FreeLab: Privacy Policy
FreeLab respects the privacy of users of this site. To better protect your privacy, we are providing this Policy to explain our on-line information practices and the way that we may collect and use information obtained from you. FreeLab may update this Policy without notice to you.
Privacy Policy Coverage:
This policy covers how FreeLab handles personal data, including information related to your use of our site. Personal information includes information about you that is personally identifiable like your name, address, email address, or phone number, project information, and that is not normally available publicly. This policy does not apply to companies that FreeLab does not own or control.
Information We Collect:
In general, some information is collected automatically like your IP address, country, and the pages you request. This information is not attached to your name or any other personal information. This data is only collected to analyze our site's usage in order to improve navigation and offer more popular content.
We only collect personal information when you request information, or a quotation using our online request form, or email us for any other reason.
When you choose to provide us with personally identifiable information, FreeLab will act in a responsible manner. FreeLab will maintain your personally identifiable information in secure on-line and off-line facilities. FreeLab may store and disclose personally identifiable information as allowed or required by applicable law. We may make disclosures that are necessary or advisable to protect the rights, safety or property of FreeLab or others, to conform to legal or regulatory requirements or to investigate or prevent violations of our Terms and Conditions. Except as set forth above, FreeLab will not disclose, sell, lease or rent your personally identifiable information.
If your personally identifiable information changes, or if you no longer want FreeLab to maintain your information, this can be accomplished by sending us an e-mail to info@angusgenomics.com or by sending your request to:
Webmaster
FreeLab Inc.
8939-00300 Ronald Ngala Street
Nairobi, Kenya
FreeLab will send a confirming e-mail to your last known e-mail address of the changes or deletion of your personally identifiable information.
Cookies and Log Files:
A cookie is a piece of data stored on your hard drive that may contain information about you. FreeLab may use cookies on this Site to provide better navigation for you on this Site. Additionally, you may still use this Site even if you reject the cookie. Cookies, however, may be used by some of the Web sites to which we link. Therefore, please review the Links section of this Policy below. In addition, we may use your Internet Protocol (IP) address to analyze trends, administer this Site and gather broad demographic information for aggregate use in order to improve this Site. We will not link any IP addresses that we may collect to any personally identifiable information. We may use multiple third parties to monitor traffic, statistics, advertisement click-through and other activities on this Site. Such third parties may use cookies, log files, beacons and other monitoring technologies to compile anonymous aggregate statistics on this Site's visitors.
Links:
On this Site, you may have the opportunity to follow a link from or to other web sites maintained by third parties. Because these other Web sites may not be hosted or controlled by FreeLab, we are not responsible for the privacy practices of those Web sites. The privacy policies of other Web sites may differ from FreeLab, and we encourage you to review the privacy policies of the Web sites to which we may link. This Policy only applies to information collected and maintained by FreeLab, its subsidiaries and affiliates.
Your Consent:
By using the FreeLab web site, you are consenting to our collection and use of both automatically and voluntarily collected information. If we change or update our policy, you will find the changes here.
HIPAA Information
FreeLab’s Notice of Privacy Practices
This Notice Describes How Medical Information About You May Be Used And Disclosed And How You Can Get Access To This Information. Please Review It Carefully.
This Notice of Privacy Practices applies to Bioinformatics Institute of Kenya and all of its subsidiaries and business units (collectively referred to as "FreeLab" in this Notice), except to the extent that a subsidiary, division, or business unit of FreeLab performs occupational screening, forensic tests, paternity/identity tests, clinical trials tests or other services that do not involve standard electronic transactions for which the Ministry of Health (MOH) has adopted standards.
FreeLab's Protection of Protected Health Information (PHI)
FreeLab is committed to the protection of your protected health information (PHI) and will make reasonable efforts to ensure the confidentiality of your PHI, as required by Kenyan law. We take this commitment seriously and will work with you to comply with your right to receive certain information under Kenyan laws, The Data Protection Act 2019, and The Health Insurance Portability and Accountability Act of 1996 (HIPAA).
FreeLab's Use and Disclosure of PHI,
The following categories explain the types of uses and disclosures of PHI that FreeLab may make. Some of the uses and disclosures described may be limited or restricted by Kenyan laws or other legal requirements.
- For treatment — FreeLab may use or disclose PHI for treatment purposes, including disclosure to physicians, nurses, medical students, pharmacies, and other health care professionals who provide you with health care services and/or are involved in the coordination of your care, such as providing your physician with your laboratory test results.
- For payment — FreeLab may use or disclose PHI to bill and collect payment for laboratory or genetic counseling services we provide. For example, FreeLab may provide PHI to your health plan to receive payment for the health care services provided to you.
- For health care operations — FreeLab may use or disclose PHI for health care operations purposes. These uses and disclosures are necessary, for example, to evaluate the quality of our laboratory testing, accuracy of results, accreditation functions and for FreeLab’s operation and management purposes. FreeLab may also disclose PHI to other health care providers or health plans that are involved in your care for their health care operations. For example, FreeLab may provide PHI to manage disease, or to coordinate health care or health benefits.
- Appointment reminders and health-related benefits and services — FreeLab may use and disclose PHI to contact you as a reminder that you have an appointment with us and may use and disclose PHI to tell you about health-related benefits and services that may be of interest to you. For example, FreeLab may contact you about a new patient service center in your area or about new testing services available at FreeLab based on services ordered by your physician.
- Disclosure of PHI to you — FreeLab may disclose PHI to you or as directed by you to a third party. Your right to see and receive a copy of your PHI is listed below under patient rights regarding PHI.
- Emergency circumstances and notifications — If you are present and capable, FreeLab will obtain your agreement to use and/or disclose PHI about you during an emergency event to notify, or assist in the notification of a family member, your personal representative, or another person responsible for your care regarding your location, general condition, or death. Otherwise, FreeLab may exercise its professional judgement based on the circumstances and use and disclose PHI for your safety.
- Individuals involved in your care or payment for your care — FreeLab may disclose PHI to a person who is involved in your care or helps pay for your care, such as a family member or friend. We also may notify your family about your location or general condition or disclose such information to an entity assisting in a disaster relief effort. As allowed by Kenyan law, we may disclose the PHI of minors to their parents or legal guardians.
- Business associates — FreeLab may disclose PHI to its business associates to perform certain business functions or provide certain business services to FreeLab. For example, we may use another company to perform billing services on our behalf. All of our business associates are required to maintain the privacy and confidentiality of your PHI. In addition, at the request of your health care providers or health plan, FreeLab may disclose PHI to their business associates for purposes of performing certain business functions or health care services on their behalf. For example, we may disclose PHI to a business associate of Medicare for purposes of medical necessity review and audit.
- Disclosure for judicial and administrative proceedings — Under certain circumstances, FreeLab may disclose your PHI in the course of a judicial or administrative proceeding, including in response to a court or administrative order, subpoena, discovery request, or other lawful process.
- Law enforcement — FreeLab may disclose PHI for law enforcement purposes, including reporting of certain types of wounds or physical injuries or in response to a court order, warrant, subpoena or summons, or similar process authorized by law. We may also disclose PHI when the information is needed: 1) for identification or location of a suspect, fugitive, material witness or missing person, 2) about a victim of a crime, 3) about an individual who has died, 4) in relation to criminal conduct on FreeLab premises, or 5) in emergency circumstances to report a crime, the location of the crime or victims, or the identity, description, or location of the person who committed the crime.
- As required by law — FreeLab must disclose your PHI if required to do so by federal, state, or local law.
- Public Health — FreeLab may disclose PHI for public health activities. These activities generally include: 1) disclosures to a public health authority to report, prevent or control disease, injury, or disability; 2) disclosures to report births and deaths, or to report child abuse or neglect; 3) disclosures to a person subject to the jurisdiction of the Food and Drug Administration (FDA) for purposes related to the quality, safety or effectiveness of an FDA-regulated product or activity, including reporting reactions to medications or problems with products or notifying people of recalls of products they may be using; 4) disclosures to notify a person who may have been exposed to a disease or may be at risk for contracting or spreading a disease or condition; and 5) disclosures to an employer about an employee to conduct medical surveillance in certain limited circumstances concerning work-place illness or injury.
- Disclosure about victims of abuse, neglect, or domestic violence — FreeLab may disclose PHI about an individual to a government authority, including social services, if we reasonably believe that an individual is a victim of abuse, neglect, or domestic violence.
- Health oversight activities — FreeLab may disclose PHI to a health care oversight agency for activities authorized by law such as audits, civil, administrative, or criminal investigations and proceedings/actions, inspections, licensure/disciplinary actions, or other activities necessary for appropriate oversight of the health care system, government benefit programs, and compliance with regulatory requirements and civil rights laws.
- Coroners, medical examiners, and funeral directors — FreeLab may disclose PHI to a coroner, medical examiner, or funeral director for the purpose of identifying a deceased person, determining cause of death, or for performing some other duty authorized by law.
- Organ and Tissue Donation — If requested, FreeLab may disclose PHI to organizations that handle organ procurement, or eye and tissues donation banks, or other health care organization as needed to make organ and tissue donation and transplantation possible.
- Personal Representative — FreeLab may disclose PHI to your personal representative, as established under applicable law, or to an administrator, executor, or other authorized individual associated with your estate.
- Correctional institution — FreeLab may disclose the PHI of an inmate or other individual when requested by a correctional institution or law enforcement official for health, safety, and security purposes.
- Serious threat to health or safety — FreeLab is allowed to disclose PHI when it has a good faith belief that the disclosure (1) is necessary to prevent or lessen a serious and/or imminent threat to the health or safety of the patient or others and (2) is to a person or persons reasonably able to prevent or lessen the threat.
- Research — FreeLab may use and disclose PHI for research purposes. Limited data or records may be viewed by researchers to identify patients who may qualify for their research project or for other similar purposes, so long as the researchers do not remove or copy any of the PHI. Before we use or disclose PHI for any other research activity, one of the following will happen: 1) a special committee will determine that the research activity poses minimal risk to privacy and that there is an adequate plan to safeguard PHI; 2) if the PHI relates to deceased individuals, the researchers give us assurances that the PHI is necessary for the research and will be used only as part of the research; or 3) the researcher will be provided only with information that does not identify you directly.
- Government functions — In certain situations, FreeLab may disclose the PHI of military personnel and veterans, including Armed Forces personnel, as required by military command authorities. Additionally, we may disclose PHI to authorized officials for national security purposes, such as protecting the President of the Kenya, conducting intelligence, counter-intelligence, other national security activities, and when requested by foreign military authorities. Disclosures will be made only in compliance with Kenyan Law.
- Workers’ compensation — As authorized by applicable laws, FreeLab may use or disclose PHI to comply with workers’ compensation or other similar programs established to provide work-related injury or illness benefits.
- De-identified Information and Limited Data Sets — FreeLab may use and disclose health information that has been “de-identified” by removing certain identifiers making it unlikely that you could be identified. FreeLab also may disclose limited health information, contained in a “limited data set”. The limited data set does not contain any information that can directly identify you. For example, a limited data set may include your city, county and zip code, but not your name or street address.
Other Uses and Disclosures of PHI
For purposes not described above, including uses and disclosures of PHI for marketing purposes and disclosures that would constitute a sale of PHI, FreeLab will ask for patient authorization before using or disclosing PHI. If you signed an authorization form, you may revoke it, in writing, at any time, except to the extent that action has been taken in reliance on the authorization.
Additional Safeguards and Protections
FreeLab employs additional safeguards for PHI that is subject to protection under other Kenyan laws, for example, relating to mental health, HIV/AIDS, and genetic testing. Alcohol and drug treatment programs are subject to restrictions on the use and disclosure of alcohol and drug abuse treatment information. As applicable, FreeLab will obtain your permission before disclosing the information to other health care providers who are not involved in your treatment program or care.
Information Breach Notification
FreeLab is required to provide patient notification if it discovers a breach of unsecured PHI unless there is a demonstration, based on a risk assessment, that there is a low probability that the PHI has been compromised. You will be notified without unreasonable delay and no later than 60 days after discovery of the breach. Such notification will include information about what happened and what can be done to mitigate any harm.
Patient Rights Regarding PHI
Subject to certain exceptions, HIPAA establishes the following patient rights with respect to PHI:
- Right to Receive a Copy of the FreeLab Notice of Privacy Practices — You have a right to receive a copy of the FreeLab Notice of Privacy Practices at any time by contacting us at privacyofficer@freelab.co.ke, calling us at +254716335266/734972158 or by sending a written request to: Bioinformatics Institute of Kenya, Kenbelt Business Park, Old Mombasa Road, P.O. BOX 106148-00101, Nairobi, Kenya. This Notice will also be posted on the FreeLab Internet site at www.freelab.co.ke
- Right to Request Limits on Uses and Disclosures of your PHI — You have the right to request that we limit: 1) how we use and disclose your PHI for treatment, payment, and health care operations activities; or 2) our disclosure of PHI to individuals involved in your care or payment for your care. FreeLab will consider your request, but is not required to agree to it unless the requested restriction involves a disclosure that is not required by law to a health plan for payment or health care operations purposes and not for treatment, and you have paid for the service in full out of pocket. If we agree to a restriction on other types of disclosures, we will state the agreed restrictions in writing and will abide by them, except in emergency situations when the disclosure is for purposes of treatment.
- Right to Request Confidential Communications — You have the right to request that FreeLab communicate with you about your PHI at an alternative address or by an alternative means. FreeLab will accommodate reasonable requests.
- Right to See and Receive Copies of Your PHI — You and your personal representative have the right to access PHI consisting of your laboratory test results or reports ordered by your physician. You can access your electronic reports by logging in to our portal at any time. You have the right to access and receive your PHI in an electronic format if it is readily producible in such a format. You also have the right to direct FreeLab to transmit a copy to another person you designate, provided such request is in writing, signed by you, and clearly identifies the designated person and where to send the copy of your PHI. Within 30 days after our receipt of your request, you will receive a copy of the completed laboratory report from FreeLab unless an exception applies. Exceptions include a determination by a licensed health care professional that the access requested is reasonably likely to endanger the life or safety of you or another person, and our inability to provide access to the PHI within 30 days, in which case we may extend the response time for an additional 30 days if we provide you with a written statement of the reasons for the delay and the date by which access will be provided.To request a copy of your PHI:
- Ask for a courtesy copy when you visit a FreeLab patient service center for specimen collection.
- Ask a FreeLab patient service technician for information on how to open a FreeLab patient portal account to receive your laboratory reports electronically.
- Complete the FreeLab HIPAA Patient Request Form.
- Contact the Privacy Officer at +254716335266 or by e-mail at privacyofficer@freelab.co.ke
- Right to Receive an Accounting of Disclosures — You have a right to receive a list of certain instances in which FreeLab disclosed your PHI. This list will not include certain disclosures of PHI, such as (but not limited to) those made based on your written authorization or those made prior to the date on which FreeLab was required to comply. If you request an accounting of disclosures of PHI that were made for purposes other than treatment, payment, or health care operations, the list will include disclosures made in the past six years, unless you request a shorter period of disclosures. If you request an accounting of disclosures of PHI that were made for purposes of treatment, payment, or health care operations, the list will include only those disclosures made in the past three years for which an accounting is required by law, unless you request a shorter period of disclosures.
- Right to Correct or Update your PHI — If you believe that your PHI contains a mistake, you may request, in writing, that FreeLab correct the information. If your request is denied, we will provide an explanation of the reasoning for our denial.
How to Exercise Your Rights
To exercise any of your rights described in this notice, you must send a written request to: HIPAA Privacy Officer, Bioinformatics Institute of Kenya, Kenbelt Business Park, Old Mombasa Road, P.O. BOX 106148-00101, Nairobi, Kenya. Except, patients may update insurance and/or billing information through our website or by contacting the Patient Billing Department using the phone number indicated on the billing invoice.
How to Contact Us or File a Complaint
If you have questions or comments regarding the FreeLab Notice of Privacy Practices, or have a complaint about our use or disclosure of your PHI or our privacy practices, please contact: privacyofficer@freelab.co.ke , call us at +254716335266 and ask for the FreeLab HIPAA Privacy Officer, or send a written request to: HIPAA Privacy Officer, Bioinformatics Institute of Kenya, Kenbelt Business Park, Old Mombasa Road, P.O. BOX 106148-00101, Nairobi, Kenya.
Changes to the FreeLab Notice of Privacy Practices
FreeLab reserves the right to make changes to this notice and to our privacy policies from time to time. Changes adopted will apply to any PHI we maintain about you. FreeLab is required to abide by the terms of our notice currently in effect. When changes are made, we will promptly update this notice and post the information on the FreeLab website at www.freelab.co.ke. Please review this site periodically to ensure that you are aware of any such updates.
Effective Date of Notice: June 1, 2022