Privacy Policy

 

This Privacy Policy describes how Robyn Inc. (“Robyn”, “we”, “our” or “us”) collects, uses and shares your information when you visit our website at https://wearerobyn.co/ (or such other URLs or web addresses as may be made available by Robyn from time to time; the foregoing together as the “Site”) and use the services, features, content or applications we offer (collectively with the Site, the “Services”). We receive information about you from various sources, including: (i) if you register for the Site and the Services, through your user account on the Services (your “Account”); (ii) your use of the Services generally; and (iii) from third party websites and services. You acknowledge that this Privacy Policy is part of our Terms of Service, and by agreeing to use the Services, you are agreeing to be bound by all of its terms and conditions and all applicable laws and regulations. If you do not agree and consent, discontinue use of the Service.

Robyn Inc. is a U.S. company. Regardless of the country in which you live, you authorize us to access, transfer, store, and use your Personal Information (as defined below) in the United States and in accordance with this Privacy Policy. U.S. privacy and data protection laws and rules may vary from those in the country where you live.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information (“Personal Information”) gathered when you are using or accessing the Services. “Personal Information” is information that can be used to identify you by itself or when it is combined with other information, such as your first and last name, e-mail address, postal address or payment card information. This Privacy Policy also covers our treatment of any Personal Information that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (“Third Party Services”) that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access. Certain aspects of the Services are designed to help you share information with the world. If you make information public through our Services, other users will have access to it. We cannot guarantee information you make public through our Service will remain protected in accordance with this Privacy Policy. Please think carefully before making information public. You are solely responsible for information you make public.

Personal Information once “de-identified” is not subject to this Privacy Policy and we and our service providers and Agents (as defined below) may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

What Information Do We Collect?

The information we gather enables us to personalize, improve and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Information. We collect the following types of information from our users.

Account Information

When you create an Account, you provide information that could be Personal Information, such as your name, password and email address. You acknowledge that this information may be personal to you, and by creating an account on the Services and providing Personal Information to us, you consent to allowing others, including us, to identify you and therefore such Personal Information may not be anonymous. We may use your account information, which may include Personal Information, in a manner consistent with this Privacy Policy including to send you information about our Services. You may unsubscribe from these messages through your Account settings, although we, regardless, reserve the right to contact you when we believe it is necessary, such as for account recovery purposes.

User Content

Some features of the Services allow you to provide content to the Services, such as written comments. All content submitted by you to the Services may be retained by us indefinitely, even after you terminate your account.

IP Address Information and Other Information Collected Automatically

We automatically receive and record information from your web browser when you interact with the Services, including your IP address and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on).

Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site. We may use this data in aggregate form, that is, as a statistical measure, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

Email Communications

We may receive a confirmation when you open an email from us. We use this confirmation to improve our customer service.

Information Collected Using Cookies

Cookies are pieces of text that may be provided to your computer through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services through the Internet.

Our cookies do not, by themselves, contain Personal Information, and we do not combine the general information collected through cookies with other Personal Information to tell us who you are. As noted, however, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one.

Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Services.

This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer.

Information Related to Advertising and the Use of Web Beacons

To support and enhance the Services, we may serve advertisements, and also allow third parties’ advertisements, through the Services. These advertisements are sometimes targeted and served to particular users and may come from third party companies called “ad networks.” Ad networks include third party ad servers, ad agencies, ad technology vendors, and research firms.

Advertisements served through the Services may be targeted to users who fit a certain general profile category and may be based on anonymized information inferred from information provided to us by a user, including Personal Information (e.g., gender or age), may be based on the Services usage patterns of particular users, or may be based on your activity on Third Party Services. We do not provide Personal Information to any ad networks for use outside of the Services.

To increase the effectiveness of ad delivery, we may deliver a file (known as a “web beacon”) from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network’s servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site.

Aggregate Information

We collect statistical information about how both unregistered and registered users, collectively, use the Services (“Aggregate Information”). Some of this information is derived from Personal Information. However, this statistical information is not Personal Information and cannot be tied back to you, your Account or your web browser.

Information from Other Sources

We may obtain information about you from other sources, including service providers and third party services, and combine such information with information we have collected about you. To the extent such third party sourced information, alone or in combination with other information, can be used to identify you personally, we will treat the third party sourced information as Personal Information under this Privacy Policy. We are not responsible for the accuracy of any information provided by third parties or third party policies or practices.

HIPAA and Protected Health Information

Under the Health Insurance Portability and Accountability Act (“HIPAA”), some health and/or health-related information that we collect as part of providing the Services may be considered “protected health information” or “PHI.”

What PHI do we collect?

When you voluntarily give your PHI to us through our website and through your use of our Services we maintain such PHI in our systems. Examples of PHI you may provide include:

  • When you use your Account to make appointments or engage with medical professionals, Personal Information such as your name, address, and medical history.
  • When you use the Services, health information such as appointment information, claims processing data, and payment information.

HIPAA provides specific protections for the privacy and security of PHI and restricts how PHI is used and disclosed. We may use or disclose your PHI for treatment, payment, or healthcare operations purposes on behalf of healthcare providers and other purposes permitted or required by law. We may also disclose your PHI to other companies or individuals that need the information to provide services to us. For example, we may provide information to companies that assist us with support services or billing services now or in the future. These other entities, known as “business associates,” are required by HIPAA to also keep the PHI confidential and secure. Additionally, you may be asked by us to e-sign an authorization (the “HIPAA Authorization”). Your decision to e-sign the HIPAA Authorization is entirely voluntary. If you choose to e-sign the HIPAA Authorization, you agree that we may use and disclose your PHI in the same way we use and disclose your Personal Information that is not PHI. These uses and disclosures are described in this Privacy Policy. To the extent any provision in the HIPAA Authorization is inconsistent with this Privacy Policy, then the provisions in the HIPAA Authorization only controls with respect to your PHI. If you do not e-sign the HIPAA Authorization, then your Personal Information that is not PHI is governed by this Privacy Policy and your Personal Information that is PHI is used and disclosed by us only as permitted in accordance with our agreements with your healthcare provider(s).

 

What are my rights to my PHI?

You have rights regarding the PHI that we collect. You can request that we restrict the use and disclosure of your PHI by sending written request to the address below.

You can request that we send your health information by alternative means to an alternative address. Once you review your PHI, if you see any problems with your PHI, you may request amendments to your PHI by making a written request to us at the address below. We may deny the request in some cases. If we deny your request to change your PHI, we will provide you with a written explanation of the reason for the denial and additional information regarding further actions that you may take.

You also have the right to receive a list of certain disclosures of your PHI made by us in the past six years from the date of your written request to us at the address below. Under HIPAA, this does not include disclosures made for purposes of treatment, payment, or healthcare operations or the other certain other purposes we have stated above. We are required under HIPAA to notify you in the event of a breach involving your PHI and will do so as required by law.

Send requests regarding your PHI to hello@wearerobyn.co

How We May Use Your Information

We may use information about you, including your Personal Information, for any purposes consistent with our statements under this Privacy Policy or as permitted by applicable law,

including

  • Manage our Service, including your registration and account;
  • Process and facilitate your transactions, including purchases made through our marketplace;
  • Respond to your comments, questions, and requests, and provide customer service;
  • Send you technical notices, updates, security alerts, information regarding changes toour policies, and support and administrative messages;
  • Prevent and address fraud, breach of policies or terms, and threats or harm;
  • Monitor and analyze trends, usage, and activities;
  • Conduct research, including focus groups and surveys;
  • Improve the Services or other Roybn websites, applications, marketing efforts, products and services;
  • Send you advertisements and communicate with you regarding our and third party products, services, offers, promotions, rewards and events we think you may be interested in (for information about how to manage these communications and marketing efforts, please see “What Choices Do I Have Regarding My Information” below); and
  • Fulfill any other purpose disclosed at the time you provide Personal Information.We will not use information we have collected from you for purposes that are materially different, unrelated or incompatible with this Privacy Policy without providing you with prior notice.

How, and With Whom, Is My Information Shared?

The Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with third parties.

Public Information About Your Activity on the Services

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content (including videos and comments) you have posted publicly on the Site or otherwise through the Services.

Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

Please remember that if you choose to provide Personal Information using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

IP Address Information

While we collect and store IP address information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

Information You Elect to Share

You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within the Site. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services’ privacy policies. This Privacy Policy only governs information collected on the Services.

Aggregate Information

We share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non-Personal Information about you that they have independently developed or acquired.

Email Communications with Us

As part of the Services, you may occasionally receive email and other communications from us, such as communications relating to your Account. Communications relating to your Account will only be sent for purposes important to the Services, such as password recovery.

User Profile Information

User profile information including your username and other information you enter may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.

Information Shared with Our Agents

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our “Agents”). We may need to share Personal Information with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Information or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Information with our Agents.

Information Disclosed Pursuant to Business Transfers

From time to time, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, sell all or substantially all of our assets, are acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred to or acquired by a third party. You acknowledge that such transfers may occur, that we may transfer for your Personal Information in accordance with this policy and applicable law, and agree that any acquirer of us or any of our assets may continue to use your Personal Information as set forth in this policy.

Information Disclosed for Our Protection and the Protection of Others

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof or thereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Information We Share With Your Consent

If we plan on sharing your Personal Information with third parties in a manner different than that set forth above, you will be notified and will be able to prevent such sharing of your Personal Information.

Is Information About Me Secure?

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Information by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.

We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

We otherwise store all of our information, including your IP address information, using industry- standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Information or otherwise.

In the event your Account and/or Personal Information is compromised, we will notify you promptly.

What Information of Mine Can I Access?

If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.

California Privacy Rights

This section of our Privacy Policy applies solely to visitors and users who reside in the State of California.

California Shine the Light Law

California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about Personal Information we disclosed to third parties for direct marketing purposes in the preceding calendar year. If you are a California resident and would like a copy of this notice, please send an e-mail to hello@wearerobyn.co or write to us at 145 S. Fairfax Ave, Suites 200 & 300, Los Angeles, CA 90036. Not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response. Under California law, businesses are only required to respond to a request once during any calendar year.

California Consumer Privacy Act (CCPA)

The CCPA provides California residents with specific rights regarding their Personal Information. This section of our Privacy Policy describes those CCPA rights and explains how to exercise those rights. The categories of Personal Information that we collect from you can be found in the “What Information Do We Collect” section above, which you can access by clicking here.

The business or commercial purposes for which we use the categories of Personal Information we collect can be found in the “How We May Use or Disclose Your Information” section above, which you can access by clicking here.

Your California Rights under CCPA

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (“Right to Know”). You have the Right to Know (i) the categories of Personal Information we collected about you; (ii) the categories of sources for the Personal Information we collected about you; (iii) our business or commercial purpose for collecting that Personal Information; (iv) the categories of third parties with whom we share that Personal Information; (v) the specific pieces of Personal Information we collected about you.

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (“Right to Delete”). Once we receive and confirm your verifiable request, we will delete your Personal Information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us to: (i) complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another party to exercise their free speech rights, or exercise another right provided for by law; (v) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (vi) comply with a legal obligation; or (vii) make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Your Rights

To exercise your Right to Know or Right to Delete, please submit a verifiable request to us by sending an email to hello@wearerobyn.co.

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your Personal Information. The verifiable request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We may need to contact you to request additional information in order to verify you are the person about whom we collected Personal Information or that you are an authorized representative. We will not use any information provided as part of a request, including any contact information you provide or that we request in order to respond to or verify a request, for any purpose other than to respond to or verify your request.

We will make an effort to respond to your verifiable request within 45 days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing either by mail or electronically, at your option. Any disclosures we provide will only cover the 12-month period before our receipt of the verifiable request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights by (i) denying you goods or services; (ii) charging you a different price or rates for goods or services; or (iii) providing you a different level of quality of goods or service.

For additional information regarding your rights under the CCPA, or how to exercise them, you may contact us at hello@wearerobyn.co.

How Can I Delete My Account?

Should you ever decide to delete your Account, you may do so by emailing hello@wearerobyn.co. Please note that we will need to verify that you have the authority to delete the Account. If you terminate your Account, any association between your Account and information we store will no longer be accessible to you through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and will remain accessible to the public.

What Choices Do I Have Regarding My Information?

You can use many of the features of the Services without registering, thereby limiting the type of information that we collect. You can always opt not to disclose certain information to us, even though it may be needed to take advantage of some of our features.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is used or collected. If we make changes in the way we collect or use information that, in our sole discretion, is material, we will notify you by posting an announcement on the Services or sending you an email. By continuing to access or use the Services after those changes become effective, you agree to be bound by any changes to the Privacy Policy.

Data Security

We take reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. Nevertheless, transmission via the internet is not completely secure and we cannot guarantee the security of your information collected through our Service.

International Transfer

We are based in the U.S. and the information we and our service providers and Agents collect is governed by U.S. law. If you are accessing the Service from outside of the U.S., please be aware that information collected through the Service may be transferred to, processed, stored and used in the U.S. Data protection laws in the U.S. may be different from those of your country of residence. Your use of the Service or provision of any information to us therefore constitutes your consent to the transfer to and from, processing, usage, sharing and storage of your information, including Personal Information, in the U.S. as set forth in this Privacy Policy.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to hello@wearerobyn.co.

This Privacy Policy was last updated on March 6, 2020.

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