Privacy Policy

We process your data on the basis of the following reasons:

• Your explicit consent to process your data (in accordance with clause 2 below), and for the purposes mentioned in clause 4 below;
• For the performance of contracts entered into by you for providing any of the services; and
• Our legitimate interests, i.e. registering and administering accounts on our services to provide you access to all content, updates and services you have purchased, and to facilitate the efficient running and operation of our business.

We are the data controller for all data collected from you when you use the website. We collect certain data from you directly, like your full name, email address, name of the organization, state, contact number. We also collect some data automatically, like information about your device, IP address and what parts of the website you interact with or spend time using.

1. Shared content: Some parts of the Services you to share content publicly, such as posting a testimonial on the website. You understand and accept that such shared content may be publicly viewable by other visitors/ users of the website based on the location of the shared content on the website.
2. Your information, including but not limited to your full name, email address, employer's name, resident state and contact number, may be retained by us to provide you our services on a continuous basis.
3. We may obtain certain information through your social media or other online accounts, if you permit and if these are linked to your registered account on the website. For e.g., if you wish to access our social media links on the website or use other functions, you will be redirected to a third-party site and may be required to log-in using your existing social media account. These third-party sites, platforms and services make information available to us through their APIs, and the information we receive depends on your disclosures and privacy settings on the third party sites or platforms.
4. If you access or use our website through a third-party site, platform or service, or click on any third-party links available on our website, the collection, use, processing and sharing of your data will be subject to the privacy policies and other agreements of such third party sites or platforms. You are requested and required to read these privacy policies prior to your engagement with the third-party sites or platforms. You fully understand and accept that the Company shall, in no manner whatsoever, be responsible for the collection, usage, processing or storage of your data on such third-party sites or platforms.
5. If you contact us for support or inquiry or to report a problem or concern, we collect and store your contact information, messages, and other data about you, like your name, email address, location, operating system, IP address, and any other data you provide or that we collect through automated means. We use this data to respond to you and research your question or concern, in accordance with this Policy.

2.1 Data We Collect through Automated Means

1. When you access the website (including browsing courses), we collect certain data by automated means, including:
   • System data: Technical data about your computer or device, like your IP address, device type, operating system type and version, unique device identifiers, browser, browser language, domain, and other systems data, and platform types;
   • Usage data: Usage statistics about your interactions with the website, including programs and courses accessed, time spent on pages or the website, pages visited, features used, click data, date and time, and other data regarding your use of the website;
   • Approximate geographic data: An approximate geographic location, including information like country, city, and geographic coordinates.
2. The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.

We use tools like cookies, web beacons, analytics services, and advertising providers to gather the data listed above. Some of these tools offer you the ability to opt out of data collection.

3.1 Cookies and Data Collection Tools

1. Our service providers acting on our behalf (like Google Analytics and third-party advertisers) and us, use server log files and automated data collection tools like cookies, tags, scripts, customised links, device or browser fingerprints, and web beacons (“Data Collection Tools”) when you access and use the website. These Data Collection Tools automatically track and collect certain System Data and Usage Data (defined in clause 2.1) when you use the website. In some cases, we tie data gathered through these Data Collection Tools, to other data that we collect, in accordance with this Policy.
2. We use cookies i.e. small files that the website sends to your device to uniquely identify your browser or device or to store data in your browser (“Cookies”), to analyse your use of the website, personalise your experience, make it easier to log into the website, and recognise you when you return to the website. We use web beacons i.e. small objects that allow us to measure the actions of visitors and users using the website, to identify whether a page was visited, identify whether an email was opened, and advertise more efficiently, by excluding current users from certain promotional messages, or identify the source of a new page visit.
3. We use the following types of Cookies:
   • Preferences: Cookies that remember data about your browser and preferred settings that affect the appearance and behaviour of the website (such as your preferred language).
   • Security: Cookies that enable you to log in and access the website; protect against fraudulent login; and help detect and/or prevent abuse or unauthorised use of your account.
   • Functional: Cookies that store functional settings.
   • Session State: Cookies that track your interactions with the website to help us improve the website and your browsing experience, remember your login details. These are strictly necessary for the website to operate properly, so if you disable these Cookies, then certain functionalities will become unavailable or unfunctional.
4. You can align your web browser settings to alert you on our attempts to place Cookies on your computer, limit the types of Cookies you allow, or refuse Cookies altogether. If you do, you may not be able to use some or all features of the website to its full capacity, and your experience may be different or less functional.
5. Some of the third-party partners who provide certain features on our website may also use local storage objects (also known as Flash Cookies or LSOs) to collect and store data.

3.2 Analytics

We use third-party analytics services like Google Analytics, Hotjar, GetSiteControl, Mixpanel, Leadsquared, Wistia, YouTube and Drift on the website. These services use Data Collection Tools to help us analyse your use of the website, including information like the third-party website you arrive from, how often you visit the website, usage and performance data. We use this data to improve the website, better understand how the website performs on different devices and provide information that may be of interest to you.

3.3 Online Advertising

1. We use third-party advertising services like Facebook, Google's ad services, and other ad networks and ad servers to advertise our website and services on other websites and applications that you may use. The advertisements may be based on datapoints that we know about you, like your Usage Data and System Data (defined in clause 2), and datapoints that the advertisement service providers know about you based on their tracking systems. The advertisements may be based on your recent activity or activity over time and across other websites and services, and may be tailored to your interests.
2. Depending on the types of advertising services we use, the advertisement service providers may place Cookies or other tracking technologies on your computer, phone, or other devices, to collect data about your use of our website, and may access those tracking technologies in order to serve these tailored advertisements to you. To help deliver tailored advertising, we may provide the service providers with your email address and content that you share publicly on the website.

4.1 How we use your data:

1. We use your data to provide services on our website, communicate with you, troubleshoot issues, secure you against fraud and abuse, improve and update our website, analyse your usage of our website, serve personalised advertisement, and as required by law or necessary for safety and integrity.
2. We use the data we collect through your use of the website to:
   • Provide and administer the website, including to display customised content and facilitate communication with other users;
   • Process your requests for programs, plans, specific services, information, or features;
   • Communicate with you about your account by:
     • Responding to your questions and concerns;
     • Sending you administrative messages and information, notifications about changes to our website, and updates to our agreements;
     • Sending you information about our website;
   • Facilitate the website's technical functioning, including troubleshooting and resolving issues, securing the website, and preventing fraud and abuse;
   • Solicit feedback from users;
   • Market and administer surveys and promotions administered or sponsored by us;
   • Learn more about you by linking your data with additional data through third-party data providers or analysing the data with the help of analytics service providers;
   • Identify unique users across our website;
   • Tailor advertisements;
   • Improve our website and develop new products, services, and features;
   • Analyse trends, traffic, and track Usage Data;
   • Advertise the website on third-party websites and applications;
   • As required or permitted by law; or
   • As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our website.

4.2 Criterion For Determining Data Retention Period:

It is not possible for us to determine a specific period for which we may retain your data. We may retain your data for longer than necessary, taking into account the following:

1. The purpose(s) and use of your data, both now and in the future (such as whether it is necessary to continue to store that information in furtherance of our obligations under a contract with you, or to contact you in the future);
2. If we have any legal obligation to continue processing your data, such as any record-keeping obligations imposed by any applicable law;
3. If we have your consent;
4. If there exists any agreed industry practice to retain your data;
5. The levels of risk and liability involved for us to continue holding the data;
6. The feasibility to retain your updated and accurate data; and
7. Any other circumstances (such as the nature and status of our relationship with you).

5.1 We may share your data with our analytics and data enrichment providers, your social media providers and advertising companies who help us promote our website. We may also share your data as needed for security, legal compliance, or as part of a corporate restructuring. Lastly, we may share your data if it is aggregated or de-identified or if we get your consent.

5.2 We may share your data with third parties under the following circumstances or as otherwise described in this Policy:

• With service providers, contractors, and agents: We share your data with third-party companies who perform services on our behalf, data analysis, marketing, and advertising services (including retargeted advertising), email and hosting services, and customer services and support. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service.
• With business partners: We have agreements with other websites and platforms to distribute our website and drive traffic to us.
• With analytics and data enrichment services: As part of our use of third-party analytics tools like Google Analytics and data enrichment services like Clearbit or Pipl, we may share certain contact information, Account Data, System Data, Usage Data (as defined in clause 2.1), or de-identified data with them, as needed. De-identified data means data from which personally identifiable information such as names and email addresses have been removed and replaced with a unique token ID or identifier. This process enables our service providers to perform analytics or match the data with publicly available databases including contact and social information from other external sources. The de-identified data allows us to engage with you in a more effective and personalized manner while ensuring that your personal information remains protected.
• To power social media features: The social media features within the website may enable third-party social media providers to collect information, including your IP address and details regarding the specific page of the website you are visiting. Additionally, these providers may set Cookies to facilitate the functionality of the features. Your interactions with these social media features are governed by the privacy policies of the respective third-party companies.
• To administer promotions and surveys: We may share your data as required by applicable law.
• For advertising: If we choose to implement advertising in the future, we may utilize and share certain System Data and Usage Data with third-party advertisers and networks to provide generalized demographic and preference information regarding our users. Additionally, we may permit advertisers to collect System Data through Data Collection Tools (as detailed in clause 3.1), and to use this data to deliver targeted advertisements (behavioral advertising) tailored to your user experience, as well as to conduct web analytics. Advertisers may also share with us the data they collect about you. For more information or to opt out of participating in behavioural advertising networks, please refer to clause 7.1 (Your Choices About the Use of Your Data) below. Please note that opting out will not prevent you from receiving advertisements; however, these ads will be generic in nature.
• For security and legal compliance: We may disclose your data to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
  • Permitted or required by law;
  • Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
  • Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
  • Reasonably necessary to enforce our Terms of Use, this Policy, and other legal agreements;
  • Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues; or
  • Reasonably necessary in our discretion to protect against imminent harm to our rights, property, or safety, or that of our users, employees, members of the public, or our website.
  • We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Policy.
• During a Change in Control: If we undergo a business transaction and/or a restructuring process like merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale assets, we may share, disclose, or transfer all of your data to the successor organisation during such transition or in contemplation of a transition (including during due diligence).
• After Aggregation/De-identification: We may disclose or use aggregate or de-identified data for any purpose.
• With Your Permission: With your consent, we may share your data to third parties outside the scope of this Policy.

6.1 We take appropriate security measures such as using HTTPS to transfer and protect your data against unauthorised access, alteration, disclosure, or destruction that we collect and store. These measures vary based on the type and sensitivity of the data. However, it is important to note that no system can be entirely secure, and as such we cannot guarantee that communications between you and us, the website, or any information provided to us in connection with the data we collect through the website will be completely protected from unauthorised access by third parties.

You have specific rights regarding the use of your data, including the right to opt out of promotional emails, disable Cookies, and prevent collection of your data by certain analytics providers. You may contact us with individual rights requests concerning your personal data. These requests may include restricting our processing of your data, erasing all data we have stored about you, or requesting that your data be provided to you or transferred to another service in a commonly used, machine-readable format.

7.1 Your Choices About the Use of Your Data:

You may choose not to provide your specific data to us, but you may not be able to use certain features of the website

1. To stop receiving promotional communications from us, you may opt out by using the unsubscribe mechanism in the promotional communication you receive or by changing the email preferences in your account. Please note that regardless of your email preference settings, we shall send you transactional and relationship messages regarding the website, including administrative confirmations, important updates about the website, and notices about our policies.
2. The browser you use may allow you to control Cookies and other local data storage. If you have any questions about your data, our use of it, or your rights, contact us at privacy@lenity.health.

7.2 Accessing, Updating and Correcting, Porting and Deleting Your Personal Data:

You may access and update your personal data that we collect and maintain as follows:

1. To request access to, correction, portability, or deletion of your personal data, revocation of consent or to restrict processing of your personal data, please email privacy@lenity.health. Please allow up to 30 days for a response. For your security, we may require that the request be submitted via the email address previously provided to us, and we may need to verify your identity before processing your request. Please note that even after deletion, we may retain certain data where we have a lawful basis to do so.

7.3 Complaints about our privacy policy or use of your data:

While we implement comprehensive measures to protect and secure your data, we acknowledge that you may have concerns or grievances regarding our use of your data, or of our data protection measures. Please feel free to reach out to us at privacy@lenity.health with any such complaints, questions or concerns.

Certain states provide residents with privacy rights. Such rights are not absolute and in certain cases are subject to conditions or limitations as specified in your state's privacy law. We will not unlawfully discriminate against you because you exercised any of your rights under applicable state privacy law.

8.1 Nevada Resident Privacy Rights

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell your personal information to third parties as defined in Nevada law and will not do so in the future without providing you with notice and an opportunity to opt-out of such sale as required by law.

8.2 Virginia Resident Privacy Rights

1. Right to Access
   You have the right to confirm whether we are processing your personal data and to access your personal data.
2. Right to Correct
   You have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes of the processing.
3. Right to Delete
   You have the right to delete personal data provided by or obtained about you.
4. Right to Portability
   You have the right to obtain a portable copy of the personal data that you provided to us.
5. Right to Opt-Out
   You have the right to opt-out of targeted advertising (as defined under Virginia law). We do not sell data as defined under Virginia law.

8.3 California Resident Privacy Rights

These rights are not absolute and in certain cases are subject to conditions or limitations as specified in California privacy law. We will not unlawfully discriminate against you because you exercised any of your rights under California Consumer Privacy Act, 2018.

1. Right to Know
   You have the right to request, up to two times each year, access to categories and specific pieces of personal information about you that we collect, use, disclose, sell, and share.
2. Right to Correct
   You have the right to request that we correct inaccurate personal information that we maintain about you, subject to applicable legal exceptions.
3. Right to Delete
   You have the right to request that we delete personal information that we collect from you, subject to applicable legal exceptions.
4. Right to Portability
   You have the right to obtain a portable copy of the personal data that you provided to us.
5. Right to Opt-Out of Sale or Sharing of Personal Information
   You have the right to ‘opt out’ of the ‘sale’ or ‘sharing’ of your ‘personal information’ to or with ‘third parties’ (as those terms are defined by applicable law). However, Lenity does not sell or share its clients' health information. We also do not exchange your data for financial gain. We do not knowingly sell any personal information of children under age.

California privacy law does not apply to data protected under certain federal and state laws. For example, it does not apply to:

1. Health Insurance Portability and Accountability Act (“HIPAA”) protected health information collected by a covered entity or business associate;
2. Receipt and use of consumer reports (i.e. background checks) by an employer in accordance with the Fair Credit Reporting Act.

California privacy law also has a limited application to financial data subject to the Gramm-Leach-Bliley Act or state motor vehicle records subject to the Driver's Privacy Protection Act of 1994.

The website is hosted in the United States of America and is intended only for the visitors of the United States of America. This website is not intended for users located in other countries, including those within the European Economic Area. Please be aware that your personal information may be transferred to and maintained on servers or databases located outside your state, province or country and that such information is processed and stored in the United States of America. By providing your personal information, you confirm your consent to having such personal data hosted and accessed in the United States of America.

We do not specifically collect information about children nor market our products or Services to children. We have no reason to believe that our website will attract children, or that children will access the website or provide personal information.

Whenever we make a material change to this Policy, we will notify you through email, in-product notice, or another mechanism required by applicable law. Such changes will become effective on the date they are posted. For any questions, concerns or grievances regarding these changes, please contact us via email.

11.1 Modifications to This Privacy Policy:

From time to time, we may update this Policy. In the event of any material changes, we will notify you via email, through a notification posted on the website, or any other method as required by applicable law. We will also provide a summary of the key changes. Unless stated otherwise, modifications will take effect on the date they are posted.

As permitted by applicable law, if you continue to use the website after the effective date of change, then your access and/or use will be deemed as an acceptance of (and agreement to follow and be bound by) the revised Policy. The revised Policy shall supersede all previous privacy policies.

11.2 Interpretation:

Any capitalised terms not defined in this Policy are defined as specified in our Terms of Use.

11.3 Contact Information:

If you have any questions, concerns, or disputes regarding our Policy or to exercise your state-specific privacy rights, please feel free to contact our privacy team at privacy@lenity.health.

12.1 What are cookies?

Cookies may be used to collect, store, and share data about your activities on Lenity's website. Cookies enable us to retain information about your visits to our website, to enhance the ease of use of the website.

We utilize session Cookies and persistent Cookies. Session Cookies expire after a brief period or when you close your browser and are used to identify you during a single browsing session, such as when you log into our website. Persistent Cookies, which remain stored in your browser for a specified duration, are employed to recognize you over an extended period, such as when you request to remain signed in.

12.2 Why do we use cookies and similar technologies?

We use Cookies and similar technologies like web beacons, pixel tags, or local shared objects (“Flash Cookies”), to deliver, measure, and improve our services in various ways. We use these Cookies when you visit our website through a browser. As we adopt additional technologies, we may also gather additional data through other methods.

We use Cookies for the following purposes:

To identify a user's device upon visiting the website, monitor a user's activity throughout the website. Additionally, to enhance the website's user experience and analyse its usage patterns.

12.3 What are my privacy options?

You have a number of options to control or limit how we and our partners use Cookies:

• Most browsers automatically accept Cookies, but you can change your browser settings to decline Cookies by consulting your browser's support articles. If you decide to decline Cookies, please note that you may not be able to sign in, customise, or use some interactive features in the Services.
• Flash Cookies operate differently than browser Cookies, so your browser's Cookie-management tools may not remove them.