What Information Do We Collect?
User Interaction Data:We may use mobile tracking technologies such as cookies, web beacons, pixel tags and clear GIFs, as well as embedded code in the Services itself, in order to operate the Service efficiently, and to collect data related to your usage of and interaction with the Service, and general use and interaction with your mobile device. All such collected data (collectively, “User Interaction Data ”) may include how and when you use your mobile device for communications with others, including mobile phone and text use, and your location and speed of movement while you use your mobile device. Such User Interaction Data may also include, but is not limited to, call information, SMS information (see Safeguards below), location samples, accelerometer samples, smartphone actions, and smartphone screen-time related to, or resulting from, your use of the Services. We do not access or collect the content of your mobile phone communications, such as conversations or text messages.
User Survey Data; Personal Information:We collect the following personal information in connection with the Service: (a) when you register to use the Service, whether in your individual capacity or on behalf of an organization, we may collect the personal information that is disclosed on our online registration form, such as your name, email address and other information detailed therein (the “Account Data”); (b) if you communicate with us by email, we will collect your email address; and (c) if you use the Services to respond to surveys and questions from an Institutional Client, we may collect the information you provide in your responses, such as health information (if any) (the “User Survey Data”). Such User Survey Data includes, but is not limited to, your answers or submissions to study surveys and health questionnaires, inferred health status for specific conditions, and survey alerts. The User Survey Data, together with the User Interaction Data, is referred to as “Unprocessed User Data.” We may also collect certain demographic information, such as age and gender, that may be disclosed by you. All of the Account Data, e-mail addresses, demographic information, and Unprocessed User Data is referred to in this Policy as “Personal Information”. Any health information that you provide is safeguarded in accordance with applicable U.S. laws.
How Do We Use the Information We Collect?
Creation of Processed Data. Ginger.io will use its proprietary technology and the Unprocessed User Data to compile personalized behavioral features known as Ginger.io Behavior Feature(s) (“GBF”) for each user. Such GBF analysis, and other data processed from Unprocessed User Data (collectively, the “Processed User Data”), may be summarized or otherwise set forth in one or more written report(s) (the “Reports”). Such Processed User Data and Reports may be delivered to the applicable Institutional Client. The applicable Institutional Client may also be provided with User Survey Data.
Use of Personal Information:We will use and store Personal Information for the purpose of delivering the Service to you and where applicable, to our Institutional Clients, and to analyze and enhance the operation of the Service. We store Personal Information, and where applicable, any information obtained from our Institutional Clients for proprietary analysis and development of personalized GBF for each user for you or where applicable, the Institutional Client. Personal Information may also be used for the internal operational and administrative purposes of the Service. We will not sell or use Personal Information for purposes other than what is authorized pursuant to your End User License Agreement. For example, we will not sell your identifying Personal Information to third party direct marketers or advertisers. In order to share insights across Institutional Clients, allow for additional research and product development, and to garner insights about the data that we gather over time, Ginger.io may anonymize your Personal Information, or de-identify your health information in a way that meets the Health Insurance Portability and Accountability Act of 1996 (HIPAA) de-identification standard, so that the data will no longer be identifiable or linkable to you.
Aggregate Information:We will create statistical, aggregated data relating to our users and the Service for analytical purposes. Aggregated data includes data derived from Personal Information and obtained by Ginger.io from other sources in aggregated, anonymous form and does not identify any individual (such data, “Aggregate Information”). Subject to applicable laws and regulations, we use Aggregate Information to understand our customer base and to develop, improve and/or market our Services. We may provide Aggregate Information to third parties.
Email Communications:If you register and provide your email address, we may send you administrative emails. If you wish to opt out of these emails, you may do so by following the “unsubscribe” instructions in the email; provided however, Ginger.io may maintain the right to send you important emails about your account or the Services.
User Testimonials:We value your feedback on, and appreciate any testimonials about, our Services. If you send us any such feedback or testimonials, they shall be deemed, and shall remain, the property of Ginger.io and none shall be subject to any obligation of confidence on our part. However, Ginger.io shall obtain prior written approval of any usage of your identity or contact information, if Ginger.io wishes to reference you in connection with that feedback or testimonial.
What Information Do We Disclose to Third Parties?
Aggregate Information:We may disclose Aggregate Information to third parties, such as the Institutional Client, potential customers, business partners, advertisers, and funding sources, in order to describe our business and operations. We may also license, sell, or otherwise use or provide Aggregate Information.
Additional Disclosures:We reserve the right to disclose any information we collect in connection with the Service, including Personal Information, (a) to a subsidiary or parent company or to any successor to our business as a result of any merger, acquisition, asset sale or similar transaction; and (b) to any law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights or to protect third parties.
Accessing and Updating Your Personal InformationWhenever you use our Services, we aim to provide you with access to your Personal Information. If that information is wrong, we strive to give you ways to update it quickly, or to delete it – unless we have to keep that information for legitimate business or legal purposes. You may send us an email to firstname.lastname@example.org requesting that we remove your account and delete all of your Personal Information, that we stop collecting data from your mobile phone, or to otherwise provide us with the necessary changes to update your Personal Information. We aim to maintain our Services in a manner that protects information from accidental or malicious destruction. Your identifying Personal Information shall be deleted from our records within 90 days of your request or the termination of the End User License Agreement you enter with us. Notwithstanding, we have the right to continued use of any Aggregate Information or de-identified information even if we have deleted the underlying Personal Information. Furthermore, even when your Personal Information is deleted from Ginger.io’s system, you acknowledge there is no way to remove any data from existing GBF, the Processed User Data or Reports that were built off of that data and may have been previously provided to Institutional Clients.
Safeguards:We have implemented the following technical safeguards to minimize the potential risk of a privacy breach: - During analysis, data is linked only to coded identifiers for the participants, and not to any personal identifiers. - Contents of SMS messages or phone calls are not captured. Only SMS and phone call events are logged. - Incoming and outgoing phone numbers and names from your contacts are stored encrypted. - Raw audio is not captured or stored. - Email addresses used during the Mobile Application install process and to send notifications will be unaccessible for analysis, and stored in encrypted form.
Do Not Track Browser Requests:Ginger.io does not use services that track your behavior across the Web. Therefore, our Service does not alter its behavior or change its services upon receiving Do Not Track requests from your web browser.
Children:Ginger.io does not knowingly collect or maintain personally identifiable information from persons under 13 years of age, and no part of the Service is directed at persons under 13. If you are under 13 years of age, then please do not use the Service. If Ginger.io learns that personally identifiable information of persons less than 13 years of age has been collected without verifiable parental consent, then Ginger.io will take the appropriate steps to delete this information. To make such a request, please contact us at email@example.com.