What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” or “sensitive personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

Personal Data

Categories of Personal Data We Collect

This chart details the categories of Personal Data that we collect and have collected over the past 12 months:

Category of Personal Data (and Examples)

Profile or Contact Data such as first and last name, email, phone number, and zip code.

Providing, Customizing and Improving the Services
Marketing the Services
Corresponding with You

Advertising Partners
Business Partners
Parties You Authorize, Access or
Authenticate

Device/IP Data such as IP address, device ID, and type of device/ operating system/ browser used to access the Services.

Providing, Customizing and Improving the Services

Service Providers

Web Analytics such as web page interactions.

Providing, Customizing and Improving the Services

Analytics Partners

Consumer Demographic Data such as age and/or date of birth, zip code, gender, race, and ethnicity.

Providing, Customizing and Improving the Services
Marketing the Services

Advertising Partners
Analytics Partners
Business Partners

Health Data such as medical conditions, weight, health or exercise activity monitoring, or any information concerning a consumer’s health, including information about a mental or physical health condition or diagnosis.

Providing, Customizing and Improving the Services
Marketing the Services

Advertising Partners
Analytics Partners
Business Partners
Parties You Authorize, Access or Authenticate

Categories of Data Considered “Sensitive” Under the State Privacy Laws (as defined below) such as:

Race or ethnic origin;
Health Data

Providing, Customizing and Improving the Services
Corresponding with You.

Advertising Partners
Analytics Partners
Business Partners

Inferences Drawn From Other Personal Data Collected such as user attributes.

Providing, Customizing and Improving the Services
Corresponding with You.

Advertising Partners
Analytics Partners
Business Partners

Other Identifying Information that You Voluntarily Choose to Provide such as emails, letters, texts, or other communications you send us

Providing, Customizing and Improving the Services
Corresponding with You.

Service Providers
Parties You Authorize, Access or Authenticate

Our Commercial or Business Purposes for Collecting Personal Data

1. Providing, Customizing and Improving the Services

Creating and managing your account or other user profiles.
Providing you with the products, services or information you request.
Meeting or fulfilling the reason you provided the information to us.
Providing support and assistance for the Services.
Improving the Services, including testing, research, internal analytics and product development.
Personalizing the Services, website content and communications based on your preferences.

2. Marketing the Services

Marketing and selling the Services.

3. Corresponding with You

Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about Zeteo or the Services.
Sending emails and other communications according to your preferences.

Other Permitted Purposes for Processing Personal Data

In addition, each of the above referenced categories of Personal Data may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, Zeteo or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice or obtaining your consent.

Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

1. You

When you provide such information directly to us.

When you create an account or use our interactive tools and Services.
When you voluntarily provide information in free-form text boxes through the
Services or through responses to surveys or questionnaires.
When you send us an email or otherwise contact us.

When you use the Services and such information is collected automatically

If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.

2. Third Parties

Third Parties and Business Partners

We may receive information about you from claims administrators.
We may receive information about you from eligible member lists.

How We Disclose Your Personal Data

We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

Service Providers.

These parties help us provide the Services or perform business functions on our behalf. They include:

Hosting, technology and communication providers.

Analytics Partners.

These parties provide analytics on web traffic or usage of the Services. They include:

Companies that track how users found or were referred to the Services.
Companies that track how users interact with the Services

Business Partners

These parties partner with us in offering various services. They include:

Businesses that you have a relationship with, such as health insurance providers, health systems and health providers who purchase access to Zeteo.

Business Partners

Third parties you access through the services.

[fs-toc-omit]Legal Obligations

We may disclose any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Other Permitted Purposes for Processing Personal Data” section above.

[fs-toc-omit]Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). 

[fs-toc-omit]Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and disclose it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not disclose such data in a manner that could identify you.

Tracking Tools, Advertising, and Opt-Out

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

Please note that because of our use of Cookies, the Services do not support “Do Not Track” requests sent from a browser at this time.

We use the following types of Cookies:

Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records,please be aware that no method of transmitting data over the internet or storing data is completely secure.

[fs-toc-omit]Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

Personal Data of Children

As noted in the Terms of Use, we do not knowingly collect or solicit Personal Data from children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at admin@zeteo.health.

Other State Law Privacy Rights

California Resident Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at admin@zeteo.health.
Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com.

Nevada Resident Rights

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through Zeteo and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to Zeteo in the U.S. and will be hosted on U.S. servers, and you authorize Zeteo to transfer, store and process your information to and in the U.S., and possibly other countries. In some circumstances, your Personal Data may be transferred to the U.S. pursuant to a data processing agreement incorporating standard data protection clauses[ and/or the Data Privacy Framework(s), as discussed below].

Contact

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at: