Effective Date: August 1, 2022

  1. Introduction
  1. Scope
  1. What Information We Collect
  1. How We Use Your Information
  1. Use of Cookies
  1. Your Choices
  1. How We Share Your Information
  1. Third Party Links
  1. International Transfers of Personal Information
  1. Security
  1. Your California Privacy Rights
  1. Children’s Privacy
  1. Changes to This Privacy Notice
  1. Contact Us
  1. Introduction

Welcome! You have arrived at a website operated by Aver Inc. d/b/a Enlace Health or our affiliates (“Enlace Health,” “we”, “our” or “us”). Enlace Health delivers the only end-to-end solution that solves the infrastructure challenges driving today’s unsustainable healthcare system. Connecting payers, providers, and patients, Enlace™ empowers any type of healthcare delivery model, from facilitating retrospective programs to enabling risk for prospective programs. Combining executive-level healthcare DNA with an extensible technology platform, Enlace Health is the bridge from chaotic healthcare to the healthcare world when Triple Aim optimization is truly realized.

At Enlace Health, we take your privacy very seriously. This Privacy Notice (“Notice”) describes the types of personal information (as defined below) that we collect, how we use it, how and when we share it, and the rights you have with respect to your information. It also explains how we communicate with you and how you can make inquiries and requests to us about your information. We strive to help you understand how we use your information to improve our products, services, marketing, and interactions with you, as part of our commitment to maintaining your trust.

  1. Scope

This Notice applies when you use or access the publicly available website, www.enlacehealth.com (the “Site”); or otherwise provide Personal Information or interact with us online or in-person. We do not collect Protected Health Information (“PHI”), as defined by the Health Insurance Portability and Accountability Act of 1996 and its implementing guidance and regulations (“HIPAA”), on this Site. For clients using our Solutions, please see our Products Privacy Notice. For the purpose of this Notice, “Personal Information” means any personal information relating to an identified or identifiable inpidual that is protected by applicable privacy laws. We refer to all of the above as “Services.” By using the Services, you agree to our Terms of Service.

Where applicable, we indicate whether and why you must provide us with your Personal Information, as well as the consequences of failing to do so. If you do not provide Personal Information when requested, you may not be able to benefit from our Services if that Personal Information is necessary to provide you with the Services or if we are legally required to collect it.

If you have any questions about this Privacy Notice, please contact us at privacy@enlacehealth.com.

  1. What Information We Collect

This section describes what information we collect from you through our Site or Services. We may receive information (including Personal Information) in the following ways:

Information That You Provide to Us

As you interact with our Site or Services, we may collect Personal Information via webforms or inputs/uploads on our Site, as well as through webinars, tradeshows, telephone calls, emails and other communications with you. Specifically, we collect the following Personal Information:

  • Contact information. We may collect information such as your first and last name, email address, company name, business address, telephone numbers and mobile numbers;
  • Social media information. We may collect information such as social media handles, content and other data shared with us through third-party features that you use on our Site or Services or on our social media pages such as Facebook, Twitter, LinkedIn and YouTube;
  • Employment information. If you apply for employment with us, we may collect information such as your current or past employment or educational information, as well as references and referrals provided to us in connection with your employment applications; and/or
  • Other information. We may collect other information that could reasonably be used to identify you personally.

Your decision to provide us with Personal Information is voluntary, but if you choose not to provide any requested information, you may not be able to take advantage of all the features of the Site or Services.

Information That Is Automatically Collected

Like many businesses, we and/or our service providers may automatically collect and/or store certain information when you visit or interact with the Site or Services (“Usage Information”). This Usage Information may be stored and/or accessed from your personal computer, laptop, tablet, mobile phone, cable box, smart TV or other device (a “Device”) whenever you visit or interact with our Site. Usage Information may include:

  • Your IP address, IDFA, Android/Google Advertising ID, IMEI, cable box ID number or another unique identifier;
  • Your Device functionality (including browser, browser language, settings and behavior, operating system, hardware, mobile network information);
  • Referring and exit web pages and URLs;
  • The areas within the Site that you visit and your activities there, including remembering you and your preferences;
  • Your Device location or other location information, including the zip code, state or country from which you accessed the Services;
  • Your Device characteristics;
  • Certain other Device data, including the time of day you visit our Site or other information used to provide analytics or other usage information;
  • Information about your engagement with our emails; and

Statistical information about how both unregistered and registered users, collectively, use the Site and Services. This aggregate information is derived from Personal Information but cannot be tied back to you or your web browser.

Information Collected from Third Parties

The Site may include functionality that allows certain kinds of interactions between the Site and your account on a third-party website or application. The use of this functionality may involve the third-party site providing information to us. For example, we might obtain information about the traffic and usage of Enlace from third parties. These third parties also use cookies and other tracking technologies to capture information about your interactions with Enlace. Enlace does not have control over the information that is collected, used, and shared by these third parties. We encourage you to review the privacy statements of these third parties to understand their privacy practices.

We might also receive Personal Information from tradeshow organizers and webinar platforms that we utilize.

  1. How We Use Your Information

We use your information for business and commercial purposes, including to use or browse the Site, to offer our Services, to provide you with customer service, to prevent security and fraud, to provide marketing information about our products and services, and to perform website analytics.

We may use the information we collect about you in a variety of ways, including to:

To Provide Our Services

We process certain Personal Information when you access or use our services, including to facilitate the functionality of our Site and customize experiences and personalization when you are on our Site.

To Communicate with You

We may process certain information in order to communicate with you in relation to our Services, our marketing, and your requests, including to:

  • communicate with you about our Services and Products;
  • respond to your customer service inquiries and requests for demos or information; and
  • market our Products and Services to you via cross-contextual advertising (also known as retargeting) on social media and other platforms.

To Improve Our Site and Services

We want to ensure that our Site and Services are continually expanding so that we meet and exceed your needs and expectations. To do so, we may process certain Personal Information to maintain, improve, and analyze our Site or Services; and detect, prevent, or investigate suspicious activity or fraud.

To Comply with Applicable Laws

We may be required to process certain Personal Information under certain laws and regulations, such as tax laws, as well as to:

  • maintain appropriate records for internal administrative purposes; and
  • comply with applicable legal and regulatory obligations, and respond to lawful governmental requests, as needed.

To Enforce our Terms, Agreements, or Policies

To maintain a safe, secure, and trusted environment for you when you use our Site and Services, we may use Personal Information to ensure our terms, policies, and agreements with you and any third parties are enforced.

Evaluate Your Application for Employment

We may use Personal Information to evaluate your application for employment.

With Your Consent

We may process certain Personal Information in order to fulfill any other business or commercial purposes at your direction or with your consent.

  1. Use of Cookies

We use cookies and other tracking technologies to personalize your experience, analyze user trends, and improve the Services. These tracking technologies allow us to collect information such as your device type, browser type, interactions with our Site, geographic location, your web request, the date and time of your web request, your Internet Protocol address, the domain name of your Internet service provider and other data. If you can be identified from this information, for example by combination with other pieces of information, then we will treat this information as Personal Information.

You can alter the configuration of your browser to refuse to accept cookies, but it is possible that doing so may cause limited functionality of the Site. For example, we may not be able to recognize your computer or device, and you may need to log in every time you visit.

We may use “cookies” (a small text file sent by your computer each time you visit our site) or similar technologies to record log data. Many browsers default to accepting cookies. You may be able to change this setting in your browser and you can also clear your cookies. If you do, you may lose some functionality of our site. Check your browser’s help function to learn more about your cookie setting options.

We may use the following types of cookies:

  • Strictly necessary cookies. These cookies are essential for you to browse the website and use its features, such as accessing secure areas of the site. Cookies that allow web shops to hold your items in your cart while you are shopping online are an example of strictly necessary cookies. While it is not required to obtain consent for these cookies, what they do and why they are necessary should be explained to the user.
  • Functionality cookies. Also known as “preference cookies,” these cookies allow a website to remember choices you have made in the past, like what language you prefer, what region you would like weather reports for, or what your user name and password are so you can automatically log in.
  • Analytics cookies. Also known as “performance cookies,” these cookies collect information about how you use a website, like which pages you visited and which links you clicked on. None of this information can be used to identify you. It is all aggregated and, therefore, anonymized. Their sole purpose is to improve website functions. This includes cookies from third-party analytics services as long as the cookies are for the exclusive use of the owner of the website visited.
  • Advertising cookies. These cookies track your online activity to help advertisers deliver more relevant advertising or to limit how many times you see an ad. These cookies can share that information with other organizations or advertisers. These are persistent cookies and almost always of third-party provenance.

We might also use pixel tags, which are small graphic files that allow us and third parties to monitor the use of the Site and provide us with information based on your interaction with the Site. These tags may collect the IP address of the device from which you loaded the page and the browser type. Pixel tags are also used by our third parties to collect information when you visit our site, the links and other actions you take on our site, and we may use this information in combination with cookies to display targeted advertisements.

Other data technologies may be used that collect comparable information for security and fraud detection purposes.

If you have any questions about cookies or to generally find out more about cookies, visit this site.

  1. Your Choices

Cookies

On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive a notification when you are receiving a new cookie and how to turn cookies off. Please see the links below for guidance on how to modify your web browser’s settings on the most popular browsers:

Note, however, that if you reject our request to use cookies or turn cookies off, you may be unable to access certain parts of the Site and you may not be able to benefit from the full functionality of the Site. To find out more about cookies and similar technologies, including how to see what cookies and similar technologies have been set and how to manage and delete them, visit www.allaboutcookies.org, and/or www.youronlinechoices.com.

Do Not Track

Your browser may offer you a “Do Not Track” (“DNT”) option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites and platforms. There is no universally agreed-upon standard for what an organization should do when it detects a DNT signal. Currently, we do not monitor or take any action with respect to these signals or other mechanisms. You can learn more about Do Not Track here.

Communication Preferences

With your consent, Enlace communicates with you via a variety of print and digital media. To help us make e-mails more useful and interesting, we often receive a confirmation when you open e-mail from us if your computer supports such capabilities. You can opt out of receiving emails from us at any time. To manage your communications preferences with Enlace — or to opt out of communications entirely — please unsubscribe at the bottom of our emails or contact us at privacy@enlacehealth.com.

Analytics

We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here.

  1. How We Share Your Information

Services Providers

We share your Personal Information with our third-party service providers who provide services such as website hosting, data analysis, information technology, customer service, email delivery, online advertising, auditing, and other services.

Third Parties

We may share Personal Information with third-party partners such as tradeshow organizers and webinar platforms that we utilize.

We may also share information about your use of our Site and Services, and your interaction with our ads on other websites with our advertising partners to provide you with targeted advertisements or marketing communications we believe may be of interest to you. We collect and share some of this information directly with our advertising partners, and in some cases through the use of cookies or other technologies (which you may consent to, depending on your location).

For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s educational page here.

You can opt out of targeted advertising by visiting the following:

Other

Aside from the instances described above, we will only share your Personal Information:

  • to comply with the law;
  • to respond to claims or comply with legal process served on Enlace (e.g., a lawful subpoena, warrant, or court order);
  • to enforce or apply our policies or agreements;
  • to protect and defend our rights or property or that of our customers, employees, visitors, or the public;
  • in connection with a business transfer, sale, liquidation, or merger;
  • if we reasonably believe that an emergency involving immediate danger of death or serious physical injury to any person requires disclosure; and
  • with your consent.
  1. Third Party Links

Out Site may contain links to other websites such as social media platforms, other websites, and event and partner websites. These websites are not covered by this Privacy Notice. Please review the Privacy Notices or Policies of those websites to understand the privacy practices of these third parties.

  1. International Transfers of Personal Information

The Site is operated and targeted toward audiences in the United States. If you are located in another jurisdiction, please know that your information will be transferred to, stored, and processed in the United States. By using the Site and providing us with information, you consent to this transfer, processing and storage of your information in the United States. It is important to note that the privacy laws in the United States may not be as comprehensive as those in other countries such as those in the European Union (“EU”). Our service providers use appropriate safeguards to transfer your Personal Information to the United States.

  1. Security

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Where we have given you (or where you have chosen) a password so that you can access certain areas of our site, you are responsible for keeping this password confidential. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of your account has been compromised), please contact us at security@enlacehealth.com.

  1. Your California Privacy Rights

This section of our Privacy Notice applies to consumers who reside in California. We adopt this section to comply with the California Consumer Privacy Act (“CCPA”) and California Privacy Reform Act (“CPRA”).

If you are a California resident, you may be able to exercise the following rights. We will honor requests received to the extent required by applicable law and within the time provided by law.

Right to Access and Information Regarding Personal Information

You have the right to request that we disclose to you the categories and specific pieces of Personal Information we have collected about you. Specifically, you have the right to request that we disclose the following to you, in each case in the twelve-month period preceding your request:

  • The categories of Personal Information we have collected about you;
  • The categories of sources from which the Personal Information is collected;
  • Our business or commercial purpose for collecting or selling Personal Information;
  • The categories of third parties with whom we share Personal Information;
  • The specific pieces of Personal Information we have collected about you;
  • The categories of Personal Information about you, if any, that we have disclosed for monetary or other valuable consideration and the categories of third parties to which we have disclosed the information, by category or categories of Personal Information for each third party to which we disclosed the Personal Information; and
  • The categories of Personal Information about you that we disclosed for a business purpose.

Right to Deletion of Personal Information

You have the right to request that we delete Personal Information about you that we have collected from you. There may be certain exceptions to our obligation to delete your information such as if you have an existing account or transaction with us or if we have a legitimate business reason to keep your information.

Right to Opt-Out

You have the right to opt out of the sale of Personal Information. We do not sell Personal Information, but we recognize that some privacy laws define “personal information” in such a way that making available identifiers linked to you for a benefit may be considered a “sale.” To opt-out of this, please click on this link.

Right to Non-Discrimination

We may not discriminate against you because you have exercised any of the aforementioned rights, including by:

  • Denying you goods or services;
  • Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;
  • Providing you a different level or quality of goods or services; or
  • Suggesting that you will receive different price or rate for goods or service or at a different level or quality of goods or services.

However, as permitted by the CCPA, we may offer you certain financial incentives. Any CCPA-permitted financial incentive we offer will reasonably relate to your Personal Information’s value. Participation in a financial incentive program requires your prior opt-in consent, which you may withdraw at any time.

Personal Information We Collect about California Consumers

We collect certain types of Personal Information about you during your relationship with us, as stated above. In particular, we collected the following categories of Personal Information from California consumers within the last twelve (12) months:

Category of Personal Information CollectedCollected (Yes/No)Sources of Personal Information Collected
Identifiers such as name, address, email address, phone number, unique id, and other identifiers listed in the Personal Information Collected section above.YesYou

Automatically

Third Parties

The following categories of Personal Information described in California Civil Code §1798.80(e): (1) the Personal Information listed in the preceding bullet point as “identifiers,” and (2) the other information that identifies, relates to, describes, or is capable of being associated with a particular inpidual that we describe in “Information We Collect” above.YesYou

Automatically

Third Parties

Characteristics of protected classifications under California or federal law list any of these that you collect: 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.NoN/A
Commercial information, including information about orders or purchases of any of our products or services; registration information, specials, and information you provide or submit to us when you participate in any event, program, contest, survey or other promotion that we may offer from time to time.NoN/A
Biometric Information.NoN/A
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with our websites or Enlace pages or accounts on any third-party social media platforms.YesAutomatically
Geolocation data.NoN/A
Audio information from calls placed with customer service and accounting centers which may be reported, and electronic information in the form of Internet or other electronic network activity information described above.YesAutomatically
Professional or employment-related information.YesYou

Automatically

Third Parties

Education information.NoN/A
Inferences drawn from (1) the information we collect when you visit our websites, tools, widgets and plug-ins, (2) information we collect, including through third-party suppliers, regarding content and other data posted on the Internet (such as public locations on the Internet), and (3) information about consumers preference and behavior that we collect on our websites or purchase from third parties in order to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.YesThird Parties
Sensitive Personal Information such as racial / ethnic origin, political opinions, religious / philosophical beliefs, genetic data, biometric data, sex life / sexual orientation, past or spent criminal convictions, mail, email and text message content, precise geolocation data, social security, driver’s license, state identification card, or passport number, account login, financial account, debit card, or credit card number.NoN/A

Requests to Exercise Your Rights

You or your authorized agent may make a request to access, correct, delete or opt-out of the disclosure of your Personal Information for business purposes. You may also make a verifiable consumer request on behalf of your minor child if you believe we have received their information inadvertently. You may request to exercise the aforementioned rights by:

Please note that we may take steps to verify your identity and residency before granting you access to information or acting on your request to exercise your rights, as required or permitted by law. If you use an authorized agent, we may require proof of written authorization you have given to make the request. We may limit our response to your exercise of the above rights as permitted by law. We will confirm receipt of the request within 10 business days describing our verification process. We will respond to your request within 45 days or let you know if we need additional time.

Data Sharing for Direct Marketing Purposes

California Civil Code § 1798.83 further permits California residents to request certain information regarding our disclosure of Personal Information to third parties for their direct marketing purposes. If you are a California resident, you may ask us to refrain from sharing your Personal Information with certain of our affiliates and other third parties for their marketing purposes. Please tell us your preference by contacting us at privacy@enlacehealth.com.

  1. Children’s Privacy

Our Site is not directed at children under 18 years of age, and we do not knowingly collect or receive Personal Information from them. If you believe that we have received Personal Information from a child under the age of 18, you may contact us at privacy@enlacehealth.com to request deletion of that information.

  1. Changes to This Privacy Notice

We may change this Privacy Notice at any time. We will post all changes to this Privacy Notice on this page and will indicate at the top of the page the modified notice’s effective date. We therefore encourage you to refer to this page on an ongoing basis so that you are aware of our current privacy notice. If required by the applicable law, we will notify you of the changes. By continuing to use the Site and/or the Services or providing us with information following such a replacement Notice being uploaded, you agree that you will be deemed to have agreed to be bound by the Privacy Notice as changed.

  1. Contact Us

If you have any questions or suggestions regarding this Privacy Notice, please contact us at:

Aver Inc. d/b/a Enlace Health
Attn. Privacy Officer
41 South High Street, Suite 2350
Columbus, Ohio 43215

Email: privacy@enlacehealth.com
Contact number: 877.841.2775