Cariloop Privacy Policy

Last modified: July 2024

1. Introduction

Cariloop, Inc. (“Cariloop,” “us,” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or you may provide when you visit the website www.cariloop.com, the Caregiver Platform, or use of the Cariloop mobile application (collectively, the “Platform”) and our practices for collecting, using, maintaining, protecting, and disclosing your information.

Our use of your Personal Data (see definition below) may be further limited by a HIPAA Business Associate Agreement entered between us and your employer when your employer provides access to our Platform and our services as part of your benefits. If anything in this Privacy Policy conflicts with HIPAA or a HIPAA Business Associate Agreement, we will comply with the terms of HIPAA and/or the HIPAA Business Associate Agreement where applicable.

This Privacy Policy applies to information we collect:

on our website (from information you provide to us)
on our Platform (whether it is the web application or the mobile application); and
in email, text, and other electronic messages (including phone calls) between you and our Platform.

It does not apply to information collected by:

us offline or through any other means, including on any other website operated by Cariloop or any third party; or
any third party, including through any application or content (including advertising) which may link to or be accessible from or on the Platform.

Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Platform. By accessing or using the Platform, you agree to this Privacy Policy. This Privacy Policy may change from time to time and your continued use of the Platform after we make changes is deemed to be acceptance of those changes. As such, please check this Privacy Policy periodically for updates.

2. Children Under the Age of 18

You may use our Platform to help you in the care of your loved one of any age. However, our Platform is not intended for use by individuals under 18 years of age. No one under age 18 may directly provide any information to the Platform without verification of parental or guardian consent. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Platform or on or through any of its features, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete the respective information. If you believe we might have any information from a child under 18, please contact us at the Contact Information below.

3. Information We Collect About You and How We Collect It

General

We collect information from and about users of our Platform (“Personal Data”):

by which you may be personally identified, such as name, postal address, e-mail address, and telephone number;
about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Platform, error information, clickstream data, and other communication data and the resources you access and use on the Platform; and/or
about your internet connection, the equipment you use to access our Platform and usage details, IP addresses, operating system, and browser type.

We collect this information:

directly from you when you provide it to us;
automatically as you navigate through the Platform, for example, information collected through cookies or other tracking technologies

Zoom Meetings

your contact information and any information provided if you participate in a Zoom meeting with us

Information You Provide to Us

The information we collect on or through our Platform are:

information you provide by filling in forms on our Platform. This includes information provided at the time of registering to use our Platform, subscribing to our service, interacting with your Care Coach, or requesting further assistance through our Platform. We may also ask you for information when you report a problem with our Platform;
information you provide utilizing any of the features on the Platform;
records and copies of your correspondence (including email addresses) if you contact us;
information you provide in your private case file.

Your information may be shared with other Care Coaches of the Platform in order for us to provide the best member experience.

On occasion and solely with your permission, we may also publish feedback about our services and your Care Coach you provide on our Platform or elsewhere.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns as described above.

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 Platform and to deliver a better and more personalized service by enabling us to:

estimate our audience size and usage patterns;
speed up your searches; and
recognize you when you return to our Platform.

The automated data collection technologies we use include:

Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website and/or Platform. You can find more information about cookies at http://www.allaboutcookies.org.

4. How We Use Your Information

We use information we collect about you or you provide to us, including any Personal Data:

to present our Platform and its contents to you;
to provide you with information, products, or services you request from us;
to inform your Care Coach of new information;
to use for internal research or statistical analysis (in this situation we would sanitize and de-identify any information relating to you in accordance with HIPAA Security Rule regulations);
to use for sample cases for internal or external use (in this situation we would sanitize and de-identify any information relating to you in accordance with HIPAA Security Rule regulations)
to fulfill any other purpose for which you provide it;
to provide you with notices about your account, including expiration and renewal notices;
to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
to notify you about changes to our Platform or any products or services we offer or provide though them;
to allow you to participate in interactive features on our Platform;
in any other way we may describe when you provide the information;
to provide to a third-party if your employer sponsored plan has an incentive program; and
for any other purpose with your consent.

5. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy, including to your employer or the health plan sponsored by your employer. However, we may disclose aggregated information about our users and information which does not identify any individual, without restriction, in accordance with the Service Agreement signed by your employer. This may include incentive programs which your employer or your Plan utilize.

We may disclose Personal Data we collect or you provide as described in this Privacy Policy:

to service providers who perform services for us (for example, providing marketing assistance). They have access to Personal Data as needed to perform their functions, but may not disclose the Personal Data for other purposes;
to your Care Coach and potentially other Care Coaches to provide the best member experience;
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 Cariloop, Inc.’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Cariloop, Inc. about our Platform’s users is among the assets transferred;
to fulfill the purpose for which you provide it;
for research and development purposes, including to analyze and improve our Services and business to develop new products and services;
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;
to enforce or apply our Terms of Service [Please see Terms of Service at www.cariloop.com]
if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Cariloop, Inc., our customers, or others. This includes exchanging information with other companies and organizations such as law enforcement or other regulatory authorities.
We may share the fact you are utilizing Cariloop services to your program sponsor by disclosing name, ID, email, or the number of cases opened. We will not disclose the details about your case other than duration unless you consent or authorize Cariloop to provide this information.
We may use or disclose information to allow your participation in additional third-party services for programs sponsored by your Program Sponsor. This information may be shared back with your employer.
We may provide information to an analytics processor in a group format to derive analytical information. These analytic processors do not have any right to use your information except to provide the aggregation and analysis services.
Your program sponsor may have engaged our services through a distributor or aggregator service. If directed by the Program Sponsor, we may share limited amounts of personal information with these services related to your participation in utilizing Cariloop services.
We do not share phone numbers with third-parties / affiliates or partners.
We do not sell personal information to any third-parties.

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 Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information as strictly confidential.

7. Accessing and Correcting Your Information

You can review and update your Personal Data by logging into the Platform and visiting your account page. You may also contact us through the Contact Information below to request access to, correct or delete any Personal Data you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your Personal Data from the Platform, copies of your Personal Data may remain viewable in cached and archived pages. Proper access and use of information provided on the Website, including User Information, is governed by our Terms & Conditions.

8. Do Not Track Signals

We also may use automated data collection technologies to collect information about your online activities over time on our website. 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 modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

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 have our control environment and infrastructure tested by independent external firms to ensure we have best practices in place in compliance with various risk frameworks.

The safety and security of your information also depends on you. Where you require a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password 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 our Platform. 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 Platform except where required by law.

10. Artificial Intelligence (AI)

Our Caregiver Support Platform® sometimes utilizes AI to provide a better experience for our Members. It is currently used to find content which may relate to our Members and their respective case.

Members have the option to utilize AI if they choose to on our Platform. Please note AI is not used to collect your personal information and a Member does not enter any information into an AI tool.

11. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. If we make material changes to how we treat our users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Website home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Policy to check for any changes.

12. International Customers

Canada Customers

For individuals living in Canada, please see the above sections for the following:

Types of information we obtain
How we use the respective information
How to access your information
Privacy choices

If you have any questions regarding this Privacy Policy, please email the address noted in the Contact Information section below.

13. Contact Information

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact through the contact information below or through the “Contact Us” page on our Website.

To contact Cariloop, please email:

privacy@cariloop.com