Guide Services Application Privacy Policy

Effective dateNovember 22, 2021 

 

The Guide Services application is operated Loyal Health, Inc. (“Loyal”, “Company,” “our,” “we,” or “us”).  We respect your privacy and are committed to protecting it as described in this Privacy Policy (the “Policy”).  This Policy applies when using the Loyal Guide Services Application (the “Services” or “Application”).   

In order to provide you with relevant information, respond to your requests, and increase the benefits you receive from the Services, we sometimes request that you provide us with information about yourself. This Policy sets out important information on where and how we collect your personal information, what we do with it, how we protect it, and what your rights are.  

This Policy may change from time to time; we will post updates here when revisions are effective.  You can determine when the Policy was last revised by referring to the “Effective date” at the top of this page.     

Please be aware that use of the Services is at all times subject to the Application Terms of Use, which is available here. This notice does not apply to aggregate or anonymized information which does not relate to any identified or identifiable individual. 

 

What Personal Information We Collect and How We Collect It 

We collect information, including personal information, when you use our Application. We may collect information meant to support you knowingly choose to disclose. We collect usage information as you and others use our Services.  If you choose to correspond with us through e-mail, we may retain the content of your e-mail message together with your e-mail address and our responses. (We may gather information about you from third parties (e.g., employers) and combine it with other information we have collected about you.) 

 

Information We Collect 

Personal data is information that can be reasonably used to identify you or any other individual to whom the information may relate personally (“Personal Data”).  

The types of information we collect may include: 

We also use this information to provide you with information related to your account and the services you receive from us, to better understand your needs and interests, to improve our service, and to personalize communications. 

 

Usage Data  

Data may be collected from you automatically when you access or interact with the Services.  We may collect information about how you access and use the Services (“Usage Data”).  Usage Data may include information such as your device’s Internet Protocol address (“IP address”), the type of browser or application you are using to access the Services, browser version, the operating system, the time and date of your visit, the time spent in the Application, unique device identifiers, keystroke logging, and other diagnostic data.  We may also collect information regarding the device(s) you use to access or use the Services. 

When you use the Services with a mobile device, we may collect certain information automatically, including, but not limited to: the type of mobile device you are using, your mobile device unique identifier, the IP address of your mobile device, your mobile device operating system, the type of mobile internet browser you are using, unique device information, and other diagnostic data. 

Usage Data may be tracked and recorded for purposes of enhancing your use of the Site and/or Services and maintained for session replay purposes. By using the Site, you agree to the collection, maintenance, and replay of this Usage Data to enhance your user experience. 

 

Tracking and Cookies Data 

We use cookies and other tracking technologies to collect Usage Data and track how you use the Services.  We may use cookies for statistical reporting for the Services and for other purposes relating to making our Services available to you.  Cookies are small files that are placed on your computer, mobile device or any other device by a website, containing the details of your browsing history on that website among its many uses.  We may use cookies and similar tracking technologies to track activity in our Application and Application and store certain information.  Tracking technologies used may include beacons, tags, and scripts to collect and track information and to improve and analyze our Services. 

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, some features of our Services may be unavailable to you. 

For more information, please see our Cookie Policy. 

 

Promotional Communications  

We may use your Personal Data to connect you with newsletters, marketing or promotional materials, and other information that may be of interest to you. We have a legitimate interest in using your data for promotional purposes (see “Why We Collect Your Personal Data” below). We may know if you click a link in an email or other communication with us. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any e-mail we send. We may still send you non-promotional emails relating to our transactions with you. 

 

How We Collect Your Personal Data

We may collect Personal Data in a number of circumstances and ways when you visit and/or use our Application, including when you: 

 

Why We Collect Your Personal Data 

 When you visit and/or use our Application, most of the Personal Data we collect is provided to us directly by you so that we can provide the Application. Your Personal Data is collected for our legitimate business interests or those of our service providers including as outlined below: 

 

Sharing and/or Disclosure of Your Personal Data 

We (and our service providers) may share your personal information in the following situations: 

We share aggregated anonymous information about you with third-party clients, partners, other web site visitors and other third parties.  We may also aggregate data on an anonymous basis with respect to job qualifications, schooling, age, experience level or other information relevant to the job search or competition among job seekers for any such job.  Such aggregated data does not identify users individually, and may be made available to employers, fellow job seekers, or community members. 

We may supply technology and related services to healthcare providers (“Providers”) in order to facilitate their interactions with you either via their respective web sites or third parties such as Google (in either case, referred to as “Linked Sites”). Personal and/or demographic information supplied by you via the Linked Sites becomes part of our database, and is shared with the company for whom the Linked Site is hosted together with any other party for whom you have consented to sharing such information.  

Information gathered on a page in a Linked Site area or on a co-branded web site may be retained by both Loyal and the applicable other company (e.g., your healthcare provider).  In that instance, the use of such information by the other company will be subject to the privacy policy of that company and Loyal is not responsible for that company’s use of your personal information (see “Third-Party Services” below for more information). 

Additionally, you may be asked to provide information on your age, gender, or race where permitted by law. You should understand that this information should only be used in accordance with applicable law. However, we are not responsible for the actions of such Providers or other companies. All such information provided will be kept separate by us from your activities through the Services.  Providing this information is strictly voluntary and you will not be subject to any adverse action or treatment from us if you choose not to provide this information. 

 

Law Enforcement   

We may disclose your Personal Data if we are required by law to do so or in response to legitimate requests of public authorities (e.g., a court or government agency). 

 

Disclosure Through Business Transfers 

We may buy, merge, or partner with another company or business and in doing so acquire or transfer Personal Data.  Personal Data collected through the Application may be among the transferred business assets.  In the event of an acquisition or merger, your Personal Data may be transferred so that we may continue to provide the Application to you.  In the course of such a transaction your Personal Data would likely be considered a business asset, and, notwithstanding limitations imposed by applicable data privacy legislation, you hereby agree to such a transfer.  

 

Other Reasons for Disclosure  

We may disclose your Personal Data in the good faith belief that such action is necessary to: 

 

How Long We Keep Your Personal Data  

We will keep information about you for the purposes set out in this Privacy Policy and in accordance with applicable privacy laws and relevant regulations. We will never retain your personal information for longer than is necessary. 

The criteria used to determine our retention periods includes: 

 

Third-Party Services 

In general, the third-party providers used by us will only be permitted to collect, use, and disclose your Personal Data to the extent necessary to allow them to perform the services they provide to us.  

However, certain third-party service providers have their own privacy policies with respect to the information we are required to provide to them for your activities with the Application.  For example, we may have agreements with your healthcare provider pursuant to which we provide them Personal Data and other data in connection with their services to you.  For these providers, we recommend that you read their privacy policies to learn about the manner in which your personal information will be handled by these providers. 

We are not responsible for the privacy, information, or other practices of any third parties, including any third party operating any site to which our websites contain a link. The inclusion of a link on any of our websites does not imply endorsement of the linked site by us. Once you leave the Application and are using or are redirected to a third-party website or application, including through the use of links as described below, you are no longer governed by this Policy or our Terms of Use.  We are not responsible for, and expressly disclaims all liability of any kind whatsoever arising out of, in connection with, related to, and/or resulting from any products, services, or information offered or provided by third-party service providers, or any of the activities of third-party service providers.  We make no warranty, express or implied, or guarantee regarding any third-party service providers, or any products, services, or information offered or provided by third-party service providers, or any activities of third-party service providers. 

 

Links  

The Services we provide may be embedded in or include links to third-party websites, plug-ins, and applications.  Interacting with those websites, including but not limited to clicking on those links or enabling those connections, may allow third parties to collect or share data about you.  We are not responsible for these third-party websites, plug-ins, applications, or their respective privacy statements, and we expressly disclaim all liability of any kind whatsoever arising out of, in connection with, related to and/or resulting from any products, services, or information offered, provided, or collected by third-party websites, or any activities of third-party websites.  We are not responsible for your use of these third-party websites, plug-ins, or applications. We make no warranty, express or implied, or any guarantee regarding any third-party websites, plug-ins, applications, or their respective privacy statements, or any products, activities, services, or information offered, provided, or collected by third-party websites, plug-ins, or applications.  When you leave the Application, we encourage you to review the privacy policies of such third parties by visiting the links included within those separate websites, since their policies may differ from this Policy, and they may use information in ways other than those described in this Policy. 

 

Security 

The security of your Personal Data is important to us, but remember that no method of transmission over the Internet is 100% secure.  To protect your Personal Data, we endeavor to take commercially reasonable precautions designed to protect your Personal Data from inappropriate loss, misuse, access, disclosure, alteration, or destruction.  Even so, technical mistakes are possible.  No company, including us, can fully eliminate security risks associated with the transmission of Personal Data over the Internet. 

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section below. 

 

Age of Consent 

The Services are not intended for use by those under the age of 18, nor are they targeted to those under the age of 18.  If you use the Services, you hereby represent and warrant that you are at least 18 years of age.  No one under the age of 18 may provide any information to or on our Services.  

We do not knowingly collect personal information from those under the age of 18, nor do we knowingly sell or otherwise disclose the personal information of those under the age of 18.  If you are under the age of 18, do not (i) use or provide any information on our Services or through any of its features, (ii) use any of the interactive or fillable features of the Services, or (iii) provide any information about yourself to us, including your name, address, telephone address, e-mail address, or any other information that could be used to identify you.   

 

California Privacy Rights 

In this section, ‘Personal Data’ means information related to an identified or identifiable individual under the California Consumer Privacy Act of 2018 (CCPA) and subject to that law. If you are a California resident, you have certain data protection rights. Under the CCPA and California Civil Code § 1798.83, you have the right to exercise the following rights:  

 

Disclosures of Personal Information We Collect 

You have the right to know:  

In connection with any Personal Data we may sell or disclose to a third party for business purposes, you have the right to know: 

 

Categories of Personal information That We Collect and Disclose 

 The table below identifies the categories of personal information (as defined by the CCPA) that we have collected about consumers in the prior 12 months, as well as how we have disclosed such information for a business purpose (subject to our applicable legal and ethical obligations). 

 

Personal Information Collected  Disclosed for business purposes 
Category  Description  Yes/No  Categories of third parties 
Identifiers  Includes direct identifiers such as a name, alias, address, email address, user ID, IP address and other online identifiers and other similar identifiers.  Yes  Service providers

Clients

Customer records  Customer records: includes personal information, such as name, account name, billing and payment information, signatures, government identifiers and other information that individuals provide us in order to use our Services.  Yes  Service providers 

Regulatory and government entities 

Affiliates 

Clients 

Parties and related parties in legal matters 

Protected classifications  Characteristics of protected classifications, such as age, gender, marital status, disability and health information that individuals provide to us.  Yes  Service providers 

Regulatory and government entities 

Affiliates 

Clients 

Parties and related parties in legal matters 

Commercial information  Such as records of purchases and use of the Services and other products and services.  Yes  Service providers 

Judicial and quasi-judicial bodies 

Regulatory and government entities 

Affiliates 

Clients 

Usage data  Internet or other electronic network activity information: including browsing history, search history, access logs and usage data, and other information regarding a person’s interaction with our Application  Yes  Service providers 

Judicial and quasi-judicial bodies 

Regulatory and government entities 

Affiliates 

Audio, Video and Electronic Data  Includes audio, electronic, visual, thermal, olfactory, or similar information, such as thermal screenings and CCTV footage (e.g., collected from visitors to our offices for health and safety purposes), photographs and images (e.g., that you provide us) and records of calls, webinars and video conferences (eg, when you participate in one of our webinars).  Yes  Service providers 

Judicial and quasi-judicial bodies 

Regulatory and government entities 

Affiliates 

Professional information  Includes professional and employment-related information such as your employer name, title, the nature of your responsibilities, and your practice area, specialties, qualifications and areas of focus.  Yes  Service providers 

Judicial and quasi-judicial bodies 

Regulatory and government entities 

Affiliates 

Parties and related parties in legal matters 

Inferences  Includes inferences drawn from any of the information identified above to create a profile about you, such as reflecting your preferences and other characteristics.  Yes  Service providers 

Affiliates