Last modified: March 23, 2021
Dr. B, PBC (“Dr. B,” or “we,” “our,” or “us”) respects your privacy, and we are committed to protecting it through our compliance with this policy.
This policy applies to information we collect:
on our Services;
in email, text, and other electronic messages between you and our Services;
when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.
It does not apply to information collected by:
us offline or through any other means, including on any other website operated by Dr. B or any third party;
any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Services.
2. CHILDREN UNDER THE AGE OF 16
Our Services are not intended for children under 16 years of age. No one under age 16 may provide any information to or through the Services. We do not knowingly collect Personal Data from children under 16. If you are under 16, do not use or provide any information on or in our Services or on or through any of their features. If we learn we have collected or received Personal Data from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 16, please contact us at firstname.lastname@example.org.
3. INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
We collect several types of information from and about users of our Services, specifically information:
by which you may be personally identified, such as (i) your name, mobile number, e-mail, zip code of residence, date of birth and profession, (ii) whether you have preexisting comorbidities of COVID-19, and (iii) whether you reside in a group setting (“Personal Data”);
that is about you but individually does not identify you, such as traffic data, logs, referring/exit pages, date and time of your visit to or use of our Services, error information, clickstream data, and other communication data and the resources that you access and use on or through our Services; or
about your Internet connection, the equipment you use to access or use our Services and usage details.
We collect this information:
directly from you when you provide it to us; and
automatically as you navigate through or use our Services (which may include estimated or precise geo-location, usage details, IP addresses, and information collected through cookies and other tracking technologies).
Information You Provide to Us
The information we collect on or through our Services is:
Personal Data such as the data identified above;
information that you provide by filling in forms on our Services (including, information provided at the time of registering with our Services, using our Services, or reporting a problem with our Services);
records and copies of your correspondence (including phone numbers and email addresses), if you contact us; and
details of transactions you carry out through our Services.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Services or transmitted to other users of the Services or third parties (collectively, “Posted Information”). Your Posted Information is posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Services with whom you may choose to share your Posted Information. Therefore, we cannot and do not guarantee that your Posted Information will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:
details of your visits to our Services, such as traffic data, location, logs, referring/exit pages, date and time of your visit to or use of our Services, error information, clickstream data, and other communication data and the resources that you access and use on or in the Services; and
information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, browser type, and App version information.
The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Services and to deliver a better and more personalized service by enabling us to:
estimate our audience size and usage patterns;
store information about your preferences, allowing us to customize our Services according to your individual interests; and
recognize you when you return to our Services.
The technologies we use for this automatic data collection may include:
Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help our Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
4. HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any Personal Data:
to provide our Site and its functionality and contents to you;
to provide our App and its functionality and contents to you;
to provide our Services to you;
to provide you with information, products, or services that you request from us or that may be of interest to you;
to provide you with notices about your Dr. B account;
to contact you in response to a request;
to fulfill any other purpose for which you provide it;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
to notify you about changes to our Services;
in any other way we may describe when you provide the information; and
for any other purpose with your consent.
5. DISCLOSURE OF YOUR INFORMATION
to affiliates, contractors, service providers, and other third parties we use to support our business (including providers of IT and infrastructure support services);
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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Dr. B about our users are among the assets transferred;
to fulfill the purpose for which you provide it;
for any other purpose disclosed by us when you provide the information; and
with your consent.
We may also disclose your Personal Data:
to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Dr. B, our customers, or others (including, exchanging information with other companies and organizations for the purposes of fraud protection).
6. CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We do not control the collection and use of your information collected by third parties described above in Section 5 (Disclosure of Your Information). These third parties may aggregate the information they collect with information from their other customers for their own purposes.
7. YOUR RIGHTS REGARDING YOUR INFORMATION AND ACCESSING YOUR INFORMATION
You can contact us to access and/or find out what information we have about you. You may also notify us via the methods set forth in Section 12 (Contact Information) of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.
To delete your account via SMS:
Text the words “DELETE DATA” to the number that we originally contacted you with during your initial registration, using the same mobile number that you used during such initial registration;
Our system will send the following SMS response:
To permanently delete your information from our database, please reply with "DELETE DATA<your birth date>. For example, "DELETE DATA 1/21/1950". If you meant to unsubscribe from the waitlist instead, reply with "LEAVE"
Enter the words “DELETE DATA” followed by your birthday in the format specified in our SMS response.
Assuming all data entered matches our system records, our system will then send the following SMS response:
Your data has been deleted.
8. DO NOT TRACK SIGNALS
Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals, but we currently do not use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services (behavioral advertising).
9. DATA SECURITY
We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.
The safety and security of your information also depends on you. You are responsible for keeping your mobile device physically secure. We ask you not to share your mobile device with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to, on or through our Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site, in your operating system, or in the App.
10. CALIFORNIA PRIVACY RIGHTS FOR CALIFORNIA RESIDENTS
Categories of Personal Information Dr. B Collects – California Residents
Personal information does not include information that is: (a) publicly available information from government records; (b) de-identified or aggregated consumer information; or (c) certain information excluded from the scope of CCPA (e.g., PHI covered under HIPAA and medical information covered under the California Medical Information Act).
Categories of Sources from which Dr. B has collected Personal Information
We collect Personal Information directly from you, for example when you provide it to us, when you contact us through our Services, when you create a Dr. B account; and indirectly from you automatically through your computer or device as you use our Services. We may also collect Personal Information about you from our service providers.
Use of Personal Information Collected from California Residents
Sharing Personal Information - California Residents
Dr. B may disclose your Personal Information to a third party for one or more business purposes (including health care providers administrating the COVID-19 vaccine). When we disclose Personal Information for a business purpose, such as to service providers, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract.
Disclosures of Personal Information for Business Purposes
We may disclose your Personal Information for our business purposes, such as your contact information, other information you have provided to us and unique identifiers that identify you to us or to our health care Provider partners and service providers. Please refer to Section 3 (Information We Collect About You and How We Collect It) for additional information and details.
We disclose your Personal Information to certain third parties such as our health care Provider partners and service providers. For additional information please refer to Section 4 (How We Use Your Information) and Section 5 (Disclosure of Your Information).
Access Request Rights
California residence have the right to request that Dr. B disclose certain information to you about our collection and use of your Personal Information over the past 12 months for the above business and commercial purposes. To submit an access request, see Exercising Access and Deletion Rights. Once we receive and confirm your verifiable consumer request, we will disclose to you:
the categories of Personal Information we collected about you;
the categories of sources for the Personal Information we collected about you;
our business or commercial purpose for collecting that Personal Information;
the categories of third parties with whom we share that Personal Information;
the specific pieces of Personal Information we collected about you;
if we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
sales, identifying the Personal Information categories that each category of recipient purchased; and
disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
Deletion Request Rights
California residents have the right to request that Dr. B delete your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless certain exceptions apply.
Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by emailing us at email@example.com.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period. The verifiable consumer request must:
Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
deny you goods or services;
charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;
provide you a different level or quality of goods or services; or
suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services;
Other California Privacy Rights
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Services that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g., requests made in 2021 will receive information regarding such activities in 2020). You may request this information once per calendar year. To make such a request, please contact us by email at firstname.lastname@example.org.
12. CONTACT INFORMATION
Dr. B, PBC
110 Greene Street
New York, New York 10012