Effective Date: May 15, 2020
Last Updated: May 15, 2020
- Terms and Conditions
- Information We Collect
- How We Use Information We Collect
- Our Legal Basis for Collecting Personal Data
- Information We Share
- Your Failure to Provide Personal Data
- Our Retention of Your Personal Data
- Your Choices and Accessing, Updating or Deleting Your Personal Data
- Third Party Links
- International Transfer
- How We Protect Personal Data
- Direct Marketing and “Do Not Track” Signals
- Sanguina Partners
- How to Contact Us
Irrespective of which country you live in, you authorize us to transfer, store, and use your information in the United States, and any other country where we operate. In some of these countries, the privacy and data protection laws and rules regarding when government authorities may access data may vary from those in the country where you live. Learn more about our data transfer operations in the “International Transfer” section below. If you do not agree to the transfer, storage and use of your information in the United States, and any other country where we operate, please do not use the Sites or Services.
Terms and Conditions
By accessing or using the Sites in any manner, you also agree to be bound by Sanguina’s Terms and Conditions (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.
Information We Collect
We collect information, including personal data, to provide better services to all our Users. We use the term “Personal Data” to refer to any information that identifies or can be used to identify you. Common examples of Personal Data include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.
“Sensitive Personal Data” refers to a smaller subset of Personal Data which is considered more sensitive to the individual, such as race and ethnic origin, political opinions, religious or philosophical beliefs, trade-union membership, genetic or biometric information, physical or mental health information, medical insurance data, or sexual orientation.
When you use our Services, we collect Personal Data and Sensitive Personal Data in the following ways:
- Information You Give to Us
You may choose to provide us with Personal Data about yourself, including your name, address, phone number, and email address by completing forms on our website, such as when you request information about our Services or register to receive services.
In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Data about yourself when you report a problem or have a question about our services.
The Sites offer interactive and social features that permit you to submit content and communicate with us. You may provide Personal Data to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other Users.
- Mobile Application
Certain information is required when creating an account to use our Services on the mobile application, such as your name, email address, user name and password.
In addition, in order to improve your experience with the Services, you may choose to provide additional information such as your gender, birth date, ethnicity, insurance provider, physical activity, and other health information, such as hemoglobin results history. You can choose not to provide certain information, but then you may not be able to register for the Sanguina Services or take advantage of some features of the Services.
When your device syncs with Sanguina’s application, certain data recorded on your device is transferred from your device to our servers.
- Information We Obtain from Your Use of Our Services
We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on Your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.
- Location Data
If you grant us access to your location, Sanguina may collect information about your location when you use our Sites and Services. Your location can be determined by: GPS, IP address, and information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. The specificity of the location data collected may depend on a number of factors, including the device you are using (e.g. laptop, smartphone or tablet) and how you are connected to the Internet (e.g., via cable broadband connection, WiFi). If you enable location services for our mobile application, we may collect location data periodically as you use or leave open our mobile application. We may associate such location data with Personal Data you provide to us. Depending on the platform you use to access our mobile application (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the mobile application.
- Device ID
When using our Services, we or our service provider may collect your unique device ID. We may use such information for internal purposes and to provide you a better experience, such as to troubleshoot application problems you may experience. We may associate device ID with personal information you provide to us. You may learn more about opt out of any anonymous device ID collection via the privacy settings available within your mobile device.
- Financial Information
In order to provide our services, we may request payment information such credit or debit card information, name and address which allows us to process payments.
- Sanguina Partners
We may partner with third parties, such as employers and insurance companies, that offer Sanguina Services to their employees and customers. In such cases, those companies may provide us with your name, email address, or similar information so that we can invite you to participate or determine your eligibility for particular benefits.
- Health and Other Special Categories of Personal Data
To the extent that information we collect is health data or another special category of Personal Data subject to the European Union’s General Data Protection Regulation, we ask for your explicit consent to process the data. We obtain this consent separately when you take actions leading to our obtaining the data. You can use your account tools to withdraw your consent at any time.
- Cookies and Similar Technologies
We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google, Lead Forensics and similar partners.
The technologies we use for this automatic data collection may include:
Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
Mobile Device Identifiers and SDKs. A mobile SDK is the mobile app version of a web beacon (see “Web Beacons” above). The SDK is a bit of computer code that app developers can include in their apps to enable ads to be shown, data to be collected and related services or analytics to be performed.
- Network Advertisers
- Other Advertising
We share certain data with Social Networks to allow us to target existing Users and customers with highly relevant advertising campaigns. We will not share your name, address, email address, telephone number or other personal information for the purpose of such campaigns. If you do not wish to receive advertisements in this way, please follow the links available here and here.
How We Use Information We Collect
We use your Personal Data in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
- To present, operate or improve the Site and Services, including analysis of Site activity;
- To inform you about Services and products available from Sanguina;
- To authorize access to our Sites and Services;
- To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
- To offer and administer programs;
- To personalize the Services to your health needs;
- To customize or tailor your experience of the Services, which may include sending customized messages;
- To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns and programs, sweepstakes, and other offers or promotions, and to deliver pertinent emails;
- To improve our Site and Services;
- To secure our Services, including to authenticate Users;
- To use statistical information that we collect in any way permitted by law, including from third parties;
- To respond to and support Users regarding their use of the Sites and Services;
- To comply with all applicable legal requirements;
- To enforce our Terms and Conditions and other agreements;
- To perform data analysis and testing;
- To resolve disputes;
- To otherwise fulfill the purpose for which the information was provided.
We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our company and our Users.
We use information collected from cookies and other technologies, to improve your User experience and the overall quality of our services. We may use your Personal Data to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.
Our Legal Basis for Collecting Personal Data
Whenever we collect Personal Data from you, we may do so on the following legal bases:
- Your consent to such collection and use;
- Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
- Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Data is necessary for:
- Intra-organization transfers for Sanguina Partner data for administrative purposes;
- Product development and enhancement, where the processing enables Sanguina to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
- Communications and marketing, including processing data for direct marketing purposes, and subject to your opt-in for these purposes, and to determine the effectiveness of our promotional campaigns and advertising;
- Fraud detection and prevention;
- Enhancement of our cybersecurity, including improving the security of our network and information systems; and
- General business operations and diligence;
Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.
Information We Share
We do not share Personal Data with companies, organizations and individuals outside of Sanguina unless one of the following circumstances applies:
- With your consent. We will share Personal Data with companies, organizations or individuals outside of Sanguina when we have your consent to do so. When we share health Personal Data, we do so for the purpose of improving health management or for purpose of health research.
- Enterprise Accounts. Your employer or your organization may offer you access to our Services. We will share Personal Data with your employer or organization. When we share health and fitness Personal Data, we do so for the purpose of improving health management or for purpose of health research and with your consent. Your employer or organization can review and manage your use of such enterprise Services.
- Your Insurance Provider. We may share your Personal Data with the insurance provider you identify to us (and do so via our Sanguina Partners) to determine eligibility, or otherwise obtain a benefit plan and other insurance-related information about you. When we share health and fitness Personal Data, we do so for the purpose of improving health management or for purpose of health research and with your consent.
- For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of Sanguina if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of Sanguina, our Users or the public as required or permitted by law.
We attempt to notify Users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
- Business Transfers. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Data about our Users is often a transferred business asset. In the event that Sanguina itself or substantially all of our assets are acquired, Personal Data about our Users may be one of the transferred assets.
- Non-Personal and Aggregate Site Use Information. Sanguina may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”). We may disclose such De-Identified Information publicly and to third parties, for example, in public reports about exercise and activity, or to Sanguina Partners under agreement with us. Sanguina may also disclose De-Identified Information for general research purposes and in research collaborations with third parties, such as universities, hospitals or other laboratories to determine the prevalence of particular conditions among Users or to determine whether a User might be suitable for research or clinical trials. Sanguina may also use De-Identified Information for commercial collaborations with private companies for purposes such as product design or enhancement of Services.
Your Failure to Provide Personal Data
Your provision of Personal Data is required in order to use certain parts of our services and our programs. If you fail to provide such Personal Data, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.
Our Retention of Your Personal Data
We may retain your Personal Data for a period of time consistent with the original purpose for collection. For example, we keep your Personal Data for no longer than reasonably necessary for your use of our programs and Services and for a reasonable period of time afterward. We also may retain your Personal Data during the period of time needed for us to pursue our legitimate business interests, conduct audits, comply with our legal obligations, resolve disputes and enforce our agreements.
Your Choices and Accessing, Updating or Deleting Your Personal Data
Whenever you use our Services, we aim to provide you with choices about how we use your Personal Data. We also aim to provide you with access to your Personal Data. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of personal information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that personal information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.
- Your Rights With Respect to Personal Data
Some data protection laws, including the European Union’s General Data Protection Regulation (“GDPR”), corresponding legislation in the United Kingdom, and some U.S. state laws, provide you with certain rights in connection with Personal Data you have shared with us. If you are resident in the European Economic Area, you may have the following rights:
- The right of access. You have the right to request a copy of your Personal Data which we hold about you.
- The right of correction: You have the right to request correction or changes of your Personal Data if it is found to be inaccurate or out of date.
- The right to be forgotten: You have the right to request us, at any time, to delete your Personal Data from our servers and to erase your Personal Data when it is no longer necessary for us to retain such data. Note, however, that deletion of your Personal Data will likely impact your ability to use our services.
- The right to object (opt-out): You have the right to opt-out of certain uses of your Personal Data, such as the processing of your health information, at any time.
- The right to data portability: You have the right to a “portable” copy of your Personal Data that you have submitted to us. Generally, this means your right to request that we move, copy or transmit your Personal Data stored on our servers / IT environment to another service provider’s servers / IT environment.
- The right to refuse to be subjected to automated decision making, including profiling: You have the right not to be subject to a decision and insist on human intervention if the decision is based on automated processing and produces a legal effect or a similarly significant effect on you.
- The right to lodge a complaint with a supervisory authority.
You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law. To make these requests, you may contact us using the contact information below, and we will consider your request in accordance with applicable laws. For your protection, we may need to verify your identity before responding to your request, such as verifying that the email address from which you send the request matches your email address that we have on file. If we no longer need to process Personal Data about you in order to provide our Services or our Sites, we will not maintain, acquire or process additional information in order to identify you for the purpose of responding to your request.
In some cases our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
- Changing or Deleting Your Information
You may update or correct information about yourself by making changes to your profile by emailing us at email@example.com. If you completely delete all such information, then your account may become deactivated. We may retain an archived copy of your records as required by law, to comply with our legal obligations, to resolve disputes, to enforce our agreements or for other legitimate business purposes.
We may contact you to request that you update your Personal Data on a regular basis to ensure its integrity for the purposes of ongoing data management.
- Our Opt-in/Opt-out Policy
We currently provide the following opt-out opportunities:
- At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us or a Sanguina Partner to unsubscribe from the service.
- Your Ad Choices
As described above, we or third party partners may place or recognize a unique cookie on your browser when you visit our Sites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). You may find more information about entities involved in online advertising and additional choices you may make, including opt-out of having your information used for internet-based advertising, through the Network Advertising Initiative (“NAI”) at the NAI Service, and the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice service. Sanguina is a participant in the online industry’s self-regulatory program administered by the DAA and has agreed to adhere to the DAA’s principles applicable to interest-based ads.
The tools provided at the DAA opt-out page and the NAI opt-out page are provided by third parties, not Sanguina. Sanguina does not control or operate these tools or the choices that advertisers and others provide through these tools.
Third Party Links
The Sites may contain links to webpages operated by parties other than Sanguina. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Sanguina strongly recommends that each User review the third party’s terms and policies.
How We Protect Personal Data
Sanguina maintains administrative, technical and physical safeguards designed to protect the User’s Personal Data and information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement appropriate technical and organizational measures to ensure a level of security appropriate to the risk, taking into account technological reality, cost, the scope, context and purposes of processing weighted against the severity and likelihood that the processing could threaten individual rights and freedoms. For example, we restrict access to personal information to Sanguina employees, contractors, business partners and agents who need to know that information in order to operate, develop or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. We use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Data.
If Sanguina collects account information for payment or credit, Sanguina will use the information only to complete the task for which the account information was offered.
The Site is not intended for use by children. We do not intentionally gather Personal Data about United States visitors who are under the age of 13 or about European Union, United Kingdom or Swiss visitors who are under the age of 16. If a child has provided us with Personal Data, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under the ages of 13 or 16 in the applicable jurisdictions, please contact us at legal@Sanguina.com. If we learn that we have inadvertently collected the personal information of a child under the minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.
Direct Marketing and “Do Not Track” Signals
Sanguina does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.
California residents are entitled to contact us to request information about whether we have disclosed personal information to third parties for the third parties’ direct marketing purposes. Sanguina does not disclose personal information to third parties for their direct marketing purposes. California users may request further information about our compliance with this law by e-mailing us at the address listed in the “How to Contact Us” section.
- Sanguina Partner Information. We collect information about individuals within our Sanguina Partners organization (“Partner Information”). Partner Information may include information related to the Partner’s account, name, work e-mail address, work phone number, job title or similar kinds of information. We use Partner Information to support the Partner account, maintain our business relationship with the Partner, respond to Partner inquiries, or perform accounting functions. Sanguina Partners may update personal information and password by logging into the Sanguina Platform and updating their account. Sanguina Partners may contact Sanguina support in order to delete their Personal Data. In some cases, we may not be able to delete Partner Information, and in such cases we will tell you why.
- Information about our Partners’ Contacts. We collect information about any contacts, such as practice groups, employees, insured parties, and others, that may be uploaded into the Sanguina Platform (“Information about our Partners’ Contacts”). Information about our Partner’s Contacts may include name, e-mail address, phone number, job title, or similar kinds of information. We use Information about our Partner’s Contacts for the purposes of providing Services to such contacts. Sanguina Partners may update or delete Information about their contacts in the Sanguina Platform. Sanguina Partners may also contact Sanguina support in order to update and delete such information. In some cases, we may not be able to delete such information, and in such cases we will tell you why.
- Archival Information. We collect User information for archival purposes on behalf of, and as directed by, our Sanguina Partners for the purpose of improving health management. This information may include User Personal Data, User communications with health coaches, User medical measurements, among other forms of data or electronic communications (“Archival Information”). Our Sanguina Partner’s privacy policies or practices apply to Archival Information, the purposes for which the Sanguina Partner collects Archival Information, how the Sanguina Partner may use Archival Information and what choices the individual may have with respect to Archival Information. Individuals must contact the applicable Sanguina Partner in order to correct, amend, or delete their information, or to opt out of any collection, uses or disclosure of their information by our Sanguina Partner.
- Automatically Collected Information. We collect information automatically about how our Sanguina Partners use our services (“Automatically Collected Information”). We do this via data collection technologies such as cookies, web beacons, gifs or other tracking technologies. We collect this information in order to monitor, support and improve our services or to provide Sanguina Partners with certain customized features. We may use Automatically Collected Information to tell us how our Sanguina Partners use our services, to improve our services or develop new products, services or features. We may combine this information with other information we collect.
We treat Partner Information, Information about our Partner’s Contacts, Archival Information and Automatically Collected Information as the confidential and proprietary information of our Sanguina Partners, subject to the terms of the Sanguina Terms and Conditions and any other service agreement between Sanguina and the Partner. We do not share Partner Information, Information about our Partner’s Contacts, Archival Information or Automatically Collected Information with third parties unless directed to do so by our Partner, as may be necessary to provide services to the Partner, to our advisors, affiliates, representatives, agents, service providers, in connection with a business transaction (such as a merger or sale), as allowed under the terms of our agreement with our Partner, or in response to a court order, subpoena, warrant or to comply with a legal requirement or to cooperate with an investigation. We may disclose Partner Information, Information about our Partner’s Contacts, Archival Information or Automatically Collected Information for the aforementioned reasons, or in order to protect our rights or the rights of our affiliates, Sanguina Partners, business partners or service providers.
We will retain Partner Information we process on behalf of our Sanguina Partners for as long as needed to provide services to our Partner, or for the period of time requested by a particular Partner.
How to Contact Us
Send e-mail to: firstname.lastname@example.org
Send mail to our address:
147 Technology Parkway
Peachtree Corners, GA 30092