Last updated: 2020-06-01

GRADIENT FLOW PRIVACY POLICY

Gradient Flow, LLC (“Gradient Flow”) respects the privacy of our consumers and visitors to our website, and we recognize your need for appropriate protection and management of personally identifiable information you share with us (any information by which you can be identified, including but not limited to, name, address, email address, and telephone number). We have established this Privacy Policy so that you are informed about how we treat any personally identifiable information that you provide to us in the course of using this website or that we may otherwise collect from or about you in connection with our products and services. This Privacy Policy will inform you of:

How you will be informed of updates to this Privacy Policy
What personally identifiable information of yours we may collect and how we may use this information
Limits on how we would share and disclose your personally identifiable information
Our policy regarding collection of personally identifiable information from minors
How our website uses cookies and similar technologies
Our practices concerning retargeting and interest-based advertising
Our policy regarding browser “do not track” signals
How our website uses social media plugins
Our policy regarding links to third party websites
Security of our website
Additional information for California residents
How you can correct and update your personally identifiable information

Your access to and use of the website constitutes acceptance of this Privacy Policy and consent to Gradient Flow’s collection and use of your information as outlined below.

Privacy Policy Updates

From time to time, Gradient Flow may revise this Privacy Policy. Any such changes to this Privacy Policy will be promptly reflected on this page. Gradient Flow encourages you to review this Privacy Policy regularly for any changes. Your continued use of this website will be subject to the then-current Privacy Policy. The effective date of this Policy is 2020-06-01.

Information Collection and Use

You can generally visit our website without revealing any personally identifiable information about yourself. However, to access certain options and services we may ask you to provide certain personally identifiable information and without providing such personally identifiable information, you may be unable to access certain options and services. The following is personally identifiable information that we may collect from or about you and how we use it:

Surveys and Newsletters. Information obtained from you on web surveys or newsletter subscription forms, such as contact information (name, email address), job information (job title, company, industry) and demographic information (country). We may use this personally identifiable information to provide you with newsletters, or information and services for which you have expressed an interest, or that you may find useful. Additionally, we may refer to your personally identifiable information to better understand your needs and how we can improve our website.
Registration. Information obtained from you on registration forms used to process your requests for services and information, such as contact information (name, email address), job information (job title, company, industry), demographic information (country), and/or account information (username or code, password). This registration information may also be gathered if you register for certain services via fax or mail. We may use this information to send you a welcoming email to verify your username and password, website updates, special offers, notices regarding updates to our services and information, or other information responsive to the data that you provide to us. Additionally, we may refer to your personally identifiable information to better understand your needs and how we can improve our website.
Email Content to a Friend. Information obtained from you regarding friend or family name and email address, if you elect to use our referral service for sending some of our website content to friends and family. We may use this personally identifiable information to automatically send the friend or family member a one-time email inviting them to visit the website. We may store this information for the sole purpose of sending this one-time email.
Other Modes of Collection. Information we collect from or about you in other online or offline contexts, including information submitted during purchases of Gradient Flow products, interactions with Gradient Flow employees, adverse event reporting, or participation in a research study. We use such information for a variety of purposes.
CALIFORNIA RESIDENTS: To learn more about the personally identifiable information we collect from or about you, including how we may use and share it, please see the Privacy Policy’s ‘California Supplemental Privacy Notice‘.

We may combine the personally identifiable information you share with us through our website with other information we collect from or about you, both online and offline. We may also combine this personally identifiable information with records provided by third parties. We use this consolidated information to help us better design Gradient Flow products and services, to communicate information to you, to enhance our marketing and research activities, and to facilitate other business functions.

In addition to the purposes described above, any information we collect may also be used for analytics purposes (e.g., evaluating site usage patterns, assessing throughput) so that we can gauge the effectiveness of our programs and improve the usefulness of information presented to users.

Gradient Flow is the owner of all information collected on our website. California residents can learn more about the personally identifiable information we collect from or about you and how we may use it in the Privacy Policy’s ‘California Supplemental Privacy Notice‘.

Sharing and Disclosure

We may provide your personally identifiable information that we collect and the data generated by cookies (discussed below) to partner entities, and the vendors and service agencies that we may engage to assist us. For example, we may provide your personally identifiable information to an organization in order to complete a service (e.g., send out newsletter emails you have requested), to assist us in reviewing the data or to provide marketing or advertising on our behalf.

We will also disclose your personally identifiable information if we reasonably believe we are required to do so by law, regulation, legal process, or other government authority; to investigate fraud; to protect your safety or the safety of others; or when we have reason to believe that disclosing this information is necessary to protect our rights or the rights of a third party who may be harmed by your activities.

We may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization in which Gradient Flow participates, or to a purchaser of all or a portion of Gradient Flow’s assets; or pursuant to a financing arrangement or co-promotional agreement. Any successor entity shall be bound by terms and conditions reasonably similar to this Privacy Policy.

California residents can learn more about how we may disclose the information we collect from or about you in the Privacy Policy’s ‘California Supplemental Privacy Notice‘.

Minors

Our website is not intended for or designed to attract children under the age of 13. Moreover, we do not knowingly collect any personally identifiable information from anyone under the age of 18 without the consent of a parent or guardian, and you must be 18 years of age or older to submit registration or survey information. Should you believe that a minor of whom you are a parent or guardian has registered, please contact us at privacy.office@gene.com and we will make reasonable efforts to remove all personally identifiable information related to the minor.

Cookies, LSOs, GIF Files, and Other Tracking Technologies

Our website may use cookies, local shared objects (LSOs) and other tracking technologies to identify users who have previously visited so the user is recognized upon return, thereby saving them time while on our website. A cookie is a piece of data stored on the user’s hard drive containing information about the user. If a user rejects the cookie, they may still use our website. A cookie may be placed by us, or by vendors or service agencies who work with us or with our partners. Similar to a cookie, a Local Shared Object is a collection of data that a web site running Adobe Flash can place on your hard drive to recognize a repeat visitor and store settings and other information.

Our website and emails we send to you may contain transparent GIF files (also known as “web beacons,” “action tags,” or “pixel tags”) to help manage online advertising. These GIF files are used by us and our ad management partners to recognize when a visitor views a web page or opens an email. This information enables us to learn which emails and advertisements bring users to our website.

If you have provided us with personally identifiable information, e.g., through a registration or a request for certain materials, we may associate this personally identifiable information with information gathered through these tracking technologies. This allows us to offer increased personalization and functionality.

Our website may use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to analyze use patterns and may collect information about your use of the website, including your IP address. More information on Google Analytics can be found here: www.google.com/policies/privacy/partners/. If you would like to opt out of having your data used by Google Analytics, please use the Google Analytics opt-out available here: https://tools.google.com/dlpage/gaoptout/. Other information on opt-outs for targeted advertisement delivery is available below. Please note that Gradient Flow makes no representations regarding the functionality of Google opt-out mechanisms, and further, opting out of Google Analytics will not preclude the use of your data by other analytics services.

Retargeting and Interest-Based Advertising

We use third party advertising companies to place ads on other websites. These companies may use data about your visits to this and other websites in order to measure advertising effectiveness and to provide advertisements about our goods and services that may be of interest to you. Like most advertisers, we place advertisements where we think they will be most relevant to consumers. One way we do so is by allowing network advertising companies with whom we work to place their own cookies when an individual visits our site. This enables the network advertising company to recognize individuals who have previously visited our site. When the individual visits a third-party web site on which that network advertising company has purchased ad space, the advertising company can then recognize the individual’s interest in our products and services and deliver one of our advertisements.

Our website may occasionally use two Google Analytics Advertising Display Features, which collect information through cookies: Remarketing with Google Analytics and Demographics and Interests reporting. If you would like to opt out of having your data used by these cookies, please use the Google Analytics opt-out available here: https://tools.google.com/dlpage/gaoptout/.

The Digital Advertising Alliance maintains a web site where consumers can opt out from receiving interest-based advertising from some or all of the network advertising companies participating in the program (www.AboutAds.info/choices).

Do-Not-Track Signals and Similar Mechanisms

Some web browsers may transmit “do-not-track” signals to websites with which the browser communicates. Our website does not currently respond to these “do-not-track” signals.

Social Media Plugins

Our website may use social media plugins (e.g., the Facebook “Like” button, ‘”Share to Twitter”‘ button) to enable you to easily share information with others. When you visit our website, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited our site. If you are logged into the social media website (e.g., Facebook, Twitter, Google+) while browsing on our website, the social plugins allow that social media website to receive information that you have visited our website. The social plugins also allow the social media website to share information about your activities on our website with other users of their social media website. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allow you to see your friends’ Facebook activity on our website. Gradient Flow does not control any of the content from the social media plugins. For more information about social plugins from other social media websites you should refer to those sites’ privacy and data sharing statements.

Log Files and Aggregate Information

We may track the total number of visitors to our website, the number of visitors to each page of our website, IP addresses, and the domain names of our users’ Internet Service Providers, and we may analyze these data for trends and statistics in the aggregate, but such information will be in aggregate form only and it will not contain personally identifiable data. Such aggregate information is not linked to any personally identifiable information that can identify any individual person.

We may use such aggregate information to analyze trends, administer the website, track user’s movement, and gather broad demographic information for aggregate use. We may share this aggregate information with our corporate partners and contracted vendors to assist us in operating the website and to enable them to better understand Gradient Flow’s business.

Links to Third-Party Sites

Our website may contain links to other websites on the Internet that are not under the control of or maintained by Gradient Flow. Such links do not constitute an endorsement by Gradient Flow of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that Gradient Flow is providing these links to you only as a convenience, and you agree that Gradient Flow is not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites.

Security

Gradient Flow and its third-party providers may employ procedural and technological security measures, consistent with industry practice. Such measures are reasonably designed to protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. Gradient Flow may use encryption, password protection, secure socket layers, internal restrictions and other security measures to help prevent unauthorized access to your personally identifiable information. However, you provide your information to us at your own risk. We cannot guarantee that your data will not be lost, accessed without authorization, disclosed, altered, or destroyed.

California Residents

The California Consumer Privacy Act of 2018 (CCPA) gives California residents the right to know what personally identifiable information Gradient Flow collects about them, including whether it is being sold or disclosed to third-parties, and the right to prevent Gradient Flow from selling that information. The CCPA also prevents companies from retaliating against consumers for exercising these rights – companies must continue to give consumers who exercise the right to refuse sale of their personally identifiable information access to equal products for equal prices.

A list of the categories of personal information Gradient Flow has collected from or about California consumers in the preceding 12 months, as well as lists of the categories of personal information Gradient Flow has disclosed for a business purpose, can be found in the Privacy Policy’s ‘California Supplemental Privacy Notice‘. In addition, California residents have certain rights with respect to Gradient Flow’s use and disclosure of personal information about California consumers:

Right of Access | Right to Notice. If you are a California resident, you have the right to request that Gradient Flow disclose to you the categories of personal information we have collected about you, the categories of sources from which the personal information is collected, the business purpose or commercial purpose for collecting or selling personal information, the categories of third parties with whom we share personal information, the categories of personal information we have sold about you or disclosed about you for a business purpose, and the specific pieces of personal information we have collected about you in the preceding 12 months.
Right to Deletion. If you are a California resident, you have the right to request that Gradient Flow delete the personal information we collect from you. However, in certain situations we are not required to delete your personal information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your personal information internally in a lawful manner that is compatible with the context in which you provided the information.
Right to Opt Out of the Sale of Personal Information. If you are a California resident and Gradient Flow sells your personal information to third parties, you have the right, at any time, to direct us not to sell your personal information. Gradient Flow does not sell personal information.
Right Not to Be Subject to Discrimination. Gradient Flow shall not discriminate against a consumer because the consumer exercised any of the consumer’s California rights described above.

To exercise any of the rights described above (if applicable), email us at contact@gradientflow.com.

Correction/Updating Personally Identifiable Information

Gradient Flow is committed to respecting your right to access and correct your personal information. You can email us at contact@gradientflow.com and we will be happy to assist you with your request. You may also “opt out” of receiving emails and other communications from us by using the unsubscribe feature included in the emails we send. If you have any questions about this online privacy policy or the information practices of our sites, you may contact us by email at contact@gradientflow.com.

GRADIENT FLOW CALIFORNIA SUPPLEMENTAL PRIVACY NOTICE

The California Consumer Privacy Act of 2018 (CCPA) gives California residents the right to know what personal information Gradient Flow collects about them, including whether it is being sold or disclosed to third-parties, and the right to prevent Gradient Flow from selling that information.

DEFINITION OF PERSONAL INFORMATION UNDER CCPA

California law defines ‘Personal Information’ to mean information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal information includes, but is not limited to the categories of personal information identified below if such information identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.

Most companies need to collect and share consumers’ Personal Information for everyday business purposes, marketing, and maintenance of the safety, security, and integrity of their websites and other assets, to comply with legal and regulatory obligations, among other reasons. This supplemental notice provides the information required under the CCPA and applies to both Gradient Flow’s online and offline activities.

The types of Personal Information we collect and disclose depends on your relationship with Gradient Flow. Not all of the categories listed below may apply to you. If the nature of your relationship with Gradient Flow changes, additional categories of Personal Information may also apply. In some cases, an additional data privacy notice may apply and will be provided to you.

CCPA NOTICE ON COLLECTION OF YOUR PERSONAL INFORMATION. If you are a California resident, the following sections detail how we collect, use and share your Personal Information:

Categories and Sources of Personal Information

CONTACT INFORMATION

We collect this type of information from:

You
Those authorized to provide on your behalf such as your authorized representative.

We assign a customer number to you when you contact us for assistance or register a complaint.

Third parties, such as ad delivery companies who place cookies containing advertising IDs on your devices for us.
Third parties who provide product fulfillment services in connection with our products and services.
Consumer reporting agencies and other third parties who verify the information you provide.
Third parties who help us maintain the accuracy of our data and data aggregators that help us complete and enhance our records.
Third parties who provide digital marketing and analytics services for us using cookies and similar technologies that contain a unique identifier, such as an advertising ID.

Representative Data Elements

Data elements in this category include:

Full name, or unique pseudonym
Honorifics and titles, preferred form of address
Postal address
Email address
Phone number
Contact information for related persons, such as authorized users of your account
Company name
Company ID number [customer number, account number, subscription number, rewards program number etc.]
System identifiers (e.g., usernames or online credentials)
Job title
Device identifier
Advertising ID
Customer number
IP address
Social security number
Service Request ID number
Cookie ID

Purpose for Collecting and Sharing the PI

We use this type of information:

To identify you and communicate with you
To send transactional messages such as confirmations or responses for assistance
To send marketing communications, surveys and invitations
To personalize our communications and provide customer service
To administer and manage events
To identify you or your device, including to associate you with different devices that you may use
For record-keeping and reporting, including for data matching
For metrics and analytics,
To track your use of products, services, websites, including for ad delivery and personalization
To troubleshoot product issues
To determine and verify program, product, and service eligibility and coverage.
To enroll you in our programs and provide our products and services to you.
To administer, manage, analyze, and improve our programs, products, and services.
To procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
To analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
To conduct internal business analysis and market research.
Advertising and product promotion, including to contact you regarding programs, products, services, and topics that may be of interest or useful.
To engage in joint marketing initiatives.
To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
To provide access to, monitor, and secure our facilities, equipment, and other property.
To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
To comply with legal and regulatory obligations.
To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, products, services, and advertisements for such purposes.
To evaluate a potential employment or contractor relationship with you.
To perform background checks and verify past employment, educational history, and professional standing and qualifications.
To evaluate, determine, and arrange compensation, payroll, and benefits.
To assess your fitness for work.
To contact you regarding your application and potential employment or contractor relationship with us.
For our everyday business purposes.

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Service Providers, including to social media companies such as Facebook which use the data only to identify which of our customers use their platforms so that we can deliver ads to you on the platform
Service providers such as companies who help manage and coordinate events
Third parties who deliver our communications, such as the postal service and couriers
Other third parties (including government agencies) as required by law, such as pursuant to legally binding subpoenas, court orders, and similar instruments)
Service providers, including companies who assist with our information technology and security programs
Third party advertising network companies, when you opt-in via our cookie banner to have such Personal Information disclosed for advertising (see Third Party Advertising below)
Third parties who assist with fraud prevention, detection and mitigation.
Authorized/legal representatives, family members, and caregivers.
Third parties with whom we have joint marketing and similar arrangements.
Third parties who provide program enrollment and product fulfillment services in connection with our products and services.
Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
Other third parties as necessary to complete transactions and provide our products/services, including delivery companies, agents, and manufacturers.
Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors..
Consumer reporting agencies.
Our lawyers, auditors, and consultants.
Legal and regulatory bodies and other third parties as required by law.

PHYSICAL CHARACTERISTICS OR DESCRIPTION

We collect this type of information from:

You (directly from participant).
Authorized/legal representatives.
Third parties who provide program enrollment and product fulfillment services in connection with our products and services.
Third parties that provide access to information you make publicly available, such as social media platforms.
Third parties who provide us with supplemental consumer data or data analytics and market research services, such as data aggregators.

Representative Data Elements

Data elements in this category include:

Gender

Purpose for Collecting and Sharing the PI

We use this type of information:

To administer, manage, analyze, and improve our programs, products, and services.
To analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
To conduct internal business analysis and market research.
To comply with legal and regulatory obligations.
For our everyday business purposes.

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Authorized/legal representatives
Third parties with whom we have joint marketing and similar arrangements.
Third parties who provide program enrollment and product fulfillment services in connection with our products and services.
Other third parties as necessary to complete transactions and provide our products/services.
Our lawyers, auditors, and consultants.
Legal and regulatory bodies and other third parties as required by law.

COMMERCIAL INFORMATION

We collect this type of information from:

You
Third parties that provide access to information you make publicly available, such as social media.
Third parties that provide information that helps us understand our customers, including data aggregators and public records providers.
We may also infer information about you based on information that you have given us and your past interactions with us and other companies.
Consumer reporting agencies.
Third parties who provide program enrollment and product fulfillment services in connection with our products and services.
Other third parties who facilitate, process, and complete transactions for us, such as resellers, sales agents, and program partners.

Representative Data Elements

Data elements in this category include:

Propensity scores obtained from third parties, such as likelihood that you may be interested in certain purchases
Products or services you have purchased
Records of products or services purchased, obtained, or considered
Records of program enrollment and activity

Purpose for Collecting and Sharing the PI

We use this type of information:

To better understand you and to understand our customers generally
To design products, services and programs including subscription and special offer programs
To identify prospective customers
For internal business purposes, such as quality control, training and analytics
To enroll you in our programs and provide our products and services to you.
To administer, manage, analyze, and improve our programs, products, and services.
To communicate with you regarding our programs, products, and services.
To procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
To analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
To conduct internal business analysis and market research.
To engage in joint marketing initiatives.
To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
To comply with legal and regulatory obligations.
For our everyday business purposes

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Third parties with whom we have joint marketing and similar arrangements
Service Providers, including companies who assist us in program administration
Our lawyers, auditors and consultants.
Authorized/legal representatives.
Third parties with whom we have joint marketing and similar arrangements.
Third parties who provide program enrollment and product fulfillment services in connection with our products and services.
Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
Other third parties as necessary to complete transactions and provide our products/services.
Third party network advertising partners.
Consumer reporting agencies
Legal and regulatory bodies and other third parties as required by law.

TRANSACTION AND INTERACTION INFORMATION

We collect this type of information from:

You
Third parties that provide access to information you make publicly available, such as social media.
Automatically, such as when you interact with our website or survey forms.

Representative Data Elements

Data elements in this category include:

Subscription program data
Household demographic data
Data from social media profiles, such as Facebook, Twitter, LinkedIn and similar platforms
Education information
Professional information
Hobbies and interests

Purpose for Collecting and Sharing the PI

We use this type of information:

To fulfill our business relationship with you, including customer service
For recordkeeping and compliance, including dispute resolution
For internal business purposes, such as finance, quality control, training, reporting and analytics
For risk management, fraud prevention and similar purpose
For our everyday business purposes

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Third parties with whom we have joint marketing and similar arrangements
Service providers, including third parties as needed to complete the transaction, including delivery companies, agents and manufacturers
Our lawyers, auditors and consultants
Customers, in connection with their audits of Gradient Flow
Other third parties as required by law

INFERRED AND DERIVED INFORMATION

We create inferred and derived data elements by analyzing our relationship and transactional information.
We draw inferences from the information we collect from and about you, such as your preferences, characteristics, attributes, and abilities.

Representative Data Elements

Data elements in this category include:

Propensities, attributes and/or scores generated by internal analytics programs and used for marketing
Propensities, attributes and/or scores generated by internal analytics programs and used for information security and fraud purposes
Preferred language
Inferences reflecting a consumer’s wellness, health, preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes, or other inferred data.

Purpose for Collecting and Sharing the PI

We combine inferred data with other relationship information and use this type of information:

To better understand you and to understand our customers generally
To design products, services and programs that delight our customers, including subscription programs
To identify prospective customers
For internal business purposes, such as quality control, training and analytics
To administer, manage, analyze, and improve our programs, products, and services
To analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
For advertising and product promotion, including to contact you regarding programs, products, services, and topics that may be of interest or useful.
To engage in joint marketing initiatives.
To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
To comply with legal and regulatory obligations
For our everyday business purposes

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Service providers, including those who analyze data on our behalf and who help execute programs
Our lawyers, auditors and consultants
Third parties with whom we have joint marketing and similar arrangements
Legal and regulatory bodies and other third parties as required by law.

INTERNET AND ONLINE/ ELECTRONIC TECHNICAL INFORMATION

We collect this type of information from:

You and from your computer or devices when you interact with our platforms, websites and applications. For example, when you visit our websites, our server logs record your IP address and other information.
Automatically, via technologies such as cookies, web beacons, when you visit our website or other websites.
Third parties, including computer security services and advertising partners. We also associate information with you using unique identifiers collected from your devices or browsers.
Third parties who provide website and online security services.

Representative Data Elements

Data elements in this category include:

IP Address
MAC Address, SSIDs or other device identifiers or persistent identifiers
Online user ID
Password
Device characteristics (such as browser information)
Web Server Logs
Application Logs
Browsing and search history
Viewing Data (site and app usage)
First Party Cookies
Third Party Cookies
Web beacons, clear gifs and pixel tags
Internet service provider
Referring/exiting URL
Request/response date and time
Clickstream data
Ads and web pages viewed
Time spent on a web page or mobile app
Other information regarding your interactions with our websites, applications, emails, and advertisements

Purpose for Collecting and Sharing the PI

We use this type of information:

For system administration, technology management, including optimizing our websites and applications,
For information security and cybersecurity purposes, including detecting threats
For recordkeeping, including logs and records that are maintained as part of Transaction Information
To better understand our customers and prospective customers and to enhance our Relationship Information, including by associating you with different devices and browsers that they may use
For online targeting and advertising purposes subject to choices made via the Cookie Banner
To administer, manage, analyze, and improve our programs, products, and services.
To conduct internal business analysis and market research.
For advertising and product promotion, including to contact you regarding programs, products, services, and topics that may be of interest or useful.
To engage in joint marketing initiatives.
To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
To comply with legal and regulatory obligations.
To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, products, services, and advertisements for such purposes
For our everyday business purposes

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Service providers including companies who assist with our information technology and security programs, including companies such as network security services who retain information on malware threats detected
Service providers who assist with fraud prevention, detection and mitigation
Third party advertising network companies, when you opt-in via our cookie banner to have such Personal Information disclosed for advertising (see Third Party Advertising below)
Our lawyers, auditors and consultants
Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
Legal and regulatory bodies and other third parties as required by law

AUDIO VISUAL INFORMATION

We collect this type of information from:

You
Companies conducting research such as market research companies.
Third parties that provide access to information you make publicly available, such as social media.

Representative Data Elements

Data elements in this category include:

Photographs
Video images,
CCTV recordings
Call center recordings and call monitoring records
Voicemails

Purpose for Collecting and Sharing the PI

We use this type of information:

For internal business purposes, such as call recordings used for training, coaching or quality control
For relationship purposes, such as use of photos and videos for social media purposes
For our everyday business purposes

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Service providers, including companies who assist with our information technology and security programs, and our loss prevention programs
Service providers, including companies who conduct market research on our behalf
Our lawyers, auditors and consultants
Other third parties as required by law

FINANCIAL INFORMATION

We collect this type of information from:

You
Payment processors and other financial institutions.
Authorized/legal representatives, family members, and caregivers.
Third parties who provide program enrollment and product fulfillment services in connection with our products and services.
Third parties who assist with fraud prevention, detection, and mitigation.

Representative Data Elements

Data elements in this category include:

Bank account number and details (if you use automated payments)
Payment card information
Debit or credit card number
Bank account number and routing information
Payment and reimbursement amounts

Purpose for Collecting and Sharing the PI

We use this type of information:

To fulfill our business relationship with you, including processing payments, issuing refunds and collections
For recordkeeping and compliance, including dispute resolution
For internal business purposes, such as finance, audits, training, reporting and analytics
For risk management, fraud prevention and similar purpose
To determine and verify program, product, and service eligibility and coverage.
To enroll you in our programs and provide our products and services to you.
To administer, manage, analyze, and improve our programs, products, and services.
To issue invoices and collect payments.
To reimburse customers, satisfy warranty obligations, and fulfill payment obligations.
To procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
To comply with legal and regulatory obligations
For our everyday business purposes

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Service providers, including payment processors, financial institutions and others as needed to complete the transactions and for authentication, security and fraud prevention
Our lawyers, auditors and consultants
Customers, in connection with their audits of Gradient Flow
Authorized/legal representatives.
Third parties who provide program enrollment and product fulfillment services in connection with our products and services.
Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
Other third parties as necessary to complete transactions and provide our products/services.
Consumer reporting agencies.
Legal and regulatory bodies and other third parties as required by law

ELECTRONIC AND SENSOR DATA

We collect this type of information automatically when you use our internet-enabled products such as mobile apps and connected devices from:

You (directly from participant).
Your mobile devices and other internet-connected devices and applications (automatically).
Third parties that provide access to information you make publicly available, such as social media platforms.

Representative Data Elements

Data elements in this category include:

Smart device records
IoT products

Purpose for Collecting and Sharing the PI

We use this type of information:

To enable product functionality
For internal business purposes, such product development, security, and quality control
To administer,manage, analyze, and improve our programs, products, and services.
To analyze and better understand your needs, preferences, and interests, as well as those of other consumers.
To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
To provide access to, monitor, and secure our facilities, equipment, and other property.
To comply with legal and regulatory obligations.
To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with programs, products, services, and advertisements for such purposes
For our everyday business purposes

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Service providers, including companies who assist with our information technology and security programs, including network security services and cybersecurity
Service providers, including companies who assist with fraud prevention, detection and mitigation
Third party network advertising partners
Our lawyers, auditors and consultants
Healthcare providers (including specialty pharmacies), health insurance companies (health plans), other payors and others as needed to provide the contemplated services or transactions involving the data, such as for processing health care payments
Authorized/legal representatives, family members, and caregivers.
Third parties who provide program enrollment and product fulfillment services in connection with our products and services.
Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
Third parties who assist with our information technology and security programs.
Third parties who assist with fraud prevention, detection, and mitigation.
Other third parties as necessary to complete transactions and provide our products/services.
Other third parties as required by law

GEOLOCATION DATA

We collect this type of information automatically from your mobile device and computer when you visit or interact with our websites, applications, and online platforms.

Representative Data Elements

Data elements in this category include:

Precise location data
Geofencing data

Purpose for Collecting and Sharing the PI

We use this type of information:

Provide the information, products or services requested
For information security and fraud prevention
For our Everyday Business Purposes
To administer, manage, analyze, and improve our programs, products, and services.
To conduct internal business analysis and market research.
For advertising and product promotion, including to contact you regarding programs, products, services, and topics that may be of interest or useful.
To administer, provide access to, monitor, and secure our information technology systems, websites, applications, databases, and devices.
To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
To comply with legal and regulatory obligations

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Third parties who assist with our information technology and security programs
Third parties who assist with fraud prevention, detection and mitigation
Our lawyers, auditors and consultants
Third parties who provide marketing and data analytics services, such as social media platforms used to deliver our ads, website/email optimization providers, email marketing vendors, and data analytics vendors.
Legal and regulatory bodies and other third parties as required by law.

COMPLIANCE DATA

We collect this type of information from:

You
Third parties, including companies that help us conduct internal investigations.
Third parties, such as consumer reporting agencies and data aggregators who conduct background screening for us.

Representative Data Elements

Data elements in this category include:

Compliance program data, including customer screening records, and other records maintained to demonstrate compliance with applicable laws, such as tax laws, ADA, et al.
Occupational and environmental safety records
Records relating to complaints and internal investigations, including compliance hotline reports
Records of privacy and security incidents , including any security breach notifications

Purpose for Collecting and Sharing the PI

We use this type of information:

To comply with and demonstrate compliance with applicable laws
For legal matters, including litigation and regulatory matters, including for use in connection with civil, criminal, administrative, or arbitral proceedings, or before regulatory or self-regulatory bodies, including service of process, investigations in anticipation of litigation, execution or enforcement of judgments and orders
For internal business purposes, such as risk management, audit, internal investigations, reporting, analytics
For our everyday business purposes

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Our lawyers, auditors and consultants.
Customers, in connection with their audits of Gradient Flow
Other third parties (including government agencies, courts and opposing law firms, consultants, process servers and parties to litigation) in connection with legal matters

PROFESSIONAL INFORMATION

We collect this type of information from:

You (directly from participant).

Representative Data Elements

Data elements in this category include:

Employer
Job title
Industry

Purpose for Collecting and Sharing the PI

We use this type of information:

To determine and verify program, product, and service eligibility and coverage.
To conduct internal business analysis and market research.
To comply with legal and regulatory obligations
For our everyday business purposes.

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Third parties who provide program enrollment and product fulfillment services in connection with our products and services.
Our lawyers, auditors, and consultants.
Legal and regulatory bodies and other third parties as required by law

WRITTEN SIGNATURE

We collect this type of information from:

You (directly from participant).
Authorized/legal representatives.
Third parties who provide program enrollment and product fulfillment services in connection with our products and services.

Representative Data Elements

Data elements in this category include:

Your signature on a program enrollment form

Purpose for Collecting and Sharing the PI

We use this type of information:

To determine and verify program, product, and service eligibility and coverage.
To enroll you in our programs and provide our products and services to you.
To procure vendor/supplier products and services, including to manage and satisfy related vendor/supplier contractual obligations.
To engage in joint marketing initiatives.
To monitor, investigate, and enforce compliance with our policies, product/service terms and conditions, and legal and regulatory requirements.
To comply with legal and regulatory obligations
For our everyday business purposes.

Categories of Third Parties to whom this type of Personal Information is Shared or Disclosed for a Business Purpose

We may disclose this type of information to our Affiliates and Service Providers and to:

Payors and others as needed to provide the contemplated services or transactions involving the data, such as for processing payments.
Authorized/legal representatives, family members, and caregivers.
Third parties with whom we have joint marketing and similar arrangements.
Payment processors, financial institutions, and others as needed to complete transactions and for authentication, security, and fraud prevention.
Other third parties as necessary to complete transactions and provide our products/services.
Our lawyers, auditors, and consultants.
Legal and regulatory bodies and other third parties as required by law.

Third Party Advertising. If you click “Allow All” or accept certain cookies on our Cookie Banner, we will disclose information about you (as set forth in the section above) to third party advertising companies. We use third party advertising companies to place ads on other websites, including network advertising companies with whom we work who place their own cookies on your browser when you visit our website. This enables these third party advertising companies to collect and use data from their cookie on your browser, which may include information about your visits to this and other websites. These advertising companies use this information in order to deliver advertisements about our goods and services to you when you are on other websites. These advertisements will often be tailored to you. These advertisers may in turn disclose the information about you collected from their cookies to other advertisers to allow those advertisers to display ads to you as well. Under the CCPA, these additional disclosures may be considered a sale of personal information.

Gradient Flow also uses certain third party analytics tools to analyze site performance and aggregated visitor metrics. This helps us measure and improve the performance of our site. You can opt out of this use of your data by emailing us at contact@gradientflow.com or by using the opt-out available from the third parties with whom we work. If you would like to opt-out of having your data used by Google’s cookies, please use the Google Analytics opt-out available here: https://tools.google.com/dlpage/gaoptout/. If you would like to opt out of having your data used by Adobe Analytics, you can use Adobe’s opt-out tool, available here: http://www.adobe.com/privacy/opt-out.html.

In addition, the Digital Advertising Alliance maintains a web site where consumers can opt out from receiving interest-based advertising from some or all of the network advertising companies participating in the program (www.AboutAds.info/choices).

Gradient Flow does not sell and will not sell your Personal Information at this time. In the event that this changes, we will modify this California Supplemental Privacy Policy and take the additional steps required under the CCPA.

Your Rights Under CCPA. In addition, California residents have certain rights with respect to Gradient Flow’s use and disclosure of personal information about California consumers:

Right of Access | Right to Notice. If you are a California resident, you have the right to request that Gradient Flow disclose to you the categories of personal information we have collected about you, the categories of sources from which the Personal Information is collected, the business purpose or commercial purpose for collecting or selling Personal Information, the categories of third parties with whom we share Personal Information, the categories of Personal Information we have disclosed about you for a business purpose. You also have the right to request that we provide you with a copy of the specific pieces of Personal Information we have collected about you in the preceding 12 months.

Right to Deletion. If you are a California resident, you have the right to request that Gradient Flow delete the Personal Information we collect from you. However, in certain situations we are not required to delete your Personal Information, such as when the information is necessary in order to complete the transaction for which the personal information was collected, to provide a good or service requested by you, to comply with a legal obligation, to engage in research, to secure our websites or other online services, or to otherwise use your Personal Information internally in a lawful manner that is compatible with the context in which you provided the information.

Right Not to Be Subject to Discrimination. Gradient Flow shall not discriminate against a consumer because the consumer exercised any of the consumer’s California rights described above.

To exercise any of the rights described above, you can email us at contact@gradientflow.com.