Privacy Policy


SPORA HEALTH PRIVACY POLICY

Last Updated: May 15, 2020

This Privacy Policy explains how Spora Health, Inc. (“Spora Health,” “we,” or “us”) collects, uses, and discloses information about you. This Privacy Policy applies when you use our websites and other online products and services that link to this Privacy Policy (collectively, our “Services”), shop in our stores, contact our customer service team, engage with us on social media, or otherwise interact with us.

We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website or sending you a notification). We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.


CONTENTS

Collection of Information

Use of Information

Sharing of Information

Analytics

Transfer of Information to the United States and Other Countries

Your Choices

Your California Privacy Rights

Contact Us


COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us. For example, you share information directly with us when you create an account, fill out a form, submit or post content through our Services, communicate with us via third-party platforms, request customer support, or otherwise communicate with us. The types of personal information we may collect include your name, date of birth, email address, postal address, phone number, credit card information, health insurer and primary care physician information, doctor’s appointments information, current and past medical history, demographic information, and any other information you choose to provide.

Information We Collect Automatically When You Interact with Us

When you access or use our Services or otherwise transact business with us, we automatically collect certain information, including:

  • Device and Usage Information: We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, IP address, and browser type. We also collect information about your activity on our Services, such as access times, pages viewed, links clicked, and the page you visited before navigating to our Services.
  • Location Information: In accordance with your device permissions, we may collect information about the precise location of your device. You may stop the collection of precise location information at any time (see the Your Choices section below for details).
  • Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that we use on our Services and in our emails to help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the Your Choices section below.

Information We Derive

We may derive information or draw inferences about you based on the information we collect. For example, we may make inferences about your risk of diabetes or other health conditions based on your responses to questions regarding your health.


USE OF INFORMATION

We use the information we collect to connect you with health care professionals and provide other physical and mental health resources. We also use the information we collect to:

  • Provide, maintain, and improve our products and services;
  • Process transactions and send you related information, including confirmations, receipts, and invoices;
  • Personalize and improve your experience on our Services;
  • Send you technical notices, security alerts, and support and administrative messages;
  • Respond to your comments and questions and provide customer service;
  • Communicate with you about products, services, and events offered by Spora Health and others and provide news and information that we think will interest you (see the Your Choices section below for information about how to opt out of these communications at any time);
  • Monitor and analyze trends, usage, and activities in connection with our Services;
  • Detect, investigate, and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Spora Health and others;
  • Debug to identify and repair errors in our Services;
  • Comply with our legal and financial obligations; and
  • Carry out any other purpose described to you at the time the information was collected.


SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

  • We share personal information with vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, payment processing, fraud prevention, customer service, and marketing and advertising.
  • We may share your personal information with medical providers and health insurers to facilitate your use of the services.
  • We may disclose personal information if we believe that disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
  • We may share personal information if we believe that your actions are inconsistent with our user agreements or policies, if we believe that you have violated the law, or if we believe it is necessary to protect the rights, property, and safety of Spora Health, our users, the public, or others.
  • We share personal information with our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests.
  • We may share personal information in connection with, or during negotiations concerning, any merger, sale of company assets, financing, or acquisition of all or a portion of our business by another company.
  • Personal information is shared between and among Spora Health and our current and future parents, affiliates, and subsidiaries and other companies under common control and ownership.
  • We share personal information with your consent or at your direction.


ADVERTISING AND ANALYTICS

We allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Spora Health and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity. For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

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TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Spora Health is headquartered in the United States, and we have operations and service providers in the United States. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide levels of data protection that are equivalent to those of your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.


YOUR CHOICES

Account Information

You may update and correct certain account information, or delete your account, at any time by logging into your account, emailing us at support@sporahealth.com, or using the site’s online chat feature. If you wish to delete your account, please note that we may retain certain information as required by law or for our legitimate business purposes.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually adjust your browser settings to remove or reject browser cookies. Please note that removing or rejecting cookies could affect the availability and functionality of our Services.

Communications Preferences

You may opt out of receiving promotional emails from Spora Health by following the instructions in those communications, by emailing support@sporahealth.com, or by managing your communication preferences in your account settings menu. If you opt out, we may still send you non-promotional emails, such as those about your account or our ongoing business relations.

YOUR CALIFORNIA PRIVACY RIGHTS

The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq.) affords consumers residing in California certain rights with respect to their personal information. If you are a California resident, this section applies to you.


In the preceding 12 months, we have collected the following categories of personal information: identifiers (such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, or other similar identifiers), personal information described in Cal. Civ. Code §1798.80 (including health insurance information, medical information, and credit or debit card information), characteristics of protected classifications under California or federal law, commercial information (including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies), Internet or other electronic network activity information (including browsing history, search history, and information regarding your interaction with the Service), and inferences drawn from any of the information identified in this subdivision to create a profile about you reflecting your health preferences, characteristics, and predispositions.


For details about the precise data points we collect and the categories of sources of such collection, please see the Collection of Information section above. We collect personal information for the business and commercial purposes described in the Use of Information section above. In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:


Category of Personal Information

Categories of Recipients

Identifiers

Medical providers, health insurers, vendors, service providers, professional consultants, and (when necessary to protect the rights, property, and safety of Spora Health or the public) government entities.

Personal information described in Cal. Civ. Code §1798.80

Medical providers, health insurers, vendors, service providers, consultants, and (when necessary to protect the rights, property, and safety of Spora Health or the public) government entities.

Characteristics of protected classifications under California or federal law

Medical providers, health insurers, vendors, service providers, and professional consultants

Commercial information

Medical providers, health insurers, vendors, service providers, and professional consultants

Internet or other electronic network activity information

Vendors, service providers, and professional consultants

Inferences

Medical providers, health insurers, vendors, service providers, and professional consultants


Spora Health does not sell your personal information.


Subject to certain limitations, you have the right to (1) request to know more about the categories and specific pieces of personal information we collect, use, and disclose, (2) request deletion of your personal information, (3) opt out of any “sales” of your personal information that may be occurring, and (4) not be discriminated against for exercising these rights. You may make these requests by calling +1(650) 479-4665 or by emailing support@sporahealth.com. We will verify your request by asking you to provide information related to your recent interactions with us, such as your email address, full name, and/or credit card information. We will not discriminate against you if you exercise your rights under the CCPA.

If we receive your request from an authorized agent, we may ask for evidence that you have provided such agent with a power of attorney or that the agent otherwise has valid written authority to submit requests to exercise rights on your behalf. If you are an authorized agent seeking to make a request, please contact us.


CONTACT US

If you have any questions about this Privacy Policy, please contact us at support@sporahealth.com.