Effective Date: 11/19/2020
Last Updated Date: 11/19/2020
- Terms and Conditions
- Information We Collect
- Information Collected Related to California Residents
- How We Use Information We Collect
- Sale of Personal Information
- Information We Share
- Your Failure to Provide Personal Data
- Our Retention of Your Personal Data
- Privacy Rights Specific to Californians
- Third Party Links
- International Transfer
- How We Protect Personal Data
- Direct Marketing and “Do Not Track” Signals
- Azalea Health 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 Azalea Health’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
- Website and Online Platform
We may collect information you provide us if you access, voluntary enter information into, or sign up for or request certain services from us on our Website. For example, if you are interested in learning more about Azalea Health and the services and products we offer, we may ask for information such as your name, alias, title, practice/organization name, size and address, email address, telephone number, type of user (patient, provider, partner), and city/state. If you have an account with us, we may also collect your username or other login information you use to log into or access your account.
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.
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]. You can choose not to provide certain information, but then you may not be able to register for the Azalea Health Services or take advantage of some features of the Services.
When your device syncs with Azalea Health’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.
If you grant us access to your location, Azalea Health may collect information about your location when you use our Sites and Services. Your location can be determined by: 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.
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.
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.
Azalea Health Partners
If you are a partner submitting a lead to us, we will collect information related to you as a partner as well as information related to the lead including details about the organization, address, contact information, needs, past purchase history, and purchaser preferences.
Health and Other Special Categories of Personal Data
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.
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.
Information Collected Related To California Residents
During the last twelve (12) months, we have collected the following categories of personal information from consumers.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from our customers or their agents. For example, from information that helps us monitor and communicate special offerings or services.
- Indirectly from our customers or their agents. For example, through information we collect from our clients in the course of providing Services to them.
- Directly and indirectly from activity on our website (www.clientcommand.com). For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
- From social media websites, such as Facebook, Twitter, and LinkedIn.
- From third parties that assist us in providing certain transactions and services (e.g. payment processing, hosting), even though it appears that you may not have left our Site.
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 Azalea Health;
- 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, online campaigns and programs, and other offers or promotions, and to deliver pertinent emails;
- 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.
Sale of Personal Information
In the preceding twelve (12) months, we have not sold any Personal Information.
Information We Share
We do not share Personal Data with companies, organizations and individuals outside of Azalea Health unless one of the following circumstances applies:
- With your consent. We will share Personal Data with companies, organizations or individuals outside of Azalea Health 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-related 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 Azalea Health Partners) to determine eligibility, or otherwise obtain a benefit plan and other insurance-related information about you.
- For Legal Reasons. We will share Personal Data with companies, organizations or individuals outside of Azalea Health 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 Azalea Health, 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 Azalea Health 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. Azalea Health 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 Azalea Health Partners under agreement with us. Azalea Health 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. Azalea Health may also use De-Identified Information for commercial collaborations with private companies for purposes such as product design or enhancement of Services.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:
- California Customer Records Personal Information categories;
- Protected classification characteristics under California or federal law;
- Commercial information;
- Internet or other network activity information;
- Geolocation data;
- Professional or employment-related information;
- Inferences drawn from other personal information
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates;
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the Services we provide to you.
- Service providers and other third parties we use to support our business, including without limitation those performing core services (such as credit card processing, customer support services, customer relationship management, property management, accounting, auditing, processing insurance claims, administering sweepstakes, surveys, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services.
- Commercial providers;
- Enterprise accounts, such as your employer.
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.
Privacy Rights Specific To Californians
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.
Under the California Consumer Privacy Act, California residents have specific rights regarding their personal information. This section describes Californians’ rights and explains how California residents can exercise those rights.
Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.
- Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
- Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
- Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
- Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
Exercising Your Rights
If you are a California resident who chooses to exercise your rights, you can:
- Submit a request via email to email@example.com [or the online portal], or
- Call [toll-free number] to submit your request.
You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.
Our Response to Your Request
Upon receiving your request, we will confirm receipt of your request by [sending you an email/confirming receipt via our online portal/sending a message to your online account]. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your personal information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
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, listed below, 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.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.);
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
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 an Azalea Health 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. Azalea Health 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 Azalea Health. Azalea Health 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 Azalea Health. 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. Azalea Health strongly recommends that each User review the third party’s terms and policies.
How We Protect Personal Data
Azalea Health 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 Azalea Health 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 Azalea Health collects account information for payment or credit, Azalea Health 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 persons 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 age of 16 in the applicable jurisdictions, please contact us at firstname.lastname@example.org. 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
Azalea Health 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. Azalea Health 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.
Azalea Health Partners
- Azalea Health Partner Information. We collect information about individuals within our Azalea Health 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. Azalea Health Partners may update personal information and password by logging into the Azalea Health Platform and updating their account. Azalea Health Partners may contact Azalea Health 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 Azalea Health 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. Azalea Health Partners may update or delete Information about their contacts in the Azalea Health Platform. Azalea Health Partners may also contact Azalea Health 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 Azalea Health 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 Azalea Health Partner’s privacy policies or practices apply to Archival Information, the purposes for which the Azalea Health Partner collects Archival Information, how the Azalea Health Partner may use Archival Information and what choices the individual may have with respect to Archival Information. Individuals must contact the applicable Azalea Health 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 Azalea Health Partner.
- Automatically Collected Information. We collect information automatically about how our Azalea Health 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 Azalea Health Partners with certain customized features. We may use Automatically Collected Information to tell us how our Azalea Health 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 Azalea Health Partners, subject to the terms of the Azalea Health Terms and Conditions and any other service agreement between Azalea Health 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, Azalea Health Partners, business partners or service providers.
We will retain Partner Information we process on behalf of our Azalea Health 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: email@example.com
Send mail to our address:
Azalea Health Innovations, Inc.
5871 Glenridge Drive NE
Atlanta, GA 30328