Effective Date: July 9, 2020
Last Updated: July 9, 2020
- Terms of Service
- Information We Collect
- Information Collected Related to California Residents
- How We Use Personal Information We Collect
- Sale of Personal Information
- Your Failure to Provide Personal Information
- Our Retention of Your Personal Information
- Sharing Personal Information
- Your Right to Share Your Personal Information
- Ongev Partners
- International Transfer
- Your Privacy Choices
- Privacy Rights Specific to Californians
- Our Opt-in/Opt-Out Policy
- Your Ad Choices
- Links to Other Websites
- How We Protect Personal Information
- Children’s Privacy
- Direct Marketing and “Do Not Track” Signals
- How to Contact Us
Terms of Service
By accessing or using the Sites in any manner, you also agree to be bound by Ongev’s Terms of Service (the “Agreement”). Please read the Agreement carefully. If you do not accept all of the terms and conditions contained in or incorporated by reference into the Agreement, please do not use the Sites.
Information We Collect
We collect information, including personal information, to provide better Services to all our Users. Our Users include visitors to our website, patients and caregivers, including physicians, as well as other parties. We use the term “Personal Information” to refer to any information that identifies or can be used to identify you. Common examples of Personal Information that we collect about you include: full name, email address, date of birth, gender, zip code, information about your device, and certain metadata.
In some instances, you may provide to us sensitive categories of personal information, which may include some health or medical information concerning your medical diagnosis or treatment status, or concerning the medical diagnosis or treatment status of a patient for whom you provide care. We use the term “Sensitive Personal Information” as defined by the privacy laws in some countries and under some U.S. state laws, which means personal information from which we can determine or infer an individual’s racial or ethnic origin, political opinions, religious beliefs, trade union membership or professional association, physical or mental health condition, medical treatment, genetic data, biometric information, and information about an individual’s sexual life or sexual orientation.
The Sensitive Personal Information that you give to us may also include medical diagnosis, prescriptions, device therapy, test results, medical history, counseling, laboratory and any other information related to your health or the health of a patient for whom you provide care (“Health Information”). We only process Sensitive Personal Information, including Health Information, in your jurisdiction to the extent permitted by applicable law. You are not required to provide Ongev with any of your Sensitive Personal Information, and choosing not to do so will not prevent you from using any Services from Ongev. We do not generally collect Sensitive Personal Information or Health Information unless it is volunteered by you. For example, we may use Health Information provided by you to serve you better and meet your particular needs, such as connecting you to your health care provider and clinical trials.
The Personal Information which we collect includes, but is not limited to, the following circumstances and data elements:
Information You Give to Us
Website and Online Platform
As you evaluate whether Ongev is the right solution for you, you may choose to provide us with Personal Information about yourself, including your name and email address by completing forms on our website, or when creating and signing into your account. You may also choose to provide us with employment and education information when you apply for a job at Ongev via our Site.
In some instances, you may elect to provide us with location and address information. You may also provide us with Personal Information about yourself when you report a problem or have a question about our services.
The Sites offer interactive and social features that permit you to submit content and communicate with us. You may provide Personal Information to us when you post information in these interactive and social features. Please note that your postings in these areas of the Sites may be publicly accessible or accessible to other Users.
Certain information is required when creating an account to use our Services on the mobile application, such as your name, email address, and password.
In addition, in order to improve your experience with the Services, you may choose to provide additional information such as your Sensitive Personal Information. You can choose not to provide certain information, but then you may not be able to register for the Ongev Services or take advantage of some features of the Services.
When your device syncs with Ongev’s application, certain data recorded on your device is transferred from your device to our servers.
Information We Obtain from Your Use of Our Services
We collect certain information automatically, such as your operating system version, browser type, and internet service provider. We also collect information about your interaction with the Services, such as creating or logging into your account, or opening or interacting with the Services on Your mobile device. When you use our Site, we automatically collect and store this information in service logs. This includes: details of how you used our Site; Internet protocol address; cookies that uniquely identify your browser, the referring web page and pages visited. We may also collect and process information about your actual location. The information we collect automatically is statistical data and may or may not include Personal Data, but we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties.
If you grant us access to your location, Ongev may collect information about your location when you use our Sites and Services. Your location can be determined by: IP address, and information about things near your device, such as Wi-Fi access points and cell towers. When you use our Services via a wireless device, we may solicit your permission to collect your location data. Some features within our application may only function upon confirmation of your location, and therefore such features will not be available if you choose not to provide your location data to us. The specificity of the location data collected may depend on a number of factors, including the device you are using (e.g. laptop, smartphone or tablet) and how you are connected to the Internet (e.g., via cable broadband connection, Wi-Fi). If you enable location services for our mobile application, we may collect location data periodically as you use or leave open our mobile application. We may associate such location data with Personal Data you provide to us. Depending on the platform you use to access our Applications mobile application (e.g., Apple’s iOS, Google’s Android), you may be able to control whether location data is collected from within “Settings” or other controls on your wireless device or the Applications mobile application.
When using our Services, we or our service provider may collect your unique device ID. We may use such information for internal purposes and to provide you a better experience, such as to troubleshoot application problems you may experience. We may associate device ID with personal information you provide to us. You may learn more about opt out of any anonymous device ID collection via the privacy settings available within your mobile device.
Cookies and Similar Technologies
We and our partners use various technologies to collect and store information when you visit one of our services, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services from our partners, such as advertising services. Our third party advertising and analytics partners include Google and similar partners.
The technologies we use for this automatic data collection may include:
Web Beacons. Pages of our services or our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit us, for example, to count Users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Clickstream Data. Clickstream data is information collected by our computers when you request Web pages from the Sites. Clickstream data may include information such as the page served, the time spent viewing the page, source of the request, type of browser making the request, the preceding page viewed and similar information. Clickstream data permits us to analyze how visitors arrive at the Sites, what type of content is popular, what type of visitors in the aggregate are interested in particular kinds of content on the Sites.
Mobile Device Identifiers and SDK. A mobile SDK is the mobile application version of a web beacon (see “Web Beacons” above). The SDK is a bit of computer code that application developers can include in their applications to enable advertisements to be shown, data to be collected and related services or analytics to be performed.
We may partner with third parties, such as insurance companies or medical care providers that offer Ongev Services to their patients. In such cases, those companies may provide us with your name, email address, or other personal information, including Sensitive Personal Information, so that we can invite you to participate in our Services.
Health and Other Sensitive Personal Information
Information Collected Related to California Residents
During the last twelve (12) months, we have collected the following categories of personal information from consumers.
Type of Identifiers We Collect
First and last name, unique personal identifier, online identifier, Internet Protocol address, email address.
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
A name, physical characteristics or description, insurance policy number, education, employment, employment history, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
C. Protected classification characteristics under California or federal law.
Age (40 years or older), sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions.
D. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
E. Geolocation data.
Physical location or movements.
F. Professional or employment-related information.
Current or past job history or performance evaluations.
G. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
We obtain the categories of Personal Information listed above from the following categories of sources:
- Directly from our customers or their agents.
- Indirectly from our customers or their agents. For example, through information we collect from our clients in the course of providing Services to them.
- Directly and indirectly from activity on our Site (www.ongev.com). For example, from website usage details that are collected automatically. In addition, like many companies, we use “cookies” which are small text files a website can use to recognize repeat users, facilitate the user’s ongoing access to and use of the site and to track usage behavior of, for example, the webpages you visit.
- From social media websites, such as Facebook, Twitter, LinkedIn, YouTube, Instagram, and Pinterest.
- From third parties that interact with us in connection with the services we perform and the products which we produce.
How We Use Personal Information We Collect
We use your Personal Information in ways that are compatible with the purposes for which it was collected or authorized by you, including for the following purposes:
- To present, operate or improve the Site and Services, including analysis of Site activity;
- To inform you about Services and products available from Ongev;
- To authorize access to our Sites and Services;
- To validate your identity or verify communications from you;
- To provide, maintain, administer or expand the Services, performing business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer;
- To administer content, or other Site features;
- To offer and administer programs;
- To customize or tailor your experience of the Services;
- To manage, store and enhance User data and preferences;
- To communicate about, and administer your participation in, special programs, surveys, contests, online campaigns, online programs, sweepstakes, prize draws and other offers or promotions, and to deliver pertinent emails;
- To send you confirmations, updates, security alerts, and support and administrative messages and otherwise facilitate your use of, and our administration and operation of, the Services;
- For marketing purposes, including but not limited to, facilitating interest-based advertising, creating custom audiences to target online and mobile advertising, sending integrated marketing messages across channels and devices, personalizing email marketing that we send to you, sending you other promotional materials, and notifying you about special promotions, offers, events or opportunities that may be of interest to you;
- To improve our customer service, conduct customer satisfaction, market research, and quality assurance reviews;
- To improve our Site and Services;
- To secure our Services, including to authenticate Users;
- To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts;
- To respond to and support users regarding their use of the Sites and Services;
- To process applications for employment that you submit through the Sites;
- To administer general recordkeeping;
- To comply with all applicable legal requirements;
- To respond to and support Users regarding their use of the Sites and Services;
- To comply with all applicable legal requirements;
- To enforce our Terms of Service and other agreements;
- To perform data analysis and testing;
- For any other purpose that is disclosed to you at the point of collection of the personal information, for any purpose for which you provide your prior consent, or for any other lawful purpose.
We may use your Personal Information in furtherance of our legitimate interest to provide you with the Services offered by Ongev. We may also use your information to manage our contractual relationship with you or to comply with our legal obligations.
Sale of Personal Information
In the preceding twelve (12) months, we have not sold any Personal Information.
Your Failure to Provide Personal Information
Your provision of Personal Information is required in order to use certain Services and programs. In some instances, if you fail to provide such Personal Information, you may not be able to access and use our Services, or parts of our Services.
Our Retention of Your Personal Information
We use and retain your Personal Information for as long as necessary to fulfill the purpose for which it is being processed, to carry out legitimate business interests, as well as on the basis of applicable legal requirements (such as applicable statutes of limitation).
After expiry of the applicable retention periods, your Personal Information will be deleted. If there is any data that we are unable, for technical reasons, to delete entirely from our systems, we will put in place appropriate measures to prevent any further use of such data.
Sharing Personal Information
Ongev may disclose your Personal Information to commercial providers for a business purpose, which include verifying your identity. When we disclose Personal Information for these reasons, we enter into a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except for the purposes set forth in the contract.
In the preceding twelve (12) months, we have disclosed the following categories of Personal Information for one or more business purposes:
- California Customer Records Personal Information categories;
- Protected Classification Characteristics under California or federal law;
- Internet or other network activity information;
- Geolocation Data;
- Professional or employment-related information;
- Inferences drawn from other personal information.
We disclose your Personal Information for a business purpose to the following categories of third parties:
- Our affiliates;
- Commercial providers;
- Enterprise accounts, such as your employer;
- Service providers and other third parties we use to support our business, including without limitation those performing core services (such as billing, credit card processing, customer support services, customer relationship management, accounting, auditing, administering sweepstakes, surveys, advertising and marketing, analytics, email and mailing services, data storage, and security) related to the operation of our business and/or the Services, and making certain functionalities available to our Users;
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with the Services we provide to you.
We may disclose your Personal Information for legal reasons. Specifically, we will share Personal Information with companies, organizations or individuals outside of Ongev if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- Fulfill any purpose for which you provide it;
- Meet any applicable law, regulation, legal process or enforceable governmental request;
- Enforce applicable Terms of Service, including investigation of potential violations;
- Detect, prevent, or otherwise address fraud, security or technical issues;
- Protect against harm to the rights, property, assets or safety of Ongev, our Users or the public;
- For any other purpose disclosed when you provide the information; and,
- When we obtain your consent to do so.
We attempt to notify you about legal demands for your Personal Information when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague or lack proper authority, but we do not promise to challenge every demand.
Ongev may compile and share your information in aggregated form (i.e., in a manner that would not personally identify you) or in de-identified form so that it cannot reasonably be used to identify an individual (“De-Identified Information”). We may disclose such de-identified information publicly and to third parties, or to Ongev Partners under agreement with us.
The Ongev Services permit Users to collect their Personal Information, Sensitive Personal Information, and Health Information. As a User of the Ongev Services, you have a right to license your Personal Information and Sensitive Personal Information, including Health Information, to Ongev Partners and other third parties.
Ongev will not share any Health Information it collects about you without your consent.
Maintaining the privacy and security of Your Information is important to us. Ongev has implemented appropriate safeguards to prevent unlawful use or disclosure of information. These include administrative, physical, and technical security safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of information we receive, maintain, or transmit. Nevertheless, while security of information is of tremendous importance to us, no data transmission (over the internet or any wireless network) or method of electronic storage can be guaranteed to be 100% secure. In the event of a security breach, we will notify affected individuals, regulatory authorities, and others consistent with requirements under federal and state law or contractual obligations.
- Ongev Partner Information. We collect information about individuals within our Ongev Partners’ organization (“Partner Information”). Partner Information may include information related to the Partner’s account, name, work e-mail address, work phone number, job title or similar kinds of information. We use Partner Information to support the Partner account, maintain our business relationship with the Partner, respond to Partner inquiries, or perform accounting functions. Ongev Partners may update personal information and password by logging into the Ongev Platform and updating their account. Ongev Partners may contact Ongev support in order to delete their Personal Information. In some cases, we may not be able to delete Partner Information, and in such cases we will tell you why.
- Information about our Partners’ Contacts. We collect information about any contacts, such as employees, customers, and others, that may be uploaded into the Ongev Platform (“Information about our Partners’ Contacts”). Information about our Partners’ Contacts may include name, e-mail address, phone number, job title, or similar kinds of information. We use Information about our Partners’ Contacts for the purposes of providing Services to such contacts. Ongev Partners may update or delete Information about their contacts in the Ongev Platform. Ongev Partners may also contact Ongev support in order to update and delete such information. In some cases, we may not be able to delete such information, and in such cases we will tell you why.
- Archival Information. We collect communications information for archival purposes on behalf of, and as directed by, our Ongev Partners. This information may include emails, texts, websites, and other forms of data or electronic communications (“Archival Information”). Archival Information includes data about our Ongev Partners and the third parties they correspond with. We do not control or monitor the information our Ongev Partners collect and store through our services, or their privacy practices or policies. It is our Partner’s obligation to obtain all necessary consents and to comply with all applicable laws with respect to the Partner’s communications and use of our services. Our Partner’s privacy policies or practices apply to Archival Information, the purposes for which the Partner collects Archival Information, how the Partner may use Archival Information and what choices the individual may have with respect to Archival Information. Individuals must contact the applicable Partner in order to correct, amend, or delete their information, or to opt out of any collection, uses or disclosure of their information by our Partner.
- Automatically Collected Information. We collect information automatically about how our Ongev Partners use our services (“Automatically Collected Information”). We do this via data collection technologies such as cookies, web beacons, gifs or other tracking technologies. We collect this information in order to monitor, support and improve our services or to provide Ongev Partners with certain customized features. We may use Automatically Collected Information to tell us how our Ongev Partners use our services, to improve our services or develop new products, services or features. We may combine this information with other information we collect.
We treat Partner Information, Information about our Partners’ Contacts, Archival Information and Automatically Collected Information as the confidential and proprietary information of our Ongev Partners, subject to the terms of the Ongev Terms of Service and any other service agreement between Ongev and the Partner. We do not share Partner Information, Information about our Partners’ Contacts, Archival Information or Automatically Collected Information with third parties unless directed to do so by our Partner, as may be necessary to provide services to the Partner, to our advisors, affiliates, representatives, agents, service providers, in connection with a business transaction (such as a merger or sale), as allowed under the terms of our agreement with our Partner, or in response to a court order, subpoena, warrant or to comply with a legal requirement or to cooperate with an investigation. We may disclose Partner Information, Information about our Partners’ Contacts, Archival Information or Automatically Collected Information for the aforementioned reasons, or in order to protect our rights or the rights of our affiliates, Ongev Partners, channel partners or service providers.
We will retain Partner Information we process on behalf of our Ongev Partners for as long as needed to provide services to our Partner, or for the period of time requested by a particular Partner.
Your Privacy Choices
You may have certain rights relating to your Personal Information, subject to local data protection law. Whenever you choose to visit our Site and use our Services, we aim to provide you with choices about how we use your Personal Information. Subject to applicable law, you may obtain a copy of Personal Information we maintain about you. To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to the information.
- Privacy Rights Specific to California Residents
Under the California Consumer Privacy Act, California residents may have specific rights regarding their Personal Information. This section describes Californians’ rights and explains how California residents can exercise those rights.
Below we further outline specific rights which California residents may have under the California Consumer Privacy Act.
- Right to Access Your Data. You have the right to request that we disclose certain information to you about our collection, use and disclosure of your Personal Information over the past twelve (12) months. Any disclosures we provide will only cover the 12-month period preceding the receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.
- Right to Data Portability. You have the right to a “portable” copy of your Personal Information that you have submitted to us. Generally, this means you have a right to request that we move, copy or transmit your Personal Information stored on our servers or information technology environment to another service provider’s servers or information technology environment.
- Right to Delete Your Data. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies.
- Right to Non-Discrimination for the Exercise of Your Privacy Rights. You have the right not to receive discriminatory treatment by us for exercising your privacy rights conferred by the California Consumer Privacy Act.
Exercising Your Rights
If you are a California resident who chooses to exercise your rights, you can:
- Submit a request via email to email@example.com
You may also designate an agent to exercise your privacy rights on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification.
Our Response to Your Request
Upon receiving your request, we will confirm receipt of your request by sending you an email. To help protect your privacy and maintain security, we may take steps to verify your identity before granting you access to the information. In some instances, such as a request to delete personal information, we may first separately confirm that you would like for us to in fact delete your Personal Information before acting on your request.
We will respond to your request within forty-five (45) days. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
In some cases our ability to uphold these rights for you may depend upon our obligations to process Personal Information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, listed below, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
We may deny your deletion request if retaining the information is necessary for us or our service providers to:
- Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;
- Debug products to identify and repair errors that impair existing intended functionality;
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 seq.)
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent;
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;
- Comply with a legal obligation; or
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Our Opt-in/Opt-out Policy
We currently provide the following opt-out opportunities:
- At any time, you can follow a link provided in offers, newsletters or other email messages (except for e-commerce confirmation or service notice emails) received from us or an Ongev Partner to unsubscribe from the service.
Your Ad Choices
As described above, we or third party partners may place or recognize a unique cookie on your browser when you visit our Sites for the purpose of serving you targeted advertising (also referred to as “online behavioral advertising” or “interest-based advertising”). You may find more information about entities involved in online advertising and additional choices you may make, including opt-out of having your information used for internet-based advertising, through the Network Advertising Initiative (“NAI”) at the NAI Service, and the Digital Advertising Alliance (the “DAA”) at the DAA consumer choice service.
The tools provided at the DAA opt-out page and the NAI opt-out page are provided by third parties, not Ongev. Ongev does not control or operate these tools or the choices that advertisers and others provide through these tools.
Links to Other Websites
The Sites may contain links to webpages operated by parties other than Ongev. We do not control such websites and are not responsible for their contents or the privacy policies or other practices of such websites. Our inclusion of links to such websites does not imply any endorsement of the material on such websites or any association with their operators. Further, it is up to the User to take precautions to ensure that whatever links the User selects or software the User downloads (whether from this Site or other websites) is free of such items as viruses, worms, trojan horses, defects and other items of a destructive nature. These websites and services may have their own privacy policies, which the User will be subject to upon linking to the third party’s website. Ongev strongly recommends that each User review the third party’s terms and policies.
If you have any questions about the privacy practices of other websites, you should contact the relevant parties controlling these websites for more information.
How We Protect Personal Information
Ongev maintains administrative, technical and physical safeguards designed to protect the user's Personal Information and other information against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. For example, we and/or our service providers use commercially reasonable security measures such as encryption, firewalls, and Secure Socket Layer software (SSL) or hypertext transfer protocol secure (HTTPS) to protect Personal Information.
Although we take reasonable steps designed to protect your Personal Information, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software and hacker attacks). We cannot and do not guarantee or warrant the security of your Personal Information or any information you disclose or transmit to us. We are not responsible for the acts of those who gain unauthorized access, and we make no warranty, express, implied or otherwise, that we will prevent such access, and we are not responsible for any damages or liabilities relating to any such incidents to the fullest extent permitted by law. Where required under law, we will notify you of any such loss, misuse or alteration of Personal Information that may affect you so that you can take the appropriate actions.
Our website is not intended for children under 16 years of age. We do not intentionally gather Personal Information or Sensitive Personal about visitors who are under the age of 16. If a child has provided us with Personal Information or Sensitive Personal, a parent or guardian of that child may contact us to have the information deleted from our records. If you believe that we might have any information from a child under age 16 in the applicable jurisdiction, please contact us firstname.lastname@example.org. If we learn that we have inadvertently collected the Personal Information of a child under 16, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible in accordance with applicable law.
Direct Marketing and “Do Not Track” Signals
Ongev does not track its users over time and across third party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. However, some third party sites do keep track of your browsing activities when they serve you content, which enables them to tailor what they present to you. If you are visiting such sites, your browser may include controls to block and delete cookies, web beacons and similar technologies, to allow you to opt out of data collection through those technologies.
How to Contact Us
Via e-mail: email@example.com
By writing to us:
4900 Avalon Ridge Parkway
Peachtree Corners, Georgia 30071