Truveta.com Privacy Notice
Last Updated: November 2021
Truveta Inc. is committed to respecting your privacy. This Privacy Notice (“Notice”) describes Truveta’s processing of personal information, including how we collect, use, or otherwise process information, with respect to visitors of our website (Truveta.com).
This Notice does not apply to usage of the Truveta Platform, our platform for conducting research. (The Truveta Platform has its own privacy notice.) This Notice also does not apply to patient information we process on behalf of our member health care systems or the anonymized health information in the Truveta Platform. If you are a patient of a member health system, you should read that system’s privacy notice and direct any privacy inquiries to them. Further, this Notice does not apply to personal information collected in relation to employment applications for positions with Truveta.
PERSONAL INFORMATION WE COLLECT
The personal information we collect depends on how you interact with our website and the choices you make.
We collect information about you from different sources and in various ways when you use the website, including information you provide directly, information collected automatically, information we obtain from third-party data sources and data we infer or generate from other data.
Information you provide directly. We collect personal information you provide to us. For example:
- Name and contact information. We collect name, username or alias, email address, postal address, and phone number.
- Demographic data. In some cases, such as when you register for an event or participate in surveys, we request that you provide additional demographic details.
- Communications content. If you send us email messages or other communications, we retain those communications.
Information we collect automatically. When you visit our website, we collect some information automatically. For example:
- Identifiers and device information. When you visit our website, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device’s operating system, browser, and other software including type, version, language, settings, and configuration. As further described in the Cookies and Similar Technologies section below, our website stores and retrieves cookie identifiers and other data.
- Geolocation data. Depending on your device settings, we may collect geolocation data.
- Usage data. We log activity on our website, including the URL of the website from which you came to our site, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website.
Information we create or generate. We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.
Information we obtain from third-party sources. We also obtain information from third parties. These third-party sources include, for example:
- Data brokers. Data brokers and aggregators from which we obtain data to supplement the data we collect.
- Third-party partners. Third-party applications and services, including social networks you choose to connect with or interact with through our website.
- Co-branding/marketing partners. Partners with which we offer co-branded services or engage in joint marketing activities.
- Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device’s location based on its IP address.
- Publicly available sources. Public sources of information such as open government databases.
When you are asked to provide personal information, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain website features, those features may not be available or fully functional.
COOKIES AND SIMILAR TECHNOLOGIES
What are cookies and similar technologies?
Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.
Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies. In the same way, third-party content on our website (such as embedded videos or plug-ins) results in your browser connecting to the third-party web server that hosts that content. We also include web beacons in our email messages or newsletters to tell us if you open and act on them.
We, and our analytics and advertising partners use these technologies in our website to collect personal information (such as the pages you visit, the links you click on, and similar usage information, identifiers, and device information). This information is used to store your preferences and settings, analyze how our website performs, track your interaction with our website, develop inferences, deliver and tailor relevant advertising about Truveta, combat fraud, and fulfill other legitimate purposes.
The third-party analytics and advertising providers we use on our website include, for example:
To learn about their privacy practices and how to opt-out from their use of cookie data for targeted advertising purposes, click on the links above. You may also use the advertising and cookie controls described below.
What controls are available?
- Advertising controls. Our advertising partners may participate in associations that provide simple ways to opt-out of ad targeting, which you can access at:
- United States: Network Advertising Initiative (http://optout.networkadvertising.org) and Digital Advertising Alliance (http://optout.aboutads.info/)
- Canada: Digital Advertising Alliance of Canada (https://youradchoices.ca/)
- Europe: European Digital Advertising Alliance (http://www.youronlinechoices.com/)
These choices are specific to the browser you are using. If you access our website from other devices or browsers, take these actions from those systems to ensure your choices apply to the data collected when you use those systems.
- Browser cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features of our website. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
- Email web beacons. Most email clients have settings which allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.
- Do Not Track. Some browsers have incorporated “Do Not Track” (DNT) features that can send a signal to the websites you visit indicating you do not wish to be tracked. Because there is not a common understanding of how to interpret the DNT signal, our website does not currently respond to browser DNT signals. Instead, you can use a range of other tools to control data collection and use, including the cookie controls and advertising controls described above.
OUR USE OF PERSONAL INFORMATION
We use the personal information we collect for the purposes described in this Privacy Notice or otherwise disclosed to you. For example, we use each of the categories of personal information for the following purposes:
- Product and service delivery. To provide and deliver our website, including troubleshooting, improving, and personalizing the website.
- Business operations. To operate our business, such as billing, accounting, improving our internal operations, securing our systems, detecting fraudulent or illegal activity, and meeting our legal obligations.
- Product improvement, development, and research. To develop new services or features, and conduct research.
- Personalization. To understand you and your preferences to enhance your experience using the website.
- Customer support. To provide customer support and respond to your questions.
- Communications. To send you information, including confirmations, technical notices, updates, security alerts, and support and administrative messages.
- Marketing. To communicate with you about offers, promotions, upcoming events, and other information about our Services (see the Choice and Control section of this Notice for how to change your preferences for promotional communications).
- Advertising. To display relevant advertising to you, for example for “retargeting” where you might visit our website and then later see an ad for Truveta (see the Cookies section of this Notice for information about personalized advertising and your advertising choices).
We combine data we collect from different sources for these purposes and to give you a more seamless, consistent, and personalized experience.
OUR SHARING OF PERSONAL INFORMATION
We share personal information with your consent or as necessary to provide the services you have requested or authorized. In addition, we share each of the categories of personal information described above, with the types of third parties described below, for the following business purposes:
- Service providers. We share personal information with vendors or agents working on our behalf for the purposes described in this Notice. For example, companies we’ve hired to host our website or assist in protecting and securing our systems may have access to personal information as part of providing those functions.
- Legal and law enforcement. We will access, disclose, and preserve personal information when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.
- Security, safety, and protecting rights. We will disclose personal information if we believe it is necessary to:
- protect our customers and others, for example to prevent spam or attempts to commit fraud, or to help prevent the loss of life or serious injury of anyone;
- operate and maintain the security of our website and related infrastructure, including to prevent or stop an attack on our computer systems or networks; or
- protect the rights or property or ourselves or others, including enforcing our agreements, terms, and policies.
Third-party analytics and advertising companies also collect personal information through our website including identifiers and device information (such as cookie IDs, device IDs, and IP address), geolocation data, usage data, and inferences based on and associated with that data as described in the Cookies section of this Notice.
Please note that our website may include integrations, references, or links to services provided by third parties whose privacy practices differ from ours. If you provide personal information to any of those third parties, or allow us to share personal information with them, that data is governed by their privacy notices.
Finally, we may share de-identified information in accordance with applicable law.
CHOICE AND CONTROL OF PERSONAL INFORMATION
Access, correction, and deletion. If you wish to access, correct, or delete personal information about you that we hold, you may contact us as described at the bottom of this Privacy Notice. However, to the extent permitted by applicable law, we reserve the right to decline requests that are unreasonable or excessive, where providing the data would be prohibited by law or could adversely affect the privacy or other rights of another person, where deleting data would interfere with a legal or business obligation that requires retention of the data, or where we are unable to authenticate you as the person to whom the data relates.
Communications preferences. You can choose whether to receive promotional communications from us by email, SMS, and telephone. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message or by contacting us as described in the Contact Us section below. If you receive a sales call from us, you can ask to be placed on our do-not-call list. These choices do not apply to certain informational communications including surveys and mandatory service communications.
Choices for Cookies and Similar Technologies. See the Cookies section for choices about cookies and other analytics and advertising controls.
EUROPEAN DATA PROTECTION RIGHTS
If the processing of personal information about you is subject to European Union data protection law, you have certain rights with respect to that data:
- You can request access to, and rectification or erasure of, personal information;
- If any automated processing of personal information is based on your consent or a contract with you, you have a right to transfer or receive a copy of the personal information in a usable and portable format;
- If the processing of personal information is based on your consent, you can withdraw consent at any time for future processing;
- You can to object to, or obtain a restriction of, the processing of personal information under certain circumstances; and
- For residents of France, you can send us specific instructions regarding the use of your data after your death.
To make such requests, please use the contact information at the bottom of this Notice. When we are processing data on behalf of another party that is the “data controller,” you should direct your request to that party. You also have the right to lodge a complaint with a supervisory authority, but we encourage you to first contact us with any questions or concerns.
We rely on different lawful bases for collecting and processing personal information about you, for example, with your consent and/or as necessary to provide the website, operate our business, meet our contractual and legal obligations, protect the security of our systems and our customers, or fulfill other legitimate interests.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (“CCPA”), you have certain rights with respect to that information.
Right to Know. You have a right to request that we disclose to you the personal information we have collected about you. You also have a right to request additional information about our collection, use, disclosure, or sale of such personal information. Note that we have provided much of this information in this Privacy Notice.
Right to Request Deletion. You also have a right to request that we delete personal information under certain circumstances, subject to a number of exceptions.
Right to Opt-Out. The CCPA also provides for a right to opt-out from future “sales” of personal information. Note that we do not “sell” personal information as defined by the CCPA and have never done so.
To make a “request to know” or a request to delete, you may contact us as indicated at the bottom of this Notice. To provide or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you to send it from the email address associated with your account or requiring you to provide information necessary to verify your account. For some types of personal information we may have, such as logs of website usage by unauthenticated visitors, there is no reasonable method by which we can verify your identity as the person to whom that data relates.
You may also designate, in writing or through a power of attorney, an authorized agent to make requests on your behalf to exercise your rights under the CCPA. Before accepting such a request from an agent, we will require the agent to provide proof you have authorized it to act on your behalf, and we may need you to verify your identity directly with us.
Finally, you have a right to receive notice of our practices at or before collection of personal information, and you have a right to not be discriminated against for exercising these rights set out in the CCPA.
RETENTION OF PERSONAL INFORMATION
We retain personal information for as long as necessary to provide the website, comply with our legal obligations, resolve disputes, enforce our agreements, and other legitimate and lawful business purposes.
LOCATION OF PERSONAL INFORMATION
The personal information we collect is stored and processed in the United States, and may also be processed in other countries where we or our service providers maintain facilities. We take steps designed to ensure that the data we collect under this Notice is processed and protected according to the provisions of this Notice and applicable law wherever the data is located.
Location of Processing European Personal information. When we transfer personal information from the European Economic Area (EEA), UK, and Switzerland to other countries, including the United States, which have not been determined by the European Commission to have an adequate level of data protection, we use legal mechanisms, including contracts, to help ensure your rights and protections. To learn more about the European Commission’s decisions on the adequacy of personal information protection, please visit: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en.
SECURITY OF PERSONAL INFORMATION
We take reasonable and appropriate steps to help protect personal information from unauthorized access, use, disclosure, alteration, and destruction.
CHANGES TO THIS PRIVACY NOTICE
We will update this Notice when necessary to reflect changes in our website, how we use personal information, or the applicable law. When we post changes to the Notice, we will revise the “Last Updated” date at the top of the Notice. If we make material changes to the Notice, we will provide notice or obtain consent regarding such changes as may be required by law.
HOW TO CONTACT US
If you have a privacy concern, complaint, or a question for Truveta, please contact us at firstname.lastname@example.org.
Our address is: 1745 114th Ave SE, Bellevue, Washington 98004, USA