By visiting our website, using AskDrJeff, or otherwise providing personal information to us, you acknowledge that you have read, understand, and accept our privacy practices and policies outlined below, and you consent that we may collect, process, store, and share personal information as described in this Privacy Policy, subject to the exercise of individual rights as explained in this Privacy Policy.
1. Notice at Collection of Personal Information
Definition of Personal Information in the course of our business relationship, information collected, processed, stored, and shared that could be personally identified or related to a particular person or home, either directly or indirectly, shall be called “personal information.”
Sensitive personal information does not include publicly available information. Likewise, personal information is not any form of data that cannot be used in whole, or in part, to identify a person.
1.1 Kinds of Personal Information Collected
As necessary, and depending on your health needs, Dr. Jeff may collect, process, store, and securely share with third parties the following:
Contact information – full name, home or work address, email address, and phone number
Professional or employment-related information – place of employment, governing organization, registered number, job title, and role in institution
Account credentials, such as username and password
Date of birth, if provided
Financial information linked to your identity, such as bank account, wire transfer, and credit card information that can be tapped in the event of identity theft, or phishing
Commercial information linked to your identity, such as billing details, bill and payment history, products and services availed or considered, and purchasing behavior
Internet and device identifiers, activity, and analytics, such as IP address you use to access the Dr. Jeff website, cookies, and similar technologies from our online services
Geolocation data, when the website, or other Dr. Jeff services are being used
Sensitive Personal Information (SPI) such as health, age, sexual activity and orientation, ethnicity, and gender
SPI also constitutes health information, including medical symptoms, history, conditions, and other related data
Online preferences, related to marketing, data privacy, or communications
Feedback information
1.2 Our Legitimate Business Purposes for Collecting and Sharing Personal Information
We collect, process, store and/or share all of the categories of personal information identified above (unless a limited subset of categories is indicated) for our following business purposes, our legitimate interests and the legitimate interests of third parties to:
Provide our website and services, and most importantly to provide possible conditions which are suggested by the symptoms you report to us; provide users with access to the appropriate areas and functions of the Ask Dr. Jeff website
Administer, protect, support, and improve our website and services, including to keep our website working safely, securely, and efficiently by troubleshooting, testing, conducting data analysis, making updates, and detecting and preventing fraud (including through identity verification)
Support our business operations, which consist of running websites and offering services for profit, provide assistance to health professionals and others in interpreting conditions of symptoms
We process, store and share personal information to conduct data analysis and research to support and improve our business operations, to bill and collect payment for our services and to prepare and file tax forms and other documents
To market our products and services, for example, we use limited categories of personally identifiable information to show you advertisements and send you marketing communications regarding Dr. Jeff's products and services
Aggregate personal information, including aggregating, anonymizing, and deidentifying personal information so that it is no longer personally identifiable
Meet legal and compliance requirements, including to perform audits, monitoring, and reporting; support information security and anti-fraud operations; investigate and respond to disputes; exercise and defend legal claims; protect the rights, property or safety of all concerned parties
Evaluate or conduct business changes, including a merger, acquisition, sale, equity or debt financing, reorganization, dissolution, bankruptcy, or other transaction in which a third party invests in, finances or acquires control of our business or assets
We do not collect or process personal information for the purposes of automated decision-making or profiling (meaning the automatic processing of your personal information to identify your preferences and interests)
1.3 Other Legal Bases for Our Processing of Personal Information
Other legal bases for our processing of personal information include when the processing is necessary to perform a contract with you, we have a legal obligation to process the personal information, or we have your consent to process the personal information.
1.4 Categories of Parties Whom We Share Your Personal Information
Third Parties We share personal information with the following categories of third parties:
Our affiliates for purposes consistent with this Privacy Policy, including to support marketing, sale, and delivery of our website and our services
Our support vendors who provide us with services and products that help us provide services or operate our business
Our marketing vendors with whom we may share limited categories of personal information to assist with marketing, lead generation, and promotions
Authorized Parties, including third parties you access through our services, such as identity verification providers and payment processors
Legal Parties, including governmental authorities, law enforcement, courts, or other third parties in connection with the activities set forth in this privacy policy
Parties for business changes, such as during a merger, acquisition, sale, or similar transaction
1.5 We Do Not Sell or Share Your Personal Information for Targeted Advertising
We do not sell personal information. For purposes of this Privacy Policy, “sell” means the disclosure of personal information to a third party in exchange for money or other valuable consideration. We do not share personal information with third parties for cross-contextual behavioral advertising or targeted advertising.
1.6 Retention of Personal Information
We retain personal information for as long as we deem to be necessary or advisable for our business purposes described in this privacy policy. This may include keeping your personal information for up to 7 years after you have stopped using our services.
1.7 Storage and Security of Personal Information
We are committed to safeguarding your personal information and ensuring compliance with applicable regulations, including HIPAA (Health Insurance Portability and Accountability Act). Personal information collected in the course of our business relationship may be securely stored in HIPAA-compliant databases.
2. Applicability of this Privacy Policy
2.1 This Privacy Policy applies to personal information we process.
2.2 This Privacy Policy applies to you no matter your location (in the world).
2.3 This Privacy Policy does not apply to information that we collect in connection with your employment or application for employment at Ask Dr. Jeff.
3. Sources of Personal Information
3.1 Directly from you, such as when you register on our website, sign up to receive our newsletters, sign up to receive product information, or contact us via our website.
3.2 Indirectly from you, for example, we collect cookie data and other information from your device, browser, or activity on our website.
3.3 From third parties or public sources, for example, from our analytics providers and social media pages.
3.4 You are not under a statutory or contractual obligation to provide personal information to us, but if you do not provide certain personal information, we may be unable to offer services or conduct business with you.
3.5 Third-party links on our website may include links to third-party websites, plug-ins, and applications, and we are not responsible for the privacy practices of those websites.
3.6 When you leave our website, we encourage you to read the privacy policy of every website you visit.
4. Personal Information of Other Individuals
You may not disclose the personal information of another individual to us unless you have their prior written consent or are otherwise authorized under applicable law to share their information with us.
4.1 Providing all applicable notices.
4.2 Receiving the proper authority or consent to allow us to collect, store, process, and share such personal information.
4.3 Responding to data subject requests.
5. Aggregated Data
5.1 We may anonymize, deidentify, and/or aggregate data so that it no longer constitutes personally identifiable information.
5.2 We may share anonymized, deidentified, and/or aggregated data that does not identify you personally with third parties, including our Affiliates, Support Vendors, and Marketing Vendors.
5.3 We may also disclose aggregated and depersonalized user statistics with members of the healthcare community for public health trends.
5.4 We may disclose non-personal information to any third party for any reason in our sole discretion.
6. Personal Information of Children
6.1 We do not collect any personal information directly from children under 16 years of age. If you are a parent or guardian and provide or make available personal information of your children to us, you consent to our collection and use of your children’s personal information.
6.2 If you are a child under the age of 16, please do not attempt to use our website or services or send us any personal information. If we learn we have collected personal information directly from a child under 16 years of age, we will delete that data as quickly as possible.
6.3 If you believe that a child under 16 years of age may have provided personal information to us, please contact us at [email protected].
6.4 To our knowledge, we do not sell, or share for cross-contextual behavioral advertising or targeted advertising purposes, the personal information of children under the age of 16.
7. Your Privacy Rights and Choices
Notice of Your Personal Information Rights: With respect to personal information that we control, subject to exemptions and limitations provided by applicable law, if you are an individual you have the right to:
7.1 Know or access – request that we disclose certain information to you about our collection and use of your personal information.
7.2 Data portability – request a copy of the personal information you provided to us in a portable, and if feasible, readily usable format to be transferred to you or a third party.
7.3 Deletion – request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions under applicable privacy law.
7.4 Correction – request that we correct inaccurate or complete incomplete personal information.
7.5 Limit use of sensitive information – request that we limit the use or disclosure of your sensitive personal information to just those actions necessary to perform specific purposes outlined by law.
7.6 Third-party marketing opt-out – direct us to not share your personal information with third parties for third parties’ direct marketing purposes.
7.7 Object to processing – object to our processing of your personal information based on legitimate interests or for direct marketing purposes.
7.8 Restriction of processing – request that we restrict or suspend the processing of your personal information under specific conditions.
7.9 Withdraw your consent to the processing of your personal information if our processing is based on your consent.
7.10 Non-discrimination – be free from unlawful discrimination for exercising your rights under applicable privacy law.
8. We do not use or disclose sensitive personal information
8.1 Third-party marketing opt out – direct us to not share your personal information with third parties for third parties’ direct marketing purposes.
8.2 Object to processing – object to our processing of your personal information based on legitimate interests or for direct marketing purposes.
8.3 Restriction of processing – request that we restrict or suspend the processing of your personal information in the following scenarios:
8.3.1 if you want us to establish the data's accuracy
8.3.2 where our use of the data is unlawful but you do not want us to delete it
8.3.3 where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or
8.3.4 you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
8.3.5 Withdraw your consent to the processing of your personal information if our processing is based on your consent (without affecting the lawfulness of any processing prior to your withdrawal of consent).
8.3.6 Non-discrimination – be free from unlawful discrimination for exercising your rights under applicable privacy law.
9. How to Exercise Your Personal Information Rights
9.1 To exercise the rights described above, you or your Authorized Agent (defined below) must send us a written request (via the method described below) that provides sufficient information to allow us to verify that you are the person about whom we have collected personal information.
9.2 After submitting a Valid Request, you may be required to verify access to the email address you submitted.
9.3 If applicable, you may authorize an agent to exercise your rights on your behalf, but must provide written permission for this.
10. You will still receive transactional emails related to your account, purchase orders, inquiries or requests
You may also authorize an agent (an "Authorized Agent") to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
11. We may not honor your request where not required to do so under applicable privacy laws
For example, we may deny a deletion request if the information is necessary for us to provide our services to you or comply with our legal obligations.
12. The Right to Lodge a Complaint with a Supervisory Authority
Subject to applicable privacy law, should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you have the right to lodge a complaint at [email protected].
13. Our Use of Cookies Our Use of Cookies and Other Tracking Technology
Our website uses cookies and similar technologies such as JavaScript (collectively, “cookies”). Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our website. We use cookies to gather data about visitors to our website, analyze trends and operate and improve our website and services. For example, cookies allow our website to remember your username and password to save you having to retype it every time you visit our website. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own cookies on your devices.
14. Monitoring and Recording Keystrokes and Other Communication
We use cookies and other tracking technology to monitor and record keystrokes and other communications made through our platforms including via webform, webchat, email, phone and text message. You consent to us monitoring and recording all of your communications made through the Dr. Jeff Health Services and to us using and sharing such recordings for all purposes described in this Privacy Policy.
15. “Do Not Track” is a privacy preference that users can set in their web browsers
When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Our website is not currently configured to respond to Do Not Track signals or other mechanisms that provide users the ability to exercise choice regarding the collection of personal information about a user’s online activities over time and across third-party websites or online services.
16. Disable or Delete Cookies and Tracking Technology; Third-Party Cookies Disable or Delete Cookies from Your Browser or Device
You can decide whether or not to accept certain cookies through your internet browser’s settings. Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new cookie in a variety of ways. To explore what cookie settings are available to you, look in the “preferences” or “options” section of your browser's menu. You can also delete all cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the website and functionalities may not work.
17. Data Security and Processing
We will maintain reasonable technical and organizational safeguards for the protection of the security and confidentiality of personal information from unauthorized access, use, disclosure, or transfer. Despite our efforts to ensure security, we cannot guarantee or warrant that personal information will not be accessed, acquired, disclosed for an improper purpose, altered, or destroyed by an unauthorized person or as a result of a breach of our security safeguards or those of our hosting provider or other vendors or service providers. We cannot ensure the security of any data transmitted to us over the internet. To the fullest extent permitted by applicable law, we accept no liability for any unintentional disclosure by us of personal information. Therefore, we urge you to take adequate precautions to protect personal information as well, including, without limitation, never sharing your account username or password.
18. International Transfer, Storage, and Processing
The personal information we collect or receive is stored and processed in the United States. You consent to the transfer, processing, and storage of personal information in the United States. You also consent to the transfer, processing, and storage of personal information by us, our affiliated entities, our vendors, or third parties across borders and from your country or jurisdiction to other countries or jurisdictions around the world subject to the provisions of this Privacy Policy. If you are located in the European Economic Area or other regions with laws governing data collection and use that may differ from United States law, please note that we may transfer data, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction and may afford materially less privacy protections for your personal information than your jurisdiction. You consent to the transfer of data to the United States or any other country in which we, our affiliates, or vendors maintain facilities and the use and sharing of information about you as described in this Privacy Policy.
19. Changes and Amendments to Privacy Policy
We reserve the right to amend this Privacy Policy at our discretion and at any time. When we do, we will post the revised policy on our website with a new “Last Updated” date. We may, but are not required to, also provide you with notice of the amended Privacy Policy via any other means we consider reasonable, including, without limitation, email, posting on our services, or updates to our services. Your continued use of our website or services or your provision of personal information to us following the posting of changes (or other notice we provide in our sole discretion) constitutes your acceptance of such changes and the Privacy Policy as amended. We may, but are not required to, also provide you with alternative means of accepting any changes to or amended version of this Privacy Policy. We encourage you to visit this page regularly for any changes.
