Website Privacy Policy

We at Sky e-Clinic, LLC (“We”, “Us”, “the Company”, or “Sky e-Clinic”) value your (“You/Your”) privacy and are committed to keeping Your personal data confidential. This Privacy Policy describes how We collect, use, and disclose Your information in the context of providing the https://skyeclinic.org website, including all relevant content and functionality associated with the public website (collectively, the “Website”).

Privacy Policy Applicability

This Website Privacy Policy applies to personal data that Sky e-Clinic collects from users of the Sky e-Clinic public Website (“Personal Data”). The term “Personal Data” includes any information that can be used on its own or with other information in combination to identify or contact one of Our users. This Website Privacy Policy is focused on the public Website and non-clinical website interactions.

We believe that privacy and transparency about the use of Your Personal Data are of utmost importance. In this Website Privacy Policy, We provide You with detailed information about Our collection, use, maintenance, and disclosure of Your Personal Data on the Website. This Website Privacy Policy does not describe how We collect, use, maintain, or disclose Protected Health Information (“PHI”) in the context of providing clinical services, telehealth care, Patient Passport communications, prescriptions, laboratory orders, payment workflows, or medical records. Those clinical workflows are governed by Sky e-Clinic’s HIPAA Notice of Privacy Practices, clinical consent forms, and other patient-facing clinical documents.

The public Website is designed to be PHI-minimized. The public Website is not a clinical communication channel, clinical intake portal, emergency service, or substitute for Elation Patient Passport or another Sky-approved HIPAA-compliant clinical platform. Do not submit symptoms, diagnoses, medical history, medication information, prescriptions, laboratory results, medical images, date of birth, insurance information, payment-card information, or emergency requests through the public Website, public contact forms, ordinary email, LINE, SMS/text message, or other non-clinical channels. Clinical communications must occur through Elation Patient Passport or another Sky-approved HIPAA-compliant clinical platform.

For additional information related to how We use and disclose Your Personal Data please contact Our Privacy Officer at privacy-officer@skyeclinic.org.

Note regarding third-party sites: Our Website may contain links to other sites that are not operated by Sky e-Clinic. If You click a third-party link, You will be directed to that third party’s site. We strongly advise You to review every site You visit for the privacy policy(ies). Sky e-Clinic has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services. This Website Privacy Policy does not apply to Your use of or access to any third-party sites or services.

Agreement to Website Privacy Policy Terms

By accessing and/or using the WEBSITE, you are acknowledging that you have read and agree to the terms of this WEBSITE Privacy Policy. If you do not agree, you must immediately cease using the WEBSITE.

Website Privacy Policy Updates

Please note that We occasionally update this Website Privacy Policy, and it is Your responsibility to stay up to date with any amended versions. Any revisions to the Website Privacy Policy will be posted on the Website or otherwise made available through a reasonably appropriate notice method. Any changes to this Website Privacy Policy will be effective when posted or when otherwise stated in the updated notice. If You continue to use the Website following such notice, You are agreeing to those changes.

Questions or Concerns

If You have any questions or concerns after reading this Website’s Privacy Policy, please do not hesitate to contact Us at privacy-officer@skyeclinic.org. We appreciate Your feedback.

• What Personal Data Does Sky e-Clinic Collect?
• We collect three general types of information from Website users: (i) contact data; (ii) non-clinical support and inquiry data; and (iii) technology data. Each category of data is explained below. Sky e-Clinic does not intentionally collect clinical information or PHI through the public Website.
• Contact Data: Sky e-Clinic collects contact data from Website users only when You voluntarily provide it, which may include Your name, phone number, e-mail address, preferred language, and the content of a non-clinical inquiry. Depending on the feature You use, We may collect limited information needed to respond to a general inquiry, send a newsletter or other opt-in communication, or route You to an appropriate Sky-approved clinical platform. The public Website should not be used to submit symptoms or other clinical information.
• Support Data: If You contact Us for general support, billing, website, or administrative questions, We may collect information You provide and limited technical information from log files and other technologies, some of which may qualify as Personal Data (e.g., IP address). Such information will be used for troubleshooting, customer support, website security, improvement of the Website, and related administrative purposes. At launch, Sky e-Clinic does not use ordinary public Website channels for clinical support. Calls are not recorded or monitored unless Sky gives a separate notice or obtains consent where required by law.
• Technology Data: We use common information-gathering tools, such as log files, cookies, and similar technologies to automatically collect limited information from Your computer or mobile device as You navigate Our Website or interact with emails or other communications We have sent You. The information We collect may include Your IP address (or proxy server), device and application identification numbers, general location inferred from technical data, browser type, Internet service provider and/or mobile carrier, pages and files You viewed, Your operating system, system configuration information, and date/time stamps associated with Your usage. This information is used to analyze overall trends, help Us provide and improve Our Website, and ensure the proper functioning and security of the Website. Sky disables third-party analytics on Website routes that present higher health-context or PHI risk, as described below.
• How Does Sky e-Clinic Collect Personal Data?
• Website Engagement: Sky e-Clinic collects Personal Data through Your engagement with the Website, such as when You submit a non-clinical contact form, sign up to receive general information from Sky e-Clinic, sign up for a newsletter, or use administrative routing features that direct You to a Sky-approved clinical platform. The Website may ask for low-identifiability administrative information needed to determine whether a service pathway is available, such as general state/location selection, broad age category, visit type, preferred language, or service category. Such public-site routing is administrative only and is not clinical intake, diagnosis, or treatment.
• Job Opportunities: Sky e-Clinic does not collect job applications through the public Website at launch unless a specific careers or job-application feature is later added. If Sky later accepts job applications through the Website, application information may be used to assess skills and interests against career opportunities, communicate with applicants, and satisfy legal or reporting requirements.
• Browser or Device Information: Certain information is collected by most browsers or automatically through Your devices, such as computer or device type, screen resolution, operating system name and version, device manufacturer, model, language, and Internet browser type. We use this information to help ensure that the Website functions properly and securely.
• Clear GIFs / Web Beacons / Pixel Tags: Sky e-Clinic does not use retargeting pixels or session-replay tools on the Website at launch. Some permitted website analytics or email tools may use limited technologies such as web beacons or similar tools for aggregate usage or delivery statistics, but Sky does not use these tools to collect clinical information, and they are not loaded on Sky routes that are disabled for tracking due to health-context or PHI risk.
• SDKs and Mobile Advertising IDs: Sky e-Clinic does not operate a public mobile application and does not use mobile advertising IDs or mobile-app SDKs on the public Website at launch.
• Third-Party Plugins: The Website may include links to, embedded content from, or features provided by other companies. These third parties may collect information according to their own privacy policies. Sky e-Clinic does not permit third-party plugins to collect clinical intake information through the public Website. We strongly advise You to review the privacy policies of third-party sites and services You visit.
• Third-Party Online Tracking: Sky e-Clinic may use limited third-party analytics on general, non-clinical pages to understand Website traffic and improve the Website. Sky e-Clinic does not use Meta Pixel, TikTok Pixel, Google Ads remarketing, LinkedIn Insight Tag, Hotjar, FullStory, session replay, or similar advertising/retargeting technologies at launch. Sky disables Google Analytics or other third-party tracking on /start, service-specific pages, visit/intake-adjacent pages, pages carrying administrative routing codes, and any future page where the URL, page title, query string, or visible content could reveal a user’s clinical interest or health-care intent.
• What Is Sky e-Clinic’s Cookie Policy?
• Cookies are files that hold a small amount of data specific to a web application, which can later be used to help remember information entered, preferences selected, and movement within the application. We use cookies and similar technologies to operate and secure the Website, remember limited non-clinical preferences, and understand aggregate use of general Website pages.
• Our cookies do not, by themselves, contain clinical information or PHI. Further, We do not combine general public-Website cookie information with clinical information from Elation Patient Passport or another Sky-approved HIPAA-compliant clinical platform to identify You clinically. The public Website does not use cookies to access or manage Your Patient Passport account.
• Presently, Sky e-Clinic may use cookies for purposes including, but not limited to, operating the Website, maintaining Website security, remembering language or display preferences, and analyzing web traffic on general non-clinical pages using an analytics package. Analytics are disabled on pages and routes that Sky treats as higher health-context or PHI risk, including /start, service-specific pages, visit/intake-adjacent pages, and pages carrying administrative routing codes.
• How Can Users Opt-Out of Cookies?
• If You prefer, You can usually choose to set Your browser to remove and reject cookies. If You configure Your browser to prevent Us from collecting cookies, certain features of the Website may not operate correctly, and You may be unable to take advantage of some Website features. Browser settings do not control cookies or privacy settings inside third-party clinical platforms, such as Elation Patient Passport, which are governed by their own terms and privacy practices.
• Do Not Track Disclosure
• Some web browsers may transmit do not track (“DNT”) signals to websites with which the user communicates. To date, there is no industry standard for DNT, and users cannot know how a given company responds to a DNT signal they receive from browsers. Sky e-Clinic is committed to remaining apprised of DNT standards. However, Sky e-Clinic does not support DNT browser settings and does not currently participate in any DNT frameworks that would allow Sky e-Clinic to respond to signals or other mechanisms regarding the collection of Your personal information.
• How Will Sky e-Clinic Use Your Personal Data?
• Sky e-Clinic processes Your Personal Data based on legitimate business interests, the provision of the Website to You, compliance with Our legal obligations, and/or Your consent. We only use or disclose Your Personal Data when legally permitted, legally required, or where necessary to fulfill the purposes described in this Website Privacy Policy. Where required by law, We will ask for Your prior consent before disclosing Your Personal Data to a third party.
• More specifically, Sky e-Clinic processes Your Personal Data for the following legitimate business purposes:
• To provide the functionality of the Website to You.
• To respond to Your non-clinical inquiries and fulfill Your requests when You contact Us via one of Our online contact forms or when You send Us questions, suggestions, compliments, or complaints about Our Website.
• To send administrative information to You, such as a change in Our terms, conditions, and policies, and to fulfill the terms of any agreement You have with Sky e-Clinic.
• To provide You with Our newsletter and/or other marketing materials, including marketing-related emails with information about Sky e-Clinic’s services that are likely to be of interest to You, only where permitted by law and based on Your opt-in or other lawful basis.
• To manage and improve Our operations and the Website, including the development of additional functionality.
• To better understand aggregate Website usage and general interests so that We may improve the Website and provide clearer general information, while maintaining Sky’s PHI-minimized public-site design.
• To respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings and court orders.
• To protect Our rights, privacy, safety, or property, and/or that of You or others by providing proper notices, pursuing available legal remedies, and acting to limit Our damages.
• To handle technical support and other requests from You; and
• To keep Our Website safe and secure.
• Sky e-Clinic may aggregate and/or anonymize Personal Data collected through the Website so that it will no longer be considered Personal Data. We do so to generate other data for Our use, which We may use and disclose for any purpose if it no longer identifies You or any other individual.
• Does Sky e-Clinic Use Personal Data for Analytics?
• Sky e-Clinic uses limited third-party service providers to monitor and analyze the use of general, non-clinical Website pages. The analytics services and techniques We may use include, but are not limited to, Google Analytics. At launch, Google Analytics and similar third-party tracking technologies are disabled on /start, service-specific pages, visit/intake-adjacent pages, pages carrying administrative routing codes, and any future page where the URL, page title, query string, or visible content could reveal a user’s clinical interest or health-care intent.
• Where Is Personal Data Processed?
• The Personal Data We collect through the Website is generally stored and processed in the United States or through service providers that support Sky’s Website operations. Personal Data may be transmitted to third parties that help operate the Website or provide related services, subject to the safeguards and contractual obligations applicable to those relationships. Clinical PHI submitted through Elation Patient Passport or another Sky-approved HIPAA-compliant clinical platform is governed by Sky e-Clinic’s HIPAA Notice of Privacy Practices and applicable Business Associate arrangements, not solely by this Website Privacy Policy.
• With Whom Does Sky e-Clinic Share Personal Data?
• We may share Your personal information with the following categories of individuals/entities:
• Business Partners and Vendors: We share Personal Data with a limited number of partners, service providers, and other persons/entities who help run Our business (“Business Partners”). Specifically, We may employ third-party companies and individuals to facilitate Our Website, provide services on Our behalf, perform Website-related functions, or assist Us in analyzing how Our Website is used. These may include website hosting, domain/DNS services, email services, contact-form services, newsletter services, analytics services for general non-clinical pages, and information-technology support. Our Business Partners are expected to protect Your Personal Data and to use it only for the limited purpose(s) for which it is shared.
• Our Advisors: We may share Your Personal Data with third parties that provide advisory services to Sky e-Clinic, including, but not limited to, Our lawyers, auditors, accountants, and banks (collectively, “Advisors”). Personal Data will only be shared with Advisors if Sky e-Clinic has a legitimate business interest in the sharing of such data.
• Third Parties Upon Your Direction or Consent: You may direct Sky e-Clinic to share Your Personal Data with third parties. Upon Your request and consent, We may share such Personal Data with those third parties that You identify.
• Third Parties Pursuant to Business Transfers: In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Sky e-Clinic’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings), We may share Your Personal Data with a third party.
• Government and Law Enforcement Authorities: If reasonable and necessary, We may share Your Personal Data to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that violate this Website Privacy Policy; or (iii) bring legal action against someone who may be causing intentional or unintentional injury or interference to the rights or property of Sky e-Clinic or any third party, including other users of Our Website.
• How Long Does Sky e-Clinic Retain Personal Data?
• Sky e-Clinic retains Your Personal Data only if necessary and as required for Our business operations, the provision of the Website, archival purposes, and/or to satisfy legal requirements. The exact period of retention will depend on: (i) the length of time in which You use the Website; (ii) the personal risk of harm for unauthorized use or disclosure; (iii) the purposes for which We process Your Personal Data, including whether those purposes can be achieved through other means; and (iv) business operations and legal requirements. Non-clinical public contact-form submissions are retained only as long as reasonably needed for the inquiry, unless a longer period is required for legal, security, or business reasons.
• Except where requested by Sky e-Clinic through a Sky-approved HIPAA-compliant clinical platform, We ask that You do not send to Us through the public Website or otherwise disclose to Us through public/non-clinical channels any sensitive Personal Data, including social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometric or genetic characteristics, criminal background, trade union membership, symptoms, diagnoses, medications, laboratory results, medical images, date of birth, insurance information, payment-card information, or emergency requests.
• At the end of the applicable retention period, We will remove Your Personal Data from Our databases and will require that Our Business Partners remove any identifiable Personal Data from their databases. If there is any data that We are unable to delete entirely from Our systems for technical reasons, We will put in place appropriate measures to prevent any further processing of such data. Please note that once We disclose Your Personal Data to third parties, We may not be able to access that Personal Data and We cannot force the deletion or modification of such information by third parties.
• What Happens to Personal Data Submitted by Minors?
• Sky e-Clinic does not knowingly collect Personal Data from individuals under the age of 18 through the public Website without involvement of a parent or legal guardian. The Website may be used by a parent or legal guardian seeking general information or administrative routing on behalf of a minor patient, but the public Website should not be used to submit the minor’s symptoms, medical history, date of birth, images, medications, or other clinical information. If We learn that Personal Data from a user under the age of 18 has been collected through the public Website without appropriate authorization, We will take reasonable measures to promptly delete such data from Our records. If You are aware of a user under the age of 18 accessing the Website without appropriate parent or guardian involvement, please contact Us at privacy-officer@skyeclinic.org.
• If You are a resident of California under the age of 18 and have disclosed Personal Data to Us, You may ask Us to remove content or information that You have submitted through or to Our Website.

• What Rights Do Users Have Concerning Their Personal Data?
• As a user of Sky e-Clinic’s Website, You have certain rights relating to Your Personal Data. These rights are subject to local data protection and privacy laws and may include the right to:
• Access Personal Data held by Sky e-Clinic
• Erase/delete Your Personal Data, to the extent permitted by applicable data protection and privacy laws and to the extent technologically feasible
• Receive communications related to the processing of Your Personal Data
• Restrict the processing of Your Personal Data to the extent permitted by law
• Object to the further processing of Your Personal Data, including the right to object to marketing
• Request that Your Personal Data be transferred to a third party, if possible
• Receive Your Personal Data in a structured, commonly used, and machine-readable format; and/or
• Rectify inaccurate personal information and, considering the purpose of processing the Personal Data, ensure it is complete.
• If You do not want to receive emails from Sky e-Clinic, You may unsubscribe at any time by clicking on the “Unsubscribe” link in each email communication or You may contact Us at privacy-officer@skyeclinic.org. Please note that if You opt-out of marketing emails, We may still send You important administrative messages, from which You cannot opt-out.
• Where the processing of Your Personal Data by Sky e-Clinic is based on consent, You have the right to withdraw that consent at any time. If You would like to withdraw Your consent or exercise any of the above rights, please contact Us at privacy-officer@skyeclinic.org.
• How Can Users Update, Correct, or Delete Personal Data?
• You have the right to request restrictions on the uses and disclosures of Your Personal Data. While We are not required to agree to all restriction requests, We will attempt to accommodate reasonable requests when appropriate.
• If You need to make changes or corrections to Website Personal Data, You may contact Us at privacy-officer@skyeclinic.org. To comply with certain requests to limit the use of Your Personal Data, We may need to terminate Your ability to access and/or use some or all of the Website. Requests involving medical records, Patient Passport content, or PHI are governed by Sky e-Clinic’s HIPAA Notice of Privacy Practices and applicable clinical-record procedures.
• You have the right to request the deletion of any Personal Data retained by Sky e-Clinic. To request deletion of Your Personal Data, please email Us at privacy-officer@skyeclinic.org and include a description of the Personal Data You would like removed. We will respond to all requests for data deletion as soon as reasonably possible.

• Is Personal Data Secure?
• Sky e-Clinic understands the importance of data confidentiality and security. We use a combination of reasonable physical, technical, and administrative security controls to (i) maintain the security and integrity of Your Personal Data; (ii) protect against any threats or hazards to the security or integrity of Your Personal Data; and (iii) protect against unauthorized access to or use of such information in Our possession or control that could result in substantial harm to You.
• While Sky e-Clinic uses reasonable security controls, we cannot guarantee or warrant that such techniques will prevent unauthorized access to your personal DATA. SKY E-CLINIC IS UNABLE TO GUARANTEE THE SECURITY OR INTEGRITY OF PERSONAL DATA TRANSMITTED OVER THE INTERNET, AND THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. ACCORDINGLY, WE DO NOT AND CAN NOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US. You assume the risk that unauthorized entry or use, hardware or software failure, and other factors may compromise the security of your personal DATA at any time.
• What Safeguards Does Sky e-Clinic Have in Place to Secure Personal Data?
• Sky e-Clinic uses a combination of reasonable safeguards to protect Your Website Personal Data. Such safeguards may include authentication, encryption, access controls, vendor management, and PHI-minimization controls that keep clinical information inside Sky-approved HIPAA-compliant clinical platforms rather than the public Website.
• How Can Users Protect Their Personal Data?
• Sky e-Clinic has no access to or control over Your device’s security settings, and it is Your responsibility to implement any device-level security features and protections You feel are appropriate (e.g., password protection, encryption, remote wipe capability). We recommend that You take all appropriate steps to secure any device that You use to access Our Website.
• Please note that Sky e-Clinic will never send You an email requesting confidential information, such as account numbers, usernames, passwords, Social Security Numbers, symptoms, diagnoses, medication information, or payment-card details. If You receive a suspicious email from Sky e-Clinic, please notify Us at privacy-officer@skyeclinic.org.
• Further, if You know of or suspect any other security concern, please notify Sky e-Clinic immediately.
• What If Sky e-Clinic Experiences a Data or Security Breach?
• Sky e-Clinic takes the security of Your Personal Data seriously. In the event of a data or security breach, Sky e-Clinic will take the following actions: (i) promptly investigate the security incident, validate the root cause, and, where applicable, remediate any vulnerabilities within Sky e-Clinic’s control which may have given rise to the security incident; (ii) comply with laws and regulations directly applicable to Sky e-Clinic in connection with such security incident; (iii) as applicable, cooperate with any affected Sky e-Clinic user or client in accordance with the terms of Sky e-Clinic’s contract with such user or client, and (iv) document and record actions taken by Sky e-Clinic in connection with the security incident and conduct a post-incident review of the circumstances related to the incident and actions/recommendations are taken to prevent similar security incidents in the future. Sky e-Clinic will notify You of any data or security breaches as required by and in accordance with applicable law.

• If You are a California resident, the California Consumer Privacy Act (“CCPA”) and related California privacy laws may apply to You to the extent Sky e-Clinic is subject to those laws and the information is not otherwise governed by HIPAA or another applicable exemption.
• Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask for and obtain from Us an annual list identifying the categories of personal customer information which We shared, if any, with Our affiliates and/or third parties in the preceding calendar year for marketing purposes. This list will be provided free of charge. Contact information for such affiliates and/or third parties must be included. If You are a California resident and would like a copy of this notice, please submit a written request to the following address:
• Sky e-Clinic, LLC
• 1164 Bishop St, Suite 940
• Honolulu, HI 96813

• Depending on what state You live in, You may have rights in addition to the rights listed above. These rights may include:
• Right to access a copy of Your Personal Information.
• Right to correction of Your Personal Information.
• Right to delete Your Personal Information from Our Services.
• Right to receive Your Personal Information in a structured, commonly used and machine-readable format.
• Right to opt out of certain uses of Your Personal Information.
• Right to prohibit Our collection of Personal Information if it isn’t relevant and necessary to providing You Services.
• If You would like to learn more and/or exercise one or more of these rights, please contact Us at privacy-officer@skyeclinic.org.