Privacy and Cookie Notice

HealthVerity, Inc. (“HealthVerity”, “We,” “Us,” “Our”) takes the security and privacy of your personal information very seriously. This Privacy and Cookie Notice (“Notice”) describes how we process personal data about you that we collect through the website or mobile app operated and controlled by us from which you are accessing this Notice (the “Site”). This Notice does not apply to information that we collect offline, such as over the telephone, in person, or by facsimile, or through our other platforms. By using the Site, you agree to the terms and conditions of this Notice.

Some visitors to the Site may have entered into a separate written agreement with HealthVerity, such as the Marketplace Subscription Agreement or the Marketplace Participation Agreement, in which case both the terms and conditions of this Privacy Policy apply to your use of this Site and the terms and conditions of that separate written agreement govern the relationship between you and HealthVerity outside of this Site.

1. Personal Data We Collect

    1. “Personal Data” is information that identifies you as an individual, such as: name, email address, postal address, telephone number, and username or password.
    2. We may collect and process the following Personal Data about you:
      1. Information that you provide by filling in forms on the Site. This includes information provided at the time of registering to use parts of the Site, or when requesting information on the Site. We may also ask you for information when you report a problem with the Site.
      2. If you contact us, we may keep a record of that correspondence.
      3. Information that you provide in order to benefit from a particular feature or participate in a particular activity, such as when you sign up to receive emails from us.
      4. Information that you provide when you apply for a position through the Careers portion of the Site, including any information contained in any resume that you upload to the Site.
    3. Through your use of the Site, we may also gather certain information about your use of the Site that does not identify you individually, but may identify your computer or device. Generally, this information is collected through what we refer to herein as “Traffic Data.” We may collect and store such Traffic Data automatically whenever you interact with the Site. For example, we may collect your IP address, the hostname of your computer, browser information and reference site domain name every time you visit the Site. We may also collect information regarding user traffic patterns and site usage. This Traffic Data does not, however, contain anything that identifies you personally; it is used to analyze and improve the Site and to provide our users with a fulfilling Internet experience. Please see the section below in this Notice regarding Passive Information Collection for more information about our use of cookies and other technologies that collect Traffic Data.
    4. You may also be permitted to post information to the Site, which will be accessible for other users (collectively, the “Forums”). We collect Personal Data that you knowingly provide to us in the Forums. Please remember that any Personal Data that you disclose in the Forums becomes public information and may be viewed and used by others. You are solely responsible for the content you post online in the Forums. HealthVerity has no control over and will not be held responsible for any Personal Data disclosed in the Forums or the use of such Personal Data by third parties. By submitting Personal Data in the Forum, you acknowledge that you have no expectation of privacy with regard to any submission or posting. You should always exercise caution when deciding to disclose your Personal Data.
    5. We may combine your Personal Data with other information we have collected from you, whether on- or offline, including, for example, purchase history or Traffic Data. We may also combine your Personal Data with information we receive about you from other sources, such as our affiliates, publicly available information sources, and third parties. We treat the combined information as Personal Data.

2. Where Your Personal Data is Stored and Processed

    1. HealthVerity is based in the United States. No matter where you are located, you consent to the processing and transfer of your Personal Data in and to the United States and other countries. The laws of the United States and other countries governing data protection may not be as comprehensive or as protective as the laws in the country where you live.

3. How We Use Personal Data

    1. We use Personal Data about you in the following ways:
      1. If you use the Site on behalf of your employer or another organization, information related to your use of the Site may be used and disclosed by HealthVerity to provide products and services to your employer or such organization in accordance with any agreement between HealthVerity and your employer or such organization.
      2. To ensure that content from the Site is presented in the most effective manner for you and for your computer.
      3. To respond to your inquiries, including to verify your credentials.
      4. To provide you with information, products or services that you request from us or that we feel may interest you.
      5. If you provide Personal Data in order to obtain access to or use the functionality of part of the Site, we will use your Personal Data to provide you with such access or functionality.
      6. To carry out our obligations arising from any contracts entered into between you or your employer and us.
      7. To notify you about changes to our Site, products, and services.
      8. To prevent misuse or improper use of the Site.
      9. For our business purposes, such as data analysis, audits, developing new products and features, enhancing our website, market research purposes, improving our products and services, and identifying Site usage trends.
      10. As we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including public and government authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.
      11. For any other purpose specified at the point of collection.
    2. We may use and disclose non-personal, non-individual statistics or demographic information in aggregate form without restriction.

4. Disclosure of Your Personal Data

    1. We may disclose your Personal Data to third parties:
      1. Who are service providers that perform functions on our behalf. Examples include providing customer service, sending postal mail and e-mail, analyzing data, and hosting servers. These service providers have access to Personal Data needed to perform their functions but are contractually prohibited from using it for other purposes.
      2. To our affiliates for purposes described in this Privacy Policy.
      3. If you use the Site on behalf of your employer or another organization, information related to your use of the Site may be used and disclosed by HealthVerity to provide products and services to your employer or such organization in accordance with any agreement between HealthVerity and your employer or such organization.
      4. In the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceeding).
      5. If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our terms of use and other agreements; or to protect the rights, property, or safety of HealthVerity or any affiliate, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection.

      While HealthVerity may undertake efforts to see that any third party to which HealthVerity discloses personal information is under an obligation to use that personal information solely for the purposes for which the information was disclosed, such third parties are independent third parties over which HealthVerity exercises no control. HealthVerity is not responsible for, and will not be liable for, the conduct, actions, omissions, or information handling or dissemination practices of third parties.

    2. Interest-Based Advertising

      As described herein, we work with a variety of third party business partners, including advertisers, advertising networks, and advertising and analytics companies that use various technologies to collect data about your use of the Site. HealthVerity and our third party business partners may use the aforementioned technologies to:

      1. Track how you use the Site, how you arrived at the Site, and what you do after you leave the Site;
      2. Record and link your devices, including your personal computer and mobile device (this is called cross-device linking); and
      3. Provide you with information and advertisements relevant to your interests, taking into account your use of the Site and the other websites and online services that you use. Note that this information and any advertisements may be delivered to you on the Site, on third party websites and applications, and on a computer or device other than the device from which the information was collected.

      This is called “Interest-Based Advertising” or “Online Behavioral Advertising.” While we work with our third party business partners to improve your experiences with the Site, we do not control their business practices.

      Section 5 (Passive Information Collection, Use, and Choices) of this Privacy Policy describes various methods of preventing passive collection and use of your information by our third party business partners. To learn more about Interest Based Advertising, please visit www.networkadvertising.org/choices and http://www.aboutads.info/choices.

      If you wish to opt-out of participating in Interest Based Advertising, you can use some or all of the following methods:

      1. Visit http://www.aboutads.info/choices (for web-based advertising), and http://www.aboutads.info/appchoices (for mobile advertising);
      2. For mobile advertising, use your phone operating system’s opt-out settings; and
      3. Enable the “Do Not Track” feature on your web browser.

      If you use more than one device to access the Site, you should renew your opt-out choices on each such device.

    3. HealthVerity receives, maintains and uses information in “de-identified” form. “De-identified” information refers to information derived from personal information, which cannot reasonably be used to identify a person. HealthVerity will not attempt to re-identify a person from the de-identified information. HealthVerity may sell or disclose de-identified information to third parties. When HealthVerity sells or discloses de-identified information to a third party, HealthVerity prohibits the third party from attempting to re-identify a person from the de-identified information.

5. Passive Information Collection, Use, and Choices

    1. As you navigate the Site, certain Traffic Data may be passively collected, meaning it is gathered without your actively providing it. This is done using the following technologies in the following ways:
      1. Through your browser: Certain information is collected by most browsers, such as your Media Access Control (MAC) address, computer type and operating system type and version screen resolution, and Internet browser type and version.
      2. Through your device: If you access the Site through a mobile device or other network-connected product, certain information may be collected about that device, including your device type, network service provider, and other identifiers. We may collect unique device identifiers (such as IDFA and AID tags and UUID and UDID identifiers) associated with the device you use to access the Site.
      3. Using Monitoring Tools: The Site may utilize pixel tags, web beacons, clear GIFs, Flash Shared Objects, HTML5 Local Storage, HTML5 Mini Databases, and other similar technologies, both on certain aspects of the Site and in HTML-formatted e-mail messages to you. These monitoring tools are used for the purpose of, among other things, compiling statistics about Site usage and response rates, and tracking the activities of users of the Site and e-mail recipients.
      4. IP Address: Your IP Address is a number that is automatically assigned to the computer that you are using by your Internet Service Provider. An IP Address is identified and logged automatically in our server log files whenever a user visits the Site, along with the time of the visit and the page(s) that were visited. Collecting IP Addresses is standard practice on the Internet and is done automatically by many online service providers, including website operators. We use IP Addresses for purposes such as calculating Site usage levels, helping diagnose server problems, and administering the Site.
      5. Cookies: Like many companies, our Site may use “cookies” to help make sure the Site is meeting the needs of its users and to help us make improvements. Cookies are bits of text that are placed on your computer’s hard drive when you visit certain websites. We may use cookies set by us on the Site to tell us, for example, whether you have visited us before or if you are a new visitor. We use third-party cookies set by our service providers to collect information about how visitors use the Site, including how long you spend on each page, and how you got to the Site. We do not allow our service providers to use or share our analytics data. You can visit https://tools.google.com/dlpage/gaoptout for information on how to opt out of Google Analytics cookies. You can refuse our use of some or all cookies by turning off the use of cookies in your web browser. If you use your browser settings to block all types of cookies you may not be able to access all or parts of our Site or functionality may be limited. You can set your browser to notify you before you receive a cookie, giving you the chance to decide whether to accept it. You can also set your browser to turn off cookies. Changing your internet browser settings can prevent the use of cookies. Each browser has a different procedure for disabling the use of cookies. The Help function within your browser should tell you how. Alternatively, you may visit http://www.aboutcookies.org where you can review information on how to control cookies on a variety of browsers. You will also find details of how to delete cookies from your computer and other general information about cookies.

      Although our use of passive collection technologies may change over time as technology evolves, the above descriptions are designed to provide you with additional detail about our current approach to information collected from passive technologies.

6. Social Media

    1. Some aspects of the Site may allow you to interface with social media sites and online services, such as Facebook. We will diligently work to identify these aspects of the Site to you, for example, by identifying them with the applicable third-party logos or trade names. By using these interfaces, you will allow us to access information about you from those other online services, including information and other content that you submit to those online services. For a description on how such social media services and other third party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.

7. Links to Third Party Sites

    1. The Site may contain links to other Web sites for the convenience of users. If you access a third-party website from a link on this Site, any information you disclose on that website is not subject to this Privacy Notice. It is possible that these links may be used by third parties or others to collect personal or other information about you. HealthVerity is not responsible for the privacy practices of such websites or third parties or the content of such websites and it is your sole obligation to review and understand the privacy practices and policies of these other websites.

8. Information Related to Minors

    1. The Site is not intended for persons under the age of 18. We do not knowingly collect Personal Data online from persons in this age group. We reserve the right to delete any information identified as having been provided by such persons at our discretion.

9. Security

    1. HealthVerity will take reasonable steps to protect the information collected and provided via the Site from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, you should understand that no transmission over the Internet is ever fully secure. Also, HealthVerity uses reasonable efforts to ensure that the Site is generally available. However, there will be occasions when access to the Site will be interrupted or unavailable. HealthVerity will use reasonable efforts to minimize such disruption where it is within its reasonable control. You agree that HealthVerity shall not be liable to you for any modification, suspension, or discontinuance of the Site.

10. Data Retention

    1. We generally retain Personal Data for so long as it may be relevant for the purposes identified in this Privacy Notice or at the time the information is collected, unless a longer period of time is required by law.

11. Your Rights and Choices

    1. You can unsubscribe from certain emails by clicking on the “unsubscribe” link they contain. You can opt-out of the use of certain cookie-related processing by following the instructions in Section 5 above (Passive Information Collection, Use, and Choices).
    2. The laws in some countries may give you particular rights with respect to your Personal Data, including the right to access the Personal Data that we maintain, and the right to object to certain processing of Personal Data by HealthVerity. If you would like to submit a data access, correction, restriction, or deletion request, or if you would like to object to certain processing, you can do so by contacting us by email at privacy@healthverity.com and we will process such request with respect to any Personal Data that we are able to link to you individually based on the information that you can provide to us. These rights and options that you have with respect to Personal Data are subject to limitations and exceptions under applicable law.

12. Changes to Our Notice

    1. We may change this Notice from time to time. When we do, we will let you know by posting the changed Notice on this page with a new “Last Updated” date. In some cases, we may also tell you about changes by additional means, such as by posting a notice on the Site or sending an e-mail to the e-mail address we have on file for you.

13. Contact

    1. If you have any questions about this Notice, please contact us at:

      HealthVerity, Inc.
      1818 Market Street, Suite 700
      Philadelphia, PA 19103

      ATTN: Privacy

      Dated: 10/6/20

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