Updated: December 14, 2021
Healthy.io Ltd. (“Healthy”, “we”, “our” or “us”) puts great efforts in making sure that the personal data processed by us is safe and used properly, and that our data practices are properly communicated to our users and visitors.
Cookies and Tracking Technologies
Data Subject Rights
You are not legally required to provide us with any personal data. If you do not wish to provide us with your personal data, or to have it processed by us or any of our Service Providers (defined below), please avoid any interaction with us or with our Site, or submit a request to exercise your rights as further explained in Section 9 below.
We collect and generate the following types of personal data concerning our Visitors:
• Website usage information (connectivity, technical and aggregated usage data(, such as user agent, IP addresses, device data (like type, OS, device id, browser version, locale and language settings used), activity logs, session recordings, and the cookies and pixels installed or utilized on their device;
• Visitor information that you provide us, such as information you provide when submitting an online form on the Site, including the “Contact Us” form, such as, your first and last name, e-mail address, your health insurance plan, your primary care physician’s (“PCP”) contact information (such as your PCP’s name, address, fax and/or phone number, and e-mail), or information we collect by contacting us or interacting with us through any other means. In this respect, please do not provide us with any personal data or sensitive information which is not required by us to process your request or inquiry.
We collect such data either automatically, through your interaction with us or with our Site, or through third party services, social media, analytics tools, webinars and events we organize or participate in, and other business initiatives.
2. Data Uses
We use Visitors’ personal data as necessary for the operation and provision of our Site; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Site, e.g. in understanding how our Site is used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our services; providing customer service and technical support; and protecting and securing our customers, users, visitors, ourselves and our services.
Specifically, we use our Visitors’ personal data for the following purposes:
• To facilitate, operate, and provide the Site;
• To monitor, study and analyze use of the Site;
• To contact you with general or personalized service-related messages, as well as promotional messages that may be of specific interest to you;
• To gain a better understanding on how individuals use and interact with our Site, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Site and services;
• To facilitate and optimize our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively. Such activities allow us to highlight the benefits of using our services, and thereby increase your engagement and overall satisfaction with our services. This includes contextual, behavioral and interests-based advertising based on your activity, preferences or other data available to us or to our business partners;
• To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
• To create aggregated statistical data, inferred non-personal data, or anonymized or pseudonymized data (rendered non-personal and non-identifiable), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
• To comply with applicable laws and regulations.
3. Data Location
4. Data Retention
We retain your personal data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Site and offerings; in order to comply with our legal and contractual obligations; to pursue our legitimate business purposes; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your personal data for any particular period, and we are free to securely delete it or restrict access to it for any reason and at any time, with or without notice to you. If you have any questions about our data retention policy, please contact us by e-mail at [email protected].
5. Data Sharing
Legal Compliance: We may disclose or allow government and law enforcement officials access to your personal data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations. Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect our legitimate business interests, including the security or integrity of our Site, products, and services.
Service Providers: We may engage selected third-party companies and individuals to perform services complementary to our own. Such service providers may include hosting and server co-location services, communications and content delivery networks (CDNs), data security services, fraud detection and prevention services, web analytics, e-mail distribution and monitoring services, session, call or activity recording and analysis services, remote access services, performance measurement, data optimization and marketing services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, financial and compliance advisors (collectively, “Service Providers“). Our Service Providers may have access to personal data, depending on each of their specific roles and purposes in facilitating and enhancing our Site, and may only use the data for such limited purposes as determined in our agreements with them.
Protecting Rights and Safety: We may share personal data with others if we believe in good faith that this will help protect the rights, property or personal safety of Healthy, any of our Visitors, users or customers, or any members of the general public.
Your Health Plan: We may share personal data with your health plan, in the event you have a health plan and choose to provide us with that information. We share this data with your health plan to alert them to your potential interest to our services and our products. Additionally, after we confirm your PCP details with us – we will share certain information about your PCP, such as your PCP’s name, address, fax and/or phone number, and e-mail address with your health plan. For the avoidance of doubt, Healthy may share personal data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal, non-identifiable and anonymous. We may transfer, share or otherwise use non-personal and non-identifiable data at our sole discretion and without the need for further approval.
6. Cookies and Tracking Technologies
Cookies are packets of information sent to your web browser and then sent back by the browser each time it accesses the server that sent the cookie. Some cookies are removed when you close your browser session. These are the “Session Cookies”. Some last for longer periods and are called “Persistent Cookies”. We use both types.
We use Persistent Cookies to remember your log-in details and make it easier for you to log-in the next time you access the Platform. We may use this type of cookies and Session Cookies for additional purposes, to facilitate the use of the Site’s features and tools. For more information regarding cookies, you may find the following websites useful: www.allaboutcookies.org, www.youronlinechoices.co.uk.
Whilst we do not change our practices in response to a “Do Not Track” signal in the HTTP header from a browser or mobile application, you can manage your cookies preferences, including whether or not to accept them and how to remove them, through your browser settings. Please bear in mind that disabling cookies may complicate or even prevent you from using the Site.
We also use analytics tools such as Google Analytics. These tools help us understand users’ behavior on our Site, including by tracking page content, and click/touch, movements, scrolls and keystroke activities.
Further information about the privacy practices of our analytics service providers is available at: www.google.com/policies/privacy/partners/;
Further information about your option to opt-out of these analytics services is available at: https://tools.google.com/dlpage/gaoptout;
Please note that if you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers), you may also clear the opt-out cookies installed once you opt-out, so an additional opt-out will be necessary to prevent additional tracking.
We may engage you in service and promotional communications through e-mail, phone, SMS and notifications.
We may also notify you about new features, additional offerings, events, special opportunities or any other information we think you will find valuable. We may provide such notices through any of the contact means available to us (e.g., phone, mobile or e-mail), through the Site, or through our marketing campaigns on any other sites or platforms.
If you do not wish to receive such promotional communications, you may notify Healthy at any time by sending an e-mail to: [email protected], or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
8. Data Security
We implement systems, applications and procedures to secure your personal data, to minimize the risks of theft, damage, loss of information, or unauthorized access or use of information. However, although we make efforts to protect your privacy, we cannot guarantee that our Site will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.
9. Data Subject Rights
Individuals have rights concerning their personal data. Please contact us by e-mail at: [email protected] if you wish to exercise your privacy rights under any applicable law, including the EU General Data Protection Regulation (GDPR) or the California Consumer Privacy Act (CCPA), such as – to the extent applicable – the right to request access to, and rectification or erasure of your personal data held with Healthy, or to restrict or object to such personal data’s processing, or to port such personal data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you).
Please note that when you ask us to exercise any of your rights under this policy or applicable law, we may need to ask you to provide us certain credentials to make sure that you are who you claim you are, to avoid disclosure to you of personal information related to others and to ask you to provide further information to better understand the nature and scope of data that you request to access. Such additional data will be then retained by us for legal purposes (e.g., as proof of the identity of the person submitting the request).
We may redact from the data which we will make available to you, any personal data related to others.
10. Additional Notices
Children: Our Site is not designed to attract children under the age of 16. We do not knowingly collect personal data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Site, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any personal data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at [email protected].
EU Representative: Maetzler Rechtsanwalts GmbH & Co KG (Prighter) has been designated as Healthy’s representative in the European Union for data protection matters pursuant to Article 27 of the GDPR. Prighter may be contacted only on matters related to the processing of personal data. To make such an inquiry, please send an email to [email protected].
UK Representative: Healthy.io UK Limited has been designated as Healthy’s representative in the United Kingdom for data protection matters pursuant to Article 27 of the UK GDPR. Healthy UK may be contacted on matters related to the processing of personal data. To make such an inquiry, please send an email to [email protected].