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Privacy Policy

Last Updated on July 31, 2020

I. General
Komodo Health, Inc. and its affiliates (collectively, “we,” “our,” “us,” or “Komodo Health”) are committed to protecting your privacy and Personal Information (as defined below) about you. This Privacy Policy is intended to describe our practices regarding information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household (collectively “Personal Information.”) relating to visitors to the Komodo Health website (www.komodohealth.com, the “Site”), our customers, and prospective customers (“you” or “your”), for what purposes Personal Information may be used, and with whom we may share Personal Information.

II. What Personal Information Do We Collect?
a) When You Communicate With Us
When you communicate with us in and through the Site, email us, or otherwise communicate with us, we collect the following identifiers or professional information that may, alone or in combination with other information, constitute Personal Information:

  • Name;
  • Employer;
  • Job title;
  • Contact information such as email address and phone number; and
  • Content of communications sent to us.
b) When You Request Information From Us
When you use the “Contact” or “Request A Demo” functions on the Site, we collect the following identifiers or professional information that may, alone or in combination with other information, constitute Personal Information:
  • Name;
  • Company name;
  • Job title;
  • State/region;
  • Contact information such as email address and phone number; and
  • Which of our data products and services (collectively, our “Services”) may interest you.
c) When We Collect Provider Information
In connection with our Services, we collect the following professional information or identifiers about health care providers from third party sources. Some of this information may, alone or in combination with other information, constitute Personal Information:
  • Name;
  • Company name;
  • Job title;
  • National Provider Identifier (NPI); and
  • Contact information such as email address, office address, fax number and phone number.
d) Requesting Provider Correction and Appeal
If you use the Provider Correction and Appeal Request form available through https://www.komodohealth.com/provider-correction-and-appeal-request you must provide:
  • Name;
  • Organization;
  • NPI;
  • Contact information such as email address and phone number; and
  • Correction Request Details.
e) Professional or Employment-Related Information
If you approach us with respect to our career opportunities, we collect the following professional or employment-related information that may, alone or in combination with other information, constitute Personal Information:
  • Name;
  • Contact information such as email address and phone number;
  • Personal Information included in the resume/cv and cover letter; and
  • Personal Information included in your public LinkedIn profile.
f) Customer Data
If you are a representative of our customer company or a prospective customer company, we collect the following identifiers or professional information that may, alone or in combination with other information, constitute Personal Information:
  • Name;
  • Contact information such as email address and phone number;
  • Company name;
  • Job title and/or function (e.g. “Field Medical”);
  • Account user ID;
  • Password; and
  • Account use session ID
g) Internet Activity Information
Software used on the Site collects Internet or other electronic network activity information that may, alone or in combination with other information, constitute Personal Information:
  • The domain from which you access the Site;
  • The type of browser and operating system used in the device you use to access the Site;
  • Internet Protocol (IP) address;
  • The date and time you visited the Site (time stamp);
  • The pages browsed on the Site;
  • The website used to link to the Site from;
  • Any search terms used to navigate the Site;
  • The language used in browsing the Site in social media applications;
  • A browsing session ID ; and
  • Whether you are a first time visitor to the Site.

Google Analytics is an element of the Site. By using cookies, Google Analytics collects and stores data such as time of visit, pages visited, time spent on each page of the Site, the Internet Protocol address, and the type of operating system used in the devices used to access the Site. By using a browser plugin available at http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.

III. The Sources of Personal Information
In the last 12 months, we have collected Personal Information from the following categories of sources:

  • You: When you voluntarily provide Personal Information to us;
  • Software: Information automatically collected via cookies, web logs, web beacons, and other software-based analytics tools; and
  • Commercial partners: Information obtained from our data licensors and commercial partners, including commercial data aggregators.
  • Commercial resources: other commercially available resources, such as medical publications.
IV. Why We Collect Personal Information About You
We use Personal Information about you for the following purposes:
  • To operate and improve our Site, including through analytics to help us understand how you use the Site, so that we can present content in the best manner;
  • To provide the Services to you;
  • To develop and improve our Services;
  • To provide you with any information that you request from us. If you do not provide us with the information we need to respond to your request, we may not be able to provide you with the information that you request from us;
  • To notify you about changes to the Site and our Services;
  • To enable us to issue a notice, administrative, or corrective action to you in relation to the Site or the Services, if required;
  • To send you direct marketing messages that you have consented to receive;
  • To protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;
  • To comply with applicable legal requirements, industry standards, and our own policies;
  • Where permitted by law, to provide you with information about other products and services we offer that are similar to those that you have already subscribed to or enquired about and we feel may interest you.

V. How We Disclose Personal Information
In the past 12 months we have disclosed the following categories of Personal Information with the following categories of third parties for business purposes:

Category of Personal Information

Category of Third Party

  • Identifiers or professional information
  • Professional or employment-related information
  • Internet activity information

Our affiliates (such as subsidiaries that we own)

  • Identifiers
  • Professional or employment-related information
  • Internet activity information

Service providers: We use service providers such as data storage and data analysis companies and marketing technology companies. Such service providers can only use Personal Information to provide such services to us and for no other purpose.

  • Professional information

Our customers

  • Identifiers
  • Professional or employment-related information
  • Internet activity information

Parties to a corporate transaction or proceeding: In the event of a corporate sale, merger, reorganization, bankruptcy, dissolution or similar event, Personal Information may be part of the transferred assets.

  • Identifiers
  • Professional or employment-related information

Public authorities and legal proceedings: Komodo Health may disclose Personal Information about you to government or law enforcement officials or private parties as required by law, and disclose and use such information as we believe necessary or appropriate to (a) comply with applicable laws and lawful requests and legal process, such as to respond to subpoenas or requests from government authorities; (b) enforce the terms and conditions that govern the Site and/or the Services; (c) protect our rights, privacy, safety or property, and/or that of you or others; and (d) protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity.

 

VI. California Privacy Rights
a) Introduction
If you are a California resident you may also have the right:

  • To request disclosure of the categories and specific pieces of Personal Information collected about you;
  • To request the disclosure of the business purpose for collecting or selling Personal Information; the categories of third parties with whom it is shared, and the categories of sources from which Personal Information is collected;
  • To request the deletion of Personal Information, subject to the limitations set forth in California Civil Code Section 1798.105(d);
  • not to be discriminated against for exercising the rights guaranteed by California Civil Code Section 1798.100 et seq.

For a list of categories of Personal Information collected and the purposes for the processing of that Personal Information, please refer to Sections II and IV above.

b) Requests to Know
You have the right to request that we disclose:
  • The categories of Personal Information we collect;
  • The categories of Personal Information we have sold or disclosed for a business purpose;
  • The categories of sources from which we collect Personal Information about you;
  • Our business or commercial purpose for selling or collecting Personal Information;
  • The categories of Personal Information sold or shared about you, as well as the categories of third parties to whom the Personal Information was sold, by category of Personal Information for each party to whom information was sold;
  • The specific pieces of Personal Information collected about you.

Delivery may take place electronically or by mail. We are not required to respond to requests relating to Personal Information more than twice in a 12-month period.

c) Requests to Delete
With certain exceptions, you have the right to request that we delete any Personal Information we have collected about you. Upon receiving a verified request to delete Personal Information about you, we will do so unless otherwise authorized by law.

d) Verifiable Requests
We will acknowledge the receipt of requests to know or requests to delete Personal Information free of charge, within 10 business days. In order to protect your privacy and the security of Personal Information, we may verify your request by asking you to provide additional Personal Information for us to verify your identity. We will respond to your request within 45 calendar days of receipt, provided that we have been able to successfully verify your identity.

You may submit a request to know or a request to delete Personal Information via (888) 919-1959 or Request for Access.

e) Sale of Personal Information
In the last 12 months, we have not sold Personal Information collected in and through the Site or Personal Information relating to our customers. With respect to our practices relating to Personal Information collected and used as an element of our Services, we sell the following categories of Personal Information concerning specific health care providers:
  • Identifiers or professional information including name, business address, and contact information;
  • Professional or employment-related information such as field of specialty; associated patient outcomes.

If you would like to opt-out of the sale of your information, you may submit an opt-out request via (888) 919-1959 or Request for Deletion.

f) The Right to Non-Discrimination
You have a right not to receive discriminatory treatment for the exercise of your California privacy rights.

g) Authorized Agents
You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

VII. Privacy Rights under the EU General Data Protection Regulation 2018 (Regulation (EU) 2016/679) (the “GDPR”)
a) GDPR. The GDPR is a European Union regulation which protects the rights of data subjects in the European Economic Area (EEA), with respect to the processing of their “personal data,” as such term is defined in the GDPR.

b) Legal Basis for Processing. Komodo Health will process personal data only if and to the extent that at least one of the following applies:

  • i. The processing is necessary for the purposes of the legitimate interests pursued by Komodo Health;
  • ii. The processing is necessary for the performance of a contract to which you are a party;
  • iii. You have given consent to the processing of your personal data for a specific purpose;
  • iv. The processing is necessary for Komodo Health’s compliance with a legal obligation.

c) International Data Transfers. If you are located within the EEA when you visit our Site or Services, we may transfer your personal data outside of the EEA. When we do, we will ensure that an adequate level of protection is provided for the information.

d) GDPR Privacy Rights. If you are a resident of the European Union, you have certain data protection rights under the GDPR. In certain circumstances, you have the following rights:

  • Right of access. The right to obtain access to your personal data.
  • Right of rectification. The right to correct inaccurate personal data that Komodo Health has concerning you.
  • Right of erasure. Also known as the “right to be forgotten”, the right to require Komodo Health erase your personal data under certain circumstances.
  • Right to portability. The right to copy or transfer your personal data under certain circumstances.
  • Right to restrict processing. The right to restrict processing of personal data.
  • Right to object to processing. The right to object to processing of personal data for certain purposes.

If you wish to exercise one of these rights, please contact us at trust-and-safety@komodohealth.com and include materials verifying your identity when submitting your request.

VIII. Security
We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information. Despite our efforts to store Personal Information in a secure operating environment that is not available to the public, we cannot guarantee the security of Personal Information during its transmission or its storage on our systems. Further, while we attempt to ensure the integrity and security of Personal Information, we cannot guarantee that our security measures will prevent malicious third-parties from illegally obtaining access to Personal Information. We do not warrant or represent that Personal Information about you will be protected against, loss, misuse, or alteration by third parties.

IX. Data Retention
Personal Information is only kept for as long as needed for the purposes described in this Privacy Policy and for our legitimate business purposes, after which it is destroyed in accordance with Komodo Health’s document retention policies.

X. Links to Other Websites
The Site may contain links to other websites of interest. However, once you have used these links to leave the Site, we do not have any control over third party websites. We cannot be responsible for the protection and privacy of any Personal Information which you provide when visiting such sites and external sites are not governed by this Privacy Policy. You should exercise caution and review the privacy policy applicable to any website in question.

XI. Children
The Site and the Services are not intended for children under the age of 18. Accordingly, we do not intend to collect Personal Information from anyone we know to be under 18 years of age. We do not intentionally collect, sell, or process the Personal Information of individuals under 18 years of age.

XII. How Do We Use Cookies?
Some of the features on the Site require the use of "cookies" - small text files that are stored on your device's hard drive. We use cookies to measure which pages are being accessed, and which features are most frequently used. This enables us to continuously improve the Site to meet the needs of our visitors.

The following sets out how we may use different categories of cookies and your options for managing cookie settings:

Type of Cookies

Description

Managing Settings

Required cookies

Required cookies enable you to navigate the Site and use its features, such as accessing secure areas of the Site and using our Services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. These cookies allow us to uniquely identify you when you are logged into the Site and to process your online transactions and requests.

Because required cookies are essential to operate the Site, you may not be able to use all or parts of our site if you block required cookies.

Performance cookies

These cookies collect information about how you use the Site, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. Information is only used to improve how the Site functions and performs. From time to time, we may engage third parties to track and analyze usage and volume statistical information relating to individuals who visit the Site. We may also utilize Flash cookies for these purposes.

To learn how to opt out of performance cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.

Functionality cookies

Functionality cookies allow the Site to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of the Site after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on the Site to personalize your visit.

To learn how to opt out of functionality cookies using your browser settings, click here. To learn how to manage privacy and storage settings for Flash cookies, click here.

 

XIII. How We Respond to Do Not Track Signals
California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently isn’t an industry or legal standard for recognizing or honoring DNT signals, we don’t respond to them at this time.

XIV. Changes to This Notice
This Privacy Policy may change from time to time, effective from the date mentioned in the updated version of the Privacy Policy. You can tell when this Privacy Policy was last updated by reviewing the Last Updated legend at the top of this page. Please check the Site periodically to review such changes in the Privacy Policy.

XV. Contact Us
If you have any questions or concerns about this Privacy Policy or about our privacy or data security practices, or if you believe that your personal data is not handled in accordance with applicable law or this Privacy Policy, you may contact the Data Protection Officer (1) by telephone at (888) 919-1959, (2) electronically by email at trust-and-safety@komodohealth.com, or (3) by mail to the following addresses:

USA Headquarters

Komodo Health, Inc.
680 Folsom Street, 5th Floor
San Francisco, CA 94017
USA

Europe (For GDPR Related Inquiries Only)

Osano International Compliance Services Limited
ATTN: EVM9
25/28 North Wall Quay
Dublin 1, D01 H104
IRELAND