Privacy policy.

Last Updated: September 24, 2022

Health at Scale Corporation (“HAS,” “we,” or “us”) respects your privacy.  This Privacy Policy (the “Privacy Policy”) is intended to describe how we collect, use, and share information that we collect or obtain through the HAS website, healthatscale.com or the HAS careers site (“Website” or “Site”).

1.     APPLICABILITY OF THIS PRIVACY POLICY

This Privacy Policy applies only to personal information that you submit or that we collect or obtain through the Site.  This Privacy Policy does not apply to other HAS websites, applications or services, including Precision Health™,  Precision Navigation™, Precision Interception™, Precision FWA Detection™, Precision Pharmacy™ and Precision Wellness™.

2.     INFORMATION WE COLLECT

As described in this Privacy Policy, we collect certain Personal Information from or about you in connection with your use of, or your submissions to, the Website and its services.  “Personal Information,” for purposes of this Privacy Policy, generally includes information that may be used to identify you.  You are not required to provide all Personal Information identified in this Privacy Policy; however, please be advised that if you do not provide the Personal Information requested, we may be unable to provide some or all of the services. 

We may collect the following information in connection with your use of or interactions with the Website:

  • Contact Information and Identifiers.  We may collect contact information, such as your first and last name, email address, phone number, address, your organization, and job title.

  • Communications information. When you communicate with us through our Sites, we may collect your contact information and any other Personal Information that you choose to provide in the content of your message.

  • Employment Application Information.  If you apply for a job with us or inquire about employment opportunities, we may collect certain information in connection with your application, such as education, professional, and employment information. Please note, when you apply for employment with us, we utilize third parties to manage and administer the application process.

  • Device and Usage Data. We may also automatically collect certain data about your device and interactions with the Website and services, such as information about your web browser, IP address, time zone, dates and times that the Website is accessed and areas of the Website you visit or interact with, mobile device ID, model, manufacturer, operating system, version information, carrier-related information, and IDs related to the cell phone hardware in your phone as well as the network to which the device is connected, mobile phone number, application-specific and instance-specific identifiers, and location information, as further described in this Privacy Policy.  Our “Use of Cookies and Similar Technologies” section contains more information and options to control certain data collection or uses related to cookies and similar technologies.

  • Aggregated, De-identified, or Anonymous Data.  We may create aggregated, de-identified, or anonymous data from Personal Information by removing data components (such as your name or email address) that makes the data personally identifiable to you, through obfuscation, or through other means.  We may use aggregated, deidentified, and/or anonymous data for legally permissible purposes.

3.     HOW WE COLLECT AND USE INFORMATION

We collect Personal Information as described in this Privacy Policy.  The following is intended to describe the various sources through which we may collect Personal Information in connection with the Site:

  • Interactions with the Site and communications with us. We may collect Personal Information when you use or interact with the Site or otherwise utilize its services. We may also collect Personal Information when you communicate with us, submit information or inquiries, request information from us, or when you subscribe or sign up to receive communications, materials, or other information from us.

  • Employment Applications and Inquiries. We may request or otherwise collect Personal Information when you apply for a job with us or inquire about employment opportunities. We utilize third-party providers to assist in the collection and processing of Personal Information in connection with employment applications and inquiries.

  • Cookies and Similar Technologies. We may collect certain personal information using cookies and other technologies, such as web beacons, device IDs, geolocation, HTML5 local storage, and IP addresses, as further described in this Privacy Statement. The “Use of Cookies and Similar Technologies” section contains more information and options to control or opt-out of certain data collection or uses related to cookies and similar technologies.

We use the Personal Information we collect as described in this Privacy Policy, including for the following purposes:

  • to administer and provide the Site and its services;

  • to contact and communicate with you in connection with the Site and services and to address and respond to inquiries or requests;

  • to maintain, develop and improve the Site and services, including to better tailor the features, performance, and support of our Site and Services, and for statistical and analytics purposes;

  • for our direct marketing purposes and to provide you with information or materials about the Site and services and other opportunities that we believe may be of interest to you, whether offered by us or third-party partners, and to personalize, measure, and improve such offers;

  • to evaluate candidates for employment and to communicate with you in connection with employment opportunities and applications;

  • for fraud, loss, and other crime prevention purposes, to assist in the investigation of suspected illegal or wrongful activity, and to protect and defend our rights, interests, and property, or the rights or safety of third parties;

  • to enforce agreements or to comply with laws, regulators, court orders, or other legal obligations, or pursuant to legal process, or to establish or exercise our legal rights or defense against legal claims.

4.     HOW WE MAY DISCLOSE INFORMATION

We may disclose Personal Information as described in this Privacy Policy, including with the following categories of third parties:

  • Affiliates.  To our subsidiaries, affiliates, and other companies under our common control or within our corporate family, for the purposes described in this Privacy Policy. 

  • Technical and Operational Service Providers and Vendors and Professional Services Firms.  To contractors, service providers, vendors, and other third parties we use to support our business and provide the Site and services, including for technical and processing functions, technical support, and analytics.  We may disclose Personal Information to our third-party business partners and service providers in order to maintain and operate the Site and to provide and improve the Services, including to fulfill requests for the services and for other technical and processing functions, such as sending e-mails on our behalf and technical support.  We may also disclose Personal Information to professional services firms providing services to us, such as auditors, law firms, and consultants.

  • Legal and Compliance.  To comply with any court order, law, or legal process, including to respond to any government or regulatory request, and to enforce agreements and to assert and defend against legal claims.

  • Protection of Rights and Interests.  If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of our company or other third parties, and to investigate, detect, or prevent against fraud or other illegal activity.

  • Corporate Transactions.  Subject to applicable law, to a successor organization in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets, including for the purpose of permitting the due diligence required to decide whether to proceed with such a transaction.  If any such transaction occurs, the purchaser will be entitled to use and disclose the Personal Information collected by us in the same manner that we are able to, and the purchaser will assume the rights and obligations regarding Personal Information as described in this Privacy Policy.

5.     USE OF COOKIES AND SIMILAR TECHNOLOGIES

The Website or services may use cookies and similar technologies to improve user experience, for performance and analytics, and to improve our content, products, and services.  A “cookie” is a small text file that is stored on your browser or device.  A browser or the device sends cookies to a server when making a connection to the server (for example, when requesting a web page from the same domain that created the cookie). The purpose of cookies is to remember the browser or device over time and to distinguish one device or browser instance (or user) from all others.  Some cookies and other technologies may serve to track personally identifiable information previously entered by a web user on the site.  Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them.  Cookies can remember login information, preferences, and similar information. 

Cookies, as well as other tracking technologies, such as HTML5 local storage and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data. We may also use web beacons or “pixels,” and in certain circumstances may collect IP address, screen resolution, browser software, and operating system types, clickstream patterns, dates and times that our Website is accessed, and other categories of data related to your interactions with and use of the Website and Services.

Our Site currently uses Google Analytics.  Please read “How Google uses data when you use our partners' sites or apps,” which you can find here, for information about how Google Analytics collects and processes data.  To opt out of Google Analytics, please click here.

If you want to block or delete cookies, you should take the necessary steps within your device and web browser’s settings.  Please note that if you choose to delete or block cookies, certain parts of our Website may not function correctly.  For information on how to disable cookies, refer to your browser’s settings and instructions.  To manage the use of certain cookies and technologies on your mobile device, refer to your device operating system settings.

Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third-parties as defined by the initiative.  Please note that the Website does not alter its behavior or use practices if we receive a Do Not Track signal from your browser.

6.     INFORMATION ABOUT MINORS

The Site and services are not intended for individuals under 18 years of age.  We do not knowingly collect Personal Information directly from minors without the consent of the minor’s parent or legal guardian.  If you become aware that a minor has provided us with Personal Information without appropriate consent, please contact us at privacy@healthatscale.com.  If we become aware that a minor has provided us with Personal Information without appropriate consent, we will take steps to remove the data as permitted by law.

7.     YOUR RIGHTS REGARDING YOUR PERSONAL INFORMATION

Subject to applicable law, you may have the right to request confirmation from us as to whether or not we are processing your Personal Information.  Where we are processing your Personal Information, subject to applicable law, you may also have the following rights regarding your Personal Information:

  • Request access to, modification of, or correction of your personal information.  You may have the right to request access to, modification of, or correction of your Personal Information.   

  • Request deletion of your personal information.  You may have the right to request that we delete the Personal Information that we have collected about you.

  • Request restriction of processing.  You may have the right to request that we restrict processing of your Personal Information in certain circumstances, such as where you believe that the Personal Information we hold about you is inaccurate or our processing is unlawful.

  • Object to processing.  In certain circumstances, you may have the right to request that we stop processing your Personal Information, such as a request to stop sending you direct marketing communications.  To opt-out of direct marketing communications, please see the instructions in the “Updating Your Communications Preferences and Withdrawing Consent” section of this Privacy Statement.

  • Data portability.  In certain circumstances, you may have the right to receive the Personal Information concerning you that you provided to us or to request that we transmit your Personal Information to another data controller.

  • Lodge a Complaint.  You have the right to lodge a complaint with a supervisory authority.  If you are located in the European Economic Area, you may file a complaint with a supervisory authority in your relevant country or region, which you can find here.  If you are located in the UK, your supervisory authority is the Information Commissioner’s Office, which can be contacted here. 

To exercise your rights, please contact us by email at privacy@healthatscale.com.  You may also authorize someone to exercise the above rights on your behalf. 

As permitted by law, certain data elements may not be subject to access, modification, portability, restriction, and/or deletion.  We will respond to authorized and verified requests as soon as practicable and as required by law.  To protect your privacy and security, we may take steps to verify your identity in order to respond to your request.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests.  These rights are also subject to various exclusions and exceptions under the law. Under certain circumstances, we may be unable to implement your request, pursuant to applicable law. We will advise you of any reason for denying or restricting a request to the extent permitted by law.

Your California privacy rights.  California residents have certain rights with respect to our sharing of their personal information with third parties for their own direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes. However, because California residents have the right to request information regarding such practices under California’s “Shine the Light” Law, please contact us at privacy@healthatscale.com. You must include your full name, email address and postal address in your email or mail request so that we can verify your California residence and respond.

8.     UPDATING YOUR COMMUNICATIONS PREFERENCES

If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these e-mail communications, or you may contact us at 10 Almaden Blvd, Suite 960, San Jose, CA 95113 to opt-out of direct marketing.  Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices.

9.     LINKS TO OTHER SITES

Our Website may contain links or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”).  Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites.  We encourage you to read the privacy policies of any Third-Party Site with which you choose to interact.

10.  DATA RETENTION

We will retain your Personal Information for as long as necessary to fulfill the purposes for which we obtained the Personal Information, including to provide the services, or for such longer period as may be required or permitted by applicable law.  We will also retain your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements and policies.  We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the purposes for processing your Personal Information and associated legal bases; (iii) the existence of a legal obligation as to the retention period; (iv) our contractual obligations; and (v) the advisability of retaining the information in light of our legal position (for example, applicable statutes of limitations, litigation, or regulatory investigations).  

11.  DATA SECURITY

We implement technical and organizational safeguards designed to secure and protect Personal Information.  Please note, however, we cannot fully eliminate security risks associated with the storage and transmission of Personal Information.

12.  TRANSFER AND PROCESSING IN THE UNITED STATES

The Personal Information we collect from you will be processed and stored in the United States and may be stored in other countries that have different privacy laws and standards than those in your country of residence.  When you provide us with your Personal Information, you are disclosing or passing your Personal Information directly to us in the United States.  Your Personal Information may be transferred to or processed in the United States by us or a third-party service provider working for us.  When we transfer or disclose your Personal Information to other countries, we will protect that information as described in this Privacy Statement.  If you are located outside of the United States, the transfer of Personal Information may be necessary to provide you with the requested information and services and/or to perform any requested transaction.  By accessing or using any portion of the Site, you acknowledge and consent to the transfer of your information to the United States.

13.  UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time.  The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. We encourage you to review this Privacy Policy often to stay informed of how we may process your information.

14.  CONTACT INFORMATION

If you have questions about this Privacy Policy or our privacy practices, please contact us by e-mail at privacy@healthatscale.com or by mail using the details provided below:

Health at Scale, Corp.

10 Almaden Blvd, Suite 960, San Jose, CA 95113