IANACARE PRIVACY POLICY

Effective Date: November 15, 2018

About this Privacy Policy and Our Commitment to Your Privacy

Ianacare, Inc. ("ianacare", "we", "us", "our") provides online products and services (collectively, the “Services”) through our mobile applications and ianacare.com (collectively, the “Site”) that may, among other things, provide you with tools to engage in virtual supportive care management for persons that require care assistance (for chronic illnesses and other situations).  We provide this privacy policy (“Privacy Policy”) to outline the information ianacare collects from users of the Site (“Users”, “you”) and how we may use and disclose this information when the Site is accessed through any device. It also describes the choices available to you regarding our use of your information and how you can manage and update this information. Some online services offered by or affiliated with ianacare may be governed by a separate privacy policy.

Your Consent to this Privacy Policy by Using the Site

As described in this Privacy Policy, we may use and disclose your information to provide you with products and services and to improve your experience using those products and services. By using the Site, or any other website, online service or mobile application where this Privacy Policy is posted, you agree to our collection, use, disclosure, and storage of information as described in this Privacy Policy.

Third-Party Advertising on Our Site

We do not allow third parties to advertise to Users on our Site, unless you provide consent, which is not requested in this Privacy Policy.

How to Contact Us with Questions about this Privacy Policy

Please read this Privacy Policy carefully. If you have questions or complaints regarding our Privacy Policy or privacy practices, please contact us at: Attn: Chief Privacy Officer, ianacare, Inc., #290532, 23 Austin St., Charlestown, MA 02129 or info@ianacare.com.

Information Addressed by this Privacy Policy

We want you to have a clear understanding of the information addressed by this Privacy Policy. We will collect information about you (“Information”) in a variety of ways, including directly from you, through automatic means, or from third parties. The Information that is collected depends on how you use the Site.

Personal Information and Privacy

When you use our Service, you may be creating and maintaining a personal, private area of the application (“Individual Site”) on behalf of yourself and/or one or more persons within your care team (“Care Team”), or visiting and posting to an Individual Site created by someone else within your Care Team. By their very nature, these Individual Sites contain a great deal of personal information about the subject of the Individual Site and other Users on the Care Team. Our goal is to balance our Users' need to find each other and communicate information and support against our Users' desire for a measure of privacy.  By establishing an Individual Site, you represent that you have all consents and authorizations necessary to use the information relating to members of your Care Team necessary to establish the Individual Site.

Site Access

The Individual Site is accessible “By Invitation Only.”  Once established, every member of a Care Team, including the creators of Individual Sites and all Users are responsible for maintaining the confidentiality of the Individual Site in accordance with the care recipient’s wishes.

Information You Provide Directly to ianacare

When you use the Site, you may provide certain information directly to us.  For example, without limitation, when you choose to register a user account, you will be required to provide, among other things, your e-mail address, name, and phone number.  When you create a Care Team, we may collect identifying information about members of the Care Team and the caregiver, such as the caregiver’s work status and living situation. We also collect information about how the supporter can help the care recipient. We may use this information to suggest services that may be of use to the caregiver or care recipient.

Certain Information in the Services is Visible to Other Users

Information regarding the care recipient’s needs, actions taken and updates may be shared among and be available to Care Team members, but is not publicly visible to other Users outside of the Care Team.

Information that is Automatically Collected

We and third parties may use automated means to collect information about you, your computer or other device that you used to access the Site, and your use of the Site. These automated means include common technologies such as cookies or similar technologies. These technologies help us analyze trends, administer the Site, track Users’ movements around the Site, gather demographic information about our user base as a whole, and otherwise provide you with relevant content (e.g., by gathering your zip or postal code). We may receive reports on an individual as well as aggregated basis based on the use of these technologies by ianacare, and any third-party vendors acting on ianacare's behalf.

Cookies and Tokens

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Site may use HTTP cookies, HTML5 cookies, Flash cookies and other types of local storage (such as browser-based or plugin-based local storage, or application-based local storage on a mobile device).  Your may be able to restrict or disable certain cookies. Please note, however, that without cookies, you may not be able to use all of the features of our Site.

Our cookies, tokens and similar technologies (collectively, "Tracking Technologies") also are used for administering the Site, including without limitation, for authentication, to remember Users’ settings, to customize the content and layout of the Site for Users, to contact you about the Site, and to improve our internal operations, the content of our Site and our services. Users may be able to control the use of, or reject or disable, some Tracking Technologies at the individual browser level. If you reject or disable Tracking Technologies, you may still use our Site, but your ability to use some features or areas of our Site may be limited. We use Tracking Technologies to identify your device and keep track of your Internet session with our Site. Using these Tracking Technologies, we may automatically end your session on our Site after a period of inactivity (as determined by us in our sole discretion). We also use Tracking Technologies that allow us to recognize your device when you return to the Site within a certain period of time (as determined by us in our sole discretion) and automatically log you back into your account with us. UNLESS YOU AFFIRMATIVELY LOG OUT of your account PRIOR TO YOUR SESSION ENDING (whether by you or by us), YOU WILL BE AUTOMATICALLY LOGGED BACK IN THE NEXT TIME YOU OR ANY USER OF YOUR DEVICE VISITS OUR SITE within the period of time determined by us. If you do not wish to be automatically logged back in when you (or someone using your device) next initiate a session with our Site (using the same device that is being used for your current session), you should log out of your account (i) prior to ending your session, or (ii) if you will be inactive on our Site for more than a few minutes.

Web Logs

In conjunction with the gathering of data through cookies, Web servers may log records such as your device type, operating system type, device advertising identifier, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The Web server logs also may record the address of the Web page that referred you to our Site, the IP address (and associated city and state or province for the IP address) of the device you use to connect to the Internet, and data about your interaction with our Site, such as which pages you visit.

Pixels/Web Beacons

To control which Web servers collect information by automated means, we may place tags on our Web pages called "Web beacons" (or “pixels”), which are files that link Web pages to particular Web servers and their cookies. We also may include Web beacons in e-mail messages to record whether an email has been opened or whether certain links in such email have been clicked. We or third parties also may send instructions to your device using JavaScript or other computer languages to store or gather the sorts of data described above and other details about your interactions with the Site. We may use third party pixels on the Site’s registration and login pages. For example, we may use these pixels to assess your progress in registering for our Site. If you start but fail to complete the registration process, we may also use third party pixels to deliver reminders to complete your registration. We may also use these pixels to deliver notices about new and existing features on our Site. These reminders and notices may appear on other websites, and third parties who provide the pixels may use the information obtained from pixels for their business purposes.

Online Analytics

We may use third-party web analytics services on our Site, such as those of Google Analytics. These service providers use the sort of technology described in this “Information that is Automatically Collected” section to help us analyze how Users use the Site, including by noting the third-party Web site from which Users arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Site.

Mobile Application Technologies

Our mobile applications may also collect information specific to use of your mobile device, such as unique device identifier and, with your consent, precise geolocation information, motion coprocessor data (e.g. recording information such as steps, distance, and elevation), accelerometer data (showing whether you're stationary or moving), and gyroscope data.

Collection of Information Across Personal Devices and Applications

Our Use of Information

Use and Storage of Information to Provide You with the Site and Related Services

Ianacare, and any third party vendors acting on ianacare's behalf, may use and store your Information to perform activities associated with providing you with the Site and related services such as: (i) registering you to use the Site and otherwise logging you into the Site, including the authentication of your identity, where applicable, and otherwise enabling your access to the Site; (ii) resolving disputes and/or troubleshooting problems including logging into your account to troubleshoot problems or otherwise help you navigate the Site; (iii) verifying your compliance with your obligations in our Terms of Service or other ianacare policies; (iv) improving the quality of the Site, (v) fulfilling any request you make; (vi) communicating with you; (vii) connecting you with and providing you with information about services, providers of services, resources or programs to which you may have access; (viii) providing you with Site content, including, without limitation, generating recommendations (such as recommended Site activities or services), and processing your preferences and requests; (ix) analyzing, customizing, and personalizing the Site, including through the delivery of tailored content and communications; and (x) otherwise as directed by you or provided for herein. Except where prohibited by law, and only to the extent permitted by ianacare’s agreements with applicable Ianacare Partners, we may also use your Information in connection with any other services we make available to you.

Additional Information Regarding Use of Information for Communications with You

If you choose to tell a friend about our Service or share an Individual Site through our Site, we will ask you for your friend's name and email address/or phone number.  We will automatically send your friend a one-time email or text message inviting him or her to visit the site. We retain this information to identify the User as part of the care team when they sign in.

Ianacare, Ianacare Partners, and any third-party vendors acting on ianacare's behalf, may also use your Information to communicate with you (including, without limitation, via email and/or mobile push notifications) about the Site and/or our products and services (and related features and functionality) or those of any Ianacare Partner that is providing services to you. Our communications to you will include, without limitation, contacting you by SMS text message or at the email address(es) that you use to register for our Site to communicate with you regarding the Site and actions that you take in connection with the Site.

Your Choices Regarding Our Communications with You

In accordance with applicable law, we will offer you the opportunity to opt out of certain communications, such as, for example, communications that deal with any of our products or services you are not using but that we think might be of interest to you. Where applicable, you can opt out by emailing us at info@inanacare.com. However, even if you opt out of such communications, you may continue to receive other transactional, relationship, and/or administrative communications from or through ianacare that are important or related to your ianacare account or the products and services you are using (such as, for example, a notice that there has been a change in one of your services or a change to this Privacy Policy). Please also note that you, not ianacare, have control over certain settings for how communications such as emails and push notifications are displayed on your devices, and the settings you select will affect how ianacare’s communications are displayed.

Creation and Use of Combined Data, De-Identified Data, and Aggregated Data

As permitted by law and by ianacare’s agreements with applicable Ianacare Partners, ianacare, and any third-party vendors acting on ianacare’s behalf, may aggregate and/or de-identify your Information and/or combine your Information with other information maintained or available to ianacare and use or disclose such information as follows:

We may use aggregated or combined data to communicate with you about the Site and/or our products and services and disclose such aggregated or combined data to Ianacare Partners in connection with providing the Site.

We may also use and disclose de-identified data, de-identified aggregated data, and/or de-identified combined data for any business purpose, which may include, without limitation, improving our products and services, conducting analytics such as evaluating our Site and developing additional benefits, programs, and services, and disclosing to Ianacare Partners for analytics purposes.

 

Disclosure of Information

We may share your Information in the following circumstances:

·     Disclosures to Service Providers and Ianacare Partners

Ianacare, and third party vendors acting on our behalf, may disclose your Information to Ianacare Partners, third-party service providers, or vendors acting on our behalf for the purpose of providing the Site and related services to you or other Users, including, without limitation, registering you to use the Site (e.g., authenticating your identity), logging you into the Site, providing you with information you have requested through the Site or related services, and connecting you with resources and other services (e.g., transportation or meal services). For example, we may provide your name, time and location of pickup and destination to a transportation services provider, such as Uber or Lyft, for purposes of giving you or another User in your Care Team a ride. Third-party service providers or vendors acting on our behalf are authorized to use your Information only in connection with providing these services to us or as required by law.  For example, we may store your information with a cloud storage service provider, such as Amazon Web Services or similar company.

·      Additional Disclosures with Your Consent

With your consent outside of this Privacy Policy, we may share your Information with third parties or allow them to collect information from the Site in some ways not specifically described in this Privacy Policy.

·      Safety, Security and Compliance with Law

Your Information and the contents of your communications through the Site may be disclosed to third parties as required by law, such as to comply with a subpoena or similar legal process, or when we reasonably believe disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, report improper or unlawful activity, or respond to a government request.

·      Subsidiaries and Affiliated Companies

Except where prohibited by law or precluded by contract, we may share your Information with any subsidiaries or other affiliated companies under the control of, or under common control with, ianacare for the purposes set out in this Privacy Policy.

·      Sale, Merger or Similar Transaction

We may share your Information in connection with any proposed or actual merger, reorganization, a sale of some or all our assets, a financing or acquisition of all or a portion of our business by another company, or to a receiver, trustee or successor in interest in bankruptcy, in which case such company may continue to process your Information as set forth in this Privacy Policy (except where prohibited by law) or otherwise with your consent.

We Do Not Control the Privacy Policies of Third Parties

Our Site may contain links that enable you to visit or use other third-party websites, resources or programs. However, we do not have control over the other websites, resources, or programs that you choose to visit, so this Privacy Policy does not apply to information collected or that you provide while visiting such other websites, resources, or programs. You should refer to the privacy policies, if any, applicable to the other websites, resources, or programs.

Data Security and Integrity

The security of your Information is important to us. We follow security standards to protect the Information submitted to us from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction, both during transmission and once we receive it. These safeguards vary based on the sensitivity of the Information that we collect, process and store and the current state of technology. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. We also maintain procedures to help ensure that such data is reliable for its intended use and is accurate, complete and current. If you have any questions about data security and integrity on our Site, you can contact us at info@ianacare.com.

Be Sure to Log Off When Using Public or Third-Party Computers

As described above, we use Tracking Technologies that automatically log you back into your account with us unless you affirmatively log out of your account prior to your session ending (whether you end your session or we end your session, for example if our Site has "timed out" – i.e. we have ended your session automatically after a period of inactivity as determined by us in our sole discretion). If you log into the Site using a public computer or device, or a computer or device of that belongs to or is shared with another person, you should affirmatively log out of your account. Otherwise, the next user of that computer or device may be able to access your account and your Information in your account if your session has not ended.

Your Use of Persistent Login

The log-in in our application is persistent.  We recommend that you log-out after use of the application, if you are concerned about the unauthorized use or disclosure of Information via persistent login.

Managing and Updating Information

To access, review, update and/or delete certain Information, you may contact us at info@ianacare.com., and you may update and/or delete certain Information by logging into the Site and updating your account. We will respond to your request within a reasonable and lawful timeframe under the circumstances of your request. Please remember, however, if we have already disclosed some of this Information to third parties, we cannot access that Information any longer and cannot force the deletion or modification of any such Information by the parties to whom we have made those disclosures. Additionally, if you modify certain Information on our Site that we received from a third party, we reserve the right, but are not obligated, to share the updated information back to that third party. As a result, you will need to provide updated information to those third parties if you want to be sure they have your updates.

Certain Information is necessary in order for us to provide the Site and our related Services; therefore, if you delete such necessary Information you will not be able to use the Site or receive our Services. If you wish to have your account deactivated, you may contact us at info@ianacare.com. After we receive your request, within a reasonable timeframe under the circumstances of your request, we will deactivate your account; provided, however, that: 1) ianacare (and our third-party vendors acting on our behalf), our Ianacare Partners, and any other applicable third parties may continue to use and share for any purpose de-identified data and aggregated or combined data developed using your Information that has been de-identified and 2) ianacare may continue to use Information in your deactivated account for compliance with applicable regulations. Also, please note that even though you may deactivate your account or request the deletion of your Information, we may be required (by law or otherwise, such as to prevent fraud, resolve disputes, or troubleshoot problems) to retain this information, in which case we will comply with your deletion request only after we have fulfilled such requirements. We may also keep a copy of your Information to protect our legal rights, such as in connection with your use of the Site or your agreement to our Terms of Service, as permitted or required by applicable law.

California Do-Not-Track Disclosure Requirements (for California Users)

We are committed to providing you with meaningful choices about the information collected on our Site for third-party purposes. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.

Your California Privacy Rights (for California Users)

California law permits customers of ianacare who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please write us:

ianacare, Inc.

#290532

23 Austin St.

Charlestown, MA 02129

email: info@ianacare.com.

We will provide a list of the categories of personal information, if any, disclosed to third parties during the immediately preceding calendar year for third-party direct marketing purposes, along with the names and addresses of these third parties. This request may be made no more than once per calendar year. We reserve our right not to respond to requests submitted other than to the email or postal address specified above. You should put "California Privacy Rights" in the subject line and in your request. You must provide us with specific information regarding yourself so that we can accurately respond to the request.

Children; Special California Notice

The Site and Services are not directed to children under the age of 18, and children under the age of 18 years of age are not eligible to use them. Protecting the privacy of children is very important to us. Through the Site and Services, we do not collect Information from people we actually know are under 18 years of age, and no part of the Site or Services is designed to attract people under 18 years of age. If we later learn that an individual has provided us with their information through the Site or Services and they are under 18 years of age, we will take steps to remove that User's Information from our databases and to prevent the User from utilizing the Site or Services.

If you are a California resident under the age of 18 and are a registered User of our Site, you may request that we remove from our Site any content you post to our Site that can be accessed by any other User (whether registered or not). Please note that any content that is removed from our Site may still remain on our servers and in our systems. To request removal of content under this provision, please send an email to info@ianacare.com and provide us with a description of the content and the location of the content on our Site, and any other information we may require in order to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Site by you.

HIPAA and Equivalent State Laws

You acknowledge that the Health Insurance Portability and Accountability Act (“HIPAA”) and equivalent state health information privacy laws generally do not apply to User Content.  Although HIPAA and state law may apply to User Content received by  licensed healthcare providers, these laws do not generally apply to unlicensed individuals, including ianacare and our Users.

Retention of Personal Data

Personal data will be retained only for so long as reasonably necessary for the purposes set out in this Privacy Policy, considering criteria such as applicable rules on statute of limitations and at least the duration of your use of our Site and Services. Information may persist in copies made for backup and business continuity purposes for additional time.

Modifications to this Privacy Policy

From time to time, we may update this Privacy Policy to reflect changes to our information practices. If we make changes to this Privacy Policy, they will be reflected in an updated Privacy Policy that will be posted on the Site, and all changes will be effective upon such posting or upon any later date specified by us in writing. We encourage you to periodically review this page for the latest information on our privacy practices. You can determine when this Privacy Policy was last revised by referring to the "Effective Date" legend at the top of this Privacy Policy. By continuing to use the Site or any services following the effective date of any updated Privacy Policy, you are agreeing to be bound by the terms and conditions of such updated Privacy Policy.