Ovia Health Apps Privacy Policy

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Introduction and scope

This Privacy Policy (“Policy”) describes how Ovuline, Inc., doing business as Ovia Health (“Ovia”) uses and shares personal data collected through the Ovia Fertility, Ovia Pregnancy and Ovia Fertility apps and health coaching services (the “Services”).

For California residents whose personal data is governed by the California Consumer Privacy Act (“CCPA”), Ovia provides a supplementary CCPA Privacy Policy here. The CCPA Privacy Policy describes Ovia’s use and sharing of personal data of California residents using the format specifically required by the CCPA and its regulations.

For more on the scope of this Policy, click here.

Personal Data We Collect

We collect the personal data that you choose to submit to us through the Ovia apps and coaching services. We automatically collect your IP address, the Advertising ID number of your mobile device, data about your mobile device such as device type and operating system, and data about your activity in the apps such as the articles and ads you view. To facilitate automatic collection of data about your device and activity, we store cookies and similar technologies on your device. Our advertisers, advertising networks and analytics providers may also store such technologies on your device. We explain this in more detail below in the section on Cookies and Tracking Technologies. If you login through Facebook, we automatically collect your email address. We also make inferences about you based on the data you have provided.

The data we collect is transferred to servers located in the US of our cloud computing provider, Amazon Web Services (AWS).

More about this.

Cookies and Tracking Technologies

We use various technologies to collect and store information which may include sending one or more cookies or anonymous identifiers to your device. These technologies allow us to manage access to and use of the Services, recognize you and provide personalization and advertising, and help us obtain analytic data to understand how people use the Services. In selling advertising and placing affiliate marketing links in the Consumer version of the Services, we may also allow third party advertisers, ad networks and affiliate marketing networks to place or recognize cookies or other technology to collect certain information about you, the ads shown to you, and the links you click on. An advertiser or ad network may be able to collect your device’s unique identifier in the course of serving an ad, and may reuse that information to show you other advertising outside the Services. If you click on a link within an ad or sponsored content, you will be transmitting information about your device and your interaction with the ad or link to third party ad networks and affiliate marketing networks. We do not have knowledge or control of use of tracking technologies or your personal data by such third parties. For more information about online advertising, you can visit www.networkadvertising.org and https://youradchoices.com/, and you can download the AppChoices app to opt out of interest based advertising in mobile apps.

Where Do We Get Personal Data?

We collect all personal data about you directly from you, except:

How and Why Do We Use Personal Data?

We use your personal data to:

More about data usage.

When Do We Share Personal Data?

Ovia treats your personal data as confidential, and only shares it in limited circumstances as described in this Policy. We share personal data with vendors and contractors who provide services to us. If you invite others to view your account, we share the content of your account with them. For users who receive advertising, we share indirect identifiers, such as the Advertising ID number of your device, with advertisers and advertising networks. We also share indirect identifiers with companies that provide us data analytics services. The Services may contain links or interfaces to third party services; we may share personal data with third parties named in links and interfaces to fulfil the purpose of that interaction. If you click on a link in sponsored content, you are choosing to share indirect identifiers of your device and your interaction with the sponsored content with the sponsor and/or their affiliate marketing network.

If you opt in to share data with Apple Health to show Ovia data on your Apple Watch, we will send the data fields you select to Apple Health.

If you opt in to share data with an advertiser and sponsor, we will send the data fields you consent to share with the advertiser or sponsor.

If you receive Ovia as a benefit from your health plan or health care provider, Ovia is part of your care package and so we may share your personal data with your health plan or provider, or their business associates, under HIPAA. While we may share personal data with an employer health plan consistent with HIPAA, we do not share personal data with the employer itself.

We use Google technology and services to obtain analytics and provide you with ads and tailored Ovia content. As a result of this, Google obtains and uses certain of your personal data as described here.

We use Facebook technology in our apps so that users can log on via Facebook. This allows Facebook to collect device information, and data relating to your engagement with our apps, whether or not you use the Facebook login feature. Facebook may use that data to personalize advertising to you, both on and off Facebook as described in the Facebook Data Policy.

More about sharing.

What Are Your Choices?

We give you the right to:

To correct your data, go to the “More” page of your Ovia app, where you can modify your profile and your health information. To exercise any other choices, go to the “Settings” page of your Ovia app, where you can choose options including “do not sell my info” to opt out of personalized advertising, “export my data”, “reset or delete my account”, “delete my account and data” and “how is my data used?”.

More about this.

Different Product Versions

This is a summary of the differences in processing of personal data between the Consumer, Employer and Health Plan/Provider versions of the Services.

Data Security

Ovia protects personal data with security measures that are consistent with industry standards, including background checks on all employees and data encryption in transit and at rest. Ovia’s Enterprise product has achieved certification to the Hitrust Common Security Framework. Our data is hosted by Amazon Web Services, which maintains multiple security certifications. We will notify you of security incidents as required by law.

Data Retention

We store your data for the period that your account is active and then for a further period in case you return to use the Services again. After this retention period ends, we will delete your data.

How to Contact Ovia?

To contact Ovia to exercise your privacy choices, please see “What Are My Choices?” above.

Ovia has designated a Data Protection Officer. To contact our Data Protection Officer or for questions or complaints about Ovia’s processing of personal data, contact us at:

Data Protection Officer
Ovuline, Inc., dba Ovia Health
308 Congress Street, Floor 6,
Boston, MA 02210
legal@oviahealth.com

Data subjects located in the EEA and UK may contact the Data Protection Officer at the address above or Ovia’s EU representative at the address below:

DP-Dock GmbH
Ovuline, Inc., doing business as Ovia Health
Ballindamm 39
20095 Hamburg, Germany
E-Mail: oviahealth@gdpr-rep.com

You may also have the legal right to lodge a complaint about Ovia’s data processing with your local consumer protection or data protection authority.

Other Issues

Children: The Services are not available to children under 13 or who otherwise require parental consent under applicable law to use the Services or provide personal information to Ovia. Ovia does not collect personal data from children under 13. Ovia does not show advertising to any user under the age of 16. Parents and guardians may include personal data about their baby or child in their Ovia account; the parent or guardian is responsible for ensuring they have the legal right to do so.

Deidentified Data: Ovia may use personal data to create deidentified data for research and development purposes. Deidentified data is data that is no longer linked or linkable to you. We may provide deidentified data to universities and medical research institutions for research to improve health, fertility and pregnancy.

Legal requirements. Ovia may provide personal data to courts, law enforcement, and governmental authorities and other third parties if required by law, subpoena, directive from a regulatory authority or as otherwise necessary to comply with legal requirements or to protect the rights or property of Ovia or third parties. Ovia may access, use and preserve data to comply with law, in anticipation of litigation, or to protect the rights or property of Ovia or third parties, even if the data is subject to a deletion request from you. We may also provide information to law enforcement or authorities to protect the safety of users of the apps or others.

Sale, merger, or change of ownership. If Ovia merges with another company, or its equity securities or all or a part of its assets are sold to a third party, your personal data may be transferred to the buyer or successor entity. We will notify all users of any transfer to a different legal entity.

Changes to this Policy

Ovia may modify this Policy from time to time by posting an updated version of the Policy. When we modify this Policy, we will notify users by email or in-app notification.

Last updated: 15 April, 2020

Privacy Notice for California Residents

Last updated: April 15, 2020

This Privacy Notice for California Residents supplements the information contained in Ovia Health's Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California ("consumers", “users” or "you"). 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 notice.

Right to Know About Personal Information Collected, Disclosed, or Sold

Export Your Data - Data Portability

You have the right to request that Ovia provide you with a copy of the personal information Ovia has collected or obtained about you over the past 12 months. (For more on what we mean by “personal Information”, please see What is Personal Information?). To obtain this information:

You will be required to re-enter your username and password to verify your identity in order to complete the data export.

You may also submit a request by email to support@oviahealth.com. Ovia will require you to provide identifying information to verify your identity. If you have an Ovia account, Ovia may require you to verify your identity by providing your username and password.

Right to Know Summary Statement

You have the right to request that Ovia disclose what personal information it collects, uses, discloses and sells about you. We will provide this information in a summary statement sent to you. (We also provide a general description of this in our Privacy Policy.)

To obtain this summary statement:

You will be required to re-enter your username and password to verify your identity in order to obtain the summary statement.

You may also submit a request by email to support@oviahealth.com. Ovia will require you to provide identifying information to verify your identity. If you have an Ovia account, Ovia may require you to verify your identity by providing your username and password.

Once we receive and confirm your request, we will disclose to you:

Personal Information We Collect - Our Notice at Collection

Ovia Health’s applications collect personal information. Listed below are the categories of personal information we may collect from you, and for each category of personal information, the business or commercial purposes for which it may be used. The reason we classify by these categories is because the CCPA requires it.

Category A: Identifiers.

This category includes personal information such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Does Ovia Collect Personal Information in Category A?
Yes. For example, we collect your name, email address, and online identifiers such as the Advertising ID associated with your device. We collect (but do not store) your IP address.
How Does Ovia Use Category A Information?
We use Category A information to provide and improve the Ovia apps, to contact you with email notifications and marketing, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration. (For more information on what we mean by these terms, see here.)

Category B: Personal Information defined in California Personal Records Law.

This category includes personal information such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Does Ovia Collect Personal Information in Category B?
Yes. For example, we collect your name, and we may collect health, medical information and health insurance information.
How Does Ovia Use Category B Information?
We use Category B information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.

Category C. Protected classification characteristics under California or federal law.

This includes personal information such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Does Ovia Collect Personal Information in Category C?
Yes. For example, we may collect age, medical condition, race, and pregnancy.
How Does Ovia Use Category C Information?
We use Category C information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.

Category D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Does Ovia Collect Personal Information in Category D?
Yes. For example, we may ask you about your income, if you are an alcohol or caffeine user, or whether you are a smoker.
How Does Ovia Use Category D Information?
We use Category D information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.

Category E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Does Ovia Collect Personal Information in Category E?
Yes. We do not collect biometric identifiers such as voiceprint or fingerprint. We do give you the opportunity to synch your fitness tracker to Ovia, and if you do that, we collect your sleep, health and exercise data from the tracker.
How Does Ovia Use Category E Information?
We use Category E information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.

Category F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Does Ovia Collect Personal Information in Category F?
Yes. For example, we collect information showing which articles in the Ovia apps you have read and which advertisements you have clicked on.
How Does Ovia Use Personal Information in Category F?
We use Category F information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.

Category G. Geolocation data.

Physical location or movements.

Does Ovia Collect Personal Information in Category G?
Yes. Once per month, we use your IP address to understand your location by country and state. We do not continuously track your location while you are using Ovia apps.
How Does Ovia Use Personal Information in Category G?
We use Category G information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.

Category H. Sensory Data.

Audio, electronic, visual, thermal, olfactory, or similar information.

Does Ovia Collect Personal Information in Category H?
Yes. For example, we allow you to upload photographs and video to the Ovia apps.
How Does Ovia Use Personal Information in Category H?
We use Category H information to provide and improve the Ovia apps and for Ovia’s operational purposes, management and administration.

Category I. Professional or employment-related information.

Current or past job history or performance evaluations.

Does Ovia Collect Personal Information in Category I?
Yes. For example, we may ask you whether or not you are employed or a stay-at-home mom. We do not collect job history or performance evaluations.
How Does Ovia Use Personal Information in Category I?
We use Category F information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.

Category J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Does Ovia Collect Personal Information in Category J?
No.

Category K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Does Ovia Collect Personal Information in Category K?
Yes. For example, we may calculate, based on the data you have provided to us, the trimester of your pregnancy or that certain medical issues may be relevant to you.
How Does Ovia Use Personal Information in Category K?
We use Category K information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.

Does Ovia Sell Your Personal Information?

To provide the Consumer version of the Services for free, we sell advertising. To do that, we share indirect identifiers such as the Advertising ID number of your device with advertisers and advertising analytics providers to allow them to measure and track ad performance. We may also allow third party advertisers, ad networks and affiliate marketing networks to place or recognize cookies or other technology in ads and affiliate marketing content to track the ads shown to you and the links you click on. This sharing may constitute a sale of personal information under California law.

We may ask if you would like to share your personal information, such as an email address, with Ovia advertisers or sponsors. We only share your personal information with advertisers or sponsors if you expressly opt-in. Ovia may receive payments from the advertiser or sponsor for this sharing.

Except for the sharing described in the above paragraph, Ovia does not sell your personal information.

Where is Ovia’s Generally-Applicable Privacy Policy?

Click here for our Privacy Policy.

Personal Information We Have Collected In the Past 12 Months

Ovia Health's applications have collected the following categories of consumer personal information within the last twelve (12) months. The reason we classify by these categories is because the CCPA requires it.

Category A: Identifiers

This category includes personal information such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

Has Ovia Collected Personal Information in Category A?
Yes. For example, we collected your name, email address, and online identifiers such as the Advertising ID associated with your device. We collected (but do not store) your IP address.
From Whom Did Ovia Collect This Information?
We collected device identifiers such as your device’s Advertising ID number and IP address automatically from your device. If you used the Ovia applications through your employer, your employer provided us with your identifying information, such as name, address, date of birth and health insurance information, so that we could authenticate you and provide you the Enterprise version of the Ovia apps. Your employer did not provide Ovia with any health information about you. We collected all other information directly from you, when you entered answers into fields in the Ovia apps or answered questions in the apps.
What Was the Purpose of Collecting Category A Information?
We collected Category A information to provide and improve the Ovia apps, to contact you with email notifications and marketing, to display advertising in the Ovia apps and emails, and for Ovia’s operational purposes, management and administration. (For more on what we mean by these terms, see here.)
With What Categories of Third Parties Does Ovia Share Category A Information?
We disclose this information to the cloud computing provider who hosts the Ovia applications, to data analytics providers that provide us with aggregated data about how the Ovia applications perform, to vendors who provide email, support and scheduling systems and to our advertising sales platform, advertising networks and advertisers who sell, administer, serve and purchase ads. If you click on a link in sponsored content, you are choosing to share indirect identifiers of your device with the sponsor and/or their affiliate marketing network.

Category B: Personal Information defined in California Personal Records Law.

This category includes personal information such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Has Ovia Collected Personal Information in Category B?
Yes. For example, we collected your name, and we may have collected health, medical information, health insurance information and employment information.
From Whom Did Ovia Collect This Information?
From you. However, if you were using the Ovia applications as an Enterprise user, your employer provided us with your identifying information, such as name, address, date of birth and health insurance information, so that we could authenticate you and provide you the Enterprise version of the Ovia apps. Your employer did not provide Ovia with any health information about you.
What Was the Purpose of Collecting Category B Information?
We use Category B information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.
With What Categories of Third Parties Does Ovia Share Category B Information?
We disclose this information to the cloud computing provider who hosts the Ovia applications, to vendors who provide email, support and scheduling systems, and to our advertising sales platform. We did not disclose Category B information to advertisers or advertising networks, but those third parties may have been able to attribute certain characteristics to you based on the context of advertising sold.

Category C. Protected classification characteristics under California or federal law.

This includes personal information such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Has Ovia Collected Personal Information in Category C?
Yes. For example, we may collect age, medical condition, race, and pregnancy.
From Whom Did Ovia Collect This Information?
From you.
What Was the Purpose of Collecting Category C Information?
We use Category C information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.
With What Categories of Third Parties Does Ovia Share Category C Information?
We disclose this information to the cloud computing provider who hosts the Ovia applications, to vendors who provide email, support and scheduling systems, and to our advertising sales platform. We do not disclose Category C information to advertisers or advertising networks, but those third parties may have been able to attribute certain characteristics to you based on the context of advertising sold.

Category D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Has Ovia Collected Personal Information in Category D?
Yes. For example, we may ask you about your income, if you are an alcohol or caffeine user, or whether you are a smoker.
From Whom Did Ovia Collect This Information?
From you.
What Was the Purpose of Collecting Category D Information?
We use Category D information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.
With What Categories of Third Parties Does Ovia Share Category D Information?
We disclose this information to the cloud computing provider who hosts the Ovia applications, to vendors who provide email, support and scheduling systems, and to our advertising sales platform. We do not disclose Category D information to advertisers or advertising networks, but those third parties may have been able to attribute certain characteristics to you based on the context of advertising sold.

Category E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

Has Ovia Collected Personal Information in Category E?
Yes. We did not collect biometric identifiers such as voiceprint or fingerprint. We give you the opportunity to synch your fitness tracker to Ovia, and if you did that, we collected your sleep, health or exercise data from the tracker.
From Whom Did Ovia Collect This Information?
From your tracker.
What Was the Purpose of Collecting Category E Information?
We use Category E information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.
With What Categories of Third Parties Does Ovia Share Category E Information?
We disclose this information to the cloud computing provider who hosts the Ovia applications, to vendors who provide email, support and scheduling systems, and to our advertising sales platform. We do not disclose Category E information to advertisers or advertising networks, but those third parties may have been able to attribute certain characteristics to you based on the context of advertising sold.

Category F. Internet or other similar network activity.

Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

Has Ovia Collected Personal Information in Category F?
Yes. For example, we collect information showing which articles in the Ovia apps you have read and which advertisements you have clicked on.
From Whom Did Ovia Collect This Information?
From your device.
What Was the Purpose of Collecting Category F Information?
We use Category F information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.
With What Categories of Third Parties Does Ovia Share Category F Information?
We disclose this information to the cloud computing provider who hosts the Ovia applications, to data analytics providers that provide us with aggregated data about how the Ovia applications perform, to vendors who provide email, support and scheduling systems, and to our advertising sales platform, advertising networks and advertisers who sell, administer, serve and purchase ads. If you click on a link in sponsored content, you are choosing to share indirect identifiers of your device and your interaction with the sponsored content with the sponsor and/or their affiliate marketing network.

Category G. Geolocation data.

Physical location or movements.

Has Ovia Collected Personal Information in Category G?
Yes. Once per month, we use your IP address to understand your location by country and state. We do not continuously track your location while you are using Ovia apps.
From Whom Did Ovia Collect This Information?
From your device.
What Was the Purpose of Collecting Personal Information in Category G?
We use Category G information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.
With What Categories of Third Parties Does Ovia Share Category G Information?
We disclose this information to the cloud computing provider who hosts the Ovia applications, to vendors who provide email, support and scheduling systems, and to our advertising sales platform. We did not disclose Category G information to advertisers or advertising networks, but those third parties may have been able to attribute certain characteristics to you based on the context of advertising sold.

Category H. Sensory Data.

Audio, electronic, visual, thermal, olfactory, or similar information.

Has Ovia Collected Personal Information in Category H?
Yes. For example, we allow you to upload photographs and video to the Ovia apps.
From Whom Did Ovia Collect This Information?
From you.
What Was the Purpose of Collecting Personal Information in Category H?
We use Category H information to provide and improve the Ovia apps and for Ovia’s operational purposes, management and administration.
With What Categories of Third Parties Does Ovia Share Category H Information?
To the cloud computing vendor who hosts the Ovia apps.

Category I. Professional or employment-related information.

Current or past job history or performance evaluations.

Has Ovia Collected Personal Information in Category I?
Yes. For example, we may ask you whether or not you are employed or a stay-at-home mom. We do not collect job history or performance evaluations.
From Whom Did Ovia Collect This Information?
From you.
What Was the Purpose of Collecting Personal Information in Category I?
We use Category I information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.
With What Categories of Third Parties Does Ovia Share Category I Information?
We disclose this information to the cloud computing provider who hosts the Ovia applications, to vendors who provide email, support and scheduling systems, and to our advertising sales platform. We did not disclose Category B information to advertisers, advertisers or advertising networks, but those third parties may have been able to attribute certain characteristics to you based on the context of advertising sold.

Category J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Does Ovia Collect Personal Information in Category J?
No.

Category K. Inferences drawn from other personal information.

Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Has Ovia Collected Personal Information in Category K?
Yes. For example, we may calculate, based on the data you have provided to us, the trimester of your pregnancy or that certain medical issues may be relevant to you.
From Whom Did Ovia Collect This Information?
This data was inferred by Ovia based on data you provided to us.
What Was the Purpose of Collecting Personal Information in Category K?
We use Category K information to provide and improve the Ovia apps, to conduct research related to fertility, pregnancy and parenting, to display advertising in the Ovia apps and email, and for Ovia’s operational purposes, management and administration.
With What Categories of Third Parties Does Ovia Share Category K Information?
We disclose this information to the cloud computing provider who hosts the Ovia applications, to vendors who provide email, support and scheduling systems, and to our advertising sales platform. We did not disclose Category K information to advertisers or advertising networks, but those third parties may have been able to attribute certain characteristics to you based on the context of advertising sold.

Disclosure of Personal Information To Third Party Service Providers For Business Purposes

Ovia has disclosed personal information to third party service providers for business purposes in the past 12 months. The categories of personal information that Ovia disclosed to third parties for a business purpose in the past 12 months are set out below. The reason we classify by these categories is because the CCPA requires it.

For more information on why we disclose information to third parties for business purposes, please see the section “Personal Information We Have Collected in the Past 12 Months” above.

Category A: Identifiers.
This category includes personal information such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Category B: Personal Information defined in California Personal Records Law.
This category includes personal information such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Category C. Protected classification characteristics under California or federal law.
This includes personal information such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Category D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Category E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Category F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Category G. Geolocation data.
Physical location or movements.
Category H. Sensory Data.
Audio, electronic, visual, thermal, olfactory, or similar information.
Category I. Professional or employment-related information.
Current or past job history or performance evaluations.
Category K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Sale of Personal Information

Ovia has not sold and will not sell your name, email address, telephone number or the detailed health information you provided to us when using the Services, unless you have expressly opted-in as described in the paragraph below.

We may sometimes ask if you would like to share your personal information, such as an email address, with an Ovia advertiser or sponsor. We only share your personal information with advertisers or sponsors if you expressly opt-in. Ovia may receive payments from the advertiser or sponsor for this sharing.

In order to sell advertising in the Ovia apps, Ovia discloses online identifiers associated with your device, such as the Advertising ID number of your device, and your advertising profile (the criteria used to target advertising to you) to Ovia’s third party advertising sales platform. Ovia also discloses or allows the collection of online identifiers associated with your mobile device such as the Advertising ID number (but not your advertising profile) by advertisers and ad networks. Ovia allows such third parties to place cookies and similar technologies on your device in order to enable advertising. (Please refer to the "Cookies and Tracking Technologies" section of our main Privacy Policy for more information.) While these online identifiers and technologies cannot be used to readily identify you in the same way as your name or email, they could be used to identify you indirectly, and so they may constitute “personal information” under the CCPA. Ovia’s disclosure of this information for advertising might constitute a “sale” of personal information under the CCPA.

The categories of personal information that Ovia disclosed to third parties for a commercial purpose in the past 12 months, in connection with the advertising activities described in the above paragraphs, are set out below. Only Ovia’s advertising sales platform received information in all of these categories; Ovia’s advertisers and ad networks receive only information in categories A and F, but they may have the ability to attribute information in other categories to you based on advertising sold. If you opted in to share personal information with an advertiser or sponsor, Ovia shared the Category A, B and C identifiers that you elected to share. The reason we classify by these categories is because the CCPA requires it.

Category A: Identifiers.
This category includes personal information such as real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.
Category B: Personal Information defined in California Personal Records Law.
This category includes personal information such as name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Category C. Protected classification characteristics under California or federal law.
This includes personal information such as age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Category D. Commercial information.
Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Category E. Biometric information.
Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Category F. Internet or other similar network activity.
Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.
Category G. Geolocation data.
Physical location or movements.
Category I. Professional or employment-related information.
Current or past job history or performance evaluations.
Category K. Inferences drawn from other personal information.
Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Personal Information of Minors Under 16 Years of Age

Ovia does not sell the personal information of minors under 16 years of age. Ovia automatically opts all users under 16 years of age out of advertising on the Ovia apps.

Right to Request Deletion of Personal Information

You have the right to request that Ovia delete any of your personal information that we collected or maintained. To delete your personal information:

To complete the deletion, we will require you to re-enter your username and password. 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.

You may also submit a request by email to support@oviahealth.com. Ovia will require you to provide identifying information to verify your identity. If you have an Ovia account, Ovia may require you to verify your identity by providing your username and password.

We have the legal right to deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  1. 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.
  2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  3. Debug products to identify and repair errors that impair existing intended functionality.
  4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  6. 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.
  7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  8. Comply with a legal obligation.
  9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Opt-Out of Sale of Personal Information

You can opt out of the sharing of your personal information for personalized advertising.

To opt out within Ovia apps:

To opt out in your mobile browser, please visit https://optout.aboutads.info/#/ or https://optout.networkadvertising.org/# on each of your devices and browsers.

You may still see non-personalized advertising after you opt-out. These opt outs operate on a per-device basis, so if you use multiple devices you will need to opt out on each device.

If you have previously opted in for us to share your personal information (such as your email address) with our advertising partners, you may opt-out of such sharing at any time by contacting us at legal@oviahealth.com or Legal Department, Ovia Health, 308 Congress Street, Floor 6, Boston, MA 02210.

Non-Discrimination

We have a legal obligation not to discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Response Timing For Consumer Requests

If you make a request to exercise a consumer right, such as to obtain a data export or delete your data, we will respond within a reasonable timeframe. Many requests are processed automatically by the Ovia apps and so will be fulfilled almost immediately. If that is not practical, at a minimum we will acknowledge your request no later than 10 days after it is made, and will fulfill it within forty-five (45) days of its receipt. If we require more time (up to 45 days), we will inform you of the reason and extension period in writing.

If we cannot comply with a request, we will explain the reasons.

We do not charge a fee to process or respond to your 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.

Authorized Agent

Under the CCPA, you have the right to appoint an authorized agent to exercise your consumer rights to data portability, data deletion and to obtain a summary statement of personal information collected and shared.

If you wish to exercise your rights by using an authorized agent, you must submit your request by email to support@oviahealth.com. You will need to establish that the agent has been duly authorized by you, either by sending us a Power of Attorney showing the appointment of the agent or by entering your username and password to confirm the appointment.

Contact Information

If you have any questions or comments about this notice, the ways in which Ovia Health collects and uses your information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at legal@oviahealth.com or Legal Department, Ovia Health, 308 Congress Street, Floor 6, Boston, MA 02210.

Changes to Our Privacy Notice

The date that this Policy was last updated was: 15 April, 2020

Ovia Health reserves the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice in our apps and on our website and update the notice's last updated date. Your continued use of our apps following the posting of changes constitutes your acceptance of such changes.

More Information on How We Use Personal Information

In this Policy, the term “to provide and improve the Ovia apps” includes the following purposes:

In this Policy, the term “for Ovia’s operational management and administration” includes the following purposes:

What is Personal Information?

Personal information under the CCPA is information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device. Personal information includes online identifiers.

Personal information does not include: