Privacy Policy

INTRODUCTION

Gemini Health, LLC (“Gemini Health” or “Gemini”) respects the privacy of every person who receives our services. Therefore, Gemini Health has developed this Privacy Policy in accordance with industry standards and state and federal laws and requirements.

This Policy explains what information Gemini Health collects and how we use that information. It also outlines how you can verify the accuracy of this information, and how you can request that we delete, change or update your information. We want to assure you that Gemini Health has a strong commitment to protect your information and that we are always held to the highest standards to safeguard that data.

Thanks for allowing us the opportunity to serve you.

WHO WE ARE

Gemini Health is the leader in Drug-Cost Decision Support Services. We provide drug cost transparency, based on patient-specific benefit information, as well as therapeutically-equivalent, lower-cost drug alternatives to help provide lower drug cost choices for patients, provider groups, and payers.

We are based in the United States, with offices, employees, and operations across the country. Contact information for our Corporate Office is listed below. Gemini is a Business Associate of companies that are mainly considered Covered Entities. In some instances, Gemini Health may redirect any inquiries about individual data to that Covered Entity.

INFORMATION WE COLLECT

Our primary goal in collecting personal data is to provide decision making support to prescribers by sharing the present cost of chosen or existing medications and then providing lower-cost, therapeutically-equivalent drug alternatives, based on patient-specific benefits.

Personal Data

To determine patient costs of chosen or existing drugs and to find lower-cost, therapeutically-equivalent drug alternatives, Gemini Health uses patient identifiers that include:

Name (last, first)
Date of birth
Address
Telephone numbers
Prescribing Provider
Preferred Pharmacy
Prescription medication history
Medical benefit IDs
Pharmacy benefits IDs
Medical record IDs
Pharmacy Benefit Manager IDs

Patients may opt out of providing any or all of this data at any point-in-time, however, they will be unable to receive the benefits of our services.

HOW WE USE PATIENT INFORMATION

Personal Data

We use personal data about our clients’ patients to deliver decision-support services to prescribers in an effort to lower drug costs for patients, for provider groups, and for payers.

Aggregate and Statistical Data

Gemini Health may use patient data in an aggregated and in a de-identified¹ manner for marketing our services to clients.

LEGAL BASIS OF PROCESSING

We collect and process personal data where we have a business need and follow all lawful state and national requirements.

In a majority of the cases, processing personal information is based on:

Consent

Collecting and processing patient data for clients with whom the patient has provided their consent.

Contractual obligations

We collect only the minimum information needed to conduct contracted obligations to our clients.

Legal compliance

In certain circumstances we may be required by law to share personal information with legal authorities. In such cases the patient will be notified.

Legitimate interest

In some situations, we may require patient data to pursue our legitimate interests in a way that might reasonably be expected as part of conducting our business that does not materially impact patient rights, freedom or interests and is in accordance with state and federal laws.

HOW WE PROTECT PATIENT INFORMATION

Gemini Health is committed to keeping the data clients provide us secure and we take all reasonable and required precautions to protect patient personal data from loss, misuse or alteration.

Vendors, contractors, and business associates of Gemini Health who have access to patient personal data are bound by the same standards as Gemini Health and in accordance with federal and state laws.

HOW LONG WILL WE RETAIN PATIENT PERSONAL DATA?

Gemini Health will only keep patient information as long as necessary to complete the purpose for which it was collected or as long as required by federal or state laws.

At the end of that retention period, patient data will either be returned to the Client, destroyed, or rendered unrecognizable as required by federal or state laws.

HOW WE MAY SHARE PATIENT DATA

Gemini Health will not share, trade or sell personal data for use by any business, except for the purposes stated herein. However, aggregated and statistical patient information may be shared with our partners in a manner that does not identify patients personally.

We may share personal data with service providers or contractors that perform services for us and act at our direction. The services they provide may include such activities as direct mailing, fulfillment services, or e-mail campaigns but only when a patient has agreed to receive such services.

We also may share personal data with our business partners that provide joint offerings with us. When we do, such business partners are restricted in using personal data to provide only the services patients have agreed to.

Gemini Health may share patient personal data with any person or company that acquires Gemini Health’s business or any portion of the Gemini Health business to which patient personal data relates. Gemini Health will ensure that any person or company to which patient personal data is transferred agrees to abide by the same privacy obligations as Gemini Health.

Gemini Health also reserves the right to share personal data to respond to duly authorized information requests from governmental authorities or where required by Federal or State law.

Gemini may also share personal data in responding to requests from law enforcement officials, government bodies or judicial authorities to address matters of personal or public safety, national security, litigation, investigations (including data security incident investigations), and other legal matters where the data is lawfully requested.

CROSS-BORDER DATA TRANSFERS

Gemini Health has developed global data privacy and security practices designed to ensure that patient personal data is appropriately handled and protected. Personal data may be transferred, accessed and stored globally as necessary for the uses and disclosures stated above in accordance with this policy, and any Federal, State or International laws.

WHAT ARE PATIENTS RIGHT OVER PERSONAL DATA?

Patients have a right to change patient data and a right to change data use privileges given to any provider of services.

For further information around these rights, please consult Health Information Privacy at:

https://www.hhs.gov/hipaa/for-individuals/guidance-materials-for-consumers/index.html

You can also send Gemini Health a request to exercise the right to access, correct, or remove patient personal data by contacting us at any time at [email protected].

If you send us a written request to access, correct, or remove patient personal data or to remove you from a database, we will forward your request to our Client that gave us this data. We will engage with them to fulfill your request.

CONTACT INFORMATION

Patient privacy is very important to Gemini Health.

If you have any questions that we have not answered in this policy, please contact our Privacy Officer who will be pleased to help you:

• Email us at [email protected]
• Or write to us at:

Gemini Health
Attn: Privacy Officer
2 Alexander Ave.
Sausalito, CA 94965

UPDATES

Gemini Health may update this Privacy Policy from time to time. When we update this Privacy Policy, we will post the changes on our website and applications.

We encourage you to check this Privacy Policy regularly for changes.

Unless otherwise noted, any changes we make to this Privacy Policy will become effective immediately once posted.

Please note the effective date indicated below for the latest revision.

Continued use of the Services following any changes to this Privacy Policy indicates consent to the practices described in the revised Privacy Policy.

Date of Last Update: 24-April-2023

¹ De-identification is the process used to prevent a person’s identity from being connected with other information. For example, data produced during human subject research might be de-identified to preserve research participants’ privacy.

² De-identification is the process used to prevent a person’s identity from being connected with information. For example, data produced during human subject research might be de-identified to preserve research participants’ privacy.