Date of Last Revision: 7/2/2019
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect several types of information from and about users of our Websites and Apps, including information:
- by which you may be personally identified, such as name, e-mail address, telephone number, country, or any other information collection on the Websites or Apps that is defined as personal data or personally identifiable information under an applicable law (“personal information”);
- that is about you but individually does not identify you, such as whether you are a current user, product interests, or information related to your inquiry or request;
- about your internet connection, the equipment you use to access our Websites or Apps, and usage details; and/or
- about your medical condition, treatment options, physician referrals, prescriptions, and lab results, including protected health information (“PHI”) or other related health information.
We collect this information:
- Directly from you when you provide it to us.
- Automatically as you navigate through the Websites. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
- From third parties intermediaries, for example, the physicians, medical professionals, and pharmacies with whom we partner to provide you with services.
Information You Give to Us. The information we collect on or through our Websites or Apps may include:
- Information that you provide on our Websites or Apps. This includes information provided when you sign up for our Services; when we process or respond to your inquiries related to requests for treatment, payment, customer service; and when you provide feedback on our Websites or Apps.
- Your responses to questions that we might ask you to complete for research purposes.
- Details of transactions you carry out through our Websites and Apps and of the fulfillment of your inquiries or requests.
- Your search queries on the Websites.
Information We Collect About You. As with many other websites and mobile applications, as you navigate through and interact with our Websites or Apps, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
- Details of your visits to our Websites or Apps, including traffic data, location data, logs, language, date and time of access, frequency, and other communication data and the resources that you access and use on the Websites or Apps.
- Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type.
- Details of referring websites (URL). We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).
The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information you provide to us or that we collect in other ways or receive from third parties. It helps us to improve our Websites or Apps and to deliver a better and more personalized service, including by enabling us to:
- Estimate our audience size and usage patterns.
- Store information about your preferences, allowing us to customize our Websites or Apps according to your individual interests.
- Speed up your searches.
- Recognize you when you return to our Websites or Apps.
Cookies Used on the Websites. Our Websites and Apps use two types of cookies: single-session (temporary) and multi-session (persistent). Temporary cookies last only as long as your web browser is open, and are used for technical purposes such as enabling better navigation through our Websites or Apps. Once you close your browser, the cookie disappears. Persistent cookies are stored on your computer for longer periods and are used for purposes including tracking the number of unique visitors to our Websites and information such as the number of views a page gets, how much time a user spends on a page, and other pertinent web statistics. Cookies, by themselves, will not be used by Ro to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit the Websites or Apps. We do not respond to ‘do not track’ signals in your browser. We may also collect data by using “pixel tags,” “web beacons,” “clear GIFs,” or similar means (collectively, “pixel tags”) that allow us to know when you visit our Websites or Apps. Through pixel tags, we obtain non-personal information or aggregate information that can be used to enhance your online experience and understand traffic patterns.
Information We Receive From Other Sources. This is information we receive about you if you use any of the other websites we operate or the other Services we provide. We are working closely with third parties (including, for example, third parties intermediaries, such as the physicians, medical professionals, and pharmacies with whom we partner to provide you with services, sub-contractors in technical, advertising networks, analytics providers, and search information providers).
HOW WE USE YOUR INFORMATION
In connection with providing you with the Websites, Apps, and Services, we may use, compile, analyze, and save your information in the following ways:
- To carry out the Services and, as applicable, facilitate the provision of health care services to you by physician or other health care provider and ensure that the physicians or health care providers have the services and support necessary for health care operations.
- To communicate with you about the Websites, Apps, and Services, or your use of the Websites, Apps, and Services, and send you communications on behalf of physicians or other health care providers utilizing the Services to meet your needs.
- To provide you with information that you have requested or to respond to your inquiries.
- To provide you with technical support and to improve our Websites, Apps, and Services.
- To verify your identity and administer your account, including processing your payments and fulfilling your orders.
- In order to ensure that content from our Websites and Apps is presented in the most effective manner for you and for your computer or mobile phone, to allow you to participate in interactive features of our Services (when you choose to do so), and as part of our efforts to keep our Websites and Apps safe and secure.
- To communicate with you about our products and Services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses and those of our third-party partners.
- To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.
- In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us.
- To notify you about changes to our Websites, Apps, or Services.
- For any purpose where you have given your consent (where legally required).
- To comply with applicable federal and state law.
Information We Receive From Other Sources. We will combine information we receive from other sources with information you give to us and information we collect about you. We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).
DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated, de-identified information about our users, and information that does not identify any individual, without restriction.
- To any member of our group, which means our subsidiaries and affiliates, including our ultimate holding company and its subsidiaries.
- To health care providers (i) to schedule and fulfill appointments and provide health care services as part of the Services, (ii) to whom you send messages through our Services, and (iii) for other treatment, payment or health care operations purposes, including pharmacy services, upon your request.
- To health care organizations, pharmacies, contractors, service providers, and other third parties we use to support our business or in connection with the administration and support of the Services.
- To our third party service providers that provide services such as the hosting our Websites or Apps, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing, and other similar services.
- To any third parties we believe necessary or appropriate to comply with applicable laws.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ro’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ro about our Website or App users is among the assets transferred.
- To fulfill the purpose for which you provide it. For example, if you email us asking us to contact a third party (including a medical professional), we may transmit the contents of your email to the recipient.
- For any other purpose disclosed by us when you provide the information or with your consent.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information.
Do Not Track. We do not currently respond to “do not track” signals as we do not track our customers across third party websites.
Promotional Offers from Ro. If you do not wish to have your contact information used by Ro to promote our own products or Services, you can check certain boxes on the forms we use to collect your data. You can also always exercise your right to ask us not to process your personal information for marketing purposes by contacting us at the address below. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way.
ACCESSING, CORRECTING & DELETING YOUR INFORMATION
You may contact us at the address below—or by emailing [email protected]—to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. If Ro deletes your user account, medical providers and other affiliates may still have the right to retain information as required by applicable law, regulations, or their own retention policy. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Unless otherwise required by law, Ro will also erase personal information when the personal information is no longer necessary in relation to the purposes for which was collected or otherwise processed; when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; when you object to the processing and there are no overriding legitimate grounds for the processing; when your personal information has been unlawfully processed; and when it is necessary to comply with legal obligations.
We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Websites and Apps, you are responsible for keeping this password confidential. We ask you not to share a password with anyone. The information you share in public areas may be viewed by any user of the Websites or Apps.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our Websites or Apps; any transmission is at your own risk.
USE BY MINORS
Chief Privacy Officer
900 Broadway, Suite 706
New York, NY 10003