Firefly Health Privacy Policy

‍Last Modified: May 21, 2020
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Welcome to the website (the “Website”) for Firefly Health, Inc. (“Firefly Health” ”we”, “us” and/or“our”).  This Website is operated by Firefly Health and has been created to provide information about our company and the services we offer, including those made available through our mobile applications (together with the Website, the “Services”), to our visitors and users (“you”, “your”).  Firefly Health respects your privacy and is committed to protecting it as outlined in this Privacy Policy.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you use our Services, including your personally identifiable information (“Personal Information”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

‍This Privacy Policy does not cover the collection, use or disclosure of protected health information (“PHI”).  A complete description of the purposes for which Firefly Health uses and discloses any PHI collected from you is described fully in its Notice of Privacy Practices or any other applicable notices provided to you.‍

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, you may not use our Services. By accessing or using our Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of our Services after we make changes is deemed to be acceptance of those changes. Please review this Privacy Policy periodically for updates.  

‍Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Services, including:

• Information that you provide by filling in forms on our Services. This includes information provided at the time of registering to use our Services, subscribing to our newsletter, or requesting further services. We may also ask you for information when you submit comments to us or you report a problem with our Services.
• Records and copies of your correspondence (including email addresses), if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Details of transactions you carry out through our Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Services.

By voluntarily providing us with Personal Information, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Information through our Services, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Firefly Health and the authorized third parties referred to herein located in the United States.

Use of Cookies and Other Tracking Technologies

Firefly Health may use cookies to help provide additional functionality to our Services or help us analyze Services usage more accurately to understand your preferences for future visits, such as to help us keep track of advertisements and compile data about site traffic via third-party providers. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on, as turning off cookies may negatively impact your experience using the Services.  

We may, and we may allow third party service providers to, use cookies (as noted above) or other tracking technologies, such as web beacons, to collect information about your browsing activities over time and across different websites following your use of our Services, including for advertising and reporting purposes. For example, we may use Google Analytics to track visitors to our Website. If you do not wish to be tracked by Google Analytics, you can use the Google Analytics Opt-Out Browser add-on, located here.  Firefly may also use the Facebook Pixel to track visitors to our Services.

Third Party Processors

‍Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processors include:
(i) Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733. You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.

How We Use Your Information

We use the Personal Information you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Information for a certain reason, we may use the Personal Information in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Information you provide to answer your question or resolve your problem. We may also use information that we collect about you or that you provide to us, including any Personal Information:

• To provide our Services to you.
• To improve, perform maintenance on, or troubleshoot any problems with our Services.
• To provide you with information, products, or services that you request from us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our Services or any products or services we offer or provide through it.
• To notify you of products or services which we think may be of interest to you.
• To allow you to participate in interactive features of our Services.
• To enforce our Terms of Use, and to detect and protect against error, fraud and other unauthorized or illegal activities.
• In any other way, we may describe when you provide the information.
• For any other purpose with your consent.

Disclosure of Your Information

We may disclose information that we collect or you provide, including any Personal Information, without further notice to you, as set forth below:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business, including our advertising and marketing efforts.
• 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 Firefly Health’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which such information held by Firefly Health about our Services users is among the assets transferred.
• To fulfill the purpose for which you provide it. 
• For any other purpose disclosed by us prior to the provision of your information.
• With your consent.

We may also disclose your information, including any Personal Information:

• To comply with any court order, law, or legal process, including responding to any government or regulatory request.
• To enforce or apply our Terms of Use and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Firefly Health, our customers, or others. 

Aggregated or De-Identified Personal Information

We may use and disclose aggregated and/or de-identified information about our users that does not identify any particular individual for any legal purpose, without restriction.  For example, we may conduct research on our customer demographics, interests and behavior based on the Personal Information and other information provided to and/or collected by us, and may aggregate and share this aggregate data with our affiliates, agents and business partners.

Accessing and Correcting Your Personal Information

You may send us an email at info@firefly.health to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change Personal Information if we believe the change would violate any law or legal or contractual requirement or cause the Personal Information to be incorrect. 

Data Security

We have implemented commercially reasonable measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on servers behind firewalls. 

The safety and security of your information also depend on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Services, you are responsible for keeping this password confidential and not disclosing your password to any third parties. 

Unfortunately, the transmission of information via the internet is not completely secure. Although we take commercially reasonable steps designed to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures employed by the Services.

Our Website currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.

Children Under the Age of 13

Our Services are not intended for children under 13 years of age. We do not knowingly collect Personal Information from children under the age of 13. If you are under 13, you may not use our Services. If you have reason to believe that a child under the age of 13 has provided Personal Information to us, please contact us and we will endeavor to delete that information from our databases.

Links to Other Websites  

This Privacy Policy applies only to our Services. Our Services may contain links to other websites or applications not operated or controlled by us (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from our Services do not imply that we endorse or have reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page with a notice that this Privacy Policy has been updated.  This Privacy Policy was last updated on the date indicated above.  If we make material changes to how we treat our users’ Personal Information, we will notify you through a notice made available on our Services. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, please email us at info@firefly.health or write to us at Firefly Health, 101 Walnut St. Watertown, MA 02472.