PRIVACY POLICY

PLEASE READ THIS PRIVACY POLICY (THE “PRIVACY POLICY”) CAREFULLY BEFORE ACCESSING ANY PAGES IN THIS OR ANY OTHER BRAEBURN WEBSITE OR BEFORE ACCESSING, DOWNLOADING, VIEWING, OR USING, IN ANY MANNER, FROM YOUR SMART PHONE OR OTHER MOBILE DEVICE, ANY APPLICATION (OR “APP”), DISTRIBUTED, PRODUCED, DEVELOPED, MARKETED, OR MADE AVAILABLE BY BRAEBURN THROUGH ANY BRAEBURN WEBSITE (COLLECTIVELY, THE “SITE”).

Braeburn Inc. (Braeburn) respects the privacy of visitors to our Site and those who wish to access specific content or services (referred to individually as “User” and collectively as “Users”).

This Privacy Policy describes what information we may collect from you or on your behalf, how we use that information, and what we do to protect it. By using the Site, you expressly consent to the collection, use, and disclosure of your personal information as described in this Privacy Policy.

This Privacy Policy is incorporated into and is subject to the Braeburn Terms of Use. Your use of the Site and any personal information you provide on the Site is subject to the Terms of this Privacy Policy and the Braeburn Terms of Use.

THE INFORMATION BRAEBURN COLLECTS:

Personally Identifiable Information: You may provide to Braeburn what is generally called “Personally Identifiable Information” (sometimes “PII”) (such as your name, email address, postal mailing address, home/mobile telephone number, , billing information, personally identifiable Health Information, and the names and email addresses of other individuals to whom you forward content from the Site) when using the Site. For example, if you use the Site to contact Braeburn, we will ask for your email address so that we can respond to you.

Health Information: You may provide to Braeburn what is generally called “Health Information” (including but not limited to any and all spoken or written information about your health, treatment, medications, insurance benefits, and other data collected and maintained by Braeburn as part of your communication). By contacting Braeburn via the Site, you authorize Braeburn to receive, use, disclose, transmit, and maintain Health Information on your behalf in connection with any ongoing support and services provided to you by Braeburn.

Automatically Collected Information: When you visit the Site, we may automatically record certain information from your web browser by using different types of technology. This “Automatically Collected Information” may include your internet protocol address (“IP Address”), web browser type, traffic patterns, the web pages or sites that you visit just before or just after the Site, the pages you view on the Site, and the dates and times that you visit the Site.

We may collect this non-personally identifiable information through the use of website technology, including “cookies,” and similar tools. A “cookie” is a small, text-only file that is placed on your hard drive to allow us to recognize you if you return to the website using the same computer and browser.

You can set your browser to notify you when you receive a cookie, giving you a chance to decide whether to accept it or not. Alternatively, you can set your browser to disable cookies, and can remove existing cookies. Each browser is different, so you will need to check your specific browser’s “Help” menu to learn how to change the cookie preferences. While you may decide to not accept cookies, by doing so, you may not be able to experience the full functionality of the website.

Registration: Some of the services provided on this Site may require registration. When registering with Braeburn, you may need to complete certain data fields as well as provide a username and password. This registration discloses your identity. Please note that in the event you decide to withhold certain requested personal data, it may not be possible for you to access certain parts of the Site or access certain services.

Please note that from time-to-time Braeburn may operate other websites, applications, or services that do not link to this Privacy Policy and may be subject to separate privacy notices, which will be provided separately or made available via those sites, applications, or services. In such cases, those privacy notices shall supersede this Privacy Policy.

HOW WE USE YOUR PERSONAL INFORMATION

Subject to applicable data protection laws, we may use your personal information for the following purposes: (i) to provide you with the services and information offered through the Site; (ii) to contact you and respond to your requests and inquiries; (iii) for business administration, including statistical analysis; (iv) to personalize your visit to the Site and to assist you while you use the Site; (v) to improve the Site by helping us understand who uses the Site; (vi) to contact you to tell you about products and services offered by us which we believe may interest you; and (vii) for fraud prevention and detection and to comply with applicable laws, regulations or codes of practice.

SHARING OF YOUR PERSONAL INFORMATION

We may use selected third parties to provide us with services, including companies that provide us with technical support and assistance in respect of the Site, who may have access to your personal information while performing services on our behalf. Our affiliates may also have access to your personal information including through or in connection with this Site for the purposes set out in this Privacy Policy.

Similarly, we may share your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, fight fraud, collect a debt, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property, or the rights, property or safety of others, including to advisers (e.g. lawyers, auditors, accountants), law enforcement, judicial and regulatory authorities. We may also transfer your personal information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets, or shares (including in connection with any bankruptcy or similar proceedings.)

The servers used in the operation of the Site automatically identify a computer by its IP address. If we, in good faith, determine that you have or are attempting to misuse or harm the Site, we may investigate and cooperate with appropriate law enforcement to protect our rights or property.

RETENTION OF PERSONAL INFORMATION

We will retain your PII for as long as reasonably necessary to fulfil the purposes for which it was obtained, including for the purposes of satisfying any legal, regulatory, tax, accounting, or reporting requirements. We may retain your PII for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation and we believe the PII is relevant.

To determine the appropriate retention period for PII we consider: the necessity to retain the PII; the amount, nature, and sensitivity of the PII; the potential risk of harm from unauthorized use or disclosure of your PII; the purposes for which we process your PII; whether we can achieve these purposes through other means; and the applicable legal, regulatory, tax, accounting or other similar requirements.

SOCIAL NETWORKING SERVICES

We use social networking services such as Twitter, LinkedIn, Facebook, and YouTube to communicate with the public about our work. When you communicate with us using these services, we may collect your personal information, but we only use it to help us to communicate with you and the public. The social networking service may also handle your personal information for its own purposes. These services have their own privacy policies. You can access the privacy policies for Twitter, Facebook and YouTube (a Google company) on their websites.

ONLINE PRIVACY FOR CHILDREN

Braeburn is committed to protecting the privacy of children. We do not intend to collect personally identifiable information from children under 18 years old. If a child has provided us with personally identifiable information, the parent or guardian of that child may contact us.

SECURITY

We maintain reasonable physical, electronic, and procedural safeguards designed to help us protect your information against: (a) accidental or unlawful destruction; (b) accidental loss; and (c) unauthorized alteration, disclosure, or access. However, no security systems are impenetrable. We cannot guarantee the security of our database, website, or services, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet. We are not responsible for the actions of third parties.

Notice to California Residents

This PRIVACY NOTICE FOR CALIFORNIA RESIDENTS supplements the information contained in the Privacy Statement of Braeburn Inc. and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws.  Any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

We collect 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”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Personal information we collect CCPA categories of personal information (Definitions are available here) Sources of personal information Purposes for which we may collect and use personal information
  • Correspondence
  • Digital Information
  • Demographic information
  • Device data
  • Online activity data
  • Identifiers
  • Personal information categories
  • Professional or employment related
  • Protected classification characteristics
  • Commercial Information
  • Inferences
  • Internet or Network Information
  • Geolocation data
  • Online Identifiers
  • You
  • Business partners
  • You
  • Automatic collection
  • To provide services and information
  • To respond to inquiries
  • Hiring
  • To operate the site
  • To create anonymous data for analytics

This notice does not apply to the information we collect in connection with clinical trials, or to any health or medical information we collect that is otherwise governed by California’s Confidentiality of Medical Information Act or the Health Insurance Portability and Accountability Act of 1996.  This notice also does not apply to information related to our business contacts (including healthcare providers).

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract. We do not sell personal information.

California Residents’ Privacy Rights

The information provided in this section applies only to California residents.

The CCPA grants California residents the following rights.

You can request information about how we have collected, used and shared and used your Personal Information during the past 12 months.

  • Access. You can request a copy of the personal information that we maintain about you.
  • Deletion. You can ask us to delete the personal information that we collected or maintain about you.

You are entitled to exercise the rights described above free from discrimination. Please note that the CCPA limits these rights by, for example, prohibiting us from providing certain sensitive information in response to an access request and limiting the circumstances in which we must comply with a deletion request.  If we deny your request, we will communicate our decision to you.

How to submit a request

  • To request access to or deletion of personal information:
  • Identity verification. We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.
  • Authorized agents. California residents can empower an “authorized agent” to submit requests on their behalf.  We will require the authorized agent to have a written authorization confirming that authority.

CHANGES TO THIS PRIVACY POLICY

We reserve the right, in our sole discretion, to modify, alter, or otherwise update this Policy at any time, and you agree to be bound by such modifications, alterations, or updates. We will notify you of material changes to this Policy by posting the revised policy with the date it was revised on this page. We will not materially alter the use of personally identifiable information about you that we have already collected without contacting you directly and seeking your affirmative consent. Your continued use of the website constitutes your agreement to this Policy and any updates. We encourage you to periodically review this Policy to stay informed about how we are protecting the personally identifiable information we collect.

NON-U.S. USER

Please note that the website is directed towards users who reside in the United States. It is not our intent to gather personally identifiable information from individuals residing outside of the United States. If you are located outside of the United States, the information you provide to us will be transferred to the United States whose laws may not provide the same level of protection for personally identifiable information as your home country. By using this website, you consent to this transfer. You also consent to the adjudication of any disputes arising in connection with this website in the federal and other courts of, and in accordance with the laws of, the state of Delaware.

HOW TO CONTACT US?

If you have any questions, comments, or concerns regarding this Privacy Policy, please contact us here.

Last Updated: September 3, 2024