Last Updated: June 14, 2022
This Privacy Notice applies to personal information we have that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual, household, or device (“personal information”). Personal information does not include information publicly available from government records. Personal information does not include information that is not personal, like anonymous, deidentified, or aggregated data (for example, summary statistics), even if it comes from personal information.
How We Collect Personal Information About You
We collect personal information about you in the following ways:
- Directly from you or your representatives, such as when you register for our services or to receive information from us (including registration through HM representatives, our website, or other contact forms) or when you communicate or interact with us in any way, including in-person, mail, email, phone, chat, QR code, or social media
- Indirectly from you, such as Wi-Fi connection and usage data
- From our corporate customers and partners, for example, our corporate customers and partners may provide information about individuals associated with them (employees, members)
- From other sources, such as trade associations and industry marketing lists
What Personal Information We Collect and Disclose
We collect and disclose to third parties, for our business purposes, the following categories of personal information:
- Identifiers, such as name, postal address, email address, and other similar identifiers
- Personal information (as defined in the California safeguards law), such as name, address, telephone number, and past and present employment information (some personal information included this category may overlap with other categories)
- Characteristics of protected persons, such as age, date of birth, and gender
- Commercial information, such as products or services purchased or considered
- Internet or other similar network activity, such as your Wi-Fi connection and usage data
- Professional or employment-related information, such as past and present employer, title, and professional contact information
- Sensitive personal information: complete account access credentials for your HM account, such as username and password
- Preference information, including preferences related to marketing, advertising, privacy, communications, and participation in HM programs
- Other information you choose to provide, like when you submit a customer service query, enter a contest or promotion, or contact us
- Inferences drawn from any of the personal information listed above; for example, to create a profile of an individual’s preferences and characteristics
How We Use Personal Information About You
We use or disclose the personal information we collect for one or more of the following business purposes:
- Perform services, including to provide advertising or marketing services, to provide customer service, to verify customer information, and to perform our contractual obligations
- Develop, customize, and improve products and services
- Respond to your inquiries and comments and conduct surveys
- Market and advertise products and services to you, including newsletters, promotions and events, and other marketing communications
- Comply with laws, regulations, and legal process (including to comply with any internal policy based on or reflecting legal or regulatory guidance, codes, or opinions), respond to requests from law enforcement and government authorities, protect or defend our rights or property, or act in urgent circumstances to protect the personal safety of users of our services or the public
- Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred
We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without providing you notice.
How We Share Personal Information About You
We may share your personal information by disclosing it to third parties for business purposes.
We may share any of the categories of personal information described in the section What Personal Information We Collect and Disclose with the following categories of third parties for our business purposes:
- Vendors and service providers who provide services such as information technology and infrastructure, data analysis, and marketing and marketing research activities
- Government authorities, law enforcement, or other persons in order to comply with legal obligations or protect or defend our rights or property
- Other third parties for uses described in this Privacy Notice or for purposes you have requested
We do not sell personal information, including personal information of minors under the age of 16. For purposes of this notice, “sell” means to the disclosure of personal information to a third party for money or other valuable consideration.
Deidentified and Aggregated Information
Anonymous, deidentified, or aggregated data is not personal information, even if it comes from personal information. We reserve the right to collect and use such anonymized, deidentified, or aggregated non-personal information for any reason in our sole discretion, including but not limited to performing statistical analysis of such information, or to share such information with third parties.
Deidentified Patient Information
We may disclose deidentified patient information to third parties for our business purposes as described in the sections How We Use Personal Information About You and How We Share Personal Information About You. We do not sell deidentified patient information. To deidentify patient information, we follow the HIPAA safe harbor method.
How We Protect Your Personal Information
We use administrative, technical, contractual, and physical safeguards designed to protect your personal information.
Despite our efforts to ensure security, we cannot guarantee or warrant that your personal information will not be accessed, acquired, disclosed for an improper purpose, altered, or destroyed by an unauthorized person or as a result of a breach of our security safeguards. We cannot ensure the security of any information transmitted to us over the internet, and to the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure of such information. Therefore, we urge you to take adequate precautions to protect your personal information as well.
Your Personal Information Rights and Choices
You have the right to:
- Request that we disclose certain information to you about our collection and use of your personal information (the “right to know“):
- The categories of personal information we collected about you
- The categories of sources for the personal information we collected about you
- Our business purpose(s) for collecting or sharing that personal information
- The categories of third parties with whom we shared your personal information, identifying the personal information categories that each category of recipient obtained and the purpose(s) for sharing your personal information
- The specific pieces of personal information we collected about you (also called a “data portability request”).
- Request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions under applicable privacy law (the “right to delete“).
- Direct us to not sell your personal information at any time (the “right to opt out of sale“). We do not sell personal information, including personal information of minors under the age of 16.
- Direct us to not share your personal information for cross-context behavioral advertising purposes or targeted advertising (the “right to opt out of targeted advertising”). “Targeted advertising” means the advertisement is selected based on personal information obtained from your activities over time and across nonaffiliated websites/applications to predict your preferences or interests. We do not share your personal information for cross-context behavioral advertising or targeted advertising.
- Direct us not to share your personal information for the purposes of profiling in furtherance of decisions that produce legal or similarly significant effects concerning you (the “right to opt out of profiling”). We do not share your personal information for profiling purposes.
- Limit the use or disclosure of your sensitive personal information to just those actions necessary to perform specific purposes outlined by law (the “right to limit use of sensitive information”). We only use or disclose sensitive personal information for purposes that would continue to be allowable after the receipt of a limitation request, including to provide services and ensure the security and integrity of your account.
- Correct inaccurate personal information (the “right to correct”).
- Be free from unlawful discrimination for exercising your rights under applicable privacy law.
How to Exercise Your Personal Information Rights and Choices
To exercise your rights as described above, please submit a request by either:
- Emailing us at email@example.com; or
- Calling us at (800) 422-4112
We will acknowledge receipt of your request and advise you how long we expect it will take to respond if we are able to verify your identity. We will work to process all verified requests within 45 days. If we need an extension for up to an additional 45 days in order to process your request, we will provide you with an explanation for the delay.
We may ask for information to verify your identity, such as name, contact information, or date of birth.
You may authorize an agent to make a request on your behalf by contacting us at the email or toll-free number listed above. As part of our verification process, we may require, as applicable:
- Information to verify the requestor’s identity, such as name, contact information, or date of birth (if the requestor is individual), or the requestor’s active registration with a state or governmental agency (if the requestor is a company or organization)
- information to verify the identity of the person on whose behalf such request is made, such as name, contact information, or date of birth
- a document to confirm that the requestor is authorized to make the request, such as a power of attorney; we may require proof of authorization and verification of identity directly from the person on whose behalf the request is made.
In some instances, we may not be able to honor your request. For example, we will not honor your request if we cannot verify your identity or if we cannot verify that you have the authority to make a request on behalf of another individual. Additionally, we will not honor your request where an exception applies, such as where the disclosure of personal information would adversely affect the rights and freedoms of another individual or where your personal information is not subject to applicable privacy law rights.
We will advise you in our response if we are not able to honor your request.
You have the right to appeal our decision to not honor your request or our refusal to take action on a request within a reasonable period of time by contacting us at the email or toll-free number listed above and clearly stating that the purpose of the contact is an “appeal of privacy rights.” Within 60 days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions.
Manage How We Communicate with You
We offer you choices about how to manage how we communicate with you.
- Email. You may opt out of receiving marketing emails from us at any time by sending an email to firstname.lastname@example.org or by clicking on the unsubscribe link in our emails. You will continue to receive service-related emails (e.g. order status).
- Direct Mail. To opt out of direct mail marketing, please send your request to email@example.com and include your postal address in the body of the email.
- Telephone Calls/Text Messages. To opt out of telephone and text message marketing, please send your request to firstname.lastname@example.org and include your phone number in the body of the email.
- Updating Your Profile. You may update or correct your personal information related to your account through your dashboard of your account or by sending a request to email@example.com.
We will respond to your communication preference requests within a reasonable timeframe.
Under the California Consumer Privacy Act (CCPA), individuals who are California residents have personal information rights, including the right to access, delete, and stop the sale of personal information. Information regarding these rights can be found in this Privacy Notice in the sections on Your Personal Information Rights and Choices and How to Exercise Your Personal Information Rights and Choices.
California residents can find additional information required by the CCPA in this Privacy Notice in the following sections:
- Categories of Personal Information Collected and Disclosed for business purposes in the preceding 12 months is described in the section What Personal Information We Collect and Disclose.
- Business or Commercial Purpose for Collecting Personal Information is described in the sections How We Use Personal Information About You and How We Share Personal Information About You.
- Categories of Sources of Personal Information is described in the section How We Collect Personal Information About You.
- Categories of Third Parties with Whom We Share Personal Data for business purposes in the preceding 12 months is described in the section How We Share Personal Information About You.
California law requires us to tell you that in the past 12 months, we have not sold personal information, including personal information of minors under the age of 16.
Under the Shine the Light law, Californians may request information about whether a business has disclosed personal information (as defined in that law) to any third parties for their direct marketing purposes. We don’t disclose personal information to third parties for their marketing purposes.
We don’t knowingly collect personal information about or from children without permission from their parent or guardian. We collect information about children directlythrough contact forms that may be completed by their parent or guardian.
We collect the following personal information about children:
- Contact information, such as name, postal address, email address, and phone number
- Characteristics, such as age, date of birth, and gender
We do not enable children or parents or guardians to make children’s personal information publicly available.
The main reason we collect children’s personal information is to provide services related to the collected information. We may use children’s information to do things like:
- Guide our development of products and services, including related to children
- Conduct aggregate (meaning data is not associated with an individual child) analyses of users of our services
- Comply with and enforce legal and regulatory obligations, respond to requests from law enforcement and other government authorities, or otherwise protect the rights, safety, or property of HM, our customers, and others
We use vendors and service providers to store children’s personal information. They are required to keep children’s personal information we provide to them confidential and to use it only to provide the services we request.
We may also share children’s personal information with third parties, including the government, for legal processes, or to protect life and safety where we believe that access, use, preservation, or disclosure of the information is reasonably necessary.
Your Rights as a Parent or Guardian
Parents and guardians have rights when it comes to their children’s information:
- To change their mind and withdraw consent to the collection of their child(ren)’s personal information
- To see the personal information we collect about their child(ren)
- To ask us to delete personal information we have collected about their child(ren)
The operator of our website is:
Health Monitor Network
11 Philips Parkway
Montvale, NJ 07046
You can exercise any of your rights as a parent or guardian or make any other inquiry about your child(ren)’s privacy by contacting the operator of our website by:
- Emailing us at firstname.lastname@example.org; or
- Calling us at (800) 422-4112
We may need to collect some information from you to confirm you are the parent or guardian.
Do Not Track
We do not track our customers or users over time and across third party websites and therefore do not respond to Do Not Track (DNT) signals.
We retain personal information for such period as is reasonably necessary to achieve the collection and use purposes described in this Privacy Notice.
Changes to Our Privacy Notice
We reserve the right to amend this Privacy Notice at our discretion and at any time. When we do, we will post the revised notice on this webpage with a new “Last Updated” date. Your continued use of our website or services, or your provision of personal information to us following the posting of changes constitutes your acceptance of such changes.
Phone: (800) 422-4112
Health Monitor Network
11 Philips Parkway
Montvale, NJ 07046
If you are unable to review or access this Privacy Notice due to a disability, please email us at email@example.com or call us at (800) 422-4112 so we can share it in another format.