Privacy Policy

Last modified: January 12, 2021

Introduction

This privacy policy (the “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you access and use the Site and our practices for collecting, using, maintaining, protecting, and disclosing that information. This Privacy Policy is incorporated by reference into the Terms of Use.

This Privacy Policy describes:

·      The information that we collect from you in any form, including when you interact with the Site.

·      How we collect, use and disclose the information that we receive, including sharing that information with third parties.

·      How we store and secure such information.

This Privacy Policy does not apply to information collected by:

·      Us offline or through any other means, including on any other website operated by any third party (including our affiliates and subsidiaries); or

·      Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Site.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information. By using the Site, you accept and agree to be bound and abide by the Privacy Policy. If you do not want to agree to the Privacy Policy, you must not access or use the Site. Any capitalized term used but not defined in this Privacy Policy shall have the meaning in our Terms of Use.

About the Site

Company offers a range of services and products to employers, schools, events and event management companies, individuals, movie and TV production companies, and non- and for-profit companies (“Sponsors”), healthcare providers (“Healthcare Providers”), and individuals (“Individuals”) including a platform and dashboard with program-specific analytics, a care coordination portal for patient management, a patient portal with health and testing information, and health-related products. We are not a medical service provider, health insurance company, or licensed to sell health insurance.

Children Under the Age of 13

Please review our Privacy Policy for Children Under the Age of 13.

Information We Collect

We collect several types of information from and about users of the Site, including the following:

Personal Information

When you access the Site, we may ask you to voluntarily provide us with certain information that personally identifies or could be used to personally identify you (“Personal Information”). Personal Information includes (but is not limited to) the following categories of information:

• Contact information, such as your name, address, e-mail address and phone number;

• Demographic data, such as your gender, date of birth and zip code;

• Payment information, such as your credit card number and billing address; and

• Medical data and health information you choose to share.

We may also collect additional information, which may be Personal Information, as otherwise described to you at the point of collection or pursuant to your consent.

Billing, Collection and Payment Information

When you make a payment through the Site to (as further described in our Additional Terms), your payment card information may be processed by our payment processing partner, Stripe (https://stripe.com). Stripe collects your voluntarily provided payment card information necessary to process your payment. Stripe’s use and storage of information it collects is governed by Stripe’s applicable terms of service and privacy policy. The information we store includes your payment card type and the last four digits of the payment card. We may provide to you the option to remove your stored payment card information through your account settings.

Traffic Data

We also may automatically collect the following types of data when you use the Site:  (1) IP address; (2) domain server; (3) type of device(s) used to access the Site; (4) web browser(s) used to access the Site; (5) referring webpage or other source through which you accessed the Site; (6) geolocation information; and (7) other statistics and information associated with the interaction between your browser or device and the Site (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be Personal Information.

Information Subject to Additional Protections

Certain information receives additional protections under the law:

Protected Health Information and HIPAA

Under a federal law called the Health Insurance Portability and Accountability Act (“HIPAA”), some of the contact, demographic, payment, and health and/or healthcare-related information that Company collects may be considered “Protected Health Information” or “PHI.” HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. Company may only use and disclose PHI in the ways permitted by the Healthcare Provider(s) and HIPAA. Healthcare Providers may provide Individuals with their own Notice of Privacy Practices.

We may use and disclose PHI to provide the services, for our own management and operations, to meet our legal obligations, as set forth in the business associate agreement with Healthcare Providers, or for any other purpose for which you have given consent. 

Student Data and FERPA

Under a federal law called the Family Educational Rights and Privacy Act (“FERPA”), when Sponsors are educational providers certain data we collect may be considered “personally identifiable information” from “education records” (collectively, “PII”) as those terms are defined by FERPA. To the extent applicable, we will operate under the direct control of your school district with respect to handling of PII.

We may use and disclose PII to provide the services, to meet our legal obligations, as directed by you, and for other purposes permitted by applicable law.

How We Collect Information

We collect this information:

·      Directly from you when you provide it to us.

·      When you use the Site’s interactive tools and services.

·      If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant services, such as information that lets Company know when you are logged on and available to receive update or alert notices.

·      If you download our mobile application, we may receive information about your location and mobile device.

·      Automatically as you navigate through the Site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

·      From third parties, for example, our business partners, Sponsors, or Healthcare Providers.

Information You Provide to Us 

The information we collect on or through the Site may include:

·      Information that you provide by filling out forms on the Site. This includes information provided at the time of registering to use the Site, subscribing to a service, or requesting further services. We may also ask you for information when you report a problem with the Site.

·      Records and copies of your correspondence (including email addresses), if you contact us.

·      Your responses to surveys that we might ask you to complete for research purposes.

·      Details of transactions you carry out through the Site. You may be required to provide financial information before placing an order through the Site.

·      Your search queries on the Site.

·      Your User Content.

·      Information you authorize third parties to release to us.

Information We Collect Through Automatic Data Collection Technologies 

As you navigate through and interact with the Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

·      Details of your visits to the Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.

·      Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

Do Not Track: The term “Do Not Track” refers to a HTTP header offered by certain web browsers to request that websites refrain from tracking the user. We take no action in response to Do Not Track requests.

The information we collect automatically does not include Personal Information, but 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 the Site and to deliver a better and more personalized service, including by enabling us to:

·      Estimate our audience size and usage patterns.

·      Store information about your preferences, allowing us to customize the Site according to your individual interests and speed up your searches.

·      Recognize you when you return to the Site.

The technologies we use for this automatic data collection may include:

·      Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Site.

·      Flash Cookies. Certain features of the Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on the Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

·      Web Beacons. Pages of our the Site and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain Content and verifying system and server integrity).

·      Website Analytics. We may use third-party website analytics services in connection with the Site, including, for example, to register mouse clicks, mouse movements, scrolling activity and text that you type into the Site. These website analytics services generally do not collect Personal Information or PHI through text that you type while using the telemedicine related services, but may collect usage data, such as whether or not you provided a response. We use the information collected from these services to help make the Site easier to use and as otherwise set forth in this Privacy Policy.

·      Mobile Device Identifiers. Mobile device identifiers are data stored on your mobile device that may track mobile device and data and activities occurring on and through it, as well as the applications installed on it. Mobile device identifiers enable collection of Personal Information (such as media access control, address and location) and Traffic Data. As with other Tracking Tools, mobile device identifiers help us learn more about our users’ demographics and internet behaviors.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Site are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use the Site. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use Personal Information you provide to us or we collect from you as follows:

·      To present the Site and the Content to you.

·      To provide you with information, products, or services that you request from us.

·      To fulfill any other purpose for which you provide it.

·      To provide you with notices about your account, including expiration and renewal notices.

·      To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

·      To notify you about changes to the Site or any products or services we offer or provide though it.

·      To allow you to participate in interactive features on the Site.

·      To customize and tailor your experience of the Site, which may include sending customized messages or showing you Sponsored Offers related to goods or services that may be of interest to you based on information collected in accordance with this Privacy Policy.

·      In any other way we may describe when you provide the information.

·      For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. For more information, see Choices About How We Use and Disclose Your Information.

We may use your information to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We may use information that is not Personal Information, PHI, or PII (including information that has been de-identified and aggregated) to better understand who uses the Site and how we can deliver a better experience, or otherwise at our discretion. Our use of PHI and PII is limited as discussed above.

How We Share Your Information

We may share Personal Information that you provide to us or we collect from you as follows:

·      To fulfill the purpose for which you provide it.

·      With your consent.

·      To the Healthcare Providers or Sponsors.

·      With organizations that collect, aggregate and organize your information so they can make it more easily accessible to the Healthcare Providers or Sponsors.

·      To contractors, service providers, and other third parties we use to support our business.

·      To another company in connection with a merger, sale, acquisition or other change of ownership or control by or of Company (whether in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy policies and practices.

·      If we determine in good faith that such disclosure is needed:

o   To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

o   To prevent or lessen a serious and imminent threat to the health or safety of you, another person or the public.

o   To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.

o   If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Third parties and Sponsors that receive this information may or may not have a legal obligation to keep your personal information private.

We may disclose information that is not Personal Information, PHI, or PII (including information that has been de-identified and aggregated) at our discretion. Our disclosure of PHI and PII is limited as discussed above.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:

·      Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of the Site may then be inaccessible or not function properly.

·      Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data.

·      Promotional Offers from Company. If you do not wish to have your email address used by Company to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data. If we have sent you a promotional email, you may use the unsubscribe button or send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Company as a result of a purchase, product service experience or other transactions.

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 opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Data Security

We use a combination of technical, administrative, and physical controls to maintain the security of your data. If you have a security-related concern, please contact us. Always be sure to secure your login credentials for on-line access. In order to protect you and your information, we may suspend your use of any of the on-line service, without notice, pending an investigation, if we suspect any breach of security.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to the Site. 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 Site.

Links to Third Party Websites

The Site may contain links to third party websites and services (e.g. Stripe for payment processing) and some of those third-party websites may be co-branded with our logo (the “Third-Party Services”).  These Third-Party Services are not our services. We do not control (and are not responsible for) third party content or privacy practices. Any personal information you provide to them is not covered by this Privacy Policy. We encourage you to review carefully the legal and privacy policies of all other digital services that you visit.

Changes to Your Information

All users may review, update, correct or delete the Personal Information in their user account by contacting us at hello@tamarin.health. If you completely delete all of your information with us, then your user account will be deactivated. We may retain an archived copy of your records. 

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Site home page. If we make material changes to how we treat our users’ Personal Information, we will notify you by email to the email address specified in your account or through a notice on the Site home page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you in order to receive such notices.

Contact Information

If you have any questions, concerns or complaints about our Privacy Policy or our data collection or processing practices, or if you want to report any suspected security violations to us, please contact us at hello@tamarin.health.

Privacy Policy for Children Under the Age of 13

The Children’s Online Privacy Protection Act of 1998 and its rules require us to inform parents and legal guardians ( “parents”) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children”). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.

This Privacy Policy for Children Under the Age of 13 (the “Children’s Privacy Policy”) notifies parents of:

·       The types of information we may collect from children.

·       How we use the information we collect.

·       Our practices for disclosing that information.

·       Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.

·       All operators that collect or maintain information from children through this Site.

This Children’s Privacy Policy only applies to children under the age of 13. Any capitalized term used but not defined in this Children’s Privacy Policy shall have the meaning in our Privacy Policy.

Information We Collect from Children

Children may access many parts of the Site and its content and use many of its features without providing us with personal information. However, some content and features require us to collect certain information, including personal information, from them, particularly in relation to information collected in connection with child’s use of the platform when requested by or made available through a Sponsor. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Site.

We only collect as much information about a child as is reasonably necessary for the child to benefit from the use of Tamarin’s platform. 

·       Information We Collect Directly. A child, or a parent on behalf of a child, must provide us with the following information to register a child with the Site:  the child’s first and last name, birth date, and a parent’s email address. We also require the child to create a user name and password. To utilize the Site in connection with a Sponsor, children, or parents on behalf of their children, may also be asked to input data related to their health symptoms and test results or such information may be generated by other applications you utilize. We specify whether information is required or optional when we request it.

·       Automatic Information Collection. We use technology to automatically collect information from our users, including children, when they access and navigate through the Site and use certain of its features. The information we collect through these technologies may include:

o   Details of your visits to the Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.

o   Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.

How We Use Your Child’s Information

We use the personal information we collect from your child to:

·      Register him or her with the Site;

·      Communicate with him or her about activities or features of the Site that may be of interest;

We use the information we collect automatically through technology (see Automatic Information Collection) and other non-personal information we collect to improve our Site and to deliver a better and more personalized experience by enabling us to:

·       Estimate our audience size and usage patterns.

·       Store information about the child’s preferences.

·       Speed up your searches.

We use geolocation information we collect to assess our audience size and usage patterns.

Our Practices for Disclosing Children’s Information

We do not share, sell, rent, or transfer children’s personal information other than as described in this section.

We may disclose aggregated information about many of our users. In addition, we may disclose children’s personal information:

·       To a Sponsor when the child is using the Site when requested by or made available through a Sponsor.

·       To third parties we use to support the internal operations of our Site and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.

·       If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.

·       If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers or others, including to:

o   protect the safety of a child;

o   protect the safety and security of the Site; or

o   enable us to take precautions against liability.

·       To law enforcement agencies or for an investigation related to public safety.

In addition, if Company is involved in a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding or event, we may transfer the personal information we have collected or maintain to the buyer or other successor.

Accessing and Correcting Your Child’s Personal Information

At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information.

You can review, change, or delete your child’s personal information by:

·       Logging into your child’s account and visiting his or her dashboard.

·       Sending us an email at hello@tamarin.health. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.

Operators That Collect or Maintain Information from Children

For any inquiries regarding a Sponsor’s privacy practices and use of children’s information , please contact the Sponsor directly.