Privacy Policy

This Privacy Policy applies to visitors of the following publicly available websites: Clafiya.com, my.clafiya.com, wallet.clafiya.com.

For the purposes of this Disclaimer, "you" and "your" means you as the visitor of the Websites.

This Privacy Policy describes the types of Personal Information we collect from visitors of our public Websites and our practices for using, maintaining, sharing, and protecting it. It also describes the rights and choices you may have with respect to your Personal Information and how you may contact us.

This Privacy Policy does not apply to information collected from visitors who register and log-in ("Members") to the password-protected and secure portions of our sites, including login pages and registration pages ("Secure Platforms"). The Secure Platforms allow eligible Members to use Clafiya Services. All information collected and stored by Clafiya or added by our Members into such Secure Platforms is considered Protected Health Information ("PHI") and/or medical information and is governed by laws that apply to that information, for example the Health Insurance Portability and Accountability Act (HIPAA). How Clafiya uses and discloses such PHI is in accordance with the Clafiya Health Notice of Privacy Practices. To understand how we use and disclose PHI, for example data you have consented to Health Practitioners adding your data into the Secure Platform. Clafiya will not use or disclose health information received from your Health Practitioner for advertising, marketing, or other use-based data mining purposes and will not combine it with other data and will not sell it. The Notice of Privacy Practices (and not this Privacy Policy) also applies to Personal Information collected on our Websites if specific symptoms or health conditions is also collected, as such information may be considered PHI under HIPAA.

1. TYPES OF PERSONAL INFORMATION WE COLLECT

While using our Websites, you may provide us with certain information about you. We or our advertising partners also may automatically collect information through the use of cookies and other tracking technologies (see below).

Personal Information that we collect through your use of the Websites may include IP Address, Device ID, and online identifier. We may use that Personal Information and link it to Internet or other electronic network activity information, and we may draw inferences about you from the information we collect. We may also collect your name, title, business contact information, phone number, date of birth, state, country, zip code, your health plan, email address or login identification information only if you provide such information directly to us when you begin registration to use a Secure Platform or complete a web form seeking more information. If you are a member this may be considered PHI and governed by our Notice of Privacy Practices and not this Privacy Policy.

2. HOW WE COLLECT PERSONAL INFORMATION

We may collect Personal Information using the following methods:

  • Directly from you when you provide it to us (such as information you enter into web forms, inquiries, responses, activity on the Websites, and during registration to use a Secure Platform).
  • From third parties, such as analytics and email marketing service providers.
  • Automatically through tracking technologies such as cookies, web beacons (also known as pixels) and log files, including over time and across our own and third-party websites or other online services.

3. HOW WE USE YOUR INFORMATION

We may use your Personal Information for the following purposes:

  • Operate, maintain, supervise, administer, and enhance the Websites, including monitoring and analyzing the effectiveness of content on the Websites, aggregate site usage data, and other usage of the Websites such as checking your eligibility and assisting you in completing the registration process.
  • Provide you with a tailored and user-friendly experience as you navigate our Websites.
  • Promote and market our Websites to you.
  • To complete the activity you specifically asked for, e.g., register on a Secure Platform, obtain more information, request a demo, or request an RFP.
  • Conduct research on users' demographics, interests, and behavior based upon information provided during use of our Websites.
  • Aggregate information for analytics and reporting.
  • Respond to law enforcement requests and court orders and legal process and carry out our legal and contractual obligations and enforce our rights.
  • Authenticate use, detect potential fraudulent use, and otherwise maintain the security of the Websites and safety of users.
  • Develop, test, improve, and demonstrate the Websites.
  • Any other purpose with your consent.

HOW WE SHARE YOUR INFORMATION

We may share Personal Information with third parties including service providers in certain circumstances or for certain purposes, including:

  • For business purposes: We may share your Personal Information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security. We also may share Personal Information with professional advisors, such as auditors, law firms, and accounting firms. We may disclose your name, email address, date of birth, phone number, and address if you provided it to us via a form on the website or during an incomplete or failed registration to Service Providers.
  • With your direction or consent: We may share your Personal Information with third parties if you request or direct us to do so. This includes your use of social media widgets on our Websites.
  • With our partners within our Webapp: We may share your Personal Information with any subsidiaries or affiliates within our corporate group.
  • Compliance with law: We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
  • For other business reasons: We may share your Personal Information to enforce any applicable Legal Disclaimer, and to ensure the safety and security of the Websites and/or our users.
  • For advertising: Using cookies and web beacons, we may disclose Personal Information regarding your activity on our Websites to third-party advertising partners to optimize marketing. See Section 7 for additional details.

We also may disclose information

Note that if you make any Personal Information publicly available on the Websites, anyone may see and use such information.

6. THIRD PARTY WEBSITES AND LINKS

Our Websites may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook, LinkedIn or Twitter) may also be viewable by other users of the Websites and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Websites. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of Personal Information by third parties. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.

7. COOKIES AND INFORMATION USED FOR ADVERTISING

As discussed above, on our Websites we may collect and disclose Personal Information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. This section of our Privacy Policy provides details and explains how to exercise your choices. You may see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons (also known as pixels). The networks use this information to show you advertisements that may be tailored to your individual interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the webpages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

You may disable or delete browser cookies through your browser settings. Cookies generally are easy to disable or delete, but the method varies between browsers. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts or functionality of our Websites may not work properly.

Each type of web browser offers ways to restrict and delete cookies. For more information on how to manage cookies visit the appropriate link below.