Last updated [EFFECTIVE DATE — set on approval]
1. Who We Are & What This Policy Covers
This Privacy Policy explains how [LEGAL ENTITY NAME], doing business as Wheelchair Transport Service (“WTS,” “we,” “our,” or “us”), collects, uses, shares, and protects personal information when you visit our website, book or ride in our vehicles, contact us, use our Partner Portal, or apply for a job. It should be read with our Terms of Service. If you are a patient or rider, certain health information we hold may also be covered by the Health Information section below.
2. Information We Collect
Depending on how you interact with us, we may collect:
- Identifiers and contact details — name, address, phone number, email address.
- Trip information — pickup and drop-off locations, appointment and scheduling details, trip history, and booking preferences.
- Health and mobility information — medical transport requirements, mobility equipment, and health-related details necessary for safe transport.
- Billing and payer information — insurance or Medicaid details, payment information, and billing history.
- Account and security information — login credentials and multi-factor authentication details for Partner Portal and account users.
- Communications — messages, form submissions, live-chat conversations, and records of calls and emails with us.
- Website usage data — device and browser type, IP address, pages viewed, and approximate location, collected through cookies and analytics tools.
- Employment information — if you apply for a job, the information you submit through our hiring system (see Section 9).
3. How We Collect Information
- Directly from you — when you book a trip, submit a form, call, chat, create an account, or apply for a job.
- From others involved in your care or payment — such as hospitals, facilities, physicians, care coordinators, insurers, and Medicaid programs that request or authorize your transportation.
- Automatically — through cookies and similar technologies when you use our website, and through vehicle systems described in Section 8.
4. How We Use Your Information
- Schedule, coordinate, dispatch, and complete your transportation requests
- Process payments, insurance claims, and Medicaid billing
- Communicate with you about your bookings, including confirmations, ETAs, and service updates
- Provide customer support and respond to your requests and complaints
- Maintain the safety and security of our riders, drivers, vehicles, website, and systems
- Improve our website and service offerings, including through analytics you have allowed
- Comply with applicable laws and regulations, including HIPAA where applicable, and respond to legal process
- Evaluate and manage job applications
5. Health Information & HIPAA
As a transportation provider working with medical patients, WTS takes the protection of health information seriously. [COUNSEL TO CONFIRM WTS’S HIPAA STATUS AND SELECT THE APPLICABLE TEXT: (a) WTS is a covered entity and handles protected health information under HIPAA and our Notice of Privacy Practices, available at [LINK]; and/or (b) WTS acts as a business associate of facilities and payers and handles protected health information under business associate agreements.] Health-related information is used and disclosed only as permitted by HIPAA, other applicable federal and Florida law, and any agreements we have with you or the facility that requested your trip. We do not sell or rent your protected health information. Please do not send sensitive health details through the website chat or unsecured forms.
6. How We Share Information
We may share your information with:
- Medical facilities, physicians, or care coordinators as needed to complete your transport
- Insurance providers and Medicaid programs for billing and authorization purposes
- Subcontractors and independent contract drivers who assist us in providing services, under confidentiality obligations
- Service providers who process data on our behalf (such as website analytics, live-chat, form, hosting, and hiring-system providers), under agreements that limit their use of the data to the services they perform for us — see Section 7
- Law enforcement, regulators, or other parties when required by law or to protect rights, safety, and property
- A successor organization if WTS is involved in a merger, sale, or reorganization, subject to this Policy
We do not sell your personal information, and we do not share it with third parties for their own cross-context behavioral advertising.
7. Cookies, Analytics & Third-Party Services
Our website uses cookies and similar technologies (including browser local storage). We group them into the categories below, and you control the optional ones through our cookie consent banner. Strictly necessary cookies are always active because the site cannot function without them; every other category is off until you opt in.
- Strictly necessary — required for the site to work, including your session, security (CSRF protection), remembering your cookie choice, and your theme (light/dark) and accessibility display settings. These are always on: they only control how the page looks in your browser, and are never used for tracking or shared with anyone.
- Analytics — help us understand how visitors use the site so we can improve it. We use Google Analytics, a service provided by Google LLC, which sets its own cookies and may process usage data (such as pages viewed and approximate location derived from your IP address). Google’s handling of this data is described in the Google Privacy Policy.
- Live chat — loads a third-party chat widget, provided by 8x8, Inc., so you can message us directly from the site. 8x8 processes the messages and contact details you choose to share in the chat; its handling of that data is described in the 8x8 Privacy Policy. Please do not share sensitive health information through chat.
These optional services are loaded only after you consent to the relevant category. You can accept all, reject all non-essential categories, or choose category by category. To change or withdraw your choices at any time, use the “Cookie Preferences” link in the website footer. You can also block or delete cookies in your browser settings, though some features of the site may be affected.
Our contact and booking forms are provided through a third-party form service, and our job listings are provided through a third-party hiring system (PrismHR Hire); information you submit there is processed by those providers on our behalf and under their own privacy terms. [CONFIRM ALL PROVIDERS.]
Do Not Track and Global Privacy Control. [CONFIRM: the site honors browser Global Privacy Control signals as an opt-out of optional cookies.] Because there is no common standard for “Do Not Track” signals, we respond to them only as described here.
We may add other analytics or interactive third-party services in the future; when we do, they will be added to the appropriate category above and will remain subject to your consent choices.
8. Vehicle Technology, Location & Recordings
[CONFIRM WITH WTS BEFORE PUBLISHING; DELETE IF NOT APPLICABLE.] Our vehicles may be equipped with GPS tracking and in-vehicle safety technology, which may include cameras that record video inside and outside the vehicle, to support rider and driver safety, quality, dispatch, and the live trip tracking offered to facilities through the Partner Portal. Where audio is recorded, we will give notice as required by law. Calls to our dispatch and office lines may be recorded or monitored for quality and safety, and we will tell you if a call is being recorded. Recordings and location data are used for the purposes in Section 4, kept for [RETENTION PERIOD], and shared only as described in Section 6.
9. Careers & Job Applicants
If you apply for a position, we and our hiring-system provider collect the information you submit, such as contact details, work history, education, licenses and certifications, and, where lawful and relevant to driving positions, driving records and background-check results. We use it to evaluate your application, verify qualifications, and meet legal obligations, and we may keep it for [APPLICANT RECORD RETENTION PERIOD]. Background checks are conducted only with your authorization and in compliance with applicable law.
10. How Long We Keep Information
We keep personal information only as long as needed for the purposes in this Policy, including to complete and document trips, meet billing, Medicaid, insurance, tax, and regulatory record-keeping requirements, resolve disputes, and enforce our agreements. [RETENTION PERIODS BY CATEGORY TO BE CONFIRMED — for example trip and billing records, health-related records, recordings, website analytics, and applicant data.] When information is no longer needed, we delete or de-identify it, subject to legal holds.
11. Data Security
We implement industry-standard administrative, technical, and physical safeguards to protect your information from unauthorized access, disclosure, alteration, or loss, including SSL/TLS encryption in transit, access controls, and multi-factor authentication for accounts. No method of transmission or storage is completely secure, so we cannot guarantee absolute security. If a breach affects your personal information, we will notify you and regulators as required by applicable law, including Florida’s data breach notification statute.
12. Your Privacy Choices & Rights
You may have the right to:
- Request access to the personal information we hold about you
- Request correction of inaccurate information
- Request deletion of your information, subject to legal and record-keeping obligations
- Withdraw consent for optional cookies at any time through “Cookie Preferences”
- Opt out of non-essential email and text communications
- Receive a copy of your information in a portable format, where applicable law provides
To make a request, contact us using the information in Section 17. We may need to verify your identity before acting, and we will respond within the time required by applicable law [CONFIRM — typically 30–45 days]. We will not discriminate against you for exercising your rights. Patients may also have separate rights over their protected health information under HIPAA. [COUNSEL TO ADD STATE-SPECIFIC DISCLOSURES IF REQUIRED — e.g., Florida Digital Bill of Rights, California, or other states, depending on whether WTS meets applicability thresholds.]
13. Children’s Privacy
Our website is not directed to children under 13, and we do not knowingly collect personal information from them through the website. We transport minors only when a parent, guardian, or other authorized adult books the trip and provides the necessary information. If you believe a child has submitted information to us through the website, please contact us and we will delete it.
14. Third-Party Links
Our website may link to third-party websites and services, including the Partner Portal, forms, the hiring system, and map services. We are not responsible for their privacy practices, and we encourage you to read their policies.
15. Communications Preferences
We send transactional messages about your trips by phone, text, and email as described in our Terms of Service. You can opt out of text messages by replying STOP and of marketing emails by using the unsubscribe link or contacting us. Opting out will not stop trip-critical notices for an active booking.
16. Changes to This Policy
We may update this Privacy Policy periodically. Any changes will be posted on this page with a revised effective date. For material changes, we will make reasonable efforts to provide additional notice, and where required we will seek your consent.
17. Contact Us
For privacy-related questions, requests, or concerns, contact [PRIVACY CONTACT / TITLE] at contact@wheelchairtransport.com or call (727) 586-2811. Mailing address: [LEGAL MAILING ADDRESS].