Privacy Policy (archived)

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Effective as of November 13, 2017

We are committed to respecting your privacy and providing transparency about our data practices. This Privacy Policy (this “Privacy Policy”) explains how OwHealth, Inc. (“Company” or “we” or “us”) collects, stores, uses, and discloses personal information from our users (“you”) in connection with the Flo™ mobile application and related services (collectively, the “App”).

We reserve the right to and may change this Privacy Policy from time to time. If we make any material changes, we will notify you by email (sent to the email address specified when you register), through the App, or by presenting you with a new version of this Privacy Policy for you to accept. Your continued use of the App after the effective date of an updated version of the Privacy Policy will indicate your acceptance of the Privacy Policy as modified. We encourage you to periodically review this website for the latest information on our privacy practices. If you do not accept the terms of the Privacy Policy, we ask that you do not use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy.

When you sign up to use the App, the types of personally identifiable information we may collect include your name, email address, gender, date of birth, and password, and as you use the App, you may choose to provide health-information such as your weight, body temperature, menstrual cycle dates, and other information about your health and activities (collectively, “Personal Information”). You will be able to modify and update your Personal Information in the App.

The App will allow you to share personal stories with us and other users of the App.

You will also have an option to permit us to import into the App data from third-party services such as Apple HealthKit and Google Fit, among others. We will not use the information gained through your use of the HealthKit and Google Fit framework for advertising or similar services, or sell it to advertising platforms, data brokers, or information resellers. You expressly consent that we may only share such information to a third party if they are also providing a health or fitness service to you, or for medical research purposes, or for other purposes specified in this Privacy Policy and permitted under applicable agreements governing the use of Apple HealthKit and Google Fit frameworks. Permitting us to access third party information can help you to maximize your App experience, and we will handle any such third-party information in accordance with this Privacy Policy.

All information that you provide to us through the App is automatically uploaded to our servers and is stored there in duplicate to the information stored on your device. If you remove data from your account, you will no longer see it in the App, but some backups of the data may remain in our archive servers.

You are responsible for ensuring the accuracy of the information that you submit to Flo. Inaccurate information will affect your experience when using the Flo Web Sites and tools and our ability to contact you as described in this Privacy Policy.

When you access or use the App, we may automatically collect the following information: 

• Device Information: We collect information about the mobile device you use to access the App, including the hardware model, operating system and version, unique device identifiers and mobile network information.
• Location Information: We collect your IP address, time zone, and information about your mobile service provider, which allows us to infer your general location.
• Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information about your use of the App, such as frequency of use, which areas and features of our App you visit and your use patterns generally, engagement tracking with particular features, etc. To collect this information, we may send cookies to your mobile device or computer. Cookies are small data files stored on your hard drive or in device memory.

We may use your information, including your Personal Information, as follows: 

• to analyze, operate, maintain and improve the App; 
• to customize content you see when you use the App;
• to provide and deliver the products and services you request, process transactions and send you related information, including confirmations and reminders;
• to customize product and service offerings and recommendations to you, including third-party products and offerings (except data from Apple HealthKit and Google Fit);
• to verify your identity;
• to send you technical notices, updates, security alerts and support and administrative messages;
• to respond to your comments, questions and requests and provide customer service;
• to monitor and analyze trends, usage and activities in connection with our App;
• solely with respect to information that you mark for sharing, for Company promotional purposes (except data from Apple HealthKit and Google Fit);
• to link or combine with information we get from others to help understand your needs and provide you with better service; and
• for any other purposes disclosed to you at the time we collect Personal Information. 

a. Information We Share with Third Parties

We may share certain Personal Information, excluding information regarding your marked cycles, pregnancy, symptoms, notes and other information that is entered by you and that you do not elect to share, with third party vendors who supply software applications, web hosting and other technologies for the App. Third parties will not have access to our survey results and we will not reveal information about which articles you view. We will only provide these third parties with access to information that is reasonably necessary to perform their work or comply with the law. Those third parties will never use such information for any other purpose except to provide services in connection with the App. 

b. Aggregated Information 

We may also share aggregated, anonymized or de-identified information, which cannot reasonably be used to identify you. For example, we may share, including, without limitation, in articles, blog posts and scientific publications, general age demographic information and aggregate statistics about certain activities or symptoms from data collected to help identify patterns across users.

c. Special Circumstances

We will not share or sell any of your Personal Information to any third party except as otherwise stated in this Privacy Policy and in the following circumstances: (i) in response to subpoenas, court orders or legal processes, to the extent permitted and as restricted by law; (ii) when disclosure is required to maintain the security and integrity of the App, or to protect any user’s security or the security of other persons, consistent with applicable laws; (iii) when disclosure is directed or consented to by the user who has input the Personal Information; or (iv) in the event that we go through a business transition, such as a merger, divestiture, acquisition, liquidation or sale of all or a portion of its assets, your information will, in most instances, be part of the assets transferred. 

d. Information Posted by User 

The App features several community areas and other public forums where users with similar interests or medical conditions can share information and support one another or where users can post questions for experts to answer. We also offer online discussions which may be moderated by healthcare experts. Our communities are open to [the public/the App community] and should not be considered private. 

Any information (including Personal Information) you share in any online community area or online discussion is by design open to the public and is not private. You should think carefully before posting any Personal Information in any public forum. What you post can be seen, disclosed to, or collected by third parties and may be used by others in ways we cannot control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, the information you post may also show up in third-party search engines. 

If you mistakenly post Personal Information in our community areas and would like it removed, you can send us an email as listed below to request that we remove it. In some cases, we may not be able to remove your Personal Information. 

e. Retained Information

We will retain your Personal Information as long as your account is active or needed to provide you services. At any time you can remove your Personal Information or instruct us to remove it by emailing us at support@owhealth.com, but you should be aware that we may retain certain personal information after your account has been terminated in an aggregated, anonymized form. Any posts or comments you submit may remain visible if and after you delete your account. We are not obligated to remove your posts or comments. We reserve the right to use your information in any aggregated data collection after you have terminated your account, however we will ensure that the use of such information will not identify you personally. We will also retain your Personal Information as necessary to comply with legal obligations, resolve disputes and enforce our agreements. 

You can direct us to share data from the App with other parties. For example, you can permit us to share data with other health apps and services like Google Fit and Apple HealthKit. Once you direct us to share your data with a third party, that third party will have their own privacy policy and we do not control how the third party uses or handles the information. You can revoke your consent to share information with such a third party at any time in your App account settings. 

We take commercially reasonable measures to protect all collected information from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Please understand that you can help keep your information secure by choosing and protecting your password appropriately, not sharing your password and preventing others from using your mobile device. Please understand that no security system is perfect and, as such, we cannot guarantee the security of the App, or that your information won’t be intercepted while being transmitted to us. If we learn of a security systems breach, we may either post a notice, or attempt to notify you by email and will take reasonable steps to remedy the breach.

We process information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current and reliable for its intended use.

We are committed to protecting the privacy of children. The App is not intended for children and we do not intentionally collect information about children under 13 years old. The App does not collect Personal Information from any person the Company actually knows is under the age of 13. If you are aware of anyone under 13 using the App, please contact us at support@owhealth.com. 

Although the App may contain links to third party websites or services, we are not responsible for the privacy policies and/or practices on those third-party websites or services. Please understand that this Privacy Policy applies only to information we collect from you. Where we have linked to a third-party website or service, you should read the privacy policy stated on that third-party website or service. 

We may contact you from time to time via email to communicate with you about products, services, offers, promotions, rewards, and events offered by us and others, and provide news and information that we think will be of interest to you. You can always opt out of receiving emails by unsubscribing via the “Unsubscribe” link contained in the email. Opting-out of these emails will not end transmission of important service-related emails that are necessary to your use of the App. 

This Privacy Policy does not apply to information, content, business information, ideas, concepts or inventions that you send to the Company by email. If you want to keep content or business information, ideas, concepts or inventions private or proprietary, do not send them in an email to the Company. 

The Company is based the United States and the information we collect is governed by U.S. law. Please be advised that U.S. law and laws of other countries may not offer the same protections as the law of your jurisdiction.

In addition, you agree that information collected through the App may be stored and processed in Canada, where the Company currently rents servers, or in any other country in which the Company or its affiliates, subsidiaries or agents maintain facilities, and by using the App, you consent to any such transfer of information outside of your country.

If you do not want your Personal Information used by the App or the Company as provided in this Privacy Policy, you should not register as a user. You may correct, update or review Personal Information you have submitted through registration, tools and applications by signing in and updating your registration information. If you have registered and would like to remove your personal information from the site, you may email us at support@owhealth.com, and we will delete your Personal Information. 

If you would like to update your Personal Information, delete your account, change your preferences or have any questions or concerns about your privacy, you may contact us at support@owhealth.com. As mentioned above, if you would like to remove your personal information from our site, please contact us. Please note that some information may remain in our records after deletion of your account, including any information or records that we are legally obligated to retain or that we elect to retain for legitimate business purposes.