Smart Steps LLC Privacy Policy


Smart Steps LLC (the “Company”“we,” or “our”) is strongly dedicated to protecting the privacy of our customers’ personal information, which includes your personally-identifiable information (“PII”) and your Protected Health Information (“PHI”).

We are providing this privacy policy (“Privacy Policy”) in order to let you know how we collect, use, and disclose your personal information when you use our website, (the “Website”), when you use our mobile app, Smart Steps Mobile (the “MobileApp”), and when you contact or interact with your call center vendor(s) or Emergency Contacts which you have elected to enter into your MobileApp. (“Emergency Contact(s)”) (together, our “Services”).

For clarity, this Privacy Policy applies to your personal information (a) that we collect automatically from you when you use the Website or the MobileApp, (b) that you provide or disclose to us when you, on the Website or the MobileApp, register, complete a survey, post information, participate in a conversation, or otherwise choose to provide or disclose information to us or to the public on the Website or the MobileApp, (c) that you provide or disclose to your call center vendor(s) or Emergency Contacts when you call or interact with your third party call center vendor(s) or Emergency Contact(s), or (d) that you otherwise provide or disclose to us, a vendor(s), or with the public, either online or offline. App User acknowledge that a third party Company may, from time to time, monitor telephone communications for purposes of assuring quality and timeliness of responses.

The terms “App User”“you”“your”, or “user” as used herein refer to any individual or entity accessing or using the Services. Your use of any of the Services signifies your agreement with this Privacy Policy.


When you use the Services, we may collect PII, and sometimes PHI, from you. When you use the Website or the MobileApp, we may also automatically collect non-personally identifiable information from you.

PII that could be collected includes your full name, your address, your ZIP code, your photograph, your e-mail address, your telephone number, your credit card information, and other specific information that you volunteered to us when you set up your account and/or when you create or edit content in the app.

PHI information that could be collected includes specific information that identifies you, plus information about your physical or mental health or the medical care that you have or may receive. We would only collect this information if you voluntarily posted or disclosed it on the Website or the MobileApp or if you voluntarily disclosed it to us in conversation. You have the option to post information about yourself in the Notes box, which shows up on your Profile screen. You also have the option to store personal information when creating or editing a decision tree. You might indirectly disclose information with the Emergency Contacts that you choose to add to your account.

Non-personally identifiable information that could be automatically collected includes the IP address of your computer or mobile device, the make and model of your computer or mobile device, the type of web browser you are using, historical search data, information about your location (such as location information from your smart phone), and other electronic information. Such data is collected using cookies, web beacons, and other technologies. Your phone creates a ping on the server when working through a decision tree.


In general, we collect non-medical information from you so that we can more effectively serve you. Specifically, we may use the information in order to, among other things:

We will not rent or sell your information to third parties for marketing purposes. However, we may disclose:


When completing the User Profile, you may choose to enter Personal Health Information or you may share Personal Health Information when communicating with Smart Steps or a vendor/Emergency Contact by email or phone. Certain PHI about you is protected under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and applicable state law. We are required by law to maintain the privacy and confidentiality of PHI we collect, if any, and we operate the Company in accordance with state and federal laws governing the privacy and security of PHI. Smart Steps does not intentionally or routinely collect PHI.

SMART STEPS IS NOT A HEALTH CARE PROVIDER. If you receive medical or health care advice from a Health Care Provider, you should refer to your Health Care Provider’s Privacy Practices to obtain additional information about how your PHI may be accessed, used, and disclosed under HIPAA.

We may disclose PHI to courts or law enforcement agencies as required by law or legal process, and we may disclose PHI in life threatening situations or to protect the safety of any person.


We use “cookies” to collect information. Cookies are data files that are stored on your hard drive and that are used, generally, to improve your online experience. For example, cookies can be used save your user credentials for future logins, to enable certain features of the Website and the MobileApp, and to track your usage of the Website and the MobileApp. We also may work with third party contractors and vendors who will place or read cookies on your hard drive. You can set your web browser to stop accepting cookies or to warn you before it accepts cookies. However, if you do not accept cookies certain functionality of the Website and the MobileApp will not work.

We also may use web beacons to collect information. Web beacons are transparent graphic images placed on the Website or the MobileApp or in an email that tell us about your interactions with us. For example, a web beacon may tell us if you have opened an e-mail from us.


We have put in place industry-standard technology and administrative processes and privacy and security measures designed to safeguard and protect information under our control, including any PII or PHI, from unauthorized access, disclosure, or use. However, we cannot guarantee or warrant that such unauthorized access, disclosure, or use will never occur. You acknowledge and agree, therefore, that any information or communication that you send or transmit to us, or that is stored by us, is communicated, transmitted, and/or stored at your own risk.

We will make all legally required disclosures regarding any breach of security or confidentiality with regard to your PII. Any such required disclosures will be made by e-mail or by posting to the Website or the MobileApp, without unreasonable delay.


The Website and the MobileApp may contain hypertext links to third party websites. The opportunity to click on these links does not constitute an endorsement or representation regarding the content, security, privacy policies, or terms of use of these third party websites, nor is it a representation that we have any affiliation with these third party websites, and we disclaim any and all responsibility for such content, security, privacy policies, or terms of use. You should check the privacy policies of these other websites before you provide any personal information to them. You acknowledge and agree, therefore, that your use of any third party websites linked by hypertext to the Website or the MobileApp is at your own risk.


You may update, change, or delete some of the information you have previously provided to us. You may update your information through the Website.

The Website and the MobileApp may make available functionality that allows you to communicate online and to post or upload personal information, including PII and PHI. THE COMPANY IS NOT RESPONSIBLE FOR THE USE OF ANY PERSONAL INFORMATION, INCLUDING PII AND PHI, THAT YOU VOLUNTARILY SUBMIT THROUGH THE WEBSITE, THE MOBILEAPP, OR BY ANY OTHER USE OF THE SERVICES.

You understand and agree that all of the personal content, communications, and disclosures that you post or upload to the Website or the MobileApp, and that are visible to other users of the Website or the MobileApp becomes public information. In addition, you agree that by making such personal content, communications, and disclosures you grant to the Company a perpetual, irrevocable, worldwide, license to publish, display, copy, transmit, distribute, and otherwise use such personal content, communications, and disclosures in any media or medium and in any format now known or hereafter developed.

You agree that you will not use the Website or the MobileApp to post or upload any personal content, communications, or disclosures that violate or infringe upon any rights of any party, including, but not limited to, any person’s copyright, trademark, or other intellectual property rights. In addition, you agree that you will not use the Website or the MobileApp to post or upload any personal content, communications, or disclosures that are abusive, offensive, hateful, obscene, pornographic, or sexually explicit.


You may opt-out of receiving most communications from us by sending an e-mail to with the word UNSUBSCRIBE in the header or text. You can also click unsubscribe in the footer of emails. However, as long as your account is open you will be unable to opt-out of certain minimal communications from us, including policy updates and certain account and billing matters.


The Company may amend, modify, change, or remove this Privacy Policy, in whole or in part, at any time. All updated notices will be immediately posted to the web site and will be effective when posted. We will indicate the date of the most recent update. Your continued use of the Services following any amendment, modification, change, or removal shall constitute your acceptance thereof.


If you have any questions about this Privacy Policy, the Terms of Use, or any other practices or policies of the Company, you may contact us at Please note that given the nature of e-mail technology, your e-mail communications may not be secure, so you should not include any PHI, credit card, or other confidential information in your e-mails to us.

This Privacy Policy Was Last Updated on February 16, 2022.