Services Privacy Policy

We may obtain the Personal Information listed above from the following categories of sources:

• Directly from you. For example, when you: 
  
  • register yourself with the Platform;
  • track appointments, events, or other tasks;
  • upload documents or photos;
  • chat with other family members or caregivers within the Platform; 
  • fill out or complete any forms or other free-text fields on the Platform;
  • connect the Platform with any third party software or platforms that are supported;
  • subscribe to one of our e-newsletters; or
  • otherwise communicate with us, such as contacting us for more information. 
• Indirectly from you. For example, through information we collect from you in the course of providing our services to you.‍
• Directly and indirectly from activity on the Platform. For example, from Platform usage details that are collected automatically. For more information on automatic information collection, please review the “Automated Information Collection” section below.

5. AUTOMATED INFORMATION COLLECTION

In addition to the information that you provide to us, we may also collect information about you during your visit to the Platform. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Platform. Some of the tools we use to automatically collect information about you may include:

1. Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:

1. session cookies, which do not stay on your device after you close your browser, and 
2. persistent cookies, which remain on your device until you delete them or they expire.  
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We may use the following categories of cookies on the Platform. 

1. Strictly Necessary Cookies.  These cookies are essential in order to enable you to move around the Platform and use its features. Without these cookies, services you have requested cannot be provided.
2. Performance Cookies.  These cookies collect anonymous information on how you use the Platform to help us understand how you arrive at the Platform, browse or use the Platform and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
3. Functionality Cookies.  These cookies remember choices you make such as the country from which you visit the Platform, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to the Platform more tailored to your preferences. The information in these cookies may be anonymized.  These cookies cannot track your browsing activity on other websites.
4. Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign.  The cookies are usually placed by third-party advertising networks.  These cookies remember the websites you visit and that information is shared with other parties, such as advertisers.
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2. Analytics Partners.  Analytics cookies help us improve our Platform by collecting and reporting information on how you use it. We may partner with service providers to provide us with analytics services. Our service providers collect information such as how often users visit the Platform, what pages they visit and when they do so, and what other sites they used prior to coming to the Platform. We use the information we get from our service providers only to improve our Platform.
3. Google Tag Manager. The Platform uses, and sends user information to, Google Tag Manager for the purpose of providing us with the ability to conduct technical and statistical analysis on the Platform’s performance. For more information on how Google Tag Manager supports the Platform and uses information sent from the Platform, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites and Google’s data privacy practices for Google Tag Manager at https://support.google.com/tagmanager/answer/9323295?hl=en.
4. Web Beacons.  A Web Beacon is an electronic image.  Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior.  If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails.  We may also use them to track if you click on the links and at what time and date you do so.  Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on the Platform.  This information is only collected in aggregate form and will not be linked to your Personal Information.  Please note that any image file on a webpage can act as a Web Beacon.
5. Embedded Web Links.  Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link.  The tracking is accomplished through a redirection system.  The redirection system allows us to understand how the link is being used by email recipients.  Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you.  This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.
6. Third-party Websites and Services.  We work with a number of service providers of marketing communications technology.  These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide.  The information collected can be gathered on the Platform and also on the websites where our marketing communications are appearing.  For example, we may collect data where our banner advertisements are displayed on third-party websites.
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In addition to the information that you provide to us, we may also collect information about you during your visit to our Application. We collect this information using automated technology.  This technology may collect information about your behavior and your device, such as your internet address (IP Address), the pages you have viewed, the actions you have taken while using the Application, saved preferences, and log-in Session ID. You can manage how your mobile device or your mobile browser share information with us, as well as how your mobile device or your mobile browser handles cookies and related technologies by adjusting your mobile device privacy and security settings. Please refer to instructions provided by your mobile service provider or the manufacturer of your device to learn how to adjust your settings. 

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings.  However, by disabling cookies on your device, you may be prohibited from full use of the Platform features or lose access to some functionality. For more information about internet browsers, please refer to this “All About Cookies” guide. For more information about trackers, including information about how to manage and delete trackers, please visit the ICO’s website.

The third-party advertisers, ad agencies and other vendors with which we work may be members of the Network Advertising Initiative (NAI), the Digital Advertising Alliance (DAA) Self-Regulatory Program for Online Behavioural Advertising and/or the European Digital Advertising Alliance (eDAA). To opt out of certain advertising from the participating companies, please visit AboutAds.info or the European Digital Advertising Alliance for laptops and NAI Mobile Choices or AppChoices for mobile devices. Note that opting out through these channels does not mean you will no longer see ads and is specific to the device and browser you are using. You will still receive other types of ads from these companies, and any type of ad from nonparticipating companies. The sites you visit may still collect your information for other purposes.

6. HOW WE USE YOUR INFORMATION

The information we gather and that you provide is collected to provide you information and the services you request, in addition to various other purposes, including, but not limited to: 

• providing the products and services you request from us;
• security, credit or fraud prevention purposes;
• providing you with effective customer service;
• providing you with a personalized experience when you use the Platform;
• developing new products and services;
• to provide you support when responding to your questions, concerns, complaints, or other requests;
• to process your payments for your subscription or other purchases;
• contacting you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
• contacting you with information and notices related to your use of the Platform;
• inviting you to participate in surveys and providing feedback to us (in accordance with any privacy preferences you have expressed to us);
• better understanding your needs and interests;
• improving the content, functionality and usability of the Platform;
• improving our products and services;
• improving our marketing and promotional efforts; and
• any other purpose identified at the point of data collection, in an applicable privacy notice, in a click-through agreement or in any other agreement between you and us. 

Duration. The length of time Company intends to retain Personal Information, including sensitive personal information, if any, is for as long as reasonably necessary to carry out Company’s intended business purpose for such information.  

7. HOW WE DISCLOSE YOUR INFORMATION

We do not sell or lease your Personal Information to any third party.  We may disclose your Personal Information to a third party for a business purpose, including the following categories of third parties: 

• Our Affiliates. We may disclose the information collected through the Platform with our affiliates, service providers, and other related entities in order to provide our products, services and effective customer support.
• Third-party Service Providers. We disclose Personal Information collected through the Platform with third-party Service Providers who act for or on behalf of the Company. These third parties may need information about you to perform their functions. “Service Providers” may include suppliers, dealers, distributors, companies and consultants that provide website hosting, software development, payment processing, website and data analytics, order fulfillment, information technology and related infrastructure support, customer service, email delivery, and auditing.
• Your Members. As part of our services on the Platform, you may add members to your Circle or provide certain individuals with access to your information. These individuals may include your family members, friends, or other caregivers (“Members”). We may disclose your information with your approved Members, or your approved Members may have access to your information. Company is not responsible or liable for any uses of your information or your content by your Circle Members.
• In Aggregate or De-Identified Form. We may aggregate or otherwise anonymize the data we collect for purposes of analytics, research, marketing and other business interests of the Company.  Such use shall not include Personal Information or information that can identify you as an individual or reasonably be used to identify you.

Except as described in this Policy, we will not disclose your information with third parties without your notice and consent, unless it is under one of the following circumstances:  

• Legal Reasons
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  • We believe that disclosure is reasonably necessary to comply with any applicable law, regulation, subpoena, or court order;
  • To respond to duly authorized information requests from law enforcement or other governmental authorities;
  • To enforce our agreements or policies;
  • To investigate and prevent security threats, fraud, or other malicious activity; or
  • To respond to an emergency that we believe in good faith requires us to disclose such information to assist in preventing the death or serious bodily injury of any person or Company employee.

• Sale of Business or Merger. There are circumstances where the Company may decide to buy, sell, or reorganize its business. Under these circumstances, it may be necessary to disclose or receive Personal Information with prospective or actual purchasers, acquisition targets, partners or affiliates. In such circumstances, the Company will ensure your information is used in accordance with this Policy.

8. YOUR CHOICES AND SELECTING YOUR PRIVACY PREFERENCES

We want to provide you with relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertains to such information. 

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed.  Transactional or service-oriented messages, such as delivery confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide goods and services, and are not intended for the purposes of marketing.

From time to time, we may send you email newsletters and marketing emails.  You may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email.  Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided. Even if you opt-out of receiving marketing material, we may still need to contact you with important information about your account or responding to your requests or questions.

9. TEXT MESSAGING 

You may have the opportunity to receive SMS or "text" messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties.  Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested.  In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number.  In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us.  You further acknowledge that: (a) no purchase is required to opt into this service; (b) you may opt out at any time by following the instructions provided in our communications to you; and (c) your receipt of text messages may result in separate charges from your mobile provider. 

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

10. ACCURACY AND ACCESS TO YOUR PERSONAL INFORMATION

We strive to maintain and process your information accurately.  We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements.  We employ technologies designed to help us maintain information accuracy on input and processing. 

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security.  We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.  

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

11. INFORMATION OF MINORS

We do not knowingly collect or use information from individuals under the age of thirteen (13) without parental or guardian consent.  We do not target the Platform to minors, and would not expect them to be engaging with the Platform or our services.  We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet.  If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems. 

12. FEEDBACK 

We welcome inquiries or feedback on the services or products you might use or like to use. Any inquiries, feedback, suggestions, or ideas you provide to us (collectively, “Feedback”) will be treated as non-proprietary and non-confidential. Your Feedback on or through the Platform may be available to others who visit the Platform. In addition, we may use your Feedback in advertising campaigns and other promotions. We may or may not use your name in connection with such use, and we may or may not seek your consent before using the Feedback for such purposes. Therefore, you should have no expectation of privacy with respect to your Feedback on or through the Platform. You should not submit any content you do not wish to make available to the general public, and you must take special care to make sure your Feedback comply with our Services Terms and Conditions or other applicable agreements. All terms and conditions of our Services Terms and Conditions apply to Feedback on or through the Platform. In particular, your Feedback must not violate the privacy or other rights of others. You may not use false identifying information or contact information, impersonate any person or entity, or otherwise mislead us as to the origin of any Feedback.

13. THIRD-PARTY WEBSITES 

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Platform may link to third-party websites and services. For example, if you click on an advertisement on the Platform, you may be taken to another website that we do not control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.  

14. YOUR RIGHTS UNDER STATE LAW

California.

• Shine the Light law.  Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.  
• Do Not Track Signals.  Other than as disclosed in this Policy, the Platform does not operate any differently when it receives Do Not Track signals from your internet web browser.
• WE DO NOT SELL OR SHARE YOUR PERSONAL INFORMATION. If we ever decide to “sell” or “share” Personal Information, as those terms are defined under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, we will update you via this Policy and include a link entitled “Do Not Sell or Share My Personal Information,” to provide you with an opportunity to opt out of the selling or sharing of your Personal Information. 

Nevada.

Nevada law permits customers in Nevada to opt-out of the sale of certain kinds of Personal Information. We do not sell your Personal Information to third parties as defined in Nevada law. If you are a Nevada resident and wish to opt-out of the sale of your Personal Information, should we change our practices in the future, you can contact us at [email protected].

Your Consumer Rights. 

Some state laws in the United States provide consumers with additional rights with respect to their Personal Information (also known as “personal data”), as those terms are defined under those applicable state laws. Such state laws may include, but are not limited to, the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020, the Colorado Privacy Act, the Connecticut Data Privacy Act, the Delaware Personal Data Privacy Act, the Iowa Consumer Data Protection Act, the Maryland Online Data Privacy Act, the Minnesota Consumer Data Privacy Act, the Montana Consumer Data Privacy Act, the Nebraska Data Privacy Act, the New Hampshire Data Privacy Act, the New Jersey Data Privacy Act, the Oregon Consumer Privacy Act, the Tennessee Information Protection Act, the Texas Data Privacy and Security Act, the Utah Consumer Privacy Act, and the Virginia Consumer Data Protection Act (collectively, the “U.S. State Privacy Laws"). Any Personal Information we collect is collected for the commercial purpose of effectively providing our services to you, as well as enabling you to learn more about, and benefit from, our services. If you reside in a state that provides additional rights with respect to your Personal Information, you may exercise each of your rights as identified below, subject to our verification of your identity.

1. Access.  You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. 
2. Correction.  You can correct what personal data the Platform database currently contains by contacting us to request that we correct or rectify any personal data that you have provided to us. 
3. Limit Use and Disclosure of Sensitive Personal Information. If we collect any sensitive personal information, you have the right to request that we limit the use of the sensitive personal information to that use which is necessary to perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
4. Portability.  Upon request and when possible, we can provide you with copies of your Personal Information. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.
5. Deletion.  You have the right to request that we delete any of your Personal Information, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. Where applicable, we will ensure such changes are shared with trusted third parties.
6. Opt-out of Processing. You have the right to request that we do not sell your Personal Information, use your Personal Information for Targeted Advertising, or use your Personal Information for profiling. Where applicable, we will ensure such changes are shared with trusted third parties.
7. Non-Discrimination. If a consumer exercises his or her rights under applicable U.S. State Privacy Laws, we shall not discriminate against that data subject by denying our goods or services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our goods or services, or taking any other adverse action. 
8. Exercising your rights. If you are a consumer that has rights under applicable U.S. State Privacy Laws who chooses to exercise the rights listed above, you can: 

1. Submit a request via email at [email protected]; or
2. Call us at +1 (888) 629-8058 to submit your request. 

Only you, or someone legally authorized to act on your behalf, may make a request related to your Personal Information. If an authorized agent makes a request on your behalf, we may require proof that you gave the agent permission to submit the request.   

Responding to Your Request. Upon receiving your request, we will confirm receipt of your request by sending you an email confirming receipt. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the Personal Information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.

We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. You may have the right to appeal our decision regarding your request. If you would like to appeal our decision, please contact us using the contact information provided above.

In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.

15. LOCATION OF OUR WEBSITE AND SERVICES

We do not warrant or represent that this Policy or the Platform’s use of your Personal Information complies with the laws of every jurisdiction.  Furthermore, to provide you with our services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours.  Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

16. SAFEGUARDING THE INFORMATION WE COLLECT

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information against accidental loss and from unauthorized access, use, alteration, and disclosure.  However, we can never promise 100% security.  You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password.  If you believe your credentials have been compromised, please change your password. Please also notify us immediately of any actual or suspected unauthorized use of the Platform or your information. 

17. CHANGES TO THIS POLICY

This Policy describes our current policies and practices with regard to the information we collect through the Platform. We are continually improving and adding to the features and functionality of the Platform along with the products and services we offer through the Platform. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

18. HOW TO CONTACT US

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please contact us by email at [email protected].