Privacy Policy

Introduction

This Privacy Policy (our “Privacy Policy”) describes how Jasper Health, Inc. (“we,” “our,” or “us”) collects personal information about you through the use of www.hellojasper.com, its subpages, or our app (collectively our “Platform”) and through other electronic communications between you and Jasper Health, Inc. This Privacy Policy also describes our practices for collecting, using, maintaining, protecting, and disclosing that information. We respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy applies to information we collect:

on our Platform;
in email, text, and other electronic messages between you and our Platform;
when you interact with our advertising and applications on third-party Platforms and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by us or any third-party;
any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Platform. We do not maintain these websites and are not responsible for the privacy practices of the websites that we do not operate. Please refer to the privacy policies posted on those websites.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using our Platform, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see below under “Changes to Our Privacy Policy”). Your continued use of our Platform after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Information We Collect About You

We collect, or may collect, several types of information from and about users of our Platform, specifically information:

by which you may be personally identified, such as your name, postal address, billing address, work address, shipping address, e-mail address, telephone numbers (home, work, and mobile), government identification numbers, date of birth, credit or debit card number (for payment purposes only), gender, race, religion, political orientation, salary, photos of you, and other personal information;
that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Platform, error information, clickstream data, and other communication data and the resources that you access and use on the Platform;
about your internet connection, the equipment you use to access our Platform and usage details.

We refer to this information collectively as “Personal Data” in this Privacy Policy.

We are not a health care provider. Our affiliate, Jasper Health Services Florida, LLC (“Jasper FL LLC”) provides you with patient care. We may collect Protected Health Information (“PHI”) for some users on Jasper FL LLC’s behalf, which is regulated under the Health Insurance Portability and Accountability Act of 1996 (HIPAA). Please review Jasper FL LLC’s Notice of Privacy Practices for information on how we use and disclose your PHI on their behalf. Please note that the following sections may include examples of how we collect, use, and share personal data that is PHI subject to HIPAA and governed by our Notice of Privacy Practices.

How We Collect Information About You

We collect Personal Data directly from you when you provide it to us, automatically as you navigate through the Platform and from third parties, for example, our business partners.

The information we collect on or through our Platform provided by you may include:

information that you provide by filling in forms on our Platform. This includes information provided at the time of registering to use our Platform, completing a questionnaire or form, or requesting further services. We may also ask you for information when you report a problem with our Platform;
records and copies of your correspondence (including email addresses), if you contact us;
your responses to surveys that we might ask you to complete; and
details of transactions that may be tracked through our Platform and of initiation of services. You may be required to provide financial information as part of initiation of services through our Platform.

We may also collect information about you, including Personal Data, automatically when you visit our website. The information we collect automatically may include personally identifiable information or we may maintain it or associate it with personally identifiable information we collect in other ways or receive from third parties. It helps us to improve our website and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
verify your location to ensure we can provide you with our services;
store information about your preferences, allowing us to customize our website according to your individual interests;
recognize you when you return to our website.

The technologies we use for this automatic data collection may include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
Web Beacons. Pages of our Platform and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single- pixel gifs) that permit us, for example, to count users who have visited those pages, used those screens, or opened an email and for other related Platform statistics (for example, recording the popularity of certain Platform content and verifying system and server integrity).
Flash Cookies. Certain features of our Platform may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Platform. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
Third-Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on the Platform are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any Personal Data:

to provide our Platform and its contents to you;
to communicate with you about our products and services;
to send newsletters, advertisements, or other promotional materials to you regarding our products and services;
to develop services for you;
to provide you with information, products or services you request from us;
to register and service your account;
to provide you with notices about your account;
to track administration of care coordination transactions and initiation of services you request;
to capture session audio for transcription or note-taking purposes;
to administer quizzes, surveys, sweepstakes, promotions, and contests;
to contact you in response to a request;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
to enforce our rights arising from contracts or our intellectual property rights;
to notify you about changes to our Platform or any of our products and services;
in any other way we may describe when you provide the information;
to fulfill any other purpose for which you provide it;
for any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. For more information, see Choices About How We Use and Disclose Your Information.

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

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Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We may disclose your Personal Data:

to our contractors and third-party service providers that we use to support our business;
to a company we merge with, acquire, or that buys us, or in the event of change in structure of our company of any form, such as a sale or transfer of some of all of our assets, or a bankruptcy, liquidation or similar proceeding;
to affiliates and third parties for their commercial purposes;
to enforce or apply our and other agreements, including for billing and collection purposes;
to affiliates and third parties to market their products or services to you if you have not opted out of these disclosures;
to comply with our legal obligations;
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others (including without limitation exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction);
to enforce our rights;
to resolve any potential fraud or perceived irregularity in any audits of the accuracy of any documentation or information submitted to us by you or on your behalf, as deemed appropriate by us;
to health information networks or exchanges
to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
to fulfill the purposes for which your provide it;
for any purpose disclosed by us when you provide the information; and
with your consent.

We may also disclose aggregated information about our users, and information that does not identify any individual, without restriction.

Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising.

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

Tracking Technologies and Advertising. You can set your browser or operating to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Platform may then be inaccessible or not function properly.
Promotional Offers from Us. If you do not wish to have us use your email address to promote our products and services, you can opt-out at any time by emailing us at the contact info below. This opt out does not apply to information provided to us as a result of your purchase or use of our products and services.
Disclosure of Your Information to Affiliates and Third Parties. By using our Platform, you consent to our sharing of your Personal Data with our affiliates and third parties for their promotional purposes. If you wish to unsubscribe from such affiliate and third parties’ promotions, you can do so by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from them.
Targeted Advertising. We belong to ad networks that may use your browsing activity across participating Platforms to show you interest-based advertisements on those Platforms. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative Platforms (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. 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. You can also opt out of receiving targeted ads from members of the NAI on its Platform.

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. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

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Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, Washington, and Utah may have additional personal information rights and choices. Please see your State Privacy Rights for more information.

Promotions for Our Products and Services

We may use your Personal Data to contact you about products and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by contacting us at the email below. For more information, see Choices About How We Use and Disclose Your Information.

Purchase and Sale of Products and Services

You may have the opportunity to purchase products and services on our Platform. When you make a purchase or attempt to make a purchase through our Platform, we collect certain information from you, including your name, billing address, shipping address, payment information (including credit card numbers), email address, and phone number. We refer to this information as “Order Information” and for purposes of this Privacy Policy, Order Information is considered Personal Data.

We use Order Information we collect generally to process, fulfill and administer transactions and orders for products and services placed through our Platform (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). We also use Order Information to communicate with you, screen our orders for potential risk or fraud, and, when in line with your preferences you have shared with us, provide you with information or advertising relating to our products and/or services.

We use a third party to process purchases and shipment of our products and services on our Platform. Accordingly, we may share your Personal Data with that third party to facilitate your purchase of our products and services.

In connection with our products and services, we may be required or permitted by law to share your Personal Data, without prior notice to you, under certain circumstances including reporting adverse reactions to certain items, product recalls, preventing disease and for health research purposes. In accordance with applicable laws and/or in a good faith effort, we may disclose your Personal Data, without prior notice to you, in an effort to safeguard the personal safety of users of our Platform and/or the general public.

Advertising Partners

We may use how you browse in order to show you ads for our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our Platform or third party sites we do not own.

Links To Other Platforms

Our Platform contains links to other Platforms that have information we believe may be of interest. We do not endorse these sites. While we try to link only to Platforms that share our high standards and respect for privacy, we are not responsible for the content of the sites or privacy practices employed by other sites. We encourage you to read the privacy policy of each site you visit that may collect information or ask you to disclose Personal Data. This Privacy Policy does not apply to information collected on external Platforms that may be linked to or through the Site.

Testimonials

We may display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or deactivate your testimonial, you can contact us at the contact information listed below.

SMS/MMS Mobile Messaging Marketing Program

We may use your telephone number for the purpose of sending you SMS messaging related to the services we provide, marketing messages, order and shipping confirmations, and other purposes if you have opted in to receive such messaging. Message and data rates may apply. To stop receiving SMS, reply STOP at any time. For help, contact support@hellojasper.com.

Messaging will be sent by an automated system initiated by our third party messaging provider. We do not share your telephone number with third parties for the purposes of receiving third party marketing messages. We also will not send messages to you promoting the goods or services of third parties. For additional information regarding our SMS messaging program, please read our Terms of Service or reach out to us at the contact information below.

Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may review and change your Personal Data settings by emailing us at the contact information below. You may also notify us through the contact information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your Personal Data. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about California residents' privacy rights, visit https://oag.ca.gov/privacy/ccpa.

We do not disclose personal information obtained through our Platform to third parties for their direct marketing purposes. Accordingly, we have no obligations under Civil Code § 1798.83.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:

Confirm whether we process their personal information.
Access and delete certain personal information.
Data portability.
Opt-out of personal data processing for targeted advertising and sales.

Colorado, Connecticut, and Virginia also provide their state residents with rights to:

Correct inaccuracies in their personal information, taking into account the information's nature processing purpose.
Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

To exercise any of these rights you may submit a request via email to support@hellojasper.com. To appeal a decision regarding a consumer rights request you may submit a request via email to support@hellojasper.com.

Nevada provides its residents with a limited right to opt-out of certain personal information sales. Residents who wish to exercise this sale opt-out rights may submit a request via email to support@hellojasper.com.

No negative consequences will be imposed on you for exercising any of your State Privacy Rights.

Data Retention

We will retain your information for as long as your account is active or as needed to provide you services. If you wish to deactivate or delete your account or request that we no longer use your information to provide you services, contact us at the contact information listed below. If you provide, enter, upload, or create any information on our Site, it may be difficult if not impossible, to deactivate or delete this information if you later desire to remove the data. By providing this information in any form, you consent that this information loses its right for future deletion. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

Do Not Track Signals

We also may use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such signal is broadcast or received.

Data Security

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where you have chosen a password for the use of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Platform. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform or in your operating system.

Data Protection Rights

We would like to make sure you are fully aware of all your data protection rights. Every user is entitled to the following:

The right to access: You have the right to request our Company for copies of your personal data. We may charge you a small fee for this service.

The right to rectification: You have the right to request that our Company correct any information you believe is inaccurate. You also have the right to request our Company to complete information you believe is incomplete.

The right to erasure: You have the right to request that our Company erase your personal data, under certain conditions.

The right to restrict processing: You have the right to request that our Company restrict the processing of your personal data under certain conditions.

The right to object to processing: You have the right to object to our Company’s processing of your personal data, under certain conditions.

The right to data portability: You have the right to request that our Company transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us via email at support @hellojasper.com.

We do not sell personal data to third parties or engage in targeted advertising as defined under applicable laws. We do not use personal data subject to the Colorado Privacy Act for profiling in furtherance of decisions that produce legal or similarly significant effects concerning individuals. We may use protected health information subject to HIPAA to provide you with personalized medical care, including providing preventative care and treatment options.

To exercise your rights, please submit a request by emailing us at support @hellojasper.com. If legally required, we will comply with your request upon verification of your identity and, to the extent applicable, the identity of the individual on whose behalf you are making such request. To do so, we will ask you to verify data points based on information we have in our records. If you are submitting a request on behalf of another individual, please use the same contact methods described above. If we refuse to take action regarding your request, you may appeal our decision by emailing us at support @hellojasper.com.

Please note the privacy rights described above do not apply to personal data that is collected, processed, or disclosed pursuant to HIPAA. Because we are subject to those laws and regulations, much of the personal data that we collect is exempt from other applicable privacy laws. Your choices and rights with respect to our use and sharing of that information is subject to our Notice of Privacy Practices.

Spouse and Dependent Authorization

Before you enroll in any of the available health and wellness programs, we would like to provide you with some information about the health information we may ask for from you, how and why we use it, and how we protect it. You are not required to participate in any of these programs. Participation is completely voluntary. However, if you choose to participate, you may receive incentives and/or information on services to help you manage your health. If you choose not to participate, you may not receive program incentives, if any, offered by your health plan for participation in such health and wellness programs.

What information do we obtain?

Our health risk assessment (HRA) asks questions about your health status and conditions, health-related activities and behaviors.
Our condition management programs, including, but not limited to, asthma, diabetes, chronic obstructive pulmonary disease, coronary artery disease, and heart failure disease management programs ask questions about your health status and conditions, health-related activities and behaviors.
We may also receive and share PHI through health information exchanges

How do we use your information?

Information provided to us as part of an HRA, or as part of a biometric screening, may be used to identify services that may be relevant to you, including those wellness coaching services or condition management services noted above.
Information provided to us as part of the condition management programs may be used to help us provide you with [feedback and educational information about your lifestyle and condition, to help you in your journey to better manage your health.

How do we share and protect your information?

The health information you give us as part of a health and wellness program is generally not shared with your spouse’s/parent’s employer, although we may share certain information (e.g., the amount of incentives earned), as necessary where their employer or their designated third party vendor is administering incentive awards. We will share information with our wellness coaches, nurses, and doctors, whom are involved in administering your wellness and condition management programs and health plan. We only share information with our research partners, vendors and subcontractors in accordance with applicable laws, including HIPAA, as necessary to administer your wellness and condition management programs or health plan, and anyone who receives information from us for purposes of providing you services is required to abide by the same confidentiality requirements.
We take reasonable precautions to protect data and to avoid data breaches, including maintaining physical, technical, and administrative safeguards. Such safeguards may include, for example, firewalls, encryption, identity management, and intrusion prevention/detection to prevent improper access, use, and disclosure of your data in our networks. In the event of a data breach involving information you provide in connection with the wellness program, we will notify you within the time periods required by applicable laws, including HIPAA.

Your California Privacy Rights

Under some circumstances, California law may provide you with the right to obtain a list of third parties (if any) that we provide your Personal Data to for their own direct marketing purposes.

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Platform that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the preceding calendar year (e.g., requests made in 2020 will receive information regarding such activities in 2019). You may request this information once per calendar year. To make such a request, please send an email by using the Contact Information below.

Children Under the Age of 18

Our Platform is not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Platform. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Platform or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18, we will delete that information. If you believe we might have any information from a child under 18, please contact us using the contact information listed below.

Storage of Personal Data in the United States

All of the information that you provide to us will be stored and processed in the United States. While you may access our Platform from a location outside of the United States, you agree not to transfer any of your information to us from outside the United States. The laws in the United States may not offer the same degree of privacy protection as the laws in your jurisdiction.

Changes to Our Privacy Policy

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we collect or use our users’ Personal Data, we will notify you by email to the email address you have provided to us and/or through a notice on our website (http://www.hellojasper.com) home page and on our app. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Platform and reviewing this Privacy Policy to check for any changes.

Contact Information

You may contact us through the contact information below.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Platform.

Contact Us

Name: Jasper Health, Inc.

‍Address: 950 W Bannock Street, Suite 1100, Box 9160, Boise, ID 83702

‍Telephone: +1 929-552-3904

‍Email: support@hellojasper.com

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