At Claren Health, Inc. (“Claren Health,” “we,” “us,” or “our”), we take your privacy seriously. This Privacy Policy describes how we collect and process your personal information through our website and our Services (as defined in our Terms of Service).

This Privacy Policy applies to our processing of personal information in our capacity as a controller. This Privacy Policy does not apply to personal information that we process on behalf of our health plan or other enterprise customers as a service provider. Our processing of such personal information is governed by the agreements we have with such customers.

1. Categories of Personal Information We Collect

We collect the following categories of personal information:

Information you provide to us, including:

• Contact information, such as your first and last name, email address, phone number and mailing address.
• Account information, including your username and password.
• Demographic data such as your age, date of birth, and gender.
• Consumer health data, including information about individual health conditions, treatment and any inferences derived from non-health information, in each case that you choose to share with us. Please refer to our Consumer Health Data Privacy Notice for additional information about the processing of your consumer health data.
• Commercial data, including subscription history within our Services.
• Payment information needed to complete your transactions with us, including name, payment card information, and billing information. This information is processed by our payment service providers. We do not have access to your full payment card information.
• Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us online.
• Marketing information, such as your preferences for receiving our communications, and details about how you engage with our communications.
• Communications we exchange with you, including support services or other types of communications.
• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Information we receive from third party sources, including:

• Third-Party Services. When you explicitly grant us permission to collect data from third parties (such as your accounts with Oura, Fitbit, Apple Health, and other compatible third-party services), information that you authorize will be transmitted through to us.
• Third-party login information, such as information we receive when you authenticate through a third-party service depends on the settings, permissions and privacy policy controlled by that third-party service.
• Advertising partners, including information about you that we receive from our vendors who assist us with marketing or promotional services related to how you interact with our websites, applications, products, Services, advertisements or communications.
• Data providers, including publicly available information about you.

Information we collect automatically, including:

• Device data, such as your computer’s 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., WiFi, LTE, 3G), and general location information such as city, state or geographic area.
• Usage data, such as pages or screens you viewed, how long you spent on a page or screen, the website you visited before browsing to our website, navigation paths between pages or screens, information about your activity on a page or screen, access times, duration of access, and whether you have opened our marketing emails or clicked links within them.

We use the following tools for automatic data collection:

• Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand website user activity and patterns. For example, Google Analytics collects information about how users use our website, which we then use to compile reports that disclose trends without identifying individual visitors, and help us improve our website. For more information on Google Analytics, click here.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

2. How We Use Personal Information

We use personal information as follows:

• To provide our Services to you, including to provide personalized information.
• To communicate with you. We use personal information to respond to your requests, provide customer support, and otherwise communicate with you about our Services, including by sending announcements, surveys, updates, security alerts, and support and administrative messages.
• To improve, monitor, and personalize our Services. We use personal information to improve our Services, including by understanding your needs and interests, and personalizing your experience with the Services and our communications.
• For research and development. We may use your personal information for research and development purposes, including to analyze and improve our Services and our business. As part of these activities, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We may use this data and disclose it to third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.
• Direct marketing. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, newsletters, and updates on news and events. You may opt out of our marketing emails as described in the “Opt out of marketing communications” section below.
• For interest-based advertising. We may engage advertising partners, including third party advertising companies and social media companies, to display ads around the web. These companies may use cookies and similar technologies to collect information (including the automatically-collected data described above) about your interactions over time across our website, our communications, and other online services, and use that information to serve online ads that they think will interest you.
• Compliance and protection. We may use personal information to comply with legal obligations, and to defend our company against legal claims or disputes, including to:
  • Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas 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 and internal policies.
  • Enforce the terms and conditions that govern our website.
  • Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

3. How We Disclose Your Personal Information

We may disclose your personal information to:

• Service Providers. We may disclose your personal information to our service providers and partners who assist us in providing and operating the Services (e.g., hosting, analytics, secure storage, AI technology providers, customer care management, payment processing, and security and fraud prevention), who process personal information on our behalf and in accordance with our instructions.
• Affiliates. We may disclose your personal information to our subsidiaries and affiliates, for purposes consistent with this Privacy Policy.
• Advertising Partners. Third party advertising companies, including for the interest-based advertising purposes described above.
• Law enforcement, government agencies or other third parties where we believe in good faith to be necessary or appropriate to comply with applicable laws or protect our legitimate interests.
• Business transferees, in connection with a business transfer, such as a merger, financing, acquisition, sale of assets, or bankruptcy transaction or proceeding, in which case we may disclose your consumer health data to the prospective buyer or seller of such business or assets, as well as their and/or our business and legal advisors.
• Other third parties, but only if you direct us to or provide your explicit consent, including with your healthcare providers and their staff, if you choose to share your information with them.

4. Your Rights and Choices

Account information. If you have an account with us, you can review and update certain account information by logging into your account.

Opt out of marketing communications. You may opt out of marketing-related emails and other communications by following the opt-out or unsubscribe instructions at the bottom of the emails or within the messages or other communications you receive from us. You may continue to receive service-related and other non-marketing emails or other communications.

Personal Information Requests. Depending on your location and the nature of your interaction with the Services, you may have the following rights with respect to your personal information:

• Confirm whether we collect, share or sell your personal information.
• Access your personal information.
• Delete your personal information.

Please note that in some circumstances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. In those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include personal information, if necessary to verify your identity and the nature of your request.

We will not discriminate against you for exercising your rights described above.

Please refer to our Consumer Health Data Privacy Notice to learn about your rights under applicable state privacy laws with respect to such data.

How To Submit Personal Information Requests

To submit a request regarding any of the rights described above, please send us an email at support@clarenhealth.com.

Opt out of online tracking. There are a number of ways to opt out of having your online activity and device data collected through our Services, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our Services from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block cookies/trackers.
• Google Analytics. We use Google Analytics to help us better understand how people engage with our Service by collecting information and creating reports about how users use our Service. For more information on Google Analytics, click here. For more information about Google’s privacy practices, click here. You can opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Platform opt-outs. The following advertising partners offer opt-out features that let you opt out of use of your information for interest-based advertising:
  • Google
  • Facebook
  • LinkedIn
  • Microsoft
• Advertising industry opt-out tools. You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies:
  • Digital Advertising Alliance
  • Network Advertising Initiative

Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

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” or similar signals. To find out more about “Do Not Track,” please visit https://www.allaboutdnt.com.

5. Other Services

Our Service may contain links to websites and other online services operated by third parties. 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 or online services operated by third parties, and we are not responsible for their actions. This Privacy Policy does not apply to such third-party sites or services.

6. Security

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

7. Retention of personal information

We retain personal information for as long as is reasonably necessary and proportionate for the purposes described in this Privacy Policy, while we have a legitimate business need to do so, or as required by applicable law.

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 personal information, the purposes for which we use personal information and whether we can achieve those purposes through other means, and the applicable legal and regulatory requirements.

8. Personal Information of Children

We do not knowingly collect or solicit personal information from individuals under 18. If you are under 18, please do not attempt to register for or otherwise use the Services or send us any personal information. If we learn we have collected personal information from a child under 18, we will delete that information. If you believe that a child under 18 may have provided us personal information, please contact us at support@clarenhealth.com.

9. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. The most current version will be available on our website and within the Service. If we make material changes to how we treat your personal information, we will notify you through the Service, by email, or through another appropriate method. If you use the Services after any changes to the Privacy Policy have been posted, you acknowledge all of the changes. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting).

10. Contact Us

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, please do not hesitate to contact us by email at: support@clarenhealth.com.