Onsera Health, Inc. and its subsidiaries or affiliates (collectively, “We”, “Us”, “Our”, or “Onsera Health”).
This statement sets forth Onsera Health’s Privacy Policy (“Privacy Policy”) and describes the practices that We will follow with respect to the privacy of the information of users of this website and its various webpages (“Sites”). As used in this Privacy Policy, "Services" refers to the Sites and the services, features, and content offered by Onsera Health through or in connection with the Sites. “You”, “your”, or similar terms refer to you as a user of the Services. We encourage you to review this Privacy Policy regularly to stay informed about Our information practices and the choices available to you.
This policy applies to information we collect:
This policy does not apply to:
As used in this Privacy Policy, the terms “using” and “processing” information may include, amongst other things, subjecting such information to analysis, using cookies or web beacons, and managing information in a number of ways, including but not limited to: collection, storing, evaluating, modifying, deleting, using, combining, and/or disclosing.
Should you have any questions about this policy, Our HIPAA Notice of Privacy Practices, or Our practices, please send an email to privacy@onserahealth.com.
Onsera Health collects various types of information about you, as described below.
Identifiers. We may collect identifiers such as your real name, e-mail address, phone number, other contact information, username, account name, online identifiers, Internet Protocol (IP) address, and device identifiers associated with your device or browser.
Demographic Information. We may collect information that relates to characteristics of protected classifications under California or federal law, such as date of birth, age or age range, and gender.
Commercial Information. We may collect commercial information, including records of products or services purchased, obtained, or considered, and transactional information about the products or services that you purchase. We may also collect information about your favorite products, hobbies and interests, and household or lifestyle data.
Internet or Other Electronic Network Activity Information. We may collect information about your use of Our Services, including technical information about your device, browser, or mobile carrier; usage information such as when you access the Services, for how long, and the websites you accessed before or after your use of the Services; and information concerning your interaction with the Services. We may also collect online identifiers such as device identifiers and IP address. If you link a third-party social media account with Us, We may collect information you have publicly shared on your account and information about your interaction with Our Services through that linkage.
Geolocation Data. We may collect or infer information about your approximate location based on your zip code or IP address.
Audio, Electronic, Visual, and Similar Sensory Information. We may collect content that you create and share with Us on third-party social networks, such as photos, videos, personal stories, or other similar media or content. Where permitted, We may collect and publish consumer-generated content in connection with activities such as contests and other promotions, community features, consumer engagement, and third-party social networking. We may also collect information you provide when you request customer support or otherwise communicate with Us.
Inferences. In order to better understand Our customers and offer products and services of interest to you, We may draw inferences from the information We collect to create a profile reflecting your preferences, characteristics, interests, and trends. Examples may include inferences drawn from your age range, geographic indicators (such as zip code), favorite products, hobbies and interests, household or lifestyle data, transactional information about products or services you purchase, and information about your interaction with Our Services.
You may choose not to provide Us with certain information, but that may result in Our inability to provide you access to the Services.
There are several ways We may obtain information about you. Onsera Health collects information from you (a) that you choose to share with Us when using Our Services and when you otherwise interact with Us, such as through Our customer service channels, (b) that We collect automatically when you use Our Services, and (c) that We receive from third parties.
We collect information from you directly. We collect information when you use Our Services or otherwise interact with Us. This may include signing up for communications. We may collect information when you use the Services (including when you use computer vision features, body scales, blood pressure cuffs, other hardware provided through the Services), or enter a promotion or contest, or if you participate in any of Our surveys or provide a review. We may also, with your consent, record your interactions with your healthcare providers and health coaches or your exercises or other engagement with Our mobile application or otherwise collect identifiable information about you from Our website and mobile application.
We collect information automatically. We and Our third party service providers collect data about you using automated technology like cookies and pixels via Our Services to support site functionality, analytics, and advertising as described below. We use these technologies to improve Our Services and your experience, see which areas and features of Our Services are popular, and count visits. They also help Us understand information like access times, pages viewed, links clicked, and the page you visited before navigating to Our Services. For more information about Our use of cookies and other tracking technologies, see the “Targeted Advertising and Analytics” section and the “Cookies” sub-section of the “Your Privacy Rights and Choices” section below.
We limit these technologies in sections of Our Services that are governed by Our HIPAA Notice of Privacy Practices. If you access a HIPAA-governed portal or experience, Our HIPAA Notice of Privacy Practices, not this Privacy Policy, describes how PHI is used and disclosed.
We get information about you from other sources. We may collect information about you from Our business partners or affiliates. We may also acquire information from other sources to help Us maintain the accuracy of the information We collect, personalize your experience with the Services, target Our communications so that We can inform you of products and services or other offers that may be of interest to you, measure ad quality and responses, and for internal business analysis or other business purposes.
To change or remove any information, please contact Us through the application, or at privacy@onserahealth.com.
We may use the information that We collect from and about you for a variety of business purposes, as noted below. We may combine personal and non-personal information collected by Onsera Health about you and may combine this information with information provided by external sources, as well as information collected offline, across other computers or devices that you may use, and from third party sources.
We and Our third party service partners may use cookies, web beacons, software development kits (“SDKs”), device identifiers, and other technologies to collect information about your use of Our Services and other website and mobile apps, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information allows Us to determine whether you have visited the Sites previously and save and remember any preferences that may have been set and statistically monitor how many people are using Our Sites and for what purpose. This information is used to deliver advertising targeted to your interests and to analyze and track data, determine the popularity of certain content and better understand your activity. We may also make use of “persistent” or “memory based” cookies, which remain on your computer’s hard drive until you delete them. You have the ability to modify your browser to either accept all cookies, notify you when a cookie is sent, or reject all cookies, but it may not be possible to utilize Our Services if you reject all cookies. Web beacons are small pieces of code (also called pixels) that are embedded on the pages of websites and that can report your visit or use to a third party. We use web beacons to collect automatic information about Our visitors that may include identifiers that are considered personal information under applicable law. Onsera Health may use these tools for the purposes of web analytics, marketing, and error management. You may modify your browser to prevent web beacons from collecting automatic information about you.
We disclose information within Our family of companies. We may disclose information with the Onsera Health family of companies, which includes all direct and indirect subsidiaries and affiliates of parent company Onsera Health, Inc. and any future related companies.
We disclose information with service providers. We may disclose information with external companies who perform business, technical, professional, or marketing related services for Us. This also includes companies that help Us with fraud detection and Service operations. These vendors are contractually restricted from using personal information for purposes other than providing services to Us, except as permitted by applicable law.
We disclose information with other third parties We work with. We may disclose information to third parties that use information for their own purposes (for example, with data analytics vendors or market research companies). Where required by law, We provide choices, including the right to opt out of sales/sharing for cross-context behavioral advertising.
We disclose information if We think We have to in order to comply with the law or to protect ourselves. For example, We may disclose all categories of information to respond to a court order or subpoena. We will disclose information if a government agency or regulatory body requests it. This includes U.S. and non-U.S. law enforcement or regulatory authorities.
We may disclose information in connection with a corporate transaction. If We are involved in a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction.
We disclose aggregate or anonymous information. We may disclose aggregate, anonymous, or de-identified information that cannot reasonably be used to identify you or via scientific research papers regarding Our Services.
We disclose information as permitted by law and for other reasons We may describe to you.
We disclose information to other third parties when you have consented to the disclosure.
Through your use of the Services, you may choose to make certain elements of your information, including PHI that you post and/or disclose in the course of engaging with the Services, available to other participants and users. While We take considerable efforts to protect your privacy, We cannot take and expressly disclaim responsibility for whether and how other users will use or disclose information made available by you through the Services. Only make such personal information available that you feel comfortable disclosing to other participants and users.
Onsera Health may contact you by email, postal mail, short message service (“SMS”), multimedia messaging service (“MMS”), text message, or other reasonable means now known or hereinafter developed. Onsera Health will provide notice and request consent to receiving text messages at the point of collection for mobile phone numbers. By providing your telephone number, you agree to receive messages from Onsera Health, including informational and promotional messages, which may be sent by an automatic telephone dialing system. If you enroll in Onsera Health's services, text messaging will be governed by the applicable Onsera Health member privacy policy.
We use reasonable administrative, technical, and physical safeguards designed to protect information. However, email and SMS are not always encrypted end-to-end and may be transmitted through or stored by third-party providers outside Our control. Please use care when choosing what information to send via email or SMS.
Opting out of targeted advertising, sharing, and sales. As described in the “Targeted Advertising and Analytics” section above, We process personal information to understand and improve your experience with Our Services. Some of these activities may be considered “sales” or “sharing” of your personal information or “targeted advertising” under certain laws. Depending on where you reside, you may have the right to opt out of targeted advertising, sharing, and sales of your personal information. You can do so by navigating to the “Your Privacy Choices” link at the bottom of this page or by visiting Our Sites with a legally-recognized opt-out preference signal enabled, such as the Global Privacy Control. Please note that, depending on which opt-out preference signal you use and whether you are logged into your account with Us, Our processing of the signal may be limited to the specific browser or device that you are using Where required by law, We process legally recognized opt-out preference signals (such as the Global Privacy Control) for the browser or device that sends the signal, and in some cases We may need additional information (for example, if you are logged into an account) to apply your choice more broadly. You may need to renew your opt-out if you use a different browser or device to access Our Services.
Cookies. Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of Our Sites.
Communication preferences. You may opt out of receiving promotional communications from Us by following the instructions presented at the time you sign up for them, as well as by following the instructions in those communications. If you opt out, We may still send you non-promotional communications, such as those about your account, relationship with Us, or Our ongoing business relations.
We use reasonable administrative, technical and physical safeguards to protect your personal information. However, while We strive to protect your personal information, We cannot ensure or warrant the security of any information you transmit to Us or receive from Us while that information is in transit. This is especially true for information you transmit to Us via email since We have no way of protecting that information until it reaches Us since email does not have the security features that are built into Our Sites.
If you are using an Onsera Health website or mobile application for which you registered and choose a password, We recommend that you do not share your password to anyone. Do not store extraneous personal information on Onsera Health provided devices, as We cannot protect the safety and security of devices in your personal possession, and keep the device password protected. We will never ask you for your password in an unsolicited phone call or in an unsolicited email. Always remember to sign out of the Onsera Health website and close your browser window when you have finished using the Services. This is to ensure that others cannot access your personal information and correspondence to Us if others have access to your computer or mobile device.
The Onsera Health Sites and Services are not designed to be used by or intended to attract children under the age of 13. Individuals who We actually know are under the age of 13 will not be permitted to use the Onsera Health Sites and Services and We will not collect their personal information. We do not share the personal information of consumers We know to be less than 16 years of age, unless We receive affirmative authorization (the “Right to Opt In”) from the minor who is between 13 and 16 years of age. If you are a parent or guardian and you are aware that your child who is under the age of 13 has provided Us with identifiable personal data, please contact Us. If We become aware that We have inadvertently collected data from children under the age of 13 without verification of parental consent, We will timely remove that information from Our servers to the extent permissible by law.
We want to provide website visitors valuable information, services, and products. Featured programs and other Onsera Health website content may link Our users to third-party websites. Onsera Health does not control and is not responsible for privacy or security practices of any third party websites or the information that is collected, stored, or used by those sites, so please read each site’s privacy policy carefully.
Do Not Track is an optional setting that enables you to express your preferences regarding the collection of information about your online activities over time and across third-party websites. Your browser sends Do Not Track signals to the websites you visit expressing your preference not to be tracked. However, because there is no industry-standard approach to responding to Do Not Track signals, We do not process or respond to Do Not Track signals.
We will retain your personal information for as long as is necessary for the purposes set out in this Policy unless a longer period is required under applicable law or is needed to resolve disputes or protect Our legal rights. For example, We generally retain (i) account information for as long as your account is active and for a limited period thereafter, (ii) customer support communications for a period necessary to address your request and maintain records, (iii) security and fraud-prevention logs for a limited period to investigate and prevent misuse, and (iv) marketing contact information until you unsubscribe or We no longer need it for Our communications. In addition, where We are processing personal information based on contract requirements, We generally will retain the information for the duration of the contract plus some additional limited period of time that is necessary to comply with law or that represents the statute of limitations for legal claims that could arise from the contractual relationship.
Updates
As We continually update and improve Our Services, We may periodically make changes to this Privacy Policy. Or, We may modify this Privacy Policy to reflect new changes in laws or regulations. Accordingly, please check back and review this Privacy Policy periodically.
If you live in California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah and Virginia, you may have certain rights that apply to you. Please note that many of these State Laws specifically exclude medical information or PHI and other data that is collected by a covered entity or business associate governed by HIPAA. If you are a resident of one of these states, this section may apply to you.
In the preceding 12 months, We have made disclosures as described herein. We collect the following categories of personal information: identifiers, demographic information, commercial information, internet or other electronic network activity information, audio and visual data, and inferences. For details about the precise data points We collect and the sources of such collection, please see the “Information We Collect” section above.
We collect personal information for the business and commercial purposes described in the “Use of Information” section above.
We disclose personal information to Our service providers or contractors for the following business and commercial purposes:
Depending on where you live, you may have the following rights:
To exercise your rights, please email Us at privacy@onserahealth.com. We will verify your request by asking you to provide certain identifying information, which may include your name, email address, mailing address, and phone number. In some cases, We may request different or additional information, including a signed declaration that you are who you say you are. We will inform you if We need such information.
We will assess any request to exercise one of these rights on a case-by-case basis. There may be circumstances in which We are not legally required to comply with your request because of a relevant legal exemption provided for under applicable law.
You can opt out of the sale or sharing of your personal information through website tracking technologies by navigating to the “Your Privacy Choices” link at the bottom of this page or by visiting Our Sites with a legally-recognized opt-out preference signal enabled, such as the Global Privacy Control. Please note that, depending on which opt-out preference signal you use and whether you are logged into your account with Us, Our processing of the signal may be limited to the specific browser or device that you are using. Where required by law, We process legally recognized opt-out preference signals (such as the Global Privacy Control) for the browser or device that sends the signal, and in some cases We may need additional information (for example, if you are logged into an account) to apply your choice more broadly. You may need to renew your opt-out if you use a different browser or device to access Our Services.
Nondiscrimination
We will not discriminate or retaliate against you for exercising your privacy rights. If you choose not to disclose certain personal information, this may limit Our ability to provide the Services to you.
Appeals
If We deny your request, you may appeal Our decision by contacting Us at legal@onserahealth.com. If you have concerns about the results of an appeal, you may contact the Attorney General in the state where you reside.
Authorized Agents
If you reside in certain states, you can designate an authorized agent to submit a privacy rights request on your behalf. We may ask authorized agents to submit proof of your authorization to make the request, such as a valid power of attorney or proof that you have signed permission from the individual who is the subject of the request. Please do not provide any sensitive personal information in connection with the request, such as a driver's license or other government-issued ID. In some cases, We may be required to contact the individual who is the subject of the request to verify his or her own identity or confirm you have permission to submit this request. If you are an authorized agent seeking to make a request, please contact Us at privacy@onserahealth.com. We do not use or disclose sensitive personal information for the purpose of inferring characteristics about you.
Some of Our advertising and analytics activities may constitute “sharing” or “selling” under California law. In order to advertise Our products to you and better understand, improve, and personalize Our interactions with you, We share and sell the following categories of personal information to the following categories of third parties:
We do not knowingly sell or share personal information about consumers under the age of 16.
You have the right to opt out of sharing and sales at any time by navigating to the “Your Privacy Choices” link at the bottom of this page or by visiting Our Services with a legally-recognized opt-out preference signal enabled, such as the Global Privacy Control. Please see the “Your Privacy Rights and Choices” section above for more information about your privacy rights and how to exercise them.
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