Privacy Policy

Privacy Policy

Effective as of March 15, 2023.

This Privacy Policy describes how Retain Health, Inc. and our corporate subsidiaries and affiliates (collectively, “Retain Health”, “we”, “us”, or “our”) collects, uses and shares your personal information if you use our Retain Your Brain platform available at www.retainhealth.com, visit www.retainhealth.com, or our other websites or services that link to this Privacy Policy (collectively, the “Services”), contact us, receive our communications, or attend our events.

This Privacy Policy does not address our practices during federally regulated clinical trials. You can learn more about how we use and protect data collected as part of a clinical trial by reviewing the informed consent applicable to your participation or by contacting us.

Table of Contents

 

Personal Information We Collect

Information you provide to us.  Personal information you provide to us through the Services may include:

  • Contact information, such as your first and last name, email address, and phone number.
  • Profile information, such as your username and password and any account preferences for the Services.
  • Feedback or correspondence, such as information you provide when you contact us with questions, feedback, or otherwise correspond with us.
  • Usage information, such as information about how you use the Services and interact with us, including information you provide when you use any interactive features of the Services.
  • Marketing information, such as your preferences for receiving communications about our products, activities, and publications, and details about how you engage with our communications.
  • Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.
  • Health background that we may collect by prompting you during use of the app to enter information about your medical history, family history, and lifestyle.

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Information we obtain from social media platforms. We may maintain pages for Retain Health on social media platforms, such as Medium, Facebook, Twitter, and LinkedIn. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.

If you choose to connect your account on a third-party platform or network to the Services, we may collect information from that platform or network. You may also have the opportunity to provide us with additional information via the third-party platform or network, such a list of your connections. You can read more about your privacy choices for social media networks and other third-party platforms below.

Information we obtain from other third parties.  We may receive personal information about you from third-party sources, such as marketing partners, publicly-available sources, and data providers.

Cookies and Other Information Collected by Automated Means
We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and activity occurring on or through the Services. The information that may be collected automatically includes your computer or mobile device operating system type and version number, manufacturer and model; device identifier; browser type; screen resolution; IP address; the website you visited before browsing to our website; general location information such as city, state or geographic area; and information about your use of and actions on the Services, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and length of access.  Our service providers and business partners may collect this type of information over time and across third-party websites and mobile applications.

See our Cookie Policy for more information.

How We Use Your Personal Information

We use your personal information for the following purposes and as otherwise described in this Privacy Policy or at the time of collection:

To operate the Services.  We use your personal information to:

  • provide, operate, and improve the Services;
  • establish and maintain your user profile on the Services;
  • facilitate social features of the Services, such as connecting with other users, and our blog;
  • communicate with you about the Services, including by sending you announcements, updates, security alerts, and support and administrative messages;
  • understand your interests and personalize your experience with the Services;
  • provide support and maintenance for the Services; and
  • respond to your requests, questions and feedback.

For research and development. We analyze use of the Services to improve the Services,  and to develop new products and services.

To send you marketing and promotional communications. We may send you marketing communications as permitted by law. You can opt out of our marketing and promotional communications as described below.

To comply with law.  We use your personal information as we believe necessary or appropriate to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.

For compliance, fraud prevention, and safety.  We may use your personal information and disclose it to law enforcement, government authorities, and private parties as we believe necessary or appropriate to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); (b) enforce the terms and conditions that govern the Services; and (c) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

With your consent.  In some cases we may specifically ask for your consent to collect, use, or share your personal information, such as when required by law.

To create anonymous data.  We may create aggregated and other anonymous data from your personal information and other individuals whose personal information we collect.  We make personal information into anonymous data by removing information that makes the data personally identifiable to you.  We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business. We may in the future partner with organizations to share or even sell de-identified health information that we receive as part of the Services to show measurable health outcomes and build commercial relationships. This data will be de-identified pursuant to the Safe Harbor method (as detailed in HIPAA) before being shared and we will prohibit the recipient from a) re-identifying, or attempting to re-identify, the natural person associated with the de-identified health data, b) further disclosing the de-identified health data to any third party unless the third party is contractually bound by restrictions and conditions the same as or stricter than those of the seller or licensor of the de-identified health data.

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How We Share Your Personal Information

We do not share your personal information with third parties without your consent, except in the following circumstances or as otherwise described in this Privacy Policy:

Affiliates.  We may share your personal information with our corporate subsidiaries and affiliates for purposes consistent with this Privacy Policy.

Service providers.  We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate the Services.  As of the date we posted this privacy policy, some of our vendors and areas where we use service providers are: customer support, hosting (AWS (the privacy policy is here) and Netlify (the privacy policy is here), analytics (Google Analytics, the privacy policy is here), email delivery (Amazon SES, Simple Email Services, the AWS privacy policy applies), text message delivery (Twilio, the privacy policy is here), marketing, and database management services (AWS RDS, the AWS privacy policy applies)). These third parties may use your personal information only as authorized by their contracts with us.

Partners. See our Cookie Policy for more information about third parties that collect information through our Services with cookies and similar technologies.  We may share de-identified health information with partners as described above.

Third-party platforms and social media networks. If you have enabled features or functionality that connect the Services to a third-party platform or social media network (such as by connecting your account with a third party to the Services or sharing content via a third-party platform), we may disclose the personal information that you authorized us to share. We do not control the third party’s use of your personal information.

Other Users of the Services and the Public. We may provide functionality that enables you to disclose personal information to other users of the Services or the public. For instance, if you submit content to the Services (such as comments to a blog post or chat room, sharing information about lifestyle changes with other users when you choose to do so, such as to build a support network to help you stay on track and achieve your goals), we may display some information, such as your name and a link to your user profile along with the content you submit. We do not control how other users or third parties use any personal information that you make available to other users or the public.

Professional advisors. We may disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.

For compliance, fraud prevention and safety. We may share your personal information for the compliance, fraud prevention and safety purposes described above.

Business transfers.  We may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a (potential) business transaction such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

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Your Choices

In this section, we describe the rights and choices available to all users.

Access or update your information. If you have registered for an account with us, you may review and update certain personal information in your account profile by logging into your account.

Opt out of marketing communications.  You may opt out of marketing emails by following the unsubscribe instructions at the bottom of the email. You may continue to receive service-related and other non-marketing emails.

Cookies & browser web storage.  For information on how to disable cookies and similar technologies used in the Services, see our Cookie Policy.

Do Not Track.  Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit.  We currently do not respond to “Do Not Track” or similar signals.  To find out more about “Do Not Track,” please visit www.allaboutdnt.com.

Choosing not to share your personal information. Where we are required by law to collect your personal information, or where we need your personal information to provide the Services to you, if you do not provide this information when requested (or you later ask to delete it), we may not be able to provide you with the Services.  We will tell you what information you must provide to receive the Services by designating it as required at the time of collection or through other appropriate means.

Third-party platforms or social media networks. If you choose to connect to the Services via a third-party platform or social media network, you may have the ability to limit the information that we may obtain from the third party at the time you connect your third-party account to the Services. Subsequently, you may be able to control your settings through the third-party platform. If you withdraw our ability to access certain information from a third-party platform or social media network, that choice will not apply to information that we have already received from that third party.

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Other Sites, Mobile Applications, and Services

The Services may contain links to, or content or features from, other websites and online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in mobile applications or online services that are not associated with us. We do not control third-party websites, mobile applications, or online services, and we are not responsible for their actions.  Other websites and services follow different rules regarding the collection, use, and sharing of your personal information.  We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

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Security Practices

The security of your personal information is important to us.  We employ a number of organizational, technical and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.  As of the date of this policy, it is our policy to use the following security practices:

annual risk assessments, de-identification and encryption of all personal identifiable information automated administrator alerts for account authentication failures, and maintain a strong password policy.

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International Data Transfers

We are headquartered in the United States and have service providers in other countries, and your personal information may be transferred outside of your state, province, or country to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

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Children

The Services are not directed to, and we do not knowingly collect personal information from, anyone under the age of 16.  If we learn that we have collected personal information of a child without the consent of the child’s parent or guardian, we will delete it.  We encourage parents with concerns to contact us.

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Changes to this Privacy Policy

We may amend this Privacy Policy at any time by posting the amended version on the Services and indicating the effective date of the amended version. We may announce any material changes to this Privacy Policy through the Service and/or via email if we have your email address.  In all cases, your continued use of the Services after the posting of any modified Privacy Policy indicates your assent to the amended Privacy Policy.

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How to Contact Us

If you have any questions or comments about this Policy or Retain Health’s privacy practices, email us at support@retainhealth.com. You may also write to us via postal mail at:

Retain Health

Attn: Legal – Privacy

200 Great Rd. Suite 238, Bedford, MA 01730

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Your California Privacy Rights

Under California law, California residents are entitled to ask us for a notice identifying the categories of personal customer information that we share with certain third parties for marketing purposes, and providing contact information for such third parties.  We do not share personal customer information with third parties for their marketing purposes.

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Your Nevada Privacy Rights

Nevada residents may review and make changes to their information by contacting us at support@retainhealth.com.  In some cases, users may review and make changes to their information directly in the platform.

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