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Privacy Policy

Last updated October 23, 2017

At Carrot Inc. we respect your privacy and value the trust you have placed in us. We are committed to the responsible management, use, and protection of your information. This Privacy Policy explains how Carrot Inc. (“Carrot,” “we,” “our,” or “us”) collects, uses, and discloses information we obtain through www.pivot.co and our products that link to this Privacy Policy including the Pivot Breath Sensor and the Pivot mobile application (collectively, the “Service”). This Privacy Policy is incorporated by reference into the Carrot Terms of Service.

YOUR HEALTH PRIVACY RIGHTS

A Federal law entitled the Health Insurance Portability and Accountability Act, (commonly referred to as HIPAA), safeguards “protected health information” that we create, receive, maintain, or transmit. As used in this Privacy Policy, the term “protected health information” includes any information covered by U.S. federal health laws that we maintain that reasonably can be used to identify you and that relates to your physical or mental health condition, the provision of care to you, or the payment for such care. Federal law limits how we may use and disclose this information. We are also required to, among other things, apply reasonable and appropriate measures to safeguard the confidentiality, integrity, and availability of your protected health information.

HOW WE COLLECT YOUR INFORMATION

Information You Provide

We collect any information that you provide us when you use the Service.

Pivot. We collect any information that you provide when you use Pivot Breath Sensor and the Pivot mobile application. For example, when you register you provide your name, cell phone number, and email address. In addition, through the Pivot Breath Sensor and Pivot mobile application we collect smoking behavior information you provide, for example: when you submit a breath sample, log cigarettes and/or identify triggers.

Communications and other Interactions. We may collect information through your communications with our customer-support team, our coaches or through other communications with us, including through social media and when you submit your email address and/or cell phone number to us so we can contact you.

Information We Collect When You Use Our Service

We may automatically collect certain technical information from your computer or mobile device when you use the Service.

Information and Content from Your Device. We automatically collect information about your device, such as a device ID and browser type, so that we can provide and customize functionality, such as push notifications. You may also permit us to access and collect information from your device’s contact list and photo storage for purposes of social networking.

Cookies and Related Technologies. We and our third party partners, such as advertising networks, social media widgets, and analytics providers, may collect certain information by automated means, such as cookies, web beacons and web server logs. The information collected in this manner includes IP address, browser characteristics, device IDs and characteristics, operating system version, language preferences, referring URLs, and information about the usage of our Service. We may use this information, for example, to determine how many users have visited certain pages or opened messages or newsletters, or to prevent fraud. We may link this data to your profile. Our partners also may collect information about your online activities over time, on other devices, and on other websites or apps, if those websites and apps also use the same partners. When they provide such services, they are governed by their own privacy policies. You may be able to change browser settings to block and delete cookies when you access the Service through a web browser. However, if you do that, the Service may not work properly.

HOW WE USE YOUR INFORMATION

Internal and Service-Related Usage. We use the information we collect about and from you for a number of purposes, including: providing, supporting, and improving the services we offer, analyzing how you use the Service, and better tailoring features.

Communications. We may send email to the email address you provide to us and push notifications, lessons, questionnaires, videos, animations, etc. to your mobile device to provide the Services and for informational and operational purposes, such as account management, customer service, system maintenance, and other Service-related purposes. We may also send you promotional emails or other information about the products or services we offer. You may opt out of email marketing by using the unsubscribe link in a marketing email or by writing to us at the address given at the end of this Policy.

Aggregate Data. To the extent permitted by applicable law, we may de-identify your information and process it in an anonymous and/or aggregated form for other purposes than described above.

CARROT  MAY DISCLOSE YOUR INFORMATION

Except as otherwise described in this Privacy Policy, we will not disclose information that we collect about you on the Service to third parties without your consent.

We Use Vendors and Service Providers. We may share any information we receive with vendors and service providers we use to help us provide and improve the Service. For example, we may provide your collected information to our database hosting provider.

Employers and Health Plans. If an employer, health plan or other third party purchases our Services on your behalf, the purchasing entity may require us to share your name or other identifying information for purposes of validating your participation and facilitating payment.

Coaches.  Carrot coaches will see information, including protected health information, about you when you use the Service. For example, a Carrot coach will be able to view the contents of your monitoring history, logs, user-generated content and other information obtained within the Service. If you move to a program supported by non-Carrot coaches, you may share your information with these coaches yourself or request that Carrot do so on your behalf. If you directly share personal information obtained through use of the Service with a non-Carrot coach, other person or entity or request Carrot to do so, and we are able to honor that request, we are not responsible for protection of the information shared outside our operating environment.

Marketing and Publication. We do not rent, sell, or share information that we collect from you on the Service with other people or nonaffiliated companies for their direct marketing purposes, unless we have your permission. In accordance with applicable law, we may allow anonymized access to data collected by the Service by third parties to enable the delivery of online advertising on the Service, or to send you information we think may be useful or relevant to you. We may use anonymized user information, statements, or feedback in our marketing or promotional materials.  In addition, we may publish reports and information on anonymous and aggregated user information such as demographics, outcomes, service performance and traffic patterns.

Legal and Similar Disclosures. We may access, preserve, and disclose collected information, if we believe doing so is required or appropriate to: comply with law enforcement requests and legal process, such as a court order or subpoena; respond to your requests; comply with the law; or protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, sale of Carrot assets, or transition of service to another provider, your information may be disclosed in connection with the negotiation of such transaction, and/or sold or transferred as part of such a transaction as permitted by law and/or contract.

With Your Permission. We may also disclose your collected information with your permission.

INFORMATION SECURITY

We take steps in an effort to treat your information securely and in accordance with this Privacy Policy. Unfortunately, the Internet and mobile networks over which our Services are delivered cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. We do not accept liability for unintentional disclosure.

CHILDREN’S PRIVACY

We do not knowingly collect, maintain, or use information collected from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If you learn that your child has provided us with information without your consent, you may alert us at [email protected] If we learn that we have collected any information from children under 13, we will promptly take steps to delete such information and terminate the child’s account.

INTERNATIONAL USERS

If you choose to access the Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that the Service is hosted in the United States and thus, you may be transferring your information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information on or to the Service, you consent to such transfer, storage, and processing.

UPDATE YOUR INFORMATION OR POSE A QUESTION OR SUGGESTION

If you would like to request that we update or correct any information that you have provided to us through your use of the Service or if you have questions regarding this Privacy Policy, including our use and disclosure practices, please send an email to [email protected]

CHANGES TO OUR PRIVACY POLICY AND PRACTICES

Please revisit this page periodically to stay aware of any changes to this Privacy Policy, which we may update from time to time. If we modify this Privacy Policy, we will make it available through the Service, and indicate the date of the latest revision. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of this Privacy Policy.  In the event that the modifications materially alter your rights or obligations hereunder, we will make reasonable efforts to notify you of the change. For example, we may send a message to your email address, if we have one on file, or generate a pop-up or similar notification when you access the Service for the first time after such material changes are made.

Contact Information
Carrot Inc.
1600 Seaport Blvd, Suite 150,
Redwood City, CA  94063,  USA
Email: [email protected]