2. PERSONAL INFORMATION WE COLLECT
The categories of personal information we collect, with your consent, depend on how you interact with us, our Services, and the requirements of applicable law. For example, we may collect different information depending on whether you are a patient or visitor to our website. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.
Information You Provide to Us Directly
We may collect the following personal information that you provide to us.
We may collect the following personal information that you provide to us.
Automatic Data Collection Through Our Services. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services.
Location Information. When your device settings allow us to do so, we may collect your precise location information to provide you with enhanced Services. If you do not want us to collect this information, you can change the settings on your device.
Cookies. Cookies are small text files placed in device browsers that store preferences and facilitate and enhance your experience.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded. Our uses of these Technologies fall into the following general categories:
Operationally Necessary This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity, improve security, or allow you to make use of our functionality;
Performance-Related We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services;
Functionality-Related We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
Advertising- or Targeting-Related We may use first party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
Analytics. We may use Technologies and other third-party tools to process analytics information on our Services. Some of our analytics partners include:
C. Biometric Information
Within the context of healthcare, your Healthcare Provider may order labs and collect biometric information (such as blood and saliva samples). Your biometric information may be stored in your medical records and accessed by Healthcare Providers and other third-party providers in order to perform the Services. From time to time, we may ask you to consent to the sharing of this information for medical research when legally required. Where required by law, we will delete your biometric information within the required time under the applicable law unless we have your permission to retain it for longer.
D. Information Collected from Other Services
We may obtain information about you from other sources, including through third-party services and organizations. For example, if your Healthcare Provider enrolls you in our Services, they may provide your name, date of birth, contact information, and email address in order to send you an invitation to establish a Patient Account. We may also obtain information related to your medical history through your Healthcare Provider. We may also obtain information from a patient, for example if they list you as their emergency contact or caregiver.
3. HOW WE USE YOUR INFORMATION
We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
A. Provide Our Services
We use your information to fulfill our contract with you and provide you with our Services, such as:
B. Administrative Purposes
We use your information for various administrative purposes, such as:
C. Marketing and Advertising our Products and Services
We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.
Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based“ or “personalized advertising,“ including through cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us“ below.
D. Other Purposes
We also use your information for other purposes as requested by you or as permitted by applicable law.
4. HOW WE DISCLOSE YOUR INFORMATION
We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.
A. Disclosures to Provide our Services
The categories of third parties with whom we may share your information are described below.
B. Disclosures to Protect Us or Others
We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others' rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.
C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
5. YOUR PRIVACY CHOICES AND RIGHTS
Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.
6. SECURITY OF YOUR INFORMATION
By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system's breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.
7. INTERNATIONAL DATA TRANSFERS
All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.
8. RETENTION OF PERSONAL INFORMATION
9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA“). While we are not subject to the CCPA, we provide the below information to provide insight into our privacy practices. The CCPA provides California residents with the right to know what categories of personal information Tono has collected about them and whether Tono disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:
Category of Personal Information Collected by Tono
Category of Third Parties Information is Disclosed to for a Business Purpose
A real name, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))
A name, signature, physical characteristics or description, address, telephone number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Protected classification characteristics under California or federal law
Age (40 years or older), medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), genetic information (including familial genetic information).
Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Physiological, biological, or behavioral, characteristics (including DNA) that can be used to establish individual identity, and rhythms, gait patterns, or rhythms, and sleep, health or exercise data that contain identifying information.
Internet or other electronic network activity
Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.
Physical location or movements.
Audio, electronic, visual, thermal, olfactory, or similar information.
Professional or employment-related information (from Healthcare Providers)
Current or past job history.
Inferences drawn from other personal information to create a profile about a consumer
Profile reflecting a consumer's characteristics, psychological trends, behavior, abilities, and aptitudes.
The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect“ and “How We Use Your Personal Information“ above, respectively.
“Sales“ of Personal Information under the CCPA
For purposes of the CCPA, Tono does not “sell“ personal information, nor do we have actual knowledge of any “sale“ of personal information of minors under 16 years of age.
Tono does not have actually knowledge of any “sale“ of persona information of minors under 16 years of age.
Additional Privacy Rights for California Residents
Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.
Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us“ below and provide written authorization signed by you and your designated agent.
Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.
If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us“ below. We will process such requests in accordance with applicable laws.
Right for minors to remove posted content. Where required by law, California residents under the age of 18 may request to have their posted content or information removed from the publicly-viewable portions of the Services by contacting us directly as set forth in “Contact Us“ below.
10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us at Info@Tonohealth.com with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Information as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.
11. CHILDREN‘S INFORMATION
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children, except where we have parent's verifiable consent.
If you are a parent or guardian and wish to review information collected from your child, or have that information modified or deleted, you may contact us as described in “Contact Us” below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child's account if applicable.
12. OTHER PROVISIONS
Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.
13. CONTACT US
90 Furman, 801
Brooklyn, NY 11201