Protecting your privacy is very important to us. This Privacy Policy describes how Trove Health Tech, Inc. together with our affiliates and subsidiaries (Trove Health, “We”, “Us”, “Our”) collects, uses and discloses personal information in connection with our services, websites and applications (collectively, the “Services”), and when you otherwise interact with us. By using our Services, you consent to this Privacy Policy.

What Information Do We Collect?

Information Collected Directly 
The types of information that Trove Health may collect includes, but is not limited to, the following categories listed below.  We may receive this information when it is provided directly to us by you for use of our Services, through our business partners, and in some cases, certain trusted service providers we work with.  We may also obtain information from other sources for example, we may collect information about you from publicly available sources.  We may combine information that we receive from the various sources described above for the purposes identified in this Privacy Policy.

• Contact Information; such as name; phone number, email address and postal address;

• Account/Authentication Information;such as username and password; 

• Business Information;such as business email address, company name, title, company logo etc.;

• Payment Information; such as your credit card number, CVV code and expiration date collected through our payment processor to process your payments;

• Verification information;may be collected with your consent, such as your driver’s license, passport, e-signatures and other forms of government ID information for verification purposes;

• Personal Health Information;may be collected in some instances with your consent such as health reports, diagnostic and genetic information for some of our Services which include clinical trial matching and recruitment; 

• Demographic Information; such as your gender, age and date of birth, for example, to tailor our Services to you, for age verification and to make our communications to you more relevant;

• Photos and Images;for example, if you choose to provide them while using our Services.

 

Aggregate and Deidentified Information

We may also collect, use and share aggregate and deidentified information that does not identify you as permitted by applicable laws. For example, we may collect, analyze and share statistical information about number of visitors to our website in order to better understand and improve our Services.

Information Collected Automatically When You Use the Service 

As is true of most websites and applications, Trove Health may collect certain information automatically through your interaction with our Services using technologies such as, cookies, pixels, web beacons and tags.  We track and store data about how you visit and use our Services, particularly through our websites and apps. The information we may collect includes without limitation:  your IP address, your operating system, your browser, the URLs of any pages you visit on our sites and apps, device type, unique device identifiers, advertising identifiers and other usage information.

We may combine this data with other information we collect about you. For more information about tracking methods on Trove Health’s Services, and how to manage them, please see our Cookies and Other Technologies section within this Privacy Policy.

How Do We Use Information?

Depending on your use of our Services, we may use your information to:

• To provide, maintain and improve our Services; for example, to provide you with our clinical trial recruitment Services; 

• To manage and administer your account and to personalize and tailor your experience with our website;

• To process your payments (if applicable);

• To provide customer service, including contacting you to provide assistance with our Services;

• For identity, age and proxy consent verification purposes;

• For promotions, surveys research and analytics; 

• For marketing purposes (with consent and/or where permitted by law) for example, we may email you with information and offers related to our Services; 

• To develop new products and Services;

• To protect the rights and property of Trove Health, our users, and others;

• To detect, prevent, and respond to fraud, abuse, and security issues;

• To comply with legal, regulatory or contractual requirements; and

• To carry out any other purpose described to you at the time the information was collected.

Communications with you in connection with these uses may be via mail, telephone, e-mail, text message, social media and other electronic messages.  We may send you text messages using an automated telephone dialing system to the mobile phone number you have provided if you have opted into receive text messages. Opting into receive text messages is not a requirement to buy Services from Trove Health, and message and data rates may apply.  See “Your Choices” below to learn how to manage your communication preferences.

How Do We Share Information?

We may share the information we collect about you in the following circumstances:

• Within Trove Health and our current and future parents, affiliates, subsidiaries and other companies under common control and ownership;

• With our trusted services providers who work on our behalf;

• With our business partners and customers (if applicable) for example, Contract Research Organizations if you opt-in to our clinical trial recruitment Services, or Biotechnology and Pharmaceutical companies for research and development, marketing, and other purposes (with the appropriate authorization, consents and verification)

• With your consent, for example, we may license your Personal Health Information with your consent to our customers.  Another example of when we may share your information with your consent is if you intentionally interact with third-parties on our site;

• With healthcare proxies with the appropriate authorization, consents and verification;

• In connection with the sale, transfer or financing of a significant part of Trove Health’s business or its assets;

• When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud or respond to a law enforcement request; and

• As required by law, such as in conjunction with a subpoena, government inquiry, litigation, dispute resolution or similar legal process.

Cookies and Other Technologies

Cookies are small text files that are transferred from our websites, applications, or services and stored on your device. We use cookies to help us provide you with a personalized service, and to help make our websites, applications, and services better for you.  

Our cookies may be session cookies (temporary cookies that identify and track users within our websites, applications or services that are deleted when you close your browser or leave your session in the application or service) or persistent cookies (cookies which enable our websites, applications, or services to “remember” who you are and to remember your preferences within our websites, applications, or services, and which will stay on your computer or device after you close your browser or leave your session in the application or service).

We use the following different types of cookies:

Strictly necessary cookies:
These are cookies that are needed for our websites, applications, or services to function properly; for example, these cookies allow you to access secure areas of our website or to remember what you have put into your shopping basket.

Performance cookies and analytics technologies:
These cookies collect information about how visitors and users use our websites, applications, and services; for instance, which functionality visitors use most often and if they get error messages from areas of the websites, applications, or services. These cookies do not collect information that identifies a visitor or user. All information these cookies collect is aggregated and therefore anonymous. We only use these cookies to improve how our website, applications, and services work.

Functionality cookies:
These cookies allow our websites, applications, and services to remember choices you make (such as your username, language, or the region you are in) and provide enhanced, more personalized features. These cookies can also be used to remember changes you have made to text size, fonts, and other parts of web pages that you can customize. They may also be used to provide services you have asked for. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

Targeting or advertising cookies:
These cookies are used to deliver advertisements more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operators’ permission. They remember that you have visited a website and this information is shared with other organizations, such as advertisers. Quite often, targeting or advertising cookies will be linked to site functionality provided by the other organization.

Web beacons and parameter tracking:
We also use cookies and similar software known as web beacons to count users who have visited our website after clicking through from one of our advertisements on another website or in emails and to collect details of any products or services purchased. These web beacons collect limited information, which does not identify particular individuals. It is not possible to refuse the use of web beacons. However, because they are used in conjunction with cookies, you can effectively disable them by setting your browser to restrict or block cookies.

How to disable cookies:
For more details on these types of cookies and information on how to opt-out, visit trovehealth.io. You may be able to configure your browser or our website, application, or service to restrict cookies or block all cookies if you wish, however if you disable cookies you may find this affects your ability to use certain parts of our website, applications, or services.

Google Analytics:
Google Analytics uses “cookies,” to help the website analyze how users use the websites, applications or services. The information generated by the cookie about your use of the websites, applications or services (including your IP address) will be transmitted to and stored by Google. Google will use this information for the purpose of evaluating your use of the websites, applications, or services compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third-parties where required to do so by law, or where such third-parties process the information on Google’s behalf. 

You may refuse the use of cookies by selecting the appropriate settings on your browser or within the application, however please note that if you do this you may not be able to use the full functionality of this website. By using our websites, applications, or services you consent to the processing of data about you by Google in the manner and for the purposes set out above. To find out more, see “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/, or any other URL Google may provide from time to time).

To opt out of being tracked by Google Analytics, visit: http://tools.google.com/dlpage/gaoptout.

Do-Not-Track

Your browser or device may include “Do-Not-Track” settings or functionality. Currently, our systems do not recognize browser “Do-Not-Track” requests. The information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Privacy Policy, whether or not a Do-Not-Track signal is received. However, you may disable certain tracking on our Sites, as discussed in the Cookies and Other Technologies section of this Privacy Policy (e.g., by disabling cookies). For more information about Do-Not-Track signals, please click here.

Third Party Links and Social Media

If you follow a third-party link from our website, application, or service to another site or service, this Privacy Notice will no longer apply. We are not responsible for the information handling practices of third-party sites or services and we encourage you to read the privacy notices appearing on those sites or services.

Our websites, applications, or services may enable you to share information with social media sites, or use social media sites to create your account or to connect your social media account. Those social media sites may automatically provide us with access to certain personal information retained by them about you (for example any content you have viewed). You should be able to manage your privacy settings from within your own third-party social media account(s) to manage what personal information you enable us to access from that account.

Your Choices

Accessing, Updating and Modifying Your Personal Information
Subject to applicable law, you may have the right to request access to and receive details about the personal information we maintain about you, update and correct inaccuracies in your personal information, and have the personal information deleted (subject to exceptions), as appropriate. We may take reasonable steps to verify your identity before granting access or making corrections. You may request to access, change or delete your personal information by contacting us at privacy@trovehealth.io.

Email:
You always have the opportunity to opt-out of our marketing communications or change your preferences by following the link provided in the footer of all non-transactional email messages from us, or by emailing us at privacy@trovehealth.io. Some communications from us are considered transactional or service communications (for example, important account notifications and billing information), and your account(s) for our products and services are provided to you upon the condition that you receive these communications from us. You must cancel your account(s) for our products and services, as applicable, if you do not wish to receive any transactional or service communications. You may still receive marketing communications from us even after you cancel your account unless you also opt-out of our marketing communications, as described above.

Phone:
We may contact you by telephone, with your consent where applicable, for marketing purposes (including by automatic dialer and/or prerecorded message). If you do not want to receive marketing text messages, please follow the opt out instructions in the text message. You do not need to agree to receive automated marketing phone calls or texts from us to use our Services.

How We Protect Information

We maintain reasonable administrative, technical, and physical safeguards designed to protect the personal information you provide against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure, or use.

Children

This site is not intended for children under the age of 18 and we do not knowingly collect, process or use any information via this site directly from visitors under the age of 18, however our registration process allows for the entry of information about children by a parent or guardian with the appropriate authorization, consent and verification in order to provide our Services. Children cannot directly register with our sites and applications. 

International Data Transfers

We may transfer the personal information we have about you to countries other than the country in which the information was originally collected and your personal information may be processed and stored outside of your country of residence. Those countries may not have the same data protection laws as your country of residence and your personal information will be subject to applicable foreign laws. When we transfer your information to other countries, we will protect that information in the manner described in this Privacy Policy.

Updates To This Privacy Policy

We may update this Privacy Policy from time to time. When we make updates to this Privacy Policy, we will provide notice on our website so please read it carefully when you visit our website (the ‘last updated’ reference tells you when we last updated this Privacy Policy).

How To Contact Us

Please contact Trove Health Tech, Inc. with any questions that you may have. 

Please contact us at:
Trove Health Tech, Inc.
Phone: 917-648-4535
privacy@trovehealth.io

European Residents

If you reside in the European Economic Area (“EEA”), European Union, United Kingdom or Switzerland, the following rights and disclosures apply to you.  The Controller of your personal information with respect to the use of our Services is Trove Health Tech, Inc. 226 Banks St, Apt 6, Cambridge MA, 02138 who provides clinical trial recruitment services. Visit http://www.trovehealth.io or contact us at +1-917-648-4535 to learn more.

Legal Basis for Processing

Under GDPR we will ensure that your personal data is processed lawfully, fairly, and transparently, without adversely affecting your rights. We will only process your personal data if at least one of the following legal basis applies:

• you have given consent to the processing of your personal data for one or more specific purposes;

processing is necessary for the performance of a contract to which you are a party or in order to take steps at the request of you prior to entering into a contract;

• processing is necessary for compliance with a legal obligation to which we are subject;

• processing is necessary to protect the vital interests of you or of another natural person;

• processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller; and/or

• processing is necessary for the purposes of the legitimate interests pursued by us or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.

Your Rights Under the General Data Protection Regulation (“GDPR”)

In some cases, you also have the following rights related to your personal information under the GDPR:

• The right to access, update, or delete your personal information.

• The right of rectification—to have your information altered if it is inaccurate or incomplete.

• The right to object to our processing of your personal information.

• The right of restriction—to request that we restrict how we process your personal information.

• The right to data portability—to receive a copy of the information we have on you in a structured, machine-readable, and commonly used format.

• The right to withdraw consent to our processing of your personal information.

• The right to complain to an EEA data protection authority (a government agency) about our management of your personal information.

If you wish to know what personal information we hold about you, to have us remove it, or otherwise to exercise your rights, please contact our data protection officer at:

Trove Health Tech, Inc.
226 Banks St, Apt 6, Cambridge MA, 02138
Phone: 917-648-4535
privacy@trovehealth.io

Automated Decision-Making and Profiling

In the event that we use personal data for the purposes of automated decision-making and those decisions have a legal (or similarly significant effect) on you, you have the right to challenge to such decisions under GDPR, requesting human intervention, expressing their own point of view, and obtaining an explanation of the decision from Us.

Your right described in this section does not apply in the following circumstances:
The decision is necessary for the entry into, or performance of, a contract between you and us;

The decision is authorised by law; or 

You have given you explicit consent.

Where we use your personal data for profiling purposes, the following shall apply:
Clear information explaining the profiling will be provided, including its significance and the likely consequences;

Appropriate mathematical or statistical procedures will be used;
Technical and organisational measures necessary to minimise the risk of errors and to enable such errors to be easily corrected shall be implemented; and
All personal data processed for profiling purposes shall be secured in order to prevent discriminatory effects arising out of profiling.