Privacy Policy
HLTH INC. (“HLTH” “we” or “us”) recognizes the importance of respecting the privacy of those who visit our websites (our “Site”), utilize any of our services or otherwise interact with us. We are the controllers of your personal information (this simply means we are responsible for your personal information) and believe it is important for you to know how we treat any personal information we receive about you. “Personal Information” here means any information that we process about you that relates to you or that can be used to identify you - for example, your name, email, company, or events you have signed up for.
Please read this Privacy Policy carefully as it contains important information on how and why we collect, store, use and share your Personal Information. It also explains your rights in relation to your Personal Information and how to contact us if you have any questions or complaints. .
We reserve the right to change this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by email or by updating the date of this Privacy Policy and posting it on the Site.
This Site is not intended for children under the age of 13 and we do not knowingly collect data relating to children.
How to Contact Us
If you have any questions or comments about this Privacy Policy, or if you would like us to update certain information you have provided to us or your communication preferences, contact us by:
E-mail:
US & Rest of World - info@hlth.com
Europe - info@europe.hlth.com
Mail:
US & Rest of World
HLTH, INC.
155 East 44th Street, Suite 701,
New York, NY 10017
Europe
HLTH Europe Ltd
2 Kingdom Street,
London
W2 6JG
If you are located in the United Kingdom (UK), European Union (EU) or European Economic Area (EEA), our representative can be contacted as below:
Katy Fryatt, Managing Director, HLTH Europe Ltd
Quick Guide To Contents
Personal Information We Collect and How We Use Personal Information
How We Share Your Personal Information
International Transfers Of Your Personal Information
Retention Of Your Personal Information
Your Choices
Security
Privacy Policies of Third-Party Websites
Links to Other Websites
Privacy Notice For California Residents
Rights of UK and EEA Residents
1. Personal Information We Collect and How We Use Personal Information
We collect Personal Information about you, either directly from you, from a third-party source or by automated means (when you visit the Site for example). Under certain data protection law we can only use your Personal Information where we have a lawful bases (justification), and this can be either “to carry out a contract with you or to take steps on your instruction prior to entering a contract with you”, “where we have a legal obligation”, where you have given us your consent”; or “where it is necessary for our legitimate interests” (this means that we have a business or commercial interests in using your Personal Information).
The table below sets out clearly how we collect and use your Personal Information and the lawful bases we rely on for using your Personal Information. Where we have said that using or keeping your Personal Information is necessary for our legitimate interests, we have carried out an assessment to ensure this is not unfair to you.
You can choose not to provide us with your Personal Information, or refuse our use of your Personal Information. However, if you do so, we may not be able to provide you with the services you have requested where this Personal Information is necessary or these services may be delayed.
Information You Give Us
| Personal Information We Collect | How We Use Your Personal Information And Our Lawful Basis |
|---|---|
HLTH Account You give us Personal Information about you when you create a HLTH account on our website and register for events using your profile. This is generally information including your name, email, company, title, image and details of events you have registered for and receipts of payment. | Legitimate Interests
|
Event or Webinar Registration Alerts You give us Personal Information about you when you sign up to receive event or webinar registration alerts from us. This is generally information including your name, email and company name. | Legitimate Interests We use your Personal Information to send you communications alerting you when registration opens for an event or webinar you have expressed interest in. |
Event or Webinar Registration You give us Personal Information about you when you register yourself and any other person in your group for any of our events or webinars. This is generally information including name, email, location (city, country, province), company name, job title, details of the relevant event or webinar, your marketing preferences and confirmation of accessibility assistance. Where payment is required for an event or webinar, we will also give us your payment details (bank card details and billing address). | Legitimate Interests We use your Personal Information to complete and fulfil your registration for any of our events or webinars, including taking payment where applicable, sending you a confirmation message so you know your registration is confirmed, sending you updates on the event or webinar you have registered for and providing you with access to relevant content related to your registered event or webinar. |
Sponsor Sign Up You give us Personal Information about you when you express an interest or sign up to become a sponsor of any of our events, webinars or initiatives for your own purposes or on behalf of your company. This is generally Personal Information including your name, email, phone number, company name, job title and details of your sponsorship goals/expectations. | Legitimate Interest We use your Personal Information to contact you regarding your request to sponsor any of our events and initiatives, to consider your request for sponsorship, and to administer and effect any agreed sponsorship arrangements involving you. |
Announcement Spotlights You give us Personal Information about you where you express an interest and sign up to make sponsored announcements on our Site for your own purposes or on behalf of your company. This is generally information including your name, job title, email, company name and description and content of your announcement. | Legitimate Interest
|
Caricatures Where you are a content provider or contributor on our Site (e.g. a blog post author, featured on our podcast, featured on our announcement spotlight, a moderator or panellist on our webinars) we generate and display a caricature image of you on the Site along with the relevant content associated with you. | Legitimate Interest We use your Personal Information to identify your contributions to our Site, content, services and other initiatives. |
Marketing Communications and Updates You give us Personal Information about you when you subscribe to receive marketing communications from us, by signing up to our mailing list or otherwise. This is generally information including your name, email address, company name and your marketing preferences (i.e. the kind of marketing communications you want to receive). | Consent
|
Online and Social Media Advertising We collect Personal Information about your use of our website through Cookies for the purposes of showing you adverts online (on our website and other websites you visit). This is information on the fact that you have visited our Services (including particular actions you have taken on our mobile app and website), if you have a HLTH profile and if you have signed up for any events or webinars. We also use social media pixels on our websites which are similar technology to Cookies and collect Personal Information about you from your device when you access our website. This is information on the fact that you have visited our website (including particular actions you have taken) and that you have an account on our partner social media platforms (Twitter, LinkedIn and Google). Please see our Cookie Policy here for more details on what Cookies (and other similar technologies) are and how we use them. | Legitimate Interests:
|
Suppliers, Partners and Sponsors You give us Personal Information about you when you enter into a supplier/partnership/sponsorship agreement or relationship with us or are a representative of a supplier/partner/sponsor. This is generally information including your name, email address, phone number, company name, job role, strategic goals and business correspondence. | Legitimate Interest We use your Personal Information to contact you and to manage our continued relationship with you and/or your company. |
Contacting Us You give us Personal Information about you when you contact us or otherwise interact with us, including via the contact us forms on our Site, phone, email, post or social media. | Legitimate Interest To respond to your inquiries and fulfill your requests, for example, when you send us questions, suggestions, compliments or complaints, or when you request information about us, any of our events, webinars or other initiatives. |
Information We Collect Automatically
| Personal Information We Collect | HOW WE USE YOUR PERSONAL INFORMATION AND OUR LAWFUL BASIS |
|---|---|
Visiting our Website We collect Personal Information about you automatically when you visit and interact with our website. Our servers keep an activity log unique to you that collects certain administrative and traffic information including your device details, device location, source IP address, time of access, date of access, web page(s) visited, language use, software crash reports and type of browser used. | Legitimate Interests We use your Personal Information to make sure you are able to use our website, to monitor how our website is being used, to help us discover and fix any problems with the Site and to determine what country you are in when you use the Site. |
Cookies (and Similar Technologies) We collect Personal Information about you by automated means when you visit and use the Site, through cookies and similar technologies (eg. web beacons, pixel tags, etc.) placed on your device. The information collected may include a user ID assigned to you, your IP address, the content you have interacted with, duration of each visit and error messages you encounter. Please see our Cookie Policy here for more information on what cookies (and other similar technologies) are and how we use them. We use the following tools for automatic data collection:
| Legitimate Interests
|
Information Provided By Third Parties
| Personal Information We Collect | How We Use Your Personal Information And Our Lawful Basis |
|---|---|
Personal Information provided by your affiliated company Where you are an employee or representative of any of the company’s we have a relationship with, we may be provided with your Personal Information by your affiliated company during the course of this relationship. For example, if you feature on a spotlight announcement or your company registers you for an event, a webinar or any other HLTH initiative. | Legitimate Interests We use your Personal Information for the business purposes requested by your affiliated company, including providing you with the relevant HLTH services requested and/or displaying relevant HLTH content requested. |
Internal Business Processes
| Personal Information We Collect | How We Use Your Personal Information And Our Lawful Reason (Basis) |
|---|---|
Fraud and Security Monitoring Our fraud and security monitoring processes may apply to any of the above Personal Information we collect about you. | Legitimate Interests We use your Personal Information to carry out fraud and security monitoring within our business, for example, to detect and prevent cyberattacks or attempts to commit identity theft. |
Business Administration Our processes for ensuring the proper data to day running of our business may apply to any of the above Personal Information we collect about you. | Legitimate Interests We use your Personal Information as necessary to operate our business efficiently. |
Legal Claims and Compliance with Legal Obligations Our processes for complying with our legal obligations and protecting our rights under the law may apply to any of the Personal Information we collect about you listed in this Privacy Policy. | Legitimate Interests We use your Personal Information to effectively defend or bring claims to protect our legal rights and interests, to respond to investigations from regulators or law enforcement, and to audit our internal processes for compliance with legal and contractual requirements. Legal Obligation We use your Personal Information to comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities, and audit our internal processes for compliance with legal requirements. |
2. Personal Information We Collect and How We Use Personal Information
We share your Personal Information in the following circumstances:
We share your Personal Information with trusted third parties who perform functions on our behalf and help us provide you with the services and initiatives we offer, and also in operating and maintaining our Site. Third parties such as service providers (including website and cloud providers, database management providers, business communication providers, email distribution providers, direct marketing and data collection providers, data storage and analysis providers, and customer service support providers), business consultants, and professional advisors (including lawyers and accountants). These third parties comply with similar and equally stringent undertakings of privacy and confidentiality.
We share your personal information with our partners and event sponsors in a manner consistent with the uses of your Personal Information communicated under this Privacy Notice and as permitted by law.
Personal Information
We may share your Personal Information with our affiliates, meaning an entity that controls, is controlled by, or is under common control with HLTH. Our affiliates will use the Personal Information we share in a manner consistent with this Privacy Policy.
We share your Personal Information to send you custom advertisements on the social media platforms and networks you use, we share your email and information collected from our social media pixels with our social media partners (Twitter, LinkedIn and Google) who match this Personal Information with your user account on their platforms (if you have one), and include you on a list of individuals to whom we can send our advertisements on the social media platform and its affiliated network of websites. This “Custom Audience” list is created and stored only on your social media platform and although we can send our advertisements to you on these platforms, we do not have access to your social media profile or any of the information on your social media account. This information remains under the control and protection of your social media platform.
We share your Personal Information if we are under a duty to do so, in order to comply with (or where we reasonably believe we are under a duty to comply with) any legal obligation; or in order to enforce any agreement we have in place with you; or to protect the rights, property, safety, or security of HLTH, third parties, users of our Site and services or the public.
Occasionally, we may be required by law enforcement or judicial authorities to provide Personal Information to the appropriate governmental authorities. We will disclose Personal Information upon receipt of a court order or subpoena or to cooperate with a law enforcement investigation. We fully cooperate with law enforcement agencies in identifying those who use our services for illegal activities. We reserve the right to report to law enforcement agencies any activities that we in good faith believe to be unlawful.
We may also share your Personal Information with acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, HLTH or our affiliates (including, in connection with a bankruptcy or similar proceedings).
We share your Personal Information where you give us express permission to do so in the course of your relationship with us from time to time.
3. Personal Information We Collect and How We Use Personal Information
HLTH INC, the parent company of HLTH Europe Ltd, is located in the United States and we store and process your Personal Information both in the US and in the UK where HLTH Europe Ltd is based. We will also transfer your Personal Information to our service providers that process your Personal Information on our behalf in the US and the UK.
If you are located in the United Kingdom (UK) or European Economic Area (EEA), and we share your Personal Information to parties in countries not recognized as adequate for the transfer of your Personal Information, to the extent a safeguard is required under law for such transfers of your Personal Information, we have put in place Standard Contractual Clauses approved by the EU Commission (for EEA transfers) and the UK government approved international data transfer agreement/addendum (for UK transfers). Please contact us for further details on the safeguards in place.
4. Data Retention
We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.
In certain circumstances you can ask us to delete your data.
In some circumstances we may anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.
5. Your Choices
You can access and modify certain Personal Information stored on our Site, such as your name, phone number, email address, and mailing address, by contacting us via email.
You may opt out of marketing-related email communications by following the opt out or unsubscribe instructions contained in the marketing communications we send you.
Online tracking opt-out. There are a number of ways to limit online tracking on our Services, which we have summarized below:
Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit https://www.allaboutcookies.org/.
Using privacy plug-ins or browsers. You can block our websites from setting cookies by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers.
Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.
California residents may have different or additional rights, please see the “PRIVACY NOTICE FOR CALIFORNIA RESIDENTS” section below.
EEA residents may have different or additional rights, please see the “RIGHTS OF EUROPEAN ECONOMIC RESIDENTS (EEA)” section below.
6. Security
We employ a number of technical, organizational and physical safeguards designed to protect the Personal Information we collect. However, no security measures are failsafe and we cannot guarantee the security of your Personal Information.
7. Privacy Policies of Third-Party Websites
When you use a link to go from our Site to a website operated by a third party, this Privacy Policy does not apply to your activity on that third party website. We are not responsible for the privacy practices employed by third-party websites linked to or from our Site, nor for the information or content contained therein.
8. Links to Other Websites
We may provide links to other websites for your convenience and information. These sites operate independently from our Site and are not under our control. These sites may have their own privacy notices in place, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content of these sites, any products or services that may be offered through these sites, or any other use of these sites.
9. PRIVACY NOTICE FOR CALIFORNIA RESIDENTS
This Section applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”) in compliance with the California Consumer Privacy Act of 2018 (CCPA). Capitalized terms used herein and not defined in the Privacy Policy have the same meaning as defined in the CCPA.
Your California privacy rights. The CCPA grants individuals whose information is governed by the CCPA the following rights:
Information. You can request information about how we have collected and used your Personal Information during the past 12 months. We have made this information available to California residents without having to request it by including it in this Privacy Policy.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt out of sale of your Personal Information. We do not sell Personal Information in the traditional sense. Like many businesses, we use services that display interest-based ads to users around the web. We offer instructions on how to limit online tracking in the “Online tracking opt out” section above.
You are entitled to exercise the rights described above free from discrimination.
Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request. If we deny your request, we will communicate our decision to you.
How users in California can exercise their rights
You may exercise your California privacy rights described above as follows:
Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:
Emailing info@hlth.com
Right to opt out of sale of Personal Information. We offer instructions on how to limit online tracking in the “Online tracking opt-out” section above.
Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf. We will require the authorized agent to have a written authorization confirming that authority.
10. Rights Of UK, EU and EEA Residents
Under certain circumstances, EU and EEA residents have rights under data protection laws in relation to their Personal Information. If you are an EU or EEA resident, you have the right to:
Object to processing of your Personal Information where we are relying on legitimate interests (please see the “Personal Information We Collect and How We Use Personal Information” section above) as a lawful basis for processing your Personal Information and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Information for any direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
You also have the right to:
Request access to your Personal Information (commonly known as a “data subject access request”). This enables you to receive a copy of the Personal Information we hold about you, along with supplemental transparency information similar to what is provided in this Privacy Policy.
Request correction of the Personal Information that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
Request erasure of your Personal Information. This enables you to ask us to delete or remove Personal Information where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal Information where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully or where we are required to erase your Personal Information to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
Request restriction of processing of your Personal Information. This enables you to ask us to suspend the processing of your Personal Information in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
Request the transfer of your Personal Information to you or to a third party. We will provide to you, or a third party you have chosen, your Personal Information in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
Withdraw consent at any time where we are relying on consent to process your Personal Information. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.
Lodge a complaint about the way we handle or process your Personal Information with a data protection regulator.
If you wish to exercise any of the rights set out above, please contact us using the information at the top of this page, or by emailing us at info@hlth.com.