Caregility may change this policy from time to time by updating this page. You should check this page from time to time to ensure that you are happy with any changes. If we make a material change to this policy, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this website prior to the change becoming effective.
This policy is effective from January 1, 2022.
Children Under the Age of 13
Our website, products and services are not intended for children under 13 years of age. No one under age 13 may provide any information through our website, products or services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this website or on or through any of our products or services or any of their features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us at the contact information set forth below.
What we collect
We may collect the following information from you:
- information by which you may be personally identified, such as name, job title, email address, phone number, physical and/or postal address and other information relevant to customer surveys and/or offers (“personal information”); and
- Information that is about you but does not identify you.
We may collect the following information automatically from your device:
- Information about you that does not directly identify you, such as device type or IP address.
Information we collect on or through our website, products or services may include:
- Information that you provide by filling in forms on our website or in connection with our products or services. We may also ask you for information when you report a problem to us.
- Information you provide to us at a trade show or other event.
- Records and copies of your correspondence (including email addresses), if you contact us.
- Your responses to surveys that we might ask you to complete for research purposes.
- Details of transactions you carry out with us, including, through our website and of the fulfillment of your orders.
- Your search queries on our website.
We may also collect your contact information, including name and email address, from a third party, in the case where your employer licenses our services and provides you with an account. If you believe your personal information has been provided to us from your employer and would like to request that it be removed from our database, please contact your employer for this request.
If one of your contacts invites you to a meeting using our service, we will collect your name and email address in order to schedule that meeting and send you a meeting notification. Your personal information will not be used for any other purpose.
Individuals may have the right to limit the use and disclosure of their personal information as required by the Privacy Shield’s Principles, such as whether your personal information is disclosed to a third party or used for purposes materially different from the purpose for which the personal information was originally collected or subsequently authorized by you.
Should we decide to use your information for a purpose that is materially different from the purpose(s) for which it was originally collected or subsequently authorized by you, we will obtain your consent at that time or establish the use under a lawful basis under applicable law, before such use occurs.If you wish to limit the use and disclosure of personal information in accordance with the Privacy Shield Principles, please contact us at firstname.lastname@example.org, or call us at 855-499-7527 (available in U.S. only).
We use traffic log cookies to identify which pages are being used. This helps us analyze data about web page traffic, gather demographic information about our user base as a whole and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.
Overall, cookies help us provide you with a better website experience, by enabling us to monitor which pages you find useful and which you do not. Cookies also facilitate customer engagement by providing relevant advertisement. A cookie in no way gives us access to your computer or any information about you, other than the data you choose to share with us.
You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to disable cookies if you prefer. This may, however, prevent you from taking full advantage of the website.
As is true of most websites, we gather certain information automatically. This information may include Internet protocol (IP) addresses, browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
What we do with the information we gather
We require this information to understand your needs and provide you with a better service, and, in particular, for the following reasons:
- To provide you with a service
- To keep internal records
- To provide usage reports and statistics to your company under which your account for services is contracted with.
- To improve our products and services
- To provide customer service and technical assistance
- To periodically send promotional emails about new products, special offers or other information which we think you may find interesting using the email address which you have provided
- Occasionally we may contact you for market research purposes. We may contact you by email, phone or mail. We may use the information to customize the website according to your interests
- To re-engage web site visitors with relevant products and services information.
Sharing with Third Parties
We may share your information with third parties who provide services on our behalf to help with our business activities. These companies are authorized to use your personal information only as necessary to provide these services to us.
These services may include:
- Providing customer service
- Fulfilling services
- Conducting research and analysis
- Providing cloud computing infrastructure and services
We may share your information with a service provider to send you marketing communications on our behalf. If you would like to discontinue receiving this information, you may update your email preferences by using the “Unsubscribe” link found in emails we send to you or by contacting us at email@example.com, or call us at 855-499-7527 (available in U.S. only).
- To our subsidiaries and affiliates.
- To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Caregility’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Caregility is among the assets transferred.
- To fulfill the purpose for which you provide it.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
- To enforce or apply our terms of any agreements, including for billing and collection purposes.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Caregility, our customers, or others.
Processing of Employment Applications
We are committed to ensuring that your information is secure. In order to prevent unauthorized access or disclosure, we have put in place generally accepted physical, electronic and managerial procedures to safeguard and secure the information we collect online. If you have any questions about the security of your personal information, you can contact us at privacy@Caregility.com, or call us at 855-499-7527 (available in U.S. only). Your personal information will not be used for any other purpose.
Links to other websites or applications
Use of Third Party Applications, Services and Plug-ins
Accessing and updating your personal information
Upon request Caregility will provide you with information about whether we hold any of your personal information. You may access, correct, or request deletion of your personal information by contacting us at privacy@Caregility.com, call us at 855-499-7527 (available in U.S. only), or writing to us at the address below. We will respond to your request within a reasonable time frame. We hold your information for as long as is necessary for the purpose for which it was collected.In certain circumstances, we may be required by law to retain your personal information, or may need to retain your personal information to continue providing a service. We may not accommodate a request to change information if we believe the change would cause the information to be incorrect.
Controlling your personal information
We may use your personal information to send you promotional information about third parties which we think you may find interesting if you tell us that you wish this to happen.
You may choose to restrict our collection or future use of your personal information in the following ways:
- If you have previously agreed to us using your personal information for direct marketing purposes, you may change your mind at any time by writing to us at the address below, emailing us at privacy@Caregility.com, call us at 855-499-7527 (available in U.S. only), or clicking on the “unsubscribe” link found in the emails we send to you.
Caregility’s SMS Opt-in Compliance Overview
Caregility offers a platform enabling healthcare professionals to seamlessly connect with patients and their relatives through SMS-invited consultations. As network carriers introduce mandatory opt-in rules for SMS communication, Caregility is committed to ensuring that its operations adhere to all regulatory requirements.
Compliance with New Rules:
While the new rules necessitate opt-in capabilities for SMS recipients, Caregility leverages a unique approach. Our clients, primarily healthcare service providers, collect and input the phone numbers of patients and related individuals into our system, initiating the SMS invitation. Given that these numbers are directly sourced, Caregility communicated to its SMS API provider, Twilio, asserting that the workflow is exempt from the new opt-in requirements.
As the recipients are not direct clients of Caregility, the platform cannot solicit opt-in consent from them. Instead, Caregility’s stance is that consent should be secured by its clients prior to the SMS invitations. While CTIA guidelines highlight best practices, they aren’t obligatory. By acting as an intermediary, Caregility believes it fits the criteria of Non-Consumer or Message Sender, delegating consent responsibility to its clients.
Caregility’s GDPR Standpoint:
From the GDPR perspective, all organizations must have a legitimate foundation for processing personal data, such as phone numbers. In healthcare scenarios within the EU, a vital interest, especially during life-threatening situations, supersedes consent for personal data processing. Given that Caregility’s clients are the primary collectors of contact information and only instruct Caregility for SMS purposes (not marketing), the need for direct marketing-based opt-ins seems non-applicable.
Moreover, while Caregility operates as an intermediary in the U.S., the GDPR’s jurisdiction doesn’t extend there, and currently, the U.S. lacks a federal law dictating personal data processing terms.
In light of evolving regulations, Caregility remains steadfast in its dedication to maintaining the highest standards of compliance. By aligning with its clients and clarifying roles in data collection and processing, Caregility aims to ensure a seamless, compliant, and efficient communication experience for all involved parties.
EU-US, Swiss, and UK Data Privacy Framework
Caregility is responsible for the processing of personal data it receives, under the DPF, and subsequently transfers to a third party acting as an agent on its behalf. Caregility complies with the DPF Principles for all onward transfers of personal data from the EU, UK, and Switzerland, including the onward transfer liability provisions.
The Federal Trade Commission [OR U.S. Department of Transportation] has jurisdiction over Caregility’s compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF. In certain situations, Caregility may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, Caregility commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to TRUSTe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. These dispute resolution services are provided at no cost to you.
For complaints regarding DPF compliance not resolved by any of the other DPF mechanisms, you have the possibility, under certain conditions, to invoke binding arbitration. Further information can be found on the official DPF website.
Slavery and Human Trafficking Statement
Our Recruitment and Employment Principles
We embrace principles supportive of equal treatment without discrimination and with the protection of employment law for all staff.
They are broadly based on principles developed by the United Nations and Institute for Human Rights and Business regarding migrant workers. However, we have chosen to extend relevant principles to all our staff.
We treat all staff equally; without discrimination and with respect for their human rights. All staff enjoy the protection of relevant UK law in respect of their employment. In particular:
- We bear the full costs of recruitment and do not charge staff fees for hiring, placing or promoting them.
- We provide written statements of terms and conditions of employment to all staff as required by law. These documents explain everything in a clear and transparent way.
- We support the right to seek, obtain and hold employment without discrimination and with complete respect for dignity.
- We do not coerce anyone to work for us. When you choose to work for us you do so voluntarily.
- You must prove your entitlement to work in the UK. However, we do not hold or retain original passports, identity documents or residency papers. You should retain such documents personally.
- Everyone is paid regularly, in accordance with their terms and conditions. We provide a written summary of pay and deductions (pay slip) on every occasion.
- Everyone has the right to join or not join a trade union at their complete discretion.
- We provide safe and decent working conditions with suitable training as necessary. Our operations comply with or exceed statutory health and safety standards.
- We provide formal grievance provisions through which staff are free to lodge a work related complaint or raise a matter of concern.
- We do not impede anyone’s freedom of movement or their opportunity to seek employment elsewhere. We also encourage our suppliers to endorse such principles to demonstrate their opposition to human trafficking and modern day slavery.
81 Corbett Way
Eatontown, NJ 07724, USA