Effective date: January 1st, 2024

This Privacy Policy explains how Online Interventions, LLC, a California limited liability company, (“Online Interventions,” “we,” “us,” and “our”) collects, uses, and discloses information about you through our website, products, and services (collectively, the “Services,” as defined in the Agreement) or when you otherwise interact with us.

Each time you use the Services, the current version of this policy will apply. Policy changes will be reflected on this page and, in some cases, we may notify you with additional notice such as adding a statement to our homepage or sending you a notification.

We encourage you to regularly check the date of this policy and review any changes made to stay informed about our information practices and the choices available to you.

CONSENT

BY SUBMITTING PERSONAL INFORMATION TO ONLINE INTERVENTIONS OR ITS AGENTS, YOU AGREE THAT ONLINE INTERVENTIONS MAY COLLECT YOUR PERSONAL INFORMATION (as defined below) AND YOU CONSENT TO THE USE, DISCLOSURE, AND TRANSFER OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY AND AS PERMITTED OR REQUIRED BY LAW.

Subject to legal and contractual requirements, you may refuse or withdraw your consent for certain purposes identified herein by contacting us. If you refuse to provide or later withdraw your consent, you acknowledge that we may not be able to provide you, or continue to provide you, with Services.

COLLECTION OF INFORMATION

Information You Provide to Us

We collect Personal Information, which is information that identifies you as a specific individual, such as your name, phone number, email address, visual and audio information, and other information about you such as demographic information (for example: gender, age, geographic location, or similar information). We may also collect Personal Health Information including information related to your health and wellness, health issues, and health conditions that you submit through our Services. For example, we may collect information when you:

Create an account or profile;

Participate in any features of our Services;

Fill out any assessments or forms; or

Otherwise communicate with us.

By using the Services, you may generate statistics, preference related information, or other use history information that we may collect.

Automatically Collected Information

When you access or use our Services, we may automatically collect information about you, including:

Log and Usage Information: We may collect information related to your access to and use of the Services, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating our Services.

Device Information: We may collect information about the computer or mobile device you use to access our Services, including the hardware type and model, operating system and version, unique device identifiers, IP address and browser type, internet service provider (ISP), mobile advertising ID, media access control (MAC) address, language preferences and location, date and time of your access to the Services, internet domain and host name, referral URL, and mobile network information.

Location Information: In accordance with your device permissions, we may collect information about the precise geolocation of your device. We may also use your IP address to estimate your approximate location.

Information Collected by Cookies and Other Tracking Technologies: Like many commercial websites, we may analyze how visitors use our Services through what is known as “cookie” technology. A cookie is a small text file that is placed on your computer when you access the Services and allows us to recognize you each time you visit the Services. We may use cookies to: (1) enhance or personalize your Services usage; (2) monitor Services usage; (3) manage the Services; and (4) improve our Services. If you choose, you can set your browser to reject cookies or you can manually delete individual or all of the cookies on your computer by following your browser’s help file directions. However, if your browser is set to reject cookies or you manually delete cookies, you may have some trouble accessing and using some of the pages and features that are currently on our Services, or that we may put on our Services in the future.

We may also use web beacons on the Services, in our emails, and in our advertisements on other websites. Web beacons are tiny graphic images that are used to collect information about your Services visit, such as the pages you view and the features you use, as well as information about whether you open and/or act upon one of our emails or advertisements. Web beacons help us analyze our Services’ visitors’ behavior and measure the effectiveness of the Services and our advertising. We may work with service providers that help us track, collect, and analyze this and other site usage information.

We may combine the non-personal information we collect, such as through cookies and web beacons, with other information we have collected from you.

Information We Collect from Other Sources

We may obtain information from other sources and combine that with information we collect through our Services. If you create or log into your account through a social media site we will have access to certain information from that site, such as your name and account information, in accordance with the authorization procedures determined by the third-party site.

USE OF PERSONAL INFORMATION

Although Online Interventions may use user information in any way not specifically limited by this Agreement or applicable law, it is useful to understand how we typically use the information collected from users, such as:

Processing your registration and related transactions for the Services, including creating and managing your online account and profile;

Collecting information entered by you and transmitting that information to third parties through our Services;

Developing, enhancing, and providing the Services you request or that are reasonably anticipated within the context of our ongoing business relationship;

Personalizing your experience;

Maintaining and improving the quality of our website and Services;

Creating Backups and allowing for disaster recovery;

Complying with legal obligations;

Responding to requests and communications from you;

Analyzing and auditing your use and engagement with our Services;

Providing advertising or marketing services about products, services (including our Services), offers, promotions, events, and to solicit feedback or input about our Services;

Sending you notices about our Services, account notifications, technical updates, security alerts, and administrative messages; or

Creating aggregate information from de-identified data which we may use and disclose for any purpose.

AUTHORIZATION FOR PERSONAL HEALTH INFORMATION DISCLOSURE

YOU HEREBY AUTHORIZE THE USE AND/OR DISCLOSURE OF YOUR PERSONAL INFORMATION AND PERSONAL HEALTH INFORMATION AS DESCRIBED BELOW. YOU UNDERSTAND THAT THIS AUTHORIZATION IS VOLUNTARY, AND YOU ARE PROVIDING IT UNDER YOUR OWN FREE WILL. YOU UNDERSTAND THAT ONCE ONLINE INTERVENTIONS RECEIVES THIS AUTHORIZATION THEY MAY USE OR DISCLOSE YOUR PERSONAL INFORMATION AND THAT WE ARE NOT RESPONSIBLE FOR ENSURING THAT ANY RECIPIENT OF YOUR INFORMATION WILL FURTHER USE AND/OR DISCLOSE THE INFORMATION FOR THE PURPOSES LISTED BELOW.

INFORMATION TO BE USED AND/OR DISCLOSED

YOU AUTHORIZE ONLINE INTERVENTIONS TO USE AND/OR DISCLOSE YOUR INFORMATION INCLUDING: NAME, EMAIL ADDRESS, TELEPHONE NUMBER, ZIP CODE, GENDER, AND ANY HEALTH AND WELLNESS RELATED INFORMATION PROVIDED BY YOU TO US. THIS INFORMATION MAY BE USED, SOLD AND/OR DISCLOSED TO THIRD PARTIES WHO ARE DIRECTLY RELATED TO MEDICAL RESEARCH AND MAY HAVE INFORMATION TO HELP YOU DISCOVER AND ENROLL IN CLINICAL TRIALS.

COMPENSATION

YOU UNDERSTAND THAT ONLINE INTERVENTIONS MAY RECEIVE COMPENSATION OR REMUNERATION IN EXCHANGE FOR THE DISCLOSURE OF YOUR INFORMATION.

VOLUNTARY AND REVOCABLE AUTHORIZATION

YOU UNDERSTAND THAT THIS AUTHORIZATION IS VOLUNTARY, AND YOU MAY REFUSE TO AGREE. YOU UNDERSTAND THAT REFUSING TO AGREE TO THIS AUTHORIZATION MIGHT LIMIT THE SERVICES WE MAY PROVIDE YOU.

YOU UNDERSTAND THAT YOU HAVE THE RIGHT TO REVOKE THIS AUTHORIZATION AT ANY TIME BY CONTACTING US AT [email protected]. YOU UNDERSTAND THAT YOUR REVOCATION WILL BE VALID EXCEPT TO THE EXTENT THAT ONLINE INTERVENTIONS OR RECIPIENT ORGANIZATIONS AUTHORIZED TO MAKE THE REQUESTED USE AND/OR DISCLOSURE HAVE TAKEN ACTION IN RELIANCE ON THE AUTHORIZATION BEFORE IT IS REVOKED.

TELEPHONE NUMBERS

You may provide us with your telephone number as part of your registration or via other methods. You understand and agree that Online Interventions may use your telephone number for any reason including, but not limited to, commercial phone calls and texts, whether automated or made manually.

SECURITY

Online Interventions takes reasonable measures designed to protect the information collected from or about you from accidental or unlawful destruction, accidental loss or unauthorized access, use, modification, interference, or disclosure. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security or any information.

LIMITATIONS ON DATA RETENTION AND ACCOUNT TERMINATION

Online Interventions may keep your data as long as is permitted or required under the law. Additionally, data may be retained, backed up, and used in our system to satisfy any of the authorized uses under this Privacy Policy. For example, we may use retained data to prevent, investigate, or identify possible wrongdoing in connection with the Services or to comply with legal obligations. Please note that information may exist in backup storage even after it has been removed from Online Interventions’ active databases.

CHILDREN UNDER 13

Online Interventions complies with the Children’s Online Privacy Protection Act of 1998 (“COPPA”) and is not intended for use by children under 13 years of age. We do not knowingly or intentionally collect any personal information from or market to individuals under the age of 13. If you become aware that a child has provided us with personal information without parental consent, please contact us. If we become aware that a child under 13 has provided us with personal information without parental consent, we will take steps to remove such information and terminate the child’s account. If you believe that a child under the age of 13 has provided personally identifiable information to us, please contact us.

FOREIGN USERS

If you are outside the United States, by using the Services, you are consenting to having any data you submit or generate including your Personal Information transferred to the United States and anywhere that Online Interventions serves data from.

EUROPEAN UNION USER’S GDPR RIGHTS

If you are within the European Union, the following may apply:

You may be entitled to certain information and have certain rights under the General Data Protection Regulation. You may have the right to request access to your data that we store. You may have the right to either correct or request deletion of your personal data from our Services. Be aware that nothing can be completely removed from the Internet. We will take reasonable steps, as required by law, to honor any request for deletion of your personal information from our Services, but we cannot and do not guarantee that your data will be entirely removed. We are not responsible for third parties’ policies, practices, or compliance regarding your data. If you provide third parties with personal data and wish to have it removed, you must contact those parties directly.

You may have the right to seek restrictions on our processing of your data. To the extent that you provided consent to Online Interventions’ processing of your personal data, you have the right to withdraw that consent. For you, Online Interventions requires only the information that is reasonably necessary to provide you with our Services. You understand that withdrawing consent for the processing of your data might limit the services available to you or prohibit us from providing the Services.

CALIFORNIA USER’S CCPA RIGHTS

If you are within the state of California, the following may apply:

You have the right to request disclosure of your personal information and additional details regarding the personal information we have collected and its use purposes, including any third parties with which we have shared your information.

You have the right under the California Consumer Privacy Act of 2018 to opt-out of the sale of your personal information. If you exercise your right to opt-out of the sale of your personal information, we will refrain from selling your personal information unless you subsequently provide express authorization for the sale of your personal information. You understand that if you opt-out of the sale, it may limit the Services that we are able to provide you.

To opt-out of the sale of your personal information, visit our homepage and click on the “Decline” link on the Use of Cookies popup at the bottom of the page here: www.onlineinterventions.com

YOUR CHOICES

Online Interventions offers you some limited choices regarding the collection, use, and sharing of your information and we will respect the choices you make. Please note that if you decide not to provide us with the information that is requested, you may not be able to access some or all of the features of the Services.

Rescinding your Consent

You have the right to refuse further collection, use, and/or disclosure of your information by notifying us of your rescission of consent. If you have consented to your access to and use of the Services, but wish to rescind such consent, please contact us to submit the request.

Online Interventions will, within a reasonable amount of time, discontinue your access to and use of the Services such that no additional information may be collected. Please note, however, that if you refuse further collection, use, and/or disclosure of your information, you may not be able to access and use all or a portion of the Services.

Requests for Deletion of your Data

In applicable jurisdictions, you may have the right to request that we delete data collected from you. We will comply with such requests in a reasonable time as required by law. However, we may still retain some or all of your data in order to: (a) comply with state and federal law, (b) to prevent or assist in the prosecution of criminal or illegal conduct, (c) fulfill its service to you and complete your transactions with us or other internal uses reasonably aligned with consumer expectations, (d) diagnose, debug, or otherwise repair problems related to our Services, (e) to engage in public or peer-review scientific, historical, or statistical research in the public interest, and (f) whenever necessary to protect or ensure the privacy of your data.

ADDITIONAL DATA COLLECTION CHOICES

We strive to provide you with choices regarding the Personal Information you provide to us. The following are some ways you may have control over your information:

Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Services may then be inaccessible or not function properly.

Location. Mobile browsers may collect real-time information about the location of your device for geo-fencing, mileage tracking or similar purposes. If you do not want us to collect this information, you may decline our request or disable location services in your mobile device’s settings if requested. However, opting out of the collection of location information will cause location-based features to be disabled and the online and/or mobile browsing may not function properly.

Stored Information and Files. Our Services may also access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information. You may opt out of this data collection in your mobile device’s settings, however, opting out will interfere with the Services’ functionality.

Promotional Offers from Us . If you do not wish to have your email address or other contact information used by us to promote our own or third parties’ products or services, you can opt-out. If we have sent you a promotional email, you may opt out using the unsubscribe or opt-out link in the email, if applicable, or by sending us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to us as a result of a product or service purchase, product service experience, or other transactions.

HOW WE RESPOND TO "DO NOT TRACK" SIGNALS

Your online browser settings may allow you to automatically transmit a “Do Not Track” signal to websites and online services you visit. Our Services do not respond to a “Do Not Track” signal from a visitor’s browser. If you would like to find out more about “Do Not Track,” please visit www.allaboutdnt.com.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at: [email protected]