Privacy Policy

Introduction

Almond Digital Health, Inc. (“Company” or “We”) respect your privacy and are committed to protecting it through our compliance with this policy. This policy describes: the types of information that we may collect or receive when you download, access or use the [name of application] (the “App”); our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect in this App[, in email, text, and other electronic communications in connection with this App]. This policy DOES NOT apply to: the information that is collected offline, at websites other than the Company website for downloading the App, including websites you may access through this App; or the information that you provide to or is collected by any third-party service provider.

Please read this policy carefully to understand our policies and your right regarding your information. If you do not agree with our policies and practices such as this privacy policy, do not download, register with or use this App. By downloading, creating an account at, or using this App, you indicate that you have read the terms of use that applies to the App, you accept and consent to this privacy policy. This policy may change from time-to-time. Your continued use of this App after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. CHILDREN

We do not offer the App to be used for children, and we do not collect personal information from children. If we learn we have collected or received personal information, we will delete that information. If you believe we might have any information from or about a child, please contact us at [contact information].

2. INFORMATION WE RECEIVE

We may receive or collect information from and about users of the App, including:

i. Protected Health Information, including mental health information; 

ii. Identifiable Health Information;

iii. Unidentifiable Health Information;

iv. Aggregated Information

v. Personal Information including the following;

• Language
• Unique Username
• Password
• Email
• Zip code
• Date of Birth
• Pronouns (optional)
• Interests (optional)
• Notification preferences
• Information we receive about your feeling and habits about gambling   
• Documents you share with our professionals
• Information you share with us during our support for you

vi. Sensitive Personal Information.

• Demographic Information
• Sexual Orientation
• Religion
• Ethnicity 

Directly from you when you provide it to us explicitly or automatically when you use the App.

Indirectly, we may receive or collect information about the users’ families, healthcare providers, caretakers, insurers, including:

i. Protected Health Information; 

ii. Identifiable Health Information;

iii. Unidentifiable Health Information;

iv. Aggregated Information

v. Personal Information; 

vi. Sensitive Personal Information.

3. How Information Is Collected by Us

a. Information you provide.

When you download, register with or use this App, we may ask you provide information:

i. Information by which you may be personally identified, such as name, postal address, email address or telephone number (“personal information”) and information by which you may not be personally identifiable (“non-personal information”).

ii. Information that you provide by filling in forms in the App. 

iii. Information provided at the time of creating an account, during your use of the App’s functions and programs.

iv. Information that you exchange on a communication platform (needs more information if this is applicable) offered by the App.

v. Information that you provide when you request our assistance, intervention, or response. 

vi. Information conveyed through your search using the App. 

vii. Information that you provide by replying to questions, surveys, or inquiries about services related to the App and performance of the App. 

viii. Information conveyed through your correspondence, including email addresses and phone numbers, when you contact us.

ix. Information about your transaction carried out via the App, including your credit card information and other financial information.

x. Information that you signal to convey to multiple recipients or publish (“Post”) on public areas of websites you access through the App (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk and may or may not be secured. Please be aware that no security measures are perfect. We may not control technologies used by third parties with whom you may choose to share your User Contributions. 

b. Automatic collection of information.

When you download, access and use the App, certain technologies automatically collect or receive:

i. Usage Details and Service Data. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, internet service provider, referring/exit pages, operating system, time stamps. Information may be stored in log files location of data, and other communication data and the resources that you access and use on or through the App.

ii. Device Information. Information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, network and device information, and the device’s telephone number.

iii. Data Submitted from Device. The App also may receive metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts and address book information communicated from your device.

iv. Location Information. This App collects real-time information about the location of your device that may locate the user (usually, you) within several miles. 

If you do not want us to collect this information, do not use the app, or opt out where that option is provided. Note, however, that opting out of the App’s collection of location information will cause its location-based features to be disabled.

The technologies we use for automatic information collection may include:

i. Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting, you may be unable to access certain parts of our App.

ii. Web Beacons. Pages of the App may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

iii. Embedded scripts.

iv. Location tracking technologies.

v. Fingerprinting technologies.

vi. Device recognition technologies.

vii. Any other recognition technologies.

c. Third-party information collection

When you use the App or its content, certain third parties may use technologies to automatically retain or collect information about you or your device. These third parties include:

i. Advertisers, ad networks and ad servers.

ii. Analytics included in internet service providers and affiliated analytics companies.

iii. Your mobile service provider.

These third parties may use tracking technologies to receive and collect information about users. This may include information about the App users’ use of this App and other apps and websites to serve them interested-based (behavioral) advertising. We do not control the third parties’ tracking technologies or how they may be used.

4. Information we have collected in the previous 12 months

We have collected during the last 12 months and will collect information from and about users of our App:

i. Protected Health Information 

ii. Identifiable health information

iii. Personal Information

iv. Sensitive Personal Information

Directly from you when you provide it to us explicitly or automatically when you use the App.

Indirectly, we may receive or collect information about users’ families, healthcare providers, caretakers, insurers, including:

i. Protected Health Information; 

ii. Identifiable Health Information;

iii. Unidentifiable Health Information;

iv. Aggregated Information

v. Personal Information; 

vi. Sensitive Personal Information.

5. HOW WE USE YOUR INFORMATION

a. We use obtained information, including any personal information, after processing and securely storing data that are inputted from your device, automatically or consciously transmitted from your device, internet service providers (e.g., mobile application platforms), telecommunication providers, and third-party sites engaged to realize your use of the App, to:

i. Run programs on the App. 

ii. Give you access to contents, information.

iii. Provide products to you, and maintain and tailor our services to you.

iv. Activate your account.

v. Answer your questions and complaints in using the App.

vi. Troubleshoot issues, provide technical support to users, and perform customer service.

vii. Understand your use of the App and improve the App’s operation and the quality of our service. 

viii. Audit users’ compliance with the terms of use of the App and other terms and conditions.

ix. Fulfill any purposes for which you provide information such as registration with our services (matching with a professional, registration in an event, program, service).

x. Give you notices about your account and subscription, including expiration and renewal notices.

xi. Conduct clinical and other academic research. 

xii. Carry out our obligations under contracts and perform our services in accordance with the terms of use of the App. 

xiii. Protect and assist you in emergency.

xiv. Control safety and security of the App for users and us.

xv. Prevent misuse and mitigate any harm to you and us.

xvi. Enforce our rights arising from any contracts entered into between you and us, including for billing and collection of dues.

xvii. Notify you when App updates are available, of changes to any products or services we offer, of changes in the terms of use of the App.

xviii. Perform quality control.

xix. Comply with federal and state laws/regulations, respond to orders and demands from authorities.

xx. Maintain safety and security of our users, services, professionals, contractors, and us.

b. The information that has been obtained and processed at our App control system helps us to improve our App and to deliver a better and more personalized experience, after processing and securely storing data that are inputted from your device, automatically or consciously transmitted from your device, internet service providers (e.g., mobile application platforms), telecommunication providers, and third-party sites engaged to realize your use of the App, to:

i. Analyze trends of use to adjust the App and our services, by tracking visits to the App or the Company’s website.

ii. Estimate the volume of demand for use of the App and its pattern.

iii. Customize your experience of the App in accordance with your individual interests and preferences (profiling).

iv. Recommend and provide information about our services that you may like.

v. Deliver targeted advertising to you and provide information about your use of the App.

vi. Speed up your searches, improve our program/services, develop our products/services, control our programs/services.

vii. Recognize you when you use the App.

viii. Review and oversee our App system

ix. Your location information to improve your use.

x. We may also use your information to contact you about our and third parties’ goods and services that may be of interest to you.

If you do not want us to use your information in this way, you may opt out by contacting us at support@almonddigitalhealth.com 

c. Aggregated information and unidentifiable information.

We may use aggregated information and unidentifiable information (de-identified information) for operational purposes. The aggregated information and unidentifiable information may be used for maintaining, managing, and improving our services. We may share them for analysis, describing services to users and third parties, sharing with contractors, third parties, and their agents as much as legally permitted under the circumstances, and other business purposes.

d. Use in research

To perform research and improve our operations and better support you and other users, we may use information about you. In using your information for a research, we will aggregate information and your information will be de-identified. 

We will reach out to you to ask for your participation in surveys. Such surveys may ask you about: health; feeling; well-being; and use and experience of the services. You can decide whether you join it or you don’t.

We may share such information with third party partners. 

In performing research, we abide by laws and regulations. We will require third party partners to enter into a confidentiality agreement. If the research produces results that we intend to report or publish, the results will not show your information or your participation.

If you do not want us to use your information in this way, you may opt out by contacting us at support@almonddigitalhealth.com

6. DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users and other information that does not identify any individual (de-identified) without restriction.

In addition, we may disclose, share, and/or transfer your personal information, on a need-to-know basis:

i. To our subsidiaries, parent company, and affiliates.

ii. To contractors, service providers (entities whom we hire to perform certain business-related services, entities who provide data storage, information hosting, and disaster recovery), third parties involved in the operation of the App, and third parties working for us who owe identical confidentiality obligations to serve purposes specified in the previous section for which we use collected personal information.

iii. To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which information held by the Company about our App users is among the assets transferred.

iv. To third parties to market their products or services to you if you have not opted out of these disclosures. 

v. To third parties to use information for the third-party’s research, analysis, and product or service development.

vi. To disclose, share with, and/or transfer to third parties to use information for the third-party’s target advertising and marketing.

vii. To disclose, share with, and/or transfer to certain information to a recipient according to your instruction or consent. 

viii. For any other information use disclosed by us when you provide the information.

ix. To disclose, share with, and/or transfer to authorities to comply with any court order, law or legal process, including to respond to any government or regulatory request.

x. To disclose, share with, and/or transfer to contracting parties and their representative to exercise our rights arising from contracts controlling your use of the App, including the user agreement, and the terms of use of the App.

xi. When disclosure is necessary and appropriate to protect the rights, property, or safety of the Company, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

7. Information That You Publicly Shared 

You may share your personal information with others as User Contributions, including written consent, user profiles, etc. We may moderate User Contributions before they become published. Once they are published, anyone may access and use your User Contributions. Your information and privacy in the published content is not subject to this privacy policy and it may be used by us, other users, and third parties. You must be careful before making User Contributions.

8. Information that We Sold in the preceding 12 months 

We have not sold consumer PI in the preceding 12 months

9. Information that We disclosed in the preceding 12 months 

We have not disclosed consumer PI in the preceding 12 months

10. YOUR CHOICES ABOUT OUR COLLECTION, USE AND DISCLOSURE OF YOUR INFORMATION

To ensure you have the ability to control the use, disclosure, sale, or sharing of your personal information, the following mechanisms are available to you:

i. Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.

ii. Location Information. You can choose whether or not to allow the App to collect and use real-time information about your device’s location. If you block the use of location information some parts of the App may then be inaccessible or not function properly.

iii. Promotion by the Company. If you do not want us to use your contact information to promote our own or third parties’ products or services, you can opt-out by sending an email to support@almonddigitalhealth.com.

iv. Targeted Advertising by the Company. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by sending an email to support@almonddigitalhealth.com.

v. Third-party research, analysis, and product development. If you do not want us to share or sell your personal information with affiliated third parties, and unaffiliated or non-agent third parties for their business purposes, you can opt-out by sending an email to support@almonddigitalhealth.com.

vi. Disclosure, transfer, and sale of your information for third-party’s target advertising and marketing. If you do not want us to share your personal information with unaffiliated or non-agent third parties for advertising and marketing purposes, you can opt-out by sending an email to support@almonddigitalhealth.com.

vii. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

11. YOUR PRIVACY RIGHTS Under State Statutes

Some states (e.g., California Civil Code Section 1798.83) give state residents rights to access and correct personal information. You can review and change your personal information by logging into the App and visiting your account profile page. As long as relevant state privacy protection statues apply to you, you may access, obtain a copy of, correct, or delete your personal information, request limitations on the use of sensitive personal information, opt out from processing of your personal information for targeted advertising, opt out from sale, opt out from profiling or automated decision making, or request certain information regarding the collection, use, disclosure, sale, and/or sharing of personal information, by sending an email to [email address]. You can exercise state privacy rights without fear of discrimination. We will not discriminate against you for exercising any of their statutory privacy rights.

We will ask you to submit sufficient identification that shows your identity and/or the identity of an authorized agent before processing a request. We will then obtain your personal information, such as a government issued ID, to confirm your identity. Please note that a request for access may be limited to twice within a 12-month period.

We cannot delete your personal information unless we delete your user account. If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other App users. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

12. DATA SECURITY

We have implemented reasonable measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls. 

The safety and security of your information also depends on you and the device and services that you use. Where we have given you (or where you have chosen) a password for access to certain parts of the App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. The information you share in public areas may be viewed by any user of the App.

The transmission of information online and mobile platforms are subject to malicious attacks. Although we protect your personal information accordance with security standards prevalent at the time in the location of our App system, we cannot guarantee the security of your personal information through our measures. You agree to consider and assume the risk of security defects in transmission, collection, or retention of personal information relating to the App. We cannot take responsibility for circumventions of security measures that protect your information.

13. Use of Cookies and Web Beacons

a. We have implemented cookies and other tracking technologies, which recognize your browser and collect a preset range of information about you as described in Section 5. Your information such as IP address and a unique identifier of your device may be collected. We learn how you use our services, what site or page you access, where you access the App, how long you access the App, based on the collected information. We can improve our services, determine your interests, filter advertisements, propose contents to you, and fix glitches based on the collected information. 

b. Cookies are small files generated from web servers including our internet servers, and are sent to your device when you access a webpage. Some cookies originate from our website server, but others are generated by third parties. These entities are essential for our website to work properly and seamlessly. The cookies that come from us are called “first party cookies” and those from third parties are called “third party cookies.” Cookies interact with a web server to indicate your previous access to a webpage. Cookies may last longer than a few minutes or a few years. Cookis help the optimal operation of our website.

c. Web beacons count website visitors who come to our websites after seeing an add or banner on third party websites. Web beacons are employed on websites and do not usually monitor activities after visitors leave the websites. 

d. When you click on a link on our websites/the App to third party websites, services, applications, and platforms, cookies that track your online activities may be used by third parties. Once you are directed to third party websites, you are subject to the rules and the terms of use established by third parties, and no longer subject to this privacy policy. Third parties may share information that they obtained at their website with us according to their policies

e. We do not take any responsibility for and make no representations about the policies and business practices of third parties.

f. We do not recognize browser “do not track” signals. 

g. We have the following types of cookies on our websites.

i. Essential and strictly necessary: mandatory for the App to function

ii. Analytics: implemented to improve our services based on the information by tracking your access to the App, services, and other online contents. We may use service providers such as Mixpanel to analyze information. We may be able to deliver better service to you after analysis of the information through cookies.

iii. Advertising: enabled to gather information about your interest and online activities so that we can customize our promotions and services 

h. You can control cookies. By clicking setting from a dropdown menu of your browser, you may check what cookies and other programs are tracking your online activities and what information may be collected by them. If you wish to make changes to data tracking through cookies, you may select the level of data that cookies and other programs can track your online activities and the types of tracking programs allowed. You may refuse all the cookies. When you limit data tracking by cookies, your experience may not be optimal when you return online. You may need to reenter a password in some browsers. You can find more information at 

https://www.aboutads.info/choices, https://choice.live.com/AdvertisementChoice,

 https://youronlinechoices.eu/, https://aboutcookies.org. 

i. We may have the following kinds of cookies. 

The Company: User preferences

Record the cookies you choose to enable. Necessary cookie. Not designed to collect information other than this purpose.

Mixpanel: Ajs_user_id

Collect anonymous information about your use of the App to enhance our services. Analytic cookie.  

Segment: Ajs_anonymous_id

Collect anonymous information about a trigger of your access to understand visitor behaviors.

14. Data Retention

After we collect information about you, you may remove a part of your information that we control, by making selections at your account, or by contacting us. Generally, your information is retained for a certain period of time, based on the type of information, the terms of use of the App, and applicable law. Some of your information may be kept by us as long as it has not been removed and your account is maintained. We need to retain a set of information to perform our duties and achieve purposes for which it was collected, which may be modified in accordance with other necessities and principles. At the end of the retention period, we will remove information from our databases, and if applicable, we will ask third parties who had access to it to remove information from their databases. When information cannot be fully removed from our system, we will protect it per industry standards. We may keep anonymized data indefinitely. 

15. CHANGES TO OUR PRIVACY POLICY

We may update our privacy policy from time-to-time. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page.

The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting this privacy policy to check for any changes.

CONTACT INFORMATION

To contact us: support@almonddigitalhealth.com