Introduction

This Privacy Policy (“Privacy Policy”) explains how Clinakos, Inc. (“Clinakos,” “we” or “us”) collects, uses and shares personally identifiable information of visitors of our web site (the “Site”), users of our application (the “App”) and users of our products and services (the “Services”). By using the Site, App, and/or Services, you consent to the collection, use, and disclosure of your personally identifiable information in accordance with this Privacy Policy.

Information we collect and how we use it

You can generally visit the Site without revealing any personally identifiable information about yourself. We do not collect personal information from our Site visitors without the Site visitor providing us with this information as set forth in this Privacy Policy.

If you request to receive company or product information or request an online or trial demonstration of the Services, you will be asked to complete the contact form on our Site that asks for your name, title, e-mail address, company name, state or province, country, and phone number. You can also voluntarily provide comments to us when submitting the request form. We use the information from the request form to deliver the requested information and/or provide you with an online demonstration of the Services.

Use of the App/Services requires that you provide certain personally identifiable information, that may include (but not be limited to) your name, age, gender, telephone and address information.

You allow us to gather Personal Health Information about you (including medical records, treatment information, health benefit information, and financial information) in order to provide the Service to you. This information may be gathered from your healthcare providers or other third parties. You allow us to use your personally identifiable information to register you to use the Services and provide you with the Services; verify your authority to enter the App and access the Services; notify you of Services updates; improve the content and general administration of the App and the Services; provide you with notices regarding the Services and other services that you have purchased or may wish to purchase in the future. We do not provide e-mail addresses to third parties for marketing purposes. Pursuant to the terms of your Services Agreement, we may remove personal identifiers from personal information so it cannot be reasonably used for identification and may use such de-identified information as part of our Services and for any other purposes. We may aggregate and/or de-identify information collected (such that it cannot be used to identify you) and may use de-identified or aggregated data for any purposes allowed by law, including sharing such de-identified or aggregated information with third parties for research or analysis.

Other information collected

Clinakos may also automatically collect and analyze information about your general usage of the Site, App, and Services. We might track your usage patterns to see what features of the Site, App, and Services you commonly use, Site traffic volume, App traffic volume, frequency of visits, type and time of transactions, type of browser, browser language, and IP address, type of operating system, other unique identifiers, including mobile device identification numbers,  sites you visited before and after visiting the Site, information collected through cookies, web beacons, and other technologies, information about your interactions with emails or in-app messages, such as the links clicked on and whether the messages were opened or forwarded, standard server log information, and statistical information about how you use the Services.

 We may use cookies, pixel tags, and similar technologies to automatically collect this information.  Cookies are small bits of information that are stored by your computer’s web browser. Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.  By using the Services, you consent to our use of cookies and similar technologies. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services, or features on the Services.

Children

Clinakos recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Neither the Site nor the App is intended for children under the age of 13 and we endeavor not to collect any personally identifiable information from children under the age of 13. Clinakos targets its Site, Services, and App to adults and not to children under 13.

California Resident Privacy Rights

California residents have the right to request from certain businesses with whom the California resident has an established business relationship (as such terms are defined by the CCPA and CPRA) a list of all third parties to which the business, during the previous calendar year, has disclosed certain personally identifiable information for direct marketing purposes. This request is only required to be granted once during any calendar year. To obtain this information, you should send a written request to support@clinakos.com with the subject heading “California Privacy Rights.” In your request, please attest to the fact that you are a California resident and provide a current California address for our response. Please be aware that not all information sharing is covered by the California Privacy Rights requirements and only information on covered sharing will be included in our response.

Under the CCPA, personal data does not include certain publicly available information, deidentified or aggregated consumer information, and certain types of other information such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) or the California Confidentiality of Medical Information Act (CMIA), or clinical trial data subject to the Common Rule. The CCPA also does not apply to information that is de-identified in accordance with the requirements for deidentification set forth in Section 164.514 of Part 164 of Title 45 of the Code of Federal Regulations and is derived from patient information that was originally collected, created, transmitted, or maintained by an entity regulated by the Health Insurance Portability and Accountability Act, the Confidentiality of Medical Information Act, or the Federal Policy for the Protection of Human Subjects. Therefore, this section also does not cover our collection, licensing, or disclosure of such de-identified information.

Disclosure for Colorado, Virginia, Utah, and Connecticut Consumers

‍We do not sell or share Personal Information to Third Parties or process Personal Information for purposes of targeted advertising, as the terms “sell,” “share,” “process,” and “targeted advertising” are defined in the CPA, VCDPA, UCPA, and CDPA. If you believe we have, please contact us immediately at support@clinakos.com with the subject heading “(Insert Your State) State Disclosure”

General Data Protection Regulation

We do not knowingly collect personal information about individuals residing in the European Union.  If you believe that we have collected or processed personal information about any individuals residing in the European Union, please contact us immediately at support@clinakos.com with the subject heading “GDPR.”

Disclosure of your personal information

We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties. We may also disclose your personally identifiable information: (a) if we are required to do so by law, regulation or other government authority or otherwise in cooperation with an investigation of a governmental authority, (b) to enforce our client agreements, or (c) to protect the safety of users of our Site, our App and our Services. In addition, we may transfer your personally identifiable information to a successor entity upon a merger, consolidation, or other corporate reorganization.

Data retention

We retain personal information and the personal data we process on behalf of our customers for as long as needed to provide the Services. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements with customers, and/or the period required by laws in applicable jurisdictions.

Updating, correcting, and deleting your information

If you believe that Clinakos has incorrect information that was provided as part of the Services, you may use the Services to correct, amend, or delete that information. You may also contact us by e-mailing our customer support at support@clinakos.com. Alternatively, you may send a letter with your requested changes, corrections, or deletions to the address listed on our website.

Opt-out preferences

If you wish to subscribe to our newsletter(s) or other materials available through the Site, we will use your name and email address to provide them to you. If you wish to opt out of receiving these materials, you may follow the unsubscribe procedure provided in the email.

Security

The security of your personal information is important to us. Clinakos employs procedural and technological measures to protect your personally identifiable information. These measures are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration, or destruction. We may use software, secure socket layer technology (SSL) encryption, password protection, firewalls, internal restrictions, and other security measures to help prevent unauthorized access to your personally identifiable information. However, Clinakos cannot guarantee that unauthorized third parties will never be able to defeat these measures or use your personally identifiable information for improper purposes. Therefore, you should be aware that when you voluntarily display or distribute personally identifiable information, that information could be collected and used by others. Clinakos is not responsible for the unauthorized use by third parties of information you post or otherwise make available publicly.

Links to other websites

The Site, App, and Services may provide links to third party websites or resources not associated with us and over which we do not have control (“External Web Sites”). Such links do not constitute an endorsement by Clinakos of the External Web Sites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that Clinakos is only providing these links as a convenience, and cannot be responsible for the content of such External Web Sites.

Material Changes

Clinakos reserves the right to change this Privacy Policy from time to time. Clinakos will post the revised Privacy Policy on this App located at https://www.clinakos.com/privacy-policy. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Site, App, and/or Services will be subject to the then-current Privacy Policy.

We welcome your comments or questions concerning our Privacy Policy. If you would like to contact Clinakos regarding this Privacy Policy, please contact us by emailing us at support@clinakos.com.