Some of the information we collect from users may be subject to laws and regulations governing the use and disclosure of health information, including the Health Insurance Portability and Accountability Act of 1996, as amended from time to time, together with the regulations adopted thereunder (“HIPAA”). When we store, process or transmit “individually identifiable health information” (as defined by HIPAA) on behalf of a healthcare provider, we do so as its “business associate” (as also defined by HIPAA). Notwithstanding any other provision in this Policy, for any information we collect from you that is subject to HIPAA, we will comply with all applicable HIPAA law and regulations.
1. Information Collected by NonCaptive. We may collect information that you provide to us in connection with your use of the Service when you (A) register as a user of the Service or use the Service; (B) make changes to your user profile information; (C) send email messages, forms, or other information to us through the Service; (D) post or contribute content via the Service; (E) participate in Service-related activities and events; (F) purchase insurance products from us; or (G) share with us your social media or fitness/exercise/activity applications or data. We may also collect information about you from third-party business partners and service providers, and from publicly available sources. The information we collect may include, but is not limited to, your name and contact information, demographic data, health data, financial data, social media data, actuarial data, Health IQ quiz information, fitness/exercise/activity data, Internet activity, information regarding your use of the Service, a profile picture, and other information. If you purchase insurance from us, you may also provide your driver’s license information, social security number, and payment information. If you provide it to us, we may also collect from you some of the above information about other members of your household.
If you register for a NonCaptive account via a third-party network like Facebook, you authorize NonCaptive to use the information you provide on such account to pre-populate the registration and other relevant information fields of your NonCaptive account. If you connect your NonCaptive account to another network, you agree to comply with the terms and conditions and policies applicable to such network. Your use of such third-party networks remains subject to the terms and conditions and policies you have agreed to with such third-party network providers.
2. Information You Share on the Service. Some portions of the Service allow you to submit comments, reviews, tags, ratings, pictures and other content. This content may be displayed on the Service and may be viewable by other users of the Service. By default, certain aspects of this information is available to other users of the Service unless you elect to make your profile private. By posting or submitting content through the Service, you agree to permit us to disclose the information and material you post.
3. Information Automatically Collected Through the Service. NonCaptive, along with our third-party service partners, vendors and business partners may automatically collect information about you when you use the Service. The information automatically collected about you may include, but is not limited to, device ID, device type, browser type and version, geo-location information, computer and connection information, statistics on page views, traffic to and from the Service, ad data, IP address and standard web log information.
The Service may include third-party advertising, links to other websites and other content from third-party businesses.
In addition, you may be able to adjust your browser settings or other settings so that “do not track” requests are sent to the websites and mobile applications that you use. However, NonCaptive will not disable tracking technology that may be active on the Service in response to any “do not track” requests that are sent to the Service.
5. Use of Information by NonCaptive. NonCaptive may use information that we collect about you through the Service to:
• provide access to the Service and to provide you with requested services and customer support and to process and respond to your inquiries;
• personalize, customize, measure and improve our services, content and advertising, and to enhance your experience of the Service;
• prevent, detect and investigate potentially prohibited or illegal activities, and enforce the Terms;
• analyze the accuracy, effectiveness, usability or popularity of the Service, our products, or our marketing campaigns;
• generate and review reports and data about our user base and service usage patterns;
• compile and analyze data for internal and external business purposes;
• resolve disputes and troubleshoot problems;
• prepare actuarial analyses;
• develop new products or features;
• prepare reports for any of the purposes described in this Policy, including for current or future sponsors, advertisers, investors, or other partners to show utilization or trends about the use of our Services;
• qualify you for insurance products;
• contact you with information, including promotional, marketing and advertising information and recommendations that we believe may be of interest to you;
• provide you with other services requested by you as described when we collect the information; and
6. NonCaptive Disclosure of Information to Third Parties. NonCaptive may disclose your information to the following third parties:
A. Our Service Providers and Business Partners. We may share your information with third-party business partners, contractors or service providers for several purposes, including but not limited to operating and supporting the Service, marketing, research and analytics, product development, actuarial analyses, telemarketing, and offering you products or services that may be of interest to you. The further use and sharing of your data by these third parties is governed by their respective privacy policies or other corporate policies.
B. Other Users. Information that you post on the Service (e.g., photos, comments, your profile) will be made available to other users of the Service, subject to your ability to make your profile private.
C. Companies that Acquire Our Business or Assets. If NonCaptive becomes involved in a proposed or actual merger, acquisition, sale of assets, securities offering, bankruptcy, reorganization, dissolution, or any other transaction or if the ownership of all or substantially all of our business otherwise changes, NonCaptive may share or transfer your information to a third party or parties in connection with the applicable transaction, as is reasonably necessary to enable the recipient to make business decisions and only in the event such recipient agrees not to disclose the information in a way that violates existing law.
E. Our Insurance Partners. If you apply for an insurance policy with us, we may share some or all of the information you provide to us with our partner insurers, medical exam vendors, or other third parties involved in the insurance application and underwriting process. Our partner insurers may use this information to offer your products or services, where reasonably necessary to detect or prevent material misrepresentation or material nondisclosure, and where reasonably necessary in order for NonCaptive or its partner insurers to perform their respective functions in connection with an insurance transaction involving you.
F. Aggregate or De-identified Information. NonCaptive may share information relating to visitors and users of the Service with affiliated or unaffiliated third parties on an aggregate or de-identified
basis. We note that, while this information will not identify you personally, in some instances these third parties may be able to combine this information with other data they have about you, or that they receive from third parties, in a manner that allows them to identify you personally. Any third parties receiving such information will agree to not further disclose this information, and to destroy or return this information once it is no longer needed.
G. Legal Requirements. To the extent permitted by law, we may share your information with law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other NonCaptive user to legal liability, or to protect our rights or property, or during emergencies when safety is at risk. We may also share your information in response to court orders, subpoenas, or other legal or regulatory requests, and we may provide access to your information to our legal counsel and other consultants in connection with actual or potential litigation.
H. DMCA Notices. We may share your information with third parties when we forward Digital Millennium Copyright Act (“DMCA”) infringement notifications and counter-notifications as described in the Terms. DMCA infringement notifications and counter-notifications (including any personal information included as part of the notifications) will be forwarded as submitted to us without any deletions.
I. Unforeseeable or Unpreventable Disclosures. Your information may be disclosed to third parties in unforeseeable situations or situations that are not preventable even when commercially reasonably protections are employed, such as in the case that NonCaptive or the Service is subject to a hacking or other attack.
7. No Spam, Spyware or Spoofing. NonCaptive and our users do not tolerate spam. To report NonCaptive-related spam or spoof emails to us, please forward the email to privacy@ NonCaptive.com. You may not use our communication tools to send spam or otherwise send content that would violate the Terms.
8. Security. NonCaptive takes reasonable measures to protect the information you provide to NonCaptive or submit through the Service against loss, theft and unauthorized use, disclosure, or modification. However, we cannot guarantee or warrant the security of any information you transmit to NonCaptive or submit through the Service and you do so at your own risk. No internet or email transmission is ever fully secure or error-free. Emails sent to or through the Service may not be secure. You should use caution whenever submitting information online and take special care in deciding what information you send to us via email.
9. Accessing, Changing and Managing Your Information. You may change and update the information you provide through the Service, or change your preferences concerning how we use your information, as follows:
A. Changing or Updating Your Information. You may make changes to the user information you have provided in connection with your NonCaptive account by logging in to your account and changing the applicable information or by contacting us at privacy@NonCaptive.com. If you choose to terminate your account, you may also request that we delete your public-facing information by contacting us at privacy@NonCaptive.com. Following receipt of a request from you, we will take reasonable steps to update or correct your information, or delete your public-facing information if requested. However, unless prohibited by applicable law, postings or comments you provided and which are associated with your public profile prior to closing your account, will remain accessible.
B. Email Communications. You can make changes regarding receiving email communications from us within your NonCaptive account. You can also choose not to receive email communications from us by following the “unsubscribe” instructions in any email communication you receive from us.
11. Third Parties. The Service may contain links to websites that are not owned or operated by NonCaptive. Please be aware that we are not responsible for the privacy practices of these websites. If you visit these websites or provide any information directly to parties other than NonCaptive (even if those websites display the NonCaptive brand), different policies may apply to the collection and use of your information. We encourage you to investigate and ask questions before accessing third-party websites or disclosing information to third parties.
12. No Use by Children. The Service is not intended for use by children under the age of 13. We will never knowingly collect information directly from children under the age of 13 without verifiable parental consent. If you are under the age of 13, you may not use the Service and please do not provide us with information of any kind whatsoever. If we become aware that a user is under the age of 13 and has submitted information to the Service without verifiable parental consent, we will remove his or her information from our files and deactivate his or her account. We encourage parents and guardians to spend time with their children online and to be familiar with the websites they visit. If you have reason to believe that we may have accidentally received personal information from a child under the age of 13, please contact us immediately at privacy@NonCaptive.com.