Privacy Policy

Santovia (“we”) and its affiliates are committed to protecting and preserving your privacy. This policy, together with our Terms of Use and Conditions, the SantoviaUser Authorization and Participation Agreement, and any other underlying agreements or terms, sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us. By using our website or online portal (“Site”), or mobile applications (“Applications”), you are accepting the practices described in this Privacy Policy. This Privacy Policy also describes the manner in which we process, use and disclose information you provide to us when you agree to our SantoviaUser Authorization and Participation Agreement for your use of our portal through our Site and/or Applications.

By using this Site or Applications, you consent to the use of information that you provide us in accordance with this Privacy Policy. We do update this Privacy Policy from time to time so please review this Privacy Policy regularly. If we materially alter our Privacy Policy, we will notify you of such changes by posting a notice on our Site or within our Applications. Your continued use of the Site or Applications will be deemed your agreement that your information may be used in accordance with the new policy. If you do not agree with the changes, then you should stop using the Site or Applications and you should notify us that you do not want your information used in accordance with the changes.

We have structured your download of our Applications through third parties. You should review and understand the third party’s Privacy Policy before you download our Applications through them.

 

Website and Application Privacy Notices

Please read this Policy carefully to fully understand how we collect, share and protect information about you. This Policy is incorporated into and is a part of the Terms of Use and Conditions and Santovia User Authorization and Participation Agreement for this Site and our Applications. To review the Santovia User Authorization and Participation Agreement, click here.

By accessing and using the Site or Applications, you agree that you have read and understand this Privacy Policy and that you accept and consent to the privacy practices and uses or disclosures of information about you that are described herein.

In order to deliver personalized and relevant information to you through our Site and our Applications, we collect certain information from users.

 

Information We Collect

In operating our Site and Applications, we may collect and process the following data about you:

1. Details of your visits to our Site and the resources that you access, including, but not limited to, traffic data, location data, weblogs and other communication data, including your IP address, the date and time you accessed or left the Site and which pages you viewed. Some parts of our Site and Applications use cookies and other technologies to collect this information about your general internet usage. See section below ‘How We Use Cookies” to learn more.
2. Information that you provide directly to us by filling in forms on our Site, in our Applications, and/or through your SantoviaUser account.
3. Information provided to us when you communicate with us for any reason (for example, to contact us, you must provide your name and e-mail address).
4. Information provided to us if you choose to submit personal information and/or personal health information. Understand that the personal health information and medical information that you enter on this Site, through any of our forms, or in our Applications, is regarded as confidential. It is subject to the usual protections afforded medical records in accordance with the Health Insurance Portability and Accountability Act (“HIPAA”). Please review the SantoviaUser Authorization and Participation Agreement for further information.
5. Information that you provide to us if you choose to complete one of our surveys.

How we use Cookies

A “cookie” is a piece of text which asks permission to be placed on your computer’s hard drive. Once you agree, this cookie file is stored on the hard drive of your computer. They help us and our affiliates to improve our Site and Applications. They ensure that the content from our Site and Applications is presented in the most effective manner for you and your computer.

All computers have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies; you may be unable to access particular parts of our Site or Applications.

The third-party service providers that we use include, but are not limited to, Google Analytics (see more information below), Facebook, LinkedIn, YouTube, Google, and Instagram. These third-party service providers may use cookies to collect standard internet log information and website user behavior information. The information generated by the cookie about your use of our site (including your IP address and geo-location) is transmitted to these service providers. This information is then used by the service providers to evaluate our users’ use of our site and to compile statistical reports on site activity for Santovia. The third parties who provide access to download our Applications may also use cookies, over which we have no control. Such cookies (if used) would be downloaded once you click links from our Site or use our Applications through other third-party interfaces.

We do not track our users across time or across websites.

Use of your Information

1. The information that we collect and store relating to you is primarily used to enable us to provide our services to you in the best possible manner. In addition, we may use the information for the following purposes:
2. To provide you with information relating to our services or products;
3. To provide third parties with statistical information about the users of our website;
4. To monitor and conduct an analysis of our Site and Application traffic and usage patterns;
5. To inform your health care providers and health service professionals about your medical condition(s) and/or answers to any surveys on our application that you complete.
6. To analyze trends.

Disclosing Your Information

To secure your information, we have put in place commercially suitable physical, electronic, and managerial procedures to safeguard and secure the information we collect on our Site or through our Applications.

Nonetheless, the transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically on our Site or through our Applications, and transmission of such data is therefore entirely at your own risk.

Where applicable, we may disclose your personal information to any affiliated business entities or third parties necessary to provide services to you. This includes, where applicable, third parties involved in the administration and operation of our site and/or provision of services. We may also disclose your personal information to other third parties, such as:

1. Where we sell any or all of our business and/or our assets to a third party, whether through bankruptcy proceedings or other sale or merger.
2. Where we are legally required to disclose your information, including, but not limited to, pursuant to a valid subpoena, order, search warrant or other law enforcement request.
3. When we are contractually obligated to disclose it.

Where we disclose personal information for a purpose set forth herein, we enter a contract with the third party that describes the purpose and requires the third-party recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We do not sell your personal information to third parties.

Third Party Website and Interaction and Google Analytics

By accessing other third-party websites or applications through our Site or Applications, you are consenting to the terms and privacy policies of those websites. We do not accept any responsibility or liability for their policies whatsoever as we have no control over them.

We use a tool called “Google Analytics” to collect information about use of our website. Google Analytics collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. We use the information we get from Google Analytics only to improve this site. Google Analytics collects only the IP address assigned to you on the date you visit this site, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Although Google Analytics plants a permanent cookie on your web browser to identify you as a unique user the next time you visit this site, the cookie cannot be used by anyone but Google. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Use (as amended for government websites) and the Google Privacy Policy. You can prevent Google Analytics from recognizing you on return visits to this site by disabling cookies on your browser. Find Google’s privacy policy here.

 

Children’s Privacy

Our Site is designed and intended for those who have reached the age of majority (18 years of age). We do not knowingly collect or market to any individuals under the age of 18 through our Site. By using our Site, you affirm that you are at least 18 years of age or older. We are not liable for any damages that may result from a user’s misrepresentation of age on our Site. No one under age 13 is authorized to submit or post any information, including personally identifying information, on our Site. Under no circumstances may anyone under age 13 use our Site. Parents or legal guardians of children under 13 cannot agree to these Site terms on their behalf.

We do not directly collect any personal information from minors under the age of 13 through our Application; health care providers collect and maintain any and all information submitted through this portal. Any and all information accessed and/or received by Santovia through the portal is disclosed by health care providers directly to Santovia. However, Santovia does not access, use or disclose any information received from a health care provider unless permitted by applicable law(s), including state and/or federal laws, including, but not limited to, the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”).

 

For California Residents

If you reside in California and have provided personally identifiable information to us, you may request information about our disclosure of certain categories of personal information to third parties for their direct marketing purposes under California’s Shine the Light law. Such requests must be submitted to us at one of the following addresses: Santovia, 151 Tremont St, Suite 110, PO Box 323, Boston, MA, 02111 or call 800 646 9305.

If you are a resident of California, effective January 1, 2020, you have the following rights under the California Consumer Privacy Act of 2018 (“CCPA”):

• to know what categories of personal information about you we have collected and used, including how the personal information was collected;
• to know what categories of personal information is being sold or disclosed and to know that your personal information has not been sold.
• to access your personal information, including the right to download or transfer personal information collected during the previous 12 months click here for more information on “Access to Specific Information and Data Portability Rights;
• to request that your personal information be deleted click here for more information on “Deletion Request Rights”; and
• to equal service and equal price for goods or services even if you exercise your rights under the CCPA.

While California residents have the right to opt-out of the sale of their personal information under CCPA, we do not sell personal information to any third parties, and therefore, we have not included a “Do Not Sell My Personal Information” link on our Site. If our practices change, we will update this Privacy Policy and take any other necessary action to comply with applicable law.

If you are a California resident and you want to exercise any of your rights as set forth above, please contact us at 800 646 9305 or info@santovia.com. For all requests, it is helpful to put the statement “California Privacy Rights” in the body of your request, describe the nature of your request, and provide your name, street address, city, state, and zip code. In your request, you need to attest to the fact that you are a California resident and provide a current California address for our response. For more information click here.

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.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Accessibility Statement

We are committed to making sure that our Site is accessible to everyone. To access this Privacy Policy in an alternative form, please contact us at 800 646 9305 or info@santovia.com.

Contact Us

We welcome any queries, comments, complaints or requests you may have regarding this Privacy Policy. Please do not hesitate to contact us. If you have any questions, comments or complaints, please contact us at:

Santovia, 151 Tremont St, Suite 110, PO Box 323, Boston, MA, 02111 or call 800 646 9305.

Effective Date: June 30, 2020