Privacy

Privacy & Cookie Policy

Last Updated: July 20, 2019

General

Drawbridge Health, Inc., and through our affiliates worldwide (“Drawbridge Health”, “we”, or “us”), respects your privacy and appreciates the trust you have placed in us. We have established this Privacy Policy to explain how we collect, use, and disclose information we obtain through www.drawbridgehealth.com or any other website operated by us that links to this Privacy Policy (collectively, the “Website” or “Websites”).  This Privacy Policy describes the practices and guidelines that we follow to help ensure the confidentiality and security of personal information provided by users (“you” or “user”) of our Websites, and the related services we provide through the Internet, in person, through the telephone or through use of electronic communications (individually and collectively, the “Services”).

This Privacy Policy, together with our Cookie Policy, describes our practices regarding the Personal Data we collect from you when you access the Websites or use the Services.  As used in this Privacy Policy, “Personal Data” means data that allows someone to identify or contact you (for example, your name, address, telephone number and e-mail address) and any other non-public information about you that is associated with or linked to such data.

If you have any concerns or questions about your privacy or use of our Websites or Services, please contact us as provided below in the section “Contact Us.”  If you live in the EU or Switzerland, please read our Notice of Privacy Practices for EU and Swiss Residents under GDPR, which is available through this link.

This Privacy Policy is subject to occasional revision. We encourage you to visit this page regularly to view our current Privacy Policy, which will indicate the date of the last change. If we make any substantial changes in the way we use your Personal Data, we will notify you by prominently posting notice of the updated Privacy Policy on this page, together with its effective date, and will notify users as required by law.  Continued use of our Services, after we have posted changes on this page and with a new effective date shall indicate your acknowledgement of such changes and your agreement to be bound by the terms and conditions of such changes.

 

Consent

By using this Website and/or submitting Personal Data through our Services, you agree to the terms of this Privacy Policy and you consent to the use of your Personal Data in accordance with this Privacy Policy.

How We Collect Your Information

Information You Provide. Drawbridge Health collects any information you voluntarily provide to us including your name, telephone, shipping address, and email address. For example, you may elect to provide information about yourself when you complete a web survey, subscribe to a newsletter, respond to a posted employment opportunity, or register for certain offers or promotions. We may also collect information through your communications with our support-team.  We do not collect your name, address, telephone number, e-mail address or other contact information unless you choose to provide that information.

Information We Collect from Your Use of our Website. We automatically collect certain technical information from your computer or mobile device when you access our Websites. For example, we receive information from your device, including IP address, web browser type, mobile operating system version (to the extent applicable), and unique device identifiers. We may also collect and store your browser settings and preferences. We receive information about your interactions with our Websites, such as the time spent interacting with content and the dates and times of your visits.  When we send you an electronic communication, such as an e-mail, we may collect certain information, such as the action taken upon receipt of the e-mail (for instance, whether you opened or deleted the e-mail).

Information from Cookies and Similar Technologies. We and our service providers may collect information using cookies or similar technologies. Cookies are pieces of information that are stored by your browser on the hard drive or memory of your computer or other Internet access device. Cookies enable us to personalize your experience on our Website and with our Services, maintain a persistent session, passively collect demographic information about your computer, and monitor other activities. Our Website may use different kinds of cookies and other types of local storage (such as browser-based or plugin-based local storage).

We may combine the data you provide us through our Websites and Services with other data you have shared with us offline, as well as with records provided by third parties.  Please review our Cookie Policy for further information about how we use cookies and how you can disable them.

Personal Data Collected from Third Parties.  We may obtain information from third parties with whom we do business, such as in connection with a trade show, or through public databases, social media or joint marketing partners.

How We Use Your Information

General Use. Drawbridge uses the information we collect about and from you for a number of purposes, including: providing and improving the Website; analyzing how you use the Website; managing our network; and better tailoring our Website and Services to you. In addition, we may use information provides through use of our Websites for the following:

  • To keep records of contact information and correspondence.
  • To remember a user’s preferences, such as language, font size and communication type, and the user’s interests regarding subject matter.
  • To personalize a user’s online experience, including the provision of content addressing a user’s preferences or interests and expediting the processing and completion of a transaction.
  • To administer our Services, diagnose technical problems, and otherwise manage our business.
  • To determine the approximate location of each user, calculate usage levels, diagnose server problems, and in general to administer the Services, in each case through use of a user’s IP address.
  • To improve, enhance or modify our business and the Services through data analysis, audits, security and fraud monitoring and prevention.
  • To aggregate information and create Anonymous Data, as described below.
  • To perform other functions or processes described to the user at the time of collection of the Personal Data.

We also use your information to communicate with you. For example, if you have expressed an interest in a particular product or program, we will use your data to provide you with the requested information or to respond to questions. We may also use the information we collect for marketing purposes, such as providing you with promotional materials that may be useful, relevant, valuable or otherwise of interest to you. Where required under applicable law, we will obtain your prior opt-in consent to send you electronic marketing communications.

We may also process the information we collect about you or from you for the following purposes: (i) to enforce our terms or other legal rights, including intellectual property infringement; (ii) as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and (iii) to comply with industry standards and our policies.

Creation of Anonymous Data.  We may also de-identify (removing identifying information), pseudonymize (replacing identifying information with numbers so that a key is needed to re-identify) and anonymize (irreversibly removing identifying information) your information and process it in an anonymous and aggregated form for other purposes than described above, for example, in research to improve our products.  We reserve the right to use and disclose Anonymous Data to third parties for research, analytic or strategic purposes.

Feedback.  If you provide us with feedback on our Websites or any of our Services, we may use such feedback for any purpose.  We will treat the Personal Data in such communication in accordance with this Privacy Policy.

 

How We May Disclose and Share Your Information

Service Providers. Except as otherwise stated in this policy, we do not generally sell, trade, share, or rent the Personal Data collected from our Services to other entities.  However, we may share your Personal Data with third party service providers to provide you with the Services; to conduct quality assurance testing; to facilitate creation of accounts; or to provide technical support. These third party service providers are contractually required not to use your Personal Data other than to provide the services we request.  You expressly consent to the sharing of your Personal Data with our third party service providers for the sole purpose of providing the Services.

Analytics. We use third party analytics vendors to evaluate and provide us with information about your use of the Website. We do not share your information with these third parties, but theses analytics service providers may set and access their own cookies, pixel tags and similar technologies on the Website and they may otherwise collect or have access to information about you which they may collect over time and across different websites. Some parts of our Website use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to analyze use patterns and may collect information about your use of the website, including your IP address. More information on Google Analytics can be found here: www.google.com/policies/privacy/partners/.  You may opt-out from the collection of your information by downloading the Google Analytics opt-out browser add-on available at https://tools.google.com/dlpage/gaoptout.

Ad Network Providers. We may also allow ad network providers to set and access their own cookies, pixel tags and similar technologies to collect information about Website use. These network advertisers may use this and other information they have collected about you to deliver targeted advertisements for products and services in which you might be interested based on your use of the website. If you prefer to not receive targeted advertising, you can opt-out of some network advertising programs that use your information. To do so please visit the Digital Advertising Alliance (DAA) Opt-Out Page: http://www.aboutads.info/choices.

As Required by Law and Similar Disclosures. We may disclose information about you: (i) if we are required to do so by applicable law (including laws outside the user’s country of residence), regulation, or legal process, such as a court order or subpoena; (ii) in response to requests by government agencies, such as law enforcement authorities; (iii) when we believe disclosure is necessary or appropriate to protect against or respond to physical, financial or other harm, injury, or loss to property;  (iv) in connection with an investigation of suspected or actual unlawful activity; or (v) when we believe that a user has violated the Terms of Use of our Services or otherwise misused our Services, such as to gain unauthorized access to any system, to engage in spamming activities, to engage in denial of service or similar attacks, or to conduct any fraudulent or unlawful activity.

Affiliates and Partners. We may share your Personal Data with other Drawbridge Health affiliates and other partners with whom we are jointly marketing a product or service. These entities will be required to abide by this Privacy Policy.

Merger, Sale, or Other Asset Transfers. We reserve the right to transfer Personal Data to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets.  Except as otherwise provided by a bankruptcy or other court, the use and disclosure of all transferred Personal Data will be subject to policies that are consistent with the policies described in this Privacy Policy. However, any information that a user submits or that is collected after that transaction may be subject to the privacy policy adopted by the successor entity.

Third Party Links.  Our Website may contain links to other websites that are not under the control of or maintained by Drawbridge Health. Such links do not constitute an endorsement by Drawbridge Health of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that Drawbridge Health is providing these links to you only as a convenience, and you agree that Drawbridge Health is not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites.

Permission. We may also disclose your Personal Data with your permission.

 

Your Choices Regarding Your Personal Data

Cookie Preferences and Opt Out From Communication.   If you do not want the Website to collect information through the use of cookies, your browser may allow you to be notified when you receive certain types of cookies and restrict or disable certain cookies. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. Please be aware that if you disable or reject cookies, some features of the Website may not work properly. You can opt-out of receiving further promotional messages from us by following the unsubscribe instructions provided in the promotional email you receive or by contacting us directly at the contact information listed below. Please see our Cookie Policy here.

We may periodically send you free newsletters and e-mails that directly promote the use of our Services and potentially those of our marketing partners.  When you receive newsletters or promotional communications from us, you may indicate a preference to stop receiving further communications from us and you will have the opportunity to “opt-out” by following the unsubscribe instructions provided in the e-mail you receive or by contacting us directly (please see contact information below).  Despite your indicated e-mail preferences, we may send you notices of any updates to our Terms of Use or Privacy Policy.

Changes to and Deletion of Personal Data.  You may request that we change or delete any of your Personal Data in your account by sending an e-mail to us at the e-mail address set forth below.  However, we may be required (by law or otherwise) to retain this information and not delete it (or to retain this information for a certain time period, in which case we will comply with your deletion request only after we have fulfilled such requirements).  In regions where there is a right to erasure (right to be forgotten) with respect to your Personal Data, we will use all reasonable efforts to delete such Personal Data without undue delay. When we delete any information, it will be deleted from the active database, but may remain in our archives.

Security and Retention of Your Personal Data

Drawbridge Health employs procedural and technological security measures designed to protect your information from loss, unauthorized access, disclosure, alteration or destruction. However, you provide your information to us at your own risk. Despite these security measures, we cannot guarantee that your data will not be lost, accessed without authorization, disclosed, altered, or destroyed.

We retain information about users or as long as necessary to perform the activities described in this Privacy Policy and to comply with our legal obligations. We may need to retain certain information for record keeping purposes or for completing a transaction that you commenced prior to requesting a change or deletion.  In addition, it is likely that residual information may remain within our databases, back-ups or other records, and not be fully removed.

International Users

If you are visiting our Website from the European Economic Area or other regions with laws governing data collection and use, please note that we may transfer your information to recipients in countries other than the country in which the information was originally collected, including the United States of America. Those countries may not have the same data protection laws as the country in which you initially provided the information. When we transfer your information to other countries, we will protect that information as described in this Privacy Policy. By providing your information and/or using the Service you consent to any transfer and processing in accordance with this Privacy Policy.

 

Social Media Plug-ins

Our Service may use social media plugins (e.g., the Facebook “Like” button or the “Share to Twitter” button) to enable you to easily share information with others. When you visit our website, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our site. If you are logged into the social media website (e.g., Facebook, Twitter, Google+) while browsing on our website, the social plugins allow that social media website to receive information that you have visited our website. The social plugins also allow the social media website to share information about your activities on our website with other users of their social media website. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website. Drawbridge Health does not control any of the content from the social media plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.

Minors

Our Website is not intended for or designed to attract children under the age of 13. Moreover, we do not knowingly collect any personal information from anyone under the age of 18 without the consent of a parent or guardian, and you must be 18 years of age or older to submit registration or survey information. If we become aware that any person submitting personal information to the Service is under the age of 13, we will promptly take steps to delete any personal information collected and terminate the relevant account.

 

Do Not Track Signals

Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the Internet. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Consequently, due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to the laws of California or any other jurisdiction. 

How to Reach Us

If you have any questions or comments about this Privacy Policy, our privacy practices or if you would like to exercise your rights and choices, please contact us by phone at 650-714-6791, by email at info@dbhealth.com, or by writing to us at:

Drawbridge Health Inc.
Attn: Privacy Office
11535 Sorrento Valley Road, Suite 407
San Diego, CA 92121

Dispute Resolution

If you believe that we have not adhered to this Privacy Policy, please contact us by email at the email address provided above.  We will do our best to address your concerns.  If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation.

 

We use cookies, which are small text files placed on your computer or mobile device when you visit our Services to better enable their features and functionality. By using our Services, you consent to our use of cookies as described in this Cookie Policy. Please note that third party websites that you may be directed to may use their own cookies.
We use two types of cookies: persistent cookies and session cookies.
A persistent cookie helps us recognize you as an existing user, so it is easier to return and interact with our Services. After you accept our Cookie Policy, a persistent cookie stays in your browser and will be read by our Services when you return.

Terms of Use

Last Updated: July 24, 2019

The website located at www.drawbridgehealth.com (the “Site”) is a copyrighted work belonging to Drawbridge Health, Inc. (“Company”, “us”, “our”, and “we”). Certain features of the Site may be subject to additional guidelines, terms, or rules, which will be posted on the Site in connection with such features. All such additional terms, guidelines, and rules are incorporated by reference into this Agreement.
THESE TERMS OF USE (“AGREEMENT”) SETS FORTH THE LEGALLY BINDING TERMS FOR YOUR USE OF THE SITE. BY ACCESSING OR USING THE SITE, YOU ARE ACCEPTING THIS AGREEMENT (ON BEHALF OF YOURSELF OR THE ENTITY THAT YOU REPRESENT) AND YOU REPRESENT AND WARRANT THAT YOU HAVE THE RIGHT, AUTHORITY, AND CAPACITY TO ENTER INTO THIS AGREEMENT (ON BEHALF OF YOURSELF OR THE ENTITY THAT YOU REPRESENT). YOU MAY NOT ACCESS OR USE THE SITE OR ACCEPT THE AGREEMENT IF YOU ARE NOT AT LEAST 18 YEARS OLD. IF YOU DO NOT AGREE WITH ALL OF THE PROVISIONS OF THIS AGREEMENT, DO NOT ACCESS AND/OR USE THE SITE.

At Drawbridge Health, Inc. (“Drawbridge Health”, “we”, or “us”) we respect your privacy and appreciate the trust you have placed in us. We have established this Privacy Policy to explain how we collect, use, and disclose information we obtain through www.drawbridgehealth.com or any other website operated by us that links to this Privacy Policy (collectively, the “Service”).

1. SITE


1.1 License. Subject to the terms of this Agreement, Company grants you a non-transferable, non-exclusive, license to use the Site for your personal, noncommercial use.


1.2 Certain Restrictions. The rights granted to you in this Agreement are subject to the following restrictions: (a) you shall not license, sell, rent, lease, transfer, assign, distribute, host, or otherwise commercially exploit the Site; (b) you shall not modify, make derivative works of, disassemble, reverse compile or reverse engineer any part of the Site; (c) you shall not access the Site in order to build a similar or competitive service; and (d) except as expressly stated herein, no part of the Site may be copied, reproduced, distributed, republished, downloaded, displayed, posted or transmitted in any form or by any means. Any future release, update, or other addition to functionality of the Site shall be subject to the terms of this Agreement. All copyright and other proprietary notices on any Site content must be retained on all copies thereof. In addition, you agree not to use the Site to: (i) upload, transmit, or distribute any computer viruses, worms, or any software intended to damage or alter a computer system or data; (ii) send unsolicited or unauthorized advertising, promotional materials, junk mail, spam, chain letters, pyramid schemes, or any other form of duplicative or unsolicited messages, whether commercial or otherwise; (iii) interfere with, disrupt, or create an undue burden on servers or networks connected to the Site or violate the regulations, policies or procedures of such networks; (iv) attempt to gain unauthorized access to the Site, other computer systems or networks connected to or used together with the Site, through password mining or other means; or (v) introduce software or automated agents or scripts to the Site so as to produce multiple accounts, generate automated searches, requests and queries, or to strip, scrape, or mine data from the Site (except that we grant the operators of public search engines revocable permission to use spiders to copy materials from the Site for the sole purpose of and solely to the extent necessary for creating publicly available searchable indices of the materials, but not caches or archives of such materials, and in all cases only to the extent permitted by any robots.txt or other similar exclusion file that may be implemented for the Site from time to time).


1.3 Modification. Company reserves the right, at any time, to modify, suspend, or discontinue the Site or any part thereof with or without notice. You agree that Company will not be liable to you or to any third party for any modification, suspension, or discontinuance of the Site or any part thereof.


1.4 No Support or Maintenance. You acknowledge and agree that Company will have no obligation to provide you with any support or maintenance in connection with the Site.


1.5 Ownership. You acknowledge that all the intellectual property rights, including copyrights, patents, trade marks, and trade secrets, in the Site are owned by Company or Company’s licensors. The provision of the Site does not transfer to you or any third party any rights, title or interest in or to such intellectual property rights. Company and its suppliers reserve all rights not granted in this Agreement.


1.6 Feedback. If you provide Company any feedback or suggestions regarding the Site (“Feedback”), you hereby assign to Company all rights in the Feedback and agree that Company shall have the right to use such Feedback and related information in any manner it deems appropriate. Company will treat any Feedback you provide to Company as non-confidential and non-proprietary. You agree that you will not submit to Company any information or ideas that you consider to be confidential or proprietary.


2. INDEMNITY

You agree to indemnify and hold Company (and its officers, employees, and agents) harmless, including costs and attorneys’ fees, from any claim or demand made by any third party due to or arising out of (a) your use of the Site, (b) your violation of this Agreement; or (c) your violation of applicable laws or regulations. Company reserves the right, at your expense, to assume the exclusive defense and control of any matter for which you are required to indemnify us and you agree to cooperate with our defense of these claims. You agree not to settle any matter without the prior written consent of Company. Company will use reasonable efforts to notify you of any such claim, action or proceeding upon becoming aware of it.


3. THIRD PARTY SITES AND ADS


3.1 Third Party Sites & Ads. The Site might contain links to third party websites, services, and advertisements for third parties (collectively, “Third Party Sites”). Such Third Party Sites are not under the control of Company and Company is not responsible for any Third Party Sites. Company provides these Third Party Sites only as a convenience and does not review, approve, monitor, endorse, warrant, or make any representations with respect to Third Party Sites. You use all Third Party Sites at your own risk. When you link to a Third Party Site, the applicable third party’s terms and policies apply, including the third party’s privacy and data gathering practices. You should make whatever investigation you feel necessary or appropriate before proceeding with any transaction in connection with such Third Party Sites.


3.2 Release. You hereby release and forever discharge us (and our officers, employees, agents, successors, and assigns) from, and hereby waive and relinquish, each and every past, present and future dispute, claim, controversy, demand, right, obligation, liability, action and cause of action of every kind and nature (including personal injuries, death, and property damage), that has arisen or arises directly or indirectly out of, or relates directly or indirectly to, any interactions with, or act or omission of, other Site users or Third Party Sites. IF YOU ARE A CALIFORNIA RESIDENT, YOU HEREBY WAIVE CALIFORNIA CIVIL CODE SECTION 1542 IN CONNECTION WITH THE FOREGOING, WHICH STATES: “A GENERAL RELEASE DOES NOT EXTEND TO CLAIMS WHICH THE CREDITOR DOES NOT KNOW OR SUSPECT TO EXIST IN HIS OR HER FAVOR AT THE TIME OF EXECUTING THE RELEASE, WHICH IF KNOWN BY HIM OR HER MUST HAVE MATERIALLY AFFECTED HIS OR HER SETTLEMENT WITH THE DEBTOR.”


4. DISCLAIMERS


THE SITE IS PROVIDED “AS-IS” AND “AS AVAILABLE” AND WE (AND OUR SUPPLIERS) EXPRESSLY DISCLAIM ANY WARRANTIES AND CONDITIONS OF ANY KIND, WHETHER EXPRESS OR IMPLIED, INCLUDING THE WARRANTIES OR CONDITIONS OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, TITLE, QUIET ENJOYMENT, ACCURACY, OR NON-INFRINGEMENT. NOTWITHSTANDING ANYTHING TO THE CONTRARY CONTAINED HEREIN, OUR (AND OUR SUPPLIERS’) LIABILITY TO YOU FOR ANY DAMAGES ARISING FROM OR RELATED TO THIS AGREEMENT (FOR ANY CAUSE WHATSOEVER AND REGARDLESS OF THE FORM OF THE ACTION), WILL AT ALL TIMES BE LIMITED TO THE GREATER OF (A) FIFTY U.S. DOLLARS (U.S.$50) OR (B) AMOUNTS YOU’VE PAID COMPANY IN THE PRIOR 12 MONTHS (IF ANY). THE EXISTENCE OF MORE THAN ONE CLAIM WILL NOT ENLARGE THIS LIMIT.

5. TERM AND TERMINATION

Subject to this Section, this Agreement will remain in full force and effect while you use the Site. We may (a) suspend your rights to use the Site or (b) terminate this Agreement, at any time for any reason at our sole discretion, including for any use of the Site in violation of this Agreement. Upon termination of this Agreement, your right to access and use the Site will terminate immediately. Company will not have any liability whatsoever to you for any termination of this Agreement. Even after this Agreement is terminated, the following provisions of this Agreement will remain in effect: Sections 1.2, 1.5, 1.6, 2, 3.2, 4, and 6.

 

6. GENERAL

6.1 Changes to Terms of Use. This Agreement is subject to occasional revision, and if we make any substantial changes, we may notify you by prominently posting notice of the changes on our Site. Any changes to this Agreement will be effective thirty (30) calendar days following our posting of notice of the changes on our Site. These changes will be effective immediately for new users of our Site. Continued use of our Site following notice of such changes shall indicate your acknowledgement of such changes and agreement to be bound by the terms and conditions of such changes.

6.2 Dispute Resolution.
(a) Governing Law and Venue. This Agreement shall be governed by the laws of the State of California without giving effect to any conflict of laws principles that may require the application of the law of another jurisdiction. Any action or proceeding relating to a claim or controversy at law or equity that arises out of or relates to this Agreement or the Site (a “claim”) must be brought in a federal or state court located in San Francisco, California and each party irrevocably submits to the exclusive jurisdiction and venue of any such court in any such action or proceeding, unless such claim is submitted to arbitration as set forth below. Notwithstanding anything to the contrary, Company may seek injunctive relief in any court having jurisdiction to protect its intellectual property or confidential or proprietary information.
(b) Alternative Dispute Resolution. For any claim where the total amount of the award sought is less than $10,000 USD, the party requesting relief may choose to resolve the dispute through binding non-appearance-based arbitration in accordance with the following: (i) the arbitration will be provided through a nationally-recognized alternative dispute resolution provider mutually agreed upon by the parties; (ii) the arbitration will be conducted in one or more of the following manners at the option of the party initiating arbitration: telephone, online, or written submissions; (iii) the arbitration will not involve any personal appearances by the parties or witnesses unless otherwise agreed by the parties; and (iv) any judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction.

6.3 Entire Agreement. This Agreement constitutes the entire agreement between you and us regarding the use of the Site. Our failure to exercise or enforce any right or provision of this Agreement shall not operate as a waiver of such right or provision. The section titles in this Agreement are for convenience only and have no legal or contractual effect. The word including means including without limitation. If any provision of this Agreement is, for any reason, held to be invalid or unenforceable, the other provisions of this Agreement will be unimpaired and the invalid or unenforceable provision will be deemed modified so that it is valid and enforceable to the maximum extent permitted by law. Your relationship to Company is that of an independent contractor, and neither party is an agent or partner of the other. This Agreement, and your rights and obligations herein, may not be assigned, subcontracted, delegated, or otherwise transferred by you without Company’s prior written consent, and any attempted assignment, subcontract, delegation, or transfer in violation of the foregoing will be null and void. The terms of this Agreement shall be binding upon assignees.

6.4 Copyright/Trademark Information. Copyright © 2019, Drawbridge Health, Inc. All rights reserved. All trademarks, logos and service marks (“Marks”) displayed on the Site are our property or the property of other third parties. You are not permitted to use these Marks without our prior written consent or the consent of such third party which may own the Marks.

6.5 Contact Information:
Drawbridge Health, Inc.
Attn: Legal Department
1455 Adams Drive, Suite 2010
Menlo Park, CA 94025
legal@dbhealth.com
These Terms of Use were last revised on July 2019.

GDPR Compliance

Effective Date: July 20, 2019

Effective May 25, 2018, the European Commission approved and adopted the General Data Protection Regulation (GDPR), a new framework for European data protection law. The GDPR strengthens the rights for individuals regarding the personal data relating to them, and seeks to unify data protection laws across Europe, regardless of where data is processed. Drawbridge Health is committed to the robust data privacy and security protections enabled by GDPR compliance.

Drawbridge is located in the United States and any Personal Data we receive or create will be maintained in the U.S. The GDPR protects the privacy and security of such Personal Data transferred out of the EU. This Notice lets you know what Personal Data we collect, what we do with it, who can access it and what rights you have concerning your Personal Data. This Notice provides important information about our use and control of Personal Data. If you would like to review our full Privacy Policy, click here.

What types of data does Drawbridge collect?  Drawbridge collects Personal Data and Anonymous Data from you when you visit our site and when you send us information or communications as described below.

    • Personal Data allows someone to identify or contact you, e.g., your name, address, telephone number, email address, and any other non-public information about you.
    • Anonymous Data is not associated with or linked to your Personal Data. It does not permit the identification of individual persons.  Drawbridge collects both Personal Data and Anonymous Data.

How does Drawbridge use the information collected? Drawbridge takes your privacy very seriously, and only uses your Personal Data for the following activities:

    • To provide the Services requested by a user.
    • To respond to user questions and other requests for information made through the Services.
    • To remember a user’s preferences, such as language, font size and communication type, and the user’s interests regarding subject matter.
    • To personalize a user’s online experience, including the provision of content addressing a user’s preferences or interests and expediting the processing and completion of a transaction.
    • To administer our Services, diagnose technical problems, and otherwise manage our business.
    • To allow a user to navigate or browse through our Services more quickly and efficiently.
    • To aggregate information and create Anonymous Data.
    • To send marketing information, invitations to events or other communications that we believe may be of interest to the user.

Drawbridge will only use this information to send you communications you have opted into receiving. You may update your preferences at any time.

 

Your Rights

If you are in the European Economic Area (EEA), you have the following rights with respect to information that Drawbridge holds about you:

  • Right to access. You have the right to access (and obtain a copy of, if required) the categories of Personal Data that we hold about you, including the information’s source, purpose and period of processing, and the persons to whom the information is shared.
  • Right to rectification. You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database.
  • Right to erasure. You have the right to request that we delete your Personal Data in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.
  • Right to restriction of processing. You may also have the right to request us to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data. However, we can verify whether we have overriding legitimate grounds to use it.
  • Right to data portability. You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.
  • Right to object. You have the right to object to the use of your information in certain circumstances, such as the use of your Personal Data for direct marketing.
  • Right to complain. You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.

How can I make changes to (or remove) my Personal Data?  You may request that we change or delete any of your Personal Data in your account by sending an e-mail to us at compliance@dbhealth.com.  However, we may be required (by law or otherwise) to retain this information and not delete it (or to retain this information for a certain time period, in which case we will comply with your deletion request only after we have fulfilled such requirements). In regions where there is a right to erasure (right to be forgotten) with respect to your Personal Data, we will use all reasonable efforts to delete such Personal Data without undue delay. When we delete any information, it will be deleted from the active database, but may remain in our archives.

How does Drawbridge secure Personal Data? Drawbridge is committed to protecting the security of your Personal Data.  We use a variety of industry-standard security technologies and procedures to help protect your Personal Data from unauthorized access, use, or disclosure. Despite these measures, you should know that no transmission over the internet can ever be considered fully secure, and that Drawbridge cannot fully eliminate security risks associated with Personal Data.

How can I remove my Personal Data? You can ask us to delete any record we have with your detailed Personal Data at any time. Please contact our legal department at compliance@dbhealth.com and our Compliance Officer will contact you shortly.

Please take time to familiarize yourself with Drawbridge’s privacy policy which describes how Drawbridge may use and retain your Personal Data and any Anonymous Data.

Feel free to contact us  if you have additional questions.

All materials have been prepared for general information purposes only; they are intended to permit you to learn more about Drawbridge’s position on GDPR. The information presented is not legal advice, is not to be acted on as such, may not be current and is subject to change without notice.

 

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