This Privacy Statement describes the practices and policies of Ginger.io Inc, ("Ginger.io") regarding the collection, use, storage, and disclosure of personally identifiable information ("Personal Information") we collect from our website (www.ginger.io) (the "Website"), mobile application (the "App"), and related services (collectively, the "Services" or "Service")
You may have been invited to use, download or install the Service by your Employer, as part of an ongoing study or research project or your healthcare provider (an "Institutional Client"), or a third party healthcare provider, such as Ginger.io of California Medical P.C. ("G.io Medical"), whose services are provided through the Ginger.io mobile application, or you may have subscribed or downloaded and installed the Service for your personal use.
WHAT INFORMATION DO WE COLLECT?
We may collect the following types of Personal Information in connection with our delivery of Services to you:
- When you register to receive services from us, whether in your individual capacity or on behalf of an organization, we collect any Personal Information that you submit through our registration form, including your name, email address, mailing address, phone number, payment card information, and any other Personal Information you voluntarily submit through the online registration form (your "Account Data");
- When we deliver Services to you, we collect Personal Information and health information that you voluntarily provide to us, our coaches, clinicians including information about your personal goals and health circumstances (your "Care Data");
- When you use our Services we automatically collect information about your web browser, mobile device, and how and when you use our mobile application, including the manufacturer and model of the device, unique device identifiers, and IP address ("Mobile Data");
- We collect usage information about our Website and Services and use visitor logs to compile anonymous aggregate statistics, (e.g., information such as your web requests, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the paths you took on our Site, and IP Addresses) ("Usage Data");
- When you use the Services to respond to our surveys and health questionnaires, we may collect the information you voluntarily provide in your responses as well inferred health status for specific conditions and survey alerts (your "Survey Data").
We may also collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our Services.
HOW DO WE USE INFORMATION WE COLLECT?
We will use and store Personal Information for the purpose of delivering the Service to you and, where applicable, to Institutional Clients and healthcare providers, and to analyze and enhance the operation of the Service.
We also use and store Personal Information and, where applicable, information obtained from Institutional Clients and healthcare providers, for proprietary analysis and development of personalized behavioral profiles for you and/or, where applicable, the healthcare provider or Institutional Client.
In particular we use:
- Account Data to manage your account, communicate with you in relation to your account, process your transactions, and deliver and monitor the performance of our services;
- Care Data to help you, your coach, clinician, or healthcare provider understand your personal objectives and circumstances, help you develop and execute strategies to overcome your challenges and achieve your goals, deliver appropriate care, evaluate the quality and progress of our program, and optimize delivery of services;
- Mobile Data to monitor and enhance the performance of the App, analyze trends, usage and activities in connection with the App, and ensure its technological compatibility with users;
- Usage Data to analyze trends, administer our services, improve the design of our App and Website, and otherwise enhance the services we provide;
- Survey Data and reports to our coaches, clinicians, and applicable Institutional Clients to better understand your health status, provide feedback, and to provide proactive alerts.
To allow for additional research, product development, and insights over time, Ginger.io may anonymize or de-identify your Personal Information and health information in a manner that meets the Health Insurance Portability and Accountability Act of 1996 (HIPAA) de-identification standard, such that such data is no longer reasonably identifiable.
We create statistical, aggregated data relating to our users and the Service for analytical purposes. Aggregated data includes data derived from Personal Information and obtained by Ginger.io from other sources in aggregated, anonymous form. Aggregate Information cannot reasonably be used to identify any individual. We use Aggregate Information to understand our customer base, market our Services, and improve and enhance our site and services.
EMAIL AND OTHER COMMUNICATIONS
We may use your personal information to contact you regarding an inquiry or to provide you with more information about Ginger.io or other marketing information we believe you may be interested in. We will send you email alerts or notification messages unless you unsubscribe.
If you wish to opt out of these emails, you may do so by following the "unsubscribe" instructions in the email; provided however, Ginger.io may maintain the right to send you important emails about your account or the Services.
Email and text messaging allows healthcare providers to exchange information efficiently for the benefit of users/patients. We recognize that email and text messaging may not be a completely secure means of communication. Your use of the Service means that you agree and consent to the use of email and/or text messaging as an acceptable form of communication.
We value your feedback on, and appreciate any testimonials about, our Services. If you send us any such feedback or testimonials, they shall be deemed, and shall remain, the property of Ginger.io and shall be subject to any obligation of confidence on our part. However, Ginger.io shall obtain prior written approval of any usage of your identity or contact information, if Ginger.io wishes to reference you in connection with that feedback or testimonial.
WHAT INFORMATION DO WE DISCLOSE TO THIRD PARTIES?
We will not sell or rent your personal information to any other company or organization We will not disclose your Personal Information to any third party except as follows:
- To a provider on whose behalf the information was collected for the purpose of providing services to you.
- To emergency services and other agencies to protect you, the clinician, the coach, or others from harm
- To third parties engaged to provide services on our behalf such as managing our accounts, processing transactions, operating the App, or providing customer service. We enter into agreements which require such providers to protect such information and use the Personal Information they receive only to perform services for us.
- To obtain and process payment for our services
- To law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights, to protect you, or to protect third parties.
- In the event of a reorganization, merger, acquisition, asset sale or similar transaction, we may transfer any and all Personal Information we collect to the relevant third party involved in the transaction, with your consent if and as required under applicable privacy laws.
- We may otherwise disclose your Personal Information only when we have your prior consent to share the information.
We may otherwise disclose your Personal Information only when we have your prior consent to share the information.
ACCESSING AND UPDATING YOUR INFORMATION
You have the right to review, amend, or correct your email address, Account Data, or other Personal Information held in our database. To do so, please contact us by sending an email to firstname.lastname@example.org with a clear description of your request. We will try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by applicable laws.
If you would like your Personal Information permanently removed from our database, please contact us at email@example.com. We will then terminate your account, you will no longer be able to use our services, and you will no longer receive emails from Ginger.io. Subject to applicable law and necessary record retention requirements, your identifying Personal Information shall be deleted from our records within 30 days of your request. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or authorized by law.
We use reasonable and appropriate security precautions to protect the security and integrity of your Personal Information in accordance with this Privacy Statement and applicable law. However, no Internet transmission is completely secure, and we cannot guarantee that security breaches will not occur.
We have implemented administrative, physical, and technical safeguards including use of SSL and encryption of your information.
Ginger.io does not knowingly collect or maintain personally identifiable information from persons under 18 years of age, and no part of the Service is directed at persons under 18.
To submit a question or concern, please contact us at firstname.lastname@example.org or write to us at the following address: Ginger.io, Inc. c/o Customer Support - Privacy 332 Pine Street Suite 800, San Francisco, CA 940104.
VISITORS FROM OUTSIDE THE UNITED STATES
Last Updated: May 1, 2018