- What personally identifiable information Prananaz, or a third party acting on Prananaz’s behalf, collects through our Site and how we use it;
- To whom Prananaz may disclose this information;
- Choices available to you with respect to collection, use and distribution of your information;
- Security procedures in place to protect the confidentiality, availability, and integrity of your information; and
- How to request access to, or correct inaccuracies of, your information.
Important Information about Our Privacy Practices
Personally Identifiable Information (“Personal Information”)
Personally Identifiable Information (or “Personal Information”) is information that we collect about you that can be used to identify or contact you, as well as other personal data.
In the United States, some of the Personal Information provided by you or collected by us through this Site may be health information. Although Prananaz is not a “covered entity” under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), Prananaz is subject to some aspects of HIPAA when Prananaz performs services on behalf of covered entities, including health plans sponsored by employers for their employees (“Corporate Customers”). Prananaz will comply with applicable HIPAA requirements under those circumstances.
Information Collection and Use
- Automatically Collected Information
We collect information about devices you use to access the Site (such as domain name and IP address) from all visitors to the Site (“Automatically Collected Information”). We use this information internally to help us improve your experience on the Site, including to create your profile and profiles of our users generally as well as to record internet protocol (IP) addresses, browser types, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks. We use the profiles and records to analyze trends, administer the Site, track movements in the aggregate, and gather broad aggregate demographic information.
For example, Prananaz uses “cookies” and “web beacons” to collect information about your use of our Site and emails we may send you. Cookies are small computer files that we transfer to your computer’s hard drive that allow us to know how often you visit the Site and what activities you conduct on the Site. Internet browser software generally can be set to reject all cookies, and most browsers offer instructions on how to reset the browser to reject cookies. If you reject our cookie, certain functions and conveniences we automatically provide for you on our Site may not work, but you do not have to accept our cookie to use our Site. Similarly, web beacons are tiny graphic image files embedded in a web page or email that send information from your browser back to Prananaz’s, or its service provider’s, server. We use the information cookies and web beacons collect to statistically monitor how many people are using our Site or opening our emails.
Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information. To completely “opt out” of the collection of any information through cookies or other tracking technology, you must manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult. For example, not all tracking technologies can be controlled by browsers, and unique aspects of your browser might be recognizable even if you disable a tracking technology. In addition, not all settings will necessarily last or be effective, and even if a setting is effective for one purpose, data still may be collected for another. Even if one website observes a “Do Not Track” signal, that website usually will not be able to control other websites.
We do not link Automatically Collected Information to the health and other information you voluntarily provide to us through use of the Site.
- Subscription and Account Profiles
You may also voluntarily submit additional Personal Information, for example your address, interests or photo, in order to enhance your profile on the Site. Submission of this Personal Information is strictly voluntary. Do not post information in public areas of the Site if you do not want the information to be shared with others.
- Prananaz Resource Tools
You may voluntarily provide other information to Prananaz, some of which may be Personal Information, when you register for and use some of the Prananaz resource tools, such as wellness assessments and goal tracking, or when you respond to our surveys and questionnaires. This information may include, but is not limited to, specific information regarding medical conditions, health, lifestyle, diet, exercise habits, drug and alcohol usage, workplace matters and other relevant Personal Information relating to your wellness.
- Community Forums and Activity Feeds
Personal Information of Children Under 13
This Site is not directed to children, and we do not knowingly collect any Personal Information from children under 13 years of age through this Site. If you think we have collected Personal Information from a child under 13 years of age for whom you are the parent or guardian, please contact us at the notice address provided below.
Disclosure of Your Personal Information to Third Parties
Unless we receive your permission, Prananaz will not sell, rent, or share your Personal Information to or with any third party not affiliated with or owned by Prananaz, with the following exceptions:
- Third Party Wellness Providers: Prananaz may disclose your relevant Personal Information to third parties who we have engaged on your behalf to provide disease management, health management, behavioral coaching, or similar wellness-related services (“Third Party Wellness Providers”) and who may contact you to offer their services in support of your health and well-being management goals. Prananaz and the Third Party Wellness Providers, as well as other Prananaz business partners, may also share your Personal Information to administer activities and challenges you select (“Partner Challenges”) and to award you with incentives and other rewards you earn through participation in Partner Challenges. Prananaz contractually obligates Third Party Wellness Providers, and other Prananaz business partners, to safeguard your Personal Information in substantially the same manner that Prananaz safeguards it. If you accept the services offered by a Third Party Wellness Provider, or decide to participate in a Partner Challenge, such agreement is solely between you and the Third Party Wellness Provider or applicable Prananaz business partner because they are separate and distinct entities from Prananaz. Prananaz is not responsible for the privacy practices or services of the Third Party Wellness Providers or other Prananaz business partners.
- Provision of Services: Prananaz may disclose your Personal Information to third parties that enable us to provide you with a product or service that you have requested from us. We will disclose Personal information to these third parties as necessary to enable them to provide the product or service, subject to contractual restrictions and conditions between Prananaz and the third parties that obligate them to safeguard the Personal Information.
- Participation, Incentives and Rewards: Prananaz may disclose your Personal Information to your health plan, which may be administered by your employer, in order for your employer or health plan to provide you or your spouse/same-sex domestic partner with incentives and rewards for participation in the Prananaz service. We will limit the amount of Personal Information we share to the minimum necessary for you to receive the incentives and rewards.
- HIPAA Covered Entities: Prananaz may disclose your Personal Information to entities subject to HIPAA (called “covered entities”) in certain instances. Covered entities include, for example, health care providers such as doctors and dentists. Covered entities also include health plans, such as group health plans sponsored by your employer and which may be administered by other employees of your employer. HIPAA and other laws prohibit these employees from further disclosing your Personal Information to the employer-sponsors or others for reasons other than administering the group health plan or as otherwise permitted by law.
- Aggregate Information: Prananaz may provide to third parties, including to our corporate customers who sponsor group health plans for their employees, with information about you and other users from which we have removed all identifiers and that can no longer be used to identify you (“Aggregate Information”). For example, we might inform third parties regarding the number of users of our Site and the services they used while on our Site. We may not limit the third parties’ use of the Aggregate Information, except that we do require third parties to whom we disclose Aggregate Information to agree that they will not attempt to make this information personally identifiable by combining it with other databases.
- Disclosure of Automatically Collected Information: Prananaz may provide to third parties, including to our corporate customers, Automatically Collected Information that is combined with the Automatically Collected Information of other users or Aggregate Information.
Additional Uses of Your Personal Information
- Administrative Notices: Prananaz reserves the right to send you specific administrative notices about your registration or subscription or to contact you if required by law. You may not opt-out of these kinds of communications.
- Emails and Newsletters: During program registration and at various times as you use the Site, you may have the option of receiving emails or newsletters directly from Prananaz. You may elect to opt-out of these communications by placing a check mark beside a statement stating you do not want to receive these communications or to participate in these activities.
Prananaz maintains administrative, physical, and technical safeguards to reasonably and appropriately protect the confidentiality, availability, and integrity of your Personal Information. Our employees receive training on our security practices and obligations. While we encrypt sensitive data, such as Personal Information, using SSL or VPN when it is transmitted over the Internet and when it is stored on our servers and backup systems, we cannot completely ensure the privacy of email communications to and from our Site because they are not encrypted.
Given the nature of the Internet and the fact that network security measures are not infallible, we cannot guarantee the security of your Personal Information. In the event we become aware of a data security breach, we will provide you with notice as required by applicable federal, provincial and state laws. To the extent permitted by applicable law, Prananaz will provide any such notice to you at the email address you provide with your registration, as updated from time to time. By using the Site, you agree to accept such notice electronically.
To the extent that you are accessing the Site through an employer or health plan portal or other third party website, we strongly encourage you to review and understand the privacy policies of such organizations prior to providing information to us or them that you consider to be sensitive or personal in nature.
When registering for access to a secure area of the Site, you will need to select a username and password. As explained above, your “username” is a unique set of characters (alphabetic, numeric, and special characters) that you choose to identify you on the Site upon registration. We encourage you to select a username that does not, by itself, identify you to others and to keep the username confidential because we use the username to make various communications to individuals participating in programs available through the Site (such as leaderboards, activity feeds and community forums). We likewise recommend you do not divulge your password to anyone so that others cannot access your Personal Information. We will never ask you for your password in an unsolicited phone call or in an unsolicited email.
You should sign out of the registered Site and close your browser window when you have finished using the Site so others cannot access your Personal Information and correspondence by using your desktop or laptop computer. If you access the Site through the use of a smartphone or other mobile device, we expect you to use the security controls available on your device (such as setting a confidential password) to prevent unauthorized individuals from accessing your information. We further recommend that you terminate each session to reduce the risk of inappropriate access. If you remain continuously logged in, you assume the risk that unauthorized individuals may be able to access your information.
You should notify us promptly if you suspect someone has obtained unauthorized access to your Personal Information.
If you have any questions about the security at our Site, you can send a message to firstname.lastname@example.org
Correcting, Updating, and Deleting Personal Information
You can self-administer key privacy settings via the Site in order to keep your Personal Information private. You can always contact us in order to request that we change or delete your Personal Information if you believe the Personal Information on the Site is incorrect. We will review your request but may be restricted in our ability to change or delete your Personal Information. If our Site was made available to you by a corporate customer that is sponsoring your usage of the Site, your eligibility to receive Incentives and Rewards from such parties, if any such benefits are offered, may be adversely affected by your election to remove your Personal Information from our service. You must contact the corporate customer directly for further information.
CALIFORNIA SHINE THE LIGHT LAW
We may provide you the ability to post information on the Site. If you are a California resident who is under 18 and a registered user of the Site and you are unable to remove content or information you posted in a public area of the Site email email@example.com. When requesting removal please be specific about the information or content you want removed and provide the URL for each page on the Site where it is located. We are not required to remove any content or information that: (a) federal or state law requires us or a third party to maintain the content or information; (b) the content or information was not posted by you, the registered user; (c) we anonymize the content or information so that you cannot be identified; (d) you don’t follow our instructions for removing or requesting removal; or (e) you received compensation or other consideration for providing the content or information. REMOVAL OF YOUR POSTED CONTENT OR INFORMATION FROM THE SITE DOES NOT ENSURE COMPLETE OR COMPREHENSIVE REMOVAL OF THAT CONTENT OR INFORMATION FROM OUR SYSTEMS OR THE SYSTEMS OF OUR SERVICE PROVIDERS. We are not required to delete the content or information posted by you; our obligations under California law are satisfied so long as we anonymize the content or information or render it invisible to other users and the public. Also, some content and information you post that has been copied or reposted by a third party is outside of our control and will not be removed.
If you are a resident of Canada, you may request access to your Personal Information in our custody or control by writing to us using the contact information in the “Contact Information” section below. We may take reasonable steps to verify your identity before providing access.
Notification of Changes
Contact Information – Questions, Accessing, Correcting and Updating your Personal Information, Direct Marketing
- Wish to make a complaint in relation to a breach of your privacy by Prananaz;
- Would like to access your Personal Information held by us;
- Would like to opt out of direct marketing; or
- Would like to correct your Personal Information held by us,
please contact us at firstname.lastname@example.org.