Privacy Policy
Circady (“we” or “us”) is committed to protecting and respecting your privacy. This Privacy Policy (together with our Terms of Use) includes the terms and restrictions pertaining to personally identifiable information (“Personal Data”) we may collect from you on our website, or that you provide to us through this website, and which is used, handled and maintained by us. Please read the following Privacy Policy carefully to understand our practices regarding your personal and non-personal data and how we will treat it. By accessing the Circady website at www.circady.com, including all related pages, or using our Services through the application or otherwise, you are accepting the practices as outlined in this Privacy Policy Statement. If you decide to visit the Circady Site or use our Services, your visit and use and any possible dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages, adjudication of disputes, and application of US and local law.
If you do not agree to the terms of our Privacy Policy, please discontinue your use, and advise us of your specific objections, questions and concerns.
-
Information You Provide to Us
- We may collect and process the following data about you:
- Information that you provide by filling in forms on our site. This includes information provided at the time of registering to use our site, booking a Service or requesting further Services.
- If you contact Circady, we may keep a record of that correspondence.
- We may also ask you to complete surveys that we use for research and analysis purposes, although you do not have to respond to them.
- Data that you provide through the use of our Service, either through the mobile application, online, through connected devices or otherwise.
- Details of your visits to our website, including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- We may collect and process the following data about you:
-
Personal Data
- Personal Data is any information about an individual that can be used to distinguish or trace an individual‘s identity, such as name, social security number, date and place of birth, mother‘s maiden name, or biometric records; and any other information that is linked or linkable to an individual, such as medical, educational, financial, and employment information.
- The Personal Data we collect allows us to keep provide and tailor our Services to you.
- We use your Personal Data to create, develop, operate, deliver, and improve our Services, content and advertising, and for loss prevention and anti-fraud purposes.
- We may use your Personal Data, including date of birth, to verify identity, assist with identification of users, and to determine appropriate Services.
- We may also use Personal Data for internal purposes such as data analysis and research to improve our Services and communication.
- If we combine non-personal information with personal information, the combined information will be treated as Personal Data for as long as it remains combined.
-
Collection and Use of Non-Personal Data
- In addition to Personal Data, we also collect data that does not, on its own, permit direct association with any specific individual. We reserve to right to collect, use, transfer, and disclose non-personal information for any purpose. Examples of collection and use of non-personal information are:
- Occupation, language, zip code, location, and the time zone which will help us better understand user behavior and improve our products, services, and advertising.
- We may collect information regarding customer activities on our website, online or mobile application. This information is aggregated and used to help us provide more useful information to our visitors & users and also to understand which parts of our website, products, and services are of most interest.
- Sleep and activity data will help us personalize the service to you as well as understand and improve services to address people’s sleep issues.
- Aggregated data is considered non‑personal information for the purposes of this Privacy Policy. We do not disclose information about identifiable individuals, but we may provide our partners and third parties with aggregate information about our users (both website users and users of the Circady Service) to analyze for various purposes, including improving service content and delivery, or outcomes analysis. Where we provide aggregated information, information about identifiable individuals will not be identifiable within the aggregated data.
- Circady collaborates with a number of research organizations. We reserve the right to share de-identified data with such research organizations with the objective to advance health research in general, with mental health and sleep disorders in particular.
- If we intend to use your Personal Data in an non-aggregated way, e.g. for research, we will seek your express consent.
- In addition to Personal Data, we also collect data that does not, on its own, permit direct association with any specific individual. We reserve to right to collect, use, transfer, and disclose non-personal information for any purpose. Examples of collection and use of non-personal information are:
-
HealthKit, Google Fit and Third- Party Applications
- If you consent, Circady will integrate with Apple Health,Google Fit and other devices such as Fitbit, and read data from those applications. You can determine which items you approve Circady to read in your app’s settings, if any. We will only use the data we obtain in a manner that is consistent with this Privacy Policy.
- If you opt to connect other applications or devices that you have with other parties (“Third-Party Applications”), you consent that we may collect data from such Third-Party Applications.
-
Cookies and Other Technologies
- Many companies offer programs that help you to visit websites anonymously. While we will not be able to provide you with a personalized experience if we cannot recognize you, we want you to be aware that these programs are available.
- We collect information about your computer, including where available, your IP address, operating system, and browser type for system administration and to report aggregate information. This is statistical data about users' browsing actions and patterns and does not identify any individual.
- Our website uses tracking cookies to distinguish you from other users of our website. This helps us to provide you with a more personalized and welcoming experience when you browse our website and also allows us to continually improve our site. Circady employs cookies in order for its server to recognize a return visitor as a unique user. The cookies placed by the Circady server are readable only by us, and cookies cannot access, read or modify any other data on a computer. The "help" portion of the toolbar on most browsers will instruct you on how to prevent your browser from accepting new cookies, how to command the browser to tell you when you receive a new cookie, or how to fully disable cookies. We strongly recommend that you leave the cookies activated, however, as cookies enable you to take advantage of most of Circady's most important features and functionality.
- We may use operationally required cookies. These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website or make use of e-billing services.
- Please note that third parties (including, for example, advertising networks and providers of external services like web traffic analysis services) may also use cookies, over which we have no control. These cookies are likely to be analytical/performance cookies or targeting cookies.
- You may block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of our site.
-
Information About Children
- The website and services are not intended for or targeted at children under 18, and we do not knowingly or intentionally collect information about children under 18. If you believe that we have collected information about a child under 18, please contact us at privacyandsecurity@healios.io so that we can take appropriate action.
-
Retention of Personal Data
- How long we keep information we collect about you depends on the type of information. as described in further detail below. After such time, we will either delete or anonymize your information or, if this is not possible, then we will securely store your information and isolate it from any further use until deletion is possible.
- We retain Personal Data that you provide to us where we have an ongoing legitimate business need to do so (for example, as long as is required to provide a service or as needed to comply with our legal and regulatory obligations, resolve disputes and enforce our agreements).
- When we have no ongoing legitimate business need to process your Personal Data, we securely delete the information or anonymize it or, if this is not possible, then we will securely store your Personal Data and isolate it from any further processing until deletion is possible. We will delete this information from the servers at an earlier date if you so request.
- If you have elected to receive marketing communications from us, we retain information about your marketing preferences for a reasonable period of time from the date you last expressed interest in our content, products, or services, such as when you last opened an email from us or otherwise responded to our communication. We retain information derived from cookies and other tracking technologies for a reasonable period of time from the date such information was created.
-
Disclosure of your information
- We may disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we may disclose your non-identifiable Personal Data to the prospective seller or buyer of such business or assets.
- If Circady or substantially all of its assets are acquired by a third party, in which case non-identifiable Personal Data held by it about its customers will be one of the transferred assets.
- If we are under a duty to disclose or share your Personal Data in order to comply with any legal obligation, or in order to enforce or apply our Terms of Website Use or our Terms of Telephone Service Use; or to protect the rights, property, or safety of Circady. This includes exchanging information with other companies and organisations for the purposes of fraud protection and credit risk reduction.
- We may disclose your personal information to third parties:
-
Where We Store your Personal Data
- The data that we collect from you may be transferred to and stored at computers outside of your state or country. It may also be processed by staff operating outside the United States who work for us or for one of our suppliers. By submitting your Personal Data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.
- Unfortunately, the transmission of information via the Internet cannot be expected to be completely secure. Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our site, and any transmission is ultimately at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
-
Confidentiality
- Circady has implemented procedures to reasonably protect data security and the use and disclosure of Identifiable Information. "Identifiable Information" means information about a participant in one of Circady's research programs or Service offerings, which reveals the identity of the participant or reasonably could be used to identify the participant. Circady protects the identity of participants in these programs; Circady does not disclose Identifiable Information unless the participant has permitted such disclosure or it is allowed or required by law.
- Circady has implemented procedures designed to protect the privacy and security of Identifiable Information. Circady uses and discloses Identifiable Information only as appropriate under and described in this Policy Statement.
- Circady stores or maintains Identifiable Information obtained in the course of administering its services and in its research programs in secure locations and limits access to Identifiable Information to workforce members and third parties that need to have such access in order to achieve only these specific purposes. Circady's workforce members use and disclose Identifiable Information only as described in this Policy or as permitted or required by law.
- When Circady receives Identifiable Information from sources other than the participant or user, Circady enters into confidentiality agreements with the entity(ies) that provide such information to Circady. Those confidentiality agreements require protections at least as stringent as those described in this Policy. Circady enters into confidentiality agreements with subcontractors and other third parties to which Circady provides Identifiable Information. Those confidentiality agreements require the third parties to implement protections for the privacy and security of such information at least as stringent as those described in this Policy.
- Prior to providing research results to clients, Circady removes Identifiable Information. At the conclusion of each research program, Circady uses reasonable efforts to destroy or de-identify (make anonymous) all Identifiable Information, unless the participant has agreed to be re-contacted about future research programs or Circady is otherwise required by contract or permitted or required by law to maintain such information.
- Circady does not and would not knowingly use or disclose Identifiable Information in violation of any privacy or security law or agreement. If we are ordered to use or disclose Identifiable Information in a legal proceeding, Circady will take reasonable steps within the context of that legal proceeding to inform the court or other decision-maker of the confidentiality of the information, and Circady will take reasonable steps to otherwise maintain the confidentiality of such information.
- Circady uses reasonable and appropriate safeguards to protect the security of Identifiable Information, including specifically the confidentiality and integrity of such information.
-
Partner Links
- Our site and applications may contain links to and from the websites of our partner networks, advertisers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies, and that we do not accept any responsibility or liability for these policies. Please check these policies before you submit any Personal Data to these websites.
-
Changes to our Policy
- Circady reserves the right, and may amend this Privacy Policy. Changes to the Privacy Policy will become effective when published on the website. Your continued use of the Services following the effective date of these changes indicates your consent to the practices disclosed in the update Privacy Policy.
- This Privacy Policy was last updated on May 24, 2018.
-
Reviewing, Correcting and Removing Your Personal Data
- You have the following data protection rights:
- You can request access, correction, updates or deletion of your Personal Data.
- You can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data.
- If we have collected and process your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
- You have the right to complain to a data protection authority about our collection and use of your Personal Data. Contact details for data protection authorities in the EEA, Switzerland and certain other countries.
- To exercise any of these rights or to unsubscribe from our communications, please contact us at privacyandsecurity@healios.io or by mail to Healios, Inc., 70 Church Str, 1st Floor, Flemington, NJ 08822, USA. We will respond to your request to change, correct, or delete your information within a reasonable timeframe and notify you of the action we have taken.
- Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed to info@circady.com. Your privacy is very import to us and we will make every effort to answer any questions you may have and to resolve your concerns.
- You have the following data protection rights: