Privacy Policy - United States of America

Effective Date: 7th November, 2017

This Privacy Policy (this “Policy”) describes how R-U-Ontrak Inc. and its affiliates (“R-U-Ontrak”, “we” or “us”) collect, use, and disclose the information collected through the R-U-Ontrak mobile application (the “App”) and website (the “Site” and together with the App, the “Platform”). This Policy also describes the ways in which you may access or correct certain information we maintain about you, and how to contact us if you have any questions or comments about your privacy. By using the Platform, you consent that we may process the data that we collect from you in accordance with this Privacy Policy.

This Privacy Policy is incorporated into and made part of our Terms & Conditions. We encourage you to review our Terms & Conditions, because they contain important limitations on our liability to you when you use the Platform.

Please note that this Policy describes how we protect your privacy as a general user of the Platform in the United States. R-U-Ontrak Pty Ltd operates other mobile applications and websites available in New Zealand and Australia, and this Privacy Policy does not apply to the data collected by those non-U.S. services.

Please use the links below to navigate through the Policy:

Our Data Collection and Use Practices

How We May Share your Information

Data Collection Technologies

Do Not Track Signals

Geolocation Tracking

How to Access, Modify or Delete Information

Children’s Privacy

Security

Your California Rights

Notice to International Users

Changes to this Privacy Policy

Contact Us

 

  • Our Data Collection and Use Practices

When you use the Platform, we may collect three types of information from or about you:

  1. Personal Information,” which is any information that can be used alone or in combination with other information to identify you, such as your name, email address, and telephone number.

 

When you use the Site, we may collect your Personal Information. For example, when you purchase a product through our Site, we will collect your name, billing address, and shipping address in order to fulfill your order. We also may collect your Personal Information when you contact us with questions, concerns, or feedback via through email or by other means. When we collect your Personal information, we will use it for the purpose(s) for which it was provided. We may also use your Personal Information to send you administrative and other important communications about, for example, the Platform, our policies, or your purchases.

When you use the App, any Personal Information that is entered in the App is saved locally on your device. Your Personal Information allows you to monitor and manage your recovery from a minor injury that is not yet associated with a goal (a “Tweak”), track your progress in achieving a goal you have set for yourself, and to customize your use of the Platform so that it is responsive to your unique needs. R-U-Ontrak does not currently use your Personal Information for its own internal use. We will notify you if our collection practices with regard to personal information change.

2. “Non-Personal Information” which is information that cannot be used to identify you, such as your IP Address, device ID, browser type and pages visited.

 

When you use the Platform on your computer, mobile or other device, we automatically collect Non-Personal Information about your visit through the use of cookies, web beacons, and other data collection technologies. To learn more about our data collection technologies and how we use them, see the “Data Collection Technologies” section below. Non-Personal Information is used for our internal business purposes so that we can understand and improve the Platform, troubleshoot your issues, and detect and protect against fraud and criminal activity.

3. “Health Information”, which is information that does not necessarily identify you but we recognize may be more private to you than other information, such as details of any Tweaks, certain interactions with your health care providers, and your health and fitness goals and progress.

In order to manage your Tweaks, you may provide Health Information about your Tweaks and how you intend to manage them into the App. You may also provide into the App Information related to the goals you set for yourself, such injury recovery, injury prevention, condition management, climbing a mountain, losing weight, or preventing future injuries or Tweaks. When you use the App, we may collect your Health Information in an anonymous or aggregated form for research, development, and marketing uses. For example, we may use anonymized information concerning your goals and Tweaks for the purpose of creating a greater database of information that you can access through the Platform. This database will be able to tell you, for instance, that 100 people sustained a particular type of injury and the recovery time for those persons, on average, was two weeks. Please note that we take steps to limit the risk of any Health Information we collect being linked back to you or otherwise used to identify you.

If you do not want us to collect, use, or share your Personal Information, including any Health Information that may be sensitive to you, in accordance with this Privacy Policy, please do not submit it through the Platform or otherwise provide it to us.

  • How We May Share your Information

We share your Personal Information with others as disclosed to you at the time of collection and in the following circumstances:

Service Providers. We may share your Personal Information with companies that we contract with to help us deliver the Platform and related services, such as email management, technology hosting, and order fulfillment. We may also use a third party service provider to collect and process your credit card information when you make a purchase on our Site.

 

Subsidiaries. We may transfer your Personal Information to subsidiaries of R-U-Ontrak in order for us to efficiently operate our business.

 

Business Transaction. We may sell, transfer or otherwise share some or all of our assets to a third party in connection with a merger, acquisition, reorganization or sale of assets, or in the event of bankruptcy. In such event, your Personal Information may be transferred to that third party.

 

As Required or Permitted by Law. We may disclose your data as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including, but not limited to, subpoenas), to protect the property and rights of R-U-Ontrak or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, any illegal, unethical or legally actionable activity, and to otherwise to comply with law.

 

We may share aggregated or anonymous information with third parties for informational, educational, and other purposes. We may share aggregated and anonymous information with third parties (e.g., health care providers, researchers, academic institutions, and government agencies) to, among other things, assist in the development of approaches to injury management and prevention. When we disclose this non-identifiable information, we perform appropriate procedures aimed to eliminate certain data elements it so that third parties cannot identify you.

 

You have the ability to share your Personal Information with your contacts. You can share your Personal Information with your contacts, team members, and other third parties through the App. You can also permit other App users to track your progress through the App. As one example, you might choose to send a text message containing your Personal Information to your health care provider to help him or her understand how you manage your injury. As another example, R-U-Ontrak may provide functionality that permits data, with your consent, to be transferred to an electronic health record maintained by your provider. R-U-Ontrak does not manage or control with whom you share your Personal Information, so please use caution when you share your Personal Information with others through the App. Neither R-U-Ontrak nor this Privacy Policy controls how those with whom you share your Personal Information use or share your Personal Information once they receive it.

  • Data Collection Technologies

We and third parties acting on our behalf use various technologies that help us to manage the operations of the Platform and track usage behavior so that we can make your visits more enjoyable and meaningful. For example, we use Google Analytics on the Site to collect information about how often users visit the Site, what pages they visit when they do, and what other websites they used prior to coming to this Site. We use the information we get from Google Analytics to improve the Platform. For more information about Google’s ability to use and share information collected by Google Analytics about your visits to the Website, please see the Google Analytics Terms of Service and the Google Privacy Policy. We also use Flurry’s Analytics Service, which helps us understand how our users use the App. For more information about Flurry and how you can opt out of Flurry’s tracking technology, please see Flurry’s Privacy Policy.

 

Our data collection technologies include:

  • Cookies: Cookies are text files containing small amounts of information that are stored on your computer or mobile device's browser directory. Cookies are created when you visit a website that uses cookies to keep track of your movements within the website. Cookies are useful because they allow us to recognize your device, remember your preferences, automatically log you in to your account, and provide us with information that we can use to further personalize your user experience. You can find more information about cookies at www.allaboutcookies.org.

 

  • Web beacons and GIFs: Certain pages on the Site contain web beacons (also known as web bugs, pixel tags and clear GIFs), which we use to monitor how users use the Site. We use web beacons in combination with Cookies to understand how our users navigate through and process the content contained on our Site.

 

  • Local Storage and Local Shared Objects: We use local shared objects (LSOs) such as Flash Cookies and local storage, such as HTML5 Local Storage, to enhance user experience by, for example, storing your user preferences and settings (e.g., volume/mute) in connection with animated content on the Platform. Local storage is similar to browser Cookies but can store data more complex than simple text. By itself, local storage cannot do anything to or with the data stored on your device. Like Cookies, local storage can only access personal data that you have provided on the Platform. Third parties with whom we partner to provide certain features on the Platform or to display advertising based upon your web browsing activity also use Flash Cookies or HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5. To manage Flash Cookies, please click here.

Your browser may allow you to manage your Cookies and local storage. Because each browser is a little different, we encourage you to check your browsers’ “Help” feature to learn how to block Cookies, how to receive notification of new Cookies, and how to disable existing Cookies. For more information about managing Cookies, please visit www.allaboutcookies.org/manage-cookies/.

  • Do Not Track Signals

 

Some web browsers incorporate a "do-not-track" (“DNT”) or similar feature that signals to websites with which the browser communicates that a visitor does not want to have his/her online activity tracked.  If a website receives a DNT signal, the browser can block that website from collecting certain information about the browser’s user.  Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, R-U-Ontrak (along with many other website operators) does not currently respond to DNT signals.  For more information about DNT signals, visit www.allaboutdnt.com.

  • Geolocation Tracking

Some components of the Platform may include a geo-tracking feature that allows us to offer you location-based services, such as access to the contact details of health care providers (including a doctor, physical therapist, pharmacy, hospital or clinic) in your immediate vicinity. You can change your preferences on your mobile device and/or browser to deny us access to your geolocation. Please note that if you disable geolocation tracking, certain features of the Platform may not be available to you. While the App contains geolocation tracking functionality, R-U-Ontrak does not currently collect your geolocation information.

  • How to Access, Modify or Delete Information

 

Any Personal Information that you input into the App may be modified by accessing your R-U-Ontrak account. If you have any questions about accessing, modifying or deleting your Personal information, including Personal Information that you submit to us through the Site, please contact us using the contact information below.

  • Children’s Privacy

 

The Platform is not directed to children under the age of 13, and R-U-Ontrak does not knowingly collect any Personal Information from children under 13 without the verifiable consent of that child’s parent or guardian. If you are aware of a child providing his or her Personal Information without parental consent, please contact us at hello@r-u-ontrak.com. We will endeavor to delete all data we collected from a child under 13 if we discover we collected it without that child’s parental consent.

  • Security

We employ reasonable security measures designed to safeguard the Personal Information under our control from unauthorized access, use, and disclosure. Despite these measures, the confidentiality of your Personal Information cannot be guaranteed. We encourage you to take appropriate steps to protect your Personal Information, such as using a PIN that is not easy to guess. If you have a security related question or concern, please contact us at hello@r-u-ontrak.com

  • Your California Rights

 

Under California Civil Code §1798.83, R-U-Ontrak is required, once per calendar year and upon request, to disclose to California residents: (i) the identity of any third party to whom we disclosed  Personal Information within the previous calendar year for the third party’s direct marketing purposes; and (ii) the type of Personal Information disclosed. Currently, we do not share your Personal Information with third parties for their direct marketing purposes.

  • Notice to International Users

 

The Platform is hosted in the United States and subject to U.S. law. If you are accessing the Platform from outside the United States, please be advised that U.S. law may not offer the same privacy protections as the law of your jurisdiction. By accessing and using the Platform, you consent to the transfer to and processing of your Personal Information in the United States.

  • Changes to this Privacy Policy

 

The Effective Date of this Policy is set forth at the top of this page. Because we are always looking for innovative ways to help you manage your goals and Tweaks, this Policy may change over time. If any modifications materially change your rights, we will notify you of these changes either by posting notice on the Platform or by sending you an email to the email address we have on file for you. By continuing to access or use the Platform after such changes take effect, you agree to be bound by the modified Policy.

  • Contact Us

 

You can email or write to us with any questions or comments at the following contact information:

 

R-U-Ontrak

Attn: Customer Service
PO Box 335, Sandringham, Victoria, 3191, Australia
hello@r-u-ontrak.com

+61 473187236 (AUS)

 

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