") describes the types of information Trova Health, Inc. ("Trova
" or "we
") collects from you, or from subscribers ("you
" or "yours
") to the Trova's software applications, including the enhancements, features, related website, and contents (the Services
). It also describes how we use and disclose such information, as well as your rights with respect to Trova's collection, use, and disclosure of such information. We understand the importance of your privacy and the privacy of visitors to your business location who access the Services ("Visitors
Information We Collect
When you use Trova Services, the company may collect the following types of information about You ("Personal Data
- Information necessary to sign up for the Trova website (the "Website") and to receive services.
- Personal Data, including names, email addresses, telephone numbers, gender, birth dates, identification number(s), location data, and/or other online identifiers of one or more factors specific to the physical, physiological, cultural or social identity of that individual.
- Usernames and User IDs, which are a way to identify you on the Website.
- Information posted to a group chat or moderated session and information kept within a personal one-on-one session with a provider.
- Banking information for billing purposes; such as account number and routing information for invoicing purposes.
- Cookies. See Cookie notice below for details.
- Emergency contact information, in the event of an emergency or mental health crisis.
When We Collect Personal Data
Trova collects Personal Data when:
- you sign up for the Services
- you use certain features of the Services that require the collection of Personal Data in order for those features to function
- you or your Visitors voluntarily enter or upload their Personal Data to or use the Services
- you or a Visitor communicate(s) with Trova, whether through the Services or through another form of communication, such as e-mail, web chat or telephone.
Purpose for Collecting Personal Data
Trova may use the informaiton it collects in the following ways:
- To provide you with the requested Services;
- To manage your account and provide you with customer support;
- To communicate with you about products or services that may be of interest to you (whether from us or from third-parties);
- To develop and display content tailored to your interests (both on our website and other websites);
- To perform research and analysis about your use of, or interest in, our services;
- To perform research and analysis about your use of, or interest in, the content, products, services, or content offered by third-parties;
- To combine with de-identified information we collect from other sources to create “de-identified information” about you;
- To properly and efficiently operate our business;
- To perform functions as otherwise described to you at the time of collection; and
- (With regard to financial information) To process payment for any purchases made on our website, enroll you in any discount, rebate, and other programs in which you elect to participate, to protect against or identify possible fraudulent transactions, and otherwise as needed to manage our business.
Sharing Personal Data with Third Parties:
Trova may share Personal Data with third party service providers as Trova deems necessary for such third party service providers to perform their duties required for the Services to function. For example, the Services may utilize mail relays, payment processers and hosting providers. A list of third party service providers used by Trova for the Services can be found at the following website: https://www.trova.health/platform-security/
In rare cases, Trova may be required, or may, acting in good faith, believe it is required, to share certain information with legal authorities. In such a case, Trova will only share what is legally necessary. When Trova do give this information to the authorities, it is for them to protect that information. Such cases include:
- if required by law
- to protect or defend itself, you, your Visitors, or others against physical harm or legal liability
- to investigate a possible crime, such as fraud or identity theft.
We utilize cookies.
WHAT IS A COOKIE?
Cookies are bits of code left behind on your computer, mobile phone, or tablet, which serve as electronic tags, scripts or beacons, allowing your website preferences to be stored. Cookies are used to collect information, where available, about your device, including tracking your IP address, noting your operating system, and browser type, and indicating how you have interacted with our Website. A cookie allows us to recognize whether you have visited before and may store user preferences and other data. Also, by remembering information about your visit to our website, cookies help personalize your experience and save you from having to reenter information about yourself or the preferences you’ve set. While cookies are used to identify users and devices, they only ever collect non-personal information such as IP addresses and device IDs.
- Store preferences you made and display content to you in a more personalized way
- Gain insight into the nature of your interactions so we can tailor our content accordingly
- Per-session Cookies: We only use these while you are visiting our Website and they are deleted when you leave.
- Persistent Cookies: These cookies stay on your computer until they expire or are deleted. We set automatic deletion dates so that we don't keep your information for longer than we need to.
- First and Third-Party Cookies: Whether a Cookie is 'first' or 'third' party refers to the website or domain placing the cookie. First party cookies are set by a website visited by you. Third-party cookies are set by a domain other than the one being visited by the user; for example, if a user visits a website and a separate company sets a cookie through that website this would be a third-party cookie.
HOW DO YOU OPT OUT OF USING COOKIES?
In your user settings on your device, which may be located under the 'Options', 'Settings' or 'Preferences' menu of your browser. If you are concerned about having cookies on your device, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your device. However, if you choose to block or delete cookies, certain features of Website may not operate optimally.
If you request that we do not use your Personal Data in a particular manner or at all, we will adopt all reasonable measures to observe your request, but we can disclose that information if:
- We subsequently notify you of the intended use or disclosure and you do not object to that use or disclosure.
- We believe that the use or disclosure is reasonably necessary to assist a law enforcement agency or an agency responsible for government or public security in the performance of their functions.
- We are required by law to disclose the information.
All Personal Data that we collect (including your contact details and, if relevant, payment details) is kept confidential to the best of our ability. Unfortunately, no system or online transmission of data can be guaranteed to be 100% secure and you should always take appropriate security measures to protect your Personal Data including ensuring that you have up-to-date antivirus software.
Aggregate Information is information about your activities on or in connection with the Services that typically cannot be used to identify, locate, or contact you or your Visitors. For example, Aggregate Information includes information regarding the frequency of use of the Services, quantity and type of data entered when using the Services, components of the Services most frequently accessed, and browser types used to access the Services. Trova collects information resulting from your and your Visitors’ use of our Website and the Services and aggregates it in a manner that retains the anonymity of each individual that interacts with the Website or registers or receives Services.
Purpose of Using and Sharing Aggregate Information
Trova uses Aggregate Information:
- to provide the Services
- to improve the Services
- to monitor usage of the Services
- to analyze usage of the Services
- to research, compile, and report on usage trends, user demographics, and user behaviors
- for other legitimate business purposes.
Trova may share Aggregate Information with its affiliates and certain third parties, such as investors, potential investors, and third party service providers we use to provide the Services. Aggregate Information is anonymized and does not have the capacity to be used to identify an individual. In other words, Trova may share this information but no Personal Data will be disclosed to third parties.
The Services may contain links to third party websites operated by other people or companies. Trova is not responsible for those websites, and links to such websites are solely for your convenience.
Security and Data Protection
Data Processing and GDPR
The European Union’s General Data Protection Regulations ((EU) 2016/679 (General Data Protection Regulation, commonly referred to as “GDPR
”)) is the European Union’s regulation for the protection of natural persons with regard to the processing of their personal data. Enforcement of the GDPR began on May 25, 2018, and applies to companies — operating within any of the EU member states (e.g., France, Germany, Italy, Spain, etc.) — that process the personal data of EU citizens. To the extent Trova has access to, or processes Personal Data for individuals who are subject to GDPR, that is, Personal Data originating from a citizen from an EU member state, Trova will adhere to the requirements of GDPR, including taking reasonable steps to ensure that Personal Data we process is accurate, complete, and current.
You have certain rights relating to the way We collect, hold and process Your data under the GDPR. You have the right to request that we:
- Provide you with a copy of any personal information that we hold about you;
- Update your personal information if it is out-of-date or incorrect;
- Delete any personal information that we hold;
- Restrict the way in which we process your information: and
- Consider any valid objections to our processing of your personal information.
) for further access and assistance. We will take reasonable steps to update, correct, and to the extent within the law, delete, Personal Data in Trova's possession.
Trova may require certain financial information, such as credit card information. We will not share this financial information, other than the financial institutions involved in processing your payment. At all times, Trova will comply in all respects with applicable consumer protection laws.
Corrections and Removals
If any part of your Personal Data, such as your name, e-mail address, mailing address, telephone number or other personal information changes, you may update, correct or remove the relevant information. If you are a Visitor to a business location that uses the Services, by contacting such business; or in all other cases, by contacting Trova at email@example.com
Opt-in. When you access any interactive tool or service on the Website that collects Personal Data, you will be asked to affirmatively choose (“opt-in”) to provide the requested Personal Data. You may always choose not to provide the requested Personal Data.
Manage email. You may elect to receive email updates about developments regarding Trova. If you decide, at any later time, that you no longer wish to receive these emails, you may unsubscribe to any such contact list by using the “Unsubscribe” links within the electronic communication channel, or by sending an email entitled “Unsubscribe” to firstname.lastname@example.org
Our Children's Notice
We recognize the importance of protecting the privacy of children. Our Website is neither intended for children nor are they designed to attract child users. Our Website, its content and our Services are intended for users over the age of eighteen (18). We do not knowingly collect any personally identifiable information from children under age eighteen (18). When a user discloses Personal Information on the Websites, the user is representing to us that he or she is at least eighteen (18) years of age. If We learn a user under the age of eighteen (18) has volunteered personally identifiable information on our Websites, we will delete such information from our active databases.
Your California Privacy Rights
If you are a California resident, California law may provide you with additional rights regarding our use of your personal information. To learn more about your California privacy rights, click here
Trova Health, Inc.
Attention: Privacy Officer
80 Arlington Street
Asheville, NC 28801
Effective Date: October 10th, 2021.