This notice describes how Personal Data (defined below) and/or medical information about you may be used and disclosed and how you can obtain access to this information. Please review it carefully.
We at Salvo Studios, Inc. d/b/a Salvo Health (“we”, “us”, “the Company”, or “Salvo Health”) value your privacy and are committed to keeping your personal data confidential. We use your data solely in the context of providing the Salvo Health mobile app (the “App”) and web-based platform (“Web App”) (collectively, the “Platform”), and providing health care and coaching services for those managing chronic conditions, including all relevant content and functionality associated with the Platform and the health care and coaching services (collectively, the “Services”) for use by qualified providers (“Salvo Provider”) and health coaches (“Salvo Health Coach”) to provide services and care to members (“Member Users”).
For additional information related to how we use and disclose your Personal Data, health data, and/or medical records data, please contact our Privacy Officer at firstname.lastname@example.org.
We collect four types of information from our Member Users: (i) demographic data; (ii) health data; (iii) support data; and (iv) technology data. Each category of data is explained in depth below.
Demographic Data: Salvo Health collects demographic data from Member Users, which may include, but not be limited to, your first and last name, birthdate, phone number, and e-mail address. The collection of this demographic data is primarily used to create your User Account, which you can use to securely receive the Services.
Health Data: In addition to demographic information, we will collect information regarding your health conditions, including, but not limited to, age, gender, weight, height, medical history, symptoms, and communications between you and the Salvo Provider and/or Salvo Health Coach who is providing services to you via the Platform. We collect this information to provide you with the Services and to provide the Salvo Provider and/or Salvo Health Coach associated with your care with the information required to provide medical treatment through the Platform.
Technology Data: We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain Personal Data from your computer or mobile device as you navigate our Platform or interact with emails or other communications we have sent you. The information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, help us provide and improve our Services, and ensure the proper functioning and security of the Platform and Services.
More specifically, Salvo Health processes your Personal Data for the following legitimate business purposes:
Salvo Health uses third-party service providers to monitor and analyze the use of the Platform as part of our Services. The analytics services we use may include, but are not limited to: Google Analytics, Auth0, Braze, and a Customer Data Platform (“CDP”).
The Personal Data we collect through the Platform will be stored on secure servers in the United States. Personal Data may be transmitted to third parties, which parties may store or maintain the data on their secure servers. These third parties are not permitted to transfer your Personal Data outside of the United States. The App is “native” to your device, meaning information you enter into the App may also be stored directly on the device that you use to access and enter information into the App.
We may share your personal information with the following categories of individuals/entities:
Business Partners and Vendors: We share Personal Data with a limited number of partners, service providers, and other persons/entities who help run our business (“Business Partners”). Specifically, we may employ third-party companies and individuals to facilitate our Services, provide Services on our behalf, perform Service-related functions, or assist us in analyzing how our Services are used. Our Business Partners are contractually bound to protect your Personal Data and to use it only for the limited purpose(s) for which it is shared. Business Partners’ use of Personal Data may include, but is not limited to, the provision of services such as data hosting, IT services, customer services, and payment processing.
Our Advisors: We may share your Personal Data with third parties that provide advisory services to Salvo Health, including, but not limited to, our lawyers, auditors, accountants, and banks (collectively, “Advisors”). Personal Data will only be shared with Advisors if Salvo Health has a legitimate business interest in the sharing of such data.
Provider and Health Coach Users: As part of the Services, we will share your Personal Data with your specified Salvo Provider and/or Salvo Health Coach. If at any point you want to deny access to one or more Salvo Provider(s) and/or Salvo Health Coach(es), you can do so by emailing email@example.com.
Third Parties Upon Your Direction or Consent: You may direct Salvo Health to share your Personal Data with third parties. Upon your request and consent, we may share such Personal Data with those third parties that you identify.
Third Parties Pursuant to Business Transfers: In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Salvo Health’s corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may share your Personal Data with a third party.
Salvo Health retains your Personal Data only as long as necessary and as required for our business operations, the provision of Services, archival purposes, and/or to satisfy legal requirements. The exact period of retention will depend on: (i) the amount, nature, and sensitivity of the Personal Data; (ii) the personal risk of harm for unauthorized use or disclosure; (iii) the purposes for which we process your Personal Data, including whether those purposes can be achieved through other means; and (iv) business operations and legal requirements. In general, Salvo Health strives to retain your data for no longer than 10 years after your Account is closed (the “Retention Period”); however, the above factors may extend or decrease this Retention Period.
At the end of the applicable Retention Period, we will remove your Personal Data from our databases and will require that our Business Partners remove any identifiable Personal Data from their databases. If there is any data that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing of such data. Please note that once we disclose your Personal Data to third parties, we may not be able to access that Personal Data and we cannot force the deletion or modification of such information by third parties.
Salvo Health does not knowingly collect Personal Data from individuals under the age of 18. Additionally, our Services are not directed to individuals under the age of 18. We request that these individuals not provide Personal Data to us. If we learn that Personal Data from users under the age of 18 has been collected, we will deactivate the User Account associated with that data and take reasonable measures to promptly delete such data from our records. If you are aware of a user under the age of 18 accessing the Services or Platform, please contact us at firstname.lastname@example.org.
If you are a resident of California under the age of 18 and have registered for a User Account with us, you may ask us to remove information that you have inputted through our Platform.
As a user of Salvo Health’s Services and Platform, you have certain rights relating to your Personal Data. These rights are subject to local data protection and privacy laws, and may include the right to:
Where the processing of your Personal Data by Salvo Health is based on consent, you have the right to withdraw that consent at any time. If you would like to withdraw your consent or exercise any of the above rights, please contact us at email@example.com.
You have the right to request restrictions on uses and disclosures of your Personal Data. While we are not required to agree to all restriction requests, we will attempt to accommodate reasonable requests when appropriate.
You may change your email address and other contact information by accessing your Salvo Health User Account. If you need to make changes or corrections to other information, you may contact us at firstname.lastname@example.org. In order to comply with certain requests to limit use of your Personal Data, we may need to terminate your ability to access and/or use some or all of the Services. BY REQUESTING TO LIMIT USE OF YOUR PERSONAL DATA OR DELETE PERSONAL DATA, YOU ACKNOWLEDGE AND AGREE THAT SALVO HEALTH WILL NOT BE LIABLE TO YOU FOR ANY CORRESPONDING LIMITATION IN THE SCOPE OF SERVICES OR TERMINATION OF SERVICES AS NECESSARY TO COMPLY WITH YOUR REQUEST.
You have the right to request deletion of any Personal Data from your User Account or the Salvo Health Platform. To request deletion of your Personal Data, please email us at email@example.com and include a description of the Personal Data you would like removed. We will respond to all requests for data deletion as soon as reasonably possible.
Should you decide to delete your User Account entirely, you may do so through the Salvo Health Web App or by emailing firstname.lastname@example.org. By terminating your User Account, you agree that you will not be able to access any information previously contained in your User Account. You further understand that it may not be technologically possible to remove all of your Personal Data from our systems. While we will use reasonable efforts to remove your Personal Data, the need to back up our systems to protect information from inadvertent loss means a copy of your Personal Data may exist in a non-erasable form that will be difficult or impossible for us to locate or remove.
Salvo Health understands the importance of data confidentiality and security. We use a combination of reasonable physical, technical, and administrative security controls to: (i) maintain the security and integrity of your Personal Data; (ii) protect against any threats or hazards to the security or integrity of your Personal Data; and (iii) protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm to you.
While Salvo Health uses reasonable security controls, WE CANNOT GUARANTEE OR WARRANT THAT SUCH TECHNIQUES WILL PREVENT UNAUTHORIZED ACCESS TO YOUR PERSONAL DATA. SALVO HEALTH IS UNABLE TO GUARANTEE THE SECURITY OR INTEGRITY OF PERSONAL DATA TRANSMITTED OVER THE INTERNET, AND THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. ACCORDINGLY, WE DO NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY PERSONAL DATA YOU TRANSMIT TO US. YOU ASSUME THE RISK THAT UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE FAILURE, AND OTHER FACTORS MAY COMPROMISE THE SECURITY OF YOUR PERSONAL DATA AT ANY TIME.
Salvo Health stores Personal Data on secured servers and uses a combination of technical, administrative, and physical safeguards to protect your personal information. Such safeguards include, but are not limited to, authentication, encryption, backups, and access controls.
You are solely responsible for preventing unauthorized access to your devices and your User Account by protecting your username and password (collectively, your “Account Credentials”) and limiting access to your devices. Salvo Health has no access to or control over your device’s security settings, and it is your responsibility to implement any device-level security features and protections you feel are appropriate (e.g., password protection, encryption, remote wipe capability). We recommend that you take all appropriate steps to secure any device that you use to access our Services and Platform.
Please note that Salvo Health will never send you an email requesting confidential information, such as account numbers, usernames, passwords, or Social Security Numbers. If you receive a suspicious email from Salvo Health, please notify us at email@example.com.
Further, if you know of or suspect any unauthorized use of your User Account or disclosure of your Account Credentials or any other security concern, please notify Salvo Health immediately
Salvo Health takes the security of your Personal Data seriously. In the event of a data or security breach, Salvo Health will take the following actions: (i) promptly investigate the security incident, validate the root cause, and, where applicable, remediate any vulnerabilities within Salvo Health’s control which may have given rise to the security incident; (ii) comply with laws and regulations directly applicable to Salvo Health in connection with such security incident; (iii) as applicable, cooperate with any affected Salvo Health Member User or client in accordance with the terms of Salvo Health’s contract with such Member User or client; and (iv) document and record actions taken by Salvo Health in connection with the security incident and conduct a post-incident review of the circumstances related to the incident and actions/recommendations taken to prevent similar security incidents in the future. Salvo Health will notify you of any data or security breaches as required by and in accordance with applicable law.
As a condition to joining the Salvo Health waitlist, we will ask for your consent to use your Personal Data to contact you with newsletters, marketing, or promotional materials and other information that may be of interest to you. You may opt-out of receiving any marketing or advertisement materials from Salvo Health at any time by following the unsubscribe link.
We may send communications, including emails, to you regarding your User Account and the Services or Platform. You can choose to filter any User Account, Services, and Platform emails using your email settings, but we do not provide an option for you to opt-out of these communications.
If you consent to receive marketing or other communications not related to your User Account or the Services/Platform, we will provide you with the option to opt-out of such marketing communications within the applicable message.
If you prefer, you can usually choose to set your browser to remove cookies and reject cookies. If you enable a do not track signal or otherwise configure your browsers to prevent us from collecting cookies, you will need to reenter your login information each time you visit the login page. You may also be unable to take advantage of some of the Services.
Some web browsers may transmit do not track (“DNT”) signals to websites with which the user communicates. To date, there is no industry standard for DNT and users cannot know how a given company responds to a DNT signal they receive from browsers. Salvo Health is committed to remaining apprised of DNT standards. However, Salvo Health does not support DNT browser settings and does not currently participate in any DNT frameworks that would allow Salvo Health to respond to signals or other mechanisms regarding the collection of your personal information.
If you are a California resident, the California Consumer Privacy Act (“CCPA”) may apply to you. Please see the CCPA Attachment for an explanation of your rights.
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask for and obtain from us an annual list identifying the categories of personal customer information which we shared, if any, with our affiliates and/or third parties in the preceding calendar year for marketing purposes. This list will be provided free of charge. Contact information for such affiliates and/or third parties must be included. If you are a California resident and would like a copy of this notice, please submit a written request to the following address:
Salvo Studios, Inc.
335 Madison Avenue
New York, New York 10017