Last Updated: January 19th, 2023
This Privacy Policy (“Policy”) describes how Sheer Health, Inc. (“Sheer Health,” “we,” “our,” “us”) collects, uses, and discloses certain personal information obtained through our website (“Site”), which is located at https://www.sheerhealth.com, as well as information that we process as part of offering you our services (collectively with the Site, the “Services”)
By using our Services, you are agreeing to the terms of this Policy. At Sheer Health, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy. Remember that your use of Sheer Health’s Services is at all times subject to our Terms of Use, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use. Depending on how you use the Services, we may ask you to sign an Informed Consent form that describes certain aspects of the Services and asks for your consent to process your information as part of those Services.
Our Site is not intended for anyone under the age of 18. No one under age 18 may provide any personal information to or on the Site. We do not knowingly collect personal information from anyone under 18. If you are under 18, do not use or provide any information on this Site or through any of its features, register on the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from an individual under 18, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at help@sheerhealth.com.
WHAT INFORMATION WE COLLECT AND MAINTAIN ABOUT YOU
We collect personal and other information from you directly when you provide it to us through the website. We also automatically collect certain information about you and your computer, smartphone, or other device when you use, access, or interact with our Site. We may also collect information from third parties in relation to providing you our Services.
Personal information collected from account holders.
If you make an account with us in relation to our Services, we will collect information from you related to maintaining your account. This may include your name, email address, phone number, health insurance information, dependents information, your reason for engaging our Services, as well as any User Materials that you provide. We may also collect and maintain: records and copies of your correspondence (including email addresses), if you contact us; your responses to surveys that we might ask you to complete for research purposes, your search queries on our website, and details of any transactions you carry out on our site; information about you from third parties in relation to our Services.
Other personal information collected through the Site.
You can visit the Site without submitting any information that we can use to identify you personally. However, using certain features on the Site, such as the “Sign Up” or the “Contact Us” feature, you will be required to provide personal information. Such information could include, for example, your name, email address, and phone number.
Web log data.
When you use the Site, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site, the date and time of your visit, the files that you download, the URLs from the websites you visit before and after navigating to the Site, your software and hardware attributes (including device IDs), your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity.
Cookies.
We also use cookies on the Site. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect or store information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.
Web beacons.
The Site or the emails that you receive from Sheer Health may use an application known as a “web beacon” (also known as a “clear gif” or “web bug”). A web beacon is an electronic file that usually consists of a single-pixel image. It can be embedded in a web page or in an email to transmit information, which could include personal information. For example, it can allow an email sender to determine whether a user has opened a particular email.
Third-party online tracking and behavioral advertising.
We also may partner now or in the future with certain third parties to collect, analyze, and use some of the personal and other information described in this section. For example, we may allow third parties to set cookies or use web beacons on the Site or in email communications from us. This information may be used for a variety of purposes, including online interest-based advertising or other health related partners, as discussed below (see the section entitled “Information Sharing and Disclosure”).
HOW WE USE AND PROCESS YOUR INFORMATION
We use the information that we collect about you for a variety of purposes, including to: Provide you with our Services; Respond to your questions or requests concerning the Services; Fulfill the terms of any agreement you have with us; Fulfill your requests for our Services or otherwise complete a transaction that you initiate;Send you information about our Services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications, including promotional emails; Improve our artificial intelligence and machine learning; · Deliver confirmations, account information, notifications, and similar operational communications;Improve your user experience and the quality of our products and Services; Comply with legal and/or regulatory requirements; Aggregate and de-identify information; Benchmark results for our customers; Provide you with relevant and contextual benefit recommendations and partners with affiliated relationships taking into account your insurance plan and claims history; Analyze how visitors use the Services and various Services features, including to count and recognize visitors to the Services; Create new products and Services; and Manage our business. We may link information gathered through the Site with information that we collect in other contexts. But in that event, we will handle the combined information in a manner consistent with this Policy.
INFORMATION SHARING AND DISCLOSURE
We may disclose your information with other parties for a variety of purposes, as described below.
With your consent. We may disclose your information when you provide us with your consent to do so. Subsidiaries and affiliates. We may disclose your information to our subsidiaries, affiliates and similar related parties. Third-party service providers. Sheer Health uses third-party service providers that perform services on our behalf, including, without limitation, web-hosting companies, mailing vendors, and analytics providers. These service providers may collect and/or use your information, including information that identifies you personally, to assist us in achieving the purposes discussed above. We may share your information with other third parties when necessary to fulfill your requests for services; to complete a transaction or other activity that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business.
Analytics. We partner with certain third parties to obtain the automatically collected information discussed above and to engage in analysis, auditing, research, and reporting. These third parties may use web logs or web beacons, and they may set and access cookies on your computer or other device. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.
Interest-based Advertising. The Site also enables third-party tracking mechanisms to collect information about you and your computing devices for use in online interest-based advertising. For example, third parties may use the fact that you visited our Site to target online ads to you. In addition, our third-party advertising networks might use information about your use of our Site to help target advertisements based on your online activity in general. For information about interest-based advertising practices, including privacy and confidentiality, visit the Network Advertising Initiative website or the Digital Advertising Alliance website. The use of online tracking mechanisms by third parties is subject to those third parties’ own privacy policies, and not this Policy. If you prefer to prevent third parties from setting and accessing cookies on your computer or other device, you may set your browser to block cookies. Additionally, you may remove yourself from the targeted advertising of companies within the Network Advertising Initiative by opting out here, or of companies participating in the Digital Advertising Alliance by opting out here. Do Not Track Requests. Please note that our Site does not respond to “do not track” browser headers or other "do not track" requests. However, you can limit tracking through the third-party programs asdiscussed in the preceding section.
Data usage. We may now or in the future engage with research, commercial or other types of partners to use member data for research or commercial opportunities.
Legal purposes. We also may use or share your information with third parties when we believe, in our sole discretion, that doing so is necessary: To comply with applicable law or a court order, subpoena, or other legal process; to investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the property or physical safety of any person or third party; to establish, protect, or exercise our legal rights or defend against legal claims; or to facilitate the financing, securitization, insuring, sale, assignment, bankruptcy, or other disposal of all or part of our business or assets.
Aggregated and de-identified information. From time to time, Sheer Health may also share aggregated or de-identified information about users, such as by publishing a report on trends in the usage of the Site. Such aggregated information will not identify you personally. YOUR CHOICES If you want to learn more about the personal information that Sheer Health has about you, or you would like to update, change, or delete that information, please contact us by email at privacy@sheerhealth.com. You may opt out of receiving marketing emails from us by following the instructions in those emails or by emailing us at privacy@sheerhealth.com. If you are a resident of a jurisdiction with an applicable data privacy law, you may have certain rights available to you in relation to your personal information. These rights may include the right to: be informed about our data collection practices; access and correct your data; erase or delete your data; data portability; opt-out of the sale or sharing of your information; opt-out of targeted advertising; opt-out of marketing emails and text messages; limit our use of any automated decision-making processes; and withdraw consent (to the extent applicable). To exercise any of the rights listed above, please contact us via email at privacy@sheerhealth.com. We will respond to your request as soon as reasonably possible and within the timeframe required under applicable law. Prior to complying with your request, we will first verify your identity by comparing the information you provide with the information we have on file for you. Additionally, you may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.
EXTERNAL LINKS
This Site may contain links to third-party websites. If you use these links, you will leave the Site. We have not reviewed these third-party sites and do not control and are not responsible for any of these sites, their content, or their privacy policy. Thus, we do not endorse or make any representations about them, or any information, software, or other products or materials found there, or any results that may be obtained from using them. If you decide to access any of the third-party sites listed on our website, you do so at your own risk.
DATA SECURITY
We employ physical, technical, and administrative procedures to safeguard the personal information we collect online. However, no website is 100% secure and we cannot ensure or warrant the security of any information you transmit to the Site or to us, and you transmit such information at your own risk.
DATA RETENTION
We retain personal information about you necessary to fulfill the purpose for which that information was collected or as required or permitted by law. We do not retain personal information longer than is necessary for us to achieve the purposes for which we collected it. When we destroy your personal information, we do so in a way that prevents that information from being restored or reconstructed.
INTERNATIONAL USERS
The information that we collect through or in connection with the Services is transferred to and processed in the United States for the purposes described above. Sheer Health may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or by providing any personal or other information to us, you expressly consent to such transfer and processing.
CHANGES TO THIS POLICY
We may make changes to the Site in the future and as a consequence will need to revise this Policy to reflect those changes. We will post all such changes on the Site, so you should review this page periodically. If we make a material change to the Policy, you will be provided with appropriate notice.
HOW TO CONTACT US
Should you have any questions or concerns about this Policy, you can contact us at privacy@sheerhealth.com.