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Effective Date: December 2020; Last Updated: May 2023
This Policy describes our information collection and use practices for our eligible and enrolled members. This includes on stayontrak.com and members.stayontrak.com and through our mobile app. This Policy does not describe our practices on sites or apps where it does not appear. This includes not applying to our corporate site. It also does not apply to the practices of subsidiaries or affiliates. It does not apply to the practices of any clinical providers. It does not apply to information about our employees.
Contact information. We collect your name and phone number. We also collect your address and email address. We may collect username if you create an account and a profile image.
Eligibility information. We may collect information about your eligibility for our services. This includes your age and gender. We may also collect information about your medical history or other information about your health.
Demographic information. We may collect information such as your gender, age, country, and zip code. This may include your preferred language and time zone.
Wellness information. We may collect information you provide to us about health indicators or your fitness level. You may also choose to provide us information about your diet, sleep, or lifestyle factors.
Usage information. We collect logs and session data when you visit our website. This may include location information. We collect browser and operating system information. We collect what site you came from or what site you visit when you leave us. We also look at the areas of our site you visit and any actions you make. We collect your IP address. We also collect device identifiers. This might include your hardware model.
We do not use or disclose sensitive personal information, as defined by California law, for inferring characteristics or for purposes other than those permitted by law. We keep personal information as long as it is necessary or relevant for the practices described in this Policy. We also keep information as otherwise required by law.
We use information to provide and improve our services. We use information to determine eligibility for our services. We also use information to process your enrollment. This includes your registration to let you participate in site or app features. We use information to provide our services, such as care coaching, scheduling and motivation. We also use information to make our website, app, and services better. This may include customizing your experience with us.
We use information to communicate with you. We use information to respond to your questions. This includes questions about our site or app and services, or your relationship with us. For example, we might use your information to respond to your feedback. We also use information to communicate with you about our policies and terms.
We use information for marketing purposes. We may use information to let you know about our services. This may be by phone, email, or on social media platforms. We also use information to send you newsletters or other content we think you may find interesting. We may send you surveys.
We use information for other purposes as permitted by law or as we may disclose to you.
We use information to protect our company and members. We use information to protect our company. For example, we use information to identify fraud and secure our systems and accounts.
We collect information directly from you. We collect information if you contact us. We also collect information from you if sign up for email communications, or otherwise submit it to us. This could be in person. It may also be over the phone, or online, including through chat sessions. Our platforms may let you post information publicly that others in your group may be able to see.
We collect information passively. We use tracking tools to collect information. Tracking tools include browser cookies and web beacons. To learn more about cookies visit the FTC’s Online Tracking page. We do this on our websites and in emails that we send to you. We collect information about users over time when you use our websites. We have third parties collect personal information this way.
We collect information about you from third parties. For example, our business partners may provide information about you to us. This includes the information we obtain from or on behalf of health plans that offer our services as a benefit.
We combine information we collect from you on the website with information we receive from you offline. We combine information that we have collected across other third party sites. We combine information across devices, such as computers and mobile devices. We also combine information you provide with information we obtain from third parties.
We may provide information within our family of companies. We may share all categories of information with our affiliates, parent company, and other related companies. This includes current and future companies.
We disclose information with your care coaches you choose. Certain categories of information may be provided to your care coaches to help offer those services. This includes contact, demographic, eligibility and wellness information. For example, care coaches may learn about your current or past program enrollment. They may also see what habits you have chosen to work on.
We disclose information with vendors who perform services on our behalf. We provide all categories of information with trusted vendors that help us deliver our services. For example, we may share site usage information with vendors who help us host and operate the site and app.
We disclose all categories of information if we think we have to in order to comply with the law or to protect ourselves. We share information we collect about you to respond to a court order or subpoena. We share information in response to a government agency or investigatory body request. We share information we collect when we investigate potential fraud.
We will transfer information with any successor to all or part of our business. If all or part of our business was sold, we may share all categories of information as part of that transaction. If there is a merger or acquisition, we may also share your information. If there is a financing or bankruptcy, we may share your information.
We disclose information as permitted by law and for other reasons we may describe to you.
You can opt out of receiving our marketing emails. To stop receiving our promotional emails, follow the “unsubscribe” instructions in any promotional message you get from us. Even if you opt out of getting marketing messages, we will still send you transactional messages. These include responses to your questions or other necessary information about your account.
Certain residents’ rights. If you live in California or a state with a similar law, you may have additional rights. You have the right to ask us what information we collect and use. You also have the right to ask what information we share and sell. You also have the right to request that we delete information we have collected from you. It also includes the right to fix or update information you have provided to us.
How it works: To exercise your rights contact us at [email protected]. We will verify your request by matching information you provide with information we already have about you. We will not discriminate against you because you have exercised any of your rights under CCPA. If you are submitting on someone else’s behalf we may ask for additional information to verify your identity. This may include providing a signed letter verifying your right to make this request. Certain exceptions may apply to requests you might make. For example, CCPA does not apply to Medical information governed by the Confidentiality of Medical Information Act or protected health information that is collected by a covered entity or business associate subject to the Health Insurance Portability and Accountability Act.
Sales and sharing of information: We are also required to tell Californians if we “sell” information as that term is defined by applicable law. Sell means to share personal information with a third party for monetary or other valuable consideration. We do not do this based on our understanding of that term. We do not have actual knowledge that we sell personal information of minors under the age of 16. Share is specifically defined under the law. Sharing means providing personal information to a third party for cross-context behavioral advertising. We do not “share” personal information in this way based on our understanding of that term.
Nevada residents’ rights. We also have disclosure obligations in Nevada. There, we do not exchange Nevada residents’ personal information for money. Nevada residents may opt out of the future sale of their information by contacting us as described at the end of this policy.
The Internet is not 100% secure. We cannot promise that your use of our sites or apps will be completely safe. We encourage you to use caution when using the Internet. This includes not sharing your passwords.
Information we collect is stored in the United States. This site is intended for people who are in the United States. If you live outside of the United States and choose to use this site you understand that it is at your own risk. If you live outside of the US, you understand and agree that we may transfer your information to the US. Our sites and businesses are subject to US laws, which may not afford the same level of protection as those in your country. By submitting your information, you agree to the processing of it in the US.
Our sites and apps are meant for adults. We do not knowingly collect personally identifiable information from children under 13 without permission from a parent or guardian. If you are a parent or legal guardian and think your child under 13 has given us information, you can email us. You can also write to us at the address listed at the end of this policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.
Contact Us – If you have questions about this Policy, you can email us at [email protected].
Policy Updates – We may make changes or updates to this Policy. We will notify you of any material changes to this Policy as required by law. All changes will also be posted on our website. Please check our site periodically for updates.