PRIVACY NOTICE

Last Updated: November 2018

Circle Of Inc. respects your privacy. This Privacy Notice describes our practices in connection with the information collected through Circle Of (the “App”). By using the App, you agree to the terms of this Privacy Notice.

INFORMATION YOU PROVIDE

The App collects the personal information you choose to provide (“User Information”). This may include, for example:

  • Name
  • Email address
  • Disease type
  • Your physical symptoms, feelings and mood
  • Your medications and dosage
  • Appointments
  • Reminders
  • Notes you generate
  • Recordings from your physician, caregiver or yourself relating to your health
  • Insurance information
  • Information from your calendar or other files on your phone
  • Activity information generated through the use of your connected wearable
  • Demographic data

If you provide or permit us to collect any information relating to another person, you are telling us that you have the authority to do so and to permit us to use the information as described in this Privacy Notice.

We may combine the information you provide with information we receive about you from other sources, such as public databases, joint marketing partners, providers of demographic information, social media platforms, people with whom you are connected on social media platforms and other third parties.

HOW WE USE AND DISCLOSE THE INFORMATION YOU PROVIDE

The App is social. The information you choose to share with your supporters will be visible to them.

Generally, personal information you provide in all forms and media to this Software will be stored, in an encrypted format, in a database. Only photos, audio recordings, and text notes captured in the ‘Me’ section of the Software will be stored locally on your device.

If you choose to register with Circle Of the Personal Information associated with your registration for/opt-in to Circle Of ("Registration Data") will be transmitted to and will be used by Circle Of in accordance with the Privacy Policy posted on the Circle Of website. Personal Information other than the Circle Of Registration Data will not be provided to Circle Of.

Data collected from your activity tracker will be sent from your activity tracker application in order to make the activity calculations that are displayed in the App. Any activity and information collected by the activity tracker is collected pursuant to their Privacy Policy.

In addition, you have the option to manually input outcomes from your activities that you record with a personal fitness tracker that you would own or buy separately; however, that information will not automatically sync to this App. That activity tracker is operated by a third party and not subject to this Privacy Notice, but any data that we receive from the tracker in the App is subject to this Privacy Notice once we receive it.

You may choose to share reports and other messages generated by the App with others. If you choose to share the report, it will be sent to the person(s) you designate using the email functionality on your device. If you send messages within the application, it will only be visible to the supporters that you choose.

We may use the information you provide:

  • To provide the App’s functionality and related customer service to you.
  • To respond to your inquiries and fulfill your requests, such as to send you notifications and invitation code or password resets.
  • To send administrative information to you, such as information regarding the App and changes to our terms.
  • To send you marketing communications that we believe may be of interest to you.
  • To personalize your experience on the App, including by presenting curated content and other information about products and patient service offers tailored to you.
  • To facilitate social sharing functionality.
  • To allow you to send messages to another person, such as a caregiver or friend.
  • For our business purposes, such as data analysis; audits; fraud monitoring and prevention; developing new products; enhancing, improving or modifying our products and services; identifying usage trends; determining the effectiveness of our promotional campaigns; and operating and expanding our business activities.

We may disclose the information you provide:

  • To our affiliates for the purposes described in this Privacy Notice.
  • To our third-party service providers, to provide services such as data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing and other services.
  • To identify you to anyone to whom you send a message through the App.
  • When you post on message boards, chat, profile pages and blogs and other services to which you are able to post information and materials. Please note that any information you post may be available to other App users and the general public. Be careful when deciding to disclose any information through the App.
  • To your friends associated with your social media account, to other App users and to your social media account provider, in connection with your social sharing activity, such as if you connect your social media account to your App account or log into your App account from your social media account. By connecting your App and social media accounts, you authorize us to share information with your social media account provider, and you understand that the use of the information we share will be governed by the social media site’s privacy policy. If you do not want your information shared with other users or with your social media account provider, do not participate in social sharing.
  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings).

We may also use and disclose the information you provide as we believe to be necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities, including authorities outside your country of residence; (d) to enforce our terms and conditions; (e) to protect our operations, or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

We may aggregate the information that you and other App users provide. If we do, we may use and disclose such aggregated information for any purpose. Aggregated information does not personally identify you or any other user.

OTHER INFORMATION

We may use cookies and other technologies to recognize you as you use or return to the App so that we can understand how the App is used and personalize and enhance your experience. These technologies collect certain information automatically, such as:

  • Information about your device, such as your screen resolution, operating system, device manufacturer and model, language and browser type. We use this information to ensure that the App functions properly.
  • Information about your use of the App, including content viewed, features used and the dates and times of your interactions with the App. We use this information to understand how users engage with the App and to customize and improve the App experience.

We may use third-party services, such as Google Analytics, Adobe, and Facebook analytics tools, in connection with the App. Such services may use cookies and/or similar technologies to collect and analyze information about App use and to report on activities and trends. Such services may also collect information regarding the use of other websites, apps and online services. For more information regarding Google Analytics, please go to www.google.com/policies/privacy/partners/. To learn how Facebook may use the information it collects, please go to https://www.facebook.com/about/privacy/.

We may use and disclose the information described in this section for any purpose, except where we are required to do otherwise under applicable law. If we combine the information described in this section with information that is deemed “personal information” under applicable law, we will treat the combined information as “information you provide,” as described above, for as long as it is combined.

DO NOT TRACK

Do Not Track (“DNT”) is a privacy preference that users can set in their web browsers. When a user turns on DNT, the browser sends a message to websites requesting that they not track the user. At this time, Circle Of does not respond to these signals. For information about DNT, visit www.allaboutdnt.org.

THIRD-PARTY ADVERTISING

We may use third-party advertising companies to serve advertisements regarding goods and services that may be of interest to you when you access and use the App and other apps or online services, based on information relating to your access to and use of the App and other apps and online services. To do so, these companies may use cookies, web beacons, and other storage technologies. If you would like more information about this practice, please visit http://www.aboutads.info/. You may download the AppChoices app at www.aboutads.info/appchoices to opt out of this practice in mobile apps.

LOCATION INFORMATION

We may collect the physical location of your device by using, for example, satellite, cell phone tower, GPS or WiFi signals. We use your device’s physical location to provide you with location-based services and content. You may be able to allow or deny such collection and/or use through your device settings.

THIRD-PARTY SERVICES

This Privacy Notice does not address, and we are not responsible for, the information collection, use, disclosure or security practices, or other practices, of any third party, including any third party operating a service to which the App links. The inclusion of a link within the App does not imply our endorsement of the linked service.

INFORMATION SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect the information you provide to us. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us.

YOUR PRIVACY CONTROLS

You may stop all collection of information by the App by uninstalling the App. If applicable, you may stop the receipt of push notifications through your device settings.

USE BY MINORS

The App is not directed to individuals under the age of thirteen (13), and we do not knowingly collect personal information from such individuals. If you are at least 13 years of age but less than 18 years of age, you will need your parent’s or legal guardian’s permission to use the App. Please consult with your parent or legal guardian before installing the App.

CROSS-BORDER TRANSFER

The App is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. The information we collect through the App may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the App, you consent to the transfer of information to countries outside of your country of residence, including the United States, which may have different data protection rules than those of your country.

UPDATES

From time to time, we may update this Privacy Notice. Any changes will become effective when we post the revised Privacy Notice in the App. Your use of the App following these changes means that you accept the revised Privacy Notice. This Privacy Notice was last updated as of the “Last Updated” date shown above.

CONTACT US

Please contact us if you have any questions:

Circle Of Inc.
Privacy Officer

Privacyofficer@Circle Of.io