Effective Date: January 1, 2020
Last Revised: November 16, 2020
kaleo, Inc. (“Company,” “we,” or “us”) respects your concerns about privacy. This Privacy Notice describes the types of personal information we collect on websites, mobile sites, mobile applications, and other digital services and products that are owned or controlled by us and that link to this Privacy Notice (collectively, our “Sites”), how we may use the information, and with whom we may share it. This Privacy Notice does not apply to any website, mobile app or other service or product operated by us that has a separate privacy notice or to any linked website that is not owned by us. The Privacy Notice also describes the measures we take to safeguard personal information and how users can contact us about our privacy practices.
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We obtain certain personal information through our Sites or offline. “Personal information” is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. We collect or obtain the following categories of personal information about you. Please see How We Use Personal Information for more information about why we collect the categories of information below.
Examples of Information We Collect
We collect names, addresses, phone numbers, email addresses, and account names (collectively, “Contact Information”) of patients, caregivers, health care professionals (“HCPs”) and others when you communicate with us or to provide our products and services. We collect identifiers about HCPs, such as license number and NPI number, for regulatory compliance purposes. From our shareholders, we collect the information required for regulatory compliance and communications, such as name, address, Social Security number, and email address. From our HCP shareholders, we also collect the physician type (e.g., MD, DO), specialty, and license and NPI numbers. We may automatically collect your Internet Protocol address when you visit our Sites to improve our products, services and communications (see More About Cookies below).
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
We collect names, Contact Information, and professional affiliations of HCPs to provide and promote our products and services, to process grant applications, and for the other business purposes listed below. We collect patients’ names, Contact Information, physical characteristics or description, and medical information to improve our products, services and communications and for safety, quality and the other business purposes listed below. We also may learn patients’ insurance information in the course of responding to patient communications.
Protected classification characteristics under California or federal law.
We obtain information about patients’ age and gender to improve our product quality and safety and for the other business purposes listed below. We obtain information about HCPs’ age for regulatory compliance purposes and for the other business purposes listed below.
We obtain transactional data pertaining to our products to comply with our legal obligations, to improve our products and services, and for the other business purposes described below.
Internet or other similar network activity.
We collect and use generalized location information to improve our product offerings, to comply with our legal obligations, and for the other business purposes listed below.
Professional or employment-related information.
We may obtain information about the institutional affiliations of HCPs to provide our products and services and for the other business purposes described below.
If you call us, we may collect an audio recording of the phone conversation with you in order to improve our services.
Profiles or inferences drawn from other personal information.
We may collect information reflecting a person’s preferences, characteristics, or behavior in order to improve or promote our products or services or for the other business purposes described below.
We do not collect:
The “personal information” categories disclosed in this Privacy Notice do not include:
Sources of Personal Information
We may obtain the categories of personal information listed above from the following categories of sources:
We use personal information for one or more of the following business purposes:
When you use our Sites or open our emails, we may obtain certain information by automated means, such as through browser cookies, web beacons, device identifiers, server logs, and other technologies. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.
We may use these automated technologies to collect information about your devices, browsing actions, and usage patterns. The information we obtain in this manner may include your device IP address, domain name, identifiers associated with your devices, device and operating system type and characteristics, web browser characteristics, language preferences, clickstream data, your interactions with our Sites (such as the web pages you visit, links you click and features you use), the pages that led or referred you to our Sites, dates and times of access to our Sites, and other information about your use of our Sites.
We may use third party web analytics services on our Sites, such as those of Google Analytics. These services help us analyze how users use our Sites. The information collected for this purpose (including IP address and other information collected by automated means) will be disclosed to or collected directly by these service providers. To learn more about Google Analytics and how to opt out, please visit https://policies.google.com/privacy/partners.
You can manage cookies through your web browser. Most web browsers will tell you how to stop accepting new browser cookies, how to be notified when you receive a new browser cookie and how to disable existing cookies. You can find out how to do this for your particular browser by visiting www.allaboutcookies.org. In addition, your mobile device settings may allow you to restrict your device from sharing certain information obtained by automated means with mobile app developers and operators such as us. Please note, however, that without cookies and similar technologies we use, you may not be able to take full advantage of the features of our Sites. For more information on deleting or controlling cookies, visit www.aboutcookies.org.
Our Sites do not respond to “Do Not Track” signals or similar mechanisms or signals received from browsers as no standard mechanism has yet emerged and become universally accepted.
We strive to keep your personal information accurate. To protect your privacy and security, we also will take reasonable steps to verify your identity before granting you access or enabling you to make updates or corrections.
If you are a California resident, you have the right to request that we delete certain personal information or disclose certain information to you about our collection and use of your personal information over the past twelve (12) months. If you are not a California resident, we will make reasonable efforts to consider your request to access your information, delete your information, or correct your information. We do not discriminate against consumers for exercising any of the privacy rights discussed in this Privacy Notice.
If you are a California resident, once we receive and confirm your verifiable consumer request for access to personal information collected about you, we will disclose to you:
If you are a California resident, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct any service providers with whom we have shared your personal information to delete) your personal information from our records, unless an exception applies.
We may deny your deletion request, if retaining the information is necessary for us or our service provider(s) to:
To make a request to access or delete personal information, please submit a verifiable consumer request to us by emailing PrivacyPolicy@kaleo.com or by calling 855-550-0007.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You also may make a verifiable consumer request on behalf of your minor child.
You may make a verifiable consumer request for access or data portability only twice within a 12-month period. When you make a verifiable consumer request, you must:
We will not be able to respond to your request or provide you with personal information, if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
We maintain reasonable administrative, technical and physical safeguards designed to protect personal information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.
Our Sites may contain links to other websites for your convenience and information. Linked websites may have their own privacy policies or notices, which we strongly suggest you review if you visit any linked websites. To the extent any linked websites are not owned or controlled by us, we are not responsible for their content, any use of the websites, or the privacy practices of the websites.
The Sites are designed for a general audience and are not directed to children under the age of 13. We do not knowingly collect or solicit personal information from children under the age of 13 through our Sites. If we become aware that we have collected personal information from a child under the age of 13, we will promptly delete the information from our records. If you believe that a child under the age of 13 may have provided us with personal information, please contact us as specified in the Contact Us section of this Privacy Notice.
This Privacy Notice may be updated periodically and without prior notice to you to reflect changes in our personal information practices. We will notify you before materially changing the way we use your personal information. If this Privacy Notice is revised, we will update the date at the top of this Privacy Notice and post (or provide a link to) the updated version on our Sites.
If you have any questions or concerns about this Privacy Notice or about our privacy practices, or if you would like us to update information we have about you or your preferences, please contact us by e-mail at PrivacyPolicy@kaleo.com.