Privacy

Website Privacy Statement
US: Medical P.C. Privacy StatementUS: HIPAA Notice of Privacy PracticesInternational: Coaching Privacy StatementPrivacy Notice for California ResidentsCookie Statement

Ginger Privacy Statement

Effective Date: September 1, 2022 

INTRODUCTION

This Privacy Statement describes the practices and policies of Ginger.io Inc., Ginger.io Medical P.C. and affiliated Ginger.io medical providers (together "Ginger”) regarding the collection, use, storage, and disclosure of personally identifiable information (“Personal Information”) we collect from our website (www.ginger.io) (the “Website”), mobile application and web-based application (the “App”), and related services (collectively, the "Services” or "Service")

You may have been invited to use, download or install the Service by your Employer, institution, health plan or healthcare provider. To receive Services you must download and install the Ginger App.

BY ACCESSING OR USING THE SERVICES, YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTAND, AND AGREE TO BE BOUND BY THIS PRIVACY POLICY AND OUR TERMS OF USE AND CONSENT TO THE COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL INFORMATION AS SET OUT IN THIS PRIVACY STATEMENT.

WHAT INFORMATION DO WE COLLECT?

We may collect the following types of Personal Information in connection with our delivery of Services to you:

  • When you register to receive services from us, whether in your individual capacity or on behalf of an organization, we collect any Personal Information that you submit through our registration form, including your name, email address, mailing address, phone number, payment card information, and any other Personal Information you voluntarily submit through the online registration form (your “Account Data”).
  • When we deliver Services to you, we collect Personal Information and health information that you voluntarily provide to us, our coaches and clinicians, including information about your personal goals and health circumstances (your “Care Data”). 
  • When you use our Services we automatically collect information about your web browser, mobile device, and how and when you use our App, including the manufacturer and model of the device, unique device identifiers, and IP address (“Mobile Data”).
  • We collect usage information about our Website and Services and use visitor logs to compile anonymous aggregate statistics, (e.g., information such as your web requests, browser type, browser language, domain names, referring and exit pages and URLs, platform type, pages viewed and the paths you took on our Site, and IP Addresses) (“Usage Data”)
  • When you use the Services to respond to our surveys and health questionnaires, we may collect the information you voluntarily provide in your responses as well inferred health status for specific conditions and survey alerts (your “Survey Data”).

We may also collect Personal Information that you voluntarily provide to us when you contact us with a question or comment about our Services.

HOW DO WE USE INFORMATION WE COLLECT?

PERSONAL INFORMATION

We will use and store Personal Information to provide and optimize the Service and App.

In particular we use:

  • Account Data to manage your account, communicate with you in relation to your account, process your transactions, and deliver and monitor the performance of our services;
  • Care Data to help you, your coach, clinician, or healthcare provider understand your personal objectives and circumstances, help you develop and execute strategies to overcome your challenges and achieve your goals, deliver appropriate care, evaluate the quality and progress of our program, and optimize delivery of services;
  • Mobile Data to monitor and enhance the performance of the App, analyze trends, usage and activities in connection with the App, and ensure its technological compatibility with users;
  • Usage Data to analyze trends, administer our services, improve the design of our App and Website, and otherwise enhance the services we provide.
  • Survey Data and reports to our coaches, clinicians, and authorized providers to better understand your health status, provide feedback, and to provide proactive alerts. 

To allow for additional research, product development, and insights over time, Ginger may anonymize or de-identify your Personal Information and health information in a manner that meets the Health Insurance Portability and Accountability Act of 1996 (HIPAA) de-identification standard, such that such data is no longer reasonably identifiable.

AGGREGATE INFORMATION

We create statistical, aggregated data relating to our users and the Service for analytical purposes. Aggregated data includes data derived from Personal Information and obtained by Ginger from other sources in aggregated, anonymous form.  Aggregate Information cannot reasonably be used to identify any individual. We use Aggregate Information to understand our customer base, market our Services, and improve and enhance our site and services.

EMAIL AND OTHER COMMUNICATIONS

We may use your personal information to contact you regarding an inquiry or to provide you with more information about Ginger, Ginger Services or other related information we believe you may be interested in. We will send you email alerts or notification messages unless you unsubscribe.

If you wish to opt out of these emails, you may do so by following the "unsubscribe" instructions in the email; provided however, Ginger may maintain the right to send you important emails about your account or the Services.

Email and text messaging allows healthcare providers to exchange information efficiently for the benefit of users/patients. We recognize that email and text messaging may not be a completely secure means of communication. Your use of the Service means that you agree and consent to the use of email and/or text messaging as an acceptable form of communication.

FEEDBACK AND USER TESTIMONIALS

We may also use the Personal Information you provide us to respond to your comments and questions.

We value your feedback on, and appreciate any testimonials about, our Services. If you send us any such feedback or testimonials, they shall be deemed, and shall remain, the property of Ginger and shall be subject to any obligation of confidence on our part. Prior written approval of any usage of your identity or contact information shall be obtained, if Ginger wishes to reference you in connection with that feedback or testimonial.

LEGAL EXCEPTIONS

Under certain circumstances, Personal Information may be subject to disclosure pursuant to judicial or other government subpoenas, warrants, or orders. As such, notwithstanding the above, we may in any event use Personal Information to the extent required or permitted by applicable law to resolve disputes, to enforce our agreements (including the Terms of Service) with you, or as reasonably necessary to protect our legal rights, to protect you against self-harm, or to protect third parties.

WHAT INFORMATION DO WE DISCLOSE TO THIRD PARTIES?

We will not sell or rent your personal information to any other company or organization.  We may disclose your Personal Information as follows:

  • To a provider or health plan on whose behalf the information was collected for the purpose of providing services to you.
  • To emergency services and other agencies to protect you, the clinician, the coach, or others from harm.
  • To third parties engaged to provide services on our behalf such as managing our accounts, processing transactions, operating the App, or providing customer service. We enter into agreements which require such providers to protect such information and use the Personal Information they receive only to perform services for us.
  • As described in our Notice of Privacy Practices or, if applicable, your health plan’s Notice of Privacy Practices for protected health information.
  • To obtain and process payment for our services
  • To law enforcement, judicial authority, or governmental or regulatory authority, to the extent required by law or if in our reasonable discretion disclosure is necessary to enforce or protect our legal rights, to protect you, or to protect third parties.
  • In the event of a reorganization, merger, acquisition, asset sale or similar transaction, we may transfer any and all Personal Information we collect to the relevant third party involved in the transaction, with your consent if and as required under applicable privacy laws.

We may otherwise disclose your Personal Information only when we have your prior consent to share the information.

ACCESSING AND UPDATING YOUR INFORMATION  

You have the right to review, amend, or correct your Account Data or other Personal Information held in our database. 

Subject to certain exceptions, you have the following rights:

  • to request a copy of your Personal Information
  • to have us correct or amend any inaccurate Personal Information 
  • to request that we erase Personal Information that we process about you
  • to request that we restrict our processing of your Personal Information 
  • to object to the processing of your Personal Information
  • to send us a complaint regarding our handling of your Personal information.

To exercise these rights please contact us by sending an email to privacy@ginger.io with a clear description of your request. We will respond to try to comply with your request as soon as reasonably practicable and always under the timeframes set forth by applicable laws.

RETENTION OF YOUR DATA

We store your Account Data and Personal Information for as long as we need it to provide you our services, to serve the purpose(s) for which your personal information was processed, or as necessary to comply with our contractual and legal obligations, resolve disputes, or enforce our agreements to the extent permitted by law.

If you would like your Account Data or other Personal Information permanently removed from our database, please contact us at privacy@ginger.io. We will then terminate your account, you will no longer be able to use our services, and you will no longer receive emails from Ginger.  Subject to applicable law and necessary record retention requirements, your identifying Personal Information shall be deleted from our records. Please note that we may need to retain certain information to meet legal or contractual requirements, for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or authorized by law. 

INFORMATION SECURITY

We have implemented technical and organizational security measures to protect the security and integrity of your Personal Information in accordance with this Privacy Statement and applicable law.  Such measures include restricting access to Personal Data on a “need-to-know” basis and an Information Security Management System (ISMS) aligned with ISO 27001 and 27002, We secure information using industry standard administrative, physical, and technical safeguards including encryption of information that is stored and transmitted

While we endeavor to always protect our systems, sites, operations and information against unauthorized access, use, modification and disclosure, it is important for you to know that, despite using these current industry-recommended practices, we cannot guarantee against breaches in security..   

You have an important role in protecting Personal Information.  You are responsible for maintaining the security of your login ID, password, and mobile device. If you believe that your login ID, password, or mobile device may have been compromised, you should immediately change your password and contact our support services. We are not responsible if someone else accesses your account through registration information they have obtained from you or through a violation by you of the Terms of Service.

LINKS

The Ginger Services may contain links to other websites. Ginger is not responsible for the privacy practices or the content of those websites. Users should be aware of this when they leave our Service and are encouraged to review the privacy statements of each third party website. This Privacy Policy applies solely to information collected by Ginger.

USE OF COOKIES / WEB BEACONS

We may use cookies, both session and persistent cookies, or web beacons on certain webpages and/or html email correspondence to anonymously track visitors, save website preferences or allow us to recognize visits from the same computer and browser. You have the option to disable cookies in your browser and still use our services, although it may limit your access to the services.

CHILDREN

Ginger does not knowingly collect or maintain personally identifiable information from persons under 13 years of age. Individuals under the age of 18 must receive consent from their parent or guardian in order to access Ginger Services.

CHANGES

We may modify or amend this Privacy Statement from time to time. If we make any material changes in the way in which Personal Information is collected, used or transferred, this Privacy Statement will be revised to reflect such changes.  We will post the updated Privacy Statement and ask for your consent if legally required.  The effective date appears at the top of this Privacy Statement. 

QUESTIONS

To submit a question or concern, please contact us at privacy@ginger.io or write to us at the following address: Ginger.io, Inc. attn: Privacy 2415 Michigan Avenue, Santa Monica, CA 90404. 

VISITORS FROM OUTSIDE THE UNITED STATES

Ginger and its servers are located in the United States and are subject to the applicable state and federal laws of the United States. If you choose to access or use the Service, you consent to the use and disclosure of information in accordance with this Privacy Policy and subject to such laws.