Last Updated Date: 11/7/2024
Welcome to NOWINCLUDED! Acclinate, Inc. (“Acclinate”, “we”, “us” or “our”) operates NOWINCLUDED, and we care about your privacy. We have developed this Privacy Policy (this “Policy”) to describe the information we collect, how that information may be used, with whom it may be shared, and your choices, in connection with your use of (1) our website located at https://nowincluded.com, any related subdomains, and any other websites that we link to this Policy (collectively, the “Website”), (2) our mobile application (the “App”) and (3) our NOWINCLUDED health resource community platform, including our in-person events, community outreach efforts, and related services and resources (collectively, the “Community”). The Website, the App, the Community, and all related services, content, and other resources available on or enabled via the Website, the App, and the Community shall be considered the “Services.”
This Policy is incorporated into, and is part of, our Terms of Use, which governs your access to and your use of our Services. This Policy does not cover information we receive from third parties. If you have any questions regarding this Privacy Policy, please contact us at [email protected].
By accessing the Services, you agree to be bound by this Policy. If you do not agree to the terms of this Policy, please do not use the Services. Each time you use the Services, the current version of this Policy will apply. Accordingly, when you use the Services, you should check the date of this Policy (which appears at the top) and review any changes since you last reviewed the Policy.
We respect your privacy rights as users and recognize the importance of protecting information collected from you. Our privacy philosophy at Acclinate is to provide clear and transparent information to you so that you know exactly how we use and disclose the personal information that you’ve shared with us.
We collect two types of information from users of our Services: “personal information,” which is information that can be used to identify you (such as your name, email address, or your phone number), and “aggregate information,” which is information that cannot be used to identify you (such as frequency of visits to our Website and your browser type). We collect personal information and aggregate information in the contexts described below.
Important: Acclinate is not a “covered entity” or “business associate” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), therefore, HIPAA does not apply to the personal information that you provide to us.
If you choose to share information publicly through our Services, please understand that we cannot control the actions of third parties who could access and collect this information.
In general, we collect information from you so that we can provide our Services, operate our business, and provide information that you request from us.
When you use our Services, we automatically receive and collect information from your device. This information includes the following:
Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser to help us identify you when you come to our Website. You have choices with respect to cookies. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies you may be unable to use those aspects of our Website that require registration in order to participate. You can learn more about cookies and how they work at www.allaboutcookies.org. You can always disable cookies through your browser settings. Doing so, however, may disable certain features on our Website. You can opt-out from third party cookies that are used for advertising purposes on the NAI website at http://www.networkadvertising.
We may use third parties, such as Google Analytics or other analytics providers, to analyze traffic to our Website. Google Analytics does not create individual profiles for visitors and only collects aggregate data. To disable Google Analytics, please download the browser add-on for the deactivation of Google Analytics provided by Google at http://tools.google.com/dlpage/gaoptout?hl=en. To learn more about privacy and Google Analytics, please consult the Google Analytics overview provided by Google at http://www.google.com/intl/en/analytics/privacyoverview.html. You may find additional information about Google Analytics at http://www.google.com/policies/privacy/partners/. You have the option to opt out of Google’s use of cookies by changing your settings through Google Ad Settings via the Google advertising opt-out page.
We may also use cookies, pixels, beacons, or other web tracking technologies to track the amount of time spent on our Website or social media and whether or not certain content, such as a video, was viewed. We may work with a third party to collect and process this information for us, based on our instructions and in compliance with this Policy.
At the present time our Website does not respond to “Do Not Track” signals or similar mechanisms.
We may also participate in interest-based advertising using similar technology. This means that you may see advertising on our Website tailored to how you browse, or you may see advertising for Acclinate or NOWINCLUDED on other websites based on your browsing behavior across websites. Some websites where we may advertise belong to ad networks that use your web browsing history to choose which ads to display on their network websites; these ads include advertising for Acclinate, NOWINCLUDED, and our Services. Other websites where you see our ads may use interest preferences that you have chosen on those sites, as well as registration and other information about you, to choose which ads to display to you. Some internet browsers, websites and mobile devices offer opt-outs for interest-based advertising. Please refer to the website that you are visiting, your browser and/or your device settings for additional information.
You can opt-out of receiving interest-based ads from third parties who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website (http://www.networkadvertising.org/choices/) and DAA website (http://www.aboutads.info/choices/).
We use Meta Pixel to customize our advertising and to serve you ads on your social media based on your browsing behavior. This allows your behavior to be tracked after you have been redirected to our Website by clicking on the Facebook ad. The Meta Pixel stores a cookie on your device to enable us to measure the effectiveness of Facebook ads for statistical and market research purposes. We do not have access to the information collected through the Meta Pixel. However, the information collected via the Meta Pixel is also stored and processed by Facebook. Facebook may link this information to your Facebook account and also use it for its own promotional purposes in accordance with Facebook’s Data Usage Policy. The Meta Pixel also allows Facebook and its partners to show you advertisements on and outside of Facebook. You can opt-out of displaying Facebook ads by visiting your Facebook Ad Settings, and you can clear and control the information third parties share with Facebook in your Off-Facebook Activity page. If you do not have a Facebook account, you can opt-out of Facebook ads through the Digital Advertising Alliance as described above.
We use session-replay technologies provided by third parties to record your interactions with the Services to help us diagnose problems and improve our Services. These technologies allow us to watch a DVR-like visual video playback of user sessions on our Services and capture your activities such as your clicks, mouse movements, scrolls, and keystrokes/key touches when you use our Services, and may collect personal information from and about you.
In general, we use personal information that we collect from you to provide our Services, operate our business, and provide information that you request from us. This includes the following uses and purposes:
Additionally, we use algorithms and machine learning models for personalization, safety and security, and to prevent abuse or other Terms of Use violations, including when you interact with our Chatbot. For example, our algorithms and machine learning models take into account the conversations you are having with our Chatbot to improve the responses we generate.
We want to be clear: we don’t rent or sell your personal information.
Like most companies, we share information in certain circumstances with third parties through operation of our Services and our business. Below we explain when that happens.
Many features of the Services are private but you may post personal information, such as your story, to our Community. For example, when you share your story, your first name and any information about you that you share in your story may be visible and displayed to other users and to the public.
We use third parties to assist us with operating our business and providing our Services, such as our technology vendors that help us maintain our Services, partners that assist us with our marketing and communication, and service providers that help us to prevent and detect fraud. These service providers will have access to your information in order to provide their services to us.
Our Chatbot leverages certain artificial intelligence and deep learning platforms, algorithms, tools and models (“AI Services”) to collect, analyze, and respond to user prompts and requests with automated advice. When you use the Chatbot, we may share any content or other information you provide to the Chatbot with the AI Services in order to complete your request.
If you respond to clinical trial prescreening questionnaires (as described above), we may share your contact information (such as your name and email address) with study sites (“Sites”) involved in conducting clinical trials, such as hospitals, clinics, physician offices, and universities. We do not share your prescreening questionnaire responses with the Sites, however, the Sites may be able to infer certain information about you based on your interest in a specific clinical trial. For example, if you express interest in a clinical trial involving high blood pressure, the Site may infer that you have high blood pressure. The Sites use your contact information to reach out to you with additional information about their clinical trials and with additional questions to determine if you may be eligible to participate in a clinical trial being conducted at the Site. Sometimes, a third party vendor is involved in helping Sites with these study participant recruitment efforts. We do not control the actions of the Sites or these third party vendors once they receive information from us, nor when they receive information from you or from any other third party.
Except as otherwise provided in this Policy, we share information with companies, organizations or individuals outside of Acclinate only at your direction or when we have your consent to do so.
We may share information with third party companies, organizations, governmental authorities, or individuals outside of Acclinate if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
We may share information about you as part of a merger or acquisition. If Acclinate is involved in a merger, asset sale, financing, liquidation or bankruptcy, or acquisition of all or some portion of our business to another company, we may share your information with that company before and after the transaction closes. In such a case, unless permitted or otherwise directed by applicable law, your information would remain subject to the terms of the applicable privacy policy in effect at the time of such transfer.
We may de-identify or aggregate any information, including personal information, that we collect from or about you so that you are not identified as an individual, and use and disclose that information to third parties without restriction, including for commercial purposes. We may also provide aggregate usage information and data to third parties (or allow third parties to collect that information from you), who may use such information to understand how often and in what ways people use our Services. However, we never disclose aggregate usage or de-identified information to a third party (or allow a third party to collect such information) in a manner that would identify you as an individual person.
We strive to provide you with choices with respect to your personal information. Also, remember, you can opt not to disclose certain information to us – but keep in mind some information may be needed to create an account or to take advantage of some of the features of our Services.
Community members can delete, access, and modify most of their information directly through their accounts. If you would like to delete, modify, or access additional information that is not available through your account, please contact us at [email protected]. We may ask you to verify your identity or provide additional information before we act on your request.
We may reject or deny requests for certain reasons, such as when we believe a request is fraudulent, or when we are required to retain information for legal or record-keeping reasons.
Please note that in some cases we may be prohibited from deleting certain information (we will let you know in those situations), and some information may remain in our records after your deletion of such information from your account. We may use any aggregated or de-identified data derived from or incorporating your information after you update or delete it, but not in a manner that would identify you personally.
You may unsubscribe from our marketing communications at any time by following the “unsubscribe” link at the bottom of any such communication. Most promotional communications will also offer recipients choices about receiving additional messages.
Generally, we keep your information for as long as you tell us to, or otherwise as long you have an account with us, as long as we need it to provide our Services.
We may be required to retain information to comply with certain legal obligations.
We may need to retain your information to prevent harm, investigate possible violations of our Terms of Use or other policies, investigate reports of abuse, or protect ourselves or others.
In some cases, we may need to comply with legal requirements to store your information, which prevents us from deleting it. For example, if we receive a notice from a court, if we get reports of abuse or other or policy or terms violations, or if your account, content created by you, or content created with other users is flagged by others or our systems for abuse or other terms or policy violations.
Our Services are not directed at children under 13, and we do not knowingly collect information from children under 13. If you are under 13, please do not attempt to use our Services or send any information about yourself to us.
We use reasonable security measures, including measures designed to protect against unauthorized or unlawful processing and against accidental loss, destruction or damage to your information. We also take certain measures to enhance the security of our Services, however, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information.
Our Services may contain links to other websites and services operated by third parties, and may include social media features such as Twitter, Facebook, and Instagram buttons or links. These third party websites and services may collect information about you if you click on a link or visit those websites or services, and the social media sites may automatically record information about your browsing behavior every time you visit a website that has a social media button. Your interactions with these features and third parties are governed by the privacy policy of the third party, not by this Policy.
We may make changes to this Policy from time to time. When we do, we will post the updated version on this page. We encourage you to read this page each time that you use our Services so that you will be aware of any changes, and your continued use of our Services shall constitute your acceptance of any such changes. Changes to this Policy take effect from the date of publication, unless stated otherwise.
If you have any comments, questions, concerns, complaints, or suggestions about our Policy, or about our privacy practices in general, please contact us at [email protected].
