Circadia Clinical Intelligence Platform
Privacy Policy
Last Updated: April 2, 2024
THE POLICY.
This Circadia Clinical Intelligence Platform Privacy Policy (the “Privacy Policy” or “Policy”) for describes how and why Circadia Health, Inc. (“Circadia,” “we,” “us,” or “our”) might collect, store, use, and/or share (“process”) your information when you (“you” or “your”) use the Clinical Intelligence Platform and any associated software provided by Circadia (the “Platform”) provided by Circadia Health, Inc.
PLEASE NOTE THAT THIS POLICY DOES NOT SET FORTH OR GOVERN:(i) YOUR RESPONSIBILITIES, ACKNOWLEDGEMENTS, WARRANTIES, OR REPRESENTATIONS PERTAINING TO YOUR USE OF THE PLATFORM,(ii) OUR LIABILITIES WITH RESPECT TO THE PLATFORM,(iii) YOUR RESPONSIBILITIES TOWARDS THIRD PARTY INDIVIDUALS WHOSE INFORMATION YOU MAY ACCESS USING THE PLATFORM, INCLUDING ANY THIRD PARTY INDIVIDUALS WHOSE PROTECTED HEALTH INFORMATION (PHI) YOU MAY ACCESS USING THE PLATFORM, OR(iv) YOUR USE OF SUCH INFORMATION. FOR TERMS SETTING FORTH AND/OR GOVERNING(i), (ii), (iii), AND(iv), PLEASE SEE OUR CIRCADIA CLINICAL INTELLIGENCE PLATFORM END USER TERMS OF USE.
QUESTIONS OR CONCERNS.
Reading this Privacy Policy will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use the Platform. If you still have any questions or concerns, please contact us at support@circadia.health or (800) 985 5596.WHAT INFORMATION DO WE COLLECT?
In short: we collect personal information provided to us by you or the organization you represent and on behalf of which you access the Platform (such organization, your “Organization”). We collect personal information that you voluntarily provide to us when you use the Platform, when you participate in activities on the Platform, or otherwise when you contact us.Personal Information Provided by You or Your Organization That We Store. The personal information that we collect depends on the context of your interactions with us and the Platform, the choices you make, and the products and features you use. The personal information we collect and store may include the following:
Names;
Email Addresses;
Sensitive Personal Information. We do not process Sensitive Personal Information. “Sensitive Personal Information” is information about you that may reveal your education, financial history, medical history, or criminal or employment history.
Support Data. We may request data that is necessary to resolve requests for support. We may share this data with third party vendors whom we have engaged for the purpose of tracking and/or resolving support requests.
Accuracy. All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.
HOW DO WE PROCESS YOUR INFORMATION?
In Short: We process your information to provide, improve, and administer our Platform, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.Purposes. We process your personal information for a variety of reasons, depending on how you interact with our Platform, including:
To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
To send administrative information to you. We may process your information to send you details about changes to our terms and policies and other similar information.
To request feedback. We may process your information when necessary to request feedback and to contact you about your use of our Platform.
To protect our Platform. We may process your information as part of our efforts to keep our Platform safe and secure, including fraud monitoring and prevention.
To protect our Platform. We may process your information as part of our efforts to keep our Platform
safe and secure, including fraud monitoring and prevention.
To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.
WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?
In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services, to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We may share information in specific situations described in this section and/or with the third parties specified in this section.Purposes. We may need to share your personal information in the following situations:
Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale
DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
In Short: We may use cookies and other tracking technologies to collect and store your information.Cookies. We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information.
WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Policy unless otherwise required by Jaw.
Retention. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.
Deletion. When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
HOW DO WE KEEP YOUR INFORMATION SAFE?
In Short: We aim to protect your personal information through a system of organizational and technical security measures.Measures. We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any of your personal information that we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information.
Assumption of Risk. Although we will do our best to protect your personal information, transmission of personal information to and from our Platform is at your own risk. You should only access the Platform within a secure environment.
DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly collect data from or market to children under 18 years of age.No Minors. The Platform are not intended for users below the age of 18. We do not knowingly solicit data from or market to children under 18 years of age.
Representation. By using the Platform, you represent that you are at least 18. If we learn that personal
information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at support@circadia.health or (800) 985 5596.
WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some jurisdictions, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.Jurisdictions. In some jurisdictions, you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (vi) if applicable, to data portability; and (vii) not to be subject to automated decision-making. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. We will consider and act upon any request in accordance with applicable data protection laws.
Withdrawing Your Consent. If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below. However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Contact. If you have questions or comments about your privacy rights, you may contact us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.
Marketing Third Parties. California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.
CCPA Privacy Notice. The California Code of Regulations defines a “resident” as:every individual who is in the State of California for other than a temporary or transitory purpose; and
every individual who is domiciled in the State of California who is outside the State of California for a
temporary or transitory purpose.
All other individuals are defined as “non-residents.”
If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information.Categories of Personal Information. We have collected the following categories of personal information in the past twelve (12) months:
Identifiers
Examples
Collected
Identifiers
Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name
YES
Personal information categories listed in the California Consumer Records statute
Name, contact information
YES
Protected classification characteristics under California or federal law
Gender and date of birth
NO
Commercial information
Transaction information, purchase history, and payment information
NO
Biometric information
Fingerprints and voiceprints
NO
Internet or other similar network activity
Interactions with our websites, applications, and systems
YES
Geolocation data
Device location
NO
Audio, electronic, visual, thermal, olfactory, or similar information
Images and audio, video, or call recordings created in connection with our business activities
NO
Professional or employment-related information
Business contact details in order to provide you with our Platform at a business level
NO
Education information
Student records and directory information
NO
Inferences drawn from any of the collected personal information listed
Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual's preferences and characteristics
NO
Sensitive Personal Information
NO
We will use and retain the collected personal information as needed to provide the Platform or for as long as the user has an account with us.
User Interaction. We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:
Receiving help through our customer support channels;
Participation in customer surveys or contests; and
Facilitation in the delivery of our Platform and to respond to your inquiries.
How do we use and share your personal information?
Information about our data collection and sharing practices can be found in this Privacy Policy. You
may contact us by email at support@circadia.health, or by referring to the contact details at the
bottom of this document.
If you are using an authorized agent to exercise your right to opt out, we may deny a request if the
authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Will your information be shared with anyone else?
We may disclose your personal information with our service providers pursuant to a written contract
between us and each service provider. Each service provider is a for-profit entity that processes the
information on our behalf, following the same strict privacy protection obligations mandated by the
CCPA.
We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information. We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to Platform users.
Your rights with respect to your personal data.
Right to request deletion of the data (Request to delete). You can ask for the deletion of your personal
information. If you ask us to delete your personal information, we will respect your request and delete
your personal information, subject to certain exceptions provided by law, such as (but not limited to)
the exercise by another consumer of his or her right to free speech, our compliance requirements
resulting from a legal obligation, or any processing that may be required to protect against illegal
activities.
Right to be informed (Request to know). Depending on the circumstances, you have a right to know:
whether we collect and use your personal information;
the categories of personal information that we collect;
the purposes for which the collected personal information is used;
whether we sell or share personal information to third parties;
the categories of personal information that we sold, shared, or disclosed for a business purpose;
the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
the business or commercial purpose for collecting, selling, or sharing personal information; and
the specific pieces of personal information we collected about you.
In accordance with applicable law, we are not obligated to provide or delete consumer informationthat is de-identified in response to a consumer request or to reidentify individual data to verify a
consumer request.
Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights. We will not discriminate against you if you exercise your privacy rights.
Right to Limit Use and Disclosure of Sensitive Personal Information. We do not process consumers’ Sensitive Personal Information.
Verification Process.
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g., phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use personal information provided in your request to verify your identity or
authority to make the request. To the extent possible, we will avoid requesting additional
information from you for the purposes of verification. However, if we cannot verify your
identity from the information already maintained by us, we may request that you provide
additional information for the purposes of verifying your identity and for security or fraud-
prevention purposes. We will delete such additionally provided information as soon as we
finish verifying you.
Other Privacy Rights.
You may object to the processing of your personal information.
You may request correction of your personal data if it is incorrect or no longer relevant, or
ask to restrict the processing of the information.
You can designate an authorized agent to make a request under the CCPA on your behalf. We
may deny a request from an authorized agent that does not submit proof that they have
been validly authorized to act on your behalf in accordance with the CCPA.
You may request to opt out from future selling or sharing of your personal information to
third parties. Upon receiving an opt-out request, we will act upon the request as soon as
feasibly possible, but no later than fifteen (15) days from the date of the request submission.
To exercise these rights, you can contact us by email at support@circadia.health, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.
DO VIRGINIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In Short: Yes, if you are a resident of the Commonwealth of Virginia (the “Commonwealth”), you may be granted specific rights regarding access to and use of your personal information.Virginia CDPA Privacy Notice. Under the Virginia Consumer Data Protection Act (CDPA):
“Consumer” means a natural person who is a resident of the Commonwealth acting only in an
individual or household context. It does not include a natural person acting in a commercial or
employment context.
“Personal data” means any information that is linked or reasonably linkable to an identified or
identifiable natural person. “Personal data” does not include de-identified data or publicly available
information.
“Sale of personal data” means the exchange of personal data for monetary consideration.
If this definition of “Consumer” set forth above applies to you, we must adhere to certain rights and obligations regarding your personal data.
The information we collect, use, and disclose about you will vary depending on how you interact with us and our Platform. To find out more, please see Section 3, Section 4, and Section 6.
How we use your personal data
When and with whom we share your personal data
Your rights with respect to your personal data.
Right to be informed whether or not we are processing your personal data
Right to access your personal data
Right to correct inaccuracies in your personal data
Right to request deletion of your personal data
Right to obtain a copy of the personal data you previously shared with us
Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of
personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects
(“profiling”)
We have not sold any personal data to third parties for business or commercial purposes. We will not sell personal data in the future belonging to website visitors, users, and other consumers.
Exercise your rights provided under the Virginia CDPA.
More information about our data collection and sharing practices can be found in this Privacy Policy.
You may contact us by email at support@circadia.health, by visiting circadia.health, or by referring to the contact details at the bottom of this document.
If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
Verification Process.
We may request that you provide additional information reasonably necessary to verify you and your consumer's request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.
Upon receiving your request, we will respond without undue delay, but in all cases, within forty-five
(45) days of receipt. The response period may be extended once by forty-five (45) additional days
when reasonably necessary. We will inform you of any such extension within the initial 45-day
response period, together with the reason for the extension.
Right to Appeal.
If we decline to take action regarding your request, we will inform you of our decision and reasoningbehind it. If you wish to appeal our decision, please email us at support@circadia.health. Within sixty
(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. If your appeal
is denied, you may contact the Attorney General to submit a complaint.
DO WE MAKE UPDATES TO THIS NOTICE?
If you have questions or comments about this notice, you may email us at support@circadia.health or contact us by post at:
Circadia Health, Inc.
507 S Douglas St, El Segundo, CA 90245HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please visit circadia.health.
