Privacy Policy

PRIVACY POLICY

Last Modified: 05/30/2021

At Corra Inc., a Delaware corporation (“Corra” “we” “our”) we take your privacy seriously. This Privacy Policy (“Privacy Policy”) describes how the Corra application and services (the “Application”) collects and uses information and explains how you can protect your privacy. This Privacy Policy explains:

·      How we collect and what information we use.

·      How we use and share that information.

·      How you can control the collection, use and sharing of information.

·      How to contact us if you have questions or complaints.

Information we collect. We collect information to provide the services in the Application. We may collect this information through the Application when you provide it to us and through your actions in the Application. This can include diagnosis information, symptoms, treatment information, and Application activity. In using the Application, you are free to skip any non-required questions or data fields that make you feel uncomfortable.

Information we get from your use of the Application. We may collect information about the services that you use and how you use them, like when you view and interact with our content in the Application.

Cookies. We may send cookies to your browser in order to collect data about websites visited, content viewed, searches on other websites, interaction with other websites and other click and browsing behavior. None of our cookies contain personal information and we do not collect personal information with these cookies.

Device information. To keep the services running and to improve services, we collect user activity, hardware and software information, sensor activity and cookies, and leverage other tracking technologies such as web beacons, SDKs, local storage, and log files.

Browser information. We may collect information to identify your web browser. We may collect:

  • a portion of the IP address,

  • certain HTTP header fields,

  • cached anonymous identifiers and/or

  • browser characteristics measurable through JavaScript.

IP addresses. We may collect your IP address. We also store IP addresses in server logs for anti-fraud and security reasons.

Tracking Pixels. To determine whether you have opened or clicked on a link, we may include a unique identifier in our marketing e-mails called a web beacon or pixel.

Information we get from third parties. We may collect personal information and non-personal information about you from third parties. This information may be provided to us with your consent in connection with a partner or study using our Application.

How we share information
Except as otherwise described in this Privacy Policy, we do not share personal information with companies, organizations or individuals outside of Corra unless one of the following circumstances applies:

For legal reasons. We will share personal information with companies, organizations or individuals outside of Corra if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

·      meet any applicable law, regulation, legal process or enforceable governmental request;

·      detect, prevent, or otherwise address fraud, security or technical issues; or

·      protect against harm to the rights, reputation, property or safety of Corra, our clients, our consumers or the public as required or permitted by law.

In connection with a merger or sale. If we enter into discussions to sell, merge or otherwise reorganize our business, we reserve the right to transfer and disclose all data (including personal and non-personal user information) to prospective and/or actual purchasers or investors. We will require that such purchasers/investors treat the transferred data as described in the Privacy Policy that exists prior to the change unless and until you consent to a new Privacy Policy.

We may share non-personal information (in aggregated and/or non-aggregated form) publicly and with our partners. In addition to serving the individual needs of our users, we are dedicated to better understanding patient experiences and optimizing treatment options and outcomes for everyone. To help us achieve this objective, we may anonymize your data such that it is no longer personally identifiable. This helps identify new avenues for research and help determine the success rate for patients following a particular treatment protocol. We may also provide anonymized information to others for their own uses, including medical and market research.

Information security
The privacy and security of your personal information is extremely important to us. While we are not considered a “covered entity” as defined by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), a federal law designed to protect health insurance coverage for individuals and their families, we nevertheless use the privacy and security requirements established by HIPAA as privacy and security guidelines for our use, disclosure and protection of personal information obtained through the Application.

We have security measures in place to protect against the loss, misuse, and alteration of personal information under our control. It is important that you protect and maintain the security of your account credentials and you need to immediately notify us of any unauthorized use of your account. We may use third-party products and services to secure or store your information. Note that no data transmission over the Internet can be guaranteed to be 100% secure. Consequently, we cannot ensure or warrant the security of any information you transmit to us. Please understand that any information you transfer to us is done at your own risk.

Minors and Privacy
We do not use the Application to knowingly solicit data from or market to children under the age of under the age of 16 years old. If a parent or guardian becomes aware that their child has provided us with information without their consent, they should contact us at contact@corra.app. We will delete such information from our files in accordance with applicable law.

European Privacy Rights

We respond to all requests that we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws. Rights that you may have, depending on the country in which you live, include:

  • Accessing, correcting, updating, or requesting deletion of your information.

  • Objecting to processing of your information, asking us to restrict processing of your information, or requesting the portability of your information.

  • Withdrawing your consent at any time if we have collected and processed your information with your consent. Withdrawing your consent will not affect the lawfulness of any processing that we conducted prior to your withdrawal, nor will it affect processing of your information conducted in reliance on lawful processing grounds other than consent.

  • Complaining to a data protection authority about our collection and use of your information.

Under European data protection laws, the “controller” of your information is Corra Inc. 

Your California Privacy Rights

If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Application that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to contact@corra.app.

CCPA Compliance

We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). Any terms defined in the CCPA have the same meaning when used in this section.

Our Application collects information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device ("personal information"). In particular, our Application has collected the following categories of personal information from its consumers within the last twelve (12) months: 

 

Category

Examples

Collected

A. Identifiers.

A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, telephone number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Some personal information included in this category may overlap with other categories.

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

YES

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

YES

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

YES

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

YES

G. Geolocation data.

Physical location or movements. 

YES

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

YES

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. 

NO

K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

YES

Personal information does not include:

  • Publicly available information from government records.

  • Deidentified or aggregated consumer information.

  • Information excluded from the CCPA's scope, like:

    • health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from you. For example, from forms you complete or products and services you use.

  • Indirectly from you. For example, from observing your actions on the Application.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following purposes: 

  • To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. 

  • To provide, support, personalize, and develop our Application, products, and services.

  • To create, maintain, customize, and secure your account with us.

  • To process your requests, purchases, transactions, and payments and prevent transactional fraud.

  • To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.

  • To personalize your Application experience and to deliver content and product and service offerings relevant to your interests.

  • To help maintain the safety, security, and integrity of our Application, products and services, databases and other technology assets, and business.

  • For testing, research, analysis, and product development, including to develop and improve our Application, products, and services.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Corra’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Corra about our Application users is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We share your personal information with the following categories of third parties: service providers.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose: 

Category A: Identifiers.

Category B: California Customer Records personal information categories.

Category C: Protected Classification Characteristics.

Category D: Commercial information.

Category E: Biometric information.

Category F: Internet or other similar network activity.

Category G: Geolocation data.

Category H: Sensory data.

Category K: Inferences.

We disclose your personal information for a business purpose to the following categories of third parties: service providers, in order to provide the services in the Application.

Your Rights and Choices 

The CCPA provides California residents with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

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. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

  • The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.

  • Our business or commercial purpose for collecting or selling that personal information.

  • The categories of third parties with whom we share that personal information.

  • The specific pieces of personal information we collected about you (also called a data portability request).

  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:

    • sales, identifying the personal information categories that each category of recipient purchased; and 

    • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained. 

Deletion Request Rights 

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. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to 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 or our service provider(s) to: 

  1. 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.

  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

  3. Debug products to identify and repair errors that impair existing intended functionality.

  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

  6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.

  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

  8. Comply with a legal obligation.

  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing contact@corra.app

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. 

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.

  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. 

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request. 

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (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.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response electronically. 

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

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. 

Changes
We reserve the right to change our Privacy Policy at any time without notice. However, these changes will not reduce your privacy on a retrospective basis. We will post any Privacy Policy changes on this page and it is your responsibility to check this page for updates.

Contact
If you have questions or concerns relating to this Privacy Policy, please contact us at contact@corra.app.