(47 minute read)
THE INFORMATION WE COLLECT
In providing Concierge Health Apps, we collect, store and use the following Information relating to you:
“Information” is Personal Information and Non-Personal Information; “Personal Information” is any information or combination of information that relates to you or a Connected Person, and can be used to identify you or a Connected Person. We set out examples of Personal Information (and how we collect such Personal Information) in the “How we collect Information via Concierge Health Apps” section below. “Location Data” is information that we collect regarding your location (when you use a location-enabled service), including:
technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access Concierge Health Apps, your IP address and your device’s version and identification number; information about what you have searched for and looked at while using Concierge Health Apps, such as search terms used, social media profiles visited and details of other information and content accessed or requested by you in using Concierge Health Apps; information about communications you have made using Concierge Health Apps, such as the people you’ve communicated with and the time, data and duration of your communications; and metadata, which means information related to items you have made available through Concierge Health Apps, such as the date, time or location that a shared photograph or video was taken or posted. “Non-Personal Information” is any information that relates to you but from which it is not reasonably practicable to directly or indirectly identify you, including Personal Information in aggregated, anonymized or pseudonymised form. “Shared Information” is information about you or relating to you that is voluntarily shared on Concierge Health Apps. Shared Information may include postings that you make on Concierge Health Apps (including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device’s camera and/or microphone sensor). Shared Information also includes information about you (including Location Data and Log Data) that others who are using Concierge Health Apps share about you.
HOW WE COLLECT INFORMATION VIA Concierge Health Apps
information you make available to us when you open a Concierge Health Apps account, as set out above; any information included in your publicly visible Concierge Health Apps profile, which may include your profile ID, name and photo; information you make available to us via your use of Concierge Health Apps – for example, via: participating in surveys, polls, contests, giveaways and other promotional activities within Concierge Health Apps; making purchases within Concierge Health Apps, including your credit card or bank details and information about the purchases that you make; information we collect in the course of you using Concierge Health Apps – such as certain Location Data and Log Data; and
information you provide through your communications with our customer support team. Purchases via Concierge Health Apps. When you make purchases through Concierge Health Apps, you may need to provide certain Personal Information to complete the purchase, such as your credit card information or bank account information. Where the payment is processed by a third-party payment service provider, we do not collect or store such Personal Information, though we may receive summary information about transactions. Where we or our affiliate companies process your payments as a payment service provider, or where we fulfill any purchases you have made on Concierge Health Apps, we may collect, use and store your Personal Information in order to fulfill such purchases. Working with our third-party partners. We may work with third parties to gather additional demographic information about our users on an aggregate and anonymized basis. Location Data, Log Data and your device. Concierge Health Apps automatically collects Log Data from your device to enable and assist Concierge Health Apps’s functionalities. In addition, you may also permit Concierge Health Apps to access other content and data on your device – for example, your contact list and photo storage. Cookies, Automatic Data Collection, and Related Technologies. We further explain such collection in the “Tracking Technologies” section below.
HOW WE USE YOUR INFORMATION
Use of your Information within Concierge Health Apps We may use your Information for any of the following purposes:
to provide Concierge Health Apps (and the features and services within Concierge Health Apps) to you – for example, to allow you to chat within Concierge Health Apps, to fulfill any purchases you may make within Concierge Health Apps, and to display content based on your location; for communication, verification, security, fraud-detection, archival, backup, informational and operational purposes in connection with the provision of Concierge Health Apps – including account management, customer service, system maintenance, fulfillment of purchases, notifying contest winners, and other Concierge Health Apps-related purposes; to provide you with advertising and direct marketing that is more relevant to you (as further discussed under the “Direct Marketing” section below); to better understand how you access and use Concierge Health Apps, in order for us to improve Concierge Health Apps and respond to customer desires and preferences, including for us to provide language and location customization, personalized help and instructions, or other responses to your and other customers’ usage of Concierge Health Apps; to help us develop our new services and improve our existing services; to assess the effectiveness of and improve advertising and other marketing and promotional activities on or in connection with Concierge Health Apps when your account is subscribed to an official account; and to allow you to participate in voluntary surveys about our products and services. If you choose to participate in a survey, we may request certain Personal Information from you. We may use a third-party service provider to conduct these surveys; we will prohibit them from using your Personal Information for any purpose other than to complete the survey. In addition, we may need to retain, disclose and use your Information for the following purposes (collectively, the “Retained Information Purposes”):
We may use your Information for the purpose of sending you direct marketing (whether by messaging within our services, by email or by other means) that offer or advertise our products and services and/or the products and services of selected third parties. Such products and services (of ours or third parties) include the following: our products and services and the products and services of our affiliate and subsidiary companies and joint venture partners; and third-party providers of personal health and hygiene and other products and services that we think may be relevant to you.
We will honor your request for us to not use your Personal Information for the direct marketing purposes noted above. If you wish to make such a request, please contact the “Privacy Officer” at firstname.lastname@example.org, at any time and free of charge. In addition, you may be able to opt-out of certain direct marketing by following the relevant instructions set out on our marketing communications. We will not share your Personal Information with advertisers unless we have your permission to do so. We do, however, share Non-Personal Information with advertisers for the purposes of trying to offer you advertising that is more relevant to you. When you opt out of direct marketing pursuant to the above, you may continue to see online advertising (that is not direct marketing) within Concierge Health Apps and/or our advertisements on other websites or applications.
SHARING OF YOUR PERSONAL INFORMATION WITH THIRD PARTIES
Sharing for the provision of Concierge Health Apps We may share your Personal Information within our group of companies and with joint venture partners and third-party service providers, contractors and agents (such as communication service providers who send emails or push notifications on our behalf, and mapping services providers who assist us and you with location data), in each case, for the following purposes:
Sharing for marketing purposes We may allow third party marketing partners (such as Concierge Health Apps Official Accounts partners, analytics providers and advertising partners) to collect your Personal Information over time and across different websites or online services when you use Concierge Health Apps. If you wish to opt-out of such collection of your Personal Information by our third-party marketing partners while you are using Concierge Health Apps, please contact us at email@example.com
We may also provide your Personal Information to third party marketing partners where you have asked us or consented to us doing so or where it is required in order for us to provide Concierge Health Apps to you.
A WORD ABOUT SHARED INFORMATION
Concierge Health Apps enables Shared Information to be shared publicly with your Concierge Health Apps contacts, all users of Concierge Health Apps and/or the public, via features provided by either us or third parties, so that Shared Information can be broadly and instantly transmitted. Shared Information will remain public for as long as you do not delete it; and even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us. In addition, we may also provide other Concierge Health Apps-related features that allow you to share Shared Information in public – for example, publicly accessible blogs and forums, or certain social media features within Concierge Health Apps – for example, “plug-ins” (which create a direct link between two websites) and “widgets” (which are interactive mini-programs that provide third party services within Concierge Health Apps). You should be aware that any information you provide within such features may be read, collected and used by third parties who access them.
COMMUNICATIONS FROM US
Newsletters and other types of communications When you use Concierge Health Apps, we may use your Information to send you emails, messages, newsletters or push notifications to your device. If you no longer wish to receive these communications, you can do so by following the unsubscribe instructions in the emails we send to you, opting out of notifications at the device level (if available) or contacting our Privacy Officer.
Service-related announcements We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend Concierge Health Apps for maintenance). You may not opt-out of these service-related announcements, which are not promotional in nature.
A WORD ABOUT SENSITIVE PERSONAL INFORMATION
THIRD PARTY SERVICES AND YOUR INFORMATION
Concierge Health Apps may link you to social media or other features or services (including websites, plug-ins and widgets) provided by, or allow you to share certain Information with, a third party. For example:
Children under the age of 13 are not allowed to use Concierge Health Apps. We do not knowingly collect Personal Information from any children under the age of 13. Please contact our Privacy Officer if you believe we have any Personal Information from any children under the age of 13 – we will promptly investigate (and remove) such Personal Information.
TRANSFER, STORAGE AND SECURITY OF YOUR PERSONAL INFORMATION
We operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction. Any of the third parties referenced in the “Sharing of your Personal Information” section above may also be located and/or use and/or store your Personal Information outside of your jurisdiction for the purposes set out in that section. In both instances, your Personal Information may be transferred to jurisdictions that do not have data protection laws which are substantially similar to or serve the same purpose as the laws of your jurisdiction. We will ensure that all data transfers comply with applicable legal requirements (for example, by adopting suitable data protection policies and/or contractual measures). Should you wish to know more, please contact our Privacy Officer. We use a variety of generally accepted security technologies and procedures for the purpose of preventing loss, misuse, unauthorized access or disclosure of Information – for example, we use encryption technology (such as SSL) to protect certain sensitive Information (such as Location Data) provided by you to us. Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. We do not warrant or guarantee the security of Concierge Health Apps or any information you provide to us. We may communicate with you electronically regarding security, privacy, and administrative issues relating to Concierge Health Apps. If we learn of a Concierge Health Apps security breach, we may attempt to notify you electronically by posting a notice within Concierge Health Apps or by sending direct communication to you. If you have any questions regarding the security of your Personal Information, please contact our Privacy Officer.
PERIOD OF USE OF YOUR PERSONAL INFORMATION
We will only retain your Personal Information for so long as is necessary to fulfill the purposes for which it was collected, as set out under the “How We Use Your Information” section above.
ACCESSING, UPDATING, AMENDING OR PORTING YOUR PERSONAL INFORMATION
Subject to applicable laws and regulations, you may have the right to: obtain confirmation that we hold Personal Information about you; access, rectify or delete your Personal Information that we maintain; request and receive a copy of the Personal Information you have provided us and to transmit this information to another provider. object to or request the restriction of processing of your Personal Information; and have the information deactivated, blocked, anonymized or deleted, as appropriate. To the extent provided by applicable laws and regulations, you may withdraw any consent you previously provided to us, including consent for email and targeted marketing communication and data transfers. We will use reasonable efforts to apply your preferences going forward. If you would like to update or amend your Personal Information within Concierge Health Apps, you may do so in the first instance by logging into your account and making the appropriate changes. For example, you may be able to delete certain Location Data that you have provided us via your device settings or the “Clear Location” option within Concierge Health Apps. If you wish to:
make further changes to your Personal Information; exercise any of your rights mentioned above in this section; or to request the removal of an unauthorized Concierge Health Apps account, please contact our Privacy Officer. We will use reasonable efforts to respond to all such requests made to our Privacy Officer without undue delay and in accordance with any time limits required by law. Please note that your right to access Personal Information in the above manner may be limited in some circumstances by local law requirements. In some cases, we may not be able to update, amend or remove your Personal Information, in which case we will let you know why we are unable to do so – for example, certain requests may be extremely impractical or require disproportionate technical effort (e.g., any requests that relate to our backup systems), or are prohibited by law.
International Data Transfers We are a global business. We may transfer Personal Information to countries other than the country in which the data was originally collected. For example: we operate and may continue to operate servers in a number of jurisdictions around the world, so the server on which your Personal Information is used and stored may not be in your jurisdiction; and any of the third parties referenced in the “Sharing of your Personal Information” section above may also be located and/or use and/or store your Personal Information outside of your jurisdiction for the purposes set out in that section. In both instances,
Why do we use tracking technologies? To help us better understand and provide Concierge Health Apps to you and our users Tracking technologies enable us to better understand and provide Concierge Health Apps to you – for example, tracking technologies help us collect the following Information: we require your authentication information in order to provide Concierge Health Apps to you; our translation services may require Information about your language preferences; and we require certain other Information about our users in order to provide Concierge Health Apps and to develop new features for Concierge Health Apps.
To help us deliver relevant and safe advertising to you Advertising helps keep Concierge Health Apps and many of our other services free of charge and useful to you. Tracking technologies help make our advertising:
more effective for advertisers – for example, by delivering them further information regarding who has viewed their advertisements; more safe for you – for example, by ensuring that you do not receive repeated or fraudulent advertisements or prohibited content within such advertisements; and more relevant to you – for example, by delivering advertisements based on which official Concierge Health Apps channels you may have followed or based on your location.
What are tracking technologies? The “tracking technologies” that we use within Concierge Health Apps include the following:
A cookie is a small file containing a string of characters that is placed on your computer, mobile phone or other device when you access a website or other web content.
Web beacons are electronic image files or other technologies that may be embedded within websites or emails that may be used to keep count of visitors, record when and if an email or website is viewed, or access certain cookies.
Certain information is automatically gathered and stored in log files. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and clickstream data.
An entity tag (or ETag) are HTTP headers that are sent-behind-the-scenes between a web browser and a web server. They can be used to track unique users in place of cookies, and allow us to better understand and improve Concierge Health Apps.
Anonymous identifiers are used to deliver advertisements in services where cookies may not be available (for example, in mobile applications).
How do we use tracking technologies? Tracking technologies used in partnership with third parties We, our affiliate companies and our third-party partners may from time to time use tracking technologies to collect and use certain Information. These third-party partners who assist us in such collection and use include the following:
Our analytics partners help us better understand Concierge Health Apps generally – for example, to collect website and app usage statistics and to gather demographic information about our user base as a whole, as well as to analyze any relevant trends.
Our marketing partners (including analytics partners, advertisers and Concierge Health Apps official account partners) help us deliver better and more relevant advertising to you.
Our customer support service partners help us deliver better responses to any queries from you and to deliver a better Concierge Health Apps experience to our users.
Our service partners help us administer and deliver certain features within Concierge Health Apps – for instance, hosting, language translation and mapping services.
We may receive reports based on the use of tracking technologies by these partners on an individual as well as aggregated basis. We may use Google Analytics to collect and process certain Concierge Health Apps-related usage data. Google provides additional privacy options regarding cookie use described at http://www.google.com/policies/privacy/partners/.
Our own tracking technologies. In addition, we also use our own tracking technologies to personalize your experience on Concierge Health Apps and for various other purposes. For example, we use such tracking technologies to:
remember you within Concierge Health Apps. For example, cookies and web beacons can help us identify you as a registered user of our services or keep the preferences or information that you have previously provided; and analyze how you use Concierge Health Apps. We can use tracking technologies to understand what users are doing on our services, or which pages or sections are most popular. Please note that we use our tracking technologies for these purposes, but may make certain aggregated Non-Personal Information obtained through these tracking technologies available to advertisers and other partners to analyze how you and others use our services and to serve advertising.
While we may have agreements in place with these third parties in relation to the proper handling and protection of your Personal Information, we cannot guarantee their privacy practices as they are third parties.
If you wish to opt out of interest-based advertising, click here: http://preferences-mgr.truste.com/. Please note you will continue to receive generic ads. If you do not wish to have Non-Personal Information used for the purpose of serving you targeted advertisements on your device, you may opt-out by contacting policy@Concierge Health Apps.com. Please note this does not opt you out of being served advertising. You will continue to receive generic advertisements. We may combine Information collected via tracking technologies with other Information we collect about you. For example, where you install and register for Concierge Health Apps via a third-party online advertisement, we and/or our third partner may use tracking technologies to inform us regarding where you had discovered Concierge Health Apps. We may also use tracking technologies to collect Information that, when combined with other Information, enables us to deliver relevant advertisements directly to you.
How you can control tracking technologies You may be able to block or manage certain types of tracking technologies via your browser settings (such as cookies or web beacons) or your mobile device. However, please remember that if you block tracking technologies, we may not be able to provide you with the optimal Concierge Health Apps experience and some or all of Concierge Health Apps’s features may not function properly.
You may also control what tracking technologies-collected Information we receive by certain settings within Concierge Health Apps – for instance, by using the “Clear Location” option within Concierge Health Apps. Specific types of cookies We further describe how we use specific types of cookies below. Some or all of such cookies may be stored in your browser. Category of cookies use Description Authentication These cookies notify us when you access our services, so to enable us to provide suitable services and experience to you. These cookies will also remember certain Information about your personal preferences – for instance, your preferred language and region. Security We use such cookies to ensure the security of your Information and our services, and to prevent fraudulent, criminal or other suspect activities. In particular, security cookies help us to prevent fraudulent logins and your user data.
deliver advertising on Concierge Health Apps, with the aim of delivering more relevant advertising to all of our users–for example, you may receive advertisements based on your general location derived from your IP address or from your previous Concierge Health Apps searches; and to help us and advertisers collect statistics regarding the delivered advertisements, such as how many users have viewed, clicked on and/or made purchases through such advertisements.
Mobile Analytics We use mobile analytics software to allow us to better understand the functionality of Concierge Health Apps as used on your phone. As part of such process, we may (via Concierge Health Apps) record information such as how often you use Concierge Health Apps, the events that occur within Concierge Health Apps, aggregated usage, performance data, and where and when Concierge Health Apps was downloaded from on your device. We do not link such mobile analytics information that we collect with any personally identifiable information you submit within Concierge Health Apps.
Payment processing services for members on Concierge Health Apps are provided by Stripe and are subject to the Stripe Connected Account Agreement, which includes the Stripe Terms of Service (collectively, the “Stripe Services Agreement”). By agreeing to this agreement or continuing to operate as a member on Concierge Health Apps, you agree to be bound by the Stripe Services Agreement, as the same may be modified by Stripe from time to time. As a condition of Concierge Health Apps enabling payment processing services through Stripe, you agree to provide Concierge Health Apps accurate and complete information about you and your business, and you authorize Concierge Health to share it and transaction information related to your use of the payment processing services provided by Stripe.