Scope of Policy
Information Collected by Automated Means:
We may also collect, retain and use certain information when you visit our Site or use our services, including, but not limited to, how many users visit our Site, pages accessed, geographic location and other statistics. We collect such information to gain a better understanding of our user population and to help improve our Site and user experience. We collect this information through various means, including “cookies”, “web beacons” and other analytics tools summarized below. We do not obtain personally-identifiable information about you when you visit our Site, unless you choose to provide such information.
Cookies: A cookie is a small data file that often includes an anonymous, unique token, which is sent to your browser from a website’s computers and may be stored on your computer’s hard drive. Two types of cookies are required to use the Site:
- Session Cookies are temporary cookies that remain only until you log out of the Site or exit your web browser. Session Cookies do not store any Personal Information, only a unique visitor ID number that may be used to ensure users are properly authenticated and can view Site information.
- Persistent Cookies remain in the cookie file of your browser for much longer, even after you leave the Site. Persistent Cookies also do not store any Personal Information. Persistent Cookies store preferences that should persist from visit to visit, like “Remember Me,” and a unique token to enable us to understand how users use the Site (“Site Usage”).
Web Beacons: Our Site may also use “web beacons” (also known as Internet tags, pixel tags and clear GIFs) that collect information such as advertising metrics, page views, Internet domain, IP addresses and browser type.
Log Files: We gather certain information automatically and store it in log files. This information includes IP addresses, browser type, Internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, driving logs entered into the Site, documents uploaded to the Site, messages exchanged on the Site, and clickstream data. We use this information to analyze trends, administer the Site, track users’ movements around the Site, gather demographic information about our user base as a whole, and better tailor our products and services to our users’ needs.
Analytics: Our Site may also use analytic tools and services, like Google Analytics, to create statistical reports and aggregate other information regarding users. Google Analytics collects information like how often users visit, what pages they visit and user IP addresses. You can prevent Google Analytics from recognizing you on return visits to our Site by disabling cookies on your browser. For additional information on Google and its privacy practices, you may go to https://www.google.com/policies/privacy/partners
Information Provided Voluntarily:
The following are some of the ways you may elect to provide your Personal Information to us:
Site Use: We collect Personal Information that users submit to us voluntarily in the course of use of the Site. Examples include: your name, email address and telephone number.
Patient Engagement, Assistance and Related Services: You may provide Personal Information directly to our Patient Support Team or other Company professionals via phone, email and/or our Site. This information will be used to provide you with information and services, and may be shared with potential third-party treatment providers subject to your consent.
Contact Us: If you communicate with us through the “Contact Us” link on our Site, we will use the information you provide to send you requested information.
News, Updates and Publications: You may be able to subscribe to receive news and other information from us. We use the information you provide to send you requested information. In addition, we may communicate with you regarding other topics that we believe may be of interest to you. Users who register to receive such information will automatically be added to our marketing email lists and may opt out at any time.
Blogs and Personal Stories: You may be able to submit personal stories and comments through our Site that may be posted and shared on our Site and blogs. The decision to share Personal Information and stories is yours, but we hope to hear from you. If you choose to provide such information, however, you are authorizing us to publish or otherwise publicly share such information without the receipt of payment or consideration. We cannot make any promises or guarantees that any such information provided will, in fact, be posted or publicly shared.
Careers: Job candidates may submit a resume and other information to apply for a position at Renovia, which will be used in connection with the job inquiry.
Members-Patient and Device Registration: Upon prescription of a device by your health care provider, Renovia Inc will help you register for the Member portion of our Site and provide information regarding the use of your patient and device data at that time.
Information That May Be Shared
Some of the information that users provide about themselves may be shared with the Renovia community, your selected clinician, or research partners. Examples of Shared Data that users may submit at the Site may include:
- Biographical information, e.g., gender, age, location (city, state and country), general notes;
- Condition/disease information, e.g. diagnosis date, first symptom, family history;
- Treatment information, e.g. start dates, stop dates, frequency, side effects and evaluations;
- Symptom information, e.g. severity, duration;
- Individual and aggregated survey responses;
- Information shared via free text fields, e.g. the forum, treatment evaluations, surveys, annotations, journals, feeds, adverse event reports; and
- Connections to other people on the Site, e.g. invited care team member, or research partner.
In the course of using the Site, users may share information that could be used to reasonably identify them (“Personal Information”), including name, photograph, and email address. When a user chooses to share Personal Information via a free text field (e.g. treatment results, treatment evaluations, annotations, clinical trial results, or adverse event reports) and photos or images, the information shall be treated as Shared Data.
Some of the information that users enter into certain fields when registering to use or using the Site will not be shared (“Restricted Data”), unless a user also chooses to share such information via a free text field as described above. The type of Restricted Data that users may submit at the Site may include:
- Name, as collected as part of registration or in a Member’s Account Information;
- Email address, as collected and verified as part of registration or in a Member’s Account Information;
- Password, as collected as part of registration or in a Member’s Account Information;
- Mailing address, as collected via email, or communication with your clinical care provider;
- Private messages intended for your clinical care provider; and
- When a user enters Personal Information, including name and email address, as part of registering to use Renovia Inc, that Personal Information is treated as Restricted Data.
Use of Your Data
Users should expect that every piece of information they submit to this Site (even if it is not currently displayed), except for Restricted Data, may be shared with Renovia Inc, clinicians and research partners. Users are encouraged to share health information but should consider that the more information that is entered, the more likely it is that a user could be located or identified.
There are instances where both Shared Data and Restricted Data, including Personal Information, may be used and disclosed including, but not limited to, the following:
Renovia Inc uses Shared Data, Restricted Data, and Site Usage internally, as needed, for research, for maintenance and operation of the Site, and to create the best possible tools and functionality for patients.
Renovia Inc may use a user’s data in the case of an emergency or other circumstance that we determine requires a member of the management team to directly contact the user.
Renovia Inc may use a user’s data to create a Member’s Account; respond to questions and provide customer service; and to protect, investigate and deter unauthorized activity with respect to the Site.
Renovia Inc may share or disclose a user’s data where required by law or to comply with legal process.
In the event Renovia Inc goes through a business transition, such as a merger, acquisition by another organization, or sale of all or a portion of its assets, the Shared Data and Restricted Data, including Personal Information, might be among the assets transferred. Users will be notified via this Site of any such change in ownership or control of Personal Information.
How Shared Data May Be Used
Data that could be shared is viewable by you using your username and password that you created with your health care provider. Data shared under your “Remember Me” selection can be viewed by you and may be used as aggregated reports. Renovia Inc may use such aggregated reports for marketing and internal reporting purposes. Aggregated reports are also made available to other Renovia Inc researchers or employees for the purposes of improving the patient use of the leva. Publicly Shared Data is reported in aggregate, such as the number of patients experiencing a particular symptom.
In addition to serving the individual needs of our users, Renovia Inc and its research partners are interested in better understanding the patient experience and improving treatment regimen based on the patient’s key physical findings and experience with the leva. Renovia Inc may report Shared Data, in individual and aggregate format, to research partners and other third parties for use in scientific research and market research. When selling this information, Renovia Inc removes users’ Restricted Data to reduce the likelihood of re-identification prior to sharing information with research partners.
Renovia Inc may also periodically ask users to complete short surveys about their experiences (including questions about products and services). Survey responses are analyzed, combined with users’ Shared Data and shared with and/or sold to research partners. User participation in these surveys is not required, and refusal to do so will not impact a user’s experience on the Site.
Renovia Inc may also report individual adverse events and product safety information to the FDA, CDC, and/or other regulatory bodies (U.S. and international) as well as directly to participating clinicians. Renovia Inc does not provide Restricted Data to such regulatory bodies, although we reserve the right to contact users for follow-up at the request of agencies or research partners. The information Renovia Inc reports includes, but is not limited to, all the information about the user and/or free text or images on the forums or evaluations, which may include Shared Data.
Posting and Use of Content to Review Leva Therapy Training
You agree not to disclose to any person or entity personally identifiable information about other Members that you encounter while using this Site (whether posted in the Member Area by a Member or emailed to you by a Member) without the express consent of such Member. You may disclose information of a general nature (that could not identify the Member who provided such information or whom such information is about) to third parties outside this Site, subject to the above restriction on non-commercial use.
Member Password and Login Identity
You are responsible for maintaining the confidentiality of your Member password and login, and are fully responsible for all activities that occur under your password or Account with or without your knowledge. If you knowingly provide your login and password information to another person, your Site use and privileges may be suspended temporarily or terminated. You agree to immediately notify Renovia Inc of any unauthorized use of your membership password or login or any other breach of security.
Links to Other Websites
Renovia Inc may contain links to other websites that are not under the control of Renovia Inc. The inclusion of any link does not imply endorsement by Renovia Inc of such site and Renovia Inc is not responsible for the content of such linked sites.
You agree that Renovia Inc may, with or without cause, immediately terminate your Renovia Inc membership or limit or terminate your access to the Site without prior notice. Without limiting the foregoing, the following may lead to a termination by Renovia Inc of a Member’s access to the Site and use of the Site: (a) breaches or violations of this Agreement or other incorporated agreements or guidelines, (b) requests by law enforcement or other government agencies, (c) a request by you (self-initiated membership cancellation), (d) unexpected technical issues or problems, and (e) extended periods of inactivity. Renovia Inc has no obligation to maintain, store, or transfer to you, information or data that you have posted on or uploaded to the Site.
Other Security Issues
Renovia Inc cannot guarantee the security of the identity of any other users with whom a user may interact in the course of using the Site or who may have access to a user’s Shared Data. Additionally, we cannot guarantee the authenticity of any data that users may provide about themselves.
Finally, users should know that Renovia Inc takes commercially reasonable technical precautions to help keep user data secure.
Risks and Benefits
While our goal is to help patients improve their net health outcomes, we are not a health care provider and do not provide any medical advice, diagnosis or treatment. There are no certain benefits to using this Site. However, keeping track of your leva therapy and results is anticipated to improve your personal well-being, treatments, and symptoms. Engaging your clinical care providers in your treatment is the objective of this web based community.
There are also no known risks to using this Site, but there is a possibility that users may feel uncomfortable sharing information online. It is possible that a user could be identified using information shared on Renovia Inc (and/or in conjunction with other data sources). A user could be discriminated against or experience repercussions as a result of the information shared. For example, it is possible that employers, insurance companies, or others may discriminate based on health information.
In using the Site, users are free to skip any non-required questions or data fields that make them feel uncomfortable. Users are also free to stop using this service at any time. If a user chooses to deactivate his/her Account, Renovia Inc will not display or sell the data in that Account as of the date of deactivation. However, the user’s data will remain in the system for auditing purposes, and research conducted prior to the deactivation of a Member’s Account will still include the Member’s data.
Accessing, Correcting, “Opting-Out” and Deleting Your Information
We will take reasonable steps to accurately record the Personal Information that you provide to us, including any updates. We encourage you to review and update any Personal Information that you may have provided to ensure its accuracy. You may request confirmation of your Personal Information that may be in our possession, make modifications, or request that we delete certain Personal Information about you that is inaccurate or that you believe may infringe any applicable legal requirements by contacting us as Contact@RenoviaInc.com. To help protect your privacy, we take reasonable steps to verify your identity before granting access to your information. Please note, however, that your right to review, update, correct and/or delete your Personal Information is subject to (and may be limited by) applicable law and record retention requirements.
You may also “opt-out” of marketing and/or other information services and rescind prior consents and authorizations. To “opt out” or unsubscribe from marketing or promotional communications, please follow the unsubscribe instructions included in the specific communication. In addition, if you wish to rescind an authorization or consent previously granted for a specific purpose concerning your Personal Information, please send an email to OptOut@RenoviaInc.com. Please understand, however, that any requested revocation or rescission will necessarily be forward looking in nature and will not otherwise affect the validity of the consent for any uses and/or disclosures of your Personal Information prior to the revocation.
California’s “Shine the Light” Law: We acknowledge that California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what information is disclosed to third parties for direct marketing purposes in the preceding calendar year, as well as a list of the categories of Personal Information that were disclosed.
Children: Our Site is not directed to children and children are not eligible to use our services. Protecting the privacy of children is very important to us. We do not collect or maintain Personal Information from people we actually know are under 13 years of age, and no part of our Site or services is designed to attract people under 13 years of age. If we later learn that a user is under 13 years of age, we will take steps to remove that user’s Personal Information from our databases and to prevent the user from utilizing the Site or services.
California Online Privacy Protection Act Compliance
Because we value your privacy we have taken the necessary precautions to be in compliance with the California Online Privacy Protection Act. We therefore will not distribute your personal information to outside parties without your consent.
As part of the California Online Privacy Protection Act, all users of our site may make any changes to their information at anytime by logging into their application settings and going to the ‘Profile’ page.
A Note to Users Outside of the United States
263 Summer Street
Boston, MA 02210
V3 Effective Date: May 10th, 2018