Last updated 9/19/2023
FOR CALIFORNIA RESIDENTS: Please note, we will only share the health information of California residents for purposes set forth in the Authorization for Use or Disclosure of Medical Information form (“Authorization”). California residents are required to complete an Authorization before creating an account on the Services.
Personal information we collect
Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:
- Contact data, such as your first and last name and email address.
- Demographic data, such as your date of birth and gender.
- Account data, such as the username and password that you may set to establish an online account on the Service.
- Limited health-related data, including information about your illnesses or other chronic health conditions.
- Communications data based on our exchanges with you, including when you contact us through the Service, social media, or otherwise.
- Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
Third-party sources. We may combine personal information we receive from you with personal information we obtain from other sources, such as:
- Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
- Third-party services that you use to log into your account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.
- Wearable device accounts that you link to your account, such as data provided through integrations with your wearable device accounts like Apple Health, Oura, FitBit, and Polar, where you give us express permission. You can select what data is provided to us, which may include:
- Activity-related data (such as walking distance, steps, calories burned, elevation, and activity level);
- Heart rate monitoring and related data (such as your heart rate, heart rate variability, heart rate zones, blood pressure, and Vo2 max);
- Sleep-related data (such as amount of time asleep and sleep cycles);
- Location and other positioning; and/or
- Your username, profile picture and other information associated with any integrated accounts.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
- Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), general location information such as city, state or geographic area, and the number and type of wearable devices you connect to your account.
- Online or app activity data, such as pages or screens you viewed on our website or app, how long you spent on a page or screen on our website or app, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen on our website or app, access times and duration of access, and whether you have opened our emails or clicked links within them.
- Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Cookies and similar technologies. Some of our automatic data collection is facilitated by cookies and similar technologies. For more information, see our Cookie Notice. We will also store a record of your preferences in respect of the use of these technologies in connection with the Service.
Data about others. We may offer features that help users invite their friends or contacts to use the Service, and we may collect contact details about these invitees so we can deliver their invitations. Please do not refer someone to us or share their contact details with us unless you have their permission to do so.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
- provide, operate and improve the Service and our business;
- personalize the Service to you, including remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
- establish and maintain your user profile on the Service;
- facilitate your invitations to friends who you want to invite to join the Service;
- enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
- communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
- communicate with you about events or contests in which you participate;
- understand your needs and interests, and personalize your experience with the Service and our communications; and
- provide support for the Service, and respond to your requests, questions and feedback.
Research and development. We may use your personal information for research and development purposes, including to analyze on an aggregate basis how different categories of users react to different medications and interventions, improve the Service and our business, and to develop new products and services. As part of these activities, we may also create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business and will not attempt to reidentify any such data.
Marketing. We and our service providers may collect and use your personal information for marketing purposes. We may send you direct marketing communications and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications at any time as described in the Opt-out of marketing section below.
Service improvement and analytics. We may use your personal information to analyze your usage of the Service, improve the Service, improve the rest of our business, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails, and to develop new products and services.
Compliance and protection. We may use your personal information to:
- comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, investigations or requests from government authorities;
- protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
- audit our internal processes for compliance with legal and contractual requirements or our internal policies;
- enforce the terms and conditions that govern the Service; and
- prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
How we share your personal information
Affiliates. Our corporate parent, subsidiaries, and affiliates.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
Payment processor. Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processor, as appointed by us from time to time. Please note that this does not apply to in-app purchases, which are processed by Apple or Google (as relevant).
Third parties designated by you. We may share your personal information with third parties where you have instructed us or provided your consent to do so. We will share personal information that is needed for these other companies to provide the services that you have requested.
Business and marketing partners. Third parties with whom we co-sponsor events or promotions, with whom we jointly offer products or services, or whose products or services may be of interest to you.
Professional advisors. We may share your personal information with our professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. We may share your personal information with law enforcement, government authorities, and private parties, where we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in Pathize Health, financing of Pathize Health, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Pathize Health as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
In this section, we describe the rights and choices available to all users. Users located in Europe can also find information about their additional rights in the Notice to European users section below.
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
Linked third-party platforms. If you choose to connect to the Service through your social media account or other third-party platform, such as a wearable device account, you may revoke or limit our access to such data at any time by accessing your account settings. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party or to information that we receive from other third-party platforms.
Other sites and services
The Service may contain links to websites, mobile applications, and other online services operated by third parties, such as integrated wearable device services. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
The Service is not intended for use by anyone under 16 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
How to contact us
- Email: firstname.lastname@example.org
Notice to European users
Where this Notice to European users applies. The information provided in this “Notice to European users” section applies where we are processing the personal information of individuals located in the EEA or the UK (EEA and UK jurisdictions are together referred to as “Europe”) as a controller.
- Where we need to process your personal information to deliver our Service to you (“Contractual Necessity”).
- Where it is necessary for our legitimate interests and your interests and fundamental rights do not override those interests (“Legitimate Interests”). More detail about the specific legitimate interests pursued in respect of each purpose we use your personal information for is set out in the table below.
- Where we need to comply with a legal or regulatory obligation (“Compliance with Law”).
- Where we have your specific consent to carry out the processing for the purpose in question (“Consent”).
We have set out below, in list format, the legal bases we rely on in respect of the relevant purposes for which we use your personal information – for more information on these Purposes and the data types involved, see How we use your personal information above.
Service delivery and operations. Categories of personal information involved:
- Contact data
- Account data
- Limited health-related data
- Wearable device data
- Communications data
- Data about others
- Contractual Necessity
- Consent, in respect of Limited health-related data
Research and development. Categories of personal information involved:
- Any and all data types relevant in the circumstances
- Legitimate interest. We have legitimate interest in understanding what may be of interest to our users, improving user relationships and experience, delivering relevant content to our users, measuring and understanding the effectiveness of the content we serve to users, and understanding at a high-level how different categories of users react to different medications and interventions
Marketing. Categories of personal information involved:
- Contact data
- Communications data
- Marketing data
- Legitimate Interests. We have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose
- Consent, in circumstances or in jurisdictions where consent is required under applicable data protection laws to the sending of any given marketing communications
Service improvement and analytics. Categories of personal information involved:
- Device data
- Online app or activity data
- Communication interaction data
- Legitimate Interests. We have a legitimate interest in analyzing and improving the Service, and developing and growing our organization
- Consent, in respect of processing directly associated with any optional cookies used for this purpose
Compliance and protection. Categories of personal information involved:
- Any and all data types relevant in the circumstances
- Compliance with Law
- Legitimate interest. Where Compliance with Law is not applicable, we and any relevant third parties have a legitimate interest in participating in, supporting, and following legal process and requests, including through co-operation with authorities. We and any relevant third parties may also have a legitimate interest of ensuring the protection, maintenance, and enforcement of our and their rights, property, and/or safety
Further uses. Categories of personal information involved:
- Any and all data types relevant in the circumstances
- The original legal basis relied upon, if the relevant further use is compatible with the initial purpose for which the personal information was collected.
- Consent, if the relevant further use is not compatible with the initial purpose for which the personal information was collected.
Retention. We retain personal information for as long as necessary to fulfil the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for compliance and protection purposes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
No obligation to provide personal information. You do not have to provide personal information to us. However where we need to process your personal information either to comply with applicable law or to deliver our Services to you, and you fail to provide that personal information when requested, we may not be able to provide some or all aspects of our Service to you. We will notify you if this is the case at the time.
Security. We have put in place procedures designed to deal with breaches of personal information. In the event of any such breach, we have procedures in place to work with applicable regulators. In addition, in certain circumstances (including where we are legally required to do so), we may notify you of breaches affecting your personal information.
General. European data protection laws give you certain rights regarding your personal information. If you are located in Europe, you may ask us to take any of the following actions in relation to your personal information that we hold:
- Access. Provide you with information about our processing of your personal information and give you access to your personal information.
- Correct. Update or correct inaccuracies in your personal information.
- Delete. Delete your personal information where there is no lawful reason for us continuing to store or process it, 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 information 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 that will be notified to you, if applicable, at the time of your request.
- Portability. Port a machine-readable copy of your personal information to you or a third party of your choice, in certain circumstances. Note that this right only applies to automated information for which you initially provided consent for us to use or where we used the information to perform a contract with you.
- Restrict. Restrict the processing of your personal information, if: (i) you want us to establish the personal information's accuracy; (ii) our use of the personal information is unlawful but you do not want us to erase it; (iii) you need us to hold the personal information even if we no longer require it as you need it to establish, exercise or defend legal claims; or (iv) you have objected to our use of your personal information but we need to verify whether we have overriding legitimate grounds to use.
- Object. Object to our processing of your personal information where we are relying on legitimate interests as our legal basis, and there is something about your particular situation that makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedom – you also have the right to object where we are processing your personal information for direct marketing purposes.
- Withdraw Consent. When we use your personal information based on your consent, you have the right to withdraw that consent at any time. This will not affect the lawfulness of any processing carried out before you withdraw your consent.
Exercising These Rights. You may submit these requests by contacting us. See the How to contact us section above for our contact details. We may request specific information from you to help us confirm your identity and process your request. Whether or not we are required to fulfill any request you make will depend on a number of factors (e.g., why and how we are processing your personal information), if we reject any request you may make (whether in whole or in part) we will let you know our grounds for doing so at the time, subject to any legal restrictions. Typically, you will not have to pay a fee to exercise your rights; however, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. We try to respond to all legitimate requests within a month. It may take us longer than a month if your request is particularly complex or if you have made a number of requests; in this case, we will notify you and keep you updated.
Your Right to Lodge a Complaint with your Supervisory Authority. In addition to your rights outlined above, if you are not satisfied with our response to a request you make, or how we process your personal information, you can make a complaint to the data protection regulator in your habitual place of residence.
- For users in the European Economic Area – the contact information for the data protection regulator in your place of residence can be found here: https://edpb.europa.eu/about-edpb/board/members_en.
- For users in the UK – the contact information for the UK data protection regulator can be found here: https://ico.org.uk/make-a-complaint/
Data Processing outside Europe. We are a US-based company and many of our service providers, advisers, partners or other recipients of data are also based in the US. This means that, if you use the Service, your personal information will necessarily be accessed and processed in the US. It may also be provided to recipients in other countries outside Europe. Where we share your personal information with third parties who are based outside Europe, we try to ensure a similar degree of protection is afforded to it in accordance with applicable privacy laws by making sure one of the following mechanisms is implemented:
- Transfers to territories with an adequacy decision. We may transfer your personal information to countries or territories whose laws have been deemed to provide an adequate level of protection for personal information by the European Commission or UK Government (as and where applicable) (from time to time).
- Transfers to territories without an adequacy decision.
We may transfer your personal information to countries or territories whose laws have not been deemed to provide such an adequate level of protection. However, in these cases:
- we may use specific appropriate safeguards, which are designed to give personal information effectively the same protection it has in Europe – for example, standard-form contracts approved by relevant authorities for this purpose; or
- in limited circumstances, we may rely on an exception, or ‘derogation’, which permits us to transfer your personal information to such country despite the absence of an ‘adequacy decision’ or ‘appropriate safeguards’ – for example, reliance on your explicit consent to that transfer.
You may contact us if you want further information on the specific mechanism used by us when transferring your personal information out of Europe. See the How to contact us section above for our contact details.