JIMINI HEALTH PRIVACY POLICY
Last Update: April 2, 2024
This notice describes how Personal Data (defined below) and/or medical information about you may be used and disclosed and how you can obtain access to this information on your own behalf. Please review it carefully.
INTRODUCTION
We at Jimini Health (“we”, “us”, or “the Company”) value your privacy and are committed to keeping your personal data confidential. We use your data in accordance with the terms of your consent, and in the context of providing the Jimini Health website and mobile application available in the app stores (together, the “Platform”) as well as all relevant content and functionality associated with the Platform (the “Services”) to provide services and care to users (“Users”).
When you enroll, inquire about enrolling for or use the Services, we keep a record of medical information that you provide to us or you therapist as well as any medical information that you provide.
Privacy Policy Applicability
This Privacy Policy applies to personal data that Jimini Health collects from Users of the Jimini Health Platform and the Services (“Personal Data”). The term “Personal Data” includes any information that can be used on its own or with other information in combination to identify or contact one of our users. Some of the Personal Data we collect and transmit may be considered “health data” (i.e., data related to your physical or mental health), “protected health information” or “PHI” (i.e., information that relates to your past, present, or future physical or mental health or condition(s); the provision of health care to you; or the past, present, or future payment for the provision of health care to you), and/or medical records as defined by state law.
In addition to this Privacy Policy, the HIPAA Notices of Privacy Practices of Jimini Health’s provider entities apply to your PHI.
We believe that privacy and transparency about the use of your Personal Data are of utmost importance. Therefore, our privacy practices are intended to comply with all applicable federal and state laws related to privacy and the use and disclosure of medical records. Additionally, in this Privacy Policy, we provide you detailed information about our collection, use, maintenance, and disclosure of your Personal Data. The Privacy Policy explains what kind of information we collect, when and how we might use your Personal Data, how we protect Personal Data, and your rights regarding your Personal Data.
For additional information related to how we use and disclose your Personal Data, health data, PHI, and/or medical records data, please contact us at support@jiminihealth.com.
Agreement to Privacy Policy Terms
BY ACCESSING AND/OR USING THE SERVICES AND PLATFORM, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS PRIVACY POLICY. IF YOU DO NOT AGREE, YOU MUST IMMEDIATELY CEASE USING THE SERVICES AND PLATFORM.
Privacy Policy Updates
Please note that we occasionally update this Privacy Policy, and it is your responsibility to stay up to date with any amended versions. Users will be notified of any revisions to the Privacy Policy via email and through the application (as applicable). Any changes to this Privacy Policy will be effective immediately upon providing notice and will apply to all Personal Data that we maintain, use, and disclose. If you continue to use the Services and Platform following such notice, you are agreeing to those changes.
Account Deletion
If at any point you no longer agree to the use and disclosure of your Personal Data, as described in this Privacy Policy, you can delete your Platform user account (“User Account”) by sending a deletion request to support@jiminihealth.com with the following information:
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Your login email address; and
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A statement that you are requesting account deletion.
Once we have deleted your User Account, we will provide confirmation to you via email that your User Account has been deleted. However, please also refer to Collection and Use of Personal Data, Section VII, which addresses Jimini Health’s legal obligation to retain certain information related to your health after you delete your account.
Questions or Concerns
If you have any questions or concerns after reading this Privacy Policy, please do not hesitate to contact us at support@jiminihealth.com. We appreciate your feedback.
COLLECTION AND USE OF PERSONAL DATA
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What Personal Data Does Jimini Health Collect? We collect the following types of information, including information that is voluntarily provided, from our Users.
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Demographic and Medical Data: Jimini Health collects the following information when you create an account for yourself and are matched to a therapist, or register yourself as a patient:
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Name
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Address
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State and Country
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Date of Birth
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Phone Number
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Copy of Driver’s License or Other Official Form of Identification
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Photo
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Gender
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Sexual Orientation
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Race/Ethnicity
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Email
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Relationship Status
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Employment Status
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Information on the type of subscription you choose
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Referral source
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Information on why you are accessing our Services including what you are hoping to get from therapy
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Information regarding your mental health and mental health history
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Notification preferences
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Emergency Contact Information
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User Signature
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Use of Services: Data you provide when you use Jimini Health therapy services, including:
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Information you disclose in chat data and your chat sharing preferences (transcripts)
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Audio/Video communication; and any recordings or transcripts of audio/video communication
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Documents you share with your therapist via our chat functionality
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Information collected via the Platform tracker and information on your clinical progress
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Information collected via the therapeutic exercises
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Information collected via therapeutic assessments
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Information collected regarding your use of the Platform
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Information collected via chat, telephone, or email support channels
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Information you provide as part of treatment intake including emergency contact details, information on your health and mental health and medical history, images (optional)
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Information shared through the online chat support feature and your email address
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Support Data: If you contact us via email or otherwise for support or to lodge a complaint, we may collect technical or other information from you through log files and other technologies, some of which may qualify as Personal Data (e.g., IP address). Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the Platform and related Services in accordance with this Privacy Policy. Calls with Jimini Health may be recorded or monitored for training, quality assurance, customer service, and reference purposes.
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Payment Information and Transaction History: To process payment for Services subscriptions, we will request that you provide us your financial and billing information, such as billing name and address, credit card number, or bank account information.
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Technology Data: We use common information-gathering tools, such as Platform metrics, log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain Personal Data from your computer or mobile device as you navigate our Platform or interact with emails or other communications we have sent you. The information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, help us provide and improve our Services through the use of anonymized or aggregated data, comply with legal obligations, facilitate the delivery and optimization of Services, monitor performance of networks, systems and applications, to develop new products, and ensure the proper functioning and security of the Platform and Services.
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Does this Privacy Policy Apply to Third Party Sites? Our Services may contain links to other sites that are not operated by Jimini Health. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy(ies) of every site you visit. Jimini Health has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services. This Privacy Policy does not apply to your use of or access to any third-party sites or services. Please note that if you choose to link our Services to a third-party account, such as social media or an online forum, we may receive information about you, including your profile information, your photo, and your use of the third-party account. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.
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How Will Jimini Health Use Your Personal Data? Jimini Health processes your Personal Data based on legitimate business interests, the fulfillment of our Services to you, compliance with our legal obligations, and/or your consent. We only use or disclose your Personal Data when it is legally mandated or where it is necessary to fulfill those purposes described in this Privacy Policy. Where required by law, we will ask for your prior consent before disclosing your Personal Data to a third party. More specifically, Jimini Health processes your Personal Data for the following legitimate business purposes:
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To provide Services;
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To match you to a therapist;
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To conduct therapist oversight;
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To provide you with assistance in the event of an emergency;
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To fulfill our obligations to you under the Terms of Use;
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To communicate with you about and manage your User Account;
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To provide announcements and communicate with you, including for marketing purposes
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To properly store and track data within our Platform;
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To respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings and court orders;
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To protect our rights, privacy, safety, or property, and/or that of you or others by providing proper notices, pursuing available legal remedies, and acting to limit our damages;
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To handle technical support and other requests from you;
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To address any complaints;
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To enforce and ensure your compliance with our Terms of Use or the terms of any other applicable services agreement we have with you;
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To manage and improve our operations, Services, and the Platform, including the development of additional functionality;
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To support machine learning model training and analytics;
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To analyze how our Services and the Platform are being used so we can improve User experience;
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To evaluate the success of our marketing campaigns;
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To manage payment processing;
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To control quality of Services, as well as to evaluate the quality of the Service you receive, identify usage trends, and improve your user experience;
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To find and prevent fraud, and keep our Services and Platform safe and secure;
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To send you information about changes to our terms, conditions, and policies;
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To conduct research and analysis (for additional information see below), internally and with approved research partners, using your information, which may be subject to your separate written authorization;
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To report permissive reporting of expressed threats of violence towards an ascertainable victim;
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To allow us to pursue available remedies or limit the damages that we may sustain; and
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For other purposes for which we provide specific notice at the time the information is collected.
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Does Jimini Health Use Personal Data for Analytics? Jimini Health uses third-party service providers to monitor and analyze the use of the Platform as part of our Services. The analytics services we use may include but are not limited to: Google Analytics, Squarespace, and Meta.
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With Whom Does Jimini Health Share Personal Data? We may share your personal information with the following categories of individuals/entities:
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Business Partners and Vendors: We share Personal Data with a limited number of partners, service providers, and other persons/entities who help run our business (“Business Partners”). Specifically, we may employ third-party companies and individuals to facilitate our Services, provide Services on our behalf, perform Service-related functions, or assist us in analyzing how our Services are used. Our Business Partners are contractually bound to protect your Personal Data and to use it only for the limited purpose(s) for which it is shared. Business Partners’ use of Personal Data may include, but is not limited to, the provision of services such as data hosting, IT services, customer services, order fulfillment, and payment processing.
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Our Advisors: We may share your Personal Data with third parties that provide advisory services to Jimini Health, including, but not limited to, our lawyers, auditors, accountants, and banks (collectively, “Advisors”). Personal Data will only be shared with Advisors if Jimini Health has a legitimate business interest in the sharing of such data.
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JHProviders: Jimini Health will make your Personal Data available to its affiliated healthcare therapists and providers (“JH Providers”) for the purposes of providing the Services, and to oversee and direct your mental health care.
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Third Parties Upon Your Direction or Consent: You may direct Jimini Health to share your Personal Data with third parties. Upon your request and consent, we may share such Personal Data with those third parties that you identify.
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Third Parties Pursuant to Business Transfers: In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Jimini Health’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may share your Personal Data with a third party.
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Government and Law Enforcement Authorities: If reasonable and necessary, we may share your Personal Data to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that violate this Privacy Policy or the Terms of Use; or (iii) bring legal action against someone who may be violating the Terms of Use or who may be causing intentional or unintentional injury or interference to the rights or property of Jimini Health or any third party, including other users of our Services.
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How Long Does Jimini Health Retain Personal Data? Jimini Health retains your Personal Data only if necessary and as required for our business operations, the provision of Services, archival purposes, and/or to satisfy legal requirements. The exact period of retention (the “Retention Period”) will depend on: (i) the amount, nature, and sensitivity of the Personal Data; (ii) the personal risk of harm for unauthorized use or disclosure; (iii) the purposes for which we process your Personal Data, including whether those purposes can be achieved through other means; and (iv) business operations and legal requirements. Please note, all PHI and other data that may be considered part of a User’s medical record will be maintained in accordance with all applicable medical retention laws, rules and regulations, by JH Providers. At the end of the applicable Retention Period, we will remove your Personal Data from our databases and will require that our Business Partners remove any identifiable Personal Data from their databases. If there is any data that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing of such data. Please note that once we disclose your Personal Data to third parties, we may not be able to access that Personal Data and we cannot force the deletion or modification of such information by third parties. Jimini Health and its Business Partners reserve the right to continue using de-identified data indefinitely, even after Personal Data has been removed from Jimini Health’s databases. We may continue to disclose de-identified data to third parties in a manner that does not reveal personal information, as described in this Privacy Policy. Our continued use of de-identified data will comport with applicable law.
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How Will Jimini Health Use My Personal Data for Research? Separate and apart from internal healthcare operations and quality assurance activities undertaken for the purpose of delivering and optimizing patient care via the Services and through the Platform, from time to time, Jimini Health may conduct or participate in research studies on its own or with third parties, such as universities. You may be offered the opportunity to participate in these studies. If your PHI will be disclosed as part of these studies, your information will only be included upon your written authorization. You will be asked to review and accept terms and enrollment separately from the information included in this Privacy Policy. Information from these studies may be published by third parties including through various media platforms/academic journals.
USER RIGHTS
What Rights Do Users Have Concerning Their Personal Data?
As a user of Jimini Health’s Services and Platform, you have certain rights relating to your Personal Data. These rights are subject to local data protection and privacy laws, and may include the right to:
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Access Personal Data held by Jimini Health;
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Erase/delete your Personal Data, to the extent permitted by applicable data protection and privacy laws and to the extent technologically feasible (note, however, that PHI and related medication information contained in your medical record will remain subject to Retention Period requirements as well as all applicable state and federal laws, including HIPAA);
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Receive communications related to the processing of your Personal Data;
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Restrict the processing of Personal Data to the extent permitted by law;
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Object to the further processing of your Personal Data, including the right to object to marketing;
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Request that your Personal Data be transferred to a third party, if possible;
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Receive your Personal Data in a structured, commonly used, and machine-readable format; and/or
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Rectify inaccurate personal information and, considering the purpose of processing the Personal Data, ensure it is complete.
Where the processing of your Personal Data by Jimini Health is based on consent, you have the right to withdraw that consent at any time. If you would like to withdraw your consent or exercise any of the above rights, please contact us at support@jiminihealth.com.
How Can Users Update, Correct, or Delete Personal Data or Their User Account?
You have the right to request restrictions on uses and disclosures of your Personal Data. While we are not required to agree to all restriction requests, we will attempt to accommodate reasonable requests when appropriate.
You may change your email address and other contact information by contacting us at support@jiminihealth.com. To comply with certain requests to limit use of your Personal Data, we may need to terminate your ability to access and/or use some or all of the Services. BY REQUESTING TO LIMIT USE OF YOUR PERSONAL DATA OR DELETE PERSONAL DATA, YOU ACKNOWLEDGE AND AGREE THAT JIMINI HEALTH WILL NOT BE LIABLE TO YOU FOR ANY CORRESPONDING LIMITATION IN THE SCOPE OF SERVICES OR TERMINATION OF SERVICES AS NECESSARY TO COMPLY WITH YOUR REQUEST.
You have the right to request deletion of any Personal Data from your User Account or the Jimini Health Platform. To request deletion of your Personal Data, please email us at support@jiminihealth.com and include a description of the Personal Data you would like removed. We will respond to all requests for data deletion as soon as reasonably possible.
Should you decide to delete your User Account entirely, you may do so by emailing support@jiminihealth.com. By terminating your User Account, you agree that you will not be able to access any information previously contained in your User Account. You further understand that it may not be technologically possible to remove all of your Personal Data from our systems. While we will use reasonable efforts to remove your Personal Data, the need to back up our systems to protect information from inadvertent loss means a copy of your Personal Data may exist in a non-erasable form that will be difficult or impossible for us to locate or remove.
Notwithstanding the foregoing, as noted above, all PHI and certain other data that may be considered part of a medical record will be maintained in accordance with all applicable medical retention laws, rules and regulations, by a JHProvider. If after your User Account has been deleted, you need access to test results, please contact the Provider directly.
PROTECTION OF PERSONAL DATA
Is Personal Data Secure?
Jimini Health understands the importance of data confidentiality and security. We use a combination of reasonable physical, technical, and administrative security controls to: (i) maintain the security and integrity of your Personal Data; (ii) protect against any threats or hazards to the security or integrity of your Personal Data; and (iii) protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm to you.
While Jimini Health uses reasonable security controls, WE CANNOT GUARANTEE OR WARRANT THAT SUCH TECHNIQUES WILL PREVENT UNAUTHORIZED ACCESS TO YOUR PERSONAL DATA. JIMINI HEALTH IS UNABLE TO GUARANTEE THE SECURITY OR INTEGRITY OF PERSONAL DATA TRANSMITTED OVER THE INTERNET, AND THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. ACCORDINGLY, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US. YOU ASSUME THE RISK THAT UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE FAILURE, AND OTHER FACTORS MAY COMPROMISE THE SECURITY OF YOUR PERSONAL DATA AT ANY TIME.
What Safeguards Does Jimini Health Have in Place to Secure Personal Data?
Jimini Health stores Personal Data on secured servers and uses a combination of technical, administrative, and physical safeguards to protect your personal information. Such safeguards include, but are not limited to, authentication, encryption, backups, secure socket layer technology (SSL) encryption, and access controls.
How Can Users Protect Their Personal Data?
You are solely responsible for preventing unauthorized access to your devices and your User Account by protecting your account credentials and limiting access to your devices. Jimini Health has no access to or control over your device’s security settings, and it is your responsibility to implement any device-level security features and protections you feel are appropriate (e.g., password protection, encryption, remote wipe capability). We recommend that you take all appropriate steps to secure any device that you use to access our Services and Platform.
Please note that Jimini Health will never send you an email requesting confidential information, such as account numbers, usernames, passwords, or Social Security Numbers. If you receive a suspicious email from Jimini Health, please notify us at support@jiminihealth.com.
Further, if you know of or suspect any unauthorized use or disclosure of your User Account information or any other security concern, please notify Jimini Health immediately.
What If Jimini Health Experiences a Data or Security Breach?
Jimini Health takes the security of your Personal Data seriously. In the event of a data or security breach, Jimini Health will take the following actions: (i) promptly investigate the security incident, validate the root cause, and, where applicable, remediate any vulnerabilities within Jimini Health’s control which may have given rise to the security incident; (ii) comply with laws and regulations directly applicable to Jimini Health in connection with such security incident; (iii) as applicable, cooperate with any affected Jimini Health user or client in accordance with the terms of Jimini Health’s contract with such user or client; and (iv) document and record actions taken by Jimini Health in connection with the security incident and conduct a post-incident review of the circumstances related to the incident and actions/recommendations taken to prevent similar security incidents in the future. Jimini Health will notify you of any data or security breaches as required by and in accordance with applicable law.
ADVERTISING, MARKETING, AND TRACKING
Does Jimini Health Send Marketing or Advertisement Materials?
Jimini Health may use your Personal Data to contact you with newsletters, marketing, or promotion materials and other information that may be of interest to you. You may opt out of receiving any marketing or advertisement materials from Jimini Health at any time by following the unsubscribe link or by contacting us.
Can Users Opt Out of Receiving Communications from Jimini Health?
We may send communications, including emails, to you regarding your User Account and the Services or Platform. You can choose to filter any User Account, Services, and Platform emails using your email settings, but we do not provide an option for you to opt out of these communications.
If you consent to receive marketing or other communications not related to your User Account or the Services/Platform, we will provide you with the option to opt out of such marketing communications within the applicable message.
What Is Jimini Health’s Cookie Policy?
Cookies are small files that a web server sends to your computer or device when you visit a web application that uses cookies to keep track of your activity on that site. Cookies also exist within applications when a browser is needed to view or display certain content within the application. Cookies hold a small amount of data specific to a web application, which can later be used to help remember information you entered in the application (like your email or username), preferences selected, and movement within the application. We use cookies and other technologies to, among other things, better serve you with more tailored information, and to facilitate efficient and secure access to the Services.
Our cookies do not, by themselves, contain Personal Data. Further, we do not combine the general information collected through cookies with any other Personal Data to identify you. However, we do use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your User Account (if one exists).
In addition, Jimini Health may also collect information using pixel tags, web beacons, clear GIFs, or other similar technologies. This information may be used in connection with website pages and HTML formatted email messages to, among other things, track the actions of users and email recipients and compile statistics about usage and response rates.
How Can Users Opt Out of Cookies?
If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you enable a do not track signal or otherwise configure your browsers to prevent us from collecting cookies, you will need to reenter your login information each time you visit the login page. You may also be unable to take advantage of some of the Services.
Do Not Track Disclosure
Some web browsers may transmit do not track (“DNT”) signals to websites with which the User communicates. To date, there is no industry standard for DNT and users cannot know how a given company responds to a DNT signal they receive from browsers. Jimini Health is committed to remaining apprised of DNT standards. However, Jimini Health does not support DNT browser settings and does not currently participate in any DNT frameworks that would allow Jimini Health to respond to signals or other mechanisms regarding the collection of your personal information.
CONTACT US
If you have questions regarding this Privacy Policy, you may contact us at support@jiminihealth.com.