Effective and last updated on July 22, 2020.
Curable Inc. (“Curable”, “us”, “we”, or “our”) knows that you care about how your personal information is collected, used, processed, and shared, and we take your privacy seriously. We are committed to protecting and respecting your privacy through our compliance with this policy.
When we refer to “you” or “your” or similar terms, we are referring to you as a user of our Services (as defined below).
This policy describes the types of information we may collect or that you may provide when you visit, purchase, download, install, register with, access, or use the websites, including www.curablehealth.com (the “Websites”), and the mobile device applications (“Apps”) owned and operated by us, and our practices for collecting, using, maintaining, protecting, processing, and disclosing that information. We may refer to the Websites and the Apps collectively as the “Sites”. We refer to the information and services made available through the Websites and the Apps, including information communicated through messages, text, and email, collectively as the “Services”.
This policy DOES NOT apply to information that you provide to or is collected by any third party (see Ads, Analytics, and Third-Party Information Collection).
For more information about your rights and choices with respect to your information, please see Your Rights to Access, Modify, and Erase Personal Information and Your Choices About Our Collection, Use, and Disclosure of Your Information.
1. INFORMATION WE COLLECT AND HOW WE COLLECT IT
We collect the following information from and about users of our Sites and other Services:
Information You Provide to Us
When you visit, download, register with, subscribe to, purchase, access, or use the Websites, Apps, or other Services, we may ask you to provide (or if not required, you may choose to provide) information:
By which you may be personally identified, such as your name, date of birth, home or business postal address, city or town, email address, telephone number, videos, photos, stories, GIFs, personal information of individuals for whom you purchase gift subscriptions or refer to our Sites or other Services, usernames, passwords, medical conditions, other health information (including illnesses, symptoms, treatments, and feelings about your medical conditions and/or yourself), any other identifier by which you may be contacted online or offline, and other data that you provide when using our Sites or the other Services (collectively, “personal information”).
This information includes:
• Information provided by you at the time of registering to use the Sites or subscribing to or purchasing our Services, and requesting further services.
• Information that you provide by filling in forms on, answering questions, using chats, and participating in online or virtual question and answer sessions through the Websites or in the Apps.
• Information when you report a problem with the Services.
• Records and copies of your correspondence (including email addresses and phone numbers), if you contact us.
• Your responses to surveys that we might ask you to complete, which you choose to complete.
• Details of purchases you make through the Sites and of the fulfillment of your purchases of products and services. You may be required to provide financial information before purchasing goods or services through the Sites.
Information Shared Through Curable Online Communities
Curable’s Websites and Apps feature programs that offer online and virtual group discussions, question and answer sessions and coaching sessions facilitated by both licensed professionals and professionals who are not licensed (collectively, “Virtual Group and Coaching Programs”). Users participate in Virtual Group and Coaching Programs through virtual communication methods that may permit your voice or likeness to be shared with Curable facilitators and other Site users, including video and audio conference calls and virtual meetings. Virtual Group and Coaching Programs are intended to provide users with an opportunity to discuss topics related to chronic pain management and related topics such as support and suggested resources for further exploration. Accordingly, users of Virtual Group and Coaching Programs will likely share or discuss their personal experiences during such programs. You choose and control whether to participate in Virtual Group and Coaching Programs and what, if any, information (including personal information) you share in any Virtual Group and Coaching Programs (collectively, “User Program Contributions”). Certain Virtual Group and Coaching Program sessions may be recorded by Curable and made available elsewhere on the Site. Curable will give advance notice of which sessions will be recorded, and you may choose to participate or not. By participating in any Virtual Group and Coaching Program, you consent to such recording and transmission, distribution, performance, and display by Curable on its Sites.
Automatically Collected Information and Online Tracking
When you visit, download, access, and use the Sites, we may use technology to automatically collect:
• Usage Details. Certain details of your access to and use of the Sites, including traffic data, logs, the page or feature you requested, when you last used the Services, when you last updated your information, time and duration of your activities on the Sites, and other communication data and the resources that you access and use on or through the Sites.
• Device Information. Information about your mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
• Stored Information and Files. Metadata and other information associated with other files stored on your device. This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Online Tracking. We do not collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking). We do not currently respond to browser “Do Not Track” signals sent from web browsers on our Websites or Apps.
The technologies we use for automatically collected information may include:
• Cookies. A cookie is a small data file placed on your device when you visit or access our Websites or Apps. Cookies enable us to recognize your browser or device and collect and store information about your use of the Services. It may be possible to refuse to accept cookies by activating the appropriate setting on your browser or device. However, if you select this setting, certain functionality or features of the Sites may be diminished or inoperable.
• Web Beacons. Pages of the Sites and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us to monitor activity and collect information such as counting users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain Site content and verifying system and server integrity).
Ads, Analytics, and Third-Party Information Collection
We partner with third-party analytics providers to help us collect statistical information about your use of the Sites and Services and traffic on the Sites. Five of the analytics providers we currently use are Google, Facebook, Mixpanel, and Lucky Orange. When you use the Sites or its content, these third parties may use automatic tracking technologies to collect information about you. We share your email addresses with these third-party providers in order for them to deliver the services we require of them. In addition, the information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
What Is A Cookie?
“Cookies” are small data files that are stored on the hard drive of the device you use to view a website. Each device that accesses a Site is assigned a different cookie by Curable.
Session cookies are specific to a particular visit and carry information as you view different pages within a Site. Session cookies expire and delete themselves automatically in a short period of time, e.g., when you leave the website or when you close your browser.
Persistent cookies enable us to recognize you when you visit a Site and remember your preferences. Persistent cookies are stored on your browser or mobile device until you choose to delete them, and otherwise typically delete themselves at expiration.
Third-party cookies are placed by someone other than Curable, and may gather browsing activity across multiple websites and sessions. They are usually persistent cookies and are stored until you delete them or they expire based on the time period set in each third-party cookie.
“Web Beacons” (also referred to as clear gifs, pixel tags, and single-pixel gifs) are small electronic files embedded in a page of a website that permit us to monitor activity and collect information such as counting users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain Site content and verifying system and server integrity). Web beacons send back to its home server (which can belong to the host site, a network advertiser, or some other third party) information from your browser, such as the IP address, the URL of the page on which the Web Beacon is located, the type of browser that is accessing the site, and the ID number of any cookies on your computer previously placed by that server.
“Application SDKs” are mobile application third-party software development kits that are embedded in mobile applications. These app SDKs permit the collection of information about the app itself, activity in the app, and the device the application is running on.
Curable Cookie Uses
The cookies used on the Sites are used for one of the following purposes:
• Essential functionality. These cookies are essential to access some areas of the Sites and provide services that our users need on our Sites. For example, these cookies may enable us to identify registered users and ensure that they have access to content that is available only to registered users.
• Important functionality. These cookies enable us to remember your preferences and choices you make on the Sites, such as your user name, language, or the region you are in, and provide more personalized features. We may also use these cookies to provide services you have asked for, such as watching a video. These cookies are persistent cookies that will not have to be set again the next time you visit the website. The information these cookies collect cannot track your browsing activity on non-Curable websites.
• Performance and Analytics. These cookies enable us to analyze how visitors use the Sites and to monitor website performance. We use the information collected by these cookies to improve the performance of the Sites and our Services. All information these cookies collect are aggregated and do not collect information that identifies you.
Your Options for Managing Cookies
In addition, certain third party analytics or advertising networks, including Google, allow users to opt out of or customize preferences associated with your internet browsing.
3. HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any personal information, to:
• Provide you with the Websites and Apps and their contents, features, and programs, the other Services, and any other information, products, or services that you request from us.
• Improve, research, develop, or create new Websites, Apps, or other Services.
• Administer your account and subscriptions, including to give you notices about your account and subscriptions, including expiration and renewal notices.
• Recognize you when you use the Sites, customize content for you that we think you might like based on your usage patterns, and deliver a more personalized experience when you use the Sites and other Services.
• Process transactions.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when Site or other Service updates are available, and of changes to any products or services we offer or provide though any of them.
• Contact you via phone, text, email, or other electronic means with newsletters, details of blog posts, and other communications, services, or features that are available on our Sites or through our other Services, that we think may be of interest to you or that we in our sole discretion determine is related to your usage (including User Submissions) of our Services.
• Obtain your feedback about the Sites and other Services.
• Respond to User Submissions.
• Provide customer support.
• Identify issues with the Sites and other Services.
• Help make our communications more relevant, useful, interesting, or helpful to our users.
• Help maintain the safety, security, and integrity of our Sites, other Services, databases, other technology assets, and business.
• Obtain statistical behavior regarding usage patterns, trends, user behavior, preferences, and activity with respect to the Sites and other Services and for other testing and analysis related to the Sites and other Services.
• Fulfill and enforce our terms and conditions.
• Comply with our obligations to third parties.
• Comply with judicial and administrative orders and other applicable law.
• Fulfill any other purpose for which you provide personal information or for which you provide your consent.
We may also use your information to contact you about our third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, you may unsubscribe from receiving those communications (please see Your Choices About Our Collection, Use, and Disclosure of Your Information).
4. DISCLOSURE OF YOUR INFORMATION
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
User Submissions that you share through any other Public Forum, including through our Facebook page, groups, and communities, are Public Submissions and are available to the general public and are not private.
In addition, we may disclose personal information that we collect or you provide:
• To our subsidiaries and affiliates for our and their legitimate business purposes or to provide you with a product or service that you have requested, or to offer you services or products that we believe may be of interest to you.
• To agents, contractors, service providers, and other third parties we use to provide our Services or support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Curable’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Curable about users of our Sites and other Services is among the assets transferred.
• To fulfill the purpose for which you provide it. For example, if you give us an email address to use the gift subscription feature of our Site, we will use that email address to transmit the contents of that email and your name and email address to the gift recipient.
• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce our rights arising from any contracts entered into between you and us, including Site terms and conditions and for billing and collection.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Curable, our affiliates, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection, detection, or suppression and credit risk reduction.
• For any other purpose disclosed by us when you provide the information.
• Except as provided in this policy with respect to third party information collection (see Ads, Analytics, and Third-Party Information Collection), we do not share your personal information with unaffiliated third parties without your prior consent, which you may withdraw at any time by sending an email to us at firstname.lastname@example.org (for more information, see Your Choices About Our Collection, Use, and Disclosure of Your Information).
5. DATA SECURITY
We employ industry standard administrative, physical, and technical measures designed to safeguard and protect your personal information under our control from accidental loss and from unauthorized access, use, alteration, and disclosure.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and we suggest that you limit access to your computer and browser by signing off after you have finished accessing your Curable account. We urge you to be careful about giving out information in public areas of the Sites like message boards. The information you share in public areas may be viewed by any user of the Sites.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure, and we cannot and do not guarantee the security or confidentiality of your personal information transmitted through any of our Sites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
We will make all legally required disclosures of any breach of your unencrypted, electronically stored “personal information” or “medical information” (as defined in applicable state statutes or other applicable laws on security breach notification). To the extent permitted by applicable laws, we will disclose any such breach to you via email or a conspicuous posting on your private profile on the Sites in the most expedient time practicable and without unreasonable delay, subject to and as consistent with (a) the legitimate needs of law enforcement, or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of our data system.
If you have any questions about data security, you can contact us at email@example.com.
6. YOUR RIGHTS TO ACCESS, MODIFY, AND ERASE PERSONAL INFORMATION
You may request to receive your personal information by emailing us at firstname.lastname@example.org. Curable will use commercially reasonable efforts to provide you access to your personal information within thirty (30) days of such request, but may not provide access under certain circumstances, including but not limited to instances where the information cannot legally be disclosed, where such access would compromise others’ privacy or other legal rights, where it would be unduly burdensome or expensive to provide such access as balanced against the risks to your privacy, or where the information is subject to confidentiality or proprietary restrictions.
Editing or deletion of personal information is handled in the following ways:
• Personal information contained in or transmitted through User Program Contributions (such as information shared during your participation in video conferences or calls that have already occurred via Virtual Group and Coaching Programs) cannot be edited or deleted. User Submissions made in or through Virtual Group and Coaching Programs are available to the Curable facilitators and the other participants and are considered public, and question and answer sessions may be recorded and made available elsewhere on the Site.
• Personal information contained in non-public User Submissions made directly to Curable through email, phone, or text cannot be edited or deleted, but are not shared with third parties except in accordance with this policy.
• Personal information you share with Curable in response to its chatbots (e.g., information you submitted through the App regarding your experiences, health, and goals, etc.) may not be edited. Such personal information may be deleted by deleting your Curable account by emailing us at email@example.com (see Your Choices About Our Collection, Use, and Disclosure of Your Information).
7. YOUR CHOICES ABOUT OUR COLLECTION, USE, AND DISCLOSURE OF YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
• Promotion by Curable. All promotional emails that we send with opportunities from us, our affiliates, our sponsors, or third parties will contain an opportunity to unsubscribe from getting additional emails of that type in the future from us. If you do not want us to use your email address or other contact information to promote our own or third parties’ products or services in the future, click the “Unsubscribe” link contained in the emails and follow the directions to indicate this preference, or make a request by emailing us at firstname.lastname@example.org. Please note that if you do not want to receive legal notices from us, such as this policy, those legal notices will still govern your use of the Sites and other Services, and you are responsible for reviewing such legal notices for changes. We will process your request to unsubscribe within a reasonable time, but you may receive additional emails until your request is processed.
• Deletion of Account. You may at any time request to remove or delete your personal information from our system or withdraw your consent to our use, sharing, and processing of your personal information as described in this policy (although a withdrawal of consent shall not affect the lawfulness of processing your personal information at any time prior to the date of such withdrawal and is subject to the other terms of this policy). If you wish to remove or delete your personal information or withdraw your consent, you may request deletion of your account with us by sending an email to email@example.com. We will process your request within a reasonable time, but you may continue to receive communications from us until your request has been processed. Some information may remain in our records after deletion of your account, including any information or records that we are legally obligated to retain and as described in Your Rights to Access, Modify, and Erase Personal Information. In addition, deletion of your account does not affect Public Submissions and personal information others may have about you, including copies of posts, messages, or other User Submissions to or from you.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
8. RETENTION OF PERSONAL INFORMATION
We will retain the personal information we receive from you as described in this policy for as long as you use the Sites or other Services or as long as necessary to fulfill the purposes for which such personal information was collected, to provide our Services, to resolve disputes and prepare for, defend against, and otherwise conduct any legal action or process, to conduct audits, to pursue our legitimate business purposes, to enforce or comply with contracts, and to comply with applicable laws.
9. CHILDREN UNDER THE AGE OF 18
The Sites and Services are not designed or intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. If you are under the age of 18, you may not create an account through, and must not use, our Sites or other Services. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that user’s account. If you believe we might have any information from or about a child under 18, please contact us at firstname.lastname@example.org.
10. LOCATION OF DATA
Curable and our (or our service providers’) servers containing personal information are located in the United States. If you are located outside of the United States, your personal information must be transferred or transmitted to the United States for storage and processing in compliance with this policy. By using our Sites and other Services, you consent to such collection, storage, and processing in the United States. Please be advised that the United States or such other countries may not afford the same level of data protection as is required in your own country. Pursuant to legal process made in the United States, your personal information may be available to the United States government or its agencies.
11. ADDITIONAL INFORMATION SOLELY FOR USERS LOCATED IN THE EU OR A EUROPEAN ECONOMIC AREA
If you are a user of Services who is located in an EU member state or a European Economic Area, you may contact us at email@example.com to inquire whether we are processing your personal information. You may request that Curable cease processing your personal information by emailing us a request at firstname.lastname@example.org, in which case Curable will delete your account pursuant to such request (see Your Choices About Our Collection, Use, and Disclosure of Your Information).
If you are a user of Services who is located in an EU member state or a European Economic Area and you believe that we have not complied with applicable data protection laws, you may file a complaint with your local supervisory authority.
13. CONTACT INFORMATION
If you have any questions or concerns regarding privacy on our Sites or with respect to our Services, please send us a detailed email to email@example.com or contact us at the address below:
Curable Inc. 201 Milwaukee Street Denver, CO 80206