Privacy policy

PRIVACY POLICY

Date of Last Revision: 09/12/2018

 

INTRODUCTION

This Privacy Policy (“Privacy Policy”) describes the types of information Roman Health Ventures Inc. and its affiliates, including Roman Health Medical LLC and Roman Health Pharmacy LLC, (collectively, “Ro,” “we,” “our,” or “us”) may collect from you or that you may provide when you visit the websites located at www.ro.co, www.getroman.com, quitwithzero.com, and romanhealthpharmacy.com (collectively, our “Websites”) and any affiliated mobile applications (the “Apps”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.  This Privacy Policy is incorporated into our Terms of Use. All capitalized terms used in this Privacy Policy but not defined herein have the meanings assigned to them in the Terms of Use.  

This Privacy Policy does not apply to information collected by us offline or through any other means, including on any other website operated by Ro or any third party; or any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Websites or Apps.

Please read this Privacy Policy carefully.  By accessing or using the Websites and Apps, you accept the practices and policies outlined in this Privacy Policy and you hereby consent that we will collect, use, and disclose your information as set forth in this Privacy Policy.  If any term in this Privacy Policy is unacceptable to you, please do not use the Websites or Apps or provide any personal information. This Privacy Policy may change from time to time (see Revisions to Our Privacy Policy) and your use of the Websites and Apps after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

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:

We collect this information:

Information You Give to Us.  The information we collect on or through our Websites or Apps may include:

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:

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:

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:

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.

We may disclose your personal information to third parties in connection with the provision of our Services or as otherwise permitted or required by law.  You agree that we have the right to disclose personal information that we collect or you provide as described in this Privacy Policy, including:

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.

Tracking Technologies and Advertising. 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 Websites or Apps may then be inaccessible or not function properly.

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 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.

DATA SECURITY

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.

THIRD PARTIES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices, including data privacy and security process and standards of any third parties, including physicians and other health care providers using the Services, the manufacturer of your mobile device and other IT hardware and software, and any other third party mobile application or website to which our Websites, Apps, or Services may contain a link.  These third parties may at times gather information from or about you. We have no control over the privacy practices of these third parties.

Even though Ro may not be a “covered entity” as defined in HIPAA, any physician or other health care provider engaging through our Services may be a “covered entity” and therefore subject to the provisions of HIPAA from time to time.  If you are using the Services, your acceptance of the Terms of Use and this Privacy Policy incorporates your acceptance and consent to the Ro Professionals Notice of Privacy Practices included on the Websites. This notice describes how your physician or other health care provider uses and discloses your PHI.  Ro has agreed that its collection, use, and disclosure of your PHI on behalf of your physician or health care provider will be done consistent with the Ro Professionals Notice of Privacy Practices except to the extent you have expressly authorized additional uses and disclosures.

USE BY MINORS

If you are under 18 years of age, we must obtain valid and verifiable consent by your parent or legal guardian to this Privacy Policy and our Terms of Use before you can use Websites, Apps, and Services.  Such consent will be obtained via reasonable methods, as determined by us in our sole discretion. If we determine that the consent obtained is inadequate, we will notify you and you may not use or access the Websites, Apps, or Services at any time or in any manner.  However, if you are a parent, legal guardian or personal representative of a minor child under 18 years of age, you may, in compliance with the Terms of Use use our Services on behalf of such minor child. Any information you provide us on behalf of your minor child will be treated in accordance with this Privacy Policy.  We do not knowingly collect information for individuals under the age of 18 for whom we have not obtained adequate consent pursuant to the above. If we learn that we have received any information for an individual under the age of 18 for whom we have not obtained adequate consent pursuant to the above, we will only use that information to respond directly to that child (or a parent, legal guardian or personal representative) to inform him or her that he or she cannot use our Service, and subsequently we will delete that information from our own servers.

REVISIONS TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time.  It is our policy to post any changes we make to our Privacy Policy posted on this page.  The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy.  Your continued use of our Websites or Apps after such amendments will be deemed your acknowledgment of these changes to this Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us at:

 

Zachariah Reitano

Chief Privacy Officer

900 Broadway, Suite 706

New York, NY 10003