1.0 PRIVACY POLICY DISCLOSURE 

 

Last modified: February 23, 2021

 

Navus Health (“Navus” “us,” “we,” “our,” or “us”) is committed to protecting your privacy. This Navus Health Privacy Policy (this “Policy”) applies to our websites, online experiences and mobile apps for Apple iOS, Windows, or Android mobile devices that link to this Policy (collectively, our “Sites”), and describes how we collect, use and disclose your personal information when you visit our Sites, Pop Up Clinics, visit with our Clinical Testers for in-home testing services, or otherwise engage with us (collectively, our “Service,”  or “Services”).

 

By accessing or using our Service, you signify that you have read, understood, and agree to our collection, storage, use, and disclosure of your personal information as described in this Policy.

 

Click on the links below to jump to each section:

 

(1) WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

(2) HOW DO WE USE PERSONAL INFORMATION?

(3) WHAT INFORMATION MAY BE COLLECTED AUTOMATICALLY?

(4) HOW WE SHARE YOUR INFORMATION

(5) CALIFORNIA RESIDENTS

(6) YOUR CHOICES AND CONTROL OVER YOUR INFORMATION

(7) HOW WE STORE AND PROTECT YOUR INFORMATION

(8) CHILDREN’S PRIVACY

(8) LINKS TO OTHER WEB SITES AND SERVICES

(10) HOW TO CONTACT US

(11) CHANGES TO OUR PRIVACY POLICY

 

 

  1.  WHAT PERSONAL INFORMATION DO WE COLLECT ABOUT YOU?

 

We may collect several types of information about you in connection with our Services. 

 

Information You Provide to Us.

There are a number of circumstances in which you supply us with personal information in connection with the Services, which include:

 

Contact data such as your personal or business contact information such as your name, e-mail address, street address and phone number.

Registration data such as information you provide when you register for any of our Services or when you register for events.

Payment and transaction information such as items purchased, date and time of your transaction, amount purchased, whether you used a particular coupon or deal, and payment information, such as your credit/debit card, when you make an online purchase or in-person interaction with us. We use this information to fulfill your order and complete your transaction, update your profile, detect and prevent fraud, and to inform of our advertising and marketing.

 

Marketing data such as information related to your preferences for receiving communications, subscribing to our publications, newsletters and other content, completing surveys, participating in market research, coupons, and other related Services. 

Communications, Comments, chat and opinions: When you contact us directly (e.g., by email, phone, mail or by completing an online form or participating in online chat), we may record your comments and opinions.  We may also record comments and opinions you express when responding to surveys, or taking part in a promotion. We use this information to respond to your question or comment, to evaluate and improve our products and services and to inform our marketing and advertising activities.  When you contact us directly to submit a concern, complaint or question, we may record your comments and collect the personal information contained in your communications (e.g., contact information, health or medical information,, etc.). We use this information to respond to your questions or concerns, and to evaluate and improve our products and services.

Demographic information such as your city, state, country of residence, postal code, gender and age.

Profile information such as your username and password that you may set to establish an online account with us, your photograph, interests, social media account ID, and preferences.

Content you choose to upload to the Services such as text, images, audio, and video, along with the metadata associated with the files you upload.

Information from Third Parties:  We may receive information about you from third parties and combine it with information we receive from or about you. For example:

Information from social media websites:  When you interact with any Navus Health page or account on a social media platform, such as Facebook, Twitter, Instagram, or LinkedIn, or otherwise connect your account on the third-party platform or network to your account through our sites, we may collect the personal information available from that page or platform or that you make available to us on that page or account, including your social media account ID, username, user ID, profile picture, cover photo, and networks to which you belong, friends and connections and contact information.  You can read more about your choices in the “Your Choices and Control Over Your Information” section.

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.

 Information from publicly or commercially available sources: We may collect certain information about you from third parties, including business partners (such as advertising and joint marketing partners) data providers (such as information services and data licensors) and public sources (such as blogs, forums or social media platforms).

 Information we receive from authentication services you connect to our Service. We may receive information from Face ID, Touch ID or fingerprint authentication as a log-in method if you access the Service through an Apple or Android device equipped with authentication technology. We are only notified as to whether the authentication was successful and cannot access the data associated with the enrolled fingerprint. For more details, please refer to the fingerprint security guides offered by your device provider.

 Other Information We Collect. We also may collect other information about you, your device, or your use of the Services in ways that we describe to you at the point of collection.  You may choose not to provide us with certain types of information, but doing so may affect your experience in using the Services.

 

(2) HOW DO WE USE PERSONAL INFORMATION?

 

To fulfill your requests and provide our Services to you. For example, we may use your information to complete your order or other online and in-person transactions, deliver orders you place online, coordinate and facilitate delivery of specimen sent to lab, coordinate and facilitate delivery of specimen results from lab, or respond to your customer service requests or feedback. We may also use your information to personalize your experience with us and facilitate any discounts, or coupons. We also use this information to provide the Service to you across our operations, including by supporting your in-person experience when you engage with different product services and offerings.

For marketing purposes. We may send you communications about new features, updates, products and special offers. We may also use your information to serve you ads about products and special offers about our products or other products or services we think you might find interesting. We may also use individual and aggregate information about you to inform our marketing and advertising campaigns. For more information on your choices about marketing communications, see Your Choices and Control Over Your Information below.

To communicate with you. For example, we may communicate with you about your account activities, such as by providing you transaction confirmations, or updating you about upcoming scheduled appointments for which you’ve requested. If you register with us, we may enroll you in our email newsletter or other periodic electronic communications and may also send you user surveys and promotional communications. We may communicate with you by email, postal mail, telephone, text message, or other means. We may use push notifications on our mobile apps to your mobile device. For more information on how to adjust your communications preferences, see Your Choices and Control Over Your Information below.

To monitor, improve and develop our products and services. We may use your information to understand our online visitors and in-person interactions and tailor our product offerings accordingly. From time to time, we analyze statistics and trends to make our Sites and Services better and to develop new services or features.

To protect the security and integrity of our business, comply with legal requirements and obligations, or as otherwise permitted by law. We may use information to protect our company, our affiliates, our customers, and our websites. We may also use information in order to comply with laws, regulations, court orders, or other legal obligations or to assist in an investigation, to protect and defend our rights and property, or the rights or safety of third parties, to enforce our Terms of Use, this Policy, or agreements with third parties, to detect and prevent fraud or for crime-prevention purposes, or for any other reason permitted by law.

 

 (3) WHAT INFORMATION MAY BE COLLECTED AUTOMATICALLY?

 Information We Automatically Collect About Your Use of the Services. We, our service providers, and our business providers may automatically log information about you, your computer or mobile device, and your activity occurring on or through our websites, such as:

Device information: We may collect device identifiers and settings such as your computer or mobile device model, IP address, other unique device identifiers, operating system version, browser type, language, and settings, and device type and settings. 

  •       Usage information: We may collect information about the Services you use, the time, date, and duration of your use of the Services, your interaction with content offered through the Services, site engagement, search terms used, our referring website, browsing and search history, site and advertisement interactions, and software crash reports. We also collect information stored using cookies, mobile ad identifiers, and similar technologies set on your device. Our servers may automatically keep an activity log of your use of the Services. We may collect such usage information at the individual or aggregate level.
  •       Location information: We collect and store your device’s source IP address, which may disclose the general location of your device at the time you access the Services and precise location derived from GPS-enabled services.  Advertisements and certain content may be directed to you based on this data.

 

Cookies and Other Similar Tracking Technologies

We may collect data about your use of the Services through cookies and other similar tracking technologies. 

Note that you can change your Internet browser settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer; Google Chrome; Mozilla Firefox; Apple Safari (Desktop); Apple Safari (Mobile); or Android Browser).

You can also manage the use of Flash technologies, including cookies and local storage objects with the Flash management tools available at Adobe’s website.

Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.

 

Location Information

We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information and features. In order to do this, your location information may be shared with our agents and vendors. If you do not want us to provide you with these location-based features, you may disable location tracking through your device settings.

 

 

(4) HOW WE SHARE YOUR INFORMATION

 

We may share your personal data as follows:

 

Affiliates We may share your personal information with our corporate parent HealthG2, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Your Employer. If you are an employee of a Navus Health business customer using an account pursuant to our customer agreement, we may provide or your employer may be able to directly view information you provide to us through the Services.

Third-Party Service Providers. Third party agents and vendors perform functions on our behalf, including, but not limited to marketing, analytics, billing and customer services, lab processing, mobile application processing and shipping and fulfillment.  These entities may have access to personal information if needed to perform their functions.  If such access is required, the third parties will be obligated to maintain the confidentiality and security of that personal information.  They are restricted from using, selling, distributing or altering this data in any way other than to provide the requested services to Navus Health.

Social Media Services. If you log into the Services with a social media service or if you connect a social media account with the Services, we may share information about you or your activities on that social media service, including what you view on our websites and applications, with that social media service and/or its users.  Social media services will use that information based on their own privacy policies.  If you do not want your information shared in this way, do not connect your social media service account(s) with our Services.

With your consent or at your direction: You may choose to share your activities on the Service with your friends through email, text or on various social media networks.  In addition to the sharing described in this Policy, we may share information about you with third parties whenever you consent to or direct such sharing.

Law Enforcement, Legal Process, and Emergency Situations. In some cases, we may use or disclose your personal information to a third party if we are required to do so by law or if we in good faith believe that such action is necessary to comply with the law or legal process; to protect and defend our rights or to prevent misuse of our Services; or to protect the personal safety of our employees, agents, partners, the users of the Services, or the public.

 

(5) CALIFORNIA RESIDENTS

 

This section applies only to California residents.  It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information.  For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

How We Collect, Use, and Share your Personal Information.  We collect the following statutory categories (as defined by CCPA) of Personal Information:

Identifiers: (e.g., name, email address, mailing address, phone number, driver’s license number, passport number, or other similar identifiers.).

 Online identifiers: (e.g., device identifier, IP address, unique browser ID, cookies, beacons, pixel tags, account login, other unique identifiers).

Purchase History or Tendencies: Commercial information, including records of products or services considered, purchased or owned.

 Internet or network information: (e.g., browsing and search history, site and advertisement interactions).

 Geolocation data: (e.g., precise location derived from GPS-enabled services).

Audio/Visual: Audio, electronic, or visual recordings, or similar information.  Please note that we do not intentionally collect this information, but it may be revealed in identity data or other information we collect (e.g., through virtual Zoom testing services)

Employment information: (e.g., information you provide when you or your employer sets up an account with us for Services).

Education information: (e.g., information you provide when you apply for a job with us,).

Protected classification characteristics: (e.g., age or gender)

Inferences (e.g., information about your interests, preferences, and favorites).

 

The sources from which we collect information are described in Section 1 of this Privacy Policy; the business and commercial purposes for which we collect this information are described in Section 2 of this Privacy Policy; and the categories of third parties to whom we “disclose” the information for a business purpose are described in Section 3 and Section 4 of this Privacy Policy. 

As a California resident, you may be able to exercise the following rights in relation to the Personal Information about you that we have collected (subject to certain limitations at law):

The Right to Know

You have the right to request any or all of the following information relating to your personal information we have collected and disclosed in the last 12 months, upon verification of your identity:

  • The specific pieces of personal information we have collected about you;
  • The categories of personal information we have collected about you;
  • The categories of sources of the personal information;
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;
  • The categories of personal information we have sold and the categories of third parties to whom the information was sold; and
  • The business or commercial purposes for collecting or selling the personal information.

The Right to Request Deletion

You have the right to request the deletion of personal information we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales

You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future. 

 

The right to opt out of personal information sales is separate from our direct communications with you for marketing and advertising purposes.

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising these rights.

 

However, please note that if the exercise of these rights limits our ability to process personal information (such as in the case of a deletion or do not sell request), we may no longer be able to provide you our products and services or engage with you in the same manner.

 

“Shine the Light”

 

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

 

Identity Verification and Additional Information Needed to Process a Request.  We reserve the right to confirm your California residence to process your requests and will need to confirm your identity to process your requests to exercise your information, access or deletion rights.  As part of this process, government identification may be required.   California residents can empower an “authorized agent” to submit requests on their behalf.  We will require the authorized agent to have a written authorization confirming that authority.  We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

We will need to verify your identity before processing your request, which may require us to request additional personal information from you. We will only use personal information provided in connection with a Consumer Rights Request to review and comply with the request.

In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request.

Please contact us according to the How To Contact Us section below, if you would like to make a request under this section or if you have any questions regarding this section for California residents.

 

(6) YOUR CHOICES AND CONTROL OVER YOUR INFORMATION

You may update your personal data and your preferences at any time as well as choose to disable your account through your member account portal or by contacting us at privacy@navushealth.com. Different programs and services may offer different phone numbers, links or preference managers that allow you to inform us of your updates and choices, including opting out of particular communications. These contact options are typically available on our Sites or in the emails or texts we send, but you may always contact our Privacy Officer for assistance at privacy@navushealth.com  if you have any difficulty finding these tools or otherwise updating your data or preferences. Please remember that limited communications may be necessary in order to complete your transaction or for you to participate in a particular program or service.

 

(7) HOW WE STORE AND PROTECT YOUR INFORMATION

 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. You need to help protect the privacy of your own information. You must take precautions to protect the security of any personal information that you may transmit over any home networks, wireless routers, wireless (WiFi) networks or similar devices by using encryption and other techniques to prevent unauthorized persons from intercepting or receiving any of your personal information. You are responsible for the security of your information when using unencrypted, open access or otherwise unsecured networks.

How Long Your Information Is Stored.  The time period for which we keep information varies according to the purpose for which it is used for. In some cases, there are legal requirements to keep data for a minimum period. Unless there is a specific legal requirement for us to keep the information, we will retain it for no longer than is necessary for the purposes for which the data was collected or for which it is to be further processed.

 

 

(8) CHILDREN’S PRIVACY

We do not knowingly collect or solicit any information from children under the age of 18. If we discover that a child under the age of 18 has provided us with personal information and we do not have parental consent, we will delete that child’s information as soon as possible. If you believe we may have collected, or may have been provided with the personal information of a child under the age of 18 without parental consent, please notify us immediately at privacy@navushealth.com

 

 

(9) LINKS TO OTHER WEB SITES AND SERVICES

The Service may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability resulting from you following a link to these websites.  Additionally, other privacy policies may apply when you engage with us through a co-branded or co-sponsored promotional or marketing activity. We strongly recommend that you read the privacy policies and terms and conditions of use of any third party website or service to understand how your information will be collected, used and shared. We are not responsible for the privacy practices or the content on the websites of third-party sites.

 

(10) HOW TO CONTACT US

If you have questions about our Privacy Policy, please contact us at privacy@navushealth.com or alternatively you can send correspondence to:

 

Attn: Chief Security & Compliance Officer

Navus Health, LLC

20 Melville Road

Princeton Junction, NJ 08550

 

 

(11) CHANGES TO OUR PRIVACY POLICY

From time to time, we may update this Privacy Policy. Any changes will be effective when we post the revised Privacy Policy. This Privacy Policy was last updated as of the effective date listed above. If the Privacy Policy changes in a way that significantly affects how we handle personal data, we will not use the personal data we previously gathered in the manner described in the new policy without providing notice and/or obtaining your consent, as appropriate.  It is your responsibility to review the Privacy Policy periodically.  Your continued use of the Services following the posting of changes to this Policy will signify you accept those changes.