Azadi, Inc. (“Azadi,” “we,” “us,” or “our”) has prepared this Privacy Policy to explain what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. Through our mobile application (the “App”), we provide a behavioral health solution that includes access to community support, coaches, and therapists to help people deal with depression and anxiety (such services, including https://www.gotoAzadi.com/ (the “Site”) and the App, are referred to collectively in this Privacy Policy as the “Service”).
This Privacy Policy explains what Personal Data (defined below) we collect, how we use and share that data, and your choices concerning our data practices. This Privacy Policy is incorporated into and forms part of our Terms of Service.
Before using the Service or submitting any Personal Data to Azadi, please review this Privacy Policy carefully and contact us if you have any questions. By using the Service, you agree to the practices described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not access the Site or otherwise use the Service.
1.PERSONAL DATA WE COLLECT
We collect information that alone or in combination with other information in our possession could be used to identify you (“Personal Data”) as follows:
Personal Data You Provide: When you create an account, we collect your name, email, password, zipcode, the passcode you received from your employer or health plan to access the Service, demographic information like you gender identity, ethnicity, level of education, annual income, and date of birth, medical information such as recent symptoms of nervousness and anxiety and a your experience with abuse and trauma during childhood, and a profile picture (if you choose to provide one). When you use the Service, we will collect any medical records you provide, information you provide through assessments of your symptoms, and any information that may be contained in your posts on the Service or in your communications with us. If you engage in video conferences with our coaches and/or therapists, please be aware that we will record the videos taken during those sessions.
Social Media Data: We have pages on social media sites like Instagram, Facebook, Twitter, Pinterest and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
Internet Activity Data: When you visit, use, and interact with the Service, we may receive certain information about your visit, use, or interactions. For example, we may monitor the number of people that visit the Service, peak hours of visits, which page(s) are visited, the domains our visitors come from (e.g., google.com, yahoo.com, etc.), and which browsers people use to access the Service (e.g., Chrome, Firefox, Microsoft Internet Explorer, etc.), broad geographical information, and navigation pattern. In particular, the following information is created and automatically logged in our systems:
Log Data: Information that your browser automatically sends whenever you visit the Site. Log Data includes your Internet Protocol address, browser type and settings, the date and time of your request, and how you interacted with the Site.
Cookies Data: Please see the “Cookies” section below to learn more about how we use cookies.
Device Data: Includes name of the device, operating system, and browser you are using. Information collected may depend on the type of device you use and its settings.
Usage Data: We collect information about how you use our Service, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities.
Location Data: We derive a rough estimate of your location from your IP address. [We collect your location information through the App using your device IP address, WiFi, Bluetooth, and GPS coordinates (e.g. latitude/longitude) of your mobile device. If you have given the App permission to access your location, we will collect your device’s location only while you are using the Service and store your location history. If you want to opt-out of the collection of your location data, please adjust your settings in your mobile device to limit the App’s access to your location data.
Email Open/Click Data: We use pixels in our email campaigns that allow us to collect your email and IP address as well as the date and time you open an email or click on any links in the email.
Cookies: We use cookies to operate and administer our Site, gather usage data on our Site, and improve your experience on it. A “cookie” is a piece of information sent to your browser by a website you visit. Cookies can be stored on your computer for different periods of time. Some cookies expire after a certain amount of time, or upon logging out (session cookies), others survive after your browser is closed until a defined expiration date set in the cookie (as determined by the third party placing it), and help recognize your computer when you open your browser and browse the Internet again (persistent cookies). For more details on cookies please visit All About Cookies.
On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:
Internet Explorer
Mozilla Firefox
Google Chrome
Apple Safari
Please note that if you limit the ability of websites to set cookies, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site.
Advertising networks may use cookies to collect Personal Data. Most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit the Network Advertising Initiative’s online resources at http://www.networkadvertising.org and follow the opt-out instructions there.
If you access the Site on your mobile device, you may not be able to control tracking technologies through the settings.
[Analytics: We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the Site and enhance your experience when you use the Site. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners/.]
Online Tracking and Do Not Track Signals: We and our third party service providers, including Facebook,] may use cookies, pixels, or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of the Site and use that information to send targeted advertisements]. Our Site currently does not respond to “Do Not Track” (“DNT”) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do respond to DNT signals in the future, we will update this Privacy Policy to describe how we do so.
2.HOW WE USE PERSONAL DATA
We may use Personal Data for the following purposes:
To provide the Service and help users deal with anxiety and depression;
To respond to your inquiries, comments, feedback, or questions;
To send administrative information to you, for example, information regarding the Service and changes to our terms, conditions, and policies;
To analyze how you interact with our Service;
To maintain and improve the Service;
To develop new products and services;
To prevent fraud, criminal activity, or misuses of our Service, and to ensure the security of our IT systems, architecture, and networks; and
To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.
Aggregated Information. We may aggregate Personal Data and use the aggregated information to analyze the effectiveness of our Service, to improve and add features to our Service, and for other similar purposes. In addition, from time to time, we may analyze the general behavior and characteristics of users of our Service and share aggregated information like general user statistics with prospective business partners. We may collect aggregated information through the Service, through cookies, and through other means described in this Privacy Policy.
Marketing. We may use your Personal Data to contact you to tell you about products or services we believe may be of interest to you. For instance, if you elect to provide your email, we may use that information to send you special offers. You may opt out of receiving emails by following the instructions contained in each promotional email we send you. You can also control the marketing emails you receive by updating your settings through your account. In addition, if at any time you do not wish to receive future marketing communications, you may contact us. If you unsubscribe from our marketing lists, you will no longer receive marketing communications but we will continue to contact you regarding management of your account, other administrative matters, and to respond to your requests.
Processing of Protected Health Information. Some of the Personal Data received by Azadi in connection with the Service may be provided by healthcare providers that are subject to laws and regulations, such as rules issued under the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and Health Information Technology for Economic and Clinical Health Act of 2009 (HITECH), that govern providers’ use and disclosure of certain individually identifiable health-related Personal Data (“Protected Health Information”). When we receive Protected Health Information, we may do so as a “Business Associate” of the healthcare provider under an agreement that, among other things, prohibits us from using or disclosing the Protected Health Information in ways that are not permissible by the healthcare provider itself, and requires us to implement certain measures to safeguard the confidentiality, integrity, and availability of the Protected Health Information. When we act as a Business Associate, we may be subject to certain laws and regulations, including certain HIPAA rules that govern our use and disclosure of Protected Health Information and that may be more restrictive than otherwise provided in this Privacy Policy. For more information about our HIPAA-compliant activities, please contact us.
3. SHARING AND DISCLOSURE OF PERSONAL DATA
In certain circumstances we may share the Personal Data described above without further notice to you, unless required by the law, with the following categories of third parties:
Vendors and Service Providers: To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with vendors and service providers, including providers of hosting services, cloud services, and other information technology services providers, email communication software and email newsletter services, advertising and marketing services, payment processors, customer relationship management and customer support services, and analytics services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data.
Business Transfers: If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of all or a portion of our assets, or transition of service to another provider (collectively a “Transaction”), your Personal Data and other information may be shared in the diligence process with counterparties and others assisting with the Transaction and transferred to a successor or affiliate as part of that Transaction along with other assets.
Legal Requirements: If required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, including to meet national security or law enforcement requirements, (ii) protect and defend our rights or property, (iii) prevent fraud, (iv) act in urgent circumstances to protect the personal safety of users of the Service, or the public, or (v) protect against legal liability.
Other Users: certain actions you take may be visible to other users of the Service. For example, your posts will appear in other users’ feeds and your profile information will be accessible to other users. You acknowledge that by sharing posts or adding information to your profile you make the information shared available to other users and that Azadi cannot control, and shall not be responsible for any use other users make of such information.
Healthcare Providers: In order to provide the Service, we will share your Personal Data with any healthcare providers involved in providing you the Service.
Employers and Health Plans: We will share some of your Personal Data, such as whether you have created an account and accessed and/or used the Service, including the fact that you have participated in coaching/therapy sessions, with the employer or health plan responsible for paying for your access to the Service.
With Your Consent: If we need to use or disclose any Personal Data including Protected Health Information, in a way not identified in this Privacy Policy, we will notify you and/or obtain consent as required under applicable privacy laws.
We keep Personal Data for as long as reasonably necessary for the purposes described in this Privacy Policy, while we have a business need to do so, or as required by law (e.g. for tax, legal, accounting, or other purposes), whichever is longer.
5. UPDATE YOUR INFORMATION
Please log in to your account or contact us if you need to change or correct your Personal Data.
Our Service is not directed to children who are under the age of 16. Azadi does not knowingly collect Personal Data from children under the age of 16. If you have reason to believe that a child under the age of 16 has provided Personal Data to Azadi through the Service please contact us and we will endeavor to delete that information from our databases.
7. LINKS TO OTHER WEBSITES
The Service may contain links to other websites not operated or controlled by Azadi, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies.
You use the Service at your own risk. We implement commercially reasonable technical, administrative, and organizational measures to protect Personal Data both online and offline from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or e-mail transmission is ever fully secure or error free. In particular, e-mail sent to or from us may not be secure. Therefore, you should take special care in deciding what information you send to us via the Service or e-mail. Please keep this in mind when disclosing any Personal Data to Azadi via the Internet. In addition, we are not responsible for circumvention of any privacy settings or security measures contained on the Service, or third party websites.
In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Service, you may be unable to use those features. You can also contact us to ask us to update or correct your Personal Data.
10. CHANGES TO THE PRIVACY POLICY
The Service and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do we will post an updated version on this page, unless another type of notice is required by the applicable law. By continuing to use our Service or providing us with Personal Data after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and practices described in it.
If you have any questions about our Privacy Policy or information practices, please feel free to contact us at our designated request address:
Azadi Health, Inc.
746 S. Los Angeles
Los Angeles, California 90014
