Polygon Health
Data Privacy Policy
Last Updated: 10/26/2022
Introduction
Polygon Health (“Polygon Health,” “we,” “our,” or “us”) is the patient-driven health data marketplace, where you can sell your health data privately to researchers improving lives. We respect your privacy and we are committed to protecting it through our compliance with this privacy notice (“Privacy Notice”). This Privacy Notice describes the types of information we may collect or that you may provide when you download, access, and/or use the application (“App”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.
Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, do not download, register with, or use the App. By downloading, registering with, or using the App, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see the “Changes to Our Privacy Notice” section below). Your continued use of the App after we revise this Privacy Notice means you accept those changes, so please check this Privacy Notice periodically for updates.
Children Under the Age of 18
The App is not intended for children under 18 years of age, and we do not knowingly collect personal data from children under 18. If we learn we have collected or received personal data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at privacy@polygonhealth.com.
California residents under 16 years of age may have additional rights regarding the collection and sale of their personal data. Please review the “Your California Rights” section below for more information.
Information We Collect and How We Collect It
We collect non-health-related information from users of our App:
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Directly from you when you provide it to us.
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Automatically when you use the App.
Information You Provide to Us
When you download, register with, or use this App, we may ask you provide information:
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By which you may be personally identified, including name, postal address, email address, telephone number, Social Security number, and/or any other information the App collects that is defined as personal data under applicable law (“personal data”).
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That is about you but individually does not identify you.
The information you provide to us includes:
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Information that you provide by filling in forms in the App. This includes information provided at the time of registering to use the App, subscribing to our service, posting material, and requesting further services. We may also ask you for information when you report a problem with the App.
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Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
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Your responses to surveys that we might ask you to complete for research purposes.
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Details of transactions you carry out through the App and of the fulfillment of your orders. You may be required to provide financial information before placing an order through the App.
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Your search queries on the App.
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You may choose to import your health information into the App. If you do so, we will store that information, which may contain particularly sensitive personal information about your physical and mental health, diseases and diagnoses, and related health data, including prescription medication information. We will not use this information for other purposes unless we receive your explicit consent.
Social Media Functionality
You may also provide information for publication or display (“Posted”) on public areas of the App (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Automatic Information Collection and Tracking
When you download, access, and use the App, it may use technology to automatically collect:
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Usage Details. When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the App.
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Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number.
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Stored Information and Files. The App also may access metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
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Location Information. This App does not collect real-time information about the location of your device.
If you do not want us to collect this information, do not download the App or delete it from your device. We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). For more information, see the “Your Choices About Our Collection, Use, and Disclosure of Your Information” section below. Note, however, that opting out of the App’s collection of location information will disable its location-based features.
Information Collection and Tracking Technologies
The technologies we use for automatic information collection may include:
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Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of our App.
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Web Beacons. Pages of the App and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Polygon Health, for example, to count users who have visited those pages or opened an email and for other related App statistics (for example, recording the popularity of certain App content and verifying system and server integrity).
Third-Party Information Collection
When you use the App or its content, certain third parties may use automatic information collection technologies to collect information about you or your device.
These third parties may include:
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Service companies.
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Your mobile device manufacturer.
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Your mobile service provider.
These third parties may use tracking technologies to collect information about you when you use this App. The information they collect may be associated with your personal data or they may collect information, including personal data, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see the “Your Choices About Our Collection, Use, and Disclosure of Your Information” section below.
How We Use Your Information
We use information that we collect about you or that you provide to us to:
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Provide you with the App and its contents, and any other information, products or services that you request from us.
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Give you notices about your account/subscription, including expiration and renewal notices.
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Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
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Notify you when App updates are available, and of changes to any products or services we offer or provide though it.
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Fulfill any other purpose for which you provide it.
The usage information we collect helps us to improve our App and to deliver a better and more personalized experience by enabling us to:
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Estimate our audience size and usage patterns.
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Store information about your preferences, allowing us to customize our App according to your individual interests.
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Speed up your searches.
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Recognize you when you use the App.
We may also use your information to contact you about our own and third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see the “Your Choices About Our Collection, Use, and Disclosure of Your Information” section below.
Disclosure of Your Information
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
In addition, we may disclose personal data that we collect or you provide:
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To our subsidiaries and affiliates.
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To contractors, service providers, and other third parties (including researchers) we use to support our business and who are bound by contractual obligations to keep personal data confidential and use it only for the purposes for which we disclose it to them.
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To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Polygon Health’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by Polygon Health about our App users is among the assets transferred.
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To fulfill the purpose for which you provide it.
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For any other purpose disclosed by us when you provide the information.
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With your consent.
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To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
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To enforce our rights arising from any contracts entered into between you and us, including the App End User License Agreement and for billing and collection.
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If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Polygon Health, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
Your Choices About Our Collection, Use, and Disclosure of Your Information
We strive to provide you with choices regarding the personal data you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of over your information.
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Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the App may then be inaccessible or not function properly.
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Promotion by Polygon Health. If you do not want us to use your email address or other contact information to promote our own or third parties’ products or services, you can opt-out. You can also always opt-out by logging into the App and adjusting your user preferences in your account profile by checking or unchecking the relevant boxes or by sending us an email stating your request to privacy@polygonhealth.com
We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.
California residents may have additional personal data rights and choices. Please see the “Your California Privacy Rights” section below for more information.
Accessing and Correcting Your Personal Data
You can review and change your personal data by logging into the App and visiting your account profile page. You may also send us an email at privacy@polygonhealth.com to request access to, correct, or delete any personal data that you have provided to us. We may not be able to delete your personal data except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other App users. Proper access and use of information provided on the App, including User Contributions, is governed by our Terms of Use.
Despite the above, Polygon Health may have certain legal requirements or rights to information blocking, including preventing harm, privacy, security, infeasibility, health IT performance, content and manner, fees, and licensing.
Your California Privacy Rights
California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of the App that are California residents to request certain information regarding our disclosure of personal data to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@polygonhealth.com.
Data Security
We have implemented measures designed to secure your personal data from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls. Any sensitive data will be encrypted, both at rest and in transit.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the App like message boards. The information you share in public areas may be viewed by any user of the App.
Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal data, we cannot guarantee the security of your personal data transmitted through our App. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
Changes to Our Privacy Notice
We may update our Privacy Notice from time to time. If we make material changes to how we treat our users’ personal data, we will post an in-App alert the first time you use the App after we make the change. The date that the Privacy Notice was last updated is identified at the top of the page. You are responsible for periodically visiting this Privacy Notice to check for any changes.
Contact Information
To send us questions or comment about this Privacy Notice, please contact us at:
Polygon Health
1 Broadway, 14th Floor, Cambridge MA 02142