Privacy Policy

Effective: [July 3, 2020] 

1. OVERVIEW

1.1 Purpose

Aloe Care Health, Inc. and its current and future operating divisions, subsidiaries, affiliates, and branches (collectively, “Aloe Care,” “we,” or “us”) are sensitive to privacy issues, and it is important to us to protect the information provided to us. Accordingly, Aloe Care provides this privacy policy (the “Policy”) to inform you about our information practices, the kinds of information we may collect, how we intend to use and share that information, and how you can correct or change such information.

1.2 Scope

This Policy applies to Personal Information that is Processed by Aloe Care in the course of our business, including on Aloe Care websites, mobile applications, voice applications, devices and other offerings (together with any and all future offerings operated by or on behalf of Aloe Care, the “Services”). 

2. Transparency / Notice–Types of Personal Information We Collect and How We Use It

The categories of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with Aloe Care and the requirements of applicable law. We endeavor to collect only that information which is relevant for the purposes of Processing. Below are some of the ways we collect information and how we use it.

2.1 Types of Personal Information We Collect

Aloe Care collects Personal Information from Care Recipients, Caregivers, Purchasers, Dealers and Individuals who interact with Aloe Care online or offline (collectively “Individuals”).

2.1.1 Care Recipients

(a) Information You Provide Directly to Us

When you use the Services or engage in certain activities, such as registering for an account with Aloe Care, requesting Services or information, or contacting us directly, you may provide or we may ask you to provide some or all of the following types of information:

  • Contact information, such as name, email address, telephone or mobile number, and physical (billing and/or shipping) address;

  • Username and password;

  • Information about your home WiFi, including network password;

  • Location information as provided by your device or browser, such as your device's GPS signal or information about nearby WiFi access points;

  • Demographic information, such as your gender, ZIP code, and details about your personal preferences, interests, and characteristics;

  • Health information, including information about your medical conditions, health history, treatment and medication history, medical records, and health insurance information. Any health information that is tied to an Individual will be treated as Personal Information, provided that any Protected Health Information will be protected in accordance with the requirements of HIPAA, if and to the extent applicable;

  • Payment information, such as credit card number, expiration date, and credit card security code, where needed to complete a transaction; and

  • Requests and other correspondence you send to us.

Additionally, in some cases, Aloe Care is obligated to collect certain Personal Information to comply with regulatory requirements, including information relating to adverse effects you have experienced when using our products.

You can choose not to provide information to us directly, but some of this information is required to participate in some of the Services, and some Services may not function properly if you choose not to provide the information requested.

(b) Information We Obtain from Other Sources

We may receive information about you from other sources, including through your Caregivers, the Purchaser, Dealers, other sites to which you give us access, and Third-Party services and organizations. 

Aloe Care may collect information about your health condition, diagnosis, and treatment from your healthcare professional (e.g., a doctor), but only where your healthcare professional has obtained your consent to disclose that information to us, as required by law. 

Aloe Care may also collect information about you (including any of the information listed in Section 2.1.1(a)), your health condition, diagnosis, and/or treatment from the Purchaser, a Dealer, a Co-Brand or White Label Partner and/or your Caregivers. In some cases, the Purchaser, a Dealer, Co-Brand or White Label Partner and/or your Caregivers will be responsible for obtaining your consent to disclose that information to us.

If you, the Purchaser, a Dealer, or one of your Caregivers connect your Aloe Care account with one or more electronic health/medical record (“EMRs”), we will periodically collect information about your health condition, diagnosis, and treatment from such EMRs.

We may receive information about you from other sources, including (i) other fitness, health-monitoring and wearable smart devices and sites to which you give us access to synch accounts and information, (ii) Third-Party health, advertising and social media services and organizations to register you and/or deliver the Services, (iii) insurance companies, employers and other third-parties relating to eligibility or payment/reimbursement of device, monitoring and/or costs and (iv) a Dealer or Co-Brand or White Label Partner from whom the Purchaser or a Care Recipient may purchase the Aloe Care device and Services.

Additionally, if you access Third-Party services to login to the Services or to share information with Aloe Care, we may collect information from these Third-Party services.

2.1.2 Caregivers

(a) Information you Provide Directly to Us

When you use the Services or engage in certain activities, such as registering for an account with Aloe Care, requesting services or information, or contacting us directly, we may ask you to provide some or all of the following types of information:

  • Contact information, such as name, email address, telephone or mobile number, and physical (billing and/or shipping) address;

  • Username and password;

  • Location information as provided by your device or browser, such as your device's GPS signal or information about nearby WiFi access points;

  • Demographic information, such as your gender, ZIP code, and details about your personal preferences, interests, and characteristics; 

  • Your relationship to the Care Recipient;

  • Payment information, such as credit card number, expiration date, and credit card security code, where needed to complete a transaction; and

  • Requests and other correspondence you send to us.

Additionally, in some cases Aloe Care is obligated to collect certain Personal Information to comply with regulatory requirements, including information relating to adverse effects you or the Care Recipient have experienced when using our products.

(b) Information We Obtain from Other Sources about You

We may receive information about you from other sources, including other sites to which you give us access and Third-Party services and organizations. 

Aloe Care may also collect information about you from other sources, including (i) other Caregivers in order to carry out the Services and (ii) a Dealer or Co-Brand or White Label Partner from whom the Purchaser may purchase the Aloe Care device and Services. 

Additionally, if you access Third-Party services to login to the Services or to share information about your experience with Aloe Care, we may collect information from these Third-Party services.

2.1.3 Health Care Providers

Aloe Care may collect various information from and about healthcare professionals as part of marketing activities to healthcare professionals, including first name, last name, age, gender, home address, home phone number, medical specialization, professional qualifications, license number and scientific society membership number. 

2.1.4 Purchasers

(a) Information You Provide Directly to Us

If you make a purchase from Aloe Care, we may ask you to provide some or all of the following types of information:

  • Contact information, such as name, email address, telephone or mobile number, and physical (billing and/or shipping) address;

  • Username and password;

  • Payment information, such as credit card number, expiration date, and credit card security code, where needed to complete a transaction; and

  • Requests and other correspondence you send to us.

(b) Information We Obtain from Other Sources 

We may receive information about you from other sources, including Dealers, Co-Brand or White Label Partners and/or other sites to which you give us access and Third-Party services and organizations. 

Additionally, if you access Third-Party services to login to the Services or to share information about your experience with Aloe Care, we may collect information from these Third-Party services. 

2.1.5 Other Individuals who Interact with Aloe Care

When you use the websites or engage in certain activities, such as registering for an account with Aloe Care on behalf of a Care Recipient, requesting information, or contacting us directly, we may ask you to provide some or all of the following types of information:

  • Contact information, such as name, email address, telephone or mobile number, and physical address;

  • Name of your employer, if you are a Dealer or as otherwise applicable;

  • Username and password;

  • Location information as provided by your device or browser, such as your device's GPS signal or information about nearby WiFi access points;

  • Demographic information, such as your gender and ZIP code; and

  • Requests and other correspondence you send to us.

2.1.6 Other Information Aloe Care May Collect Directly

Customer Service and Support. If you call or otherwise interact with our customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.   

Surveys and Feedback.  We may contact you to participate in surveys or provide feedback. If you decide to participate, you may be asked to provide certain information, which may include personal information.

Interactive Features.  We may offer interactive features such as commenting functionalities, “likes”, chat services, review forums, tips, and social media pages. Aloe Care may collect the information you submit or make available through these interactive features. Any information you share on the public sections of these channels will be considered “public” and is not subject to privacy protections referenced herein. Aloe Care may use any of your public reviews along with your member profile name. 

Conferences, Trade Shows, and other Events. We may attend conferences, trade shows, and other events where we collect personal information from individuals who interact with or express an interest in Aloe Care and/or the Services. If you provide us with any information at one of these events, we will use it for the purposes for which it was collected. 

Registration for Sweepstakes or Contests. We may run sweepstakes and contests. Contact information you provide may be used to reach you about the sweepstakes or contest and for other promotional, marketing and business purposes, if permitted by law. In some jurisdictions, we are required to publicly share information of winners.

2.2 Information We Collect Automatically from Caregivers, Care Recipients, Purchasers, and Individuals Who Interact with Aloe Care 

Through the use of our device, sensors and the Services, we collect certain information about your environment, such as room temperature, air quality, motion around and activities, frequency and duration of such activities within the environment, the presence of pets, and voice(s) and voice commands when communicating through the sensors. In addition, we may collect certain information automatically through our Services , such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other identifiers, and other device identifiers that are automatically assigned to your computer or device when you access the Internet, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the services, and other actions taken through use of the Services. Information we collect may be associated with accounts and other devices.

In addition, we may automatically collect data regarding your use of our Services, such as the types of content you interact with and the frequency and duration of your activities.  We may combine your information with information that other people provide when they use our Services.

Cookies, Pixel Tags/Web Beacons and Analytics Information.  We, as well as third parties that provide content or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services.  Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us and our partners to record certain pieces of information whenever you visit or interact with our Services.

  • Cookies

    .

     

    Cookies are small text files placed in visitors’ computer browsers to store their preferences.

     

    Most browsers allow you to block and delete cookies.

     

    However, if you do that, the Services may not work properly.

  • Pixel Tags/Web Beacons

    .

     

    A pixel tag (also known as a web beacon) is a piece of code embedded in the Services that collects information about users’ engagement on that web page.

     

    The use of a pixel allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement.

  • Analytics

    .

     

    We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services.

     

    For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/.

     

    You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout

2.3 How Aloe Care Uses Personal Information

We acquire, hold, use, and Process Personal Information for a variety of business purposes as outlined in this Policy, including: 

  • To Provide Products, Services, or Information Requested: Aloe Care may use information about you to provide and fulfill requests for products, Services, or information, including information about potential or future Services, including to:

  • Generally manage Individual information and accounts;

  • Respond to questions, comments, and other requests; 

  • Provide access to certain areas, functionalities, and features of Aloe Care’s Services; 

  • Undertake activities to verify or maintain the quality or safety of a Service or device;

  • Allow you to register for events;

  • Correlate changes in your activity to other information you provide or that we have accessible relating to your health (e.g., changes in your medication) to better monitor your health condition.

  • Administrative Purposes: Aloe Care may use Personal Information about you for its administrative purposes, including to: 

  • Measure interest in Aloe Care’s Services; 

  • Improve, upgrade, or enhance our products and Services and develop new products and Services; 

  • Ensure internal quality control;

  • Detect security and/or safety incidents

  • Verify Individual identity; 

  • Communicate about Individual accounts and activities on Aloe Care’s Services and systems, and, in Aloe Care’s discretion, changes to any Aloe Care policy; 

  • Process payment for products or services purchased;

  • Process applications and transactions; 

  • Comply with regulatory requirements, including collecting and using information relating to adverse effects you have experienced when using our products;

  • Prevent and/or protect against potentially prohibited or illegal activities; 

  • Enforce our Terms of Service. 

  • Marketing Aloe Care Products and Services: Aloe Care may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services. Aloe Care may provide you with these materials by phone, postal mail, facsimile, or email, as permitted by applicable law. Such uses include:

  • To tailor content, advertisements, and offers; 

  • To notify you about offers, products, and services that may be of interest to you;

  • To provide Services to you and our sponsors;

  • For other purposes disclosed at the time that Individuals provide Personal Information; or 

  • Otherwise with your consent.

You may contact us at any time to opt out of the use of your Personal Information for marketing purposes, as further described in Section 3 below. 

  • Research and Development: Aloe Care may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, for public health, research, analytics, or any other legally permissible purpose, as well as to help us to optimally deliver our existing products and Services or develop new products and Services.

  • Other Uses. Aloe Care may use Personal Information for other purposes disclosed to you at the time you provide Personal Information or with your consent. 

2.4 Research/Survey Solicitations

From time to time, Aloe Care may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and Services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share non-identifiable Individual and aggregate data for research and analysis purposes. 

2.5 Mobile Devices

Aloe Care may provide Services that are specifically designed to be compatible and used on mobile devices. Aloe Care will collect certain information that your mobile device sends when you use such Services, like a device identifier, user settings and the operating system of your device.

Mobile versions of Aloe Care’s Services may require that users log in with an account. In such cases, information about use of mobile versions of the Services may be associated with user accounts. In addition, Aloe Care may enable Individuals to download an application, widget, or other tool that can be used on mobile or other computing devices. Some of these tools may store information on mobile or other devices. These tools may transmit Personal Information to Aloe Care to enable Individuals to access user accounts and to enable Aloe Care to track use of these tools. Some of these tools may enable users to email reports and other information from the tool. Aloe Care may use information transmitted to Aloe Care to enhance these tools, to develop new tools, for quality improvement and as otherwise described in this Policy or in other notices Aloe Care provides.

2.6 Anonymous and Aggregated Information

Aloe Care may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access Aloe Care’s Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and Aloe Care may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within Aloe Care and with business partners, including Dealers, Co-Brand or White Label Partners, insurance companies, employers and other Third Parties, for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you. 

3. Choice/Modalities to Opt Out

You have the right to opt out of certain uses and disclosures of your Personal Information.

3.1 General

Where you have consented to Aloe Care’s Processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out of further Processing by following the instructions in Section 5 below. 

Additionally, before we use Personal Information for any material new purpose not originally authorized by you, we will provide information regarding the new purpose and give you the opportunity to opt out. 

Prior to disclosing Sensitive Data to a Third Party or Processing Sensitive Data for a purpose other than its original purpose or the purpose authorized subsequently by the Individual, Aloe Care will endeavor to obtain each Individual’s explicit (opt-in) consent. Where consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Aloe Care will comply with the law or contract.

3.2 Email and Telephone Communications

Aloe Care will provide you the opportunity to opt out of any marketing or promotional email communications we send. Note that you will continue to receive transaction-related emails regarding products or Services. We may also send you certain communications regarding Aloe Care and our Services and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Service or this Policy).

We maintain “do-not-call” and “do-not-mail” lists as mandated by law. We process requests to be placed on do-not-mail, do-not-phone and do-not-contact lists within 60 days after receipt, or such shorter time as may be required by law.

3.3 “Do Not Track”

Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. DNT is a way for users to inform websites and services that they do not want certain information about their webpage visits collected over time and across websites or online services. Aloe Care does not recognize or respond to browser-initiated DNT signals.

3.4 Cookies and Interest-Based Advertising 

While Aloe Care does not currently participate in interest-based advertising, it may in the future. In the event that we do so, you may stop or restrict the placement of Technologies on your device or remove them by adjusting your preferences as your browser or device permits. Please note that cookie-based opt-outs are not effective on mobile applications. However, for some devices you may use your device’s platform controls in your settings to exercise choice (e.g., Android, iOS, and others).

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about browser and device settings, targeted advertising, consumer choice and privacy at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/.

Please note you must separately opt out in each browser and on each device. Advertisements on third party websites that contain the AdChoices link may have been directed to you based on information collected by advertising partners over time and across websites. These advertisements provide a mechanism to opt out of the advertising partners’ use of this information for interest-based advertising purposes. 

4. Onward Transfer

4.1 Information We Share

Aloe Care does not sell or otherwise disclose Personal Information about you, except as described in this Policy or as you explicitly consent to.

4.1.1 Caregivers, Care Recipients, Dealers, Purchasers, and Health Care Providers

 As part of delivering the Services, Aloe Care may share or otherwise make available via a dashboard summary or otherwise Personal Information about Care Recipients with their Caregivers, Purchasers, Dealers, Health Care Providers and PERS for Care Recipient for set-up, delivery, oversight of the Services for a Care Recipient and other purposes. Aloe Care may also share Personal Information about Purchasers, Caregivers, Dealers and Health Care Providers with Care Recipients and/or other Caregivers, Dealers and Health Care Providers involved with the same Care Recipient.

4.1.2 Emergency Responders and Call Centers

As part of delivering the Services, Aloe Care may share, provide alerts or otherwise make available Personal Information, including your location, to Aloe Care call centers service providers, PERS, emergency response centers, agencies you have identified and/or directly to emergency responders (e.g., police, fire, emergency medical technicians, etc.) once the Aloe Care device or Service identifies and reports a condition that require assistance.

4.1.3 Service Providers

Aloe Care may share Personal Information with our service providers that we have retained to perform services on our behalf including (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; and (iv) customer service activities. Payment information will be used and shared only to effectuate your order and may be stored by a service provider for purposes of future orders. 

Aloe Care has executed appropriate contracts with the service providers that prohibit them from using or sharing Personal Information except as necessary to perform the contracted services on our behalf or to comply with applicable legal requirements. 

4.1.4 Business Partners and Other Third Parties

Aloe Care may share Personal Information with our business partners and affiliates (including Dealers, Co-Brand or White Label Partners, insurance companies, employers and other Third-Parties) for our, our business partners’, and our affiliates’ internal business purposes. Aloe Care may also share Personal Information with our business partners and affiliates so that Aloe Care and/or our business partners and affiliates can provide you with a product or Service that you have requested. Aloe Care may also provide Personal Information through a dashboard of summary information about Care Recipients or otherwise to business partners,  with whom we may jointly offer products or Services, who may offer Aloe Care products or Services, or whose products or Services we believe may be of interest to you. In some cases, our business partner’s name may appear, along with Aloe Care’s. 

We may also share Personal Information about you with fitness, health-monitoring and wearable smart devices and sites to which you give us access to synch accounts and information.

4.1.5 Information Disclosed for Our Protection and the Protection of Others

We may disclose information about you: (i) if we are required to do so by law, court order, or legal process; (ii) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements; (iii) under the discovery process in litigation; (iv) to enforce Aloe Care policies or contracts; (v) to collect amounts owed to Aloe Care; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable. 

In addition, from time to time, server logs may be reviewed for security purposes – e.g., to detect unauthorized activity on the Services. In such cases, server log data containing IP addresses may be shared with law enforcement bodies in order that they may identify users in connection with their investigation of the unauthorized activities.

4.1.6 Information Disclosed in Connection with Business Transactions

We reserve the right to disclose or transfer any information we have about you in the event of a proposed or actual purchase, reorganization, sale, lease, merger, joint venture, assignment, amalgamation, or any other type of acquisition, disposal, or financing of all or any portion of our business or of any of the business assets or shares (including in connection with any bankruptcy or similar proceeding). Should such an event occur, Aloe Care will endeavor to direct the transferee to use Personal Information in a manner that is consistent with this Policy.

4.2 Data Transfers

All Personal Information collected via or by Aloe Care may be stored anywhere in the world, including but not limited to, in the United States, in the cloud, on our servers, on the servers of our affiliates or the servers of our service providers. Your Personal Information may be accessible to law enforcement or other authorities pursuant to a lawful request. By providing information to Aloe Care, you consent to the storage of your Personal Information in these locations. 

5. Your Privacy Rights 

In accordance with applicable law, you may have the right to request:

  • Access to/Portability of Personal Information

    about you consistent with legal requirements.

     

    In addition, you may have the right in some cases to receive or have your electronic Personal Information transferred to another party.

  • Correction

    of your Personal Information

    where it is inaccurate or incomplete.

     

    In some cases, we may provide self-service tools that enable you to update your Personal Information.

  • Deletion

    of your Personal Information

    , subject to certain exceptions prescribed by law.

  • Restriction of or Object to Processing of

    your Personal Information

    , including the right to withdraw your consent or to opt out of the sale of your Personal Information to third parties, if applicable, where such requests are permitted by law.

     

If you would like to exercise any of these rights, please log into your account or contact us as set forth below.  We will process such requests in accordance with applicable laws.  To protect your privacy, we will take steps to verify your identity before fulfilling your request, such as by requesting you provide us a receipt or other account information, or asking you to answer questions regarding your activities on our Services. Once you have verified your identity, you may also designate an authorized agent to exercise your rights on your behalf by providing the agent’s contact information to our customer support staff, as required by applicable law. 

Although Aloe Care makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Aloe Care is unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If Aloe Care determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Aloe Care will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.

6. Retention

Aloe Care retains the Personal Information we receive as described in this Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our products and services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws, as well as for any periods of time that you authorize (for example, if you ‘pause’ or ‘freeze’ the Services for a specified length of time). Where permitted by law, we endeavor to delete device event and activity-related information within 12 months following your termination of the Service.

7. Security

The security of all Personal Information provided to Aloe Care is important to us, and Aloe Care takes reasonable steps designed to protect Personal Information. Unfortunately, no data transmission over the Internet or storage of information can be guaranteed to be 100% secure. As a result, while Aloe Care strives to protect Personal Information, we cannot ensure or warrant the security of any information you transmit to Aloe Care, and you do so at your own risk. You are responsible for maintaining the secrecy of your own passwords. If you have reason to believe that your passwords or Personal Information is no longer secure, please promptly notify Aloe Care at privacy@getaloecare.com.

8. Redress/ Compliance and Accountability

If after reviewing this Policy, you would like to submit a request or you have any questions or privacy concerns, please contact:

privacy@getaloecare.com with the subject line “privacy question / concern”

Aloe Care will address your concerns and attempt to resolve any privacy issues in a timely manner.

9. Other Rights and Important Information

9.1 Information Regarding Children

Due to the nature of Aloe Care’s business, products and Services are not marketed to minors. Aloe Care does not knowingly solicit or collect Personal Information from children under the age of 13 (and in certain jurisdictions under the age of 16). However, if a child is a Care Recipient, Aloe Care will seek consent from a parent/guardian.

9.2 Links to Third-Party Websites

Aloe Care’s Services may contain links to other websites for your convenience and information. Aloe Care does not control Third-Party websites or their privacy practices, which may differ from those set out in this Policy. Aloe Care does not endorse or make any representations about Third-Party websites. Any Personal Information you choose to give to unrelated Third Parties is not covered by this Policy. Aloe Care encourages you to review the privacy policy of any company or website before submitting your Personal Information. Some Third Parties may choose to share their users’ Personal Information with Aloe Care; that sharing is governed by that company’s privacy policy, not this Policy.

9.3 Changes to the Policy

Aloe Care may update this Policy from time to time as it deems necessary in its sole discretion. If there are any material changes to this Policy, Aloe Care will notify you by email or as otherwise required by applicable law. Aloe Care encourages you to review this Policy periodically to be informed regarding how Aloe Care is using and protecting Personal Information and to be aware of any policy changes. Your continued relationship with Aloe Care after the posting or notice of any amended Policy shall constitute your agreement to be bound by any such changes. Any changes to this Policy take effect immediately after being posted or otherwise provided by Aloe Care.

10. Supplemental California Privacy Notice 

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Aloe Care does not share Personal Information with Third Parties for their own marketing purposes.

Additionally, under the California Consumer Privacy Act (“CCPA”), California residents have certain rights around our collection, use, and sharing of personal data as explained in the “Your Privacy Rights” section above. If you wish to exercise any of your rights as a California resident, please contact us as set forth below. If you exercise any rights under the CCPA, we may ask certain questions in order to verify your identity and your status as a California resident. An agent may also submit a request on your behalf, but we may require that you verify the agent has been authorized by you. You have the right to not be discriminated against by Aloe Care for the exercise of your rights conferred by the CCPA.

We collected the following categories of personal information from California consumers in our role as a business within the last 12 months. The categories of sources from which we collect Personal Information are set forth above. We collected this Personal Information for the business and commercial purposes described in this Privacy Policy.

Categories of Personal Information Collected

Examples of Personal Information Collected by Aloe Care

Identifiers

Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, phone number, account name, or other similar identifiers

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Name, credit or debit card number, or medical information, including medication and allergies 

Commercial Information

Records of products or services purchased, obtained, or considered

Internet or other electronic network activity

Browsing history, search history, information on a consumer's interaction with an internet website.

Professional or employment-related information

Current or past job history

Inferences drawn from other personal information to create a profile about a consumer

Profile reflecting a consumer's preferences, characteristics, behavior, abilities, and aptitudes

Audio, electronic, visual, thermal, olfactory, or similar information

Voice(s), room temperature(s), movement around and within the environment 

We disclosed for a business purpose the following categories of Personal Information to the following categories of third parties in the preceding 12 months:

Categories of Personal Information Disclosed

Categories of Third Parties to Which Personal Information was Disclosed

Identifiers

Service providers business partners (including Dealers, Co-Branded and White Label Partners, insurance companies, employers, fitness, health-monitoring and wearable smart devices and sites to which you give us access), Caregivers, Care Recipients, Purchasers, Health Care Providers and emergency responders (police, fire, emergency medical technicians, etc.)

Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

Service providers and business partners

Commercial information

Service providers, business partners, Caregivers, Care Recipients, Purchasers, and Health Care Providers

Internet or other electronic network activity

Service providers and business partners

Professional or employment-related information

Service providers and business partners

Inferences drawn from other personal information to create a profile about a consumer

Service providers and business partners

Audio, electronic, visual, thermal, olfactory, or similar information

Service providers, business partners, Caregivers, Care Recipients, Purchasers, Health Care Providers , and emergency responders (police, fire, emergency medical technicians, etc.)

We do not “sell” Personal Information as such term is defined by the CCPA, nor do we have actual knowledge that we have “sold” any Personal Information of minors under 16 years of age.

11. Definitions

“Agent” means any Third Party that Processes Personal Information pursuant to the instructions of, and solely for, Aloe Care or to which Aloe Care discloses Personal Information for use on its behalf.

“Caregiver” is an Individual who is either a professional (e.g., health care provider) or non-professional (e.g., a family member or friend) providing care to the Care Receiver. If you are a professional Caregiver, you may be subject to additional requirements pursuant to applicable laws. 

“Care Receiver” is the Individual who is the patient receiving care from one or more caregivers (professional and non-professional, such as family members) and primary recipient of Services.   

“Co-Brand or White Label Partner” is a Third-Party retail, marketing, distribution and/or Service partner whose brand, logo and/or name are placed on the Aloe Care device and/or Service documents. 

“Dealer” is any home healthcare dealer that deliver that sets up Aloe Care devices and/or Services for a Care Receiver and authorized retailers that sells Aloe Care devices and/or Services.

“Individual” is an identified or identifiable natural person. An Individual may be a customer, user or visitor of the Services, or any other natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.

“PERS” is any PERS (personal emergency response system) that uses and/or responds to an Aloe Care device and/or any of the Services.

“Personal Information” is any information relating to an identified or identifiable natural person (“Individual”) or, for purposes of CCPA, household. 

“Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.

“Protected Health Information” is a subset of Personal Information and has the meaning set out in the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (“HIPAA”), and in particular at 45 C.F.R. § 160.103, as it may be amended from time to time.

“Purchaser” is an Individual who makes an online or offline purchase of one or more Aloe Care Services. 

“Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Protected Health Information.

“Third Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, Aloe Care or Aloe Care’s Agents.

12. Superseded Documents

Title (Effective Date)

Aloe Care Privacy Policy (Effective: 01/01/2019)