Privacy Policy

Welcome to Devyn. We take your privacy seriously and want you to be familiar with how we collect and utilize your personal information and how you can exercise your privacy rights. Devyn provides an application to facilitate connections between customers and healthcare providers as well as provide information and educational material.

1. SCOPE

This Privacy Policy applies to personal information processed by us, including on our websites, mobile applications, and other online or offline offerings. To make this Privacy Policy easier to read, our websites, mobile applications, and other offerings are collectively called “Services.”

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below.

A. Information You Provide to Us Directly

We may collect the following personal information that you provide to us.

Registration and Account Information. We may collect information when you register for an account, including but not limited to, your name, email address, phone number, gender, date of birth, address, certain health information, and health insurance information.

Social Media Profile. If you choose to login through a social media profile, we may collect information from your social media profile, including but not limited to education information, professional information, hobbies and interests.

Interactive Features. We may collect personal information that you submit or make available through our interactive features (e.g., photos, posts, and comments to others posts or user-generated content, comments, feedback, requests and other information you offer to us or others using the service). Any information you provide using the public sharing features of the Services (referred to herein as “User Content”) will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein. Please exercise caution before revealing any information that may identify you in the real world to other users.

Detailed Health Data. We may collected health data from you, including but not limited to: (i) information related to the devices used with the Service (e.g. glucometer, blood pressure cuff) (ii) entries such as date/time/time zone/place, type and duration of activities (breakfast, office work, physical activity, etc.), food intake/meal/ingredients, pills taken/injections, blood glucose measurements, sensor times/measurements, notes/text, blood pressure, weight, HbA1c, ketones, steps, images/photos, medication, tags, points, imported values (iii) pregnancy status as well as general pregnancy and postpartum information

Surveys. We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information, including information related to your demographics, health, household, employment and health goals.

Information About Others. In the course of using the Services, you may provide us with information about others (such as your healthcare provider, family members or friends), we use this to facilitate the intended action or service. In the case of healthcare providers, we may also use this information to provide them more information about the Services and to sign up for access to the Services.

B. Information Collected Automatically

We may collect personal information automatically when you use our Services:

Automatic Data Collection. We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, computer operating systems, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. Even if you do not register with our Services, or submit information directly, our Services may collect this automatically collected information.

Other System Settings. Other system settings, as well as the language your system uses and the country and time zone where your device is located, device identifiers, the website(s) you visited before our services, the number of clicks, pages viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the services to upload and post content, error logs and other similar information.

Location Information. When you use the Services, we and our service providers may automatically collect general location information (e.g., IP address, city/state and or zip code associated with an IP address) from your computer or mobile device. If you access the Services through a mobile device, we may also ask your permission to collect your precise geo-location information. If you do not wish to have specific geo-location information collected and used by us and our service providers, you may disable the location features on your device. For more information regarding location services, please contact your device manufacturer or mobile carrier. Turning off location services may impact certain features of the Services.

Cookies, Pixel Tags/Web Beacons, and Other Technologies. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

Cookies. Cookies are small bits of electronic information that a website or application sends to your browser and are stored on your hard drive. We use cookies to identify users, keep the Services secure, and improve the Services’ performance. Cookies are not required to browse our Services and may be disabled or deleted. Third parties may employ cookies on the Services in order to better perform their services. We have no control over third-party cookies, and therefore, disclaim any and all liability related to third-party cookies.

Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement on our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary. This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security or that allow you to make use of our functionality;

Performance-Related. We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below), and including page response times, download errors, length of visits to certain pages and page interaction information;

Functionality-Related. We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;

Advertising- or Targeting-Related. We may use first party or third-party Technologies to deliver content relevant to your interests on our Services or on third-party websites.

See “Your Privacy Choices and Rights” below to understand your choices regarding these Technologies.

Analytics. We may use Technologies and other third-party tools to process analytics information on our Services.

Social Media Platforms. Our Services may contain social media buttons (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

C. Information Collected from Other Sources

We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

3. HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to provide our Services and for administrative purposes, as described below.

A. Provide Our Services

We use your information to fulfil our contract with you and provide you with our Services, such as:

Managing your information and accounts;
Providing access to certain areas, functionalities, and features of our Services;
Answering requests for customer or technical support; and
Communicating with you about your account, activities on our Services, and policy changes.

B. Administrative Purposes

We use your information for various administrative purposes, such as:

Pursuing our legitimate interests such as direct marketing, research and development (including marketing research), network and information security, and fraud prevention;
Detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity;
Measuring interest and engagement in our Services;
Improving, upgrading or enhancing our Services;
Developing new products and Services;
Ensuring internal quality control and safety;
Authenticating and verifying individual identities, including requests to exercise your rights under this policy;
Debugging to identify and repair errors with our Services;
Auditing relating to interactions, transactions and other compliance activities;
Enforcing our agreements and policies; and
Complying with our legal obligations.

C. Marketing and Advertising our Products and Services

We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you may include email campaigns and custom audiences advertising.

If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in “Contact Us” below.

D. Other Purposes

We also use your information for other purposes as requested by you or as permitted by applicable law.

Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

De-Identified or Aggregated Data. We may use personal information and other information about you to create de-identified and/or aggregated information by removing personal identifiers (“De-Identified or Aggregated Data”). This may include de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. We may use De-Identified or Aggregated Data without restriction in any way allowed by law. For example, we might use De-identified or Aggregated Data to understand, evaluate, or modify the Services, to generate statistical information about the Services that we share with our customers and other third parties who are evaluating, analyzing, accrediting, or researching Devyn’s Services, or for our other business purposes. We may use De-Identified or Aggregated Data in our publications, in sales and marketing materials and for research and development.

Share Content with Friends or Colleagues. Our Services may offer various tools and functionalities. For example, we may allow you to provide information about your friends through our referral services. Our referral services may allow you to forward or share certain content with a friend or colleague, such as an email inviting your friend to use our Services. Please only share with us contact information of people with whom you have a relationship (e.g., relative, friend neighbor, or co-worker).

4. HOW WE DISCLOSE YOUR INFORMATION

We do not sell your personal information for commercial purposes. We disclose your information to third parties for a variety of business purposes, including to provide and improve our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

A. Disclosures to Provide our Services

The categories of third parties with whom we may share your information are described below.

Service Providers. We may share your personal information with our third-party service providers who use that information to help us provide our Services. This includes but is not limited to service providers that provide us with IT support, hosting, payment processing, customer service, and related services, including AWS.

Business Partners. We may share your personal information with business partners to provide you with a product or service you have requested. We may also share your personal information to business partners with whom we jointly offer products or services. We may share your personal information with your healthcare providers if you provide us permission to do so.

APIs/SDKs. We may use third-party Application Program Interfaces (“APIs”) and Software Development Kits (“SDKs”) as part of the functionality of our Services. For more information about our use of APIs and SDKs, please contact us as set forth in “Contact Us” below.

B. Disclosures to Protect Us or Others

We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; when we believe your actions violate our Terms of Use; or assist with an investigation or prosecution of suspected or actual illegal activity.

C. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

Your Privacy Choices. The privacy choices you may have about your personal information are determined by applicable law and are described below.

Email and Telephone Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding our Services or updates to our Terms or this Privacy Policy).

Mobile Devices. We may send you push notifications through our mobile application. You may opt out from receiving these push notifications by changing the settings on your mobile device. With your consent, we may also collect precise location-based information via our mobile application. You may opt out of this collection by changing the settings on your mobile device.

“Do Not Track.” Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals or similar mechanisms transmitted by web browsers.

Cookies and Interest-Based Advertising. 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. However, if you adjust your preferences, our Services may not work properly. Please note that cookie-based opt-outs are not effective on mobile applications. However, you may opt-out of personalized advertisements on some mobile applications by following the instructions for Android, iOS and others.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

Access Personal Information about you, including: (i) confirming whether we are processing your personal information; (ii) obtaining access to or a copy of your personal information; and (iii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);

Request 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;

Request Deletion of your personal information;

Request Restriction of or Object to our processing of your personal information; and

Withdraw your Consent to our processing of your personal information.

If you would like to exercise any of these rights, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We have taken appropriate safeguards to require that your personal information will remain protected and require our third-party service providers and partners to have appropriate safeguards as well. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental California Privacy Notice only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA provides California residents with the right to know what categories of personal information Devyn has collected about them and whether Devyn disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months.

California residents can find this information below:

Categories of personal information we collect may include:

Identifiers
Data with special protections
Commercial information
Internet or other electronic network activity information, including content you view or engage with
Approximate geolocation data
Audio or visual information, including photos, videos and recordings, if you choose to provide it
Biometric information such as sleep, health or exercise data

Examples of how personal information is used:

Performing or providing our services
Improving and maintaining our Services, developing new products and services, repairing errors and other functionality issues. 
Communicating with you about marketing and other relationship or transactional messages. 
Analyzing usage , such as by monitoring trends and activities in connection with use of our Services. 
Personalizing your online experience , such as by tailoring the content you see on our Services based on your preferences, interests, and browsing behavior. 
Legal reasons, such as to help detect and protect against security incidents, or other malicious, deceptive, fraudulent, or illegal activity.
Researching and innovating for scientific advancement

Category of Third Parties with whom personal information may be disclosed to for a business purpose:

Third parties to whom you authorize us to disclose your personal information in connection with the Services we provide to you such as social media and health team members
Service providers and academic researchers
Law enforcement or other third parties in connection with legal requests

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in “Personal Information We Collect” and “How We Use Your Personal Information” above, respectively.

“Sales” of Personal Information under the CCPA

For purposes of the CCPA, Devyn does not “sell” personal information, nor do we have actual knowledge of any “sale” of personal information of minors under 16 years of age.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us as set forth in “Contact Us” below and provide written authorization signed by you and your designated agent.

Verification. To protect your privacy, we will take steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include asking you to answer questions regarding your account and use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in “Contact Us” below. We will process such requests in accordance with applicable laws.

Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

10. OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time at our sole discretion. We will post the most recent version of this Privacy Policy on our Site and in the App, and any changes to this Privacy Policy will become effective when posted. Use and disclosure of information that we collect is subject to the Privacy Policy in effect at the time the information is disclosed to us. You are responsible for checking this Privacy Policy periodically for changes. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

11. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at team@devynhealth.com

Last Updated: October 10, 2021