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We may combine information we collect from different sources for these purposes, and to give you a more seamless, consistent, and personalized experience. ‍

How We Disclose Personal Information

We disclose personal information with your consent or as we determine necessary to complete your transactions or provide the Services you have requested or authorized. In addition, we may disclose each of the categories of personal information described above, to the types of third parties described below, for the following business purposes: 

• Service Providers. We provide personal information to vendors or agents working on our behalf for the purposes described in this Notice. For example, companies we’ve hired to assist in protecting and securing our systems and Services may need access to personal information to provide those functions.
• Affiliates. We enable access to personal information across any subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our Services and operate our business.
• Business Partners. We may disclose your information to partners with which we offer co-branded Services or engage in joint marketing activities, for example, where you use a co-branded Service and where access helps us to provide you with the co-branded Service and operate our business.
• When Required by Law or as Necessary to Protect Our Users and Services. We access, disclose, and preserve personal information when we believe that doing so is necessary to:
  
  • protect, enforce, or defend the legal rights, privacy, safety, or property of ourselves or others, including enforcing our agreements, terms, and policies; 
  • comply with applicable law; 
  • respond to valid legal process (such as subpoenas or warrants), including from law enforcement, national security, or other government agencies;
  • protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone; or
  • operate and maintain the security of our Services, including to prevent or stop an attack on our computer systems or networks. 
• Corporate Transactions. We disclose personal information as part of a corporate transaction or proceeding such as a sale, transfer, divestiture, or transfer of all or a portion of our business or assets, or a merger, financing, acquisition, bankruptcy, or dissolution.

Third party analytics and advertising companies also collect personal information through our website and apps including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, usage data, and inferences based on and associated with that data, as described in the “Cookies” section of this Notice. These third-party vendors may combine this data across multiple sites to improve analytics for their own purpose and others. For example, we use Google Analytics on our website to help us understand how users interact with our website; you can learn how Google collects and uses information by clicking here.

Some of the data disclosures to these third parties may be considered a “sale” or “sharing” of personal information as defined under the laws of California. Please see the “Choices and Control” and “California Privacy Rights” sections below for more details.

Please note that some of our Services also include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal information to any of those third parties, or allow us to share personal information with them, that data is governed by their privacy statements.

Finally, we may disclose de-identified information in accordance with applicable law.

Security of Personal Information

We take reasonable and appropriate steps to help protect personal information from unauthorized access, use, disclosure, alteration, and destruction. If you want to report a potential cyber security vulnerability, please contact us at security@evidation.com.

Retention of Personal Information

We retain personal information for so long as reasonably necessary to provide the Services and fulfill the transactions you have requested, comply with our legal obligations, resolve disputes, enforce our agreements, and for other legitimate and lawful business purposes.

Because these needs can vary for different data types in the context of different Services, the actual retention periods can vary significantly based on criteria such as user expectations or consent, the sensitivity of the information, the availability of automated controls that enable users to delete data, and our legal and contractual obligations.

Choices and Control of Personal Information

We provide a variety of ways for you to control the personal information we hold about you, including choices about how we use that data. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law.

Access, Portability, Correction, and Deletion

If you wish to access, correct, or delete personal information about you that we hold, you may complete the “Submit a Request” form (available by clicking here); please select “Privacy” under the “What’s this about?” dropdown. 

If you are unable to access, copy, correct, or delete certain personal information we have via the means described above, you can send us a request by using contact methods described at the bottom of this Notice.

Communications Preferences

You may choose whether to receive promotional communications from us by email and SMS. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message or by contacting us as described in the “Contact Us” section below. These choices do not apply to certain informational communications including surveys and mandatory service communications. 

Targeted Advertising

To opt-out from or otherwise control targeted advertising, you have several options:

• You can use the controls available through our website cookie banner to decline advertising-related cookies by clicking “Cookies Settings” at the bottom of our website footer. 
• You can use the opt-out controls offered by the organizations our advertising partners may participate in, which you can access at: 
  
  • Network Advertising Initiative (https://optout.networkadvertising.org/) 
  • Digital Advertising Alliance (https://optout.aboutads.info/) 
• You can use the Global Privacy Control setting in a web browser or browser extension as described below.
• You can use the other cookie or mobile ID controls described below.

These choices are specific to the device or browser you are using. If you access our Services from other devices or browsers, take these actions from those devices or browsers to ensure your choices apply to the data collected when you use them.

Data Sales

Some privacy laws define “sale” broadly to include some of the disclosures described in the “How We Disclose Personal Information” section above. To opt-out from such data “sales,” please use the Global Privacy Control setting in a web browser or browser extension as described below, or follow the instructions on our “Do Not Sell or Share My Personal Information” page, available by clicking here.

Browser or Platform Controls

• Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or Services of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
• Global Privacy Control. Some browsers and browser extensions support the “Global Privacy Control” (GPC) or similar controls that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales and/or targeted advertising, as specified by applicable law. When we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting or similar control that is recognized by regulation or otherwise widely acknowledged as a valid opt-out preference signal.
• ‍Do Not Track. Some browsers include a “Do Not Track” (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Unlike the GPC described above, there is not a common understanding of how to interpret the DNT signal; therefore, our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the GPC, cookie controls, and advertising controls described above.
• ‍MAID controls. iOS and Android operating systems provide options to limit tracking and/or reset the MAIDs.

Email Web Beacons

Most email clients have settings that allow you to prevent the automatic downloading of images, including web beacons, and the automatic connection to the web servers that host those images.

Except for the automated controls described above, if you send us a request to exercise your rights or these choices, to the extent permitted by applicable law, we may charge a fee or decline requests in certain cases. For example, we may decline requests where granting the request would be prohibited by law, could adversely affect the privacy or other rights of another person, would reveal a trade secret or other confidential information, or would interfere with a legal or business obligation that requires retention or use of the data. Further, we may decline a request where we are unable to authenticate you as the person to whom the data relates, the request is unreasonable or excessive, or where otherwise permitted by applicable law. If you receive a response from us informing you that we have declined your request, in whole or in part, you may appeal that decision by submitting your appeal using the contact method described at the bottom of this Notice.

Location of Personal Information

The personal information we collect may be stored and processed in your country or region, or in any other country where we or our affiliates, subsidiaries, or service providers process data, some of which may have laws that offer different levels of data protection than the country in which you reside. Currently, we use data centers in the United States. The storage location(s) are chosen to operate efficiently and improve performance. We take steps to process and protect personal information as described in this Notice wherever the data is located.

California Privacy Rights 

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information.

Notice at Collection

At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Notice by clicking on the above links.

Right to Know

You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note we have provided much of this information in this Notice. You may make such a “request to know” by logging into your Evidation account and navigating to your “Account” page, or by completing the “Submit a Request” form (available by clicking here); please select “Privacy” under the “What’s this about?” dropdown. You can also send us a request by using contact methods described at the bottom of this Notice.

Right to Request Correction or Deletion 

You have rights to request that we correct inaccurate personal information and that we delete personal information under certain circumstances, subject to a number of exceptions. To make a request to correct or delete, please log into your Evidation account and navigate to your “Account” page, or complete the “Submit a Request” form (available by clicking here); please select “Privacy” under the “What’s this about?” dropdown. You can also send us a request by using contact methods described at the bottom of this Notice.

Right to Opt-Out / “Do Not Sell or Share My Personal Information” 

You have a right to opt-out from future “sales” or “sharing” of personal information as those terms are defined by the CCPA.

Note that the CCPA defines “sell,” “share,” and “personal information” very broadly, and some of our data disclosures described in this Notice may be considered a “sale” or “sharing” under those definitions. In particular, we let analytics providers collect identifiers (IP addresses, cookie IDs, and mobile IDs), activity data (browsing, clicks, app usage), device data, and geolocation data through our sites and apps when you use our online Services, but do not “sell” or “share” any other types of personal information. If you do not wish for us or our partners to “sell” or “share” personal information relating to your visits to our sites for advertising purposes, you can make your request by visiting our “Do Not Sell or Share My Personal Information” page (available by clicking here), using a Global Privacy Control, emailing us using the contact information at the bottom of this Notice, or using other controls described in the “Choices and Control” section of this Notice. If you opt-out using these choices, we will not disclose or make available such personal information in ways that are considered a “sale” or “sharing” under the CCPA. We will continue to make available to our partners (acting as our service providers) some personal information to help us perform analytics-related functions. Further, using these choices will not opt you out of the use of previously “sold” or “shared” personal information or stop all interest-based advertising.

We do not knowingly sell or share the personal information of minors under 16 years of age.

Right to Limit Use and Disclosure of Sensitive Personal Information

You have a right to limit our use of sensitive personal information for any purposes other than to provide the Services or goods you request or as otherwise permitted by law. Note that we do not use sensitive personal information for any such additional purposes.

Verification of Data Subject Requests

To provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by requiring you to provide information necessary to verify your identity. For example, we may request your name, email, and/or information about how you have used our Services. 

Authorized Agents

You may also designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we may require the agent to provide proof you have authorized the agent to act on your behalf, and we may require you to verify your own identity directly with us. 

Finally, you have a right to not be discriminated against for exercising these rights set out in the CCPA.

Changes to this Notice

We will update this Notice when necessary to reflect changes in our Services, how we use personal information, or the applicable law. Changes to this Notice will become effective when published, unless otherwise noted. When we post changes to the Notice, we will revise the “Last Updated” date at the top of this Notice. If we make material changes to this Notice, we will provide notice or obtain consent regarding such changes as may be required by law.

Contact Us

For any privacy questions, complaints, or inquiries regarding this Notice, please direct your inquiry to:

Evidation Health
Attn: Privacy Office
63 Bovet Rd #146
San Mateo, CA 94402
privacy@evidation.com

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