Effective Date: August 1st, 2019
Personal Data We Collect
Naima collects data to provide the Services you request, ease your navigation on our website, communicate with you, and improve your experience using our Services. Some of this information is provided by you directly, such as when you create an account to use the App, or purchase a product or service from us. Some of the information is collected through your interactions with our Services. We collect such data using technologies like cookies and other tracking technologies, error reports, and usage data collected when you interact with the App.
The data we collect depends on the Services and features thereof that you use, and includes the following:
Name and contact data. We collect your first and last name, email address, postal address, phone number, and other similar contact data.
Credentials. We process passwords and related security information used for authentication and account access and information security purposes.
Health and Medical data. If you use the App, we collect information regarding your pregnancy including but not limited to demographics, self-reported medical history, psychosocial data, perceived fetal movement and contractions.
Usage data. We collect personalized information about your use of our Services, to better understand uses thereof and identify potential improvements, as well as to send you promotional communications or offers tailored to your use of our Services and interest thereto.
· Information regarding the performance of our Services and any problems you may experience while using them. This information enables us to diagnose problems and offer support in resolution.
· Data about your device and the network you use to access our Services, including IP address, device identifiers, and regional and language settings.
Web requests. We collect information regarding every web request sent to the relevant servers. This information is used to provide support, as well as to assess usage and performance of our Services. The data collected for each request can include such things as timestamps, any exception messages, user agent, IP address, and request time and duration.
Location data. We collect your IP address and infer location such as city or postcode therefrom, when necessary in order to provide you with the Services or to send you promotional communications or for customer relationship management purposes.
Content. We may collect the content of messages you send to us, such as feedback or questions you ask our technical support representatives, when necessary to provide you with the Services you use. We will collect and utilize any data files you send to us for troubleshooting and improving our Services.
Surveys and Studies. App users will be asked to respond to periodic information requests via surveys or questionnaires as part of use of the App. .Participation is voluntary, and you have the choice of whether to disclose any requested information.
How We Use Personal Data
We will only use your personal data when the law allows us to. We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose.
Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
Naima uses information that we collect from customers and visitors for the purposes of:
· Providing our Services;
· Providing ongoing support;
· Communicating with you, including promotional communications and customer relationship management (“CRM”);
· Providing information about other Services;
· Helping us run our company, for example to improve our Services or our security, train staff or perform marketing activities, including CRM;
· Complying with our legal obligations; and
· Accounting and other administrative purposes.
Examples of the uses of information include:
Providing Services. We use data to provide Services to you. Often, this includes personal data such as email, name, and address. We may collect additional information when you register to use the Services, including contact information and credentials. We may use this data to identify and address problems and provide other support services
Improving Product and Services. We use data to continually improve our Services, including adding new features or capabilities. Data is collected throughout your interactions with our Services that enable us to understand customer usage and tailor future capabilities.
We track general, non-personalized information (e.g., operating system, browser version and type of device being used) to know how many people visit specific pages of our Services or utilize specific areas of our Services so that we may improve those Services. We may use your IP address to customize services to your location, such as the language displayed on our Services.
Please note that we use IP addresses on a highly restrictive basis to analyze trends, to administer the site, and to collect general information for aggregate use.
Marketing and event communication: We use personal data to deliver marketing and event communications to you across various platforms, such as email, direct mail, social media, and online via our Services.
If we send you a marketing email, it will include instructions on how to opt out of receiving these emails in the future. For information about managing email subscriptions and promotional communications, please visit the Your Rights Regarding Personal Data section of this privacy statement. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
How We Share Personal Data
We may provide your personal data to:
· UPMC, its affiliates, and UPMC’s designated healthcare providers through the Portal.
· Naima-controlled affiliates and subsidiaries, located in and outside your country or region;
· outsourced service providers who perform functions on our behalf, located inside or outside of your country or region;
· our authorized agents and representatives, located inside or outside of your country or region, who sell products or provide services on our behalf;
· anyone expressly authorized by you to receive your personal data;
· anyone to whom we are required by law to disclose personal data, upon valid and enforceable request thereof.
We will access, disclose and preserve personal data when we have a good faith belief that doing so is necessary to:
· comply with applicable law or respond to valid legal processes, including from law enforcement or other government agencies, upon valid and enforceable request thereof; or
· operate and maintain the security of our Services, including to prevent or stop an attack on our computer systems or networks.
Please note that some of our Services may direct you to services of third parties whose privacy practices differ from Naima’s. If you provide personal data to any of those services, your data is governed by their privacy statements or policies. Naima and our subsidiaries are not responsible for the privacy practices of these other websites. Please review the privacy policies for these websites to understand how they process your information.
Handling of Personal Data
Security of Personal Data
Naima is committed to protecting the security of your personal data. Depending on the circumstances, we may hold your information in hard copy and/or electronic form. For each medium, we use technologies and procedures to protect personal data. We review our strategies and update as necessary to meet our business needs, changes in technology, and regulatory requirements.
These measures include, but are not limited to, technical and organizational security policies and procedures, security controls and employee training.
You are responsible for maintaining the security of your account credentials for the Services. Naima will treat access to the Services through your account credentials as authorized by you. Unauthorized access to password-protected or secure areas is prohibited and may lead to criminal prosecution. We may suspend your use of all or part of the Services without notice if we suspect or detect any breach of security. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.
If we become aware of a breach that affects the security of your personal data, we will provide you with notice as required by applicable law. To the extent permitted by applicable law, Naima will provide any such notice that Naima must provide to you at your account’s email address. By using the Services, you agree to accept notice electronically.
Storage and Transfer of Personal Data
Naima also collaborates with third parties such as cloud hosting services and suppliers located around the world to serve the needs of our business, workforce, and customers. In some cases, we may need to disclose or transfer your personal data within Naima or to third parties in areas outside of your home country. When we do so, we take steps to ensure that personal data is processed, secured, and transferred according to applicable law.
If you would like to know more about our data transfer practices, please contact us at firstname.lastname@example.org.
Retention of Personal Data
Naima retains personal data for as long as necessary to provide the services and fulfill the transactions you have requested, or for other business purposes such as complying with our legal obligations, resolving disputes, and enforcing our agreements. We are required by law to keep some types of information for certain periods of time (e.g. statute of limitations). If your personal data is no longer necessary for the legal or business purposes for which it is processed, we will generally destroy or anonymize that information.
Your Rights Regarding Your Personal Data
Naima respects your right to access and control your personal data. You have choices about the data we collect. When you are asked to provide personal data that is not necessary for the purposes of providing you with our Services, you may decline. However, if you choose not to provide data that is necessary to provide a Service, you may not have access to certain features of the Services.
If you use the App, you can stop all collection of information by the App by uninstalling it. You may use the standard uninstall processes available as part of your mobile device. You can stop collection of information by any of the other Services by ceasing to use such Services
We aim to keep all personal data that we hold accurate, complete and up-to-date. While we will use our best efforts to do so, we encourage you to tell us if you change your contact details. If you believe that the information we hold about you is incorrect, incomplete or out-of-date, please contact us at email@example.com.
Access to personal data: In some jurisdictions, you have the right to request access to your personal data. In these cases, we will comply, subject to any relevant legal requirements and exemptions, including identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
If you are a corporate user of our Services (which means your employer is a Naima customer of such Services): please first request access to your personal data with your employer. Your employer will then be in touch with us with respect to your request.
Correction and deletion: In some jurisdictions, you have the right to correct or amend your personal data if it is inaccurate or requires updating. You may also have the right to request deletion of your personal data. Please note that such a request could be refused because your personal data is required to provide you with the products or services you requested, e.g. to deliver a product or send an invoice to your email address, or that it is required by the applicable law.
Marketing preferences: If you have provided us with your contact information, we may, subject to any applicable Spam Act or similar regulation, contact you via e-mail, postal mail or telephone about Naima products, services and events that may be of interest to you, including our newsletter.
E-mail communications you receive from Naima will generally provide an unsubscribe link allowing you to opt-out of receiving future e-mail or to change your contact preferences. Please remember that even if you opt out of receiving marketing emails, we may still send you important Service information related to your accounts and subscriptions.
You can also request changes to your account by contacting Naima via email at [firstname.lastname@example.org.
California Shine the Light Law:[KLG13] California Civil Code Section 1798.83 permits users who are California residents to obtain from us once a year, free of charge, a list of third parties to whom we have disclosed personal information (if any) for direct marketing purposes in the preceding calendar year. If you are a California resident and you wish to make such a request, please send an e-mail with “California Privacy Rights” in the subject line to email@example.com or write us at: Naima Health LLC 224 N Euclid Ave STE 207, Pittsburgh, PA 15206
Cookies & Similar Technologies
We may combine the information we collect via Cookies with personal data that we have collected from you to learn more about how you use our websites to improve them.
Types of Cookies
We use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your device until you delete them). To make it easier for you to understand why we need them, the Cookies we use on our websites can be grouped into the following categories:
· Strictly Necessary: These Cookies are necessary for the websites to work properly. They include any essential authentication and authorization cookies for our websites.
· Functionality: These Cookies enable technical performance and allow us to “remember” the choices you make while browsing our websites, including any preferences you set. They also include sign-in and authentication cookies and IDs that enable you to return without additional sign-in.
· Performance/Analytical: These Cookies allow us to collect certain information about how you navigate the websites or utilize the Products running on your device. They help us understand which areas you use and what we can do to improve them.
· Targeting: These Cookies are used to deliver relevant information related to our websites to an identified machine or other device (not a named or otherwise identifiable person) which has previously been used to visit our websites. Some of these types of Cookies on our websites are operated by third parties with our permission and are used to identify advertising sources that are effectively driving customers to our websites.
Cookies Set by Third Party Services
To enhance our content and to deliver a better online experience for our users, we sometimes embed images and videos from other websites on the websites. We currently use, and may in future use content from websites such as Facebook, LinkedIn and Twitter. You may be presented with Cookies from these third-party websites. Please note that we do not control these Cookies. The privacy practices of these third parties will be governed by the parties’ own privacy statements or policies. We are not responsible for the security or privacy of any information collected by these third parties, using cookies or other means. You should consult and review the relevant third-party privacy statement or policy for information on how these cookies are used and how you can control them.
Other Similar Technologies
Naima web pages may use other technologies such as web beacons to help deliver cookies on our websites and count users who have visited those wesbites. We also may include web beacons in our promotional email messages or newsletters to determine whether you open and act on them as well as for statistical purposes.
In addition to standard cookies and web beacons, our services can also use other similar technologies to store and read data files on your computer. This is typically done to maintain your preferences or to improve speed and performance by storing certain files locally.
How to Control and Delete Cookies
Cookies can be controlled, blocked or restricted through your web browser settings. Information on how to do this can be found within the Help section of your browser. All Cookies are browser specific. Therefore, if you use multiple browsers or devices to access websites, you will need to manage your cookie preferences across these environments.
If you are using a mobile device to access our websites, you will need to refer to your instruction manual or other help/settings resource to find out how you can control cookies on your device.
Please note: If you restrict, disable or block any or all Cookies from your web browser or mobile or other device, the websites may not operate properly, and you may not have access to our websites available through the websites. Naima shall not be liable for any impossibility to use the websites or degraded functioning thereof, where such are caused by your settings and choices regarding cookies.
To learn more about cookies and web beacons, visit www.allaboutcookies.org.
Do Not Track: Some web browsers (including Safari, Internet Explorer, Firefox and Chrome) incorporate a “Do Not Track” (“DNT”) or similar feature that signals to websites that a user does not want to have his or her online activity and behavior tracked. If a website that responds to a particular DNT signal receives the DNT signal, the browser can block that website from collecting certain information about the browser’s user. Not all browsers offer a DNT option and DNT signals are not yet uniform. For this reason, many website operators, including Naima, do not respond to DNT signals.
Services ARE NOT INTENDED FOR CHILDREN
You must be at least the age of majority in your place of residence to use the Services. The Services are not directed to or intended for use by minors. Consistent with the requirements of the U.S. Children’s Online Privacy Protection Act, if we learn that we received any information directly from a child under age 13 without his or her parent’s verified consent, we will use that information only to inform the child (or his or her parent or legal guardian) that he or she cannot use the Services.
California Minors: While the Services is not intended for anyone under the age of 18, if you are a California resident who is under age 18 and you are unable to remove publicly-available content that you have submitted to us, you may request removal by contacting us at: firstname.lastname@example.org. When requesting removal, you must be specific about the information you want removed and provide us with specific information, such as the URL for each page where the information was entered, so that we can find it. We are not required to remove any content or information that: (1) federal or state law requires us or a third party to maintain; (2) was not posted by you; (3) is anonymized so that you cannot be identified; (4) you don’t follow our instructions for removing or requesting removal; or (5) you received compensation or other consideration for providing the Content or information. Removal of your content or information from the Services 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.
Questions or Complaints Handling
Mail: Naima Health LLC
Attention: Legal Department
224 N Euclid Ave, STE 207
Pittsburgh, PA 15206