INTRODUCTION
This privacy policy has been compiled to better serve those who are concerned with how their ‘Personally identifiable information’ (PII) is being used online. PII, as used in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your Personally Identifiable Information in accordance with our website.
Pillo, Inc. (“Pillo” or “Pillo Health”) collects personal information from users of our website at pillohealth.com (the “Site”). Pillo takes security seriously and we care about the integrity of your personal information. Pillo is committed to protecting consumer privacy by informing you what information we collect, how we use it and with whom we may share it. We respect user privacy and intend to openly share how we collect and use data. They types of information Pillo collects from visitors to our website and what Pillo does with that information is outlined in this Privacy Notice.
In general, this information is used to provide our users and customers with the best service possible; allows us to understand how visitors navigate and use our Site; and is used by us to continually improve our services and the functionality of the Site. By visiting the Site and using our services, you agree that your personal information will be handled as described in this Privacy Notice. Your use of our Site and services, and any dispute over privacy, is subject to this Privacy Notice.
INFORMATION WE COLLECT ABOUT YOU
We collect two categories of information about you. First, we collect the personal information that you may supply to us during your use of the Site and our services. Second, we collect certain technical information automatically, to enhance the functionality and responsiveness of the Site, and to provide you with a more enjoyable user experience.
Information We Collect Directly From You
The type of information that we collect from you depends on your interaction with our Site and our services, but may include the following:
· Mailing list information. You may choose to submit your email address via a submission form located on our Site. Your email address may be used to send you news about Pillo, including promotions. We may use one or more third party service providers to administer these messages, with whom we will share this data. However, Pillo does not share your email address with spammers or any other non-affiliated third parties for their own marketing purposes without your permission. If you feel you have received an email from us in error, please contact hello@pillohealth.com.
Information We Collect Automatically/Website Use Information
We may automatically collect the following information about your use of our Site or services through cookies, web beacons and other technologies: (i) your domain name; (ii) your browser type and operating system; (iii) web pages you visit; (iv) links you click; (v) your IP address; (vi) the length of time you visit our Site and or use our services; and (vii) the referring URL, or the webpage that led you to our Site. Please see the section “Cookies And Other Tracking Mechanisms” for more information.
CHILDREN’S PRIVACY
Our Site is designed for the use of adults 18 years old and older. We will not knowingly collect, store or use any personal information about children under the age of 13. If we become aware that we have collected any personal information from children under 13 years old, we will promptly delete such information from our databases.
HOW WE — USE YOUR INFORMATION
We use your information for the following purposes:
· To provide our services to you; to communicate with you about your use of our services; to respond to your inquiries; to fulfill your orders; and for other customer service purposes.
· To tailor the content and information that we may send or display to you; to offer location customization; to provide personalized help and instructions; and to otherwise personalize and enhance your experiences while using the Site or our services.
· For our marketing and promotional purposes. For example, we may use your information, such as your email address, to send you news and newsletters, special offers, promotions or to otherwise contact you about our products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services on third party websites.
· To better understand how users access and use our Site and services, both on an aggregated and individualized basis, for the purpose of improving our Site and services and responding to user desires and preferences, and for other research and analytical purposes.
HOW WE SHARE YOUR INFORMATION
We do not sell your personal information to third parties for their own marketing purposes. We will share your information, including your personal information, with third parties to assist us in providing our services to you and for certain legal purposes. Specifically, we may share your information as follows:
· Business affiliates. We may disclose the information we collect from you to our business affiliates. However, if we do so, their use and disclosure of your personal information will be subject to the policies and limitations contained in this Privacy Notice.
· Service providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf, for example, with vendors that help us with delivering products or services to you; vendors that help us maintain and upgrade our Site; vendors that assist us with customer support; and vendors that assist us with analytics and marketing. Again, these third party vendors’ use and disclosure your personal information will be subject to the policies and limitations contained in this Privacy Notice.
· Business transfers. If we are acquired by or merged with another company, or if substantially all of our assets are transferred to another company, we may transfer the information we have collected from you to the other company.
· In response to legal process. We also may disclose the information we collect from you in order to comply with the law, judicial proceedings, court orders, or other legal process, such as in response to a subpoena.
· To protect us and others. We also may disclose the information we collect from you where we believe it is necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of this Privacy Notice, or as evidence in litigation or other legal proceedings in which we are involved.
· Aggregate and de-identified information. Aggregate and de-identified information is information that we may have collected from you, but which has been anonymized so that it can no longer be connected with a specific individual. We may share such aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.
OUR — USE OF COOKIES AND OTHER TRACKING MECHANISMS
Cookies
We use cookies and other tracking mechanisms to track information about your use of our Site or services. We may combine this information with other personal information we collect from you. Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and service. Most internet browsers allow you to disable cookies, or to delete cookies; while this is your choice, this may reduce the functionality and usability of the Site. The two types of cookies are session cookies and persistent cookies.
Session Cookies
Session cookies exist only during an online session. They disappear from your computer when you close your browser or turn off your computer. We use session cookies to allow our systems to uniquely identify you during a session or while you are logged into the Site. This allows us to process your online transactions and requests and verify your identity, after you have logged in, as you move through our Site. Session cookies are often used in the “Shopping Cart” function of websites.
Persistent Cookies
Persistent cookies remain on your computer after you have closed your browser or turned off your computer. We use persistent cookies to track aggregate and statistical information about user activity.
Third Party Cookies
We use third-party vendors, including Google, and use cookies such as the Google Analytics cookies and other third-party cookies, such as DoubleClick cookies, together to report how ad impressions, other uses of ad services, and interactions with these ad impressions and ad services relate to visits to our Site, and to otherwise analyze the effectiveness of ads and ad services.
Accepting Or Disabling Cookies
Most web browsers automatically accept cookies. If you prefer, you can edit your browser options to block cookies in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies; how to have the browser notify you when you receive a new cookie; how to disable cookies altogether; and how to delete existing cookies. Users of our Site who disable cookies will be able to browse certain areas of the Site, but are advised that without cookies enabled, some features of the Site may not function properly or at all.
Local Storage Objects
We may use Flash Local Storage Objects (“Flash LSOs”) to store your Site preferences and to personalize your visit. Flash LSOs are different from browser cookies because of the amount and type of data stored. Typically, you cannot control, delete or disable the acceptance of Flash LSOs through your web browser. For more information on Flash LSOs, or to learn how to manage your settings for Flash LSOs, go to the Adobe Flash Player Help Page; choose “Global Storage Settings Panel”; and follow the instructions. To see the Flash LSOs currently on your computer, choose “Website Storage Settings Panel” and follow the instructions to review and, if you choose, to delete any specific Flash LSO.
Clear GIFs, Pixel Tags And Other Technologies
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (sometimes referred to as web beacons, web bugs or pixel tags) in connection with our Site to, among other things, track the activities of Site visitors; help us manage content; and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed and track whether our emails are forwarded.
Third Party Analytics And Tracking
Like many websites, we use tools (including, but not limited to, Google Analytics, Optimizely, Crazyegg and Qualaroo) to collect information from visitors in order to better understand how they use our Site. Such information may include, for example, browser type, domains and page views. We use these tools to help us improve our services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. Please visit their sites to learn more about the technologies used; the respective terms and privacy policies of these entities; and your options to opt-out of their services (if applicable). We do not share your personal information with these third parties. In addition, in some of our email messages, we use a “click-through URL” linked to content on the Site. We track this click-through data to help us measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. We currently do not honor “Do Not Track” browser requests. Through third parties, however, you do have the option not to be tracked for purposes of advertising. Please see the section regarding “Third Party Ad Networks And Opt Out Options” below for additional information.
Third Party Ad Networks & Opt Out Options
We use third parties such as network advertisers including, but not limited to, Google’s Display Network to display advertisements on other websites. Through a process called retargeting, also known as “remarketing,” network advertisers place a cookie on your browser that allows us to show you ads on other website you visit based on your previous activities on our Site.
Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third party cookies and other technologies are governed by each third party’s specific privacy policy, not this Privacy Notice. We may provide these third-party advertisers with information about your usage of our Site and our services, as well as aggregate or non-personally identifiable information about visitors to our Site and users of our service. Our third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize and serve ads based on someone’s past visits to our Site. We also use Google Analytics Demographics and Interest Reporting to tailor advertisements relevant to you based on demographic information such as age, gender and interests.
You may, however, opt out of many third-party ad networks, including those operated by members of the Network Advertising Initiative (“NAI”) and the Digital Advertising Alliance (“DAA”). For more information regarding this practice by NAI and DAA members, and your choices regarding having your information used by these companies, including how to opt out of third-party ad networks operated by NAI and DAA members, please visit their respective websites, located at www.networkadvertising.org/optout_nonppii.asp (for the NAI) and at www.aboutads.info/choices (for the DAA).
Opting out of one or more NAI member or DAA member networks (many of which will be the same) only means that those members no longer will deliver targeted content or ads to you. It does not mean you will no longer receive any targeted content or ads while using our Site or other websites. You may continue to receive advertisements, for example, based on the particular website that you are viewing. Also, if your browser is configured to reject cookies when you visit this opt out page, or you subsequently erase your cookies, use a different computer or change web browsers, your NAI or DAA opt out choice may no longer be effective. Additional information is available on the NAI and DAA websites accessible by the above links.
Additionally, we use the Google Analytics features for Display Advertising, including Remarketing, Google Display Network Impression Reporting, the DoubleClick Campaign Manager integration and Google Analytics Demographics and Interest Reporting. Using the Ads Settings, you can opt out of Google Analytics for Display Advertising and customize Google Display Network ads. You can also install the Google Analytics opt out add-on to your browser to prevent your data from being collected by Google Analytics.
— USER GENERATED CONTENT
We invite you to post content on our Site, including your comments, pictures and any other information that you would like to be available on our Site. If you post content to our Site, all of the information that you post will be available to all visitors to our Site and will be subject to our website Terms of Service. If you post your own content on our Site, your posting may become public and we cannot prevent such information from being used in a manner that may violate this Privacy Notice, the law or your personal privacy.
THIRD PARTY LINKS, WEBSITES AND FEATURES
Our Site and Services may contain links to third party websites as well as social media features such as Facebook and Twitter. Any access to and use of such linked websites is not governed by this Privacy Notice, but instead is governed by the privacy policies of those third party websites. We do not control what information these websites collect.
INTERNATIONAL VISITORS
The Site is hosted in the United States. If you are accessing the site from the European Union or other regions with laws governing data collection and use that may differ from United States law, then please note that you are transferring your personal data to the United States and by providing your personal data you consent to that transfer, as well as to the uses of your personal data as described in this Privacy Notice.
WHAT CHOICES DO I HAVE REGARDING — USE OF MY PERSONAL INFORMATION?
We may send periodic promotional or informational emails to you. You may opt out of such communications by following the opt out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt out requests. If you opt out of receiving emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
SECURITY
To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed. Please note that no method of transmission over the internet or electronic storage is 100% secure. We recommend that you also take steps to prevent loss or unauthorized access to your personal data, such as signing off after using a shared computer, and keeping any log-in information and password private. We are not responsible for any lost, stolen or compromised passwords, or for any activity on your account via unauthorized password activity.
CONTACT US
If you have any questions about this Privacy Notice or would like to remove your information from our marketing lists, you may contact us at: hello@pillohealth.com, or by mail directed to:
Pillo, Inc.
150 West 56th Street, Suite 6102
New York, NY, 10019
CHANGES TO THIS PRIVACY NOTICE
This Privacy Notice is current as of the date set forth below. If we make any changes that materially affect our practices with regard to the use and handling of personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change by highlighting the change on our Site. You are encouraged to check this Privacy Notice frequently for any changes or updates.
Last Updated: May 26, 2016
HIPAA Notice
PERSONAL HEALTH INFORMATION NOTICE
Your Information. Your Rights. Our Responsibilities.
Personal health information is defined as any individually identifiable health information that is transmitted or maintained in any form or medium that identifies the individual or offers a reasonable basis to identify the individual, that relates to a past, present or future physical or mental condition, provision of healthcare or payment for healthcare provided to that individual. Some of the personal information you may provide to us by using our website and our services may be personal health information. This Notice describes how personal health information about you may be used and disclosed and how you can get access to this information. Please review this Notice carefully.
Your Rights
When it comes to your personal health information, you have certain rights. This section explains your rights and some of our responsibilities to help you.
• You can ask to see or get a copy of the personal health information we have about you. We will provide a copy or a summary of this information, usually within 30 days of your request. We may charge a reasonable, cost-based fee for doing so.
• You can ask us to correct personal health information we have about you if you think such information is incorrect or incomplete. We may say “no” to your request, but we will tell you why in writing within 60 days.
• You can ask us not to use or share certain health information for provision of services, payment or our business operations. We are not required to agree to your request, and we may say “no” if, in our discretion, such a request would unreasonably or negatively impact on any of the foregoing.
• You can ask for a list of the times we’ve shared your personal health information for six years prior to the date you ask, who we shared it with, and why. We may charge a reasonable, cost-based fee for providing you this information.
Our Uses And Disclosures Of Your Personal Health Information.
Unless you give us your written permission, we never share your personal health information for marketing purposes, or otherwise sell your personal health information. We typically use or share your health information in the following ways.
• To provided services to you.
• In connection with payment for those services.
• To run our organization and contact you when necessary.
How Else Can We Use Or Share Your Personal Health Information?
We are allowed or required to share your information in other ways—typically, in ways that contribute to the public good, such as public health and research. These include:
• Preventing disease.
• Helping with product recalls.
• Reporting adverse reactions to medications.
• Reporting suspected abuse, neglect or domestic violence.
• Preventing or reducing a serious threat to anyone’s health or safety.
• For health research.
• In connection with legal proceedings and process, such as subpoenas.
In any such use and disclosures, we comply with state and federal law requirements. For additional information, you can visit the website of the Department of Health and Human Services at http://www.hhs.gov, which provides consumers with information regarding their privacy rights pertaining to personal health information. This government website also has information about federal laws such as the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), which may provide privacy and security protections with respect to your personal health information, and a mechanism through which you can file a complaint if you feel that your rights have been violated.
Our Responsibilities
• We are required by law to maintain the privacy and security of your personal health information.
• We will let you know promptly if a breach occurs that may have compromised the privacy or security of your personal information.
• We must follow the duties and privacy practices described in this Notice.
• We will not use or share your personal information other than as described here, or as may be allowed or required by existing law, unless you tell us we can in writing. If you tell us we can, you may change your mind at any time. Let us know in writing if you change your mind.
Changes To This Notice
From time to time, we may change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be available on our website, and you are encouraged to check this Notice frequently for updates.
Effective Date Of This Notice: May 26, 2016.
Contacting Us With Any Questions Or Complaints
If you have any questions about this Notice, any request regarding our handling of your personal information or if you feel we have made an error or done something wrong and would like to submit a complaint, you may contact us at: hello@pillohealth.com, or by mail directed to:
Pillo, Inc.
150 West 56th Street, Suite 6102
New York, NY, 10019