This Privacy Policy describes the privacy practices of Elaborate Health Inc., doing business as Elaborate, ("Elaborate," "we", “us” or "our") and how we handle personal information that we collect through our digital properties that link to this Privacy Policy, including our website and web-based application (collectively, the “Service”), as well as through social media, our marketing activities, and other activities described in this Privacy Policy.

Elaborate contracts with healthcare providers to offer our software services to their patients. This Privacy Policy does not apply to information that we process on behalf of our enterprise customers while providing Elaborate services to them. Our agreements with our enterprise customers govern how we may process personal information on behalf of our enterprise customers that such enterprise customers provide to us. If you have concerns regarding personal information that we may process on behalf of an enterprise customer, please direct your concerns to that enterprise customer.

Elaborate may provide additional or supplemental privacy policies for specific products or services that we offer at the time we collect personal information

Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, email address, billing and mailing addresses, professional title and company name, and phone number.

• Demographic data, such as your city, state, and postal code.

• Profile data, such as the username and password that you may set to establish an online account with us, date of birth, interests, preferences, information about your participation in our contests, promotions, or surveys, and any other information that you add to your account profile.

• Health data, such as medical providers’ names/practices, diagnoses, medication history, and any other information that you add to your account that details past, present, and/or future medical care.

• Communications data, based on our exchanges with you, including when you contact us with questions or feedback, through the Service, social media, or otherwise.

• Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.

• Payment data, needed to complete transactions, including payment card information or bank account number.Government-issued identification numbers, such as national identification number (for example, Social Security Number, passport number, or similar), state or local identification number (for example, driver’s license or state ID number), and an image of the relevant identification card.

• Government-issued identification numbers, such as national identification number (for example, Social Security Number, passport number, or similar), state or local identification number (for example, driver’s license or state ID number), and an image of the relevant identification card.

• Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.

• User-generated content data, such as comments, questions, messages, works of authorship, and other content or information that you generate, transmit or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where, and by whom a piece of content was collected and how that content has been formatted or edited.

• Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection

We may combine personal information we receive from you with personal information we obtain from other sources, such as:

• Medical providers, such as our enterprise customers provide us with your information to the extent we can use such information for our own purposes.

• Public and private sources, such as government agencies, public records, social media platforms, and other public or private sources.

• Data providers, such as information services and data licensors provide us with personal information for our purposes such as lead generation.

• Our affiliate partners, such as our affiliate network provider and publishers, influencers, and promoters participate in our paid affiliate programs.

• Marketing partners, such as joint marketing partners and event co-sponsors.

• Third-party platforms/networks, for example, if you choose to login to the Service or otherwise connect a third-party platform/network account to the Service, we may collect information from that platform or network. For example, this data may include your username, profile picture, and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.

We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications, and other online services, such as:

• Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information such as city, state or geographic area.

• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our marketing emails or clicked links within them.

Like many online services, we may use the following technologies:

• Cookies, are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating analytics and online advertising.

• Local storage technologies, like HTML5 and Flash, provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.

• Web beacons, also known as pixel tags or clear GIFs, are used to demonstrate that a webpage or email address was accessed or opened, or that certain content was viewed or clicked.

• Session-Replay Technologies, such as through third-party services provided by, for example, Hotjar that employ software code to record users’ interactions with the Services in a manner that allows us to watch DVR-like replays of those user sessions. The replays may include users’ clicks, mouse movements, scrolls, and keystrokes/key touches during those sessions. These replays help us diagnose usability problems and identify areas for improvement. You can learn more about Hotjar at https://www.hotjar.com/legal/policies/privacy/ and you can opt-out of session recording by Hotjar at https://www.hotjar.com/legal/policies/do-not-track/

• Software Development Kids (SDKs), such as third-party computer code that may be used for a variety of purposes, including providing us with analytics regarding the use of our Service, integrating with social media, adding features or functionality to our service, or facilitating online advertising. SDKs may enable third parties to collect information directly via our Service.

These technologies may be used for the following purposes:

• Functionality. To allow the operation of the Service and certain Service features, such as by remembering your selections and preferences as you navigate the site, and whether you are logged in when you visit password-protected areas of the Service.

• Advertising. To help our third-party advertising partners collect information about how you use the Service and other online services over time, which they use to show you ads on other online services they believe will interest you and measure how the ads perform.

• Analytics. To help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails. For example, we may use Heap and other third-party cookie technologies for this purpose. You can learn more about Heap and how to prevent the use of Heap relating to your use of our sites here: https://heap.io/why-heap/how-heap-works.

• Essential. These cookies are necessary to allow the technical operation of the Service. For example, they enable you to move around the website and the Service’s features.

Users of the Service may have the opportunity to refer other contacts to us and share their contact information with us. Please do not refer someone to us or share their contact information with us unless you have their permission to do so.

We may use your personal information for the following purposes or as otherwise described at the time of collection:

We may use your personal information to:

• provide, operate and improve the Service and our business;

• establish and maintain your user profile on the Service;

• enable security features of the Service, such as by sending you security codes via email, and remembering devices from which you have previously logged in;

• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;

• administer quizzes, surveys, sweepstakes, promotions and contests;

• understand your needs and interests, and personalize your experience with the Service and our communications; and

• provide support for the Service, and respond to your requests, questions, and feedback.

We may use your personal information for research and development purposes, including to analyze and improve the Service and our business.

We, our service providers, and our third-party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct marketing. We may send you Elaborate-related or other direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.

• Interest-based advertising. We may engage third-party advertising companies and social media companies to display ads on our Service and other online services. These companies may use cookies and similar technologies to collect information about your interaction (including the data described in the automatic data collection section above) over time across the Service, our communications and other online services, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section below.

We may 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;

• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);

• audit our internal processes for compliance with legal and contractual requirements and internal policies;

• enforce the terms and conditions that govern the Service; and

• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.

We may create anonymous, aggregated or de-identified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de-identified data by removing information that makes the data identifiable to you. We may use this anonymous, aggregated or de-identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

We also may use your information as may be described in a notice to you at the time the information is collected, or in any other manner to which you consent.

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.

We may disclose your personal information to our subsidiaries and corporate affiliates for purposes consistent with this Privacy Policy.

Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, and website analytics).

Any payment card information you use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy. You may also sign up to be billed by your mobile communications provider, who may use your payment data in accordance with their privacy policies.

Third-party advertising companies for the interest-based advertising purposes described above.

We may share your personal information with third parties where you have instructed us or provided your consent to do so. For example, we may share your personal information with medical providers to offer you additional services. We do not control how such third parties may use your personal information.

We may share your personal information with the relevant enterprise customer with whom you have an existing medical care relationship. We do not control how our enterprise customers may use your personal information.

Professional advisors, such as lawyers, auditors, bankers, and insurers where necessary in the course of the professional services that they render to us.

Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.

Acquirers and other relevant participants in business transactions (or negotiations and diligence 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, Elaborate or our affiliates (including, in connection with a bankruptcy or similar proceedings).

You have the following choices with respect to your personal information.

If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and visiting your Account Preference page. You may also contact us to confirm that personal information we have about you is complete, accurate, and as current as possible or to delete your account. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, by visiting your Account Preferences page, or by contacting us. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.

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. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org.

You may be able to limit use of your information for interest-based advertising by:

• Browser settings. Blocking third-party cookies in your browser settings.

• Privacy browsers/plug-ins. By using privacy browsers or ad-blocking browser plug-ins that let you block tracking technologies.

• Platform settings. Google and Facebook offer opt-out features that let you opt out of the use of your information for interest-based advertising:

  • Google: https://adssettings.google.com/

  • Facebook: https://www.facebook.com/about/ads

• Ad industry tools. Opting out of interest-based ads from companies participating in the following industry opt-out programs:

  • Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp

  • Digital Advertising Alliance: optout.aboutads.info

  • AppChoices mobile app, available at https://www.youradchoices.com/appchoices, will allow you to opt-out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance.

• Mobile settings. Using your mobile device settings to limit the use of the advertising ID associated with your mobile device for interest-based advertising purposes.

You will need to apply these opt-out settings on each device from which you wish to opt out.

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.

We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.

You can choose to delete certain content through your account. If you wish to request to close your account, please contact us at info@elaborate.com.

The Service may contain links to websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites and mobile applications and online services you use.

We employ a number of technical, organizational, and physical safeguards designed to protect the personal information we collect. However, the security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

The Service is not intended for use by children under 18 years of age. If we learn that we have collected personal information through the Service from a child under 13 without the consent of the child’s parent or guardian as required by law, we will delete it. If you believe we might have any information from a child under 13, please contact us at info@elaborate.com.

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

• Mail: 335 Madison Ave, Floor 4, New York, NY 10017

• Email:

  • General questions - info@elaborate.com

  • Privacy questions - privacy@elaborate.com

  • Security questions - security@elaborate.com