ANCHOR HEALTH, INC.

PRIVACY POLICY

Last Updated: March 15, 2020

 

 

Welcome to Anchor Health!

DESCRIPTION OF ANCHOR HEALTH AND THE ANCHOR HEALTH PLATFORM

Anchor Health, Inc. (“Anchor Health” or “we” or “us”) is the champion of the individual in their health care management.  Health care is a fragmented industry. Products and services available to individual consumers are disjointed and they are left to piece the puzzle together. The Anchor Health Platform (“Platform”) integrates multiple point solutions and provides a one stop digital destination for the numerous challenges individuals face when navigating health care.

SCOPE OF THIS PRIVACY POLICY

This Privacy Policy will tell you about the types of personal information we collect about you, explain the choices you have about how your personal information is used and how we protect that information. We urge you to read this Privacy Policy carefully.

 

This Privacy Policy applies to the various service offerings available on the Platform which is owned and operated by Anchor Health.  Services available on the Platform include the cloud-based software platform, websites (“Sites”), mobile applications (“Apps”), messaging applications (“Messages”), voice applications (“Voice Apps”) (collectively or individually referred to as the “Service(s)”).  The Anchor Health Services champion individuals in navigating health care, saving them time and money, and providing access to innovative solutions.

 

The Platform integrates multiple point solutions and provides a one stop digital destination for the numerous challenges individuals face when navigating health care. The Platform design necessitates the use and integration of third party products and services (“Third Party Solutions”) to provide some of the features of the Platform.  Examples of the functionality provided by such Third Party Solutions include, but are not limited to information on health conditions, information and discounts on medications, and information of health care providers.   Further, we contract with companies who help with parts of our business operations (e.g., concierge services to our users, website and data hosting, fraud prevention, etc.).

 

Where feasible, we host Third Party Solutions directly on our servers so we eliminate the need to share information.  Sometimes for features of the Platform to work as intended, we may need to share your personal information with Third Party Solutions.  We limit the sharing of information to the least necessary to provide the feature requested by you.  This Privacy Policy is not applicable to any Third Party Solutions, please see the privacy policy applicable to the Third Party Solutions or the third party.

 

It is important for you to understand that Third Party Solutions are subject to their own privacy and data policies for which we are unable to bear responsibility.  Any information disclosed to Third Party Solutions is not covered by this Privacy Policy. 

 

There are numerous digital platforms commonly used by consumers to access digital products and services that are not controlled or owned by Anchor Health (“Third Party Digital Platforms”).  Current examples of such Third Party Digital Platforms include Facebook Messenger, Amazon Alexa, Google Home, Apple Home, Slack, Facebook, WhatsApp, Twitter, and Instagram. 

 

In order to champion consumers of health care products and services and grow the usage of the Platform, we have a business need to serve consumers on Third Party Digital Platforms.  We may also include social widgets on the Platform which enable you to interact with Third Party Digital Platforms. These widgets may collect Tracking Technologies and Traffic Data (as described below) which may be accessed by the third party that provided the widget, and are controlled by these third parties. 

 

It is important for you to understand that when you use Anchor Health on a Third Party Digital Platform, that Third Party Digital Platform is able to monitor and store your activity and information.  You have a choice to not access Anchor Health on Third Party Digital Platforms and use our iOS and Android applications directly.  Further, Third Party Digital Platforms are subject to their own privacy and data policies for which we are unable to bear responsibility.  Any information disclosed to Third Party Digital Platforms is not covered by this Privacy Policy.  You may be able to manage your privacy preferences directly with the applicable Third Party Digital Platform. 

 

Anchor Health works with “Partners” such as employers, health care systems, health insurance companies, pharmacies, advertisers, health care companies, and so on.  We may present you with sponsored results, content, advertisements, recommendations, communication, products, and services on behalf of our Partners.  These Partners may also choose to pay for some of the services delivered to you. 

 

It is important for you to understand that Partners are subject to their own privacy and data policies for which we are unable to bear any responsibility.  Any information that you disclose to Partners is not covered by this Privacy Policy. You may be able to manage your privacy preferences directly with the applicable Partner.


We take our responsibility seriously and are committed to strong privacy and security protections for your personal information.  By accessing the Platform or using the Services, you agree to the practices and policies outlined in this Privacy Policy and you consent to the collection, use, and sharing of your information as described in this Privacy Policy. If you do not agree with this Privacy Policy, you should not use the Platform.  If you use the Services on behalf of someone else (such as your child), you represent that you are authorized to accept this Privacy Policy on that individual’s behalf as it applies to their personal information. By using the Services, you must agree to the Anchor Health
Terms of Service, which is the contract between Anchor Health and users of the Platform.  By accepting the Anchor Health Terms of Service, you confirm that you have read and understand this Privacy Policy and the Anchor Health Cookie Policy.

 

If you have any questions or concerns about this Privacy Policy, please contact us at privacy@anchor.health.

ABOUT YOU

Anchor Health collects the following categories of information for the purposes explained below.

Personal Information and Protected Health Information

Personal Information (also sometimes called personal data) is information that either alone or in combination with other information is related to an identified or identifiable natural person. Examples of personal information include email address, cell number, social security number, drivers license information and address. Personal information may also include information related to an individual’s health, wellness, mental or physical symptoms, healthcare providers, visits to dentists or doctors, payment for healthcare services, diagnoses, prescription medications, insurance coverages or costs, or any similar information.

 

Protected Health Information (“PHI”) is one type of Personal Health Information that is defined in the Health Insurance Portability and Accountability Act of 1996 (“HIPPA”) which may be collected and used independently or in combination with other types of personal information. Protected Health Information is typically individually identifiable information relating to the past, present, or future health status of an individual that is created, collected, transmitted, or maintained by a HIPPA covered entity in relation to the provision of healthcare, payment for healthcare services, or use in healthcare operations.  For example, prescription information, lab or test results, and diagnoses are some types of Protected Health Information.

 

We collect Personal Information directly from you when you provide it to us via the Platform, including, but not limited to when you register to use the Services.  With your authorization or permission, we may also access your Protected Health Information from Covered Entities, Hybrid Entities, and Business Associates.  Covered entities are defined in the HIPAA rules as (1) health plans, (2) health care clearinghouses, and (3) health care providers who electronically transmit any health information in connection with transactions for which HHS has adopted standards.  For example, hospitals, academic medical centers, physicians, and other health care providers who electronically transmit claims transaction information directly or through an intermediary to a health plan are covered entities. Covered entities can be institutions, organizations, or persons.  A Hybrid Entity is a single legal entity that is a covered entity, performs business activities that include both covered and noncovered functions.  A Business Associate is a person or entity who, on behalf of a covered entity, performs or assists in performance of a function or activity involving the use or disclosure of individually identifiable health information, such as data analysis, claims processing or administration, utilization review, and quality assurance reviews, or any other function or activity regulated by the HIPAA Administrative Simplification Rules, including the Privacy Rule. Business associates are also persons or entities performing legal, actuarial, accounting, consulting, data aggregation, management, administrative, accreditation, or financial services to or for a covered entity where performing those services involves disclosure of individually identifiable health information by the covered entity or another business associate of the covered entity to that person or entity. A member of a covered entity’s workforce is not one of its business associates. A covered entity may be a business associate of another covered entity.

 

The authorization and permission process will allow you to select the information you want shared with us and we will use such information in accordance with this Privacy Policy. With your permission, we may share your personal information, including your Protected Health Information, with third parties that have a business reason to know such personal information in order to facilitate the Services on your behalf (e.g. Anchor Health’s service providers that provide you with concierge services, billing or payment assistance, information on accessing care or products and services relevant to you).

Information Collected With Registration

You are not required to register with Anchor Health to use, Messages, and Voice Apps. You may still access and use some of the Services if you choose not to register on the Platform or if you elect not to provide us with any personal information. However, many features of the Services that require your personal information will not be accessible to you.

When you register on the Platform, you voluntarily provide us with the following types of personal information that we store and use in accordance with this Privacy Policy. If you choose to register or update an existing account with Anchor Health or access certain Services, you may be required to provide certain personal information such as:

 

      Contact data (i.e. your name, address, telephone number, e-mail address and phone number).

      Demographic data (i.e. your gender, your date of birth, level of education and your zip code).

      Insurance data (i.e. your insurance carrier, insurance plan, member ID, group ID and payer ID).

      Medical data (i.e. which may include health care providers that you have visited, the reasons for your visit, the dates of visits, your medical history, health care preferences, end of life preferences, and other medical and health information that you choose to share with us through use of the Services).

      Other identifying information (i.e. as social security number, driver’s license number); and financial information such as payment preferences, credit card information, bank account information.

      Biometric identifiers (i.e. face or voice identification for the purpose of authenticating the user).

      Other sensitive information that you choose to provide to us during your use of the Services, the Platform, or through emails or letters that you send to us. This includes communications with your caregivers about care preferences, barriers to health, living conditions, social determinants of health, etc.

With your permission, we, our Partners, Third Party Solutions, Third Party Platforms or other business partners may contact you in the course of providing some of the Services (e.g. to provide you with content or information you requested through use of the Services, remind you of appointments scheduled using the Services, etc.). You are responsible for ensuring the accuracy of the personal information that you submit to Anchor Health and registering in accordance with the Terms of Service.

 

If you are registered with Anchor Health, we associate information that you submit to the Apps, Voice Apps, Messages or Platform with registration information that you have previously provided when using or registering the Platform or other Services. We may also provide a cross-platform service that enables you to seamlessly use the various aspects of the Services. To accomplish this, we rely on identifiers derived from use logins to associate your usage across mobile and desktop platforms.

Information Collected Without Registration

Even if you do not register to use the Platform, we collect information about your use of the Anchor Health Services. When you access the Sites or use the Services, we may also acquire information about your use from external sources.

Interactive Services

Some of our Services, such as Apps, Messages, and Voice Apps, are interactive and may request that you submit health-related information, along with demographic information such as demographic data (such as your gender, your date of birth and your zip code) or your location. Browser and Device Information

When you access and use the Services, Anchor Health automatically collects and stores in its server logs information from your browser or mobile device such as your IP address or unique device identifier, browser information (including referring URL), your preferences and settings, cookies and information about the content you have viewed and actions taken (e.g., search queries, ad engagement, clicks and the associated dates and times). Anchor Health may also collect device-specific information when you install and use our App including your device model, operating system information, advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device) and App version and usage information. When enabled by you, we collect precise location information provided by your mobile device, which you may disable through the device settings.

 

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.

Tracking Technologies and Traffic Data

We and our business partners use cookies to collect information about your use of the Platform and the Services. “Cookies” are small data files assigned to your browser when you visit the Sites which enable recognition of your browser and collect and store information about your use of the Services, as described above. In addition to cookies, we and our partners use other tracking technologies that collect personal information about your use of the Services, including mobile identifiers and "web beacons" which are small graphic files (sometimes called “clear GIFs” or “web pixels”) embedded in a web page or email typically used to monitor activity and send relevant information back to a home server (which can belong to the host site, a network advertiser or some other third party).

Our Partners may use cookies and other tracking technologies to collect information about your use of the Sites, including content you have viewed. Partners may use this information to help Anchor Health deliver sponsored advertising on the Sites. Anchor Health may further tailor the advertising to you on the Anchor Health Sites and other third party websites based on additional information to the extent known by Anchor Health or these third parties. For more information about how our cookies and other tracking technologies are used in connection with the Services, please read our Cookie Policy.

When you use the Services, Anchor Health automatically collects and stores in its server logs information from your browser or mobile device such as your IP address, unique device identifiers, browser information (i.e. the URL that referred you to the Site), your settings and browsing preferences, (including cookies as described above) and other information about the content presented to you and your online activity (e.g. search queries, ad engagement, and clicks), and other statistics and information associated with the interaction between your browser or device and the Services (collectively “Traffic Data”). Depending on applicable law, some Traffic Data may be personal information. Anchor Health may also collect device-specific information when you install and use an app including your device model, operating system information, advertising ID (which is a unique, user-resettable identification number for advertising associated with a mobile device) and App version and usage information. When enabled by you, we may collect precise location information provided by your mobile device, which you may disable through the device settings. We use this information to offer you relevant information based on your geography.

 

When you download and install Apps, Messages, or Voice App, onto your mobile device we assign a random number to your App installation. This number cannot be used to identify you personally, and we cannot identify you personally unless you choose to become a registered user of the App. We use this random number in a manner similar to our use of cookies as described in this Privacy Policy and in our Cookie Policy. Unlike cookies, the random number is assigned to your installation of the App itself and not a browser, because the App does not work through your browser. Therefore, the random number cannot be removed through settings. If you do not want us to use the random number for the purposes for which we use cookies, please do not use the Apps, Messages, or Voice App.

 

You may control interest-based advertising on your mobile device by enabling the “Limit Ad Tracking” setting in your iOS device’s settings or “Opt Out of Ads Personalization” in your Android device’s settings. This will not prevent you from seeing advertisements, but will limit the use of device advertising identifiers to personalize ads based on your interests.  If you have questions about how to reject Cookies on your specific device please check with the device manufacturer.

Anchor Health Blogs and Other Public Forums

Anchor Health features several blogs, message board areas and other public forums. Users with similar interests, including with respect to certain medical conditions or shared experiences with health care services, can share information and support one another by using the message boards or forums. Users can also post questions for experts to answer and we may offer online discussions moderated by health care experts. Our message boards are open to the public and should not be considered private.


Any information (including personal information) you share in any online message board or other forum is by design open to the public and is not private. You should think carefully before posting any personal information in any public forum. What you post can be seen, disclosed to or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines.

 

If you post personal information in any public forum and would like to request for it to be removed, you can send us an email at privacy@anchor.health. In some cases, we may not be able to remove your personal information. 

HOW WE USE YOUR PERSONAL INFORMATION

How Anchor Health Uses the Information Collected About You

Information about your use of the Platform and Services may be used for the following purposes.

 

      Perform Services,” such as the Services you request, the administration of your account and the ability to create comprehensive personal records of your healthcare and wellness activities.

      Internal Business Operations,” such as the creation, maintenance, improvement, or provision of various products and services, provision of customer service, communications to our employees, business partners, service providers and regulators.  For CCPA (defined below) purposes, this includes auditing, debugging, internal research for technological development and demonstration, and undertaking activities to verify or maintain the quality of Services.

      Verification” of users of the Services which includes our ability to authenticate your identity to respond to your inquiries and requests, to protect, investigate and deter against fraudulent, unauthorized, unlawful, or other activity.  For CCPA purposes, this includes activities for security, and to verify or maintain quality and safety of Services.

      Security” includes detection of threats, malicious code and other unlawful, unauthorized or undesirable activities on our Platform, the Services or users of same.

      Analytics” involving research and studying potential trends, decision making or activities. For CCPA purposes, this includes auditing, debugging, internal research for technological development and demonstration, and undertaking activities to verify or maintain the quality of Services.

      Advertising” includes communications, targeted ads that are about promotions, upcoming events, and other news about Products and Services offered by us, Partners and other business partners.  This is a commercial purpose as defined by the CCPA. Much of the information shared for advertising purposes has been aggregated or de-identified.  For example, in this regard, we share non-identifying information such as, “58% of the users who clicked on your ad were female.”

      “Research and Measurement.” We may combine your personal information and other information collected about your use of the Platform and Services, and also supplement with information from external sources for the purposes described in this Privacy Policy. For example, information that Anchor Health collects about you may be combined by Anchor Health with other information available to Anchor Health through third parties for research and measurement purposes, including measuring the effectiveness of content, advertising or programs. This information from other sources may include age, gender, demographic, geographic, personal interests, product purchase activity or other information. We may report aggregate information, which is not able to be identified back to an individual user of the Platform or Services to our current or prospective Partners and other business partners.


In addition, Anchor Health and our Partners may use personal information about you for other purposes that are disclosed to you at the time we collect the information and/or with your consent.

 

We derive business value from your personal information in the following manner:

 

      Personalization and customization to increase your adoption and usage of our Products and Services.

      Premium Levels of service (“Paid Memberships”) where you or a Partner pay us to provide enhanced value and features of the Platform.  The specific composition of the Platform delivered via Paid Memberships will necessarily vary over time.

      We may place curated and private sponsored results and content (“Sponsored Results”). 

Our Sponsored Results are curated because we try and select those you are likely to find valuable vs. intrusive and annoying.  For example, when you search for an oncologist, in addition to your organic search results, you may be presented with a Sponsored Result for an oncologist at a leading university who is pursuing cutting edge cancer research. 

      We may provide deidentified and aggregated information about the Sponsored Results we place on our platform for enterprises to assess the effectiveness of their marketing campaigns.

HOW WE SHARE YOUR PERSONAL INFORMATION

We may share personal information with your consent.  For example, you may provide permission to us to share your personal information with partners including but not limited to our Partners, to deliver the Services and facilitate your use of the Platform.

For Legal, Protection, and Safety Purposes

We may share personal information for legal, protection, and safety purposes.  This includes:

 

      We may share information to comply with laws.

      We may share information to respond to lawful requests and legal processes.

      We may share information to protect the rights and property of Anchor Health, Inc., our agents, customers, and others. This includes enforcing our agreements, policies, and Terms of Service.

      We may share information in a national or local emergency. This includes protecting the safety of our employees, agents, customers, or any person.

Analytics and Internal Business Uses

      We may share information with third parties to run analytics on the Services, Platform or for our internal business purposes.

      We may disclose aggregated, anonymized information to third parties, for example, when we conduct industry wide surveys to publish benchmark reports, or to include statistics when collaborating with researchers or other companies on industry white papers.

      We may share your information with others for their own marketing uses. Those uses will be subject to their privacy policies.

      We may share aggregated and/or anonymized data with other organizations, such as our Partners for their own uses such as to analyze the success of their advertising campaigns on the Platform.

      We do not share personal information with advertisers.  Rather we aggregate information and remove the possibility that your information could be traced back to you.  The type of information we share with advertisers includes for example, “58% of the users who clicked on your ad were female.” 

Information Sharing

Without your consent to collect, store, and use your personal information, it is not possible for us to champion you in health care using the full functionality of the Platform.  For example, in order to provide you with an aggregated health record, we require your consent to collect your personal information from Partners.  For example, to help you review an unexpected bill, we require your consent to contact the insurance company, analyze your data, and ask questions on your behalf. We also request your consent to provide our Partners with your personal information to enable personalized options for products and services related to the information shared by you upon Registration and through your use of the Services and collected by the Platform.        

Information Disclosed in a Change of Ownership

Anchor Health may sell, transfer, or otherwise share some or all of its assets, including information we collect about you, in connection with a merger, acquisition, reorganization, or sale of assets or in the event of bankruptcy. We may also make certain information available to a potential investor or purchaser (and their advisers) in advance of any such transaction completion.

HOW WE SECURE AND PROTECT YOUR PERSONAL INFORMATION

We take significant and reasonable security measures designed to protect your personal information.  Anchor Health employs a wide variety of administrative, physical and technical safeguards to protect the confidentiality, integrity, and availability of your personal information.

 

For example, only Anchor Health employees, business partners, service providers and consultants who have a business need to access such as those assigned to operate and provide support for the Platform, are provided electronic access to areas of the Platform where your personal information is stored.

 

We use Secure Sockets Layer (“SSL”) certificate technology so that you have assurance when using the Services that our Site is genuine and operated by Anchor Health. That technology also allows us to establish a secure, encrypted connection between the Platform and the web browser you are using when you connect to the platform. When the secure, encrypted connection exists, the address appearing in your browser’s address bar will begin with, “https://” (not just http://). If you use a high-security browser, your browser address bar will turn green to indicate your secure connection.

 

Other technical safeguards that we employ at Anchor Health to protect your personal information include the following:

 

      Encryption of Service Account passwords

      Guidance on secure user passwords

      Mandatory use of high-security web browsers and mobile platforms

      Encryption of your personal information at rest

      Encryption of your personal information in transit

      Firewalls to prevent unauthorized entry

      Audit trails to monitor access

 

However, it is important for you to understand that the threat of unauthorized access or disclosure of your personal information is persistent and, there is always some risk to using any online or mobile technologies.  Further, in some instances our third parties may provide information to us in unencrypted form.  Anchor Health will provide notice to you, government agencies with jurisdiction or relevant supervisory authorities in accordance with applicable laws in the event of a security breach that involves your personal information.

 

We retain your personal information for as long as required by the law, as long as necessary to provide you with access to the Platform, as long as your account is active, and as long as needed by us to resolve disputes and enforce agreements.  Should you deactivate or cancel your account we will take measures to purge your personal information from our systems in accordance with the law.  However, it may not be technology possible to delete all records of your interactions with the Platform.

YOUR CHOICES

Should you not agree with any aspect of this Privacy Policy please do not use the Platform. 

Opting-Out Generally

Opting-out of advertising through the below methods will not prevent you from seeing ads, but those ads will likely be less relevant because they will not be tailored to your interests. The ads might, for instance, be randomly generated or based on the web page you are visiting.

Opting-Out by Web Browser

If you are using a web browser, you can opt-out of receiving personalized ads (including retargeted ads) served by us or on our behalf by clicking on the blue icon that typically appears in the corner of the ads we serve and following the instructions provided. Please note that this “opt-out” function is browser-specific and relies on an “opt-out cookie”, thus, if you delete your cookies or upgrade your browser after having opted out, you will need to opt-out again. If you use a Safari browser, please also see directions regarding our cookie-less technology opt-out, below.

Cross-Device Opting-Out

In some cases, we may link multiple browsers or devices to you. If you opt-out on a browser or device and we have more linked to you, we will extend your opt-out decision to the other linked browsers and devices. Since we only link users across browsers and devices in some conditions, there could be cases where you are still being tracked in a different browser or device we have not linked, and where we are treating you as a different user.

Opting-Out by Mobile Device

To opt-out of receiving targeted ads that are based on your behavior across different mobile applications follow the below instructions, for iOS and Android devices:

 

Deletion

If you wish to have us delete your personal information that we’ve collected on you, please contact us at privacy@anchor.health. In addition, our marketing emails tell you how to “opt-out.” If you opt-out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.

 

You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.

 

You can typically remove and reject cookies from our Products and Services with your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, it could affect how our Products and Services work for you.

 

You can request deletion of your personal information and account profile by contacting us at our address below.

CALIFORNIA RESIDENTS: YOUR PRIVACY RIGHTS

Under the California Consumer Protection Act of 2018 (“CCPA“), California residents have certain rights around Anchor Health’s collection, use, and sharing of their personal information.  For purposes of this section, “Personal Information” has the meaning given under the CCPA. The definition of Personal Information does not include certain de-identified or aggregated information, PHI under HIPPA, medical information under the Confidentiality of Medical Information Act, information publicly available in government records, or certain information excluded from the CCPA’s scope.

Personal Information We Collect, Use, and Share

The below chart summarizes the categories of Personal Information we collect, where we collect it from, how we use it, and who we share it with.  This chart is updated in an annual review and reflects the prior twelve (12) months from the date of review.

 

Categories Collected

Sources We Collect From

Purposes Behind Collection, Use, and Sharing 

Categories of Third Parties We Disclose To

·  Identifiers

·  Consumer Customer Records Enumerations (Cal.Civ.Code §1798.80(e))

·  Commercial Information 

·  Internet or Other Electronic Network Activity 

·  Geolocation Data

·  Audio, Electric, Visual, Thermal, Olfactory, or Similar Information

·  Professional or Employment-Related information

·  Education Information (Not Publicly Available Under FERPA)

·  Inferences (Drawn to Create a Profile About a Consumer)

·  Registered Users

·  Unregistered Users

·  Partners

·  Third Party Digital Platforms

·  Third Party Solutions

·  Perform Services

·  Operations

·  Verification

·  Security

·  Analytics

·  Advertising

·  Partners

·  Third Party Solutions

·  Third Party Digital Platforms

·  Protected Classifications

·  Registered Users

·  Unregistered Users

·  Partners

·  Third Party Digital Platforms

·  Third Party Solutions

·  Perform Services

·  Operations

·  Advertising

·  Analytics

·  Verification

 

·  Partners

·  Third Party Solutions

·  Third Party Digital Platforms

·  Biometric Information

·  Registered Users

·  Unregistered Users

·  Partners

·  Third Party Digital Platforms

·  Third Party Solutions

·  Perform Services

·  Operations

·  Verification

·  Partners

·  Third Party Solutions

·  Third Party Digital Platforms

 

Your Consumer Rights Under the CCPA

These rights are not absolute and all requests are subject to exceptions and verification.  Anchor Health may be required or permitted by law to decline any request. Only you, a person that you authorize to act on your behalf, or an entity registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to accessing or deleting your Personal Information.  

 

To protect the privacy of your Personal Information, we are required to verify your request.  Verifiable requests must describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to the request.  To make a request to know or delete, we may ask you to verify your identity and proof of California residency, which may include a signed declaration under penalty of perjury that you are the individual whose Personal Information is the subject of the request.

 

When Anchor Health receives a consumer request, we make every effort to honor your request.  We maintain records of all the requests received, the time it takes to respond to requests, and we track the outcomes of all requests. 

Your Right to Access, Delete, Opt-Out of Sale, and Non-Discrimination

You can make a request to access the categories or specific pieces of Personal Information Anchor Health collected, used, or shared about you in the past twelve (12) months.  Along with your verified request, we will give you any categories of sources from which the personal information is collected, the purpose for collecting, selling, or sharing, and any categories of third parties with whom we share such Personal Information.

 

You can make a request to delete any Personal Information Anchor Health has collected about you.  Upon receiving a verified request, Anchor Health will notify you once your information has been deleted.  We will also communicate your deletion request to service providers and direct them to delete your Personal Information.

 

California broadly defines “sale” to include using services to deliver targeted advertising on other sites or applications. Anchor Health will respond to valid requests to opt-out by refraining from selling any of your Personal Information going forward.  We will also communicate your opt-out of sale request to relevant third parties as required by applicable laws and regulations.

 

Anchor Health values giving consumers control over their privacy and Personal Information.  If you choose to exercise any of your rights under the CCPA, we will not differentiate our services or products as a result of your decision.  We also do not offer any financial incentives to opt-in to sale of your personal information.

The vast majority of Personal Information we collect can be found in your account.  There are two ways to make a consumer request. First, submit a request on Anchor Health’s website: https://anchor.health and fill out a service desk request including your Member ID.  Your Member ID can be found in your User Profile when you are logged in to the Anchor Health iOS or Android app. Alternatively, you can submit your request to privacy@anchor.health.  In the subject line include “CCPA Consumer Request” and note in the body of the email, what kind of request you are seeking, and include your Member ID if you are registered on the Anchor Health Platform. 

 

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable request for access of data portability twice within a 12-month period. The verifiable consumer request must:

·     Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and

·     Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot: (i) verify your identity or authority to make the request; and (ii) confirm the personal information relates to you.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Authorized Agent

You can appoint a person or a business entity registered with the Secretary of State to act on your behalf.  In order to do so, you must provide the authorized agent with written permission to do so. Your authorized agent should submit a copy of your written authorization. This can be done by attaching the written authorization to any request sent to the email contact listed at the end of this Privacy Policy.  Anchor Health may request more information from the authorized agent if needed to verify the authorized agent’s identity or to avoid any breach of security or instances of fraud.

Minors

We do not knowingly collect personal information from children under 16.  If you are a parent or legal guardian and think your child has given us information, you can email us at privacy@anchor.health.  Please note “Minor Information Request” in the subject of your email and note the age of your child in the body of the email. 

Tracking

Some Internet browsers allow users to send a “Do Not Track” signal to websites you visit. Anchor Health does not respond to this signal at the present time.

EUROPEN CITIZENS: YOUR PRIVACY RIGHTS

Your Privacy Rights Under the GDPR

Under the European General Data Protection Regulation (EU) 2016/679 (“GDPR”) European Citizens have certain rights around Anchor Health’s collection, use and sharing of personal data. “Personal data” has the defined meaning under the GDPR.  The definition of personal data does not include certain de-identified or aggregated information.  If you are a visitor from the European Territories, our legal basis for collecting and using the personal data described above will depend on the personal information concerned and the specific context in which we collect it. "European Territories" mean the European Economic Area and Switzerland. For the purpose of this Website Privacy Notice, the term "European Territories" shall continue to include the United Kingdom, even after the United Kingdom leaves the European Economic Area following Brexit.

We will normally collect personal data from you where the processing is in our legitimate interests. For example, to administer the Platform and provide Services.

 

In some cases, we may collect and process personal data based on consent. For example, when you register for Services or download App, you will be asked to consent to Anchor Health’s collection of Personal Data.

 

If you have questions or need further information concerning the legal basis on which we collect and use your personal data, please contact us as the information in the “Our Contact Information” section at the end of this Privacy Policy.

 

If you are a resident of a European Territory, you have the following enhanced rights under EU data protection law:

If you wish to access, correct, update, transfer or request deletion of your personal information, please submit a request on Anchor Health’s website: https://anchor.health

 

If you wish to object to us processing your personal data or would like to otherwise restrict the processing of your personal data, we will honor that request. Please see the “Your Choices” section of this Privacy Policy and feel free to also submit a request on Anchor Health’s website: https://anchor.health

 

Similarly, if we process your personal data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your personal data conducted in reliance on lawful processing grounds other than consent.

 

You have the right to complain to a data protection authority about our collection and use of your personal data. For more information, please contact your local data protection authority. Contact details for data protection authorities in the European Territories. However, if you have any questions about our collection and use of your personal data, we encourage you to contact us first at privacy@anchor.health.

OUR CONTACT INFORMATION.

We welcome your comments or questions about this privacy policy. You may also contact us at our address:

 

Anchor Health, Inc.

555 Bryant St # 886

Palo Alto, California 94301

privacy@anchor.health

CHANGES TO THIS PRIVACY POLICY.

We may change this privacy policy. If we make any changes, we will change the Last Updated date above.