Platform Privacy Policy
Last modified: September 11, 2020
IMPORTANT NOTE – Our Notice of Privacy Practices is a separate document that governs how medical information about you may be used and disclosed in connection with the Health Care Services in accordance with the Health Insurance Portability and Accountability Act (“HIPAA”). This Privacy Policy does not cover personal health information submitted by you in the course of using our Service. Any conflict between this Privacy Policy and the HIPAA Policy with respect to such submitted personal health information shall be resolved in favor of the HIPAA Policy.
You are interacting with content from multiple companies that are portfolio companies of Aspire Ventures, LLC. This Privacy Policy applies to Aspire Ventures, LLC and its portfolio companies, including Connexion Health, LLC, MedStatix, Inc., Wylei, Inc., Daibetter, LLC, Clio Health Go, LLC, Aspire Ventures LLC d/b/a Clio Health, Powch, LLC, Appmobi, Inc., Fusionetics Plus, LLC, Nanodyne labs, LLC, Sweetmotion, Vita Vista and Smart Health Innovation Lab, LLC. All contact regarding this Policy and/or a portfolio company should be directed to Todd R. Bartos, J.D., General Counsel and Corporate Secretary, Aspire Ventures, LLC (todd@aspirevc.com; 717-925-8040).
Introduction
Aspire Ventures, LLC and its affiliates (each and collectively referred to as “Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy.
This policy describes the types of information we may collect from you or that you may provide when you visit the website www.aspirevc.com or use any website or app owned or managed by Company (collectively our “Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
On this Platform.
In email, text, and other electronic messages between you and this Platform.
Through mobile and desktop applications you download from this Platform or an app store, which provide dedicated non-browser-based interaction between you and Company and/or this Platform.
When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or
Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Platform.
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using this Platform, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Platform after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Children Under the Age of 13
The Children’s Online Privacy Protection Act of 1998 and its rules (collectively, “COPPA”) require us to inform parents and legal guardians (as used in this section, “parents“) about our practices for collecting, using, and disclosing personal information from children under the age of 13 (“children“). It also requires us to obtain verifiable consent from a child’s parent for certain collection, use, and disclosure of the child’s personal information.
This section notifies parents of:
The types of information we may collect from children.
How we use the information we collect.
Our practices for disclosing that information.
Our practices for notifying and obtaining parents’ consent when we collect personal information from children, including how a parent may revoke consent.
All operators that collect or maintain information from children through this Website/Service/App.
This section only applies to children under the age of 13 and supplements the other provisions of this privacy policy. Only the other provisions of this privacy policy applies to teens and adults.
Information We Collect from Children
Children can access many parts of the Website/App/Service and its content and use many of its features without providing us with personal information. However, some content and features are available only to registered users or require us to collect certain information, including personal information, from them. In addition, we use certain technologies, such as cookies, to automatically collect information from our users (including children) when they visit or use the Website/App/Service.
We only collect as much information about a child as is reasonably necessary for the child to participate in an activity, and we do not condition his or her participation on the disclosure of more personal information than is reasonably necessary.
Information We Collect Directly. A child must provide us with the following information to register with this website: the child’s name and email address and a parent’s email address. We also require the child to create a member name and password. We may request additional information from your child, but this information is optional. We specify whether information is required or optional when we request it.
We may enable registered users to communicate with others on or through this Website/Service through chat, email, and posting to public areas of the Site/Service (“Social Features“). The nature of these features allows children to disclose personal information about themselves. We do not monitor or review this content before it is posted, and we do not control the actions of third parties with whom your child shares his or her information. We encourage parents to educate their children about safe internet use and to monitor their children’s use of social features.
Automatic Information Collection and Tracking. We use technology to automatically collect information from our users, including children, when they access and navigate through the Website/App/Service and use certain of its features. The information we collect through these technologies may include:
One or more persistent identifiers that can be used to recognize a user over time and across different websites and online services
Information that identifies a device’s location (geolocation information).
We also may combine non-personal information we collect through these technologies with personal information about you or your child that we collect online.
For information about our automatic information collection practices, including how you can opt out of certain information collection, see the “Automatic Information Collection and Tracking” and “Choices About How We Use and Disclose Your Information” sections of our general Privacy Policy.
How We Use Your Child’s Information
We use the personal information we collect from your child to:
register him or her with the Site/Service;
communicate with him or her about activities or features of the Website/App/Service that may be of interest;
track his or her input;
track compliance with app functionality.
We use the information we collect automatically through technology (see Automatic Information Collection and Tracking) and other non-personal information we collect to improve our Website/App/Service and to deliver a better and more personalized experience by enabling us to:
Estimate our audience size and usage patterns.
Store information about the child’s preferences, allowing us to customize the content according to individual interests.
Speed up your searches.
Our Practices for Disclosing Children’s Information
We do not share, sell, rent, or transfer children’s personal information other than as described in this section.
We may disclose aggregated information about many of our users , and information that does not identify any individual or device. In addition, we may disclose children’s personal information:
To third parties we use to support the internal operations of our Website/App/Service and who are bound by contractual or other obligations to use the information only for such purpose and to keep the information confidential.
If we are required to do so by law or legal process, such as to comply with any court order or subpoena or to respond to any government or regulatory request.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Us, our customers or others, including to:
protect the safety of a child;
protect the safety and security of the Website/App/Service; or
enable us to take precautions against liability.
To law enforcement agencies or for an investigation related to public safety.
Accessing and Correcting Your Child’s Personal Information
At any time, you may review the child’s personal information maintained by us, require us to correct or delete the personal information, and/or refuse to permit us from further collecting or using the child’s information.
You can review, change, or delete your child’s personal information by:
Logging into your child’s account and visiting his or her account profile page.
Sending us an email at privacy@aspirevc.com. To protect your privacy and security, we may require you to take certain steps or provide additional information to verify your identity before we provide any information or make corrections.
Information We Collect About You and How We Collect It
We collect several types of information from and about users of our Platform, including information:
By which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, or any other identifier by which you may be contacted online or offline (“personal information”);
That is about you but individually does not identify you; and/or
About your internet connection, the equipment you use to access our Platform, and usage details.
We collect this information:
Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and web beacons.
From third parties, for example, our business partners.
Information You Provide to Us.
The information we collect on or through our Platform may include:
Information that you provide by filling in forms on our Platform. This includes information provided at the time of registering to use our Platform, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you report a problem with our Platform.
Personal Identifiable Information, by which you may be personally identified, such as name, e-mail address, telephone number, country, or any other information collection on the Platform that is defined as personal data or personally identifiable information under an applicable law (“personal information”). Company may also store personal information about your medical condition, treatment options, physician referrals, prescriptions, and lab results, including protected health information (“PHI”) or other related health information.
Non-Personal Information: In order to provide our Services to you and improve your Company experience, we may also collect non-personal information such as mobile device IDs, internet protocol (“IP”) addresses, web browser information, referring page URLs, and data related to your interactions with our App and Website.
Health and Medical Information: To be able to fill and dispense your medications, we also collect some medical information from you, your doctor, and your other pharmacies. Medical information collected includes things like your physician’s name and address, insurance information, prescription information, non-prescription drug information, medical diagnostics, and medical history. The collection and use of your health information is addressed in our HIPAA Policy and our Notice of Privacy Practices.
Records and copies of your correspondence (including email addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through our Platform and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Platform.
Your search queries on the Platform.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Platform, or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies.
As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
Details of your visits to our Platform, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Click here for information on how you can opt out of behavioral tracking on this website and how we respond to web browser signals and other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to:
Estimate our customer base size and usage patterns.
Store information about your preferences, allowing us to customize our Platform according to your individual interests.
Speed up your experience.
Recognize you when you return to our Platform.
The technologies we use for this automatic data collection may include:
Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
Flash Cookies. Certain features of our Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Web Beacons.Pages of our Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Third-Party Use of Cookies and Other Tracking Technologies
Some content or applications, including advertisements, on the Platform may be served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
To present our Platform and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
To provide you with notices about your account, including expiration and renewal notices.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to our Platform or any products or services we offer or provide though it.
To communicate with you through our app, text messages, emails, and in certain situations by phone call. It is important for us to be able to contact you in order to keep you updated on any issues with your prescription, your doctor’s instructions, or your insurance.
Notifications related to prescription and order status, delivery confirmations, security alerts, updates, new services, and other administrative messages.
To allow you to participate in interactive features on our Platform.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form). For more information, see Choices About How We Use and Disclose Your Information.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
We may disclose personal information that we collect or you provide as described in this privacy policy:
To our subsidiaries and affiliates.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Aspire Ventures, LLC’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Aspire Ventures, LLC about our Platform users is among the assets transferred.
To third parties to market their products or services to you if you have consented to these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them. For more information, see Choices About How We Use and Disclose Your Information.
To fulfill the purpose for which you provide it. For example, if you give us an email address to use the “email ” feature of our Platform, we will transmit the contents of that email and your email address to the recipients.
To health care providers (i) to schedule and fulfill appointments and provide health care services as part of the Services, (ii) to whom you send messages through our Services, and (iii) for other treatment, payment or health care operations purposes, including pharmacy services, upon your request.
To health care organizations, pharmacies, contractors, service providers, and other third parties we use to support our business or in connection with the administration and support of the Services.
For any other purpose disclosed by us when you provide the information.
With your consent.
We may also disclose your personal information:
To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Aspire Ventures, LLC, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt out by checking the relevant box located on the form on which we collect your data (the registration form). You can also always opt out by logging into the Platform and adjusting your user preferences in your account profile, by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@aspirevc.com.
Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties’ products or services, you can opt out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by logging into the Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@aspirevc.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a product purchase, warranty registration, product service experience, or other transactions.
Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt out by checking the relevant box located on the form on which we collect your data (the registration form) or at any other time by logging into the Platform and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@aspirevc.com.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website..
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: privacy@aspirevc.com. However, please know we do not currently sell data triggering that statute’s opt-out requirements.
Accessing and Correcting Your Information
You can review and change your personal information by logging into the Platform and visiting your account profile page..
You may also send us an email at privacy@aspirevc.com to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the Platform, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform, including User Contributions, is governed by our terms of use.
California residents may have additional personal information rights and choices. Please see Your California Privacy Rights for more information.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California Privacy Rights, visit the CCPA privacy notice for California Residents.
California’s “shine the Light” law (Civil Code Section § 1798.83) permits users of our App that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@aspirevc.com or write us at: c/o Aspire Ventures, LLC, 100 N. Queen Street, Ste 300, Lancaster PA 17603.
Data Security
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any payment transactions and User Information will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards. The information you share in public areas may be viewed by any user of the Platform.
Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Platform home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Platform home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and this privacy policy to check for any changes.
Contact Information
To ask questions or comment about this privacy policy and our privacy practices, contact us at privacy@aspirevc.com. To register a complaint or concern, please contact us at privacy@aspirevc.com.