Privacy Policy

This is the privacy policy of Diagnose Early Inc. This document explains Diagnose Early’s policies for the collection, use, and disclosure of personal information.

Effective Date: 05/04/2023

This Privacy Policy explains how Diagnose Early, Inc. (“we,” “our,” or “us”) collects, uses, discloses, and otherwise processes personal information regarding individuals that is not Protected Health Information, including, without limitation, information we may collect from your use of certain of our websites (collectively, “Sites”) and/or certain of our applications, products, or services (collectively, “Services”).   “Protected Health Information” or “PHI” includes information that identifies an individual and relates to the individual's past, present or future physical or mental health; the provision of health care to the individual; or the past, present or future payment for health care.

Our HIPAA Notice of Privacy Practices describes in general terms how we use and disclose Protected Health Information about you, including any such Protected Health Information that may be collected via our Sites or Services. Protected Health Information is handled differently than other information we may collect, use, or disclose about you and this Privacy Policy does not apply to such Protected Health Information. 

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of this Privacy Policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you a notification).  We encourage you to review this Privacy Policy periodically to stay informed about our information practices and the choices available to you.

Personal Information We Collect

Information You Choose to Provide to Us

If you visit our Sites, use our Services, or otherwise interact with us (including, without limitation, on social media, on calls, or at events) we may collect personal information that you provide to us, such as if when you submit an inquiry, apply for a job, sign up to receive promotional emails from us, or register for an event. This personal information may include your name, email address, telephone number, business name, a resume and/or cover letter, and any other details you choose to submit.

If you choose to provide us with a third-party’s personal information, such as when you provide us with personal information related to one of your employees or when taking part in our referral program, you will confirm that you have such third-party’s permission to do so prior to submitting such information.

Information We Collect Automatically

In addition to personal information you submit to us, we and our vendors may use analytics tools and other third-party technologies to collect certain information automatically when you visit our Sites, use our Services, or otherwise interact with us, including, without limitation, through the use of cookies and similar tracking technologies. A cookie is a small file, stored on a user's hard drive by a website. Its purpose is to collect data relating to the user, including such user's browsing habits. 

Our Sites and/or Services may use the following types of cookies:

1. Necessary cookies. Necessary cookies are necessary for core features of our Sites or Services to operate and are placed on your device(s) by default, such as for authentication or other security purposes. 

2. Functional cookies. Functional cookies are used to enable optional functions on our Sites and Services, such as remembering the selections you make on our Sites or Services so that your selections are saved for your next visit.

3. Analytical cookies. Analytical cookies allow us to improve the design and functionality of our Sites and/or Services by collecting data on how you access our Sites and/or Services, such as data on the content you access, how long you stay on our Sites or Services, information about the device you use to access our Sites and/or Services, and information about the websites you visit before and after our Sites and/or Services.

We may also collect information when you open email messages from us or click on links within those email messages. Information obtained automatically through our Sites or Services or otherwise, whether from the use of cookies or other similar technologies, may be combined with information about your online activities over time and across different devices and websites.

You may be able to opt out of certain tracking using cookies or similar technologies through the settings on your browser. Please note that your choice(s) may apply only to the browser or device you are using when you opt out, that we do not control how other parties manage their opt-out processes, and that if you disable cookies, some features on our Sites or Services might not function properly. Do Not Track ("DNT") is a type of privacy preference signal that may allow you to opt out of online tracking. Currently, our Sites and Services do not respond to DNT signals.

Information We Collect from Other Sources

In addition, we may collect personal information about you from other sources, such as from your employer or from other individuals who have referred you to us. This personal information may include your name, business name, title or position, and business contact information.

How We Use Personal Information

We use your personal information to operate our Sites and Services and make them available for your use. We may also use your personal information to:

  • Send you technical notices, updates, security alerts, support, and administrative messages, and to respond to your comments, questions and customer service requests;
  • Send communications to you about products, services, offers, and events offered by us and others, and provide newsletters, marketing or promotional materials, and information we think will be of interest to you;  
  • Monitor and analyze trends, usage and activities in connection with our Sites and Services;
  • Personalize and improve the Sites and/or Services and develop new products and services;
  • Advertise and market our Services, including delivering interest-based advertisements on the Sites and other sites or content syndication platforms and websites;
  • Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards; 
  • Carry out market research to understand how to improve our Site and Services and their delivery;
  • Protect the rights and property of Diagnose Early and others;
  • Detect, investigate, and prevent unauthorized, improper, fraudulent or other prohibited or illegal activities;
  • Protect the security or integrity of the Sites, Services, or our business; and/or
  • For other purposes, as disclosed to you at the point of collection or as required or permitted by law.

How We Share Personal Information

When we share your personal information, we will either do so based on a choice you’ve made or to operate our business or provide certain products and services to you or your employer, as described forth below. 

Our Services

If you are an end user of our Services, you may elect to share certain personal information with other users. If you access our Services via your employer, your employer may also receive certain information about you and your usage of the Services. 

Service Providers

We use third parties to help us operate our Sites and provide our Services. Such service providers may have access to your personal information as collected by the Sites or Services, as reasonably necessary to perform the contracted tasks on our behalf. We sign contractual agreements to obligate them to protect the personal information, only use it to deliver the contracted services to us, prohibit them from selling it and not disclose it without our knowledge and permission. Our Service Providers include the following:

Service Provider Name Business Purpose Information Collected by the Service Provider Data Location
HubSpot Collect marketing and sales contact details Name, Email address, mailing address, phone number USA
Google Fonts Display the website correctly IP Address USA
Google Analytics Monitor use and behavior of the website IP address, tracking cookie USA

Legal Disclosures; Safety

We may disclose personal information when required by law, regulation, subpoena, public authority request or other legal processes as identified in the applicable legislation or otherwise If we believe your actions are inconsistent with our agreements or policies to enforce or fulfill such agreements or policies. We may also share personal information to protect the rights, property and safety of Diagnose Early or others.

Change in Control

We can also share your personal data as part of an investment, sale, merger, change in control or in preparation for any of these events.

Any other entity which buys us or part of our business will have the right to continue to use your data, but only in the manner set out in this Privacy Policy unless you agree otherwise.

Other Circumstances

In addition to the above, we may otherwise disclose your personal information with your consent or at your direction.

Diagnose Early may also share aggregated or de-identified information, which cannot reasonably be used to identify you, with others at its reasonable discretion.

How We Protect Personal Information

We use a variety of best-practice physical, administrative and technical safeguards designed to protect your information from unauthorized access, use and disclosure. 

Your Rights

Subject to certain limitations and exceptions allowed by law, Diagnose Early honors the exercise of the following rights regardless of location: 

Access your personal information

  • If you have provided personal information to us, you may contact us to obtain a summary of the information we have about you or a copy of such  information. 

Change or correct your personal information.

  • You may update or correct your personal information or ask us to do it on your behalf.

Delete your personal information.

  • You may request the deletion of your personal information. 

Object to the processing of your personal information.

  • You may object to our processing of your personal information, such as if you object to the use of such information for direct marketing purposes. 

Restrict the processing of your personal information.

  • You may ask us to limit the way that we use your personal information, such as by limiting to storing but not further processing.

Export your personal data.

  • For personal information you provided to us, you may request that we export such personal information to you in a machine-readable format .

Revoke your consent.

  • When our processing is based on your consent, you may revoke that consent.

We do not process personal information through the use of automated means.

If you would like to exercise any of the rights described above, please contact us at  privacy@DiagnoseEarly.com. Diagnose Early may take steps to limit fraudulent activity by requiring information be provided that matches information we currently maintain about you prior to processing a request. Failure to provide us with the information requested may result in our denial of the request. We respond to all legitimate requests within legally mandated timeframes.

You also have the right to not be discriminated against for exercising any of your rights. Depending on where you reside, you may have the right to lodge a complaint with the local organizations in charge of enforcing the privacy legislation applicable in your territory, or have other, additional rights available to you.

How Long We Keep Your Personal Information

We retain information as long as it is necessary to or as long as is necessary for the purpose for which such information was collected or for other legitimate business purposes, including to meet our legal, regulatory, or other compliance obligations and to operate the Sites and/or provide the Services to you and our clients.

We may also retain information to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce our agreements and take other actions permitted by law.

The information we retain will be handled following this Privacy Policy.

Information connected to you that is no longer necessary and relevant to provide our services may be de-identified or aggregated with other non-personal data.

Other Important Information

We are headquartered and receive and process information about you in the United States, which may not provide equivalent levels of data protection as your home jurisdiction.  This processing is necessary to provide the Sites and Services to you.  We will take steps to implement appropriate safeguards to help provide an adequate level of protection for this data.

You may choose to opt-out of receiving marketing communications from us. Please click the “Unsubscribe” link in the email we sent you to stop receiving such marketing communications.

Even if you opt-out of receiving marketing communications, we may still communicate with you regarding security and privacy issues, servicing your account, fulfilling your requests, or administering any promotion or any program in which you may have elected to participate.

Contact Information

You may contact us to exercise any of your rights or ask for more information about your personal information and our privacy practices by contacting us at: 

privacy@DiagnoseEarly.com, or

Privacy Officer, Diagnose Early, 1455 Adams Drive, Menlo Park California, 94025

For Individuals Based in California

This section provides additional specific information for consumers based in California as required by the California Consumer Privacy Act of 2018 (“CCPA”) and the California Privacy Rights Act of 2020 (“CPRA”) - which significantly amends and expands the CCPA.

Categories  of Personal Information

In the last 12 months, we have collected the following categories of personal information:

  • Identifiers, such as your name, mailing address, email address, zip code, telephone number, business contact information, or other similar identifiers
  • Internet or network information, such as your browsing history, log and analytics data, information about the device(s) used to access the Sites or Services and information regarding your interaction with our Sites or Services and other usage data
  • Geolocation data, such as information about your location (at country and city level) collected from your IP address
  • Audio, video, or similar information, such as recordings of support calls or other conference calls between you and us that we record where permitted by you and/or the law
  • Profession/employment information that you send to us when applying for a position included in your CV and cover letter
  • Other personal information that does not fall into any category of data described under the CCPA, such as  other personal information you provide to us in relation to a survey, comment, question, request, article download or inquiry and any other information you upload to our Sites or Services

Categories of Sources from Which We Collect Personal Information

We collect personal information directly from you, from your browser or device when you visit our Sites, from third parties that you permit to share your information or from third parties that share public information about you, as stated above.

Purposes for Collection

See the section above, “How We Use Personal Information,” to understand how we use the personal information collected from California consumers.

  Categories of Third Parties with Whom We Share Personal Information

Please see the “How We Share Information” section of the Privacy Policy above for more information on categories of third parties with whom we have shared personal information in the preceding 12 months.

Sale of Your Personal Information

We do not sell the personal information we collect (and will not sell it in the future without changing this Privacy Policy and providing the ability to opt out of such sale). 

Sharing of Your Personal Information

Please note that we may use cookies and related technologies set by other companies to send targeted ads, as further described in the “Information We Collect” section above.  However, based in part on how we’ve configured their technologies, these companies have committed to only use the data they receive via our products and services for the limited business purpose of providing services to us.

California Privacy Rights

As a California resident, you may be able to exercise the following rights under the CCPA in relation to the personal information about you that we have collected (subject to certain limitations at law):

- The right to access/know any or all of the following information relating to your personal information that we have collected and disclosed in the last 12 months (upon verification of your identity): 

  • The specific pieces of personal information we have collected about you
  • The categories of personal information we have collected about you
  • The categories of sources of the personal information
  • The categories of personal information that we have disclosed to third parties for a business purpose, and the categories of recipients to whom this information was disclosed
  • The categories of personal information we have sold and the categories of third parties to whom the information was sold, and
  • The business or commercial purposes for collecting, selling or sharing the personal information.

- The right to request deletion of personal information we have collected from you, subject to certain exceptions.

- The right to opt-out of personal information sales to third parties now or in the future. However, at this time, we do not sell your personal information and will not sell it in the future without changing this Privacy Policy and providing the ability to opt out of such sale.

- The right to opt-in to personal information sales to third parties for consumers under the age of 16. However, we do not sell personal information of minor consumers,  nor do we knowingly collection personal information from minors.

You also have the right to be free of discrimination for exercising these rights.

In addition to the rights mentioned above, the CPRA grants California residents the following additional rights:

- The right to opt-out of sharing of personal information to third parties now or in the future (as defined within the CPRA).

- The right to request rectification/correction of inaccurate personal information, considering the nature and purposes of the processing of the information.

- The right to limit use and disclosure of sensitive personal information to that which is necessary to perform the services or provide the goods reasonably expected by an average consumer.

Please note that if exercising these rights limits our ability to process personal information (such as a deletion request), we may no longer be able to provide you with our Sites or Services or engage with you in the same manner.

How to Exercise Your California Consumer Rights

To exercise any of your rights mentioned above, please submit a request by contacting us at privacy@DiagoseEarly.com.

We will need to verify your identity before processing your request.

In order to verify your identity, we will generally require sufficient information from you so that we can match it to the information we maintain about you in our systems. Sometimes we may need additional personal information from you to be able to identify you. We will notify you of any required information after we have received any request to exercise your rights.

We may decline a request to exercise the right to know and/or right to deletion under the CCPA as well as your right to rectification under the CPRA, particularly where we cannot verify your identity or locate your information in our systems or as permitted by law.

You may choose to designate an authorized agent to make a request under the CCPA or CPRA on your behalf. No information will be disclosed until the authorized agent’s authority has been reviewed and verified. Once an authorized agent has submitted a request, we may require additional information (i.e., written authorization from you) to confirm the authorized agent’s authority.

If you are an employee/former employee of a Diagnose Early client that uses our Services, please direct your requests and/or questions directly to your employer or former employer.

If you are a third party (auditor, service provider, etc.), who was given access to the Diagnose Early Services by a Diagnose Early client, please direct your requests and/or questions directly to the Diagnose Early client that gave you access.

Minors 

Our Sites and Services are intended for business use, and we do not expect them to be of any interest to minors. We do not intentionally collect or process any personal information of consumers below the age of 16. 

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