Carrot Fertility, Inc. (“Carrot” or “we,” “us,” “our”) is committed to respecting the privacy and recognizing the need for appropriate protection and management of our users’ personal information. We understand how important the privacy of personal information is to our visitors and users. When we do need your personal information to provide services that you request or when you choose to provide us with your personal information, this Privacy Statement describes what information we collect about you and how we use or disclose that information. While Carrot is not a Covered Entity under the Health Insurance Portability and Accountability Act (“HIPAA”), Carrot does follow the guidelines set forth in HIPAA. Please take the time to read our entire Privacy Statement carefully for more information about our privacy practices.
This Privacy Statement applies to our website, https://get-carrot.com (“get-carrot.com”), and any mobile applications made available by Carrot and through the service we provide (collectively, our “Service”). By providing personal information to us through the Service you are bound by the terms of this Privacy Statement, you are consenting to the collection, use, and disclosure of your personal information in accordance with this Privacy Statement. If you do not agree with the practices described in this Privacy Statement, please do not provide personal information through Get-Carrot.com or applications made available by Carrot.
For the purposes of EU data protection laws ("Data Protection Law"), Carrot is a data controller (i.e., the company who is responsible for, and controls the processing of, your personal data).
If you choose to register and create an account with Get-Carrot.com, you will be required to submit personal information to us. This personal information may include, but not necessarily be limited to, the following:
- Name, address, and birthdate;
- Other contact information such as email address and/or test address; and
- Financial and health information, including information that appears on your bills for medical services.
- Any communications between you and Carrot and any other information you provide to Carrot.
- Information about how you use the Service, your actions on the Service, and content you post to the Service, including the groups you belong to, your interaction with your friends and with others on the Service, and photos and videos you post to the Service, and any content you provide through in-app messages, chat, or other functionality (“User Content”). To share photos and video, we will access your device camera roll and camera with your permission. If you need to update your permissions, you can do so in the “Settings” app of your device. Please remember that Carrot may, but has no obligation to, monitor, record, and store User Content in order to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, or to protect and defend our rights and property. By using the Service, you consent to the recording, storage, and disclosure of such communications you send or receive for these purposes.
Legal basis for processing in the EU
In the EU, the purposes for which we process your personal data are:
- the provision of personal data by you may be necessary for the performance of any contractual relationship we have with you;
- where it is necessary for compliance with our legal obligations laid down by EU law;
- where in our legitimate interests (provided these are not overridden by your interests and fundamental rights and freedoms - this includes our own legitimate interests and those of other entities and branches in our group of companies) such as:
- to contact you and respond to your requests and enquiries;
- for business administration, including statistical analysis;
- to provide the Service to you; and
- for fraud prevention and detection; and
- to comply with applicable laws, regulations or codes of practices.
We may also process your personal data on the basis of your freely given, specific, informed and unambiguous consent. You should be aware that you are entitled under Data Protection Law to withdraw your consent where that has been given, at any time.
If you do this and we have no alternative lawful reason to process your personal data, this may affect our ability to provide you with rights to use the Service.
How We Use Your Personal Information
We use your personal information that you provide to fulfill the purpose for which you provided the information and to enhance your experience with us. These uses include:
- Determining reimbursement eligibility;
- Submitting claims to your employer on your behalf;
- Processing or receiving payments;
- Sending you information about health care and health related services, resources and benefits that will help you manage your health and health benefits;
- Sending administrative information to you, for example, information regarding Carrot or its applications made available by Carrot and changes to our terms, conditions, and policies;
- Providing and improving customer services, including through email communications;
- Sending marketing information we think may be of interest to you;
- Sending you surveys;
- Authenticating or confirming your identity when you return to your Carrot account online;
- Conducting our business, such as data analysis, audits, developing new products, enhancing, improving or modifying our services, identifying usage trends, determining the effectiveness of our promotional campaigns and operating and expanding our business activities;
- Taking any action that we believe to be necessary or appropriate: (a) to investigate, prevent and detect illegal activities; (b) under applicable laws, including laws outside your country of residence; (c) to comply with legal process; (d) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (e) to enforce our Terms of Service and this Privacy Statement; (f) to protect our operations or those of our affiliates; (g) to protect our rights, privacy, safety or property and/or that of our affiliates, you or others; and (h) to allow us to pursue available remedies or limit the damages that we may sustain; and
- Other purposes specifically disclosed at the time we request your information
Cookies and Other Tracking Technology to Collect Information
We and our third party partners may automatically collect certain types of usage information when you visit our Service, read our emails, or otherwise engage with us. For instance, when you visit our websites, we may send one or more cookies - a small text file containing a string of alphanumeric characters - to your computer that uniquely identifies your browser and lets us help you log in faster and enhance your navigation through the site. A cookie may also convey information to us about how you use the Service (e.g., the pages you view, the links you click, how frequently you access the Service, and other actions you take on the Service), and allow us to track your usage of the Service over time. We may collect log file information about your browser or mobile device each time you access the Service. Log file information may include anonymous information such as your web request, Internet Protocol (“IP”) address, browser type, information about your mobile device, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may employ clear gifs (also known as web beacons) which are used to anonymously track the online usage patterns of our Users. In addition, we may also use clear gifs in HTML-based emails sent to our users to track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service. When you access our Service from a mobile device, we may collect unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google AdID, or Windows Advertising ID), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate a device’s location by analyzing other information, like an IP address. We may use this information to estimate your location and to provide you with more personalized content and/or services, as set forth in “Third Party Tracking and Online Advertising” below.
We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for the Service and to understand more about the demographics of our users. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Service. You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout. We may also work with third-party partners to employ technologies, including the application of statistical modeling tools, which permit us to recognize and contact you across multiple devices. Although we do our best to honor the privacy preferences of our Users, we are not able to respond to Do Not Track signals from your browser at this time.
We may use the data collected through cookies, log file, device identifiers, location data and clear gifs information to: (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information, including advertising; (c) provide and monitor the effectiveness of our Service; (d) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website and our Service; (e) diagnose or fix technology problems; and (f) otherwise plan for and enhance our service.
If you would prefer not to accept cookies, most browsers will allow you to: (i) change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Please note that doing so may negatively impact your experience using the Service, as some features and services on our Service may not work properly. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.
Information Sharing and Disclosure
We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.
We may share your personal information with:
- Your employer, when you submit a reimbursement for processing. We may share your Employee or Customer ID, name, email and information on your requested reimbursement with your designated employer in order to process the reimbursement;
- Other companies and brands owned or controlled by Carrot and other companies owned by or under common ownership as Carrot, which also includes our subsidiaries (i.e., any organization we own or control) or our ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Statement;
- Third-party vendors and other service providers that perform services on our behalf, as needed to carry out their work for us, which may include identifying and serving targeted advertisements, providing mailing services, providing tax and accounting services, contest fulfillment, web hosting, or providing analytic services. We provide only as much information as is needed to perform the Services on our behalf;
- The public when you provide feedback on our Service. For example, if you post user content on our blog or comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our website or on our social media pages;
- Other parties in connection with a company transaction, such as a merger, sale of company assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party, or in the event of a bankruptcy or related or similar proceedings; and
- Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Service or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Carrot, our visitors, or others.
We may also share information with other third parties, including your designated employer, in an aggregated or otherwise anonymized form that does not reasonably identify you directly as an individual. For example, we share anonymized and/or aggregated data about your use of and interaction with the Service for analytics purposes.
Third Party Tracking and Online Advertising
We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your online browsing history and your interests. We permit third party online advertising networks, social media companies and other third party services, to collect, information about your use of our Sites over time so that they may play or display ads on our Sites, on other websites, apps or services you may use, and on other devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies. We may share a common account identifier (such as an email address or user ID) or hashed data with our third party advertising partners to help identify you across devices. We and our third party partners use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.
To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices. You may also be able to set your browser to delete or notify you of cookies by actively managing the settings on your browser or mobile device. Please note that some advertising opt-outs may not be effective unless your browser is set to accept cookies. Furthermore, if you use a different device, change browsers or delete the opt-out cookies, you may need to perform the opt-out task again. You may also be able to limit certain interest-based mobile advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android).
Control Over Your Information
Data Integrity and Correction: If you are a registered Carrot user, requests to view and correct personal information from Get-Carrot.com may be submitted using the contact information in the “Questions, complaints, and contacts” section below. If you have any questions about reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our Service or publicly displayed content, you can contact us directly at firstname.lastname@example.org. We may not be able to modify or delete your information in all circumstances.
Profile and Data Sharing Settings: You may update your profile information, such as your user name and profile photo, and may change some of your data sharing preferences by emailing us at email@example.com.
How to Control Your Communications Preferences: You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical and security notices).
Access to your Device Information: You may control the app’s access to your device information through your “Settings” app on your device. For instance, you can withdraw permission for the Service to access your photo stream and camera.
Children and Privacy
Carrot does not knowingly collect or solicit any information from anyone under the age of 13. In the event that we learn that we have collected personal information from a child under age 13, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 13, please contact us at firstname.lastname@example.org.
Disclosure of Aggregate Information
We may combine any public and non-personal information you provide with information from other users to create aggregate data to display on the website. This sort of statistical information is called aggregate data because it reflects the characteristics of a large group of anonymous people. Aggregate data does not contain any information that could be used to identify you or contact you. For example, we might inform third parties regarding the number of users of the website and the activities they conduct while on our site. We may use aggregate data or share it with our business partners so that the information and services we provide best meet the needs of our users. Aggregate data also helps advertisers and sponsors know how effectively they are reaching and meeting the needs of their target audience.
Storage and Processing: Your information collected through the Service may be stored and processed in the United States or any other country in which Carrot or its subsidiaries, affiliates or service providers maintain facilities. If you are located in the European Union or other regions with laws governing data collection and use that may differ from United States law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and we will take all steps reasonably necessary to ensure that any personal data are treated securely and in accordance with this Privacy Statement. Such transfers are made pursuant to appropriate safeguards. If you wish to enquire further about these transfers, please contact email@example.com.
Keeping your information safe: Your Carrot account information is password-protected for your privacy and security. Carrot cares about the security of your information, and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through the Service. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. In the event that any information under our control is compromised as a result of a breach of security, Carrot will investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.
For individuals based in the EU or Switzerland, we store personal data for as long as necessary to fulfill the purposes for which we collect the data, except if required otherwise by law.
Third Parties and Links to Other Websites
Get-Carrot.com contains links to websites operated by third parties. If you provide personal information to any third party’s website, your transaction will occur on that website (not Get-Carrot.com) and that website operator will collect the personal information you provide, and this information will be subject to the third-party’s privacy policies. We encourage you to read the legal notice posted on those sites, including their privacy policies.
This Privacy Statement does not apply to your use of and activity on those other websites. We provide links through Get-Carrot.com to other websites only as a convenience, and the inclusion of these links does not imply endorsement of the linked site. We are simply a portal and do not have access to their data. We have no responsibility or liability for your use of third party websites.
Please note that we are not responsible for the collection, usage and disclosure policies and practices (including the data security practices) of other organizations, such as Facebook, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including the collection, usage and disclosure policies regarding any personal information you disclose to other organizations through or in connection with our mobile applications or other websites.
For residents in the EU and Switzerland
If you are located in the EU or Switzerland, you have the following rights in respect of your personal data that we hold:
- Right of access. The right to obtain access to your personal data.
- Right to rectification. The right to obtain rectification of your personal data without undue delay where that personal data is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your personal data without undue delay in certain circumstances, such as where the personal data is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your personal data in certain circumstances, such as where the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of that personal data.
- Right to portability. The right to portability allows you to move, copy or transfer personal data easily from one organization to another.
- Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
If you wish to exercise one of these rights, please contact us using the contact details at the end of this Privacy Statement.
You also have the right to lodge a complaint to your local data protection authority. Further information about how to contact your local data protection authority is available at http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
Changes to our Privacy Statement
We may revise this Privacy Statement from time to time to reflect the changes in our business and practices, and so you should review this page periodically. When we change the policy in a material manner we will let you know and update the ‘last updated’ date at the bottom of this page.
If you have any questions about this Privacy Statement, our policies and practices concerning Get-Carrot.com, your rights under this statement, or your dealings with Get-Carrot.com, you can contact us by sending a message to firstname.lastname@example.org, or by U.S. mail at 164 Townsend Street San Francisco, CA 94107.
This Privacy Statement was last updated September 17, 2018.