Privacy Policy

Last modified: July 15, 2021

Katon Partners LLC dba Adfire Health (“Adfire Health” or “We“) respects your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you access or use Adfire Health (our “Site“) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect on this Site or via email, text, and other electronic messages between you and this Site.
It does not apply to information collected by:
  • Us offline or through any other means, including on any other website operated by us or any third party; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Site, or that you may share directly with a third party or other users via Site features (e.g., information you share with recruiters through chat or messaging services).

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using this Site, you agree to this Privacy Policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Site after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

1. Information We Collect About You and How We Collect It

We collect several types of information (“personal information“) from and about users of our Site, including:

  • Identifiers (such as your full name, e-mail address, telephone number);
  • Customer records information (such as financial information);
  • Commercial information (such as records of products or services purchased, obtained, or considered);
  • Internet or other similar network activity (such as browsing history, information on your interactions with our website, application or advertisements);
  • Geolocation data;
  • Professional or employment-related information (such as employer, job title, occupation, specialty, years of experience, current or past job history); and
  • Inferences (such as a profile reflecting your preferences, characteristics, behavior, attitudes, or abilities).

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
  • From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Site may include:

  • Information that you provide by filling in forms on our Site. This includes information provided at the time of registering to use our Site, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Site.
  • Records and copies of your correspondence (including email addresses), if you contact us.
  • Your responses to surveys that we might ask you to complete for research purposes.
  • Details of transactions you carry out through our Site and of the fulfillment of your orders. You may be required to provide financial information before placing an order with us.
  • Your search queries on the Site and any other information you submit in a web form on the Site.

You also may provide information to be published or displayed (hereinafter, “posted“) on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, “User Contributions“). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Please also note that we do not control the privacy practices of other users of the Site. If you share information with a third party via the Site (e.g., you provide information to a recruiter via chat or telephone), your information will be subject to the third party’s privacy policy. You should review the privacy policy of any third party with whom you share your personal information.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Site, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
  • Details of your visits to our Site, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Site.
  • Information about your computer and internet connection, including your IP address, operating system, and browser type.

We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). You may choose to opt out of behavioral advertising by visiting https://optout.networkadvertising.org/ or https://optout.aboutads.info/, or by setting your browser to restrict or delete cookies.

The information we collect automatically may include personal information, and we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns; store information about your preferences, allowing us to customize our Site according to your individual interests; speed up your searches; and recognize you when you return to our Site.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Site.
  • Flash Cookies. Certain features of our Site may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Site. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
  • Web Beacons. Pages of the Site and 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 email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Site are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies and other tracking technologies to collect information about you when you use our Site. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

2. How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:
  • To present our Site and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account or subscription, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Site or any products or services we offer or provide through it.
  • To allow you to participate in interactive features on our Site (e.g., chat, messaging, or displaying your profile).
  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, you may adjust your user preferences in your account profile, opt-out through the mechanism provided at the time you submit your information, or contact us using the Contact Information below. For more information, see Choices About How We Use and Disclose Your Information.

3. Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Adfire Health about our Site users is among the assets transferred.
  • To third parties to market their products or services to you if you have not opted out of these disclosures. For more information, see Choices About How We Use and Disclose Your Information.
  • To fulfill the purpose for which you provide it. For example, if you give us an email address to make a referral, we will transmit the contents of the referral email to the recipients.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.
We may also disclose your personal information:
  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply the Adfire Health Terms of Use, Subscription Terms and Conditions, and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Adfire Health, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

4. Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by checking the relevant box located on the form on which we collect your data or contacting us directly using the Contact Information below.
  • Promotional Offers from the Company. If you do not wish to have your contact information used by us to promote our own or third parties’ products or services, you can opt-out by checking the relevant box located on the form on which we collect your data or at any other time by adjusting your user preferences in your account profile or sending us an email stating your request to sayhello@adfirehealth.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI“) on the NAI’s website.

5. Accessing and Correcting Your Information

You can review and change your personal information by logging into the Site and visiting your account profile page. You may also send us an email at sayhello@adfirehealth.com to request access to, correct or delete any personal information that you have provided to us. In some cases, we cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

6. Shine the Light Law

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using any of the methods provided in the “Contact information” below.

7. Do Not Track

We are committed to providing you with meaningful choices about the information we collect on the Site, and that is why we provide the access and control choices set forth in this Privacy Policy. However, we do not recognize or respond to browser-initiated Do Not Track (“DNT”) signals, in part because no common industry standard for DNT has been adopted by industry groups, technology companies, or regulators, nor is there a consistent standard of interpreting user intent.

8. Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. However, the safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

9. Changes to Our Privacy Policy

It is our policy to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you by email to the email address specified in your account and/or through a notice on the Site home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Site and this privacy policy to check for any changes.

10. Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Telephone: 800-941-8409

Mail:    Adfire Health

             2 Landmark Square

             Stamford, CT 06901

             Attn: Adfire Health – Privacy Officer

11. Your California Privacy Rights

This California Privacy Notice only applies to residents in the State of California (“consumers”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

We have collected the following categories of personal information from consumers within the last twelve (12) months:
  • Identifiers (such as name, postal address, online identifier, IP address, email address, or other similar identifiers)
  • Customer records information (such as financial information)
  • Commercial information (such as records of products or services purchased, obtained, or considered)
  • Internet or other similar network activity (such as browsing history, information on your interactions with our website, application or advertisements)
  • Geolocation data
  • Professional or employment-related information (such as current or past job history)
  • Inferences (such as a profile reflecting your preferences, characteristics, behavior, attitudes, or abilities)

We obtained the categories of personal information listed above from the categories of sources listed in the “Information We Collect” section above.

Uses of Personal Information

We may use or disclose the personal information we collect for one or more of the purposes listed in the “How We Use Your Information” section above.

Sharing Personal Information

We may share your personal information with the categories of third parties listed in the “Disclosure of Your Information” section above. We do not sell personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:

  • The categories of personal information we collected about you.
  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing sales, if any, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, if any, identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

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 (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) 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, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, 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 et. 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.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or deidentify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please contact us using one of the contact methods listed above. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

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

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