Clovi Inc. (the “Company”) knows that you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our privacy policy. By visiting the clovi.com website and domain name, and any other linked pages, features, content, or application services offered from time to time by the Company in connection therewith (collectively, the “Sites,” as further defined in our Terms), or using any of our Services, you acknowledge that you accept the practices and policies outlined in this Privacy Policy. Capitalized terms not defined in this Privacy Policy shall have the meanings set forth in our Terms of Use, available at
https://www.clovi.com/terms/
(“Terms”).
“Company” or the terms “we” or “us” or similar terms refer to Clovi Inc. “You” or “your” or similar terms refer to you as a user of our Services (including screening-company administrators and end participants, as applicable).
By accepting our Privacy Policy during registration, or by visiting and/or
using the Sites or any of our Services, you (a) expressly consent to our
collection, use, and disclosure of your Personal Information (as defined below)
in accordance with this Privacy Policy, and (b) expressly acknowledge that
you have read and understood our HIPAA Notice, which provides important
information to you about how we may use and disclose health information
about you. Our HIPAA Notice is available at
https://www.clovi.com/hipaa/
As used in this Privacy Policy, the terms “using” and “processing” information include, among other things, using cookies on a computer, subjecting the information to statistical or other analysis, and using or handling information in any way; including, without limitation, collecting, storing, evaluating, modifying, deleting, using, combining, disclosing, and transferring information within our organization or among our affiliates within the United States or internationally, as well as using personal information to respond to user / applicant inquiries and provide the requested products and services.
1. WHAT DOES THIS PRIVACY POLICY COVER?
Personal Information – In General.
This Privacy Policy covers how we use and disclose personally identifiable information that we gather from the time that you initially access our Sites or use our Services. Personally identifiable information refers to information about you that can be used to contact or identify you, and information on your use or potential use of the Sites or our Services (collectively, “Personal Information”). This policy does not apply to the practices of companies and / or Sites that we do not own or control, or to individuals that we do not employ or manage.
Protected Health Information.
We are dedicated to maintaining the privacy and integrity of your protected
health information (“PHI”). PHI is Personal (individually identifiable)
Information about you that relates to (a) your past, present, or future
physical or mental health or condition, (b) the provision of health care
to you, or (c) your past, present, or future payment for the provision of
health care, which is created, received, transmitted, or maintained by the
Company. This Privacy Policy describes how we protect your privacy as a
visitor to, or general user of our Sites and Services. You have additional
rights under federal and state law with respect to the access to, use, and
disclosure of Personal Information that constitutes PHI. For a more complete
description of your rights with respect to PHI, please refer to our HIPAA
Notice, which provides important information to you about how we may use
and disclose your PHI. Our HIPAA Notice is available here:
https://www.clovi.com/hipaa/
2. WHAT PERSONAL INFORMATION DO WE COLLECT?
We collect personal information you choose to provide, e.g., through registrations, applications and surveys, and in connection with your inquiries, from the time that you initially access our Sites or use our Services. The information we gather from customers enables us to personalize and improve our Services.
From time to time, we may use or augment the personal information we have about you with information obtained from third parties. For example, we may use such third party information to confirm contact or financial information, to verify eligibility, or to better understand your interests by associating demographic information with the information you have provided.
We collect the following types of information from our customers:
Personal Information You Provide to Us.
We receive and store any information you enter on our Sites or provide to us in several ways. Personal Information that we collect may include things like your full name, mobile phone number, credit card and/or other payment information (if applicable), your email address and the email address of your contacts, home and business postal addresses, IP address, browser information, username, password, certain health information (e.g., weight, insurance information), and any other information or data that you provide when using our Sites and/or our Services. You can choose not to provide us with certain information, but that may result in our inability to provide you access to many of our special features. Clovi’s goal is to use the Personal Information you provide for such purposes as answering questions and communicating with you about the Company’s products and services, including updates and new features.
Program visibility. Most use of the Services is configured by the organization sponsoring your program (for example, your employer or screening vendor). Unless that organization enables optional community, forum, chat, group coaching, or similar features, your Personal Information is not shared with other participants for social-networking purposes. When such features are enabled, information you post or submit may be visible to other participants, coaches, or administrators as described in the product or at enrollment. We cannot control what other users do with information you choose to disclose in those features. If you are not comfortable with the visibility described for a program, do not use those features or do not participate in the program.
Personal Information Collected Automatically.
We receive and store certain types of information whenever you interact with our Sites and / or use our Services. We automatically receive and record information on our server logs from your browser, including your IP address, and the page you requested. In addition, we may use personal identifiers to recognize you when you arrive at the Site via an external link, e.g., such as a link appearing on a third party site or in a Clovi-generated email presented to you. See also our What About Cookies? section below. We will also use your information to provide customer service and support.
Generally, our Services automatically collect usage information, such as the numbers and frequency of visitors to our Sites and its components, similar to TV ratings that indicate how many people watched a particular show. We only use this data in aggregate form, that is, as a statistical measure, and not in a manner that would identify you personally. This type of aggregate data enables us to figure out how often customers use parts of the Sites or Services so that we can make the Sites appealing to as many customers as possible, improving our Services. We may provide this de-identified, aggregate data to our partners to identify how our customers, collectively, use our Sites or Services. We share this type of statistical data so that our partners also understand how often people use the Sites or Services, so that they, too, may provide you with an optimal online experience. Again, we never disclose aggregate information to a partner in a manner that would identify you personally.
E-mail Communications
We often receive a confirmation when you open an email from us if your computer supports this type of program. We use this confirmation to help us make emails more interesting and helpful. We also compare our customer list to lists received from other companies, in an effort to avoid sending unnecessary messages to our customers. When you receive e-mail from us, you can opt out of receiving further e-mails by following the included instructions to unsubscribe.
Cookies
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your browser to enable our systems to recognize your browser and tell us how and when pages in our Sites are visited and by how many people. We use cookies to enhance visitors’ experiences by understanding how visitors and / or users engage with and navigate our Sites.
Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave the cookies activated, however, because cookies enable you to take advantage of some of our Sites’ most attractive features. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost.
We may serve ads on the Sites. These ads may be delivered to users by our advertising partners, who may set cookies. These cookies allow the ad server to recognize your computer each time they send you an online advertisement to compile information about you or others who use your computer. This information allows ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you. This Privacy Policy refers only to the use of cookies by the Company and does not cover the use of cookies by any third parties (e.g., advertisers).
3. WHAT PERSONAL INFORMATION DO WE SHARE?
Personal Information about our customers is an integral part of our business. We will not rent, sell, or share Personal Information about you with other people or non-affiliated companies except to provide Services, when we otherwise have your permission, or under the following circumstances:
Collaboration features: When your organization enables discussion boards, chat, messaging, profiles, or similar features, information you post—including your screen name, profile details, or messages—may be visible to other users, moderators, or administrators as designed in the product. Content posted in shared spaces may remain visible to other participants. WE ARE NOT RESPONSIBLE FOR HOW OTHER USERS USE INFORMATION YOU CHOOSE TO DISCLOSE IN THOSE FEATURES.
We may send you email or other communications relating to content or activity you submit through such features. You may manage certain communications through your account settings or the unsubscribe instructions in our messages, subject to transactional or legal notices we must send.
Affiliated Businesses We Do Not Control: In order to provide you with the optimal user experience, we anticipate that we may become affiliated, and work closely with a variety of third-party businesses. In certain situations, these businesses may sell products or services to you through the Sites. In other situations, we may provide services, or sell products, jointly with affiliated businesses. You should be able to recognize when an affiliated business is associated with your transactions, and throughout the course of the transactions, we will share your Personal Information that is related to such transactions with that affiliated business.
Agents: We employ other companies and people to perform tasks on our behalf and need to share your information with them to provide products and/or services to you. Without specific authorization and/or consent, we limit the rights of our agents to use Personal Information we share with them to that which is minimally necessary to assist us. You hereby consent to our sharing of Personal Information for the above purposes.
Promotional Offers: We will never disclose your personal information to other businesses for their marketing purposes, but we may send you offers that promote the products of other businesses. These offers will be intended to benefit you, your health, or your Clovi experience. If you do not wish to receive these offers, please email your request to [email protected] or [email protected], and we will process your request within a reasonable time. Please note that you may receive additional offers as we process your request.
Business Transfers: In some cases, we may choose to buy or sell assets. In these types of transactions, customer information, including Personal Information about customers, is typically one of the business assets that are transferred. Moreover, if Clovi Inc., or substantially all of its assets were acquired, or in the unlikely event that the Company goes out of business or enters bankruptcy, Personal Information would be one of the assets that is transferred or acquired by a third party. By continuing to use our Sites and Services, you acknowledge that if we sell or transfer our business (e.g., through an acquisition) or an asset (e.g., our website) to another company, we will share your personal information with such company and will require such company to use and protect your personal information consistent with this Privacy Policy.
Protection of the Company and Others: We may release Personal Information when we believe in good faith that release is necessary to comply with the law; enforce or apply our conditions of use and other agreements; or protect the rights, property, or safety of the Company, our employees, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.
With Your Consent: Except as set forth above, you will be notified when your Personal Information may be shared with third parties, and will be able to control the sharing of this information.
4. IS MY PERSONAL INFORMATION SECURE?
We employ administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. These measures include encrypting your communications by utilizing Secure Sockets Layer (“SSL”) software, and using a secured messaging service when we send your Personal Information electronically. In addition, when we collect, maintain, access, use, or disclose your Personal Information, we will do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws, including, without limitation, the Health Insurance Portability and Accountability Act (“HIPAA”).
Furthermore, your individual user account is protected by a password for your privacy and security. To ensure that there is no unauthorized access to your account and Personal Information, we suggest that you safeguard your password appropriately and limit access to your computer and browser by signing off after you have finished accessing your account.
We endeavor to protect user information to ensure that user account information is kept private. However, we cannot guarantee the security of your personal and other information or the appropriateness of the measures we use to safeguard such information. Unauthorized entry, access, or use; loss; hardware or software failure; and other factors, may compromise the security of user information at any time.
The Sites contain links to other sites. We are not responsible for the privacy policies and/or practices on other sites. When linking to another site you should read the privacy policy published on that site. This Privacy Policy only governs information collected on our Sites or through our Services. If necessary, we will make all legally required disclosures of any breach of the security, confidentiality, or integrity of your Personal Information, including, without limitation, breaches of your unencrypted, electronically stored, “personal information” or “medical information” (as defined in applicable state statutes on security breach notification). To the extent permitted by applicable laws, we will make such disclosures to you via email or conspicuous posting on your private profile on the Sites in the most expedient time possible and without unreasonable delay, insofar as consistent with (a) the legitimate needs of law enforcement, or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Despite these measures, the confidentiality of any communication or material transmitted to or from us via the Services offered through our Sites, by Internet or email cannot be guaranteed. If you have reason to believe that your data or your interactions with us are no longer secure, or if you have privacy or data security questions, contact [email protected] or use the mailing address in Section 10 below.
5. WHAT PERSONAL INFORMATION CAN I ACCESS?
We allow you to access the following information about you for the purpose of viewing, and in certain situations, updating that information. This list may change as the Sites change.
Real name
Account and user profile information (e.g., nickname and picture)
User email address
User mailing address
User mobile phone number
Username and password
Communication preferences
6. WHAT CHOICES DO I HAVE REGARDING MY PERSONAL INFORMATION?
As stated previously, you can always opt not to disclose information, even though it may be needed to take advantage of certain features of the Sites and the Services.
You are able to add or update certain information on pages, such as those listed in the “What Personal Information Can I Access” section, above. When you update information, however, we often maintain a copy of the unrevised information in our records.
If you would like us to remove your records from our system, you may request deletion of your account with us by sending e-mail to [email protected] or [email protected]. Please note that some information may remain in our records after deletion of your account, including any information or records we are legally obligated to retain. We will process your request within a reasonable time, but please note that you may receive additional offers as we process your request.
If you do not wish to receive email or other mail from us, please indicate this preference by emailing us at [email protected] or [email protected]. Please note that if you do not want to receive legal notices from us, such as this Privacy Policy, those legal notices will still govern your use of the Sites, and you are responsible for reviewing such legal notices for changes.
7. HOW DO WE PROTECT CHILDREN’S PERSONAL INFORMATION?
The Services are not directed to children. We do not knowingly allow or solicit anyone under the age of 13 to participate independently in any of the Services. We do not knowingly collect Personal Information from children. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, please contact us at [email protected]. If we become aware that a user of the Services is under the age of 13 and has provided us with Personal Information without verifiable parental consent, we will delete such Personal Information from our files.
8. CHANGES TO THIS PRIVACY POLICY
By using the Sites and Services, you agree to the current Privacy Policy and our Terms, into which this Privacy Policy is incorporated. We reserve the right, in our sole discretion, to modify, discontinue, or terminate the Services or to modify this Privacy Policy at any time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used or disclosed. If we make changes in the way we use Personal Information, we will notify you by posting an announcement on our Sites and/or sending you an email. By continuing to access or use the Services after we have posted a modification or have provided you with notice of a modification, you are indicating that you agree to be bound by the modified Privacy Policy. If the modified Privacy Policy is not acceptable to you, your only recourse is to cease accessing the Sites and / or using the Services.
9. CALIFORNIA RESIDENTS (CPRA / CCPA)
This section applies to California residents and supplements the disclosures above. Terms used here have the meanings given in the California Consumer Privacy Act as amended by the California Privacy Rights Act (“CCPA”).
Categories of personal information collected. Depending on how you use the Services, we may collect identifiers (such as name, email, phone, account credentials); professional or employment-related information; internet or network activity; geolocation (e.g., IP-based); health-related information you or your program submit; financial information (e.g., payment details when you pay us); and other categories described in Section 2 of this Privacy Policy.
Purposes. We use personal information for the purposes described in this Privacy Policy, including to provide and improve the Services, communicate with you, secure our systems, comply with law, and as directed by the organization sponsoring your program where applicable.
Sale or sharing. We do not sell your personal information for monetary consideration. We may use cookies or similar technologies for analytics or advertising as described in this Privacy Policy; where such use constitutes “sharing” for cross-context behavioral advertising under the CCPA, you may opt out of such sharing by using browser controls, any “Do Not Sell or Share My Personal Information” link we provide on our Sites (if applicable), or by contacting [email protected].
Sensitive personal information. We use sensitive personal information only as permitted by the CCPA and as described in this Privacy Policy and our HIPAA Notice (where applicable).
Retention. We retain personal information for as long as needed to provide the Services, comply with legal obligations, resolve disputes, and enforce our agreements. Retention periods vary by data type and context.
Your rights. California residents may have the right to request access to, deletion of, or correction of personal information; to limit use of certain sensitive personal information; and to not receive discriminatory treatment for exercising these rights. You may submit a request by emailing [email protected]. We will verify your request in accordance with law. You may designate an authorized agent to make a request on your behalf with written permission, subject to verification.
Shine the Light. California Civil Code § 1798.83: California residents may request certain information about disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their direct marketing purposes as described in that statute; you may still contact [email protected] with questions.
10. QUESTIONS OR CONCERNS; PRIVACY OFFICER
For general support, contact [email protected]. For privacy requests, HIPAA-related questions, or to reach the Privacy Officer, contact [email protected].
Mailing address (written requests): Clovi Inc., Attn: Privacy Officer, San Francisco, CA, United States.
We will make every effort to resolve your concerns promptly.