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Privacy Policy

Last Updated: May 2, 2024

Introduction

 

This Privacy Policy (“Policy”) explains how Humelan PBC (“Humelan“,” we”, “us,” “our”) collects, uses, and discloses information from and about you, and your choices regarding such information. This Policy applies to our hearing coach chatbot and other informational services and communities (collectively, our “Services”) available on our website, over texting channels, and on our mobile application (“App”).

 

By using or otherwise accessing the Services, you acknowledge the applicability of this Policy. Please read this Policy carefully to understand our practices regarding your information. If you do not agree with our policies and practices, you should not use our Services. By accessing or using the Services, you agree to be bound by the terms of this Policy. 

 

Scope

 

This Policy covers information collected through our Services. It does not govern third-party services linked to our App or website. The privacy policies of third-party services govern for those services.

 

Updates to Privacy Policy

 

We reserve the right to change this Policy. By continued use of the Services, you agree to be bound by the revised Policy.

 

Jurisdictional Issues

 

Our data is collected and stored in the United States and Humelan delivers the Services from the United States. This Policy and our collection, use, and disclosure of your information are governed by U.S. law. 

 

Information We Collect and How We Collect It:

 

We collect information from and about you when you provide it to us, automatically when you use our Services, and from other sources.

 

Information You Provide Us:

 

We collect information directly from you when you use the Services, such as when you create an account, provide feedback, and engage with the hearing coaches through the Services. The following describes information we collect from you that identifies you as an individual ("Personal Information"), including:

 

  • Contact information, such as name, postal address, telephone number, and email address;

  • Account and profile information, such as your login information, preferences, and areas of interest, and any information you choose to include in your profile, such as biographical details, occupation, country, photograph, and your profiles on social networks;

  • Demographic information, such as your gender, birth date, ethnicity, and marital status; 

  • Information from your device or other apps that you provide to us when using the Services or when you grant permission for the App to access information, such as your photos or content from your hearing device applications;

  • Location information, if you share this with us;

  • Marketing preference data, such as your preferences for receiving our communications;

  • Other information that we may collect that is not specifically listed here, which we will use as described in this Policy or as otherwise disclosed at the time of collection.

 

Protected Health Information

 

  • In addition to the Personal Information above that we collect from you, we might also collect general health information and/or protected health information (“PHI”), which includes any information relating to your health status, history, diagnoses, treatment, and care.


 

You are not required to provide us with any information about yourself. However, if you do not provide us with certain information, the Services will not function as intended or you will be unable to access certain features. For example, if you do not provide us with your name and email address, you cannot create an account. Some of the information we collect, such as PHI, is sensitive under certain laws and will therefore be subject to stricter protections.

 

Information We Automatically Collect:

 

We collect some kinds of information automatically when you interact with the Services, including, but not limited to:

 

  • Device information, such as the type of device you are using;

  • Usage information about how you interact with the Services, such as the date and time you interacted with the Services; and

  • Location information


 

Information We Collect from Other Sources:

 

We may collect Personal Information about you from third parties, including:
 

  • Medical clinics, such as those referring you to our Services or sending information about your hearing devices. Clinics may send us information automatically collected by your hearing devices;

  • Data providers, such as information Services and data licensors;

  • Other parties: We may collect additional information about you to supplement information we collect in other ways (such as demographic, contact, and statistical information) from parties such as business partners, marketers, and advertising networks.

 

If you were referred to our Services by a medical or audiology clinic, your PHI might have been shared to us through the clinic. We implement strict protections to safeguard PHI, subject to HIPAA and other regulatory laws. These measures are discussed further below.

 

How We Use Your Information:

 

We use the information we collect for a variety of purposes, which may vary depending on the type of information and how you interact with the Services. These purposes may include to:

 

  • Provide, operate, improve, and maintain the Services and our business, including to register your account and run our business and to analyze the data collected;

  • Personalize the Services, including by remembering your preferences;

  • Establish and maintain your user profile on the Services;

  • Improve and enhance the Services;

  • Provide support for the Services, and respond to your requests, questions and feedback;

  • Maintain security and prevent fraud;

  • Verify your identity or authenticate you;

  • Comply with applicable laws, regulations, and other legal process and procedures;

  • Exercise our legal rights (including by enforcing our terms and policies), detect and prevent illegal activity on the Services, or protect the rights, property, or safety of Humelan, our users, our employees, or others;

  • Audit our internal processes for compliance with legal and contractual requirements and internal policies.

 

We may combine the information we collect through the Services with information we collect automatically or receive from other sources and use such combined information in accordance with this Policy. We may also aggregate and/or de-identify information we collect in such a way that it cannot reasonably be linked to you or your device. We may use such aggregated and/or de-identified information for purposes including research, marketing, and product development.


 

How We Disclose Your Information

 

We may disclose the Personal Information we collect about you in the following ways:

 

  • Personnel. Our employees, contractors, and other personnel have access to your information as needed to provide the Services. 

  • Affiliates. We may disclose your information to our corporate affiliates and joint ventures. 

  • Vendors. We may disclose or provide access to your information to vendors that provide services on our behalf, including website hosting, data storage, analytics, research, security, content, and other services. 

  • Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

  • Legal compliance. We may disclose your information if required to do so by law or legal process, or in the good faith belief that disclosure is reasonably necessary to (1) comply with a legal obligation, (2) protect and defend the rights, property, or personal safety of ourselves, our personnel, users of the Services or the public, (3) obtain legal advice, or (4) protect against legal liability. This includes disclosures for fraud prevention.

  • Community Groups. When you choose to participate in community groups, Personal Information from your profile will be displayed to others in the group. We may also use your comments for advertising purposes, either identified with you or deidentified.  

  • Business transfers. In the event of a sale of some or all of our assets, merger, reorganization, dissolution or similar event, including during negotiations of such an event, your data may be part of the transferred assets.

  • Authorities and others. Law enforcement, government authorities, crisis lines and private parties, as we believe in good faith to be necessary or appropriate for the purposes described above. 

  • With your consent. If you consent for us to disclose your information, we may do so consistent with your consent. 


 

Disclosure of PHI

 

In some cases, PHI is shared to us through your disclosure or the disclosure of third parties. PHI is subject to the laws and regulations governing the use and disclosure of health information they create or receive. These regulations include the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), the Health Information Technology for Economic and Clinical Health of 2009 (“HITECH”), and the regulations adopted thereunder. 

 

When we store, process or transmit PHI, defined within the scope of HIPAA, on behalf of a healthcare provider, we do so as its “business associate” (also as defined by HIPAA) under a Business Associate Agreement (“BAA”). Under the BAA, we are prohibited from, among other things, using Protected Health Information in a manner that the provider itself may not. We are required to apply reasonable and appropriate measures to safeguard the confidentiality, integrity and availability of PHI we store and process on behalf of such providers. We are also subject to HIPAA’s rules governing the use and disclosure of certain information when we share PHI with our subcontractors, with whom we enter a separate BAA.  

 

Security of Information

 

Personal Information:

 

We make reasonable efforts to protect your information from unauthorized access, use, or disclosure by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.

 

PHI:

 

We will establish appropriate administrative, technical, and physical safeguards to prevent PHI from intentionally or unintentionally being used or disclosed in violation of HIPAA’s requirements

 

We retain your information for as long as is necessary for the purposes for which it is collected and processed. These periods vary depending on the nature of the information, your interactions with us, and the purposes for collection and processing.
 

 

Protection of Minors

Our Services are not intended for, nor directed to, minors under 18 years of age. If we learn that someone under 18 has provided us with their Personal Information, we will use reasonable efforts to remove that information from our databases as required by applicable law. If you are under 18 years of age, do not use the Services.

Your Rights and Choices

 

You can log in to your user profile and correct, amend, or delete information about yourself. You can decline to provide certain Personal Information. If you revoke our ability to access information from a third-party platform, that choice will not apply to information that we have already received from that third party. If you do not agree with our policies and practices, please do not use our Services.

 

Your Choices About Marketing Communications and Push Notifications

 

Subject to any applicable legal requirements, if you provide us with your email address, mobile phone number, or physical mailing address, we may send you marketing and promotional communications. You can configure our App to silence push notifications.


Contact Us

 

If you have questions about this Policy or our privacy practices, please email us at help@humelan.com or contact us using one of these methods: 
 

Humelan, PBC. 

391 Wilmington Pike, Ste 3# 262
Glen Mills, PA 19342

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