Effective Date: July 26, 2018

At Caravan Health, Inc. (“Caravan”), privacy is a priority. This Privacy Policy sets out how Caravan (“us,” “our,” or “we”) collect and use information from customers and other individuals who access or use our websites, including www.caravanhealth.com, our mobile applications, our web client or professional client, and/or any of our other sites, products, or services that link to this Privacy Policy (the “Services”). By using our Services, you understand that we will collect and use your information as described in this Privacy Policy (collectively “you”).

If you or your organization has an individual agreement with us, that agreement may have privacy terms that also apply to the information you provide to us under that agreement. Please review the terms in that agreement because they may be different or more restrictive than the terms in this Privacy Policy.

This Privacy Policy does not apply to any third-party websites and apps that you may use, including any that are linked to in our Services. You should review the terms and policies for those third-party websites and apps before clicking on any links.  This Privacy Policy also does not apply to data provided to us by the Centers for Medicare and Medicaid (“CMS”); our use of that data is governed by the Data Use Agreement pursuant to which the data was provided.
 
  1. Introduction.  We are committed to respecting privacy and recognize the need for appropriate protection and management of any Personal Data that is shared with us as part of using our Service. As used in this Privacy Policy, "Personal Data" means, subject to the exclusions above, any information that may be used, either alone or in combination with other information, to personally identify an individual.
  2. Information Collected.  We may receive and/or collect Personal Data in the following ways:
    1. Personal Data Received from Clients.  Our clients may provide us with Personal Data from time to time in the course of our providing services to them. Information obtained from or relating to clients or former clients may be further subject to the terms of any privacy terms set forth in an agreement with the client, and applicable law.
    2. Personal Data you provide to Us while using the Services.  If you send us a request  for additional information, subscribe to our newsletter, register for an event, create or update a client portal account, or sign up to receive updates, you may be required to provide us with certain information that may constitute Personal Data, such as your name, email address, company name, company address, and phone number.
    3. Information Collected Automatically.  Certain information on our Service is collected automatically by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends, and to analyze the effectiveness of our Service.  Alone or in combination with other information, such automatically collected information may constitute Personal Data.  Some of our service providers (described in Section 4, below) may use cookies or other methods to gather information regarding your use of our Service.  Such third-parties may use these cookies or other tracking methods for their own purposes by relating information about your use of our Service with any of your Personal Data that they may have.  The use of such information by a third-party depends on the privacy policy of that third-party. 
      1. Log files for Our Service.  The information inside the log files includes internet protocol (“IP”) addresses, type of browser, Internet Service Provider (“ISP”), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.
      2. Other Tracking Technologies.  When you visit our Service, we may collect your IP address.  For example, we may use IP addresses to monitor the regions from which you navigate our Services. We may also use web beacons alone or in conjunction with cookies to compile information about your usage of our Service and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Service. We may use web beacons to operate and improve our Service and email communications.
      3. Cookies.  We use cookies to make interactions with our Service easy and meaningful.  When you visit our Service, our servers may send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser.  We may use cookies that are session-based and persistent-based.  Session cookies exist only during one session.  They disappear from your computer when you close your browser software or turn off your computer.  Persistent cookies remain on your computer after you close your browser or turn off your computer.  Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate our Service, but you may not be able to successfully use all of the features of our Service. We use the following cookies:
        1. Strictly necessary cookies.  These are cookies that are required for the operation of our websites and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the Service will not then work. These cookies do not store any Personal Data.
        2. Analytical/performance cookies.  They allow us to recognize and count the number of website visitors and to see how visitors move around our websites when they are using them.  This helps us to improve the way our websites work, for example, by ensuring that users are finding what they are looking for easily.  All information these cookies collect is aggregated and therefore anonymous.  If you do not allow these cookies, we will not know when you have visited our site, and will not be able to monitor its performance.
        3. Functionality cookies.  These are used to recognize you when you return to our websites.  This enables us to personalize our content for you, greet you by name and remember your preferences (e.g., your choice of language or region).
        4. Targeting cookies.  These cookies record your visit to our websites, the pages you have visited and the links you have followed.  We will use this information to make our websites and the advertising displayed on it more relevant to your interests.  We may also share this information with third parties for this purpose.
      4. Third-party cookies.  We also allow third parties to place cookies on your device through the Services to:
        1. Help us understand and improve how visitors use our websites, including which of our pages and products are viewed most frequently;
        2. More effectively market our products and services and advertise other products and services that may be of interest to you;
        3. Obtain your feedback on our products and the Services;
        4. Allow you to engage in our social media offerings.
      5. The use of third-party cookies is not covered by our Privacy Policy.  We do not have access or control over these cookies. You may visit the third-party links below to opt out of their tracking and learn about their privacy practices. However, we are not in control of the location of the instructions and information provided by the third parties below and, therefore, you may have to locate the particular instructions and information for the respective third party if these links are no longer current.
  • Google Analytics
    • To view Google’s privacy policy, please click here.
    • To opt out, please download and install the "Google Analytics Opt-out Browser Add-on by clicking here.
  1. The purposes for which we Use Personal Data.  If you submit or we collect Personal Data through our Service, then such Personal Data may be used in the following ways: (a) to provide services to our clients in accordance with our contractual obligations; (b) to provide, analyze, administer, and improve our Service and services; (c) to contact you in connection with our Service and certain services, notifications, events, programs or offerings; (d) to send you updates and promotional materials that you have registered for; (e) to identify and authenticate your access to the parts of our Service (e.g., client portals and extranet) and services that you are authorized to access; (f) for recruiting and human resources administration purposes; and (g) to protect our rights and/or our property and to ensure the technical functionality and security of our Service.
  2. How we disclose Personal Data.  We do not sell, lease, rent, or otherwise disclose the Personal Data collected from our Service to third-parties unless otherwise stated below or with your consent.
    1. Our third-party providers.  We transfer or provide access to Personal Data to our third-party service providers to perform tasks on our behalf and to assist us in providing our Service. For example, we employ service providers who help us provide secure client portals; analyze website traffic and demographics (Google Analytics); enabling sharing of content on our website; and conduct marketing services (MailChimp).
    2. Our Clients.  We may disclose Personal Data to our clients as necessary in the course of our providing the Services.
    3. In the Event of Merger, Sale, or Change of Control. We may transfer or assign this Privacy Policy and any Personal Data to a third-party entity that acquires or is merged with as part of a merger, acquisition, consolidation, restructuring, the sale of substantially all of our shares and/or assets, in connection with bankruptcy proceedings, reorganization, or other change of control.
    4. Other Disclosures.  We may disclose Personal Data about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our terms of use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Caravan, our users, or the public.
  3. Retention of Personal Data.   We reserve the right to retain any Personal Data as long as the Personal Data are needed to: (a) fulfill the purposes that are described in Section 3 (The purposes for which we use Personal Data), and (b) comply with applicable law.  We will take all reasonable steps to destroy, or erase from our systems, all Personal Data which is no longer required for the purposes for which the Personal Data was collected.
  4. Your Rights
    1. Personal Data.  If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via our Service, you may submit a request to legal@caravanhealth.com or write to us at:

Caravan Health, Inc.
Attn: Legal Department
7509 NW Tiffany Springs Parkway, Suite #310
Kansas City, MO 64153

We will promptly review all such requests in accordance with applicable laws.  Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Data about you.  We encourage you to first reach out to us at legal@caravanhealth.com, so we have an opportunity to address your concerns directly before you do so.

b. Opting-Out of Promotional Emails.  You may choose not to receive future promotional or advertising emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us.  Additionally, you may send a request specifying your communications preferences to legal@caravanhealth.com. You cannot opt out of receiving transactional emails related to the performance of our services.  Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any "Contact Us" request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).

  1. Data Security.  The security of Personal Data is important to us. We take appropriate technical and organizational data security measures against unlawful or unauthorized processing of Personal Data, and against the accidental loss of, or damage to, Personal data.  We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it.  However, no method of transmission over the Internet, or method of electronic storage, is 100% secure.  Further, while we attempt to ensure the integrity and security of Personal Data, we cannot guarantee that our security measures will prevent third-parties such as so-called hackers from illegally obtaining access to Personal Data. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.
  2. Changes to this Privacy Policy.  We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time.  You can see when this Privacy Policy was last updated by reviewing the “Last Updated” legend on the top of this page.  We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances.  UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING.
  3. Children’s Privacy.  We do not intend to collect Personal Data from anyone we know to be a child, except as permitted by law in the course of providing our client services.Contacting Us and our Privacy Officer.  Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to our Privacy Officer at legal@caravanhealth.com. We seek to promptly resolve any concerns you may have.