Privacy Policy

Effective Date: November 7, 2022

POPULATE EMR INC. PRIVACY POLICY

Populate EMR Inc. (“Populate”, “we”, us” or “our”) is committed to protecting the privacy and security of your personal information.  This Populate Privacy Policy (“Privacy Policy”) describes the types of personal information and other information we collect from and about you when you interact with us or when you use our platform, websites, apps, or other services (collectively, the “Services”), and how we use and share your personal information.

 

Personal Information We Collect

The types of information that we may collect and receive from you while you use the Services are described in this section and include both information that you provide to us, information that we collect automatically when you use the Services, and information that we collect from third-party sources.

 

Personal Information: Personal information is information from which an individual can be identified directly or indirectly. We may collect personal information that you provide to us through our Services. For example, you may provide your personal information to us: (1) through your completing forms or setting up accounts on our platform, websites and apps; (2) through an enrollment form to register for one of our programs or services; (3) through your requests to receive marketing materials and information about our products or services; (4) by contacting the Populate customer service department; or (6) by responding to Populate questionnaires or surveys.

 

Personal information may include information such as:

  • Name, username, email address, telephone number, and home, business, and billing addressees (including street and postal code);

  • Government issued Identification, such as driver’s license number, government or national ID number, country of residence, and tax identification number;

  • Payment information, such as bank account and routing numbers, credit card number, billing address, or other financial account information;

  • Birth date and gender information;

  • Geolocation information;

  • Biometrics, such as facial, fingerprint, voice or other biometric information;

  • Images, including facial photographs, videos, voice and other recordings;

  • Social media account information;

  • Communications with us, such as recordings of calls with our customer service representatives for quality assurance and training purposes; and

  • Searches you conduct, transactions, and other interactions with you on our Services;

 

Technical Information: When you install any of our apps or use our platform or websites, we automatically collect the following types of information from your device:

  • IP address

  • Device type

  • Unique device identification numbers

  • Internet browser-type, such as Firefox, Safari, Chrome, and Internet Explorer

  • Internet Service Provider

  • Operating System

  • Mobile carrier

  • How your device has interacted with our online services, including the pages accessed, links clicked, and features used, along with associated dates and times

  • Details of any referring website or exit pages, as well as general geographic location (such as at the country or city-level)

 

Cookies and other similar technologies: When you use our Services, we may also collect information relating to your usage or visits to our platform, websites, apps and your devices. This information is generally collected using server log files, cookies, “pixel tags,” and Google Analytics[TM1] .

 

Server Log Files: Your Internet Protocol (IP) address is an identifying number that is automatically assigned to your computer by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit our websites, along with the time(s) of your visit(s) and the page(s) that you visited. We use the IP addresses of all visitors to our websites to calculate our websites’ usage levels, to help diagnose problems with website servers, and to administer the websites. We may also use IP addresses to communicate with or block access by visitors who fail to comply with our Terms of Use. Collecting IP addresses is standard practice on the Internet and is carried out automatically by many websites.

 

Cookies: Cookies are data that a web server transfers to an individual’s computer for record-keeping purposes. Cookies are an industry standard used by most websites and help facilitate users’ ongoing access to and use of a particular website. Cookies do not cause damage to your computer systems or files, and only the website that transferred a particular cookie to you can read, modify, or delete such cookie. If you do not want information collected using cookies, there are simple procedures in most browsers that allow you to delete existing cookies, to automatically decline cookies, or to be given the choice of declining or accepting the transfer of cookies to your computer (see our on-line Cookie Policy about our use of cookies[TM2] ). You can set your browser to refuse cookies, but some portions of our websites may not work properly if you refuse cookies. A session cookie is one that exists for the time-period that your browser is open. A persistent cookie is one that is saved on your device/computer even after the browser is closed.  Like many websites, we may use both session cookies and persistent cookies.

 

Pixel Tags: Our websites may use so-called “pixel tags”, “web beacons”, “clear GIFs” or similar means (collectively, “Pixel Tags”) to compile aggregate statistics about website usage and response rates. Pixel Tags allow us to count users who have visited certain pages on our websites, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.

 

Google Analytics: We may use Google Analytics, a web analysis service provided by Google, to better understand website usage. Google Analytics collects information such as how often users visit websites, what pages they visit and what other websites they used prior to visiting. Google uses the data collected to track and examine the use of the websites, to share such data with other Google services, or to personalize the ads of its own advertising network. Google’s ability to use and share information collected by Google Analytics is restricted by the Google Analytics Terms of Service and the Google Privacy Policy. To opt-out of analysis by Google Analytics on our websites, please visit //tools.google.com/dlpage/gaoptout.

 

Mobile Apps: [TM3] When you download and use any of our mobile apps, we collect certain technical information from your device to enable the app to work properly and as otherwise described in this Privacy Policy. That technical information includes:

  • Device and telephone connectivity information such as your carrier, network type, network operator, subscriber identity module ("SIM") operator, and SIM country;

  • Operating system and version;

  • Device model;

  • Performance and usage data, such as dates and times the app accesses our servers, the features and links clicked in the app, searches, transactions, and the data and files downloaded to the app;

  • Device settings selected or enabled, such as Wi-Fi, Global Positioning System ("GPS"), and Bluetooth which may be used for location services;

  • Mobile device settings;

  • Other technical information such as app name, type, and version as needed to provide

             you with services;

 

Permissions for Location-Based Services: Depending on your device’s settings and permissions and your choice to participate in certain programs, we may collect the location of your device by using GPS signals, cell phone towers, Wi-Fi signals, Bluetooth or other technologies. We will collect this information, if you opt in through the app or other program (either during your initial login or later) to enable certain location-based services available within the app (for example, locating available lodging closest to you). To disable location capabilities of the app, you can log off or change your mobile device’s settings.

 

Our Uses of Your Personal Information

The personal information that is collected in connection with our Services may be used in any of the following ways:

  • Help you to use our Services through features like the ability to sign-in using your account within our online services and websites;

  • To respond to your requests for information about our products or services; 

  • To provide you with marketing communications whether about a particular Populate product or service or concerning general services information; 

  • To contact you, such as by text message, email, phone calls, mail, push notifications, or messages on other communication platforms;

  • Create, maintain, and update user accounts on our platform and authenticate you as a user;

  • To determine if you are eligible for certain products, services, or programs; 

  • To manage or develop our business relationship with you (e.g., to respond to questions, comply with regulatory obligations, or determine eligibility for Populate programs); 

  • To recruit and/or consider you for employment; 

  • Create aggregated or otherwise anonymized or deidentified data, which we may use and disclose without restriction where permitted by law;

  • For our research, development, and collaboration efforts; and

  • For business purposes, such as payment processing and financial account management, product or service development, contract management, website administration, fulfillment, analytics, fraud prevention, corporate governance, reporting, and legal compliance.

 

The information that we collect from your devices is used to better design our websites. We analyze the information we collect to enhance our websites’ security and to track the popularity of certain pages on the websites, the success of our email notifications, traffic levels on the websites, and other usage data, all of which helps us to provide content tailored to your interests and improve our websites and related Services.

 

How We Share Your Personal Information

Third-Parties: We share personal information with third-parties in connection with the delivery of our Services to you and for the operation of our business. For example, to provide credit card processing, customer service, business analytics, and fraud prevention and compliance services. These third-party service providers are required to protect the personal information we share with them and may not use any directly identifying personal information other than to provide services we contracted them for. They are not allowed to use the personal information we share for purposes of their own direct marketing (unless you have separately consented with the third-party under the terms provided by the third-party and you should review their Privacy Policies for further information on their handling of your personal information). We may also share your personal information with third-parties with whom we have contracted, as well as affiliates and business partners. We will require these recipients to use your personal information only for appropriate purposes and take appropriate measures to protect your personal information.

 

Business partners and offers:  If we promote a program or offer a service or product in conjunction with a third-party business partner, we will share your information with that partner to assist in marketing or to provide the associated product or service.  In most of those cases, the program or offer will include the name of the third-party business partner, either alone or with ours, or you will be redirected to the website of that business with notice.

 

Mergers or Acquisitions: In the event that we sell or transfer all or a portion of our business or assets to a third-party, such as in the event of a corporate sale, merger, reorganization, dissolution or similar event, we may transfer information that we have collected to such third-party.  We will require such a third-party to continue to comply with this Privacy Policy.

 

Compliance with Applicable Laws: We may disclose information if we believe it is necessary: (a) to comply with any law applicable to us, a request from law enforcement, a regulatory agency, or other legal process; (ii) to protect the legitimate rights, privacy, property, interests, or safety of Populate, our business partners, personnel, or the general public; (iii) to pursue available remedies or limit damages; (iv) to enforce our Terms of Use; or (v) to respond to an emergency. We reserve the right to disclose personal information when we believe in good faith that such action is necessary to comply with a legal obligation.

 

Other Parties With Your Consent or At Your Direction: In addition to the disclosures described in this Privacy Policy, we may share information about you with third-parties when you consent to or request such sharing.

 

Third Party Advertising

Populate has relationships with third-party advertising companies to place advertisements on its website and other websites, and to perform tracking and reporting functions for its websites. These third-party advertising companies may place cookies on your computer when you visit our websites or other websites so that they can display targeted advertisements to you. These third-party advertising companies do not collect personal information in this process, and we do not give any personal information to them as part of this process. However, This Privacy Policy does not cover the collection methods or uses of the data collected by these third-parties. For more information about third-party advertising, please visit the Network Advertising Initiative (NAI) at www.networkadvertising.org.

 

Links To Other Websites

Our websites may contain links to third-party websites, which are not operated or controlled by Populate and for which Populate is not responsible. The links from the websites do not imply that Populate endorses or has reviewed the third-party websites. Once you have left one of our websites, we are not responsible for the protection and privacy of any information you provide.  We suggest contacting those third-party websites directly for information on their privacy practices.

 

Children's Privacy Protection

Protecting the privacy of children is especially important to us. We take seriously our obligations under applicable laws concerning the collection of personal information from children. Our Services are not directed at children and we do not knowingly allow children to communicate with us or use any of our websites or Services.  We request that children not provide any personal information through our websites or in connection with the Services.  If you are a parent and become aware that your child has provided us with personal information, please contact us at privacy@populate.com[TM4] .

 

Data Security

Populate stores personal information and other data using reasonable physical, technical and administrative safeguards to secure data against foreseeable risks, such as unauthorized use, access, disclosure, destruction or modification.  Please note, however, that while Populate has endeavored to create secure and reliable websites for our users, the confidentiality of any communication or material transmitted to or from one of our websites, texts or via e-mail cannot be guaranteed.

 

You should take special care in deciding what information you transmit, upload, send, or otherwise submit to Populate.

 

In case of a personal information security incident, as required by applicable laws, we will inform you in a timely manner and report the incident to the relevant regulatory authorities.

 

We retain your information for as long as it is necessary for the purposes set out in this Privacy Policy, unless required by our legal obligations to retain it for a longer period.

 

Changes to this Privacy Policy

We may update this Privacy Policy from time to time. At a minimum, we will post an updated version here. Populate encourages you to review this Privacy Policy regularly for any changes. Any changes will be effective immediately upon posting of the revised Privacy Policy, and your continued use of our platform, websites, apps or our Services will be subject to the then-current Privacy Policy.

 

Contact Us

If you have any questions about this Privacy Policy or about our handling of your personal information, please contact us at privacy@populate.com.

 [TM1]Hi Chance - Do you currently or are you planning to use Google Analytics? If you do not know for certain but may plan to do so, lets leave this in. It doesn’t hurt to include it even if you aren’t using it yet.

 

 [TM2]Hi Chance: We will also need to put together your Cookie Policy separate from this Privacy Policy.

 [TM3]Hi Chance: I typically include this section even if you do not have any mobile apps. At some point in the future, you may develop one or many, so this will be here when you need it. It doesn’t hurt to include it even if you do not have any apps yet.

 [TM4]Hi Chance. We will need to set up an email mailbox for privacy purposes. Whatever address you decide should be included here.