Privacy Statement
Effective Date: November 29th, 2023
Table of Contents
● Introduction
● How we collect and use (process) your personal information
● Use of the Services
● How we use your data
● Hosting your data
● Data Subject rights
● Data storage and retention
● Children’s data
● Questions, concerns, or complaints
Introduction
Cofactor AI, Inc. (“Cofactor AI”, “we”, or “us”) is a Delaware corporation that builds AI tools for healthcare organizations which automate patient care continuity and administrative processes including but not limited to insurance billing, scribing, and business intelligence.
We understand that you are aware of and care about your own personal privacy interests, and we take that seriously. This Cofactor AI Privacy Statement (this “Privacy Notice”) describes how Cofactor AI may collect, use, store, disclose, and process your personal information, through your access to or use of Cofactor AI products and services, including those at cofactorai.com, related websites, and other offerings (collectively, the “Services”). By using the Services, you signify your acceptance of this Privacy Notice. If you do not agree to this Privacy Notice, please do not use the Services. We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies. We will update this Privacy Notice by posting changes at this URL, cofactorai.com/privacy, and we may send notification emails regarding such changes. Your continued use of the Services will be deemed to be your acceptance of those changes.
Privacy Notice Applicability
This Privacy Notice applies when you access the Services or share information with Cofactor AI. Please note that this Privacy Notice applies only to the Services and not to any other third-party website linked to or from it, or any third-party website in which Cofactor AI content or functionality is embedded. We do not control the privacy policies or practices of others.
How we collect and use (process) your personal information
In general, Cofactor AI collects personal information about its users and customers through the information you provide via the Services, including through website and software input fields, phone, email, web chat, or in other such way. This information includes, but is not limited to:
· Profile or contact data: first and last name, email, phone number, unique identifiers such as usernames, passwords, and signature;
· Demographic data: age/date of birth, zip code, postal address, emails;
· Personal health information: information provided to your care provider, information pertaining to your symptoms, medical history, and diagnosis, health status, test results, and other medical records (“Medical History”);
· Inferences drawn from other personal data: profiles reflecting user attributes, profiles reflecting user behavior, inferences about preferences or aptitudes.
We use this information to provide the Services to you. You have the choice on what information to share and the services you want to engage. You can choose not to provide information to us, but in general some information about you is required in order for you to access certain functionality of the Services, such as those mentioned above or for tracking your preferences, subscribing to a newsletter, or initiating other such actions.
We do not sell personal information to anyone and only share it with third parties who are facilitating the delivery of the services.
From time to time, the Cofactor AI receives personal information about individuals from third parties, including affiliated entities, partners, and other independent third-party sources. Typically, information collected from third parties may include further details on your Medical History, use of the Services, and updated demographic information. We may also collect your personal data from a third-party website (e.g. LinkedIn).
Additionally, you may provide personal information to us to facilitate your access to and interaction with a third-party provider, such as your care provider, (“Third-Party Providers”) and the Third-Party Provider may provide us your personal information to facilitate the Services. Third-Party Providers are the administrators of your data when it is provided to and processed on the Services. If you direct us to provide personal information and/or your Medical History to such Third-Party Provider or permit the Third-Party Provider to provide such information to Cofactor AI, any usage of that information will be subject to the agreement(s) in place between you and such Third-Party Provider. We are not a party to that agreement, and any concerns you have outside of the information stated in this Privacy Notice must be directed to the Third-Party Provider.
Use of the Services
Cofactor AI’s website and the Services collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system, and other usage information about the use of Services. We use this information to help us design the Services to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.
Cofactor AI has a legitimate interest in understanding how members, customers and potential customers use its website. This assists Cofactor AI with optimizing the Services, providing more relevant products and services, communicating value to our sponsors, customers, and corporate members, and providing appropriate staffing to meet you and our customer’s needs.
We may use cookies, log files, device identifiers, and similar tracking technologies as well as other cloud-based tools to automatically collect your preferences, performance data, and information about your web usage when you visit the Services. The Services are not designed to recognize or respond to “do not track” signals received from browsers. You can control the information collected by such tracking technologies or be alerted when cookies are sent by adjusting the settings on your Internet browser or devices, but such adjustments may affect or disable certain functionality of the Services. You can learn more about targeted ads and your ability to opt out of receiving interest-based ads at optout.aboutads.info and www.networkadvertising.org/choices.
How we use your data
We process your personal information with your consent or as needed to provide you the Services. We may also use your personal information to comply with legal obligations, operate our business, protect the vital interests of you, our customers, or the public, or for other legitimate interests of Cofactor AI as described in this Privacy Notice. This may include sharing information with third parties.
More specifically, we may use your personal information to:
Optimize and improve the Services - We continually try to improve the Services based on the information and feedback we receive from you, including by optimizing the content on the Services.
Personalize the user experience - We may use your information to measure engagement with the Services, and to understand how you and our other users interact with and use the Services and other resources we provide.
Improve customer service - Your information helps us to more effectively develop the Services and respond to your support needs.
Process transactions - We may use the information you provide about yourself to fulfill your requests. We do not share this information with outside parties except to the extent necessary to provide the Services and related activities.
To send periodic emails - The email address you provide through our contact forms, will be used to send information and updates pertaining to the Services. It may also be used to respond to your inquiries or other requests. If you opt in to our mailing list, you may receive emails that include Cofactor AI news, updates, related product offerings and service information, and marketing material. If at any time you would like to unsubscribe from receiving future emails, we include detailed unsubscribe instructions at the bottom of each email or you may contact us via the contact information below.
Provide Services to Third-Party Providers - We may communicate with and transfer your information to Third-Party Providers in furtherance of our legitimate business interest with the Third-Party Provider. Please note, however, that we will only transfer, receive, or process your personal information with Third-Party Providers that you have consented to us receiving your information from.
We also may share your information:
In response to subpoenas, court orders, or other legal process; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us.
When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, interests, or safety of our company or the Services, our customers, or others; or in connection with our Terms of Service and other agreements.
In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
We may use any aggregated information (as described below) for any purpose.
Other than as set out above, we will attempt to notify you when your personal information will be shared with third parties.
Aggregated Information. We may publish, share, distribute, or disclose personal information that has been aggregated with information from other users or otherwise de-identified in a manner that does not allow such data about you to be separated and identified as originating from you to third parties, including Tryal partners, sponsors and advertisers. Such information may help Tryal identify and analyze training, demographic, and psychographic trends and information, and report to third parties how many people saw, visited, or clicked on certain content, areas of the Services, ads, or other materials. We may also use such data for research purposes and optimizing the Services’ functionality.
Hosting your data
The personal information Cofactor AI collects from you is stored in one or more databases hosted by third parties located in the United States. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval. On occasion, Cofactor AI engages third parties to send information to you, including information about our products, services, and events. Cofactor AI complies with applicable data protection laws, including applicable security breach notification requirements.
Cofactor AI currently uses Google Cloud Platform as its third-party sub processor. We reserve the right to change this sub processor at any time. We rely on Google Cloud Platform’s programs to protect personal information while stored in their respective controlled facilities. For more information on Google Cloud Platform’s security practices and processes, please see https://cloud.google.com.
The Cofactor AI website connects with third party services such as Facebook, LinkedIn, Twitter and others. If you choose to share information from the Cofactor AI website through these services, you should review the privacy policy of that service. If you are a member of a third party service, the aforementioned connections may allow that service to connect your visit to our site to your personal data.
Cofactor AI has its headquarters in the United States. Information we collect about you will be processed in the United States. By using Cofactor AI’s services, you acknowledge that your personal information will be processed in and transferred within the United States. Cofactor AI takes additional technological and organizational measures to protect your personal information against loss, theft, and unauthorized access, use, disclosure or modification. For example:
we transmit data over secured communication channels using SSL Login credentials,
all personal information is stored by trusted third party providers (e.g., Google Cloud Platform),
all systems used to provide the Services are password protected,
all Services usage is restricted on a per-user basis on the principle of least privilege, and
all data is encrypted while at rest and during transfer.
For more information or if you have any questions, please contact us at privacy@cofactorai.com.
Data Subject rights
To the extent provided by the law of your jurisdiction, you may:
● Have the right to access certain personal information we maintain about you and request details about how we process it;
● Request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes;
● Request that we update or correct inaccuracies in that information;
● Object to our use of your personal information;
● Ask us to block or delete your personal information from our database;
● Request to download the information you have shared on the Services; and
● Confirm whether Cofactor AI transfers and stores your data in the United States.
This Privacy Notice is intended to provide you with information about what personal data Cofactor AI collects about you and how it is used.
If you wish to confirm that Cofactor AI is processing your personal data, or to have access to the personal data Cofactor AI may have about you, please contact us at privacy@cofactorai.com.
Reasonable access to your personal data will be provided at no cost. If access cannot be provided within a reasonable time frame, Cofactor AI will provide you with an approximate date when the information will be provided. If for some reason access is denied, Cofactor AI will provide an explanation as to why access has been denied.
For questions or complaints concerning the processing of your personal data, you can email us at privacy@cofactorai.com.
California Resident Privacy Rights
California Civil Code Section 1798.83 permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please e-mail us or write to us at the addresses below.
Data storage and retention
Your personal data is stored by the Cofactor AI on its servers, and on the servers of the cloud-based database management services the Cofactor AI engages as described above. Cofactor AI retains service data for the duration of the customer’s business relationship with the Cofactor AI and for a period of time thereafter to analyze the data for Cofactor AI’s own operations and for historical and archiving purposes associated with Cofactor AI’s services. Cofactor AI retains personal information until such time as it no longer has business value and then is purged from Cofactor AI systems but for no longer than permitted by applicable law. All personal data that Cofactor AI controls may be deleted upon verified request from Data Subjects or their authorized agents. For more information on where and how long your personal data is stored, and for more information on your rights of erasure and portability, please contact us at: privacy@cofactorai.com.
Children’s data
The Services are not directed to children, and you may not use the Services or provide any personal information to Cofactor AI if you are under the age of 13 or if you are not old enough to consent to the processing of your personal information in your jurisdiction.
Questions, concerns, or complaints
If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at:
Cofactor AI, Inc.
Attn: Privacy Department
1421 Ozark Ave
McAllen, Texas 78504