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Privacy Policy

Effective March 7, 2022

At Luma Health your privacy is important to us. Our Privacy Policy describes the information we collect, how we collect information, and the reasons we collect information. This Privacy Policy also describes the choices you have with the information we collect, including how you can manage, update, or request to delete information. 

Please take a moment to review this Privacy Policy. By using our Platform, you are agreeing to the terms of this Privacy Policy. If you have any questions or concerns about this Privacy Policy, you may Contact Us at any time.

Table of Contents

I.Who is Luma Health?

II.Key Terms & Definitions and Our Privacy Policy

When does our Privacy Policy apply?

When does our Privacy Policy not apply

Our Privacy Policy and Terms of Use.

III.Personal Information

What is Personal Information

What types of Personal Information do we collect?

How do we collect your Personal Information?

How do we use your Personal Information?

How do we share your Personal Information?

Your choices about how we share your Personal Information.

Rights under Applicable Law.

IV.Children’s Privacy

V.Does Luma Health respond to Do Not Track signals?

VI.Data Security

VII.California’s Shine the Light Law and other Applicable Laws.

VIII.Changes to our Privacy Policy

IX.Contact Us


I. Who is Luma Health?

Luma Health is a technology company that assists healthcare providers to communicate and engage with their patients.

Luma Health is not a health care provider, nor does it provide medical advice. Please contact your health care provider

II. Key Terms & Definitions and Our Privacy Policy

It is helpful to start by explaining some of our key terms and definitions used in this Privacy Policy. 

Key Term

Definition

our “App(s)”

Our mobile applications

“Personal Information”

Any information relating to an identified or identifiable individual and any information listed below.

“Platform”

Our Website and/or App

“Privacy Policy”

This privacy policy. 

“Products”

Any products available for purchase on our Platform. 

“Terms of Use”

Our terms of use located here

our “Website(s)”

Our websites, including: www.lumahealth.io

“Luma Health,” “we,” “us,” or “our”

Luma Health, Inc.


When does our Privacy Policy apply? 

This Privacy Policy describes the types of information we may collect from you when:

  • You visit or use our Platform;
  • We communicate in e-mail, text message, and other electronic messages between you and us; and 
  • We communicate in person. 

When does our Privacy Policy not apply?

This Privacy Policy does not apply to information collected by any other website operated either by us, unless listed above, or by a third party. 

This Privacy Policy does not apply to information collected from patients who interact with their health care providers (“Provider Platform”). Do not send PHI directly to us; only to your health care provider. Your health care provider is obligated to provide you with a notice of privacy practices describing their collection and use of your health information. The Provider Platform allows patients to communicate with their health care providers, such as texting them or enabling a telehealth visit. All information collected and stored by us or added by patients or their health care providers into the Provider Platforms is considered Protected Health Information (“PHI”) and/or medical information and is governed by applicable state and federal laws that apply to that information, for example the Health Insurance Portability and Accountability Act (“HIPAA”). 

Our Privacy Policy and Terms of Use.

This Privacy Policy is incorporated into our Terms of Use, which also apply when you use our Platform.

 

III. Personal Information

What is Personal Information?

Personal information is information from and about you that may be able to personally identify you. We treat any information that may identify you as personal information. For example, your name and e-mail address are personal information. 

What types of Personal Information do we collect? 

We may collect and use the following personal information (hereinafter, collectively referred to as “Personal Information”):

Categories of Personal Information

Specific Types of Personal Information Collected

Personal Identifiers

A real name, birth date, e-mail address, home, billing, shipping address, or telephone number.

Information that identifies, relates to, describes, or is capable of being associated with a particular individual

Physical characteristics or description, credit card number, debit card number, or any other financial information, health or medical information, photo, video or voice of an individual.

Characteristics of protected classifications under California or federal law.

Race, Color, Age, National origin, sexual orientation or preference or Disability

Internet or other electronic network activity information

IP address, device mode, device ID, advertising ID, OS version, device language, operating system, browser type, browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement. 

User Generated Content

Information you provide to be published or displayed (hereinafter, “Posted”) on public areas of our Website or transmitted to other users of the Website or other third parties. 


How do we collect your Personal Information?

In part we collect Personal Information directly from you. For example, when we speak to you by phone, text message, and e-mail. Additionally, we will collect information from you when you visit our Platform and fill out forms, or otherwise purchase services from us.

We may also collect Personal Information in the following ways:

  • When you make payments through the Platform. We do not collect or store financial account information, though we may receive transaction identifiers and summary information that does not include credit card or bank account numbers.
  • When You Contact Us. When you contact Luma Health directly, such as when you contact our customer support team, we will receive the contents of your message or any attachments you may send to us, as well as any additional information you choose to provide.

We will also collect information automatically as you navigate through our Platform.

We, as well as third parties that provide advertising and analytics services to us, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

  • Cookies. Cookies are small text files placed in visitors’ computer browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
  • Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may use Facebook Pixel and Instagram
  • Analytics. We may also use Google Analytics, Marketo, LinkedIn Analytics, Gigya, Site Improve, Facebook Analytics, and Twitter Analytics and other service providers to collect information regarding visit, or behavior and visitor demographics on our Services. For more information about Google Analytics see: google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to: http://tools.google.com/dlpage/gaoptout. Google Ads (AdWords) remarketing service is provided by Google Inc. You can opt-out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads. Facebook’s Data Policy can be found at: https://www.facebook.com/about/privacy/ and withdraw your consent for use of your data with Facebook Pixel at: https://www.facebook.com/settings/?tab=ads#_=_
  • Other third party tools. We use other third party tools which allow us to track the performance of our Platform. These tools provide us with information about errors, app and website performance, and other technical details we may use to improve our Platform and/or the Services. 

How do we use your Personal Information? 

  • We may use your Personal Information for the following purposes: 
  • Operate, maintain, supervise, administer, and enhance our Platform or the Services, including monitoring and analyzing the effectiveness of content on the Platform, aggregate site usage data, and other usage of the Platform and/or the Services such as assisting you in completing the registration process.
  • Provide our Products and Services to you, in a custom and user-friendly way. 
  • Provide you with information, Products, or Services that you request from us or that may be of interest to you. 
  • Promote and market our Platform and/or the Services to you. For example, we may use your Personal Information, such as your e-mail address, to send you news and newsletters, special offers, and promotions, or to otherwise contact you about Products or information we think may interest you. We also may use the information that we learn about you to assist us in advertising our services on third party websites. You can opt-out of receiving these e-mails at any time as described below.
  • To provide you notices or about your account. 
  • Contact you in response to a request. 
  • To notify you about changes to our Platform and/or the Services or any Products we offer or provide through them. 
  • Fulfill any other purpose for which you provide it. 
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection. 
  • Anonymize and aggregate information for analytics and reporting. 
  • To respond to law enforcement requests, court orders, and subpoenas and to carry out our legal and contractual obligations.
  • Authenticate use, detect fraudulent use, and otherwise maintain the security of our Platform and the safety of others. 
  • To administer surveys and questionnaires. 
  • To provide you information about goods and services that may be of interest to you, including through newsletters.
  • Any other purpose with your consent. 

How do we share your Personal Information? 

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

  • Our business purposes. We may share your Personal Information with our affiliates, vendors, service providers, and business partners, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security advisors. We may also share your Personal Information with professional advisors, such as auditors, law firms, and accounting firms.
  • Your healthcare providers or family. With your consent, we may share your information, including information collected from your use of our Platform, with your health care providers. 
  • With your consent. We may share your Personal Information if you request or direct us to do so. 
  • 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. 
  • Business Transfer. We may share your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our users are among the assets transferred. 
  • To enforce our rights. We may share your Personal Information to enforce any applicable terms and conditions and Terms of Use, and to ensure the safety and security of our Services and our users. 
  • De-identified information. We may also disclose de-identified information, so that it cannot be reasonably used to identify any individual, with third parties for marketing, advertising, research, or similar purposes. 
  • To market our products and services. We may share your Personal Information with affiliates and third parties to market our products and services. 
  • Third Party Analytics. We use Google Analytics and other third-party analytics services to understand and evaluate how visitors interact with our Platform and/or the Services. These tools help us improve our Platform and/or the Services, performance, and your experience.
  • Our affiliated companies
  • International Data Transfers. Information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. Where required by applicable law, we will ensure that appropriate safeguards are in place to protect your Personal Information. If we engage a third party to process Personal Information on our behalf, we will also contractually require them to handle your Personal Information appropriately. Further details can be provided upon request.
  • Except as provided in this Privacy Policy, we do not disclose or sell your personal information. 
  • Your choices about how we share your Personal Information. 

    This section of our Privacy Policy provides details and explains how to exercise your choices. We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Information for our advertising to you, and other targeted advertising. We do not control the collection and use of your information collected by third parties. These third parties may aggregate the information they collect with information from their other customers for their own purposes. You can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States by visiting the National Advertising Initiative’s (NAI) opt-out page and the Digital Advertising Alliance’s (DAA) opt-out page.

    Each type of web browser provides ways to restrict and delete cookies. Browser manufacturers provide resources to help you with managing cookies.

    If you do not wish to have your e-mail address used by Luma Health to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any e-mail or other marketing communications you receive from us. This opt-out does not apply to information provided to Luma Health as a result of a product purchase, or your use of our Platform and/or the Services. You may have other options with respect to marketing and communication preferences through our Platform.

    Rights Under Applicable Law

    In accordance with applicable law, you may have the right to:

    • Access Personal Information about you consistent with legal requirements. In addition, you may have the right in some cases to receive or have your electronic personal information transferred to another party.
    • Request correction of your Personal Information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your Personal Information or we may refer you to the controller of your Personal Information who is able to make the correction. 
    • Request deletion of your Personal Information, subject to certain exceptions prescribed by law.
    • Request restriction of or object to processing of your Personal Information, including the right to opt in or opt out of the sale of your Personal Information to third parties, if applicable, where such requests are permitted by law.
    • Obtain categories of Personal Information we have either disclosed or sold about consumers in California for a business purpose in the past 12 months.

    IV. Children’s Privacy

    Our Services are not intended for children under 18 years of age. We do not knowingly collect or sell Personal Information from children under the age of 18. If you are under the age of 18, do not use or provide any information on or to the Platform or through any of its features. If we learn we have collected or received Personal Information from a child under the age of 18 without verification of parental consent, we will delete it. If you are the parent or guardian of a child under 18 years of age whom you believe might have provided use with their Personal Information, you may Contact Us to request the Personal Information be deleted. 

    V. Does Luma Health respond to Do Not Track signals?

    Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Platform is not set up to respond to those signals.

    VI. Data Security

    We have taken steps and implemented administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use. The Internet is not 100% secure and we cannot guarantee the security of information transmitted through the Internet. Where you have been given or you have chosen a password, it is your responsibility to keep this password confidential. 

    The sharing and disclosing of information via the internet is not completely secure. We strive to use best practices and industry standard security measures and tools to protect your data. However, we cannot guarantee the security of Personal Information transmitted to, on, or through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Platform, in your operating system, or mobile device. 

    VII. California’s Shine the Light Law.

    California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Platform and/or the Services that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g. requests made in 2021 will receive information regarding such activities in 2020). You may request this information once per calendar year. To make such a request, please Contact Us using the information below.

    VIII. Changes to our Privacy Policy

    We may update our Privacy Policy periodically to reflect changes in our privacy practices, laws, and best practices. We will post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on our Website’s homepage or our App’s home screen. If we make material changes to our practices with regards to the Personal Information we collect from you, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Website’s home page or the App’s home screen. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically accessing the App or visiting our Website and reviewing this Privacy Policy to check for any changes. 

    IX. Contact Us

    If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact Us” page on the Platform. 

    How to Contact Us:

    Luma Health, Inc.

    support@lumahealth.io

    3 East 3rd Ave, Suite 401
    San Mateo, CA 94401