Privacy Policy

1. Corporate Commitment to Privacy

Remmy Health Inc. (“Remmy, Remmy Health”, “we”, “us” or “our”) is committed to protecting your privacy and creating a safe and secure environment for our users. This Privacy Policy describes how we collect, use, disclose, store and otherwise process information throughremmyhealth.com and through the products and/or services provided by or through Remmy Health Inc. (collectively “Services”). In addition, this policy states how you can control the collection, correction and/or deletion of information. We will not use or share your information with anyone except as described in this Privacy Policy.

2. Scope

This Privacy Policy applies to personal information and other information collected by Remmy Health Inc. or its service providers from or about:

1. visitors to, or users of, its websites or mobile applications;
2. current customers using the Services pursuant to a written agreement with Remmy;
3. prospective and current customers using the Services pursuant to a clickwrap, browserwrap, or other online agreement;
4. service providers and business partners;
5. other third-parties that use the Services, including without limitation including without limitation the end users of prospective and current customers.

3. Personal Information

Definition of Personal Information

Personal information refers to any information relating to an identified or identifiable natural person, such as an identification number, physical, physiological, mental, economic, cultural, or social identifiers.

Definition of Personal Information (Special Categories of Information)

Special categories of personal data refers to genetic and biometric data which can identify a unique individual. Under GDPR, these categories require additional privacy protections.

4. Definition of Non-Personal Information

We may also collect information that is related to you but that does not personally identify you (“Non-personal Information”). Non-personal Information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) in order to remove or hide any Personal Information.

5. Consent

Remmy collects personal information about you in connection with many of our services. When working or using our company, you may be prompted to make an account which may hold personal information such as your name, email address, or credit card information. Prior to collecting this information, Remmy will obtain your consent. At any point in time, you can revoke consent and we will cease using and processing your data.

6. Information Collected Automatically

Remmy may also collect Technical Information about you when you visit our websites, which your web browser automatically sends whenever you visit a website on the Internet. “Technical Information” is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. Our servers automatically record this information, which may include your Internet Protocol (“IP”) address, browser type, browser language, and the date and time of your request. Gathering your information helps us ensure our websites and other services work correctly and support out customer analytic efforts. When you use our mobile application, we collect your device type, your device ID, and your IP address.

Email communication

We may use pixel tags and cookies in our marketing emails so that we can track your interaction with those messages, such as when you open the email or click a URL link that’s embedded within them. When recipients click on one of those URLs, they pass through a separate web server before arriving at the destination page on a company website. We use tools like pixel tags and cookies so that we can determine interest in particular topics and measure and improve the effectiveness of our communications.

Mobile communication

When you download or use our mobile-device applications, or access one of our mobile-optimized websites, we may receive information about your mobile device, including a unique identifier for your device.

Cookies and Similar Technologies

We may collect information about your use of the websites through cookies and similar technology. A “cookie” is a unique numeric code that we transfer to your computer so that we can keep track of your interests and/or preferences and recognize you as a return visitor to the websites. For example, we may use these technologies to collect information about the ways visitors use our websites, to support the features and functionality of our websites, and to personalize your experience when you use our websites.

7. Information Collected from Other Sources

Remmy may also collect information about you from other sources to help us correct or supplement our records, improve the quality or personalization of our service to you, and prevent or detect fraud. We work closely with third parties (for example, business partners, service providers, sub-contractors, advertising networks, analytics providers, search information providers, fraud protection services) and may receive information about you from them. The following are some examples:

Third-Party Vendors

In order to provide the services and improve Remmy’s websites, we may engage the services of third-party vendors. In the process of supplying services to Remmy, these third-party vendors may need to collect Personal Information about you.

Log Files

Log files record website activity on our services and enable us to gather statistics about our users’ browsing habits. These entries help Remmy determine (among other things) how many and how often users have accessed or used our services, which pages they’ve visited, and other similar data.

Clear GIFs

Clear GIFs, sometimes called “web bugs” or “web beacons,” are small electronic images that are placed on a web page or in an email message. We use clear GIFs to monitor user behavior, deliver cookies, collect information, count visits, understand usage and campaign effectiveness, and to tell if a recipient has opened and acted upon an email.

8. Permitted Use of Personal Information

Remmy uses your personal information to provide you products and services, such as to fulfill your requests for products or to help us personalize our offerings to you. We also use your personal information to support our business functions, marketing, and legal functions. To do this, we combine personal and non-personal information, collected online and offline, including information from third party sources. The following are some examples:

Fulfill Requests

To fulfill your requests for products and services and communicate with you about those requests;

Understand Customer Behavior

To better understand customer behavior so that we may improve our marketing and advertising efforts and to improve the distribution of our products and services;

Personalize Offerings

To help us personalize our service offerings, websites, mobile services, and advertising;

Legal

To comply with legal and/or regulatory requirements;

Responding to Customer

To respond to reviews, comments, or other feedback you provide us;

Industry Benchmarking

For industry benchmarking and analysis consistent with our legitimate business purpose;

9. Promotional Messaging or Advertising

Remmy uses your contact information to recommend products and services that might be of interest to you, to send you marketing and advertising messages such as newsletters, announcements, or special offers or to notify you about our upcoming events.

10. Disclosure of Categories of Personal Information

The California Consumer Privacy Act (CCPA) requires us to disclose categories of personal information we collect and how we use it, the categories of sources from whom we collect personal information, and the third parties with whom we share it, which we have explained above.

We collect the following categories of personal information and in the preceding twelve months, we have disclosed these categories of personal information for a business purpose to affiliates, service providers and third parties:

• Identifiers such as your name, username, email address, phone number, unique device identifiers, your IP address
• Personal information categories described in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) such as signature, insurance policy number and health insurance information
• Personal characteristics protected by law, such as your gender and age
• Commercial information, such as purchases made and payment information
• Internet or electronic network activity information, such as information about your device and your use of our Services
• Geo-location data, when shared through your device settings or photos
• Electronic, visual, or similar information, such as photos
• Professional or employment information, when you link your account to other accounts
• Education information
• Inferences we draw or derive about users, such as your interests or preferences
• Other information you provide, such as your profile picture, bio, pins, and comments

We use and disclose this information for the business purposes described in this Privacy Policy, including: provision of Services, detect security incidents and prevent fraud, debug and repair errors, maintain your account, provide customer service, process or fulfill orders, conduct research and development and other activities to improve our service, show advertising, market our services, and understand how users interact with our services.

11. Disclosure of Personal Information for Legal and Safety Reasons

Remmy may be required to disclose personal information to the authorities, law enforcement agencies, government agencies, or legal entities. We may disclose information by law, litigation, or as a matter of national security to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law. We may also need to disclose personal information in the event of an emergency that threatens an individual’s life, health, or security.

12. Disclosure of Personal Information Via Links to Third-Party Websites, Services, and Applications

Using our website or services may link to third party web websites, services, and applications. Remmy is not responsible for any personal information collected through these means. Information collected is governed through the third party’s website’s Privacy Policy. Any interactions you have with these web websites, services, or applications are beyond the control of Remmy. When you post information to or through such services, those websites’ privacy policies and cookie usage policies apply directly. We urge you to read the privacy and security policies of any external websites before providing any personal information while accessing those websites.

13. Use of Cookies and Other Technologies (e.g. Web Beacons)

Remmy uses cookies to operate and improve our website as well as to simplify the interaction with you. When you visit our websites, our servers send a cookie to your computer or mobile device to help personalize your experience and advertisements. Cookies help us better understand user behavior and facilitate effectiveness of advertisements. Cookies only stand to recognize your web browser but information collected from cookies is not personally identifiable. Remmy may also use web beacons or other technologies in conjunction with cookies to gather information about your visit to our websites. Web beacons may be embedded through our website or electronic communications and can allow servers to collect information related to your visit. Web beacons are primarily use to provide content and advertisements that are more relevant to you.

14. Ability to Disable Technologies

Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all features available through our services. For more information, visit the help page for your web browser or see http://www.allaboutcookies.org

15. Consequences of Disabling Technologies

Please note that if you disable your web browser’s cookies and other technologies, certain features of our website and services will be disabled and you will limit the functionality we can provide when you visit our site.

16. Security Measures Taken to Protect Personal Information by Remmy

Security of all information is of the utmost importance for Remmy. Remmy uses technical and physical safeguards to protect the security of your personal information from unauthorized disclosure. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. In the case of a data breach, we will notify you without delay of any loss, misuse or alteration of personal information that may affect you.

17. Choice: Your Privacy Rights

Remmy gives you choices about the ways we collect, use, and share your personal information. You can choose what contact information will be stored in your account and preferences. However, if you choose not to provide certain details, some of your experiences with us may be affected. If at any point in time you wish to know what data we process about you, you can request to access the information by emailing us at team@remmyhealth.com.

18. Collection of Information from Children

New Remedy does not direct any of our content specifically to children. Users of the Site are required to be at least 18 years old, and any user under 18 is not an authorized user. If we learn that a user is under thirteen (13) years of age, we will promptly delete any Personal Information we have collected about that user.

19. International Transfer of Personal Information

Remmy may share customer information within our family of companies for a variety of purposes, for example to provide you with the latest information about our products and services and offer you our latest promotions. To facilitate our global operations, Remmy may transfer personal data from your home country to other Remmy locations across the world.

20. California Privacy Rights

If you are a California resident, then under this Privacy Policy and pursuant to the California Consumer Privacy Act (CCPA), you have the following rights:

Right to Know and Access

You may submit a verifiable request for information regarding the: (1) categories of personal information we collect, use or share; (2) purposes for which categories of personal information are collected or used by us; (3) categories of sources from which we collect personal information; and (4) specific pieces of personal information we have collected about you. To make such a request, please email us at team@remmyhealth.com. In order to verify any request, you may need to log in to your account or respond to an email verification request.

Right to Delete

You also have the right to request the deletion of your personal data that have been collected in the past 12 months. To make such a request, please email us at team@remmyhealth.com. In order to verify any request, you may need to log in to your account or respond to an email verification request.

Do Not Sell My Personal Information

We do not sell personal information. However, the Service Providers we partner with (for example, our advertising partners) may use technology on the Service that “sells” personal information as defined by the CCPA law. If you wish to opt out of the use of your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by emailing us at team@remmyhealth.com.

Right to Equal Service

We will not discriminate against you if you exercise your privacy rights, including by: (1) denying goods or services to you; (2) charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties; (3) providing a different level or quality of goods or services to you; or (4) suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Exercising Your CCPA Data Protection Rights

To exercise any of your California Privacy Rights, please email us at team@remmyhealth.com. In order to verify any request, you may need to log in to your account or respond to an email verification request.

We will disclose and deliver the required information free of charge within 45 days of receiving your verifiable request. The time period to provide the required information may be extended once by an additional 45 days when reasonably necessary and with prior notice.

A list of the categories of personal information we collect and how we use that information is set forth in Section XIII of this Privacy Policy.

21. Europe Privacy Rights

If you are a resident of the European Union, then under this Privacy Policy and pursuant to the General Data Protection Regulation (GDPR), you have the following rights:

Right of Access

At any point in time, you can confirm your data is being processed and request to access your data. If you wish to access/confirm your data is being processed, please email us at team@remmyhealth.com.

Right to Consent

Before collecting and using your personal data, Remmy will obtain consent. At any point in time, you can revoke consent and Remmy will stop using and processing your personal data.

Right to Erasure

You have the right to request Remmy erases all of your personal data on a number of grounds, including if the data is no longer necessary for its original purpose or if you withdraw consent. If Remmy receives a request, we will inform all third parties who have the data of this request. For additional information on when you can request data erasure, please email us at team@remmyhealth.com.

Right to Rectification

If any personal data is inaccurate or incomplete, you can request Remmy corrects the data. When this occurs, Remmy will notify third parties who have access to the data of the change. If you wish to alter your data, please email us at team@remmyhealth.com.

Right to Restrict Processing

Even if personal data is still stored by a company, now or in the future, you can request Remmy stops using or processing your data. If you wish to restrict data processing, please email us at team@remmyhealth.com.

Right to Object

You have the right to object to your personal data being processed for profiling, direct marketing, scientific research, and statistics. If you wish to object, please contact us by visitingplease email us at team@remmyhealth.com.

Rights Related to Automatic Decision Making and Profiling

At any point in time, you can contact a Remmy representative to express your point of view, challenge an explanation of data use, or otherwise obtain further information on automatic data processing.

Right to Data Portability

You have the right to transfer your personal data from one electronic processing system to another without being prevented from doing so by Remmy’ data processor. Unless extended by Remmy request, within ninety (90) days, Remmy will respond to the request and provide you with the desired information for free in a structured and commonly used electronic format.

Exercising of Your GDPR Data Protection Rights

You may exercise your rights of access, rectification, cancellation and opposition by emailing us at team@remmyhealth.com. Please note that we may ask you to verify your identity before responding to such requests. If you make a request, we will try our best to respond to you as soon as possible.

You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, if you are in the European Economic Area (EEA), please contact your local data protection authority in the EEA.