Effective date: April 10, 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.
EU residents may have different or additional rights, please see Section 10 below.
5. Opting Out
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 Foundation (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:
Category (Specific Fields)
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 Foundation 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 Foundation 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 submit a request to us at HLTH FOUNDATION, 155 East 44th Street, Suite 701, New York, NY 10017 or email@example.com.
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.
10. RIGHTS OF EU RESIDENTS
Under certain circumstances, EU residents have rights under data protection laws in relation to their personal data. If you are an EU resident, you have the right to:
Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us using the information at the top of this page, or emailing us at firstname.lastname@example.org.
NO FEE USUALLY REQUIRED
You will not have to pay a fee to access your personal data (or to exercise any of the other rights unless your request is clearly unfounded, repetitive or excessive, in which case we may charge a reasonable fee. Alternatively, we may refuse to comply with your request in these circumstances.
WHAT WE MAY NEED FROM YOU
We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
TIME LIMIT TO RESPOND
We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
Whenever we transfer personal data out of the European Economic Area, we ensure that a similar degree of protection is afforded to it by implementing at least one of the following safeguards:
We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission.
Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US.