Effective date: 2/6/2020
This Site is not intended for children under the age of 13 and we do not knowingly collect data relating to children.
How to Contact Us
155 East 44th Street, Suite 701,
New York, NY 10017
1. Types of Information Collected
We collect two types of information about our website users: Personal Information and Non-Personal Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using our Site.
“Personal Information” refers to information that lets us know the specifics of who you are. When you engage in certain activities on our Site, such as contacting us, registering for our mailing list, making a purchase or sending us feedback, we may ask you to provide certain information about yourself by filling out and submitting an online form. It is completely optional for you to engage in these activities; however, we may ask that you provide us Personal Information, such as your first and last name, mailing address (including zip code), e-mail address, employer, job title and department, telephone and facsimile numbers, and other personally identifying information. Depending upon your activity, some of the information we ask you to provide is required for your participation in that activity. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
“Non-Personal Information” refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on our Site in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the website’s Uniform Resource Locator (“URL”) that you just came from, which URL you next go to, what browser you are using, and/or your Internet Protocol (“IP”) address.
2. Collection Methods and Use of Information
We may collect Personal Information from you directly when sign up for our newsletter, register for an event, request information from us, or send us an email.
In addition, we may also collect, or our third-party content server may collect, certain Non-Personal Information. Our servers automatically collect certain site use information each time you visit our Site. The Site use information includes but is not limited to the following: the domain names, operating system in use, browser and version, the website that referred you to us, and other similar information. This information may be aggregated to measure the number of visits, average time spent on our Site, pages viewed, time and date of visits, and other similar information. We may use and disclose site use information, for example, to measure the use of our Site, explain the utility of our Site, and to improve the content of our Site.
3. Release of Information
We may disclose Personal Information to our affiliates and event sponsors. We may also disclose Personal Information to third parties that partner with us or provide services for us, and to other third parties as permitted by law.
We will encourage our service partners to adopt and post privacy policies. However, the use of your Personal Information by our service partners is governed by the privacy policies of those service partners and is not subject to our control.
Occasionally, we may be required by law enforcement or judicial authorities to provide Personal Information to the appropriate governmental authorities. We will disclose Personal Information upon receipt of a court order or subpoena or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
We may also provide Non-Personal Information about our customers’ sales, traffic patterns, and related site information to third-party advertisers, but these statistics do not include any Personal Information.
4. Updating and Correcting Information
You can access and modify certain Personal Information stored on our Site, such as your name, phone number, email address, and mailing address, by contacting us via email.
We retain information provided to us indefinitely unless otherwise stated or otherwise required by law. In some circumstances, you may have the right to ask us to delete your data. In some circumstances we may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you. In addition, we will keep some Personal Information you have asked us to remove for the following purposes: (i) troubleshoot problems; (ii) assist with investigations; (iii) enforce our Site rules, or (iv) comply with legal requirements.
Therefore, you should not expect that all of your Personal Information will always be completely removed from our databases in response to your requests.
California residents may have different or additional rights, please see the PRIVACY NOTICE FOR CALIFORNIA RESIDENTS in Section 9 below.
5. User Choices on Collection and Use of Information
We may, from time to time, send you e-mail regarding our products and services. In addition, if you signed up for our mailing list, we may occasionally send you direct mail about products and services that we feel may be of interest to you. Only HLTH (or agents working on behalf of HLTH) will send you these direct mailings and only if you indicated that you do not object to these offers. If you do not want to receive such e-mails or mailings, simply tell us when you give us your Personal Information.
You can ask us or third parties to stop sending you marketing emails at any time by (i) logging into the Site and checking or unchecking relevant boxes to adjust your marketing preferences or (ii) by following the opt-out links on any marketing email sent to you or (iii) by contacting us at any time using the Contact Us information at the top of the page.
6. Security of Information
We believe that keeping Personal Information secure is one of our most significant responsibilities. We restrict access to Personal Information about you to those employees and others who need to know that information to assist us in our business or to provide products or services to you. We safeguard Personal Information according to established security standards and procedures, by maintaining physical, electronic, and procedural safeguards for the information.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity, and privacy of any and all information and data exchanged between you and us through our Site cannot be guaranteed; and (c) any such information and data may be viewed or tampered with in transit by a third party.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.
7. Privacy Policies of Third-Party Websites
8. Links to Other Websites
We may provide links to other websites for your convenience and information. These sites operate independently from our Site and are not under our control. These sites may have their own privacy notices in place, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of these sites, any products or services that may be offered through these sites, or any other use of these sites.
9. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
Information We Collect
Our Site collects Personal Information, further defined in Section 1 above. For purposes of this Section 9, “Personal Information” also includes information that identifies or could reasonably be linked, directly or indirectly, with a particular consumer or device.
Our Site has collected the following categories of Personal Information from its consumers within the last twelve (12) months:
First name, last name, email address, telephone number, email data, system usage data, location data (IP address), and other electronic data/UGC (reviews, photos) submitted, stored, sent, or received by the Data Subjects.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
First name, last name, email address, telephone number, email data, social media identifiers, system usage data, location data (IP address).
C. Protected classification characteristics under California or federal law.
D. Commercial information.
Purchased product/service, event attendance.
E. Biometric information.
F. Internet or other similar network activity.
IP Address, system usage data, aggregated data.
G. Geolocation data.
H. Sensory data.
I. Professional or employment-related information.
Job title, business email address, company information, business phone number, URL of company.
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
K. Inferences drawn from other personal information.
For purposes of this Section 9, “Personal Information” does not include:
- Publicly available information from government records.
- Deidentified or aggregated consumer information.
- Information excluded from the CCPA’s scope, such as:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;
- Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
We obtain the Personal Information listed above from directly from you when you submit it to us and indirectly from you (for example, through cookies or other tracking mechanisms.) For more information about how we collect your Personal Information, see Sections 2, 3, and 5 above.
Use of Personal Information
We may use or disclose the Personal Information we collect for the business purposes set forth in Sections 2, 3, and 5 above.
Sharing Personal Information
HLTH does not sell or disclose your Personal Information to third parties for commercial purposes or otherwise except as set forth in Sections 2, 3, and 5 above.
California Residents’ Individual Rights
The CCPA provides California consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.
Access and Data Portability Rights
California consumers have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
- The categories of Personal Information we collected about you.
- The categories of sources for the Personal Information we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Information.
- The categories of third parties with whom we share that Personal Information.
- The specific pieces of Personal Information we collected about you (also called a data portability request).
- If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
California residents have the right to request that HLTH delete their 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.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity (including fraudulent user generated content such as product reviews), or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise a right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access, Data Portability, and Deletion Rights
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by sending us a message on our Site. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We try to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Opt-Out and Opt-In Rights
If you are 16 years of age or older, you have the right to direct us to not sell your Personal Information at any time (the “right to opt-out”). We do not sell the Personal Information of consumers we actually know are less than 16 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 16 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to Personal Information sales may opt-out of future sales at any time.
To exercise the right to opt-out, you (or your authorized representative) may click the DO NOT SELL MY PERSONAL INFORMATION button on our homepage, or submit a request to us at HLTH, LLC, 155 East 44th Street, Suite 701, New York, NY 10017or firstname.lastname@example.org.
We will only use Personal Information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. However, note that many features of our Site, our products, or our services will not function without your Personal Information. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. To make such a request, please send us an electronic message through our Site or write us at our address listed on our webpage.