Privacy Policy

Bamboo Health (“Bamboo Health”, “we”, “our”, or “us”) cares about your privacy. This Privacy Notice (“Privacy Notice”) describes how Bamboo Health collects, uses, and otherwise processes your personal information in connection with any associated websites that post or link to this Privacy Notice, including www.bamboohealtdev.wpengine.com (the “Sites”).

This Privacy Policy does not apply to (i) our collection of data through our Bamboo Health platforms, mobile applications, products or services provided to our customers, or (ii) our privacy practices relating to Bamboo Health employees or other personnel.

Customer Data

In certain situations, Bamboo Health functions as a service provider for our customers. In the course of providing services for such customers, we may collect your personal information on behalf of our business customers. We refer to this type of personal information as “Customer Data.” We collect and process Customer Data on behalf of our business customers subject to restrictions set forth in our contracts with them, including HIPAA business associate agreements. This Privacy Notice does not apply to our collection and processing of Customer Data. We recommend referring to the privacy notice of the Bamboo Health customer with which you have a relationship for information on how they engage service providers, like us, to collect and process Customer Data on their behalf.

Information Bamboo Health Collects About You

Sometimes we collect personal information automatically when an individual interacts with our Sites and sometimes, we collect personal information directly from an individual. At times, we may collect personal information about an individual from other sources and third parties, even before our first direct interaction.

Personal Information You Provide to Us

We may collect any personal information you provide to us when, for example, you contact us for support or other inquiries through the Sites. The types of personal information that we may collect include:

• Contact Information: If you request additional information about our products or services, request customer support, use our “Contact Us” or similar features, register to attend our seminars, webinars, or other presentations, or download certain content, we generally require you to provide us with your contact information, including, your full name, interest, job title, company name, address, phone number, email address, and communications preferences.

• Job Application Information: If you apply for available positions through our Sites, we may ask you to provide personal information including, your full name, date of birth, phone number, email address, career and educational history, areas of expertise, resumes or CVs, writing samples, letters of recommendation, social media profiles, demographic information, criminal record history, or other information which may be obtained in a background check.

• Registration Information: If you register for any web-based or app-based online community that we host, or register to attend our seminars, webinars, or other presentations, we may ask you to provide registration information, including, a username, photo, and/or biographical information, such as your occupation, social media profiles, company name, and areas of expertise.

• Newsletter: if you sign up to receive our newsletter, we may collect your name and email address.

• User Submissions: If you publicly post any personal or other information to the Sites or any web-based or app-based online community that we host, which information may include your tips, updates, alerts, comments, feedback, or any other information that you voluntarily provide (your “Submissions”), we may display your Submissions on any of our Sites, apps, mobile platforms, or any web-based or app-based online community that we host.

Where an individual chooses to contact us, we may need additional information to fulfill their request or respond to their inquiry. We may provide additional privacy disclosures where the scope of the inquiry/request or the personal information we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information the individual provides at that time.

Personal Information We Automatically Collect

As is true of most digital platforms, we and our third-party providers may also collect personal information from an individual’s device, browsing actions and website usage patterns automatically when visiting or interacting with our Sites, which may include log data (such as internet protocol (IP) address, operating system, browser type, browser id, the URL entered and the referring page/campaign, date/time of visit, the time spent on our Sites and any errors that may occur during the visit to our Sites), analytics data (such as the electronic path taken to our Sites, through our Sites and when exiting our Sites, as well as usage and activity on our Sites); and location data (such as general geographic location based on the log data we or our third-party providers collect).

We and our third-party providers may use (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, embedded scripts, location-identifying technologies and logging technologies (collectively, “cookies”) to automatically collect this personal information. For example, our Sites use Google Analytics, a web analytics service provided by Google LLC (“Google”), to collect and view reports about the traffic on our Sites. More information about the use of Google Analytics for these analytical and non-advertising purposes can be obtained by visiting Google’s privacy policy here and Google’s currently available opt-out options are available here.

To manage cookies, an individual may change their browser settings to: (i) notify them when they receive a cookie, so the individual can choose whether or not to accept it; (ii) disable existing cookies; or (iii) automatically reject cookies. Please note that doing so may negatively impact an individual’s experience using our Services, as some features and offerings may not work properly or at all. Depending on an individual’s device and operating system, the individual may not be able to delete or block all cookies. In addition, if an individual wants to reject cookies across all browsers and devices, the individual will need to do so on each browser on each device they actively use. An individual may also set their email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether they have accessed our email and performed certain functions with it.

Our Sites may also implement the Google reCAPTCHA tool to help prevent spam and abuse. The reCAPTCHA tool collects hardware and software information from your device, which is sent to Google for purposes of providing, maintaining, and improving the reCAPTCHA tool as well as for general security purposes. This information is not used by Google for personalized advertising. Your use of the reCAPTCHA tool is subject to Google’s Privacy Policy and Terms of Use.

For more information on our and third-party partners’ data collection and online advertising practices, please see the Third Party Tracking and Online Advertising section of this Privacy Notice.

Personal Information We Collect from Other Sources

We also obtain personal information from other sources, which we often combine with personal information we collect either automatically or directly from individuals.

We receive the same categories of personal information as described above from the following sources and third parties:

• Corporate Affiliates: We may receive personal information from other companies owned or controlled by Bamboo Health, and other companies owning or under common ownership with Bamboo Health. This includes any subsidiaries (i.e., any organization we own or control) or our parent company (i.e., any organization that owns or controls us) and any subsidiaries it owns.

• Service Providers: Our service providers that perform services solely on our behalf, such as email marketing providers, cloud providers, IT services, employment verification providers, and payment processors, collect personal information and often share some or all of this information with us in connection with the facilitation of our services.

• Business Partners: When we offer co-branded services or engage in joint marketing activities with other businesses, we may receive your personal information from our business partners.

• Social Media Platforms: When an individual interacts with us through various social media networks, we may receive some information about the individual that they permit the network to share with third parties. The data we receive is dependent upon an individual’s privacy settings with the network. Individuals should always review and, if necessary, adjust their privacy settings on third-party websites and networks before sharing information with us or the social media platform.

• Third Parties Related to Employment Applications: If you apply for a job with Bamboo Health, we may receive information from your current or past employers, recruiters, third-party social media platforms and other third parties we use to obtain information about job applicants.

• Information Providers: We may from time to time obtain information from third-party information providers from whom you have permitted to share your personal information, including marketing providers. We use this information to correct or supplement other personal information we collect. For example, we may obtain updated contact information from third-party information providers to reconnect with individuals.

• Publicly Available Information: We may also collect personal information from publicly available sources, such as government records or publicly available websites, to supplement other personal information we collect.

How Bamboo Health Uses Your Information

Bamboo Health may use your personal information for the following purposes:

• Provide you with relevant information on the Sites;

• Send you information about Bamboo Health products and services and similar information on request;

• Conduct market research and customer surveys;

• Where you have submitted a job application, evaluate your candidacy for employment;

• Investigate and respond to comments or inquiries from users of the Sites and/or customers;

• Detect, prevent, or otherwise address fraud, security, or technical issues, as well as protect against harm to the rights, property or safety of Bamboo Health or the public;

• Analyze your use and measure effectiveness of the Sites for purposes of improvement, engagement, and retention;

• Place cookies and use tracker technologies on the Sites and in email communications;

• Diagnose problems on the Sites;

• In connection with legal claims, compliance, regulatory and investigative purposes as necessary (including disclosure or information in connection with government agency requests, legal process or litigation); and

• As part of a corporate transaction, such as a transfer of assets to or an acquisition by or merger with another company.

We may aggregate, de-identify and/or anonymize any information collected through the Sites so that such information is no longer reasonably capable of being associated with you. We may use aggregated or anonymized information for any purpose, including for research and marketing purposes. We may share or publish aggregated or anonymized information that doesn’t specifically identify you, such as statistical information about visitors to our websites or statistical information about how customers use our products and services.

How Your Information May be Shared

• Internal sharing: Employees and contractors of Bamboo Health may share your information internally for the delivery of Bamboo Health services, to the extent necessary to fulfill a request you have submitted via our Sites, or for customer support, marketing, technical operations, account management, or similar purposes.

• Corporate Affiliates: Bamboo Health may share your information with our corporate group of affiliated companies for the purposes listed in this Privacy Notice.

• Service Providers: We may also share your information with third party service providers, which provide Bamboo Health with services and certain business functions, such as IT and system administration and hosting, email management, credit card processing, order fulfillment, research and analytics, marketing, customer support and data enrichment.

• Business Partners: We may share your personal information with our third party business partners when you engage in a co-promotion or a co-branded product.

• Fraud Prevention, Safety and Security: We may share your information with organizations or individuals outside of Bamboo Health if we believe that doing so is reasonably necessary to detect, prevent, or address fraud, security, or technical issues. We may also share your information with others in order to protect against harm to the rights, property or safety of Bamboo Health and our employees, users, children, or the public as required or permitted by law.

• Sharing Consistent with Your Choices: We may share your information with sponsors, joint venture entities and other third parties, including entities for which we are acting as an agent, licensee, application host or publisher, that wish to send you information about their products and services that may be of interest to you, as determined by your choices in managing your communications preferences and other settings.

• Business Transaction or Reorganization: We may also share your information if we sell, transfer, or otherwise share some or all of our assets to a third party in connection with a merger, acquisition, reorganization, sale of assets or similar transaction, or in the event of bankruptcy, or in diligence leading up to a potential corporate transaction. We may disclose personal information to a third party during negotiation of, in connection with, or as an asset in such a corporate business transaction.

• Legal Purposes: We may disclose your personal information to meet any applicable law, regulation, legal process or other legal obligation.

Third-Party Tracking and Online Advertising

We may share, or we may permit third-party online advertising networks, social media companies, and other third-party services, to collect information about your use of our Sites over time so that they may play or display ads that may be relevant to your interests on other websites or apps, or on other devices you may use. Typically, though not always, the information we share is provided through cookies or similar tracking technologies, which recognize the device you are using and collect information, including hashed data, clickstream information, browser type, time and date you visited the website and other information. This information is used to display targeted ads on or through our services or on other websites, apps, or services. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests. We may also display targeted advertising to you through social media platforms, such as LinkedIn, Facebook, TikTok, Twitter, Google, Pinterest, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in our services while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. These advertisements are governed by the privacy policies of those social media companies that provide them.

Google Analytics and Advertising. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our services.

You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences, or by visiting NAI’s online resources at http://www.networkadvertising.org/choices.

To learn more about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Digital Advertising Alliance’s (DAA) resources and/or the Network Advertising Initiative’s (NAI) online resources, at www.aboutads.info/choices or http://www.networkadvertising.org/choices/ and you can opt-out of receiving some interest-based advertisements on mobile apps by visiting http://www.aboutads.info/appchoices. You may also be able to limit interest-based advertising through the settings menu on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest-based ads” (Android).

Please note that when you opt out of receiving interest-based advertisements, this does not mean you will no longer see advertisements from us or on our online services. It means that the online ads that you do see from DAA program participants should not be based on your interests. We are not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. In addition, third parties may still use cookies to collect information about your use of our online services, including for analytics and fraud prevention as well as any other purpose permitted under the DAA’s Principles.

Control Over Your Data

Marketing Communications: You can stop receiving marketing and non-transactional communications from us by clicking on the “unsubscribe” link located on the bottom of our emails, by replying or texting ‘STOP’ if you receive SMS communications, or by turning off push notifications on our apps on your device. Additionally, you may unsubscribe by contacting us using the information in the “Contact Us” section below. Please note that opting out of marketing communications does not opt you out of receiving important business communications related to your current relationship with us, such as information about your subscriptions, service announcements, or security information.

Retention Period for Your Information

When you provide us with personal information via the Sites, Bamboo Health may store, process, and use that information for as long as is necessary for our business purposes, and to the extent necessary to comply with our legal, accounting, or compliance obligations.

Children’s Privacy

The Sites are designed to provide information about our products and services, and we do not target the Sites at children. Bamboo Health does not knowingly collect or process information from children under the age of 13. If you are aware of a child providing his or her personal information, please contact us at privacy@bamboohealth.com.

Third-Party Sites

The Bamboo Health Sites may include links to other third-party websites or resources (“Third-Party Sites”) offered by independent organizations that may or may not be affiliated with Bamboo Health. Bamboo Health has no control over these Third-Party Sites and does not endorse and is not responsible for any content, advertising, products, services, or other materials found on the Third-Party Sites. To learn about the personal information practices of third parties, please visit their respective privacy policies.

Changes to this Privacy Notice

We will update this Privacy Notice from time to time to reflect changes in our practices, updated technologies, emerging legal and regulatory requirements, and other factors. If we do, we will notify individuals by email to their registered email address, by prominent posting on our online services, or through other appropriate means. All changes shall be effective from the date of publication unless otherwise provided. The date the Privacy Notice was last revised is identified at the top of the page. We encourage you to periodically review this Privacy Notice to stay informed about our collection, processing and sharing of your personal information.

Contact Us

If you have questions regarding this Privacy Notice or our privacy practices, please contact Bamboo Health at privacy@bamboohealth.com, or write to us at the following mailing address:

Bamboo Health

9901 Linn Station Rd., Suite 500
Louisville, Kentucky 40223, USA

Phone: 1-866-277-7477

Additional Privacy Information For California Residents

These Additional California Privacy Disclosures (the “CA Disclosures”) supplement the information contained in our Privacy Notice and apply solely to individual residents of the State of California (“consumers”).

These CA Disclosures provide additional information about how we collect, use, disclose and otherwise process personal information of individual residents of the State of California within the scope of the California Consumer Privacy Act of 2018 (“CCPA”).

Unless otherwise expressly stated, all terms in these CA Disclosures have the same meaning as defined in our Privacy Notice or as otherwise defined in the CCPA.

Scope of Disclosures

When we use the term “personal information” in these CA Disclosures, we mean information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. It does not include information that is made publicly available from government records, that is deidentified or aggregated such that it is not reasonably capable of being associated with an individual, or that is otherwise excluded from the CCPA’s scope.

For the purposes of these CA Disclosures, personal information does not include:

• Publicly available information from government records.

• Deidentified, aggregated or anonymized information that is maintained in a form that is not capable of being associated with or linked to you.

• Information excluded from the CCPA’s scope, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and the California Confidentiality of Medical Information Act (“CMIA”) or clinical trial data.

Categories of Personal Information We Collect

In the last 12 months, we have collected the following categories of personal information from and about you:

• Identifiers, such as full name, account name, mailing address, email address, and IP address.

• California Customer Records (Cal. Civ. Code § 1798.80(e)), such as phone number, and email address.

• Protected Classification Characteristics, such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, veteran or military status, genetic information.

• Internet/Network Information, such as mobile device content, IP address, browsing history, and usage information.

• Geolocation Information, such as your approximate location as determined though data like your IP address.

• Professional or Employment Information, such as the name and address of the company you work for and employment history in connection with job applications.

• Other Personal Information, such as testimonial information, inquiry information, feedback information, demographic information, and any other personal information an individual chooses to provide us.

• Inferences, such as predictions about which services may be of interest to an individual.

We collect this information directly from individuals, their browser or device when they interact with our services, our affiliates, an individual’s employer, our service providers and business partners, social media and professional networks, information providers and other publicly available sources. For more information about the personal information that we collect and how we collect it, please refer to the Information Bamboo Collects About You section of our Privacy Notice.

How We Use Personal Information

We use the above categories of personal information for a variety of purposes. For example, we use personal information to communicate with customers about our services, to provide customers with our services, and to otherwise operate our business. For more information about our use of Personal Information, please refer to the How Bamboo Health Uses Your Information section of our Privacy Notice.

Disclosure and Sale of Personal Information

As further described in the How Your Information May Be Shared section of our Privacy Notice, we disclose personal information to third parties for business purposes.

Disclosure for Business Purposes

In the last 12 months, we have disclosed for business purposes all categories of personal information outlined above to the following categories of recipients: Corporate Affiliates, Business Partners, Service Providers, and certain other third parties where individuals have provided consent or direction, or where we are complying with law or protecting our rights (such as to our legal advisors).

Sale of Personal Information

As is common practice among companies that operate online, in the last 12 months, we have allowed certain third-party providers to collect information about consumers directly through our website and other online services for purposes of analyzing and optimizing our services, delivering ads, providing content and ads that are more relevant, measuring statistics and the success of ad campaigns, and detecting and reporting fraud. As a result of this practice, in the last 12 months, we have sold the following categories of personal information to these third-party providers, subject to each consumer’s settings and their right to opt-out:

• Commercial Information, such as service information, including services of interest or orders made in connection with our services.

• Internet/Network Information, such as IP address, log data (including operating system and browser type) and analytics data (including usage and activity on our website and online services)

• Geolocation Data, such as general geographic location based on IP address.

Since our services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 16, we do not sell personal information of consumers we know to be under the age of 16.

For more information about how we otherwise disclose personal information, please refer to the How Your Information May Be Shared section of our Privacy Notice.

Your California Privacy Rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

The Right to Know

You have the right to request any or all of the following information relating to the personal information we have collected about you or disclosed in the last 12 months, upon verification of your identity:

• The specific pieces of personal information we have collected about you;

• The categories of personal information we have collected about you;

• The categories of sources of the personal information we have collected about you;

• The categories of personal information that we have disclosed about you to third parties for a business purpose, and the categories of recipients to whom this information was disclosed;

• The categories of personal information we have sold about you (if any), and the categories of third parties to whom this information was sold; and

• The business or commercial purposes for collecting or, if applicable, selling personal information about you

The Right to Request Deletion

You have the right to request the deletion of personal information that we have collected from you, subject to certain exceptions.

The Right to Opt Out of Personal Information Sales

You have the right to direct us not to sell personal information we have collected about you to third parties now or in the future.

The Right to Non-Discrimination

You have the right not to receive discriminatory treatment for exercising any of the rights described above.

However, please note that if the exercise of the rights described above limits our ability to process personal information (such as in the case of a deletion request), we may no longer be able to provide you our products or services or engage with you in the same manner.

“Shine the Light”

California residents that have an established business relationship with us have rights to know how their information is disclosed to third parties for their direct marketing purposes under California’s “Shine the Light” law (Civ. Code § 1798.83).

How to Exercise Your California Privacy Rights

To Exercise Your Right to Know or Right to Deletion

Please submit a request by:

• Emailing privacy@bamboohealth.com with the subject line “California Rights Request”;

• By using our contact form located here; or

• Calling 1-866-277-7477.

We will need to verify your identity before processing your request. In order to verify your identity, we will generally either require the successful login to your account or the matching of sufficient information you provide us to the information we maintain about you in our systems. Although we try to limit the personal information collected in connection with a request to exercise the right to know and/or the right to deletion to that personal information identified in our Privacy Notice, certain requests may require us to obtain additional personal information from you such as name, address, and date of birth. In certain circumstances, we may decline a request to exercise the right to know and/or right to deletion, particularly where we are unable to verify your identity.

To Exercise Your Right to Opt Out of Personal Information Sales

As described above, we permit third party advertising networks, social media companies and other third party businesses to collect and disclose your personal information (including preferences, geolocation, commercial information and internet, network and device information) directly from your browser or device through cookies or tracking technologies when you visit or interact with our websites, use our apps or otherwise engage with us. These third parties use this information for the purposes of serving ads that are more relevant, for ad campaign measurement and analytics, and for fraud detection and reporting and may sell that information to other businesses for advertising and other purposes. By visiting here, you can opt out from sales of this type of personal information by businesses that participate in the opt-out tool. To make opt-out requests related to mobile apps on your device for businesses participating in the DAA’s CCPA App-based Opt-Out Tool, you can download the appropriate app at www.youradchoices.com/appchoices. To learn more about how third parties collect information through tracking technologies and what other choices you may have in relation to those activities, please see Third Party Tracking and Online Advertising section of our Privacy Notice.

To Submit a Request as an Authorized Agent

In certain circumstances, you are permitted to use an authorized agent (as that term is defined by the CCPA) to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf by:

• For requests to know or delete personal information:
  • Receiving a power of attorney valid under the laws of California from you or your authorized agent; or
  • Receiving sufficient evidence to show that you have:
    • Provided the authorized agent signed permission to act on your behalf;
    • Verified your own identity directly with us pursuant to the instructions set forth in these CA Disclosures; and
    • Directly confirmed with us that you provided the authorized agent permission to submit the request on your behalf.

• For requests to opt out of personal information sales: Receiving a signed permission demonstrating your authorized agent has been authorized by you to act on your behalf.

We may deny a request in the event we are not able to verify the authorized agent’s authority to act on your behalf.

Minors Under Age 16

We do not and will not “sell” the personal information of consumers we know to be less than 16 years of age, unless we receive affirmative authorization (the “Right to Opt In”) from either the minor who is between 13 and 16 years of age, or the parent or guardian of a minor less than 13 years of age.

Shine the Light Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. To opt out of such sharing, please email us at privacy@bamboohealth.com.