Privacy Policy
1 - Scope
BklynHlth, Inc. (“Brooklyn Health”, “we”, “us”, and “our”) values the privacy of your personal information. This Privacy Policy will help you understand how we collect, use, and disclose your personal information and assist you in exercising the privacy rights available to you. We may update this Privacy Policy from time to time and will update the Last Updated date above.
If you have a concern or question about this Privacy Policy, about privacy with the Services, or to inquire about any personal information you provided us, please send an email with your question or concern to privacy@brooklyn.health.
Capitalized terms not defined in this Privacy Policy have the meanings set forth in our Terms of Service.
This Privacy Policy applies to personal information processed by us through the Services, including on our websites (e.g., https://brooklyn.health, https://willis.health, and any other websites that we own or operate), our application program interfaces, and our related online and offline offerings.
This Privacy Policy does not apply to any third-party websites, services or applications, even if they are accessible through our Services.
2 - What Information Is Collected
The personal information we collect depends on how you interact with our Services.
2.1 - Information You Provide to Us
Account Information. When you create a Willis Platform account, we collect the personal information you provide to us, such as your name, email address, phone number, work address, and profile picture.
2.2 - Information Collected Automatically (Technical Information)
Automatic Data Collection. We collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile advertising and other unique identifiers, details about your browser, operating system or device, internet service provider, pages that you visit, information about the links you click, and information about how you interact with and use the Services.
Usage Data. We collect and analyze data and other information relating to the access, use, and performance of the Services (“Usage Data”). Examples of Usage Data include technical logs, metadata, telemetry data, technical data, and usage information about Your Content, such as how many times it is accessed. For clarity, Usage Data excludes Your Content itself. Usage Data may include personal information such as information about your interactions with other users.
Cookies; Analytics Information. We, as well as third parties that may provide content or other functionality on or in connection with the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Cookies are small text files stored by your browser on your computer’s hard drive, which enable us to provide a more seamless experience for our users. For example, by using cookies, we can ensure a user remains logged in across browser windows in an active user session, thereby providing convenience while navigating our site. If a user rejects the cookie, there may be areas of our site that are restricted. Cookies can also enable us to track and target the interests of our users to enhance the experience of our site.
2.3 - Information from Other Sources
Brooklyn Health Customers. If you use our Services on behalf of, or in collaboration with, an organization (e.g., your employer), that organization may provide us with information about you so that we can provision your account.
3 - How We Use Your Information And Our Legal Basis For Processing
In this section, we describe all the ways we use your personal information, and the legal bases we rely on to do so.
In certain situations, we require your data to pursue our legitimate interests in a way which is reasonable for you to expect as part of running our business and which does not materially affect your rights. We have identified below what our legitimate interests are.
When we process your information based on your consent, you have the right to withdraw your consent at any time without affecting the lawfulness of processing based on such consent before it is withdrawn. To exercise your rights, see the Contact Us section of this Privacy Policy.
We use your personal information for a variety of business purposes, including as enumerated below. Each section starts by describing how we use the data, followed by which of your data we may use for such purpose, and ending with the legal basis for such data use.
3.1 - Providing and managing the Services or information requested, such as: account creation; managing your information and account; responding to questions, comments, and other requests; providing access to certain areas, functionalities, and features of our Services, including the sharing of content with colleagues and other users, and certain artificial intelligence functionality if this option is in use on your account; answering requests for customer or technical support; responding to requests in relation to personal information processed about the individual; and, if you enable phone-based two-factor authentication, for authentication.
This includes: The processing of all categories of information.
Legal Basis: Performance of the contract with you. Necessary for our legitimate interests to respond to and communicate with you (where we do not have a contractual relationship or legal obligation to do so). Necessary to comply with a legal obligation (including national data protection and consumer protection laws, for example to respond to requests in relation to personal information processed about the individual)
3.2 - Communicating with you about your account, activities on our Services and Privacy Policy or Terms of Service changes.
This includes: The processing of your Account Information and Your Content.
Legal Basis: Performance of the contract with you. Necessary to comply with a legal obligation (including national data protection and consumer protection laws).
3.3 - Administering and protecting our business and Services (including troubleshooting, data analysis, testing, system maintenance, support, reporting, internal quality control and safety and hosting of data).
This includes: The processing of your Account Information, Technical Information, Your Content, and Usage Data.
Legal Basis: Performance of the contract with you. Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise). Necessary to comply with a legal obligation (including national data protection and information security laws)
3.4 - Contacting you about products, services, developments and events we think may be of interest to you.
This includes: The processing of your Account Information.
Legal Basis: In certain situations, we seek consent before sending marketing materials to individuals and in such cases consent is our lawful basis for sending marketing to you.
Where we do not obtain consent, we rely on our legitimate interests (to develop our products/services and grow our business) as our lawful basis for sending marketing materials to you.
If you have any questions about our marketing practices or if you would like to withdraw your consent or opt out of the use of your personal information for marketing purposes, you may contact us as set out in the Contact Us section of this Privacy Policy.
3.5 - Enforcing our agreements, and complying with our legal obligations including to disclose information to law enforcement, the courts and other authorities.
This could include any personal information we process about you.
Legal Basis: Necessary to comply with a legal obligation (including national data protection, cyber security, export control, sanctions and surveillance laws). Necessary for our legitimate interests (to enforce our agreements, to seek professional advice, or to establish, exercise or defend a legal claim).
3.6 - De-identifying data and creating aggregated information, such as aggregated statistics or for analytical purposes.
We may choose to de-identify and create aggregated information out of personal information you provide to us. For example, we could aggregate information about email addresses our users use to identify legitimate email providers versus spam providers, or we could aggregate the number of users who use a particular feature to determine which features are popular.
Legal Basis: Necessary for our legitimate interests (to use personal information to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, and information about the device from which you access our Services. De-identified and/or aggregated information is used for several purposes, including research, industry analysis, analytics, and any other legally permissible purposes.)
4 - Disclosing Your Information To Third Parties
We may disclose any personal information we collect to the following categories of third parties:
Other Users of Brooklyn Health’s Services. When you use the Services to interact with others, we will disclose certain information to your collaborators. For example, when you comment, we display your name next to your comments so that other users with access to the comment know who made it.
Service Providers. We may disclose personal information we collect about you to our service providers. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of the Services; (ii) the provision of information, products, and other services you have requested; (iii) payment and transaction processing; (iv) the provision of IT and related services.
Your Organization and Administrator. If you access the Services on behalf of an organization (such as with your organization’s domain) or have your account paid for by another party, we will disclose your information to that organization or paying party at its request and give such organization certain rights over your information. For example, your organization may request that we provide extra security controls around your account to protect information about your organization or your organization may request that we link your Willis Platform account with your organization’s account to enhance collaboration. If you are the administrator of a team, organization or other account holder within the Services, we may disclose your contact information to current or past Service users related to you, for the purpose of facilitating Service-related requests. Please note that your information may also be subject to your organization’s privacy policy, and we are not responsible for the privacy or security practices of our customers.
Third-Party Platforms and Services. We will disclose certain personal information to third-party platforms and/or services if you have expressly consented or requested that we do so. Please note we do not endorse, screen or approve, and are not responsible for, the practices or conduct of such third-party services.
Disclosures to Protect Us or Others. We will access, preserve, and disclose information we have associated with you to competent law enforcement bodies, regulatory and government agencies, courts or other third parties if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our or others’ rights, property, or safety; (iii) enforce Brooklyn Health’s policies and contracts; (iv) collect amounts owed to us; (v) prevent financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vi) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred in accordance with our legitimate interests in administering our business as part of such a transaction, as permitted by law and/or contract.
5 - Your Choices
General. You have the right to opt out of certain uses of your personal information.
Email. If you receive an unwanted marketing email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future marketing emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms of Service or this Privacy Policy).
6 - Your Privacy Rights
In accordance with applicable law (including in the EU/UK, California, Connecticut, Colorado, and other U.S. states with comprehensive privacy laws), you may have the right to:
- Confirm whether we are processing your personal information;
- Request access to and portability of your personal information about you, including: (i) obtaining access to or a copy of your personal information; and (ii) receiving an electronic copy of personal information that you have provided to us, or asking us to send that information to another company (the “right of data portability”);
- Request correction of your personal information where it is inaccurate or incomplete. In some cases, we may provide self-service tools that enable you to update your personal information;
- Request deletion of your personal information (including to request deletion of your account). In limited circumstances, it may be necessary to retain your Personal Information to comply with legal requirements even if a deletion request is made;
- Request restriction of or object to our processing of your personal information;
- Withdraw your consent to our processing of your personal information; and
- Opt-out of marketing communications. Please see more on this in Section 5, above.
If you would like to exercise any of these rights, please contact us as set forth below. If you are not satisfied with how we process your request, you may have a right to appeal our decision under applicable law. Where such an appeal right exists, if so required by applicable law, we will inform you of such right and how to initiate an appeal.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. To designate an authorized agent, please contact us as set forth below.
Please note that if you use our Services on behalf of an organization (e.g., your employer), that organization may be responsible for fulfilling the individual rights requests referenced above.
7 - Data Retention
We store the personal information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and/or comply with applicable laws. The specific retention periods depend on the nature of the information and why it is collected and processed and the nature of the legal requirement.
When we have no ongoing legitimate business need or legal reason to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. You may request deletion of your personal information at any time as noted in “Your Privacy Rights”, above, but that will require you to delete your account with us, as we need your personal information to maintain your account.
8 - Security Of Your Information
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy.
We may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
9 - Third-Party Websites/Applications
The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Visiting these other websites or applications is at your own risk.
10 - Changes To Our Privacy Policy
We may revise this Privacy Policy from time to time at our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law.
11 - Contact Us
If you have any questions about this Privacy Policy or our privacy practices, or if you wish to submit a request to exercise your rights as detailed in this Privacy Policy, please contact us at: privacy@brooklyn.health