Privacy Policy

Effective Date: May 2018

TechAttribute IT Solutions LLC (“Techattribute”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information, including Personal Information that we obtain about visitors to our website www.techattribute.com (“Website”) and the services available through our Website (“Services”).

“Personal Information” means any unique information or set of information that could be used to identify or contact an individual, such as the individual’s name, title, mailing address, email address, phone number, employer/profession, login information, password, payment card information or other specific types of personal information.

Types of Information and Collection Methods

TechAttribute IT Solutions LLC. and its related companies (“We”, “Us”, “Techattribute”) take your privacy seriously, and we want you to know how we collect, use, share, and protect your information. This policy (the “Privacy Policy”) tells you what information we collect from visitors of the mobile application and therapy or other related services provided or operated by Techattribute (the “Services”) including our mobile application (the “App”), how we use that information, how we may share that information, how we protect your information, and your choices regarding your Personal Information (defined below). This Privacy Policy does not apply to information collected by us through any other means, including on any other website operated by Techattribute or any third party; or any third party, including through any application or content (including advertising) that may link to or be accessible from or on the App.

PLEASE READ THIS POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. IF YOU DO NOT AGREE TO THE PRIVACY POLICY, INCLUDING ANY CHANGES THERETO, THEN YOU MUST NOT ACCESS AND USE THE SERVICES. THIS PRIVACY POLICY MAY CHANGE FROM TIME TO TIME (SEE CHANGES) AND YOUR CONTINUED USE OF THE APP AFTER WE MAKE CHANGES IS DEEMED TO BE ACCEPTANCE OF THOSE CHANGES, SO PLEASE CHECK THIS POLICY PERIODICALLY FOR UPDATES.

To utilize the Services, you are required to submit certain information to establish an account. We collect certain information during the account registration process for identity verification purposes. We collect and utilize additional information as set forth below.

Information We Collect From You

We collect several types of information from and about users of our App (collectively “Personal Information”), including, specifically:

Personally identifiable information about you, including, when you register with the Services, your name, home, work and shipping addresses, telephone number, email address, contact information and password, and, once you have registered, your birthdate and any other information you provide to us, or grant us access to, when you access or use the Services.

Information that you provide by filling in forms on our App, including at the time of registering to use the Services, using the Services, or requesting further Services. We may also ask you for information when you report a problem with our App. Records and copies of your correspondence (including email addresses), if you contact us and Details of Services requested through our App and the fulfillment of your requests. We will process Personal Information collected through the Services in accordance with applicable law and with the agreements we have with your employer, or other applicable entity that may be sponsoring your access to and use of the Services and the App (as applicable, the “Sponsor”), and as described in the Terms of Use and this Privacy Policy. If you do not want to provide us this information, please do not utilize the Services.

Information We Collect From Third Parties

We may collect Personal Information about you from third parties, such as your Sponsor and our business partners and service providers (including, without limitation, the third-party distributors of the devices and sensors we provide to you). Your Sponsor will provide us with information so that we can provide our Services to you.

Information We Collect Automatically

The information we collect automatically may include Personal Information or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties. It helps us to improve our App and to deliver a better and more personalized service.

Additionally, we may collect certain information automatically when you use the Services, including the following information through the below methods:

Use of the App

When you use the App, we may collect certain information about such use, including traffic data, logs, the location of your mobile device, your mobile device ID, type of device and operating system you use to access our App; your browser type; your mobile network information; your activities within the App; the length of time that you are logged in through the App; and information stored on your mobile device as it relates to your use of the App.

Cookies

We may use “cookies” and other technologies to collect data that enable us to better understand and improve the usability, performance and effectiveness of our Services. For instance, we may use session cookies (which expire once you close your browser) to provide you with a more personal and interactive experience on our App. A “cookie” is a small piece of data sent from a website and stored on the user’s computer by the user’s web browser while the user is browsing. You may have the capability on your mobile device to refuse to accept browser cookies by activating the appropriate setting in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our App. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you access our App.

Third-Party Analytics

We use third parties’ analytic and tracking tools to better understand who is using the Services, how people are using the Services and how to improve the effectiveness of the Services and its content, and to help those parties advertise the Services. Those third party companies may use cookies, pixel tags or other technologies to collect and store anonymous information such as time of visit, pages visited, time spent using the Services, device identifiers, type of operating system used and other website(s) you may have visited. They might combine information they collect from your interaction with the Services with Personal Information they collect from other sources. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies. We currently use the analytic and tracking tool Google Analytics, a web analytics service provided by Google, Inc. (“Google”), and Mixpanel, a data analytics platform provided by Mixpanel, Inc. (“Mixpanel”). You can find out more about how Google uses data when you visit our App by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We also encourage you to review Mixpanel’s privacy policy, which can be found at https://mixpanel.com/legal/privacy-policy/, to learn more about how Mixpanel uses and protects your information.

DNT. Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. Techattribute and the Services do not currently recognize or respond to DNT.

What We Do with Your Information

Techattribute respects your privacy and will not sell your Personal Information to third parties; however, we may disclose your Personal Information for purposes as outlined in this Privacy Policy.

We may use your Personal Information to: provide Services to you, respond to your inquiries, provide information on products and Services you request or have a representative contact you regarding our products or Services that you may be interested in, provide you with notices about your account, carry out our obligations and enforce our rights arising from any contracts entered into between you and us or your Sponsor and us, including for billing and collection, notify you about changes to our Services, our App, or any products or Services offered through them, fulfill any other purpose for which you provide it, and for any other purpose with your consent. Unless you have otherwise opted out of receiving email or text communication from us, you agree by using the Services, to allow us to use your email or telephone number for communication and provision of Services consistent with this Privacy Policy.

Please note that if your access to our App or use of the Services is sponsored by a third party Sponsor (e.g. your employer), at the request of the Sponsor, we may share Personal Information that your provide to us, or that we otherwise collect, through the App or the Services with your Sponsor and/or third party service providers of your Sponsor.

We may also use your Personal Information to improve our products and Services, provide information regarding topics, deliver other information we believe you will find most relevant, and useful and in any other way we may describe when you provide the information or to which you consent. We may occasionally contact you to gather customer service information to help us determine how we can improve our Services and products to better meet your needs. We may also de-identify and/or aggregate your data so that it no longer reasonably identifies you for various business purposes including product, service and program development and improvement. De-identified data, in individual or aggregated form, may be used without restriction and for any purpose, including for research purposes both internally by Techattribute and with research partners and other third parties for the advancement of clinical and scientific knowledge.

We may combine or cross-reference your Personal Information with general information or other information we may have acquired about you or may acquire about you through other sources, including offline sources of information to help further customize the information, products or Services we provide to you.

We use the general information we collect from you to help us understand and analyze users of our Services, including generating aggregate statistics about Services use. This data can then be used to tailor the Services’ content and deliver a better experience for our users. We may also collect, aggregate and maintain anonymous information about the visitors to our Services. We may further share such aggregate, non-identifiable information with business partners, sponsors and other third parties.

Sharing of Personal Information with Third Parties

From time to time, we may use third parties to provide products, services or otherwise support our business or collaborate with third parties with respect to development, promotion or other business activities related to a particular product or service. These third parties may include service providers of your Sponsor or our own service providers we use to support our business and who provide IT and infrastructure support services, and marketing, and billing services. As a result, we may disclose Personal Information that we collect or you provide to contractors, “Business Associates”, service providers and other third parties for solely for purposes of providing the Services as outlined above; provided such third parties have agreed to comply with this Privacy Policy or substantially equivalent terms. We may also disclose Personal Information to our subsidiaries and affiliates; to a third party in connection with a merger, divestiture, restructuring, reorganization, dissolution, sale or transfer of some or all of our assets or other similar corporate transactions or in connection with a bankruptcy, liquidation or similar proceeding.

We may also release your Personal Information to third parties as required by law, when we believe disclosure is necessary to comply with a legal or regulatory requirements, judicial proceeding, court order or legal process served on us, to protect the safety, rights or property of patients, customers, the public or Techattribute or defend Techattribute and its officers, directors, employees, attorneys, agents, contractors and partners, in connection with any legal action, claim, or dispute. We may also disclose Personal Information to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.

While you may be using personal fitness devices, internet-connected devices (such as blood sugar monitors), or similar devices to collect biometric and other data that constitutes Personal Information and thereafter send that data to us, your relationship with Techattribute does not impact your rights and obligations with respect to the companies that manufactured and/or supplied those devices (the “Device Manufacturers”). Your relationship with Techattribute is independent of your relationship with the Device Manufacturers, and Techattribute is not responsible for any uses or disclosure of your Personal Information by the Device Manufacturers. Please refer to any privacy policies, terms and conditions, and license agreements you may have with the Device Manufacturers.

Except as set forth in this Privacy Policy or as specifically agreed to by you, we will not disclose any Personal Information we gather from you on our Services to third parties.

Your Rights Regarding Accessing and Correcting Your Information

We can review and change your Personal Information by logging onto our App and visiting the Account Preferences section of our App. You may also notify us, through one of the means listed below in the Contact Us section, of any changes or errors in any Personal Information we have about you to ensure that it is complete, accurate, and as current as possible. If you wish to delete your Techattribute account, please contact your Sponsor. We cannot delete your Personal Information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

How We Keep Your Information Secure

We seek to safeguard the security of your Personal Information and have implemented reasonable security measures consistent with accepted practices in the IT industry to protect the confidentiality of your Personal Information and limit accidental loss of, and unauthorized access to, it. We have a designated Chief Security Officer and have put in place a variety of information security measures to protect your Personal Information, including encryption technology, such as Secure Sockets Layer (SSL) and AES encryption, biometric authentication, automatic locking after periods of inactivity on the App to protect your Personal Information during data transport and at rest. However, despite our efforts to protect your Personal Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your Personal Information over the Internet will be intercepted. Unfortunately, transmission of information via the Internet is not completely secure. Although we work diligently to try and protect your Personal Information, we cannot guarantee the absolute security of your Personal Information, nor can we guarantee that information that you provide will not be intercepted while being transmitted to us over the Internet. Therefore, we urge you to also take every precaution to protect your Personal Information when you are on the Internet or using the Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the App or in your operating system. We are also not responsible for the data security of any Device Manufacturer.

How to Opt Out

We strive to provide you with choices regarding the Personal Information you provide to us; however, we do not control the We do not control the collection and use of your information collected by third parties described above. These third parties may aggregate the information they collect with information from their other customers for their own purposes. To opt out, please do not provide your Personal Information to us, or after providing your Personal Information to us, please send written notification to us at
savan@techattribute.com that you no longer wish to receive information and communications from us or otherwise share your Personal Information. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. Because there is no standard for these signals at this time, we currently do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us. Please note that certain features of the Services may not be available when cookies are disabled. To learn more about how to manage cookies, visit http://www.allaboutcookies.org. You may opt-out of certain targeted advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

Children’s Privacy

We are committed to protecting the privacy of children. The Services are not designed or intended for children and we do not knowingly collect Personal Information about children under eighteen (18) years old. No one under the age of 18 may provide information to or through the App. If you are under 18, do not use or provide any information on our App or on or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn that we have collected or received Personal Information from a child under 18 years without verification of parental consent, we will delete that information. If you believe we might have any information about a child under 18, please contact us at savan@techattribute.com.

Third Party Websites

Please be aware that our App or Services may have links to third-party websites that may collect Personal Information about you. When you click on one of these third-party links, you are entering another website for which we have no responsibility. This Privacy Policy does not cover the information practices or policies of such third-party websites. We encourage you to read the privacy policies of all such websites since their privacy policies may be materially different than our Privacy Policy.

Third Party Advertisers

In addition, we may rely on third-party advertisers, ad networks and ad servers to promote our Services. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about our users. This may include information about users’ behavior on this and other apps to serve them interested-based (behavioral) advertising. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement, you should contact the responsible advertiser directly.

Changes

We reserve the right to modify the terms of this Privacy Policy at any time and in our sole discretion, without notice. When the Privacy Policy is changed, modified, and/or amended, the revised Privacy Policy will be posted on our App. Modifications will be effective immediately. You should visit this web page periodically to review the Privacy Policy. You accept any such modifications to this Privacy Policy by continued use of our Services after such modifications are made.

Additional Terms for Businesses

In the event that you are a business or other commercial entity accessing the App and the Services, you understand that the terms of your arrangement with Techattribute and access of the App and the Services may be subject to additional terms and conditions set forth in a Master Services Agreement or other written agreement entered into by and between you and Techattribute.

Contact Us

If you would like to update your Personal Information, delete your account, change your preferences or have any questions or concerns about your privacy, you may contact us at savan@techattribute.com. Please note that some information may remain in our records after deletion of your account, including any information or records we are legally obligated to retain.