Effective: August 21, 2020
Attend Behavior, Inc. (“Attend”) operates the website and mobile application (collectively, the "Platform"). This Privacy Notice describes the types of personal information we collect, how we use the information, with whom we share it, and the choices you can make about our use of the information. We also describe the measures we take to protect the security of the information and how you can contact us about our privacy practices. Please review this Privacy Notice carefully.
For the purposes of applicable Data Protection Laws including the European Economic Area data protection law, (the "Data Protection Law"), the Data Protection Officer is Attend Behavior, Inc., and can be reached via email at firstname.lastname@example.org. For additional contact details, visit our website.
TABLE OF CONTENTS
- INFORMATION COLLECTION
- HOW WE USE THE INFORMATION WE COLLECT
- How We Share Your Information
- YOUR CHOICES
- SECURITY OF INFORMATION COLLECTED
- ABILITY TO MODIFY OR DELETE YOUR INFORMATION
- THIRD PARTY WEBSITES
- LIMITATION OF LIABILITY
- CHANGES TO THIS PRIVACY NOTICE
- CONTACT US
- YOUR CALIFORNIA PRIVACY RIGHTS
We may collect information about you directly from you and from third parties, as well as automatically through your use of the Platform. The types of personal information we may collect from users of the Platform include but are not limited to: full name, gender, date of birth of the child, home address, email address, home telephone number, mobile telephone number, work telephone number, preferred language, health-related information (including information about your height and weight and health status, healthcare and treatment, and health insurance information), communications preferences, IP address, and user ID and password.
Information We Collect
You can use the website without registering, but registration is required to log-in to the Platform, to interact with healthcare providers using the Platform, and to take advantage of other services offered by the Platform.
Healthcare Provider Users. If you are a healthcare provider and wish to register for the Platform as a Healthcare Provider User, you must provide us with certain information about yourself and your practice. Such information may include but is not limited to: name, address, email address, mobile and work phone, practice name, and a user ID and password. We may also collect certain optional information, including how long you have been treating patients, the number of patients you see each month, your home address and telephone number, and your communication preferences.
User Generated Content. Some of the Platform’s features provide you with the ability to post content about yourself. Additionally, the Platform may enable users to communicate or interact with each other. If you choose to interact with another user on the Platform, that user may be able to view certain information about you, including personal information (such as your full name and contact information). WE CANNOT PREVENT SUCH INFORMATION FROM BEING USED BY OTHERS IN A MANNER THAT MAY VIOLATE THIS PRIVACY NOTICE, THE LAW, OR YOUR PERSONAL PRIVACY.
Information Third Parties Provide About You
We may supplement the information we collect about you with outside records from third parties in order to provide you with information, services, or goods you have requested, to enhance our ability to serve you, and to tailor our content to you. We may combine the information we receive from those other sources with information we collect through the Platform. In those cases, we will apply this Privacy Notice to the combined information.
Information Collected Automatically When You Access & Use the Platform
In addition to any personal information or other information that you choose to submit to the Platform, we and our third party service providers may use a variety of technologies that automatically or passively collect certain information whenever you visit or interact with the Platform (“Usage Information”). Usage Information may include the browser and operating system you are using, the URL or advertisement that referred you to our Platform, the search terms you entered into a search engine that lead you to our Platform (if applicable), all of the areas within our Platform that you visit, the time of day you viewed the Platform and Platform traffic, among other information. Usage Information also includes the IP address or other unique identifier (“Device Identifier”) for any computer, mobile phone, tablet or other device (any of which are referred to herein as a “Device”) used to access the Platform. A Device Identifier is a number that is automatically assigned to your Device, and our servers identify your Device by its Device Identifier. Some mobile service providers may also provide us or our third-party service providers with information regarding the physical location of the Device used to access the Platform.
We may use Usage Information for a variety of purposes, including enhancing or otherwise improving the Platform and our products and services. Usage Information is generally non-identifying, but if we associate it with you as a specific and identifiable person, we treat it as personal information.
The methods that may be used to collect usage information include but are not limited to the following:
- A cookie is a data file placed on a device when it is used to visit the Platform or otherwise access our app or online content. Cookies may be used for many purposes, including, without limitation, remembering you and your preferences and tracking your visits to our web pages. If you choose to disable cookies on your device, some features of the Platform or our content may not function properly.
- Web beacons. Small graphic images or other web programming code called web beacons (also known as “1x1 gifs” or “clear gifs”) may be included in our web pages and e-mail messages. web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or e-mail can act as a web beacon. web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Platform, to monitor how users navigate the platform, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed.
- Embedded scripts. An embedded script is programming code that is designed to collect information about your interactions with the Platform, such as the links you click on. the code is temporarily downloaded onto your device from our web server or a third party service provider, is active only while you are connected to the Platform, and is deactivated or deleted thereafter.
HOW WE USE THE INFORMATION WE COLLECT
We and our affiliates may use information collected through the Platform, including your personal information and Usage Information, to:
- Enable and allow you to participate in features and services we offer or to provide related customer service, including, without limitation, to respond to your questions, complaints, or comments;
- Tailor the content we display to you;
- Process a transaction you initiate;
- Provide you with information, products, or services that you have requested or agreed to receive;
- Communicate with you about our services, offers, events, and promotions, and offer you products and services we believe may be of interest to you;
- Enable you to communicate with us through our social networks or platform features;
- Process your registration with the Platform and manage your account, including verifying that your e-mail address is active and valid;
- Operate, evaluate, or improve the platform and our business and our affiliates’ businesses (including developing new services; managing our communications; determining the effectiveness of and optimizing our advertising; analyzing our services, websites, apps. and any other digital assets; facilitating the functionality of our websites, apps. and any other digital assets; and performing accounting, auditing, billing, reconciliation, and collection activities);
- Anonymize personal information and prepare and furnish aggregated data reports showing anonymized information (including, but not limited to, the following: compilations, analyses, analytical and predictive models and rules, and other aggregated reports) for our and our affiliates’ business purposes;
- Contact you with regard to our and our affiliates’ services, or your use of the Platform, and, in our discretion, changes to the Platform policies or functionality;
- Protect against, address, and prevent fraud, unauthorized activities, claims, and other liabilities, and manage risk exposure and enforce legal and contractual obligations;
- As may be required by applicable laws and regulations or as requested by any judicial process or governmental agency having or claiming jurisdiction over us or an affiliate; and
- Comply with industry standards and our policies.
How We Share Your Information
We may share the information that we collect about you, including personal information and Usage Information, for example:
- We may share your information with our affiliated companies and subsidiaries, subject to the terms of this Privacy Notice.
- We may share information with third party service providers that perform services on our behalf, including without limitation, those that host and operate the Platform.
- We may share information to comply with law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena in compliance with applicable privacy laws, or at the request of governmental authorities conducting an investigation.
- We may share information to analyze and enhance our marketing communications and strategies (including by identifying when emails sent to you have been received and read).
- We may share information to respond to claims that any information you provide violates the rights of third parties.
- We may share information to investigate, prevent, or take action regarding actual or suspected illegal activities, suspected fraud, emergencies, violations of any Platform Terms of Service, this Privacy Notice, or other agreement, or as evidence in litigation in which we are involved, or to protect the rights, property, or personal safety of attend, its affiliates, users, third parties, and/or the public.
- We may share information in relation to the sale, assignment, transfer, or acquisition of all or substantially all of Attend’s assets or shares by a third party.
- We may share information with other third parties with your consent as required by law.
- We may share usage information and other aggregate or de-identified information about users with third parties for marketing, advertising, research and other purposes.
We offer you certain choices about what personal information we collect from you, how we use that information, and how we communicate with you. You may withdraw any consent you previously provided to us or object at any time. We will apply your preferences going forward. In some circumstances, withdrawing your consent to our use or disclosure of your personal information will mean that you cannot take advantage of certain offerings or Platform features. Your choices include the following:
- You may choose not to receive marketing email communications from us by clicking on a link in the marketing emails to unsubscribe. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any services you have requested or received from us.
- Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. please note, however, that disabling cookies may cancel opt-outs that rely on cookies.
You have certain rights relating to your personal information, subject to local data protection laws. These rights may include the right:
- to access your personal information held by us;
- to erase/delete your personal information, to the extent permitted by applicable data protection laws;
- to receive communications related to the processing of your personal information that are concise, transparent, intelligible and easily accessible;
- to restrict the processing of your personal information to the extent permitted by law (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your information, including the right to object to marketing;
- to request that your personal information be transferred to a third party, if possible;
- to receive your information in a structured, commonly used and machine-readable format;
- to lodge a complaint with a supervisory authority;
- to rectify inaccurate personal information and, taking into account the purpose of processing the information, ensure it is complete; and
- to not be subject to a decision based solely on automated processing, including profiling, which produces legal effects.
Although we will use reasonable efforts to do so, you understand that it may not be technologically possible to remove from our systems every record of your personal information that we have. The need to back up our systems to protect information from inadvertent loss means a copy of your information may exist in a nonerasable form that will be diﬃcult or impossible for us to locate or remove.
SECURITY OF INFORMATION COLLECTED
Personal information we collect through the Platform will be stored on third-party cloud-based server even if you are accessing the Platform from outside the United States. Your country’s data protection laws may not apply and may be more stringent than those to which Attend is legally subject. Personal information may be transmitted to third parties, which parties may store or maintain the data on their secure servers.
We use administrative, physical, and technical safeguards designed to protect the personal information you provide or we collect against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use.
Despite our efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your account by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your user ID and password private. WE AND OUR AFFILIATES ARE NOT RESPONSIBLE FOR ANY LOST, STOLEN, OR COMPROMISED PASSWORDS OR FOR ANY ACTIVITY ON YOUR ACCOUNT VIA UNAUTHORIZED PASSWORD ACTIVITY.
WE AND OUR AFFILIATES ARE NOT RESPONSIBLE FOR THE HANDLING, SHARING, RE-SHARING, AND/OR DISTRIBUTION OF YOUR HEALTH INFORMATION. MOREOVER, IF YOU FORWARD HEALTH INFORMATION ELECTRONICALLY TO ANOTHER PERSON ON OR OFF THE PLATFORM, WE AND OUR AFFILIATES ARE NOT RESPONSIBLE FOR ANY HARM OR OTHER CONSEQUENCES FROM THIRD PARTY USE OR RE-SHARING OF YOUR HEALTH INFORMATION.
The Platform will not respond to Web browser “do not track” signals. We may link to social media platforms, as such, other parties may collect your personally identifiable information about your online activities over time and across different web Platforms when you visit this Platform.
Please note that not all tracking will stop even if you delete cookies.
We will retain personal information for as long as you maintain an account and up to seven (7) years after the account is closed. The exact period of retention will depend on the type of information, our contractual obligation to you, and applicable law. We keep your information for as long as necessary to fulfill the purpose for which it was collected, unless otherwise required or necessary pursuant to a legitimate business purpose outlined herein. At the end of the applicable retention period, we will remove your information from our databases and will request that our business partners remove your information from their databases. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further processing of such information. We may retain anonymized data indeﬁnitely. Contact us via the contact information found on the Attend website regarding the applicable data retention period for your personal information.
NOTE: Once we disclose your information to third parties, we may not be able to access that information any longer and cannot force the deletion or modiﬁcation of any such information by the parties to whom we have made those disclosures. Written requests for deletion of information other than as described should be directed to us via the contact information found on the Attend website.
ABILITY TO MODIFY OR DELETE YOUR INFORMATION
As a registered user, as required by law, we will permit you to modify registration information by logging into your account and updating your profile information. You may request to delete any personal information we possess by using via contact information found on the Attend website.
THIRD PARTY WEBSITES AND THIRD PARTY SERVICE PROVIDERS
Our Platform contains links to other websites and may use services provided by third parties. These websites and services may operate independently from us. Linked websites and third party service providers may have their own privacy notices or policies, which we strongly suggest you review if you visit any linked websites or use any third party services. To the extent any linked websites you visit or third party services are not owned or controlled by us, we are not responsible for the websites’ or the third party services’ content, any use of the websites or the third party services, or the privacy practices of the websites or the third party service providers.
INFORMATION SUBMISSION BY MINORS
Although the Platform may ask you to share information related to a minor, we do not knowingly collect personal information directly from individuals under the age of 18 and Attend is not directed to individuals under the age of 18. We request that these individuals not provide personal information to us directly. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such information from our records. If you are aware of a user under the age of 18 using the Platform, please contact using the contact information found on the Attend website.
LIMITATION OF LIABILITY
CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice is current as of the Effective Date set forth above. We may change this Privacy Notice from time to time, and without prior notice to you, so please be sure to check back periodically. We will post any changes to this Privacy Notice on this page. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.
We encourage you to contact us if you have any questions or concerns regarding the privacy aspects of our Platform or would like to make a complaint, via the contact information listed on our website.