to be transparent about our use of Personal Information, and we are committed to maintaining the privacy and security of any Personal Information that we collect or maintain through greenwayhealth.com and our other websites and apps (together the “Sites” and, each a “Site”).  

This Privacy Statement describes the types of information that we may collect from you or that you may provide when you visit our Sites, along with information about how we collect, use, maintain, protect, and disclose that information.

Please read this Privacy Statement carefully to understand our policies and practices regarding your Personal Information. If you do not agree with any terms set forth in this Privacy Statement, you must immediately cease use of our Sites. By continuing to access or use our Sites, you agree to the terms set out in this Privacy Statement. 

“Personal Information” is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or members of your household.

This statement does not apply to any third-party content or websites that may be accessible through links on our Sites. Greenway is not responsible for the content or privacy practices of other sites. We encourage you to be aware when you leave our Sites or engage with media hosted by third parties and to read the privacy statements of any other website that collects your information.

Important Note for Patients: If you are using our patient-facing websites or applications to request healthcare records or submit health-related forms, please be aware that any Protected Health Information (“PHI”) you provide is handled in accordance with our legal obligations. We process PHI solely on behalf of and at the direction of your healthcare providers, in compliance with applicable privacy and security requirements under the Health Insurance Portability and Accountability Act (“HIPAA”) and our Business Associate Agreements with healthcare providers. While this Privacy Statement applies to your general interactions with our sites, review your healthcare provider’s “Notice of Privacy Practices” to understand how your PHI is used and disclosed and your rights under HIPAA.  

This Privacy Statement does not apply to our patient-facing websites and applications, our employees or job applicants. If you are a patient of a Greenway healthcare provider, a Greenway employee or a Greenway job applicant, please refer to the Privacy Statements on those respective websites.

Table of Contents

Personal Information We Collect and How We Collect It

How we Use Personal Information

How We Share Personal Information

How We Maintain and Protect Personal Information

Data Retention

Data Security

International Transfers

Your Choices About How We Use and Disclose Your Personal Information

U.S. State Privacy Rights

Cookies and Similar Tracking Technologies

Chatbot Functionality 

Greenway is a Service Provider

Children’s Data

Changes to this Privacy Statement

How To Contact Us

Personal Information We Collect and How We Collect It

We may collect the following categories of Personal Information about you:

  • Identifiers, such as your name, mailing address, email address, phone number, and account numbers. Typically, we collect this information from you directly to contact you regarding administrative notices, the Services, or your interactions with us, such as through an employment application.
  • Internet and other electronic activity information, such as your Internet Protocol (IP) address (which may tell us generally where you are located), language preference, browsing history, browser preferences, and type of device or system you use. Your browser may also tell us the time and date of your interactions with us or the Services, the page that led you to our Sites, or what you typed into a search engine that led you to our Sites. Typically, we collect this information through cookies and other data collection technologies to understand how you use our website.
  • Commercial information, such as financial and payment information, including credit card information. Typically, we collect this information from you to process payments for the Services or related to a business arrangement with you.
  • Information that you provide us, for example, when you create an account to use our Services, fill in forms, or submit documents on our Sites.

If you contact us about career opportunities, we may also collect additional Personal Information about you (in addition to the Personal Information listed above), as further described on our Careers Page of our Site

We collect Personal Information:

  • Directly from you, when you send us email messages, apply for a career opportunity, submit forms or feedback through our Sites, complete transactions through our Sites, or otherwise provide your information to us.
  • Automatically as you navigate our Sites, through cookies and similar data collection technologies, as further described below.
  • From third parties, including our marketing partners, recruiting partners, and background check providers.

How We Use Personal Information

We may use your Personal Information data for the following purposes:

  • Site Improvement. In order to provide you with a good user experience, we may use Personal Information to statistically analyze usage of our Sites, to improve our content and product offerings, and to customize our content, layout and services. We believe these uses allow us to improve our Sites and better tailor it to meet our visitors’ needs. We may also use web log information (such as your web browser, operating system, pages visited, etc.) to help us design our Sites, to identify popular features, and for other managerial purposes.
  • Communications. We may use Personal Information to communicate with you, provide you with information that you request, and to respond to your comments and questions.
  • Marketing and Advertising. We may use Personal Information about you to improve our marketing and promotional efforts, including delivering information to you that, in some cases, is targeted to your interests, and to market new products and services to you. We may also retarget you on third-party platforms.
  • Security. We may use Personal Information to authorize access to certain areas of the Sites, detect potential fraudulent use, and otherwise maintain the security of our Sites and safety of visitors.
  • Compliance with Law. We may use your Personal Information to respond to law enforcement requests, court orders and legal process, as well as to comply with any other applicable regulatory obligations. We may also use Personal Information to carry out our legal and contractual obligations and enforce our rights, or for any other purpose permitted by law or with your lawful consent.
  • De-identified Data. We may aggregate or de-identify, pseudonymize or anonymize Personal Information so that you cannot reasonably be identified and use such data for any lawful purpose.

How We Share Personal Information

We may disclose Personal Information in one or more of the following ways:

  • To our affiliates. We may share Personal Information with our affiliates, which are required to honor this Privacy Statement. Affiliates include our parent companies, private equity owners and any other subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.
  • To our service providers. We may share Personal Information with third parties that provide services to us. We may use third-party service providers to host the Sites, process job applications, perform website analytics, process payment transactions, authenticate or verify users, and gather and use on our behalf your Personal Information as contemplated by this Privacy Statement and applicable law. It is our policy to require such third parties to process your Personal Information only on our behalf to protect your information as much as is commercially reasonable.
  • In connection with a legal right or obligation. We may investigate and disclose Personal Information if we have a good faith belief that such investigation or disclosure is (a) reasonably necessary to comply with legal process and law enforcement instructions and orders, such as a search warrant, subpoena, statute, judicial proceeding, or other legal process served on us; (b) helpful to prevent, investigate, or identify possible wrongdoing in connection with the Sites; or (c) protect our rights, reputation, property, or that of our users, affiliates, or the public.
  • In a transaction. If we, or any of our businesses, are sold or disposed of as a going concern, whether by merger, reorganization, sale of assets or otherwise, or in the event of an insolvency, bankruptcy or receivership, any and all Personal Information, including your account information, may be one of the assets sold or merged in connection with that transaction. Information about you may also need to be disclosed in connection with a commercial transaction where we or any one of our businesses are seeking financing, investment, support or funding. In such transactions, Personal Information will be subject to the promises made in any pre-existing Privacy Statement in effect when the information was obtained.
  • With individuals to whom you direct us, such as your employer, colleagues, or references (such as in the case of a job application).
  • With your consent.

We may create, use, or disclose de-identified Personal Information only in accordance with applicable laws and so long as the entities to whom we disclose such de-identified data are prohibited from re-identifying or attempting to re-identify the information.

We do not sell your Personal Information to third parties in exchange for monetary or other valuable consideration. We may permit certain advertising and analytics partners to collect information through cookies and similar technologies, which may constitute ‘sharing’ under certain state privacy laws. You may opt out through our cookie preference center. 

How We Maintain and Protect Your Personal Information

  • Data Retention. We retain your Personal Information for only as long as we need it to provide our products and services, operate our business, and comply with our legal obligations. When we decide how long to keep your Personal Information, we keep in mind the nature and sensitivity of the information, the potential harm from unauthorized use, the reasons we collected the Personal Information, and our legal obligations. We collect only the Personal Information reasonably necessary for the purposes described in this notice.
  • Data Security. The security of your Personal Information is important to us. We have adopted safeguards to protect Personal Information from misuse, interference and loss, as well as from unauthorized access, modification or disclosure. These safeguards include:
  • Using encryption when collecting or transferring sensitive information
  • Limiting physical access to our premises
  • Limiting access to the information we collect about you
  • Ensuring that we and our business partners have appropriate security safeguards to keep Personal Information secure
  • Where required by law, destroying or de-identifying Personal Information

Communications between your browser and portions of the Sites containing Personal Information are protected with Secure Socket Layer (“SSL”) encryption. This encryption is to help protect your information while it is being transmitted. Once we receive your Personal Information, we use commercially reasonable efforts to maintain the physical and electronic security of such information.

NO DATA TRANSMISSION OVER THE INTERNET OR ANY WIRELESS NETWORK CAN BE GUARANTEED TO BE PERFECTLY SECURED. AS A RESULT, WHILE WE STRIVE TO PROTECT YOUR PERSONAL INFORMATION USING COMMERCIALLY AVAILABLE AND INDUSTRY STANDARD TECHNOLOGY, WE CANNOT ENSURE OR GUARANTEE THE SECURITY OF ANY INFORMATION YOU TRANSMIT TO US.

If we determine that your Personal Information has or may reasonably have been disclosed due to a security breach of our systems, we will notify you in accordance with and to the extent required by applicable law using the information that we have on file.

  • International Transfers. We may transfer your Personal Information among our affiliates and to our business partners, in connection with the purposes described in this Privacy Statement. This may involve the transfer of your Personal Information to countries outside your home country or region which may have a different level of data protection from your home country. Such countries may include, without limitation, the United States, India and other countries in which we, our affiliates, or our business partners maintain facilities. Where the destination country is not deemed to have an adequate level of protection for Personal Information, we will take steps to adequately protect the transfer of your Personal Information, including by entering into written contractual arrangements (as appropriate) with our affiliates and business partners for such transfers or rely on other legally approved transfer mechanisms. We take reasonable technical and organizational measures to safeguard Personal Information we transfer. For certain transfers, you have the right to obtain a copy of the appropriate safeguard entered into, you can obtain this by contacting us at the details provided at the end of this notice.

U.S. State Privacy Rights

Depending on your U.S. state of residency and subject to certain limitations and exceptions, you may have certain rights relating to your Personal Information, which may include some or all of the rights listed in this section below. Please note that these rights may not apply in your jurisdiction or may otherwise be limited by applicable law. The information in this section applies to certain states, which may include, but are not limited to the following state laws: the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act, and as may be further amended (collectively “CCPA”), the Colorado Privacy Act (CPA), the Delaware Personal Information Privacy Act (DPDPA), the Maryland Online Data Privacy Act (MODPA), the New Jersey Data Privacy Act (NJDPA), and the Oregon Consumer Privacy Act (OCPA) (collectively, “State Privacy Laws”).

Below we describe those rights, how to exercise those rights and provide additional information about your Personal Information.

  • Additional Information About Our Data Collection: We collect the categories of Personal Information described in this Privacy Statement from you and from your healthcare provider.  We use the Personal Information for the purposes described in this Privacy Statement.  The Personal Information we collect includes the following categories:  
  • Identifiers, such as your name, address, phone number, email address, and other similar identifiers. 
  • Personal data such as your medical, insurance or appointment records. 
  • Characteristics of protected classes under law, including gender, race and age. 
  • Sensitive Information, including race or ethnic origin, information concerning health, information concerning sex life or sexual orientation.  We only use sensitive Personal Information to provide you with the health-related materials you request and to perform related services on behalf of our business. 
  • Internet activity information, such as session logs of use of our platform.  However, as noted above, we do not gather information through third-party trackers placed on other sites. 
  • Sharing and Selling with Third Parties: We do not sell or share Personal Information with third parties, as defined under State Privacy Laws.  We only provide limited Personal Information to the sponsors of health-related materials on our Sites when you specifically request further material directly from the sponsor. 
  • Your Rights, How to Exercise Your Rights, and How to Contact Us: You, or your authorized agent, may exercise any of your State Privacy Law rights through the contact methods described below. Before we can implement your request, we’ll need to confirm your identity.  To allow us to confirm your identity, you will need to provide your name, date of birth, and home address. You may use an authorized agent to submit a request. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.
  • Right to Know and Access the Personal Information We Collect and Share: You have a right to request that we disclose the Personal Information we have collected about you, the categories of Personal Information we have collected, the sources of the Personal Information, and the purposes of the collection.  Much of that information is set forth in this Privacy Statement.  We will disclose and deliver the required information within 45 calendar days of receiving your request.  This 45-day period may be extended once by an additional 45 days when reasonably necessary, however we must give you notice of this extension.  You may make this request twice a year, free of charge. 
  • Right of Deletion: You may request that we delete the Personal Information we have collected about you, subject to certain legal exemptions. 
  • Right of Correction: You have a right to correct any inaccurate Personal Information we maintain about you. 
  • Right to Non-Discrimination: You have a right not to receive discriminatory treatment for the exercise of privacy rights conferred to you under State Privacy Laws.  
  • Right to Appeal: Certain laws may give you a right to appeal any denials of your request to exercise your rights. If we deny your request and you would like to submit an appeal, you can do so using the contact information provided below.
  • Retention: As described above, we retain your information for the period necessary to fulfill the purposes outlined in this Privacy Statement, unless a longer retention period is required or permitted by law. 
  • United Kingdom and European Economic Area: We do not provide services in the UK or EEA.  Greenway has a wholly owned subsidiary that provides limited services to entities outside the United States. However, we do not collect Personal Information to offer personalized health-related materials in those jurisdictions.  This Privacy Statement does not cover data handled outside the U.S.  

Consumer Health Data Privacy Notice

This Privacy Statement addresses how Greenway’s products, services and the Sites that collect and process Personal Information.  Under some state laws, some of this data is referred to as “consumer health data.”  These laws include Washington’s My Health My Data Act, Nevada’s Consumer Health Data Privacy Law, Connecticut’s Data Privacy Act, and other U.S. health privacy laws, as each are amended and as and when they become effective, including any regulations thereunder (collectively, “Consumer Health Data Laws”).   

If you are a consumer in a state with a Consumer Health Data Law and providing consumer health data to us, please refer to the separate Consumer Health Data Notice. 

Third party Sites

Our Sites may provide, or third parties may provide, links to other Sites or online resources. This Privacy Statement solely applies to our Sites. It does not apply to services offered by third parties, including Sites and other online services to which our Sites may display links. When you click on such links, you may be visiting Sites or interactive services operated by third parties who have their own information collection practices. We do not have control over how any third party collects or uses information, so we recommend that you review their privacy policies to learn about their practices.

Cookies and Similar Tracking Technologies

As you navigate through and interact with our Sites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns. 

  • What are cookies? Cookies are small files of information that are generated by a web server and sent to a user's device (web browser, phone, etc). Once there, they are stored either for a predetermined amount of time or for the duration of a browsing session. Cookies are often used to track a user’s behavior on a website, analyze his/her activity, to help deliver users with specific content, to ensure security, and many other useful things to keep a website running properly.  To find more information, please go to www.allaboutcookies.org.
  • What is our process for collecting information via the use of cookies?  As you navigate through and interact with our website, we may use automatic data collection technologies (like those set forth below) to collect certain information about your equipment, browsing actions, and patterns.  Some of the cookies on website are first-party cookies, meaning that we create and place them on your computer or device when you visit our site. Other cookies, known as third-party cookies, are placed on your computer or device when you visit or use our site, but are stored by service providers or third-party domains cookies and used to measure audiences, limit repeat advertisements to use, and customize content or advertising. We restrict the use of third-party cookies to trusted partners. These companies have their own privacy policies and data collection practices. There are two types of cookies that we use: session cookies and persistent cookies.
    • Session cookies are temporary and only last for as long as a single session, expiring automatically when you close your browser. 
    • Persistent cookies last longer, helping us to improve your navigation experience on our website(s). A persistent cookie enables us to recognize you as an existing user, so we can make it easier for you to return to our website(s) or interact with our services.

What type of information may we collect about you? 

  • Identifiers, such as your name, address, phone number, and information about your computer and internet connection (including your IP address, operating system, and browser type).
  • Customer records information, such as your name, address, phone number, credit card number, or government issued identification numbers.
  • Internet or other network activity information, such as details about your visits to Greenway’s Sites (including traffic data, location data, logs, and other communication data and the resources that you access and use on the website), applications, or advertisements, and which may include your preferences and/or characteristics.
  • Inferences, which may include creating a profile about you, reflecting personal preferences, characteristics, and behavior.
  • Geolocation data, such as your broad location information that is derived from your IP address.
  • Sensitive Information, such as personal identification numbers (driver’s license, passport), account log-in information, financial information combined with any security or access code, religious beliefs, and racial origin.

What types of technologies do we use? The technologies we use for automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our website.
  • Flash Cookies. Certain features of our website may use local stored objects (or Flash Cookies) to collect and store information about your preferences and navigation to, from, and on our website. Flash Cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our the website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Greenway, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Why do we use cookies?

The information we collect automatically is statistical data and may include personal information. It helps us to improve our website(s) and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our website(s) according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our website(s).
  • Enable certain functionality on our website(s).
  • To help maintain the safety, security, and integrity of our Sites and other technology assets.
  • For testing, research, analysis, and product development, including to develop and improve our Sites, products, and services.
  • Market or advertise solutions and services that may be of interest to you. 
  • Produce additional analytics. 

How do we use cookies?

  • Strictly Necessary Cookies: These cookies are essential for the operation of our website(s).  For example, they let us recognize that you have created an account, and have logged into that account to access our website content.  These also include cookies that enable us to remember your previous actions within the same browsing session, and to enhance the security of our website(s). Strictly necessary cookies ensure a consistent user experience and enable you to move around the website(s), as well as easily access its content and various features.
  • Analytical/Performance Cookies. These cookies are used by us and our web analytic service providers, such as Google Analytics and Marketo. They allow us to recognize and count the number of visitors to our website(s), and to see how visitors are moving around our website. These cookies track what pages are most frequently visited, and what locations our visitors come from. If you subscribe to a newsletter or otherwise register with our website(s), these cookies may apply to your usage.
  • Functional Cookies: These cookies enable us to recognize you when you return to our website(s). We use them to remember your choices and preferences, and to customize our content for you.
  • Targeting Cookies: These cookies are used to deliver online and digital advertising and marketing content, such as via email and on third-party sites and platforms that may be more relevant to your interests based on activity from your browsing activities across the internet. They may also be used to limit the number of times visitors see an advertisement and to help measure the effectiveness of advertising campaigns or for audience matching services to reach people (or people with similar characteristics) who have visited our website or are identified in one or more of our databases. We use targeting cookies. Although we do not serve third-party advertisements to you on our website, we do set targeting cookies on our sites to help us promote our solutions and services to you. We also allow certain third parties to place cookies on our website, and information collected via these cookies is used to provide you with information that may be of interest to you based on your activities on our website. 

Third-Party Cookies and Other Tracking Technologies

We utilize third-parties, such as Google Ads, Pendo Analytics or Marketo, to reach people who previously visited our website(s). These third parties may use your online data collected from your visits to our website(s) to target you with more personalized advertising content. Collection of your online data by third parties includes the use of cookies to serve ads based on your past visits to our website. Our third party vendors, including Google and Marketo, show our ads on sites across the Internet.  

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact them directly. 

You can opt out of Google's use of cookies by visiting the Google Marketing Platform opt-out page. 

You can opt-out from Marketo by unsubscribing through the unsubscribe or opt-out link in an email, or by unsubscribing via the Marketo Subscription Center at https://pages2.marketo.com/emailsubscription, or by sending an email to privacyofficer@marketo.com.  

You can also opt out of receiving targeted advertising from many providers, through the Network Advertising Initiative opt-out page.

We recognize browser-based opt-out preference signals, such as Global Privacy Control, where required by applicable law.

What are my cookie options?

Users can manage your cookies preferences via applicable pop-ups you will encounter on various pages of our website(s), including subsequent changes to your preferences. You can also adjust the setting of your Internet browser to reject the setting of all cookies, and to alert you when a cookie is placed on your device. You may also reach out to us based on the contact information options set out below. For more information about how to reject cookies, please refer to your Internet browser 'help'/'tool' or 'edit' section or see www.allaboutcookies.org.

Please be aware that if you elect to block all cookies (including strictly necessary cookies) you may not be able to access all of our Sites and/or certain functionality.

Can I delete previously stored cookies?

Yes, you can manually delete previously stored cookies at any time. Please note, however, this will not prevent our Sites (or our web analytic service providers, including Google Analytics, Pendo and Marketo) from placing further cookies on your device unless, and until, you adjust your Internet browser setting accordingly.

Where can I find more information about cookies?

You may learn more about cookies and how to opt out of them by visiting the following third-party website: www.allaboutcookies.org.

Chatbot Functionality

Through our Sites, you may interact with certain chatbot functionality. A “chatbot” or “bot” is a computer application that attempts to simulate human conversation, in order to allow people to interact with digital devices as if they were communicating with a real person. The data from the chats is retained for as long as the data is needed. Chat outputs or monitored and tested by humans for continuing accuracy. Chatbot functionality may be provided by a third party, and, therefore, such third party may have access to information about you based upon the information you disclose and/or your interaction with the chatbot. Additionally, through a chatbot tool, there may be links to third party Sites or content. These sites or content referenced in a chat may not be under Geenway’s control. If you visit one of those sites or interact with the third party content, your data may be subject to such third party’s policies and terms. We suggest that you do not submit Personal Information or other sensitive information into these chatbots.

HIPAA Compliance

As a key provider of services and technology to the healthcare industry, Greenway has implemented programs to address the transaction standards and the privacy and security requirements of the rules promulgated pursuant to the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). If you have any questions about HIPAA compliance at Greenway, you may send a request through any of the methods outlined below.

Children’s Data

Our Sites are not intended for children, which we consider to be an individual under the age of 13 or the equivalent age as specified by law under your jurisdiction. If you are a child as understood by laws of your state or country, do not provide any Personal Information to or on the Sites. We do not knowingly collect Personal Information from children. If we learn we have collected or received Personal Information from a child without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child, please contact us as provided below

Changes to This Privacy Statement

Greenway Health reserves the right to amend this Privacy Statement at our discretion and at any time. Unless otherwise noted, any such changes will be immediately incorporated into this Privacy Statement, and the “Date Last Updated” below will show when the latest changes were made. You should review the page often to ensure you have the most up-to-date information. Your continued use of our Sites following any changes indicates your consent to the terms and practices described in the most-current version of this Privacy Statement.

As related to any updates, Greenway may periodically make updates to describe how new Web features may affect our use of your information and to let you know of new controls and features that we may provide you. Greenway will NOT apply changes to this Privacy Statement retroactively to information Greenway has previously collected.

Contact Information

If you have any questions or comments about this Privacy Statement, including a request to receive this Privacy Statement in an alternative format, or the ways in which Greenway Health collects and uses your information, or any rights regarding such collection or use, you may contact us at:

Web Form link: https://www.greenwayhealth.com/consumer-privacy-request

Postal Address:
Greenway Health
Attn: Privacy Officer
4301 West Boy Scout Blvd, Suite 800
Tampa, Florida 33607

Greenway Health Privacy Statement

Last Updated: May 20, 2026

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