Privacy Policy

Effective Date: November 11, 2019 Last Updated: November 11, 2019

Humla Health doing business as Humla Health (collectively referred to herein as “Humla Health”, “we”, “our”, or “us) recognizes the importance of protecting personal data we may collect from visitors and any other individual or entity (“Users”, “you”, or “your”) who visit our web sites. This Privacy Policy applies to data collection by Humla Health and shall apply to your use of the website, www.humla.com and other Humla Health-related sites, applications, software, communications, capabilities and services (“Services”) accessible on or by any top-level Humla Health domain owned by us (each, a “Site” and collectively the “Sites”), but excluding services that state that they are offered under a different privacy policy.
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Our Privacy Policy explains:

what information we collect;
why we collect it;
how we use that information;
how we may share it; and
the choices we offer, including how to access and delete information.
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Specifically, our Privacy Policy covers the following topics:

When This Privacy Policy Applies
Conditions of Use
Information We Collect
Cookies & Other Technologies
How We Use Information We Collect
Our Legal Basis for Collecting Personal Information
Your Failure to Provide Personal Information
Our Retention of Your Personal Information
Sharing Personal Information
Sale of Personal Information
Your Rights and Choices
a. Rights Specific to Californians Rights
b. Specific to European Union Residents
Exercising Your Rights
Our Opt-in/Opt-out Policy
Third Party Links
International Transfer
How we Protect Personal Information
Children
Direct Marketing and “Do Not Track” Signals
Changes to this Privacy Policy
How to Contact Us

Please familiarize yourself with our privacy practices and let us know if you have any questions. By using the Sites, you signify your acceptance of this Privacy Policy. If you do not agree to this Privacy Policy, please do not use the Sites.

If you have any questions or comments about this Privacy Policy, please submit a request to privacy@humla.com.

When this Privacy Policy Applies

Our Privacy Policy applies to all of the services offered by Humla Health and its affiliates, and services offered on other sites, but excludes services that have separate privacy policies that do not incorporate this Privacy Policy.

Our Privacy Policy does not apply to services offered by other companies or individuals, including products or sites that may be displayed to you, or other sites linked from our Services. Our Privacy Policy does not cover the information practices of other companies and organizations who advertise our Services, and who may use cookies, pixel tags and other technologies to serve and offer relevant ads.

Conditions of Use

By accessing or using the Sites and Services in any manner, you also agree to be bound by Humla Health’s Terms of Service (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.

Information We Collect

We collect information, including personal information, to provide better services to all our Users. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information include: full name, email address, digital identity, such as a login name or handle, information about your device, and certain metadata.

The personal information which we collect includes, but is not limited to, the following circumstances and data elements:

If you express an interest in obtaining additional information about our services, request customer support, use our “Contact Us” or similar features, register to use our Sites or Services, or download certain content, we may require that you provide to us your contact information, such as your name, organization, phone number, or email address, social security number and in some instances, you may elect to provide us with location and address information;
In addition, if you register to use our Sites or Services, you will be required to submit additional information (e.g. professional history, consenting to a background check, competency testing, etc.), while also providing details that enable us to connect you to the appropriate shift or healthcare provider.
If you report a problem or have a question about our Services, you may provide us with contact information, such as a phone number or email address;
As part of our financial bank management services, we may require that you provide to us your financial and billing information, such as billing name and address, credit card number or bank account information;
If you use and interact with our websites or emails, we automatically collect information about your device and your usage of our websites or emails through cookies, web beacons or similar technologies, such as Internet Protocol (IP) addresses or other identifiers, which may qualify as Personal Information (please see the “What device and usage data we process” section, below);
If you use and interact with our services, we automatically collect information about your device and your usage of our services, through log files and other technologies, some of which may qualify as Personal Information;
If you voluntarily submit certain information to our services, such as filling out a survey about your user experience, we collect the information you have provided as part of that request; and
If you provide us or our service providers with any Personal Information relating to other individuals, you represent that you have the authority to do so and acknowledge that it will be used in accordance with this Privacy Policy. If you believe that your Personal Information has been provided to us improperly, or to otherwise exercise your rights relating to your Personal Information, please contact us by using the information set out in the “How to Contact Us” section below.

Cookies and Similar Technologies

We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google and similar partners.

The technologies we use for this automatic data collection may include:

Cookies. A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our services. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our services. For more information about our use of cookies, including details on how to opt-out of certain cookies, please see our Cookie Policy.
Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.

How We Use Information We Collect

We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:

To present, operate or improve the Site and Services, including analysis of Site activity;
To inform you about Services and products available from Humla Health;
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 authorize access to our Sites and Services;
To offer and administer programs;
To customize or tailor your experience of the Services;
To administer content, promotion, surveys, or other Site features;
To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, and other offers or promotions, and to deliver pertinent emails;
To improve our customer service.
To respond to and support users regarding their use of the Sites and Services.
To comply with all applicable legal requirements.
To investigate possible fraud or other violations of our Terms of Use or this Privacy Policy and/or attempts to harm our Users.

We use the information we collect from our Sites to provide, maintain, and improve them, to develop new services, and to protect our company and our Users.

We use information collected from cookies and other technologies, to improve your User experience and the overall quality of our services. We may use your Personal Information to see which web pages you visit at our Site, which web site you visited before coming to our Site, and where you go after you leave our Site. We can then develop statistics that help us understand how our visitors use our Site and how to improve it. We may also use the information we obtain about you in other ways for which we provide specific notice at the time of collection.

We will ask for your consent before using information for a purpose other than those set out in this Privacy Policy.

Our Legal Basis for Collecting Personal Information

Whenever we collect Personal Information from you, we may do so on the following legal bases:

Your consent to such collection and use;
Out of necessity for the performance of an agreement between us and you, such as your agreement to use our Services or your request for Services;
Our legitimate business interest, including but not limited to the following circumstances where collecting or using Personal Information is necessary for:
a. Intra-organization transfers for administrative purposes;
b. Product development and enhancement, where the processing enables Humla Health to enhance, modify, personalize, or otherwise improve our services and communications for the benefit of our Users, and to better understand how people interact with our Sites;
c. Fraud detection and prevention;
d. Enhancement of our cybersecurity, including improving the security of our network and information systems; and
e. General business operations and diligence;

Provided that, in each circumstance, we will weigh the necessity of our processing for the purpose against your privacy and confidentiality interests, including taking into account your reasonable expectations, the impact of processing, and any safeguards which are or could be put in place. In all circumstances, we will limit such processing for our legitimate business interest to what is necessary for its purposes.

Your Failure to Provide Personal Information

Your provision of Personal Information is required in order to use certain parts of our services and our programs. If you fail to provide such Personal Information, you may not be able to access and use our Services and/or our programs, or parts of our Services and/or our programs.

Our Retention of Your Personal Information

We determine the appropriate retention period for Personal Information on the basis of the amount, nature and sensitivity of your Personal Information processed, the potential risk of harm from unauthorized use or disclosure of your Personal Information and whether we can achieve the purposes of the processing through other means, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).

After expiration of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.

Sharing Personal Information

Humla Health may disclose your Personal Information to commercial providers for a business purpose, which may include, but is not limited to, verifying your identity when making a payment or registering access to your accounts. When we disclose Personal Information for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.

In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:

Identifiers;
Internet or other network activity information.

We disclose your Personal Information for a business purpose to the following categories of third parties:

Our business affiliates,
Our users of Services,
Commercial providers,
Enterprise accounts,
Third parties to whom you or your agents authorize us to disclose your personal information in connection with the services we provide to you.

We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of Humla Health if we have a good- faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

meet any applicable law, regulation, legal process or enforceable governmental request.
enforce applicable Terms of Use, including investigation of potential violations and for billing and collection purposes.
detect, prevent, or otherwise address fraud, security or technical issues.
protect against harm to the rights, property or safety of Humla Health, our Users or the public as required or permitted by law.

We attempt to notify Users about legal demands for their personal data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.

We may disclose your Personal Information in the event of a business transfer. If we establish a new related entity, are acquired by or merged with another organization, or if substantially all of our assets are transferred to another organization, Personal Information about our users is often a transferred business asset. In the event that Humla Health itself or substantially all of our assets are acquired, Personal Information about our users may be one of the transferred assets.

Sale of Personal Information

In the preceding twelve (12) months, we have not sold any Personal Information.

Your Rights and Choices

You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you use our services, we aim to provide you with choices about how we use your personal data. We also aim to provide you with access to your Personal Information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you or you may update or correct inaccuracies in that information by contacting us. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information. In addition, if you believe that Personal Information we maintain about you is inaccurate, subject to applicable law, you may have the right to request that we correct or amend the information by contacting us as indicated in the How to Contact Us section below.

Our Opt-in/Opt-out Policy

By providing an email address on the Humla Health Sites or Services, you agree that we may contact you in the event of a change in this Privacy Policy, to provide you with any Service related notices, or to provide you with information about our events, invitations, or related educational information.

For purposes of this Privacy Policy, “opt-in” is generally defined as any affirmative action by a User to submit or receive information, or use our Services, as the case may be.

We currently provide the following opt-out opportunities:

1. At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us or a Humla Health Partner to unsubscribe from the service. 2. At any time, you can contact us through privacy@humla.com or at the telephone number [1-800-360-5369] to unsubscribe from the service and opt-out of our right per your consent under the terms of this Privacy Policy to share your Personal Information. 3. At any time, you can reply or text “STOP” to [404-424-9725] to opt-out of receiving SMS texts.

Notwithstanding anything else in this Privacy Policy, please note that we always reserve the right to contact you in the event of a change in this Privacy Policy, or to provide you with any service related notices.

Third Party Links

The Sites may contain links to webpages operated by parties other than Humla Health. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Humla Health strongly recommends that each User review the third party’s terms and policies.

International Transfer

We may, directly or indirectly through third-party entities around the world, process, store, and transfer the information you provide, including your Personal Information, as described in this Privacy Policy. Specifically, the information and Personal Information that we collect may be transferred to, and stored at, a location outside of your jurisdiction. It may also be processed by staff operating outside of your jurisdiction who work for us or for one of the organizations outlined in this Privacy Policy in connection with the activities outlined in this Privacy Policy. By submitting your information and Personal Information using the Sites, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your Personal Information is treated securely and in accordance with this Privacy Policy. We have put in place commercially reasonable technical and organizational procedures to safeguard the information and Personal Information we collect on the Sites.

How We Protect Personal Information

Humla Health maintains administrative, technical and physical safeguards designed to protect the user’s Personal Information and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

Humla Health collects account information for payment or credit, and Humla Health will use the information only to complete the task for which the account information was offered.

Children

Our website is not intended for children under 16 years of age. We do not intentionally gather Personal information about visitors who are under the age of 16. If a child has provided us with Personal Information, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us privacy@humla.com. If we learn that we have inadvertently collected the personal information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible.

Direct Marketing and “Do Not Track” Signals

Humla Health does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.

Changes to this Privacy Policy

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services or programs, email notification or privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.

How to Contact Us

If you have any specific questions about this Privacy Policy, you can contact us via email or phone or by writing to us at the address below:

Send e-mail to: privacy@humla.com