GENERAL
Samata Health Inc. (“Company” or “we” or “us” or “our”) is
publishing this Privacy Policy for its users (“user” or “you”)
that use our web application located at www.app.samatahealth.com,
including other websites, media forms, media channels, mobile
websites or mobile applications related or connected thereto,
specifically including the website www.samatahealth.com
(collectively, the “Website”). The following Company privacy
policy (“Privacy Policy”) is designed to inform you, as a user of
the Website, about the types of information that Company may
gather about or collect from you in connection with your use of
the Website. It also is intended to explain the conditions under
which Company uses and discloses that information, and your rights
in relation to that information. Changes to this Privacy Policy
are discussed at the end of this document. Each time you use the
Website, however, the current version of this Privacy Policy will
apply. Accordingly, each time you use the Website you should
review any changes since the last time you used the Website.
Notice to Users Outside the United States
The Website is hosted in the United States of America and is
subject to U.S. state and federal law. If you are accessing our
Website from other jurisdictions, please be advised that you may
be viewed as transferring your personal information to us in the
United States, and by using our Website, you consent to that
transfer and use of your personal information in accordance with
this Privacy Policy. You also agree to abide by the applicable
laws of applicable states and U.S. federal law concerning your use
of the Website and your agreements with us. Any persons accessing
our Website from any jurisdiction with laws or regulations
governing the use of the Internet (including personal data
collection, use and disclosure), different from those of the
jurisdictions mentioned above may only use the Website in a manner
lawful in their jurisdiction. If your use of the Website would be
unlawful in your jurisdiction, please do not use the Website.
Further, note that your jurisdiction may offer a more limited or
different level of protection with respect to the privacy of your
data.
BY USING OR ACCESSING THE WEBSITE, YOU ARE ACCEPTING THE
PRACTICES DESCRIBED IN THIS PRIVACY POLICY.
GATHERING, USE AND DISCLOSURE OF NON-PERSONALLY-IDENTIFYING
INFORMATION
Users of the Website Generally
“Non-Personally Identifying Information” is information that,
without the aid of additional information, cannot be directly
associated with a specific person. “Personally Identifying
Information,” by contrast, is information such as a name or email
address that, without more, can be directly associated with a
specific person.
Like most website operators, Company gathers from users of the
Website Non-Personally Identifying Information of the sort that
Web browsers, depending on their settings, may make available.
That information includes the user’s Internet Protocol (IP)
address, operating system, browser type and the locations of the
websites the user views right before arriving at, while navigating
and immediately after leaving the Website. Although such
information is not Personally Identifying Information, it may be
possible for Company to determine from an IP address a user’s
Internet service provider and the geographic location of the
visitor’s point of connectivity as well as other statistical usage
data. Company analyzes Non-Personally Identifying Information
gathered from users of the Website to help Company better
understand how the Website is being used. By identifying patterns
and trends in usage, Company is able to better design the Website
to improve users’ experiences, both in terms of content and ease
of use.
From time to time, Company may also release the Non-Personally
Identifying Information gathered from Website users in the
aggregate, such as by publishing a report on trends in the usage
of the Website.
Web Cookies
A “Web Cookie” is a string of information which assigns you a
unique identification that a website stores on a user’s computer,
and that the user’s browser provides to the website each time the
user submits a query to the website. We use cookies on the Website
to keep track of services you have used, to record registration
information regarding your login name and password, to record your
user preferences, to keep you logged into the Website and to
facilitate purchase procedures. Company also uses Web Cookies to
track the pages that users visit during each Website session, both
to help Company improve users’ experiences and to help Company
understand how the Website is being used. As with other
Non-Personally Identifying Information gathered from users of the
Website, Company analyzes and discloses in aggregated form
information gathered using Web Cookies, so as to help Company, its
partners and others better understand how the Website is being
used.
COMPANY USERS WHO DO NOT WISH TO HAVE WEB COOKIES PLACED ON
THEIR COMPUTERS SHOULD SET THEIR BROWSERS TO REFUSE WEB COOKIES
BEFORE ACCESSING THE WEBSITE, WITH THE UNDERSTANDING THAT
CERTAIN FEATURES OF THE WEBSITE MAY NOT FUNCTION PROPERLY
WITHOUT THE AID OF WEB COOKIES. WEBSITE USERS WHO REFUSE WEB
COOKIES MAY LOSE FUNCTIONALITY OR USE OF CERTAIN FEATURES OF THE
WEBSITE.
Third-Party Advertisers
We may use third-party advertising companies to serve ads when you
visit the Website. These companies may use information about your
visits to the Website and other websites that are contained in Web
Cookies in order to provide advertisements about goods and
services of interest to you. Using a tool created by the Network
Advertising Initiative, you can opt out of several third-party ad
servers’ and networks’ Web Cookies simultaneously. If you would
like more information about this practice and to know your choices
about not having this information used by these companies, please
follow the instructions and links here: http://www.networkadvertising.org/choices/
and
http://preferences-mgr.truste.com, or http://www.aboutads.info/choices. Please contact us if you would like to know the identity of the
third-party advertising companies we are currently using to serve
ads.
We may allow advertisers to choose the characteristics of users
who will see their advertisements, and we may use any of the
Non-Personally Identifying Information we have collected
(including information you may have decided not to show to other
users, such as your birth year or other sensitive personal
information or preferences) to select the appropriate audience for
those advertisements. We do not identify you to the advertiser.
Web Beacons
A “Web Beacon” is an object that is embedded in a web page or
email that is usually invisible to the user and allows website
operators to check whether a user has viewed a particular web page
or an email. Company may use Web Beacons on the Website and in
emails to count users who have visited particular pages, viewed
emails and to deliver co-branded services. Web Beacons are not
used to access users’ Personally Identifying Information. They are
a technique Company may use to compile aggregated statistics about
Website usage. Web Beacons collect only a limited set of
information, including a Web Cookie number, time and date of a
page or email view and a description of the page or email on which
the Web Beacon resides. You may not decline Web Beacons. However,
they can be rendered ineffective by declining all Web Cookies or
modifying your browser setting to notify you each time a Web
Cookie is tendered, permitting you to accept or decline Web
Cookies on an individual basis.
Analytics
We may use third-party vendors, including Google, who use
first-party cookies (such as the Google Analytics cookie) and
third-party cookies (such as the DoubleClick cookie) together to
inform, optimize and serve ads based on your past activity on the
Website, including Google Analytics for Display Advertising. The
information collected may be used to, among other things, analyze
and track data, determine the popularity of certain content and
better understand online activity. If you do not want any
information to be collected and used by Google Analytics, you can
install an opt-out in your web browser (https://tools.google.com/dlpage/gaoptout) and/or opt out from Google Analytics for Display Advertising or
the Google Display Network by using Google’s Ads help (https://support.google.com/ad/answer/262922?hl=en).
Aggregated and Non-Personally Identifying Information
We may share aggregated and Non-Personally Identifying Information
we collect under any of the above circumstances. We may also share
it with third parties and our affiliate companies to develop and
deliver targeted advertising on the Website and on websites of
third parties. We may combine Non-Personally Identifying
Information we collect with additional Non-Personally Identifying
Information collected from other sources. We also may share
aggregated information with third parties, including advisors,
advertisers and investors, for the purpose of conducting general
business analysis. For example, we may tell our advertisers the
number of visitors to the Website and the most popular features or
services accessed. This information does not contain any
Personally Identifying Information and may be used to develop
website content and services that we hope you and other users will
find of interest and to target content and advertising.
In addition, Company may make use of de-identified information in
accordance with applicable privacy law.
Mobile Device Additional Terms
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Mobile Device. If you use a mobile device to
access the Website or download any of our applications, we may
collect device information (such as your mobile device ID, model
and manufacturer), operating system, version information and IP
address.
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Geo-Location Information. Unless we have
received your prior consent, we do not access or track any
location-based information from your mobile device at any time
while downloading or using our services, except that it may be
possible for Company to determine from an IP address the
geographic location of your point of connectivity, in which case
we may gather and use such general location data.
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Mobile Analytics. We use mobile analytics
software to allow us to better understand the functionality of
our mobile software on your phone. This software may record
information, such as how often you use the application, the
events that occur within the application, aggregated usage,
performance data and where the application was downloaded from.
We do not link the information we store within the analytics
software to any Personally Identifying Information you submit
within the mobile application.
SOCIAL MEDIA
We may use hyperlinks on the Website which will redirect you to a
social network if you click on the respective link. However, when
you click on a social plug-in, such as Facebook’s “Like” button,
Twitter’s “tweet” button or the Google+, that particular social
network’s plugin will be activated and your browser will directly
connect to that provider’s servers. If you do not use these
buttons, none of your data will be sent to the respective social
network’s plugin provider. So for example, when you click on the
Facebook’s “Like” button on the Website, Facebook will receive
your IP address, the browser version and screen resolution, and
the operating system of the device you have used to access the
Website. Settings regarding privacy protection can be found on the
websites of these social networks and are not within our control.
COLLECTION, USE AND DISCLOSURE OF PERSONALLY-IDENTIFYING
INFORMATION
Website Registration
As defined above, Personally Identifying Information is
information that can be directly associated with a specific
person. Company may collect a range of Personally Identifying
Information from and about Website users. Much of the Personally
Identifying Information collected by Company about users is
information provided by users themselves when (1) registering for
our service, (2) participating in polls, contests, surveys or
other features of our service, or responding to offers or
advertisements, (3) communicating with us, (4) creating a profile
or (5) signing up to receive newsletters. That information may
include each user’s name, photo, email address and telephone
number, and, if you transact business with us, financial
information such as your payment method (valid credit card number,
type, expiration date or other financial information). We also may
request information about your interests and activities, your
gender, age, date of birth, username, hometown and other
demographic or relevant information as determined by Company from
time to time. Users of the Website are under no obligation to
provide Company with Personally Identifying Information of any
kind, with the caveat that a user’s refusal to do so may prevent
the user from using certain Website features.
BY REGISTERING WITH OR USING THE WEBSITE, YOU CONSENT TO THE
USE AND DISCLOSURE OF YOUR PERSONALLY-IDENTIFYING INFORMATION AS
DESCRIBED IN THIS “COLLECTION, USE AND DISCLOSURE OF
PERSONALLY-IDENTIFYING INFORMATION” SECTION.
Online Postings
Certain Personally Identifying Information collected from users
may be disclosed as a matter of course as a result of your use of
the Website. We may provide areas on the Website where you can
post reviews and other information relating to your activities on
the Website. Such postings are governed by our Terms of Use. In
addition, such postings may appear on other websites or when
searches are executed on the subject of your posting. Also,
whenever you voluntarily disclose personal information on
publicly-viewable web pages, that information will be publicly
available and can be collected and used by others. For example, if
you post your email address, you may receive unsolicited messages.
We cannot control who reads your posting or what other users may
do with the information you voluntarily post, so we encourage you
to exercise discretion and caution with respect to your personal
information.
USERS ASSUME ALL RESPONSIBILITY FOR ANY LOSS OF PRIVACY OR
OTHER HARM RESULTING FROM THEIR VOLUNTARY DISCLOSURE OF
PERSONALLY IDENTIFYING INFORMATION.
Company Communications
We may occasionally use your name and email address to send you
notifications regarding new services offered by the Website that
we think you may find valuable. We may also send you
service-related announcements from time to time through the
general operation of the service. Generally, you may opt out of
such emails at the time of registration or through your account
settings, though this may not opt you out of all emails, such as
notices about your account, including service announcements and
administrative messages.
General Use by Company
Company uses the Personally Identifying Information in the file we
maintain about you, and other information we obtain from your
current and past activities on the Website (1) to deliver the
products and services that you have requested; (2) to manage your
account and provide you with customer support; (3) to communicate
with you by email, telephone and/or mobile devices about products
or services that may be of interest to you either from us, our
affiliate companies or other third parties; (4) to develop and
display content and advertising tailored to your interests on the
Website and other sites; (5) to resolve disputes and troubleshoot
problems; (6) to measure consumer interest in our services; (7) to
inform you of updates; (8) to customize your experience; (9) to
detect and protect us against error, fraud and other criminal
activity; (10) to enforce our Terms of Use; and (11) to do as
otherwise described to you at the time of collection. At times, we
may look across multiple users to identify problems. In
particular, we may examine your Personally Identifying Information
to identify users using multiple user IDs or aliases. We may
compare and review your Personally Identifying Information for
accuracy and to detect errors and omissions. We may use financial
information or payment method to process payment for any purchases
made on the Website, enroll you in the discount, rebate, and other
programs in which you elect to participate, to protect against or
identify possible fraudulent transactions and otherwise as needed
to manage our business.
Company Disclosures
Company will disclose Personally Identifying Information under the
following circumstances:
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By Law or to Protect Rights. When we believe
disclosure is appropriate, we may disclose Personally
Identifying Information in connection with efforts to
investigate, prevent or take other action regarding illegal
activity, suspected fraud or other wrongdoing; to protect and
defend the rights, property or safety of Company, our users, our
employees or others; to comply with applicable law or cooperate
with law enforcement; to enforce our Terms of Use or other
agreements or policies, in response to a subpoena or similar
investigative demand, a court order or a request for cooperation
from a law enforcement or other government agency; to establish
or exercise our legal rights; to defend against legal claims; or
as otherwise required by law. In such cases, we may raise or
waive any legal objection or right available to us.
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Marketing Communications. Unless users opt-out
from receiving Company marketing materials upon registration,
Company may email users about products and services that Company
believes may be of interest to them. If you wish to opt-out of
receiving marketing materials from Company, you may do so by
following the unsubscribe link in the email communications, by
going to your account settings (if applicable) or contacting us
using the contact information below.
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Third-Party Marketing Communications. Unless
users opt-out from receiving marketing materials upon
registration, Company may provide users’ email information to
third parties, so that those third parties may directly contact
them about additional products and services. To cease having
your email information provided to third parties, you may do so
by going to your account settings (if applicable) or contacting
us using the contact information below. Even after opting-out,
you may continue to receive marketing emails from third parties
to whom Company already has provided your email information. You
will be responsible for directly contacting such third parties
to request cessation of further marketing emails.
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Third-Party Service Providers. We may share
your Personally Identifying Information, which may include your
name and contact information (including email address) with our
authorized service providers that perform certain services on
our behalf. These services may include fulfilling orders,
providing customer service and marketing assistance, performing
business and sales analysis, supporting the Website’s
functionality and supporting contests, sweepstakes, surveys and
other features offered through the Website. We may also share
your name, contact information and credit card information with
our authorized service providers who process credit card
payments. These service providers may have access to personal
information needed to perform their functions but are not
permitted to share or use such information for any other
purpose.
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Business Transfers; Bankruptcy. Company may
disclose all Personally Identifying Information in its
possession to a successor organization in the event of a merger,
acquisition, bankruptcy or other sale of all or a portion of
Company’s assets. Other than to the extent ordered by a
bankruptcy or other court, the use and disclosure of all
transferred Personally Identifying Information will be subject
to this Privacy Policy, or to a new privacy policy if you are
given notice of that new privacy policy and are given an
opportunity to affirmatively opt-out of it. Personally
Identifying Information submitted or collected after a transfer,
however, may be subject to a new privacy policy adopted by the
successor organization.
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Employees, Contractors, and Consultants. Some
Company employees and operations contractors, and consultants
may have limited access to your Personal Information in the
course of providing services to you, including for the purpose
of troubleshooting problems and/or resolving complaints. These
contractors include vendors and suppliers that provide us with
technology, services, and/or content for the operation and
maintenance of the Website. Access to your Personal Information
is limited to the information reasonably necessary for the
employee or contractor to perform the function needed to resolve
the issue or to provide or improve the service.
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Use and Disclosure of Personally Identifying Information
for Healthcare Operations & Services We may use and disclose your Personally Identifying
Information to provide you with care, to run our healthcare
operations, to take payment, or to provide information to
clinicians who work with our Website, platforms and systems, and
to comply with state and US federal regulations. We implement a
range of technical, administrative and physical safeguards to
protect your Personally Identifying Information. To the extent
you are transmitting information known as Protected Health
Information (“PHI”) under HIPAA, this may entitle you to certain
rights described under HIPAA. Notwithstanding the foregoing,
Samata Health Inc. does not and will not perform any actions or
provide any services that constitute the practice of therapy,
medicine, or any similar licensed profession.
Your Ability to Change Personally Identifying Information; Account
Termination
You may at any time review or change your Personally Identifying
Information by going to your account settings (if applicable) or
contacting us using the contact information below. Upon your
request, we will deactivate or delete your account and contact
information from our active databases. Such information will be
deactivated or deleted as soon as practicable based on your
account activity and accordance with our deactivation policy and
applicable law. To make this request, either go to your account
settings (if applicable) or contact us as provided below. We will
retain in our files some Personally Identifying Information to
prevent fraud, to troubleshoot problems, to assist with any
investigations, to enforce our Terms of Use and to comply with
legal requirements as is permitted by law. Therefore, you should
not expect that all your Personally Identifying Information will
be completely removed from our databases in response to your
requests. Additionally, we keep a history of changed information
to investigate suspected fraud with your account.
Children's Personally Identifying Information
The features, programs, promotions and other aspects of our
service requiring the submission of Personally Identifying
Information are not intended for anyone under 18 years of age. We
do not knowingly collect Personally Identifying Information from
children under the age of 18. If you are under 18, then you may
not use or access our website or services at any time or in any
manner. If you are a parent or guardian of a child under the age
of 18 and believe he or she has disclosed Personally Identifying
Information to us, please contact us at
privacy@samatahealth.com. A parent or guardian of a child under the age of 18 may review
and request deletion of such child’s Personally Identifying
Information as well as prohibit the use thereof.
COLLECTION AND USE OF INFORMATION BY THIRD PARTIES GENERALLY
Company contractually prohibits its contractors, affiliates,
vendors and suppliers from disclosing Personally Identifying
Information received from Company, other than in accordance with
this Privacy Policy. However, third parties are under no
obligation to comply with this Privacy Policy with respect to
Personally Identifying Information that users provide directly to
those third parties, or that those third parties collect for
themselves. These third parties may include advertisers, providers
of games, utilities, widgets and a variety of other third-party
applications that may be accessible through the Website. Company
neither owns nor controls the third-party websites and
applications accessible through the Website. Thus, this Privacy
Policy does not apply to information provided to or gathered by
the third parties that operate them. Before visiting a third
party, or using a third-party application, whether by means of a
link on the Website, directly through the Website or otherwise,
and before providing any Personally Identifying Information to any
such third party, users should inform themselves of the privacy
policies and practices (if any) of the third party responsible for
that website or application, and should take those steps necessary
to, in those users’ discretion, protect their privacy.
SECURITY
We use reasonable electronic, personnel and physical measures to
protect it from loss, theft, alteration or misuse. However,
please be advised that even the best security measures cannot
fully eliminate all risks. We cannot guarantee that only
authorized persons will view your information. We are not
responsible for third-party circumvention of any privacy
settings or security measures.
We are dedicated to protect all information on the Website as is
necessary. However, you are responsible for maintaining the
confidentiality of your Personally Identifying Information by
keeping your password confidential. You should change your
password immediately if you believe someone has gained
unauthorized access to it or your account. If you lose control of
your account, you should notify us immediately.
Despite our efforts to protect your Personally Identifiable
Information, there is always some risk that an unauthorized third
party may find a way around our security systems or that
transmissions of your information over the Internet may be
intercepted. We do not utilize encryption systems for emails from
or to you. Therefore, we make no representations or warranties
regarding the sufficiency of the above security measures. No data
transmission over the Internet or through mobile devices can be
guaranteed to be 100% secure. While we strive to protect your
personal information from unauthorized access, use or disclosure,
we cannot ensure or warrant the security of any information you
transmit to us on the Website. There is no guarantee that
information may not be accessed, disclosed, altered, or destroyed
by breach of any of our physical, technical, or managerial
safeguards. It is your responsibility to protect the security of
your login information. Therefore, the Company is not responsible
for any actual or consequential damages that result from a lapse
in compliance with this Privacy Policy because of a security
breach or technical malfunction.
PRIVACY POLICY CHANGES
Company may, in its sole discretion, change this Privacy Policy
from time to time. Any and all changes to Company’s Privacy Policy
will be reflected on this page and the date new versions are
posted will be stated at the top of this Privacy Policy. Unless
stated otherwise, our current Privacy Policy applies to all
information that we have about you and your account. Users should
regularly check this page for any changes to this Privacy Policy.
Company will always post new versions of the Privacy Policy on the
Website. However, Company may, as determined in its discretion,
decide to notify users of changes made to this Privacy Policy via
email or otherwise. Accordingly, it is important that users always
maintain and update their contact information.
CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the "Shine
The Light" law, permits our users who are California residents to
request and obtain from us, at least once a year and free of
charge, information about the Personally Identifying Information
(if any) we disclosed to third parties for direct marketing
purposes in the preceding calendar year. If applicable, this
information would include a list of the categories of the
Personally Identifying Information that was shared and the names
and addresses of all third parties with which we shared Personally
Identifying Information in the immediately preceding calendar
year. If you are a California resident and would like to make such
a request, please submit your request in writing to our privacy
officer as listed below.
DO-NOT-TRACK POLICY
Most web browsers and some mobile operating systems include a
Do-Not-Track (“DNT”) feature or setting you can activate to signal
your privacy preference not to have data about your online
browsing activities monitored and collected. The Website does
currently respond to DNT browser signals or mechanisms.
QUESTIONS OR COMPLAINTS
If you have any questions regarding our Privacy Policy or
complaints regarding your privacy rights, please submit your
complaint in writing our Privacy Officer at:
Samata Health Inc.
Attn: Privacy Officer
Email:
privacy@samatahealth.com
Phone: (847) 363-0309
We will not retaliate against you for filing a complaint.
In addition, you can complain to:
Secretary of the U.S. Department of Health and Human Services
Office of Civil Rights
Attention: Regional Manager
50 United Nations Plaza, Room 322
San Francisco, California 94102
For additional information, call (800) 368-1019 or U.S Office of
Civil Rights (866) 627-7748 (Voice) or (866) 788-4989 (TTY)
EFFECTIVE DATE
This Privacy Policy is effective as of September 2, 2020 and was
last updated on September 2, 2020.
Changes to this Notice
If we change the terms of this Privacy Policy, then we will post
the new Privacy Policy on our Website. Any new Privacy Policy will
apply to all the information that we maintain, including
information that was created prior to the change.