Privacy Policy (United States)

Courage Health (the “Company”) values your privacy. By visiting the courage.health website, chatbot, or communicating with our Facebook ID, and any other linked pages, features, content, or related services offered from time to time by the Company in connection therewith or using any of our Services, you consent to this Privacy Policy and to our use and processing of Personal Information for the purposes set forth herein. Capitalized terms not defined in this Privacy Policy shall have the meanings set forth in our Terms, available at courage.health/terms-of-use.

“Company” or the terms “we” or “us” or similar terms refer to Courage Health, Inc. “You” or “your” or similar terms refer to you as a user of our Services.

By accepting our Privacy Policy during registration or by visiting and/or using the Site, the Chatbot, Facebook site or any of our Services, you (a) expressly consent to our collection, use, disclosure and processing of your Personal Information (as defined below) in accordance with this Privacy Policy, and (b) expressly acknowledge that you have read and understood our HIPAA Notice, which describes how we may use and disclose health information about you for treatment, payment or health care operations and for other purposes that are permitted or required by law, including the Health Insurance Portability and Accountability Act of 1996, as amended from time to time (“HIPAA”). Our HIPAA Notice is available at courage.health/hipaa. Any conflict between this Privacy Policy and the HIPAA Notice with respect to any PHI (as defined in the HIPAA Notice) shall be governed by the HIPAA Notice.

As used in this Privacy Policy, the terms “using” and “processing” information include, among other things, using cookies or embedded scripts on a computer, browser, laptop, tablet, mobile phone or other device (a “Device”), subjecting the information to statistical or other analysis, and using or handling information in any way, including without limitation collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and transferring information within our organization or among our affiliates within the United States or internationally, as well as using personal information to respond to user / applicant or sponsor (i.e., the entity or organization paying for your participation in our Services) requests and to provide the requested products and services.

1. WHAT DOES THIS PRIVACY POLICY COVER?

Personal Information – In General

This Privacy Policy covers how we use and disclose personally identifiable information that we gather from you starting from the time that you initially access our Site, our Chatbot or use our Services. Personally identifiable information refers to any information about you that can be used to contact or identify you and information on your use or potential use of the Site, our Chatbot or our Services, including, but not limited to, a first and last name, a personal profile, an email address or other contact information (collectively, “Personal Information”). Your privacy is important to us, and we are committed to carefully managing your Personal Information in connection with the Services that we provide. It is important for you to understand, however, that this policy does not apply to the practices of companies and / or websites or other third party services that we do not own or control, or to individuals that we do not employ or manage.

Protected Health Information

We are committed to maintaining the privacy and integrity of protected health information that we receive as part of your application for or participation in the our Services (“PHI”). PHI is Personal) Information that we receive as part of your application for or participation in the our program that relates to (a) your past, present, or future physical or mental health or condition, (b) the provision of health care to you, or (c) your past, present, or future payment for the provision of health care, which is created, received, transmitted, or maintained by the Company. This Privacy Policy describes how we protect your privacy as a visitor to, or general user of our Site, our Chatbot and Services. You have additional rights under federal and state law with respect to the access to, use, and disclosure of Personal Information that constitutes PHI. For a more complete description of your rights with respect to PHI, please refer to our HIPAA Notice, which provides important information to you about how we may use and disclose your PHI. Our HIPAA Notice is available here: courage.health/hipaa.

2. WHAT PERSONAL INFORMATION DO WE COLLECT?

We collect Personal Information you choose to provide us (e.g., through registrations, applications, use of the Services, surveys, and in connection with your inquiries), starting from the time that you initially access our Site, our Chatbot or use our Services. The information we gather from you enables us to administer your account, provide you with the Services, respond to your inquiries and send you communications regarding the Services and your access to and use of the same, obtain your feedback on our Site, our Chatbot and our Services, analyze user behavior and activity, personalize and improve our Services, conduct research activities and contact you about the services that we offer.

We collect the following types of information:

Personal Information You Provide to Us

We receive and store any information you enter on our Site, our Chatbot or provide to us through the Services, including any third party services that you connect with our Services. Personal Information that we collect may include things like your full name, gender, certain health information (e.g., cancer stage, cancer grade, date of diagnosis, etc.), and any other information or data that you provide when using our Site, our Chatbot and/or our Services.

Personal Information Collected Automatically.

We receive and store certain types of information whenever you interact with the Site, the Chatbot and / or use the Services. We automatically receive and record information on our server logs from your browser, including your Facebook username if accessing via Facebook Messenger, and the page you requested.

Cookies. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your browser to enable our systems to recognize your browser and tell us how and when pages in our Site are visited and by how many people. We use cookies to enhance visitors’ experiences by understanding how visitors and / or users engage with and navigate our Site. Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers and in some but not all instances can be blocked in the future by selecting certain settings. Each browser that you use will need to be set separately, and different browsers offer different functionality and options in this regard. Also, these tools may not be effective with regard to certain types of cookies (e.g., Adobe Flash or HTML5 cookies). Please be aware that if you disable or remove cookies on your Device, some parts of our Site or Services may not function properly and when you revisit our Site or Services your ability to limit cookies is subject to your browser settings and limitations.

We may choose to serve ads on the Site or the Chatbot. These ads may be delivered to users by our advertising partners, who may set cookies. These cookies allow the ad server to recognize your Device each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy refers only to the use of cookies by the Company and does not cover the use of cookies by any third parties (e.g., advertisers).

There may be other Tracking Technologies now and later devised and used by us in connection with the Site, Chatbot and Services. Further, third parties may use Tracking Technologies with our Website. We do not control those Tracking Technologies, and we are not responsible for them. However, you consent to potentially encountering third party Tracking Technologies in connection with your use of the Site and Services and accept that this Privacy Policy does not apply to the Tracking Technologies or practices of such third parties. In such cases, you must check the third party websites to confirm how your information is collected and used.

3. WHAT PERSONAL INFORMATION DO WE SHARE?

We will not rent, sell or share your Personal Information with other people or non-affiliated companies except to provide the Services, when we otherwise have your permission, as expressly permitted or required by the HIPAA Notice or as expressly permitted or required under this Privacy Policy, including under the following circumstances:

Messaging Services: We may provide functionality to permit you to send messages to other users through the Site, and or chatbot. Further, if a message you send using such functionality contains Personal Information, we cannot control how the Personal Information will be used or disclosed by the recipient of your message. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, in any message, and to be careful about the people to whom you send such messages.

Protection of the Company and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of the Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection, detection or suppression, and credit risk reduction. If necessary, we will make all legally required disclosures of any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted, electronically stored “personal information” or “medical information” (as defined in applicable state statutes on security breach notification). To the extent permitted by applicable laws, we will make such disclosures to you via email or conspicuous posting on your private profile on the Site or the Chatbot in the most expedient time possible and without unreasonable delay, insofar as consistent with (a) the legitimate needs of law enforcement, or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to control the sharing of this information.

De-identified Information: We may create De-Identified Information from the information that you share with us, including any Personal Information, and use such De-identified Information without restriction. We may, for example, share De-identified Information with the sponsors paying for your participation in the Services (e.g., reports containing data related to enrollment, engagement, retention, and outcomes to evidence overall program success metrics) and with third party administrators working with the sponsors to administer certain services to you (e.g., incentives vendors, wellness administrators, etc.). Again, we never disclose aggregate information in a manner that would identify you personally.

4. IS MY PERSONAL INFORMATION SECURE?

We employ industry standard administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. In addition, when we collect, maintain, access, use, or disclose your Personal Information, we will do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws, including, without limitation, HIPAA.

We exercise great care to protect your personal information. However, we cannot ensure or warrant the security and confidentiality of any information that you transmit to us or receive from us via the Services offered through our Site and Chatbot, by Internet or wireless connection, including email, or the appropriateness of the measures we use to safeguard such information. Unauthorized entry, access, or use; loss; hardware or software failure; and other factors, may compromise the security of your information at any time. This is especially true for any information that you transmit to us via email or text message, since we have no way of protecting that information until it reaches us. E-mail and text message and the communication lines they travel over do not have the security features that are built into our Site and Chatbot and may not be secure. If you have reason to believe that your data or your interactions with us are no longer secure, you may contact us at the email address, mailing address or telephone number listed at the end of this Privacy Policy. In addition, if you have privacy or data security related questions, please feel free to contact the office identified at the end of this Privacy Policy.

5. WHAT CHOICES DO I HAVE REGARDING MY PERSONAL INFORMATION?

As stated previously, you can always opt not to disclose information, even though it may be needed to take advantage of certain features of the Site, the Chatbot and the Services.

If you would like us to remove your records from our system, you may request deletion of your account with us by sending e-mail to privacy@courage.health. Please note that some information may remain in our records after deletion of your account, including any information or records we are legally obligated to retain. We will process your request within a reasonable time, but please note that you may receive additional communications and offers as we process your request.

If you do not wish to receive email or other mail, phone calls or texts from us, please click on the “Unsubscribe” link contained in the emails or indicate this preference by emailing us at privacy@courage.health. Please note that if you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Site, Chatbot and Services, and you are responsible for reviewing such legal notices for changes. We will process your request within a reasonable time, but please note that you may receive additional emails as we process your request.

6. HOW DO WE PROTECT CHILDREN’S PERSONAL INFORMATION?

The Services are not directed to children. We do not knowingly allow or solicit anyone under the age of 18 to participate independently in any of the Services. We do not knowingly collect Personal Information from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, please contact us. If we become aware that a user of the Services is under the age of 18 and has provided us with Personal Information without verifiable parental consent, we will delete such Personal Information from our files.

7. CHANGES TO THIS PRIVACY POLICY

By using the Site, Chatbot and Services, you agree to the current Privacy Policy and our Terms, into which this Privacy Policy is incorporated. We reserve the right, in our sole discretion, to modify, discontinue, or terminate the Services or to modify this Privacy Policy at any time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used or disclosed. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Site and/or sending you an email. By continuing to access or use the Services after we have posted a modification or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease accessing the Site or Chatbot and using the Services.

8. QUESTIONS OR CONCERNS

If you have any questions, concerns or complaints regarding privacy on our Site or Chatbot or if you want to make a request to access or correct your Personal Information, please contact our Privacy Officer at: privacy@courage.health

We will make every effort to respond to your questions, concerns, complaints and requests within a reasonable time.

Effective Date: October 1, 2017