Privacy Policy

Effective July 22, 2015

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Zephyr Health, Inc.

Zephyr Health, Inc. (“Zephyr Health“) is committed to protecting all personal information that is provided to us. The following sections describe the type of personal information we collect, how we use it, and the options available for making changes to that information. This Privacy Policy applies to http://zephyrhealth.com (our “Website”) and to the Zephyr Platform and the Zephyr Network (collectively referred to as our “Services”). Please check our Website regularly for updates of this policy at https://zephyrhealth.com/privacy-policy/.

Safe Harbor Statement

Zephyr Health complies with the U.S. – E.U. Safe Harbor framework and the U.S. – Swiss Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal data from European Union member countries and Switzerland.  Zephyr Health has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement.  To learn more about the Safe Harbor program, and to view Zephyr Health’s certification, please visit http://www.export.gov/safeharbor/.

Personal Information that We Collect

We collect several types of personal information from Website visitors, customers, and public websites, including contact information such as name, email address and phone number, and tracking technologies information such as your usage of our Services and IP addresses.

How We Use the Personal Information that We Collect

We use personal information to:

  • Support the processing of our Services
  • Maintain our customer accounts and records
  • Carry out our contractual and legal obligations
  • Support and manage our employees
  • Send you blog emails, newsletters, and marketing communications
  • Send a one-time email to the designated email address when you choose to share news articles via email
  • Respond to your questions and concerns
  • Improve our Website and marketing efforts
  • Conduct internal research and analysis

Zephyr Health only shares personal information with contracted third parties such as our service providers.  We will only share personal information with third parties in ways that are described in this Privacy Policy.

Tracking Technologies

Technologies such as cookies, beacons, tags and scripts are used by Zephyr Health and our online service and marketing providers. These technologies are used in analyzing trends, administering the Website, tracking users’ movements around our Website, and to gather demographic information about our user base as a whole.  We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. We use cookies to remember users’ settings (e.g. language preference) and for internal analytics usage. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our Website, but your ability to use some features or areas of our site may be limited. As is true of most Websites, we gather certain information automatically and store it in log files.  This information may include internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data.  We may combine this automatically collected log information with other information we collect about you. We do this to improve services we offer you, to improve marketing, analytics, or Website functionality.

Advertising

We partner with a third party to display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this site and other sites to provide you advertising based on your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, click here. Please note this does not opt you out of being served ads; you will continue to receive generic ads.

Making Changes to Personal Information and Opt-Out

Where Zephyr Health receives personal information from entities in the EU or Switzerland, Zephyr Health will provide individuals with an opportunity to opt-out if such personal information is to be disclosed to a third-party or used for a purpose incompatible with the purpose for which it was originally collected. You may request a change to your personal information or to opt-out by sending us a written explanation to privacy@zephyrhealth.com. Where information cannot be changed or removed, we will tell you the reason(s). We will provide confirmation that your request has been processed within (30) days upon receipt of the request.

Zephyr Platform and the Zephyr Network (Services)

The use of information collected through our Services shall be limited to the purpose of providing the service for which our customer has engaged Zephyr Health.

Zephyr Health collects information under the direction of its customers, and has no direct relationship with the individuals whose personal information it processes. Before using our Services, we enter into a written agreement with our customers that they have sufficient rights to allow us to process the personal information provided to us. Individuals who do not wish to have their personal information collected or who seeks to access, correct, or delete personal information should contact our customers directly for guidance on opting out. If you are a customer and would like to update your information, please contact us via your Zephyr Account Representative. If our customers request Zephyr Health to correct or delete personal information, we will respond within a reasonable timeframe.

We may transfer personal information to companies that help us provide our services. Transfers to subsequent third parties are covered by the service agreements with our customers.

We will retain the personal information we process on behalf of our customers for as long as needed to provide services to our customer, comply with our legal obligations, resolve disputes, and enforce our agreements.

Protection of Personal Information

Zephyr Health classifies personal information as confidential. We maintain reasonable security measures to protect confidential information from loss, destruction, misuse, and unauthorized access or disclosure. Our Website and Services use transport layer security (TLS) technology.  Please note that no method of transmission over the Internet, or method of electronic storage, is 100% secure.  Therefore, we cannot guarantee its absolute security.  If you have any questions about security on our Website and Services, you can contact us at security@zephyrhealth.com.

Retention of Personal Information

Zephyr Health retains personal information for only as long as needed to comply with our legal obligations, resolve disputes, enforce our agreements, or as otherwise reasonably necessary for our business purposes.

Disclosure of Personal Information

We may also disclose your personal information:

  • as required by law, such as to comply with a subpoena or similar legal process;
  • when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request
  • if Zephyr Health is involved in a merger, acquisition, or sale of all or a portion of its assets,  you will be notified via email and/or a prominent notice on our Website of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information;
  • to any other third party with your prior consent to do so

Social Media Features

Our Website includes social media features, such as the ShareThis  button or interactive mini-programs that run on our Website. These features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the feature to function properly. Social media features are either hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy policy of the company providing it.

Links to Other Websites

Our Website may contain links to other Internet sites, such as Twitter, and they may ask for different personal information. We do not accept any responsibility or liability for the privacy practices of third-party websites. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any website you visit.

Changes to this Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email or by means of a notice on this Website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Us

If you have any questions or concerns regarding our Privacy Policy or our Safe Harbor certification, please email us at privacy@zephyrhealth.com.

Dispute Resolution Related to This Policy

Individuals may file a complaint concerning our processing of their personal information with our Chief Information Security & Privacy Officer, whose contact information is below. We will take steps to remedy any issues arising out of a failure to comply with our Privacy Policy and the applicable Safe Harbor privacy principles. If a complaint cannot be resolved through our internal processes, we may refer the matter to the EU data protection authorities and Swiss Federal Data Protection and Information Commissioner. Individuals may file a complaint by emailing us at privacy@zephyrhealth.com or mailing us at:

Zephyr Health, Inc. Attn: Chief Information Security & Privacy Officer 450 Mission Street, Suite 201 San Francisco, CA 94105 USA

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