PRIVACY POLICY

CURATION PRIVACY POLICY

Last Updated: January 6, 2023

The protection and privacy of personal data is very important to Curation Health, LLC (“Curation” or “we”).

This Privacy Policy (the “Policy”) covers information received from our www.curationhealth.co website (the “Site”).

By utilizing the Site and any of our services (collectively the “Service”), you expressly acknowledge and accept this Policy, and such consent grants us the faculty to treat your personal data as set forth herein and in accordance with the laws, regulations and other applicable legislation applicable to your use.

Collection and Usage of Site Information

Website:  Curation uses Google Analytics to track user flow on our Site and for such purposes uses a cookie. In addition, if you sign up for one of Curation’s software trials or accounts we will store and use your email and any other information you provide to send product information and updates.

How We Use the Information

We use the information we collect for: (1) personalizing your experience; (2) communication and marketing; (3) research and development of features and products; (4) safety and security; (5) legal rights and business interest; and (6) where you provide consent for a specific purpose.  How we use the information we collect also depends in part on which services you use, how you use them, and any preferences you have communicated to us.  Below are the specific purposes for which we use the Personal Information we collect about you.

  1. To provide the Site and personalize your experience: We use Personal Data to provide support and to operate and maintain the Site.  Where you use multiple Services, we may combine information about you and your activities to provide an integrated experience, such as to allow you to find information from one Service while searching from another or to present relevant product information.
  2. Communication: We use your contact information to send certain communications via email, including responding to your comments, questions and requests, providing customer support, and sending you technical notices or updates, security alerts, and administrative messages.
  3. We may use a third-party email marketing platform, for sending product-related emails. You can control whether you want to receive these communications by opting-out whenever you receive such a communication from Curation by using the included opt-out link in any such communication.
  4. For research and development:  We are always looking for ways to make our Services smarter, faster, better integrated, more secure and useful to you.  We use collective learnings about how people use our Services and feedback provided to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services.
  5. For safety and security: We use information about you and your use of the Services to verify accounts and activity, to monitor suspicious or fraudulent activity and to identify violations of our policies.
  6. To protect our legitimate business interests and legal rights: Where required by law or where we believe it is necessary to protect our legal rights, interests and the interests of others, we use information about you in connection with legal claims, compliance, regulatory, and audit functions, and disclosures in connection with the acquisition, merger or sale of a business.
  7. With your consent: We use information about you where you have given us consent to do so for a specific purpose not listed above.  For example, we may publish testimonials with your permission.
  8. Legal basis for processing: we collect and use your information only where:
    – we need it to provide you with the Services;
    – it satisfies a legitimate interest which is not prohibited by your data protection rights, such as for research and development or to protect our legal rights;
    – you give us consent to do so for a specific purpose; or
    – we need to process your data to comply with a legal obligation.

If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time through exercise of your Personal Rights as set forth below.  However, this will not affect any processing of your information that has already taken place.

Chromium Extension (Google Chrome, Microsoft Edge) Privacy Policy

You may access our Site through our application (“App”) using a Chromium Browser Extension (CBE) installed in Google Chrome or Microsoft Edge. Curation Health does not collect or store any personal information or personal data you process through the App.

The data you process through the App is transferred from your CBE instance to the App’s processors. Curation Health utilizes Amazon’s secure data centers and the Amazon Web Service (“AWS”) technology.

The data you process through the App is protected and secured by TLS security protocol while in transit. You can learn about TLS here: https://tools.ietf.org/html/rfc5246. You can learn about AWS’ security here: https://aws.amazon.com/security/


Security, Storage and Data Retention
Security and Storage for Information processed through the Services:

Site:  We use various service providers to host the data we collect from the Site, and we use technical measures to secure such data.  We ensure a variety of security measures are implemented by such service providers, including firewalls, Secure Socket Layer (SSL) technology, encryption and authentication tools, to help protect your information. We protect your Personal Data with the same or better security measures than we protect our company data.

Personal Data Retention
Curation will retain Personal Data, in accordance with the above, for as long as needed to provide the Services to you. Curation will also retain Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce this Policy and our agreements.

Account information: We retain your account information for as long as your account is active and for a reasonable period thereafter in case you decide to re-activate the Services.  We also retain some of your information as necessary to comply with our legal obligations, to resolve disputes, to enforce our agreements, to support business operations, and to continue to develop and improve our Services. Where we retain information for Services improvement and development, we take steps to eliminate information that directly identifies you, and we only use the information to uncover collective insights about the use of our Services, not to specifically analyze personal characteristics about you.

How We Share Information

Curation does not sell or rent your Personal Data to any third party.  We do share information with third parties that help us operate, provide, improve, integrate, customize, support and market our Services.

Service Providers: We work with third-party service providers to provide application development, hosting, maintenance, newsletters, support, logs, marketplace, backup, storage, virtual infrastructure, analysis and other services for us, which may require them to access or use information about you.  If a service provider needs to access information about you to perform services on our behalf, they do so under close instruction from us, including policies and procedures designed to protect your information.

We store our data and host our platform through our Amazon Web Services (“AWS”) account.   You can learn more about Amazon’s AWS security here:  AWS Security:  https://aws.amazon.com/security/

With your consent: We share data about you with third parties when you give us consent to do so.  For example, we may display personal testimonials of satisfied customers on our Website. With your consent, we may post your name alongside the testimonial. Such consent may be provided through your acceptance of our Terms of Use.

Compliance with Enforcement Requests and Applicable Laws; Enforcement of Our Rights: In exceptional circumstances, we may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our products and services, (d) protect Curation, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.

We may transfer your Personal Data to third parties in the following situations:

  • When you have given us consent to do so;
  • In response to subpoenas, court orders, or legal process by disclosing your data and other related information, if necessary or to establish or exercise our legal rights or defend against legal claims; or
  • In order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of Curation’s Terms of Use Agreement, or as otherwise required by law.

Information for Data Subjects Related to Personal Data

  • For Personal Data collected from the Site, Curation is considered a controller. Curation may use third party processors. Such third-party processors are controlled by data processing agreements providing the same protections of your Personal Data as set forth herein.
  • Only Curation’s authorized employees and subcontractors have access to Personal Data relevant to the activities and services they provide to Curation. All subcontractors used by Curation are contractually bound to the same data security and privacy standards that apply to our employees.

Business Transfers: We may share or transfer information we collect under this Policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Standard Services if a transaction takes place, as well as any choices you may have regarding your information.

Opt-Out Preferences
When you inquire about our Services, we may use your name and email address to send periodic emails to you related to our Services, or transactional (i.e. an invoice) in nature. You may choose to stop receiving these emails by following the unsubscribe instructions included in these emails or you can contact us at [email protected].  After you opt out from receiving product related messages, you will continue to receive transactional messages from us regarding the Services.

Links to Other Sites
While using the Services, you may be exposed to content or functionality that is hosted by a third-party supplier. If you click on or access such third-party content or functionality, the privacy policy and terms of use for such third-party content or functionality will control as such other sites have their own privacy policies and personal data collection, use, and disclosure practices.  We strongly advise you to familiarize yourself with the privacy policies provided by these other sites prior to providing them with any information. Curation is not responsible for the privacy practices or the content of other websites.

In addition to the above, the following additional privacy aspects apply:

Curation’s use of Personal Data is fully intended to be in compliance with the obligations as set forth in the laws of the United States and only the United States.  If you are subject to laws outside of the United States, do not create an account or use the Services.

Personal Rights
You are, as data-owner and user of the Service, entitled to (i) access your Personal Data and be informed about the way in which your information is treated, (ii) rectify your personal data in case it is not up-to-date, it is inaccurate or incomplete, (iii) ask for your data to be removed if you consider that it is not used in accordance with the applicable principles, duties and obligations, and (iv) object to the processing of your Personal Data for specific purposes.  These rights are known as “Personal Rights”.

How to Exercise Your Personal Rights
If you decide to exercise your Personal Rights, you may contact privacy team via email at [email protected] for any requests related to your data protection rights.  To protect your data from fraudulent inquiries, your request must be accompanied with the following information and documentation:

  • Your ID information and, if applicable, the information of your legal representative. For legal representative, please attach a copy of his/her power-of-attorney.
  • A clear and precise description of the Personal Data about which the Personal Rights are to be exercised, as well as the right or rights that are to be exercised.
  • An address where you desire to hear and receive Curation’s response and any future communications and/or notifications, or, in its case, your desire to receive our response and/or future notifications or responses via email, providing us with your email address.
  • If you prefer to correspond via email, you must expressly state your desire to receive Curation’s response through an email communication, specifying the corresponding email address.

Curation will issue a response within a timely manner following receipt of your request, which will be informed to you using your selected method.  Once you receive our response you will have a 20-business day period to respond to our communication.  In the event you need to speak with us or in the event you disagree with our response please contact us at [email protected] along with a phone number for us to reach you, in order for Curation to discuss with you any issue.  In case you do not reply to our response within the before mentioned period we will understand in good faith that you agree with our conclusion.

If your request refers to your right to access data, Curation will provide you with copies of the information and/or scanned documents.

Curation may refuse the exercise of your Personal Rights in instances permitted by the laws and regulations of the territories which are applicable to your use and shall inform you about such decision.  The refusal may be partial, in which case Curation will carry out the access, rectification, cancellation, deletion, or objection in the corresponding part.

Revocation of Your Consent to The Treatment of Personal Data
You, as data-owner, can revoke your consent to the treatment of your personal data in accordance with the procedure set forth above “How to Exercise your Personal Rights”, in the understanding that once we receive your request to revoke your consent we will issue our response within a timely manner.

Options to Limit the Use and Disclosure of Your Personal Data
You, as data-owner, can limit the use and disclosure of your personal data in accordance with the procedure set forth above “How to Exercise your Personal Rights”, in the understanding that once we receive your request to revoke your consent we will issue our response within a timely manner.

Changes to this Privacy Policy
From time to time, we may update this Policy to clarify our practices or to reflect new or different privacy practices, such as when we add new features to the Service. Curation reserves the right to update or modify this Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Policy shall indicate your agreement with the terms of such revised Policy.  If you disagree with any changes to this Policy, you will need to stop using the Apps or Services and deactivate your account.