‍Overview

This Privacy Policy describes how Elder Technologies, Inc. (together with its affiliates, “Sage”, “we”, “us”, “our”, or the “Company”) collects, uses, and discloses Personal Data when you access or use https://www.hellosage.com/, our mobile application, and any other websites or platforms that the Company may create in the future (the “Website”), including the Company’s home and healthcare monitoring solution (“Care Services”) (collectively with the Websites, the “Platform”).   

This Privacy Policy does not apply to information that may fall under another state or federal regulatory framework, like the Health Insurance Portability and Accountability Act (“HIPAA”).

This Privacy Policy uses the term “Personal Data” to describe information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Personal Data We Collect / Sources of Personal Data

The table below details the categories of Personal Data that we may collect or obtain through the operation of the Platform. In addition to the sources listed below, we may collect this information from third-party service providers or vendors, including data analytics providers, and through the use of automatic tracking technologies. What information we collect depends on your interaction with the Platform. Please note that, depending on your use of the Platform, you may fall into one or more categories below. Additionally, unless otherwise stated, the below table applies to all of the following categories:

• Users: individuals who use the Care Services as part of their own home or health care activities. Users may also access some or all of the Platform in conjunction with the Care Services.
• Caregivers: individuals who are part of the User’s care team or otherwise monitor and care for Users who use the Care Services. Caregivers access some or all of the Platform in conjunction with the Care Services.
• Website Visitors: individuals who visit the Website.

How We Use Personal Data

We may use or disclose the Personal Data that we collect for one or more of the following purposes:

• Maintain, protect, operate, and improve the Platform;
• Communicate with you regarding the Platform;
• Address your inquiries; 
• Process transactions; 
• Tailor the content and information that we may send or display to you, including marketing communications; 
• Analyze use of our products, services, and the Platform;
• Improve the Platform and develop new products and services; 
• Comply with legal obligations; 
• Protect our rights, property, and safety or the rights, property, and safety of others; and
• Evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by us about our customers is among the assets transferred. You hereby consent to such transfers and we may assign and transfer all of the rights, benefits, duties, and obligations of this Privacy Policy, under the circumstances described in this paragraph.

From time to time, we may contact you via email and mail, for the purpose of providing announcements, promotional offers, alerts, confirmations, surveys, and/or other general communication. If you would like to stop receiving marketing or promotional communications via email or mail from us, you may opt-out of such communications by contacting us at the toll-free number or email address listed below.

‍How We Disclose Personal Data

We may disclose all categories of Personal Data described above in “Personal Data We Collect” to the third parties listed below for the purpose of providing the Platform.

• With Our Service Providers. We may disclose Personal Data about you with service providers that perform services for us or on our behalf. For example, this may include payment processors, companies that send emails on our behalf, or vendors that provide technology tools that help us run our services.
• With Caregivers or Other Healthcare Team Members. We disclose Personal Data about Users to Caregivers and other individuals or entities that are involved in health and care of Users. This may include parties that are involved in the direct provision of healthcare or other supporting entities that help facilitate and process treatment, payment, or other healthcare operations.
• Affiliates and Other Business Partners. This includes our affiliates or other organizations in the healthcare or caregiving industries.
• With Law Enforcement, Government Agencies, or Parties to a Legal Proceeding.  We may disclose Personal Data with such entities to comply with the law or assist in law enforcement. We may also disclose Personal Data to law enforcement and similar emergency services providers as needed in the context of providing the Care Services to Users.
• With Our Advisors. Attorneys, auditors, consultants, and similar advisors may access Personal Data in order to advise us on legal, business, or financial issues.  
• With Data Analytics Providers and Advertising Networks. These third parties may collect Personal Data about Website Visitors over time and across different websites, applications, and devices for the purposes of targeted advertising. Specifically, these providers may collect internet or other similar network activity information, details about your interaction with the Platform, social media information, demographic information, and/or commercial information. For more information on these third parties, please see the below “Cookie Policy.”
  
  We may partner with these third parties to tailor and customize our advertising to Website Visitors. The practice of targeted advertising may be considered a “sale” of Personal Data under some state laws. For more information about your choices related to this practice, please see “Your State Privacy Rights” below.

• As Otherwise Directed by You. 

‍Online Targeted Advertising

The Platform uses cookies, pixel tags, web beacons, and similar technologies to track and enhance your experience with the Platform. We and third parties, such as data analytics providers, social media networks, and advertising networks, use these technologies on our Platform to support and protect the Platform, for our own record-keeping purposes, as well as marketing and advertising uses.

You may choose to set your web browser to refuse cookies or to alert you when cookies are being sent. If you do so, some parts of the Platform may not function properly.  Our Platform does not recognize “Do Not Track” signals, but it may recognize other opt-out preference signals, such as the Global Privacy Control (“GPC”). You may set such a signal through your browser or browser extension.

Certain U.S. state privacy laws, including California, may consider targeted advertising a “sale” of Personal Data. Because we engage in targeted advertising, in the last twelve (12) months, we have “sold” or “shared” Commercial Information, Internet or Similar Network Activity, and Educational and Professional Information identified in “PERSONAL DATA WE COLLECT” with advertising networks, data analytics vendors, and social media networks

‍Children Under the Age of 16

The Platform is not intended for children under 16 years of age. We do not collect information about individuals under the age of 16.  No one under age 16 may provide any information through the Platform. We do not knowingly collect Personal Data from children under 16, and we do not have actual knowledge that we sell or share the Personal Data of children under 16. If you are under 16, do not use or provide any information through the Platform. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us.

Your Data Privacy Rights

Depending on your residency, you may have rights relating to your Personal Data. Specifically, residents of the following states may have some or all of the rights listed below: Texas, California, Colorado, Connecticut, Indiana, Iowa, Montana, Oregon, Tennessee, Nevada, Utah, and Virginia.  We reserve the right to honor your requests to exercise these rights in accordance with applicable law, including our ability to charge a reasonable fee for certain requests, such as if you request multiple copies of Personal Data.

You may have the following rights: (1) know what Personal Data we collect, use, disclose, and sell; (2) request that we delete your Personal Data that we maintain; (3) access and obtain a copy of your Personal Data that we collect; (4) correct or edit Personal Data you believe to be inaccurate; (5) opt out of targeted advertising (sometimes referred to as “sharing”); (6) opt out of “sales” of Personal Data; or (7) limit or opt out of other processing activities, such as the use and disclosure of “sensitive” Personal Data and/or certain automated decision making processes. You also have the right to not receive discriminatory treatment for exercising these rights.

To exercise any of these rights, please follow the instructions in “CONTACT INFORMATION” below. In order to protect your Personal Data from unauthorized access or deletion, we may require you to verify your account credentials and/or provide additional Personal Data to verify your identity before we process your rights request. If we are subsequently unable to confirm your identity, we may refuse your rights request. 

You may use an authorized agent to submit a rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the rights request. However, we will not request this information if your authorized agent provides documentation showing that the authorized agent has power of attorney.

If you would like to appeal a decision regarding a previous request, please indicate so in your request details, along with a short description of your prior request and the outcome that you are seeking. We may request more information in order to locate your prior request.

Retention of Data

We retain Personal Data where we have an ongoing legitimate business or legal need to do so. Our retention periods vary depending on the type of data involved.  Generally, we consider the following to determine the retention period: whether the data is reasonably necessary to provide the Platform, your reasonable expectations regarding the type of data collected and purposes for which it was collected, and any other legal or contractual obligations to retain the data. 

Data Security

We cannot guarantee absolute security, however we use commercially reasonable measures to protect our Company and your Personal Data from unauthorized access. 

Third-Party Applications and Links

Our Platform uses third-party applications, integrations, and links to enhance your experience. We disclaim any and all liability and responsibility for the use of these technologies and resources, and we encourage you to review their individual privacy policies before using our Platform or otherwise engaging with us.

Updates to This Privacy Policy

We may revise this Privacy Policy from time to time. If we make material changes to this Privacy Policy, we will notify you by email or by posting a notice on our Platform prior to or on the effective date of the changes. By continuing to access or use the Platform after those changes become effective, you acknowledge the revised Privacy Policy.

Contact Information

If you have any questions or comments about this notice, or the ways in which we collect and use your Personal Data, please do not hesitate to contact us at:

Phone: (908) 516-0991‬

Email: bd@hellosage.com

Address: 144 N 7th St, Suite 536, Brooklyn, NY 11249

Statement for California Residents

The following disclosures are made in compliance with the California Consumer Privacy Act, as amended (“CCPA”). In the past twelve (12) months, we have collected the Personal Data described above, and disclosed it to the third parties listed under the section “DISCLOSING PERSONAL DATA” for the business purposes identified therein and under the section “HOW WE USE PERSONAL DATA.” This information falls into the following categories of Personal Data under the CCPA:

• Identifiers;
• Categories of Personal Data described in section 1798.80(e) of the California Civil Code;
• Characteristics of protected classifications under California or federal law;
• Commercial information;
• Geolocation information;
• Audio, electronic, visual, thermal, or similar information;
• Internet or electronic network activity information;
• Professional or employment-related information; 
• Educational information; 
• Sensitive Personal Data: precise geolocation, login credentials, racial or ethnic origin, personal information concerning a consumer’s health, and the contents of messages that you send through the Platform; and
• Inferences drawn from any of the information identified above.

We do not use or disclose “sensitive” Personal Data for purposes other than those specified in Cal. Code Regs. tit. 11, § 7027(m).