Last Modified: February 6, 2017
1.4. Third Party Links. The Service contains third party links to other websites or services. Please be aware that we are not responsible for the content or privacy practices of such other third party websites or services. We encourage our users to be aware when they leave the Service and to read the privacy statements of any other site that collects personal information.
2. Information Collection
2.1. Information You Provide. We may collect information that identifies you (“Personal Information”) when you use the Service or register for an account. The types of Personal Information that we may collect include:
(a) Information that you provide to us when you register for an account;
(b) Information that you provide to us when you purchase a product or service, including, without limitation, payment card and billing information;
(c) Information that you provide to us and/or our third party service providers when you purchase a mobile application or in-app purchases, products or services, such as payment card and billing information;
(d) Information that you provide to us, such as your name, location, address, phone number, and email address;
(e) Information that you provide to us if you participate in a sweepstakes, contest, rewards program, or other promotion;
(f) Information that you provide if you use the Service to upload, share, or communicate any content or information, including photos, images, videos, text, social network accounts, or other Personal Information that you may include about yourself or others;
(g) Information that you publicly post via links to social media networks, forums, blogs, message boards, chat rooms or similar functionality is public information that we, or others, may share or use in accordance with the law;
(h) Information that you provide if you email, phone, contact or communicate with us or our third party service providers for customer support or other communications.
2.2. Information We Collect.
(a) Traffic and usage information generated from your visit to the Service, including traffic data, pages you visit, browser information, operating system, IP address, cookie information, and the type of device that you use to access the Service;
(c) Information from public databases and third parties;
(d) When you access or use the Service, or any portion thereof, we may collect physical location information that is sufficiently precise to allow us to locate a specific person or device (“Location Information”). We only collect Location Information with your permission (e.g., such as when you agree to provide it to us after you initially access or use the Service). We may use Location Information and provide it to third parties to provide you with content and services that are relevant to a particular location, such as advertising, search results, and directions.
3. Tracking Technologies We Use
We may use one or more of the following tracking technologies, and similar future tracking technologies, to automatically collect information: cookies, local shared objects, web beacons, unique telephone numbers, general log information and referral information from third-party services.
3.2. “Web beacons,” also known as an Internet tags, pixel tags or clear GIFs, link web pages to web servers and their cookies. Web beacons can be embedded in web pages, videos, or emails, to collect certain types of information from your browser, check whether you have viewed a particular web page or email message, and determine, among other things, the time and date on which you viewed the content, the IP address of your computer, and the URL of the web page from which the content was viewed.
3.3. “Local shared objects,” sometimes known as Flash cookies, may be used to store your preferences or display content based upon what you have viewed on various websites to personalize your visit.
3.4. “Ad IDs” and Other In-App Tracking Methods. There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activity to a particular app.
4. How We Use Information
We may use the information that we collect for any of the following purposes:
4.1. To provide, operate, maintain, improve, and promote the Service;
4.2. To enable you to access and use the Service, including uploading, downloading, collaborating and sharing content, photos, images, videos and information, with other users or third parties;
4.3. To process and complete transactions, and send you related information, including purchase confirmations and invoices;
4.4. To send transactional messages, including responding to your comments, questions, and requests; providing customer service and support; and sending you technical notices, updates, security alerts, and support and administrative messages;
4.5. To send promotional communications, such as providing you with information about services, features, newsletters, offers, promotions, contests, events and sending updates;
4.6. To monitor and analyze trends, usage, and activities in connection with the Service and for marketing, advertising, administrative, analytical, research, optimization, and other purposes. For example, we may use statistical analyses of usage data in order to measure interest in the various areas of the Service, for development purposes and to inform advertisers and partners in aggregate and anonymous terms about consumers who click on their advertising or other messages. IP addresses are also used for systems administration and troubleshooting purposes.
4.7. To investigate and prevent fraudulent transactions, unauthorized access to the Service, and other illegal activities;
4.8. To personalize the Service’s content, features or advertisements;
4.9. By using the Service, you consent to and authorize Meru Health to disclose your eligibility for and participation in the Service (i.e., you meet the clinical enrollment criteria for the Service which identifies those individuals at risk for certain mental health problems and have elected at your own discretion to participate in the program) to the other users of the Service. The users, including but not limited to Service administrators, therapists, and your fellow support group members will have access to a range of Personal Information such as your name and picture, linking you to your diagnosis and reason for program participation. Specifically, as we group participants based on certain characteristics, fellow support group members may be co-workers or other acquaintances.
We take great efforts in protecting your privacy, however, we cannot control, and expressly disclaim any responsibility for, whether or how users will subsequently use or disclose posted or previously disclosed information. If you do not consent to the disclosure of this information, you should not access or use the Service. The Service includes the ability for users to share Personal Information (such as Forums, discussion boards, chat rooms, groups, social media networks and such), including information regarding your medical condition. Any information you choose to provide or upload to the group Service, including Personal Information about your medical condition, will be visible to your group, as well as therapists, Service administrators, and other Service users. As your information will be viewable to the other users of the Service, you should provide only the information you feel comfortable disclosing. This means that if you choose to participate in a group Service, your identity and/or medical condition is no longer confidential to the Service and they might be further distributed publicly by others in the group Service. There may be an opportunity to speak on the phone or via video chat in a group conference call. Participation in such opportunities is not mandatory, but should you choose to participate, you should share only as much information as you feel comfortable sharing in these additional forums.
5. Information Sharing
5.3. Payment Processors. We share your payment information with payment services providers to:
(a) Process payments;
(b) Prevent, detect and investigate fraud or other prohibited activities;
(c) Facilitate dispute resolution such as chargebacks or refunds;
(d) For other purposes associated with the acceptance of credit or debit cards. We may share your credit or debit card number with payment services providers or card networks to monitor card transactions at participating merchants and track redemption activity for the purposes of providing card-linked services.
5.4. Authorized Personnel. Our employees, agents, consultants, contractors, or other authorized personnel, may have access to user information as necessary in the normal course of our business.
5.5. Business Transfers. In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the business assets that is transferred and you consent to the transfer of your user information in such cases. Moreover, if the Service or Meru Health, or substantially all of its assets, were acquired, merged with another company, liquidated, or dissolved, user information would be one of the assets that is transferred and you consent to the transfer of your user information in such cases.
5.6. Government, Law Enforcement or Third Parties. We may disclose any information, including, without limitation, Personal Information that we deem necessary, in our sole discretion and without your prior permission, to comply with any applicable law, regulation, legal process or governmental request. We also may exchange information, including, without limitation, Personal Information, with other companies and organizations to protect the rights, property, or safety of Meru Health and its affiliates, personnel, users, third parties, or others. We reserve the right to disclose a user’s Personal Information if we believe, in good faith, that the user is in violation of the Terms of Service, even without a subpoena, warrant or other court order.
5.8. Push Notifications. We may occasionally send you push notifications through our mobile applications to send you updates and other Service related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings.
5.9. Forums. We may make available your Personal Information through the Service (for example, discussion boards, chat rooms, profile pages, bulletin boards, blogs, instant messaging, activities, polls, games and other communication forums) (each, a “Forum”) to which you post information and materials. Some of these Forums are described more specifically below. Please note that any information, text, and images posted or disclosed by the user on or through such Forums may be visible to the user’s group(s), as well as therapists, Service administrators, visitors to the Service, and other users of the Service. Specifically, Personal Information such as the picture you’ve uploaded and your screen name, may be available for other users to view when you make a posting to such Forums. Information regarding your activities in such services may also be available for view by other users (for example, other users may be able to view a list of all experiences/reflections you have made in all available Forums). Any postings you have made to a Forum may also be available for view later by users of the Service by scrolling to older posts on the Forum. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, such as your illness, or any other information, through a Forum or otherwise through the Service.
5.10. Discussion Boards and Chat Rooms. We may provide functionality to post on our discussion boards, and permit you to enter into chat rooms and communicate with other users in the chat rooms. Please note that if you use such functionalities to communicate, your name / screen name will be disclosed to all visitors to the discussion boards, present and future, as well as all users in the chat room at that time. Please remember that information posted to discussion boards becomes public information. Use caution when posting. Further, if a comment you make on the discussion board or in the chat room contains Personal Information, we cannot control how the Personal Information will be used or disclosed by the other users of the discussion board or chat room. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, in any comment and/or message, and to be careful about the people to whom you send such comments and/or messages.
5.11. Messaging Services. We may provide functionality to permit you to send messages, including instant messages, to other users through the Service. Please note that if you use such functionality to send such a message to another user, your screen name will be disclosed to that user, as well as Service administrators. Further, if a message you send using such functionality contains Personal Information, we cannot control how the Personal Information will be used or disclosed by the recipient of your message. We urge you to exercise discretion and caution when deciding to disclose your Personal Information, or any other information, in any message, and to be careful about the people to whom you send such messages.
IN THE CASE OF YOUR USE OF FORUMS, DISCUSSION BOARDS, CHAT ROOMS AND MESSAGING SERVICES, AS DESCRIBED ABOVE, WE ARE NOT RESPONSIBLE FOR THE USE BY OTHERS OF ANY INFORMATION, INCLUDING PERSONAL INFORMATION, THAT IS DISCLOSED BY YOU OR ON YOUR BEHALF BY YOUR SYSTEM IN SUCH FORUMS, DISCUSSION BOARDS, CHAT ROOMS AND MESSAGING SERVICES. BY DISCLOSING ANY OF YOUR INFORMATION VIA FORUMS, DISCUSSION BOARDS, CHAT ROOMS AND MESSAGING SERVICES, YOU ACKNOWLEDGE AND ACCEPT ANY RISK AND DAMAGE ARISING FROM DISCLOSURE OF SUCH INFORMATION.
5.12. User Profiles. We may provide functionality to permit you to create a user profile page (“User Profile”) in which you may provide information about yourself, including, without limitation, your illness, symptoms, treatments, as well as your feelings about your illness and/or yourself (“User Submissions”). You may also be able to upload pictures, videos and stories to your profile page as part of the User Submissions. User Submissions may be displayed to other users (including members of your group(s), who may be from the same deployment or otherwise affiliated) to facilitate user interaction within the Service. Email addresses are used to add new User Submissions to user profiles and to communicate through User Submissions. Users’ email addresses will not be directly revealed to other users by us, except when the user is “connected” to another user via a shared group membership, or an invitation, or if the user has chosen to include their email address in their User Profile. Please note that any User Submissions you make, including Personal Information, on or through your User Profile may be available for other users, Meru Health, administration, moderators, and other staff. Additionally, other users may be able to post comments and view posted comments on your User Profile.
6. Choice and Opt-Out
We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information.
6.1. Choice. In accordance with local law, your controls and choices may include:
(a) You may correct, update and delete your account information, as described below;
(b) You may change your choices for subscriptions and newsletters;
(c) You may choose whether or not to receive offers from us;
(d) You may choose whether you received targeted advertising from us or our partners.
6.2. Opt-out. We may also use tracking technologies to collect information about your visits over time and across third-party services or other online services. The Network Advertising Initiative (the “NAI”) is a cooperative group of ad serving providers. The NAI has developed a set of privacy principles to which its members adhere. The NAI is committed to providing consumers with clear explanations of Internet advertising practices and how they affect you and the Internet generally. For more information about the NAI, third party ad servers generally and the opt-out options offered through the NAI, visit http://www.networkadvertising.org/index.asp.
6.3. Accessing and Correcting Your Information. If you have an account, you can help ensure that your contact information and preferences are accurate, complete, and up to date by logging in to your account or by emailing us at email@example.com. For other personal information we hold, we will provide you with access for any purpose including requesting that we correct the data if it is inaccurate or delete the data if we are not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.
7. Security of Your Information
7.1. Security Measures. We have put in place physical, electronic, and managerial procedures designed to help prevent unauthorized access, to maintain data security, and to use correctly the information we collect online. These safeguards vary based on the sensitivity of the information that we collect and store.
8. Children Under The Age of 13. We do not collect or solicit any information from anyone under the age of 13 or allow people under the age of 13 to register for the Service. The Service and its content are not directed at children under the age of 13. In the event that we learn that we have collected personal information from a child under age 13 without parental consent, we will delete that information as quickly as possible. If you believe that we might have any information from or about a child under 13, please contact us at firstname.lastname@example.org.
9. California Privacy Rights and Do Not Track Disclosures. If you are a California resident, you may have certain additional rights.
9.1. Privacy Rights. California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by us to third parties for the third parties’ direct marketing purposes. California Business and Professions Code Section 22581 permits registered users who are minors to request and obtain deletion of certain posted content. To make any such requests, please email us at email@example.com or contact us at the address below.
9.2. Do Not Track Disclosures. California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how we respond to “Do Not Track” browser settings. We do not currently take action to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
10. Users From Other Jurisdictions
11. Contact Information
Meru Health, Inc. | 470 Ramona St. | Palo Alto, CA 94301