To the extent we provide you notice of different or additional privacy policies or practices, those additional terms shall govern such data collection and use.
1. What Information Does the App Collect?
(a) Information You Provide to Us
On the App, we may ask you to provide certain categories of information such as: (1) demographic and personal identifiable information, which is information that identifies you personally, such as your first and last name, age, gender email address, zip code, and phone number, and health insurance information (“Personal and Demographic Information”); and (2) information about your health (e.g., history of disease, menstrual cycle) and information about the medications you are taking (e.g., current medications, current and past birth control methods) (“Health Information”) (“Personal and Demographic Information” and “Health Information” are referred to collectively herein as “Your Information”). In connection with the App, we may collect Your Information in the following ways:
- Through forms filled out by a user on the App.
- Through information provided by a user in connection with any services offered on the App.
- Through surveys, polls, blogs and postings and submissions.
(b) Information We Collect and Store As You Access and Use the App
In addition to Your Information or other information that you choose to submit to us via our App, we and our third-party service providers may use a variety of technologies that automatically (or passively) collect and store certain information whenever you visit or interact with the App (“Usage Information”). This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, tablet, or mobile phone (collectively referred to herein as your “Device”) whenever you visit or interact with our App. Usage Information may be non-identifying or may be associated with you. Whenever we associate Usage Information with Your Information, we will treat it as Your Information. This Usage Information may include:
- your Device functionality (including browser, operating system, hardware, mobile network information);
- the areas within our App that you visit and your activities there, including remembering you and your preferences; and
- certain other Device data, including the time of day, among other information.
We may use various methods and technologies to collect and store Usage Information (“Tracking Technologies”). For example, we use “embedded scripts.” An embedded script is programming code that is designed to collect information about your interactions with the App, such as the links you click on. The code is temporarily downloaded onto your Device from our web server or a third party service provider, is active only while you are connected to the App, and is deactivated or deleted thereafter. We may use Tracking Technologies for the following purposes:
- Performance-Related. We may use Tracking Technologies that are useful in order to assess the performance of the App, including as part of our analytic practices or otherwise to improve the content, products or services offered through the App.
- Functionality-Related. We may use Tracking Technologies that are required to offer you enhanced functionality when accessing the App, including identifying you when you visit our App or keeping track of our specified preferences, including in terms of the presentation of content on our App.
(c) Interactions with Third Party Services
(d) California Do Not Track Disclosures
Various third parties are developing or have developed signals or other mechanisms for the expression of consumer choice regarding the collection of information about an individual consumer’s online activities over time and across third-party web sites or online services (e.g., browser do not track signals). Currently, we do not monitor or take any action with respect to these signals or other mechanisms.
2. How Do We Protect the Information Collected?
We understand that protecting Your Information is important and endeavor to incorporate commercially reasonable safeguards to help protect and secure Your Information, including encrypting Your Information while it is at rest and in transit. In addition, we store your Health Information on a separate server than your Personal and Demographic Information (i.e., your Health Information is not linked to your name or other identifiers while this information is stored on the server). However, no data transmission over the Internet, mobile networks, wireless transmission or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use our App and provide us with your information at your own risk.
3. How Do We Use the Information Collected?
We may use Your Information or Usage Information for various purposes. use of Your Health Information :
- to provide you with information such as to send you electronic newsletters or to provide you with special offers or promotional and marketing materials on behalf of us or third parties;
- to enable you to participate in a variety of the App’s features;
- to improve the App, or our App offerings;
- to provide customer support;
- to contact you with regard to your use of the App and, in our discretion, changes to the App and/or App’s policies;
- to improve the overall experience of the App;
- for internal business purposes; and
4. How and When Do We Disclose Information to Third Parties?
(a) When You Request Information From or Provide Information to Third Parties.
You may be presented with an option on our App to receive certain information and/or marketing offers directly from third parties or to have us send certain information to third parties or give them access to it. If you choose to do so, Your Information and other information may be disclosed to such third parties and all information you disclose will be subject to the third-party privacy policies and practices of such third parties. In addition, third parties may store, collect or otherwise have access to your information when you interact with their Tracking Technologies, content, tools apps or ads on our App or link to them from our App. This may include using third party tools such as Facebook, Twitter, Pinterest or other third-party posting or content sharing tools and by so interacting you consent to such third party practices. It may also include ordering or purchasing products from third parties through us where we indicate that the third party rather than us is the seller. We are not responsible for the privacy policies and practices of such third parties and, therefore, you should review such third party privacy policies and practices of such third parties prior to requesting information from or otherwise interacting with them.
(b) Third Parties Providing Services on our Behalf.
We may use third-party vendors to perform certain services on behalf of us or the App, such as: (i) to assist us in App operations; (ii) to manage a database of customer information; (iii) hosting the App; (iv) designing and/or operating the App’s features; (v) tracking the App’s activities and analytics; (vi) enabling us to send you special offers or perform other administrative services; and (vii) other services designed to assist us in maximizing our business potential. We may provide these vendors with access to user information, including Device Identifiers, only as necessary to carry out the services they are performing for you or for us. Third-party analytics and other service providers may set and access their own Tracking Technologies on your Device and they may otherwise collect or have access to information about you, potentially including Your Information. We are not responsible for those third party technologies or activities arising out of them. However, some may offer you certain choices regarding their practices, and information we have been informed of regarding such choices is available in Section 5 below. We are not responsible for the effectiveness of or compliance with any third parties’ opt-out options.
(c) Administrative and Legal Reasons.
(d) Affiliates and Business Transfer.
We may share your information, including your Device Identifiers and Your Information and Usage Information with any parent, subsidiaries and affiliates. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner or operator of the App or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, including, during the course of any due diligence process.
(e) Imminent Danger.
We may call 911 when it appears as though a user presents an imminent threat of harm to himself/herself or to others and will provide first responders with Personal Information about the user as requested.
5. Do Third-Party Content, Links to Third-Party Apps and/or Third-Party Apps Appear on the App?
The App may contain content, links or apps that are supplied by a third party, and those third parties may collect Usage Information and your unique device identifier when pages from the App are served to you for their own commercial purposes. In addition, when you are on the App you may be directed to other apps and apps that are operated and controlled by third parties that we do not control. We are not responsible for the data collection and privacy practices employed by any of these third parties or their apps or apps and they may be tracking you across multiple online services and may be sharing the results of that tracking with us and/or others. These third parties may have their own terms of service, privacy policies or other policies and ask you to agree to the same. For example, if you “click” on a link, the “click” may take you off the App onto a different location. These other online services may associate their Tracking Technologies with you, independently collect information about you, including Personal Information, and may or may not have their own published privacy policies. We are not responsible for these third-party privacy policies or the practices of third-party owners. Be sure to review any available policies before submitting any personally identifiable information to a third-party application or otherwise interacting with it and exercise caution in connection with these applications. We also encourage you to note when you leave our App and to review the third-party privacy policies of all third-party locations and exercise caution in connection with them.
6. How Do I Change My Information and Communications Preferences?
8. Your California Privacy Rights
This section applies to any California residents about whom we have collected personal information from any source, including through your use of the App, by using our services, or by communicating with us electronically, in paper correspondence, or in person (collectively, “you”).
For purposes of this section, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer/resident or household.
(a) What Information We Collect
We may collect the following categories of personal information about you:
- Identifiers, which includes your first and last name; phone number; email address; postal address; and Internet Protocol (“IP”) address;
- Information relating to Internet activity or other electronic network activity, which includes cookie identifiers; pixel tags; UTM codes; date and time stamps; and information regarding your device such as browser name, operating system, hardware, and mobile network information;
- Audio, electronic, or visual information, which includes records of calls to or from our customer service centers;
- Information related to characteristics protected under California or federal law; which includes age and/or date of birth; and gender, gender identity, and preferred pronouns; and
- Other personal information not listed above and defined in California’s customer records law, which may include health insurance information, geolocation data and inferences based on the above personal information.
(b) What We Do With Your Information
We may collect or use personal information about you for the following business or commercial purposes:
- To create and manage your account
- To facilitate our mailing list and electronic newsletters
- To send you recommendations, special offers or promotions, and other relevant information via email or other means of communication
- To facilitate a payment transaction[RB8]
- To provide you with information about our products and services, and other opportunities that we believe may be of interest to you
- To provide customer support and otherwise manage our customer relationships
- For website and App optimization and maintenance
- For internal business purposes, including financial reporting and accounting
- For systems and data security
- To comply with our legal obligations, respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims
(c) Sources of Collected Information
We may collect personal information from the following categories of sources:
- Directly from you, including via our website and App, as well as via email, telephone, text message, postal mail, surveys, polls, blogs and postings, submittals, social media, forums, message boards, chatbot, or other means;
- Directly from another user] in connection with any services offered on the App;
- Via our business partners and other third parties, such as social media platforms that we link to.
(d) Who We Share Information With
We do not sell personal information, and do not otherwise share personal information unless it is necessary for our services providers and vendors in order for them to render services to Tia for the purposes described in Section 8(b) above.
As with most consumer-facing businesses with an online presence, we do share a limited set of data that is gathered when you visit our App, such as cookies and pixels, with third parties in order to allow you to see tailored digital advertisements. For more information about our collection and use of these and related tracking technologies, please see our disclosures regarding Tracking Technologies in Section 1(b) above. To the extent this activity is interpreted as included in California’s broad definition of “data sale”, we have provided you with opt-out rights as to that activity as described in Section 8(f) below.
In the last twelve (12) months, we’ve disclosed the following personal information to the following categories of third parties:
Categories of Personal Information Disclosed for a Business Purpose:
Information relating to Internet activity or other electronic network activity
Categories of Third Parties Disclosed To:
Interest-based advertising companies
(e) Your Privacy Rights
If you are a California resident, subject to applicable law, you have the following rights under California law with respect to your personal information:
- Right to Know. You have the right to request what personal information we collect, use, disclose, and/or sell, as applicable.
- Right to Delete. You have the right to request the deletion of your personal information that is collected or maintained by us.
- Right to Opt-Out of Sale. You have the right to opt-out of the sale of your personal information by us. While we do not sell your personal information, we do share a limited set of data with third parties in order to allow you to see tailored digital advertisements and have provided instructions how you may opt-out of such sharing in Section 8(f) below.
- Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.
The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the individual about whom we have collected personal information. In order to verify you, you must provide us with your [full name; email address; App or account username; telephone number; and/or other verifiable information]. These rights are also subject to various exclusions and exceptions under applicable laws.
You may also authorize someone to exercise the above rights on your behalf. If you wish to authorize someone to exercise the above rights on your on your behalf Tia requires a power of attorney that can be submitted at email@example.com
We currently do not collect household data. If we receive a request submitted by all members of a household, we will individually respond to each request. We will not be able to comply with any request by a member of a household under the age of 13, as we do not collect personal information from any person under the age of 13.
We will respond to your request within forty-five (45) days after receipt of a verifiable request for a period covering twelve (12) months and for no more than twice in a twelve-month period. Tia reserves the right to extend the response time by an additional forty-five (45) days when reasonably necessary and provided consumer notification of the extension is made within the first forty-five (45) days.
If you are a California resident and wish to seek to exercise these rights, please reach us in one of the following ways:
- Call us toll-free at +1.855.586.1306
- Email us at firstname.lastname@example.org
- Mail to 548 Market St., Ste. 45295, San Francisco, CA 94104
(f) Notice of Right to Opt-Out
We do not sell your personal information. If you wish to opt-out of our sharing of the limited data that is gathered when you visit our website or App for purposes of targeted digital advertising, we encourage you to utilize a cookie management tool such as https://privacybadger.org/ (https://privacybadger.org/) and visit the Network Advertising Initiative (https://optout.networkadvertising.org/?c=1) and/or the Digital Advertising Alliance’s Self-Regulatory Program (https://optout.aboutads.info/?c=2&lang=EN) for Online Behavioral Advertising for more information about opting out of seeing targeted digital advertisements. You may also visit these websites for more information on how you can opt back in to the sharing of data. Please note that Tia does not maintain this web tracking data in an identifiable manner. We will continue to update our business practices as direct regulatory guidance becomes available.
(g) California “Shine the Light” Law
California Civil Code § 1798.83 permits California residents who have supplied personal information (as defined in the law) to us to, under certain circumstances, request and obtain certain information regarding our disclosure, if any, of personal information to third parties for their direct marketing purposes. We do not disclose this type of personal information to third parties for their own purposes. However, if you are a California resident and would like to inquire further, please provide sufficient information for us to determine if this applies to you, attest to the fact that you are a California resident and provide a current California address for our response. To make such a request (limit one request per year), please send an email to: email@example.com with “California Privacy Rights” as the subject line or mail us a letter to: 548 Market St., Ste. 45295, San Francisco, CA 94104 . You must include your full name, email address, and postal address in your request.
9. Contact Us
- Call us toll-free at +1.855.586.1306
- Email us at firstname.lastname@example.org
- Mail to 548 Market St., Ste. 45295, San Francisco, CA 94104