Privacy Policy
Last Revised: November 11, 2021
INTRODUCTION
At Kinspire Inc. we are committed to protecting your privacy. This Privacy Policy covers how Kinspire collects, receives, uses, retains, and discloses Personally Identifiable Information (“PII”) and Protected Health Information (“PHI”) on Kinspire’s website and/or platform. PII includes information about you that is personally identifying such as your name, email address, and phone number and which is not otherwise publicly available. PHI includes information relating to your health, for example medical history, health conditions, test results, physician referrals, insurance information and other data that a healthcare provider may collect to identify an individual and determine appropriate care. PII and PHI may include other types of information depending on the legal definition that applies in your physical location. Only the definitions of PII and PHI that apply in your location will apply to you under this Privacy Policy. PII and PHI are referred to collectively in this Privacy Policy as “Personal Information.”
Kinspire Inc. (“Kinspire”, "us", "we", or "our") operates the Kinspire mobile application (the “App”), the website www.kinspirehealth.com (the "Site"), any other website, web application or mobile application that we own or control and which posts or links to this Privacy Policy now existing or implemented in the future (the “Services”). This Privacy Policy covers all Personal Information collected by Kinspire through the Services.
We use your Personal Information to provide and improve the App, the Site and the Services. Please read this Privacy Policy 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 the App, register with, or use any part of the Services. By submitting information through the App, the Site or in connection with the Services, you agree to the terms of this Privacy Policy and you expressly consent to the processing of your Personal Information in accordance with this Privacy Policy. We will review this policy regularly, and we may update it from time to time.
For people in California, we have also prepared a Supplemental Privacy Statement for California Consumers under CCPA (“California Statement”) in compliance with the California Consumer Privacy Act of 2018 (“CCPA”). Please review our California Statement attached below for more information.
1. When You Download the App or Visit the Site.
When you download the App or visit the Site located at http://www.kinspirehealth.com/, you are free to view the Site and the App without providing any Personal information. In order to register using the App or the Site, you will be required to provide certain Personal Information about yourself. Each time you visit the App and login, we request that you provide Personal information about yourself, and we may collect navigational Information on our Site and App.
2. Definitions.
2.1 Data or Personal Information - Personal Information means Individually Identifiable Information and, to the extent applicable, Protected Health Information about a Data Subject.
2.2 Usage Data - Usage Data is data collected automatically either generated by the use of the App or the Site or from the App’s or the Site’s infrastructure itself (for example, the duration of a page visit).
2.3 Cookies - Cookies are small pieces of data stored on your device (computer or mobile device).
2.4 Data Controller - Data Controller means the person who (either alone or jointly or in common with other persons) determines the purposes for which and the manner in which any personal information are, or are to be, processed.
For the purpose of this Privacy Policy, we are the Data Controller of your Personal Information. You can contact us at Kinspire Inc., 3700 QUEBEC ST #100-311, Denver, CO 80207 or via email at privacy@kinspireapp.com.
2.5 Data Processors (or Service Providers) - Data Processor (or Service Provider) means any natural or legal person who processes the data on behalf of the Data Controller.
We may use the services of various Service Providers in order to process your Data and/or Personal Information more effectively.
2.6 Data Subject - Data Subject is any identified or identifiable individual who is using the App or the Site and is the provider of Personal Information.
2.7 2.8 Caregivers – Caregivers include parents and legal guardians who have authority to act for a child with regard to the App, the Site and the Services.
3. Information Collection and Use. We collect several different types of information for various purposes to provide and improve our service to you.
4. Types of Data Collected.
4.1 Personal Information. The specific types of Personal Information we collect will depend upon the Services you use, how you use them, and the information you choose to provide. The types of Data we collect directly from you includes, without limitation:
Name, address, telephone number, [date of birth] and email address
Information about you/your child’s diagnosis, treatment options, physician referrals or other related health information
Log-in credentials, if you create an account
Information about your customer service and maintenance interactions with us
Chat messages
Demographic information such as your gender and age
Feedback or correspondence you send to us
Pictures or videos you may upload
Any other information you choose to directly provide to us in connection with your use of the Services.
You may also provide content and/or other information for publication or display (“Posted”) on public areas of the Service and related websites (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Although you may be able to set certain privacy settings for certain User Contributions, 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.
We may use your Personal Information to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send.
4.2 Usage Data
We may also collect information how the App and the Site are accessed and used. This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of the App or the Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.
4.3 Tracking Cookies Data. We use cookies and similar tracking technologies to track the activity on the App and the Site and hold certain information.
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a Site and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze the App and the Site.
We may use both session cookies (which expire once you close your web browser) and persistent cookies (which stay on your computer until you delete them). You can set your browser to not accept cookies, but that may prevent us from providing you with the full range of Services we offer. Also, please be aware that if you visit other sites you may be required to accept cookies. The use of cookies by third parties is not covered by our Privacy Policy.
4.4 Web Beacons. Web beacons are electronic images that may be used on our Site or in our emails. We use web beacons to deliver cookies, count visits, understand usage and campaign effectiveness and to tell if an email has been opened and acted upon.
4.5 Clear Gifs. We may also use clear gifs or other data files or identifiers to collect information for statistical purposes and to improve and develop the Services. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are placed on a hard drive, clear gifs are embedded invisibly on web pages.
4.6 Mobile Application Software Development Kits (SDKs). We may use third-party software development kits (“SDKs”) in our mobile applications. An SDK is third-party computer code that may be used for a variety of purposes, including to provide us with analytics regarding the use of the App, to integrate with social media, add features or functionality to our Sites or Apps, or to facilitate online advertising. SDKs may enable third parties to collect information directly via the App or the Site.
4.7 Google Analytics. Google Analytics is a web analytics service offered by Google that tracks and reports application and website traffic. Google uses the data collected to track and monitor the use of the App and the Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
You can opt-out of having made your activity on the Services available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page here.
4.8 Google Firebase. We use Google Firebase (“Firebase”) with the App. Firebase provides tools for, but not limited to, authentication (including passwords, which are not stored or managed by us), tracking analytics, push notifications and crash reporting.
For more information on the privacy and security practices of Firebase, please visit the Privacy and Security in Firebase web page here.
4.9 Do Not Track. We also may use these technologies to collect information about your online activities over time and across third-party sites or other online services (behavioral tracking). We do not respond to browser-based “do not track” signals. Some third-party sites who push content to our Site may keep track of your browsing activities over time and across different sites when they serve you content, which enables them to tailor what they present to you.
5. Use of Personal Information. Kinspire uses or may use your collected Data for various purposes:
To operate, provide and improve our Services;
To send information or content to you which we think may be of interest to you by post, email, or other means and send you marketing communications relating to our business;
To promote use of our services to you and share promotional and information content with you in accordance with your communication preferences;
To send information to you regarding changes to our Terms of Use found at https://www.kinspirehealth.com/terms-of-use, this Privacy Policy or other legal agreements;
To respond to support requests as well as send you information regarding service upgrades, improvements or issues regarding the use of the App or the Site;
To gather analysis or valuable information so that we can improve the App or the Site;
To monitor the usage of the App or the Site;
To ensure network and information security
To inform you of upgrades or changes to the App or the Site; and
To detect, prevent and address technical issues.
5.1 We Never Sell Personal Information. We will never sell your Personal Information to any third party.
5.2 Use of Navigational Information. We may use Navigational Information to operate and improve the App or the Site.
5.3 Testimonials and Comments. We may post customer testimonials and comments on our Site, which may contain Personal Information. We will obtain each customer's consent via email, Instagram, Facebook, or other social network prior to posting the customer's name and testimonial.
5.4. Security of your Personal Information. The Site is hosted by Squarespace. Please review their privacy policy to understand security protocols for Squarespace – you can access the Squarespace Privacy Policy web page here. The App infrastructure is hosted by Google Cloud. Please review their privacy policy to understand security protocols for Google Cloud – you can access the Google Cloud Privacy Notice web page here. We are committed to protecting the security of your Personal Information. We use a variety of industry-standard security technologies and procedures to help protect your information from unauthorized access, use, or disclosure. But remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal information, we cannot guarantee its absolute security.
5.5. Protected Health Information (PHI).
If necessary to perform the Services, Kinspire may collect PHI, as defined by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Any use, maintenance, or disclosure of PHI by Kinspire will be in accordance with applicable laws, including HIPAA. Our Notice of Privacy Rights for Protected Health Information (the “Notice of Privacy Rights”) describing our collection, use and disclosure of your PHI is found at [INSERT LINK]. Kinspire is a “Covered Entity” (as that term is used under HIPAA). Any Personal Health Information that a Caregiver shares with Kinspire will be subject to the privacy practices as set forth in this Privacy Policy and the Notice of Privacy Rights, and Kinspire’s use and disclosure of such PHI shall be in accordance with its obligations as a “Covered Entity”. Notwithstanding the foregoing, you understand and agree that any Personal Information, including PHI, that has been de-identified in accordance with HIPAA (“De-Identified Protected Health Information”) is no longer subject to HIPAA and may be used and disclosed in any manner permitted by this Privacy Policy and applicable law.
6. Your Choices Regarding Your Information.
6.1 Choices. We offer you choices regarding the collection, use, and sharing of your information. When you receive communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive. Should you decide to opt-out of receiving future mailings, we may share your e-mail address with third parties to ensure that you do not receive further communications from these third parties. Despite your indicated e-mail preferences, we may send you emails related to your account or transactions thereunder, or notices of any updates to our Terms of Use or Privacy Policy.
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 Service may be inaccessible or not function properly. You can choose whether or not to allow the Service to collect and use real-time information about your device’s location through the device’s privacy settings. If you block the use of location information, some parts of the Service may be inaccessible or not function properly.
6.2 Changes to Information. You may change certain information in your account on your own, including, for example, your name, email, biography, professional credentials and profile image. For any information in your account you cannot change on your own, you may change such information by sending an e-mail to us at privacy@kinspireapp.com. You may request deletion of your information by us, but please note that we may be required (by law or otherwise) to keep this information and not delete it (or to keep this information for a certain time, in which case we will comply with your deletion request only after we have fulfilled such requirements). When we delete any information, it will be deleted from the active database, but may remain in our archives.
6.3 To Unsubscribe from Our Communications. You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails or by sending us email us at privacy@kinspireapp.com or at the following address:
By Postal Mail:
Kinspire Inc.
3700 QUEBEC ST #100-311
Denver, CO 80207
Attention: Privacy.
Customers cannot opt out of receiving transactional emails.
7. Links to Other Site and Mobile Applications. The App and the Site may contain links to other sites that are not operated by us, including links to our Social Media accounts on Facebook and Instagram. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.
We may maintain pages for Kinspire on social media platforms, such as Facebook, LinkedIn, Twitter, Google, YouTube, Instagram, and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use, and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
If you choose to log into the Service via a third-party platform or social media network, or otherwise connect a third-party platform or network to your account through the Service, we may collect information from that platform or network. For example, this information may include your Facebook username, user ID, profile picture, cover photo, and networks to which you belong (e.g., school, workplace, etc.). You may also have the opportunity to provide us with additional information via the third-party platform or network, such as a list of your friends or connections and your email address.
We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party site or services.
8. Service Providers. We may employ third party companies and individuals to facilitate the App or the Site, to manage the App or the Site on our behalf, to perform Support-related services or to assist us in analyzing how the App and the Site are used.
These Service Providers have access to your Personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.
9. Third-Party Payment Processor. We use a third-party payment processor to process payments made to us. In connection with the processing of such payments, we do not retain any personal information or any financial information such as complete credit card numbers. Rather, all such information is provided directly to our third-party processor, Stripe, whose use of your personal information is governed by their privacy policy, which may be viewed at stripe.com/privacy.
10. Children's Privacy
The App and the Site do not directly address anyone under the age of 16 (a "Child").
We do not knowingly collect personally identifiable information from anyone under the age of 16. If you are a parent or guardian and you are aware that your Child has provided us with Personal information, please contact us. If we become aware that we have collected Personal information from a Child without verification of parental consent we take steps to remove that information from our databases.
11 Changes to This Privacy Policy. We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.
We will let you know via email and/or a prominent notice on our Site, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.
You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.
If you have any questions, comments or concerns about our Privacy Policy, please contact us at privacy@kinspireapp.com.
12. Dispute Resolution.
If you have any questions or concerns, please contact Kinspire by e-mail at privacy@kinspireapp.com. We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. If you and Kinspire are unable to reach a resolution to the dispute, you and Kinspire will settle the dispute exclusively under the rules of the American Arbitration Association (www.adr.org) as set forth in the Terms of Use found at https://www.kinspirehealth.com/terms-of-use.
13. Supplemental Privacy Statement for California Consumers under CCPA
Introduction
Our business proudly serves or will serve certain natural persons residing in the State of California (each, a “consumer”). This California Statement explains rights that California consumers may have under the CCPA. Please note that the CCPA expressly excludes personal information regulated under the California Confidentiality of Medical Information Act (“CMIA”) and protected health information collected by a “covered entity” (e.g., Kinspire) that provides services to a covered governed by HIPAA.
When we use the term “personal information” in this supplemental California Statement, we are using that term as CCPA defines it, which CCPA generally defines “personal information” to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. However, personal information does not include publicly available, deidentified, or aggregate consumer information (which are all defined in CCPA), or (c) certain information excluded from the scope of CCPA (e.g., PHI covered under HIPAA and medical information covered under the CMIA as discussed above). Notably, the definition of “personal information” also does not apply to the collection of personal information from job applicants, employees – whether you are our employee or any employee of the entity arranging access to our Services for you, business owners, directors, officers, medical staff, or contractors.
13.1 Categories of personal information we collect, the sources of that information, purposes for why we collect it, who we share it with, and whether we sell that personal information. Where we act as a “business” under CCPA (meaning we determine the manner and reasons for why we process your personal information), we may be required to disclose additional information regarding the categories of personal information we collect, the sources where we obtain that information, the purposes for why we collect that information, who we share that information with, as well as whether we sell that personal information – all of which depends on the specific Service.
13.2. Your privacy rights.
If you are a resident of California and are not a job applicant, employee/contractor, or employee/contractor of another company interacting with us in your job role, you have the right to request what information we collect, use, and disclose. You also have the right to request that we delete your information.
To make a request, you can contact us at privacy@kinspireapp.com. Provide us enough information to verify your identity. We will use information you provide to us to verify your request. If we cannot initially verify your identity, we may request additional information to complete the verification process, such as, for example, a copy of your driver’s license and/or a recent utility or credit card bill. You can designate an agent to make a request on your behalf by either: (1) having your agent send us a letter, signed by you, certifying that the agent is acting on your behalf and showing proof that they are registered with the California Secretary of State; or (2) by you and the agent executing and sending us a notarized power of attorney stating that the agent is authorized to act on your behalf. Please note that we may still require you to verify your identity before we process a request submitted by your agent.
California residents also have certain rights regarding the sale of personal information. California residents have the right to opt out of the sale of their personal information by contacting us at privacy@kinspireapp.com.
We will not discriminate against you because you have exercised any of your privacy rights under the CCPA.