Curative Privacy Policy
Last Updated: January 1, 2025
This Privacy Policy describes the types of Personal Information that Curative Inc. (“Curative,” “we,” “our,” or “us”) collects from and about you, how we may use and disclose such information, and your choices and legal rights with respect to such information. We ask that you carefully review this Privacy Policy, as it applies to any Curative website (a “Site”) that displays or links to this Privacy Policy (collectively, our “Services”).
Curative members can access the member portal through the Site. The member portal is governed by the Notice of Privacy Practices issued by Curative under the Health Insurance Portability and Accountability Act (“HIPAA”).
“Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, to you, and includes “personal data” or similar terms as defined under applicable law.
1. NOTICE AT COLLECTION OF PERSONAL INFORMATION
We collect the categories of Personal Information listed below. We do not “sell” or “share” (as those terms are defined in California law) Personal Information.
Category of Personal Information Collected
Identifiers/biographical information, including name, postal and email address, phone number, online identifiers, Internet Protocol (“IP”) address, and other similar identifiers: No
Identifiers/biographical information, including name, postal and email address, phone number, online identifiers, Internet Protocol (“IP”) address, and other similar identifiers: No
Characteristics of protected classifications under California or Federal law, including age and gender: No
Commercial information, including services obtained from us: No
Internet or other electronic network activity information: No
Geolocation data: No
Professional or employment-related information: No
Education information: No
Inferences, meaning inferences drawn from the above-listed categories of Personal Information to create a consumer profile reflecting consumer preferences or characteristics: Yes
Sensitive Personal Information, including Personal Information that reveals precise geolocation and health or medical information (such as health symptoms, health conditions and medications): No
We do not knowingly sell or share personal information about individuals under the age of 16.
B. The Business and Commercial Purposes for Which We Collect and Use Your Personal Information:
To provide you with our Services
To process your payments and fulfill your orders
To create, maintain, customize, and secure your account with us
To send you requested product or service information
To respond to customer service requests
To administer your account
To send you newsletters, voice messages, text messages or email communications
To respond to your questions and concerns, including through bots
To improve the Services and our marketing efforts
To conduct internal quality improvement or business analysis
To customize your experience on the Site, including the display of location-based information that's relevant to your care and how to find care
To review the usage and maintain the operation of our Services
To monitor, protect, and maintain the security and integrity of our Services and our business, and protect against fraud
To comply with applicable laws and regulations and respond to lawful requests for information
To carry out sales and business transactions in which Personal Information held by us is among the assets transferred or is otherwise relevant to the evaluation, negotiation, or completion of the transaction
To protect our rights, privacy, safety, property and/or those of others
To fulfill any other purpose for which you provide your Personal Information or as explained to you at the point of information collection
C. Retention
We will retain your Personal Information for as long as reasonably necessary to provide you with our Services that you request, for marketing purposes unless you opt out as described in our Privacy Policy, or otherwise where permitted or required in accordance with applicable law. We will retain and use your Personal Information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. What this means in practice will vary between different types of information, and retention periods take into account ongoing business or legal needs for the information, for example in relation to tax, health and safety, and potential or actual disputes or investigations.
2. PERSONAL INFORMATION WE COLLECT
There are several ways we may obtain Personal Information about you, including through (A) information you provide to us; (B) information we automatically collect; (C) information we receive from third parties; and (D) combining information from different sources. This includes data that identifies you personally whether directly or indirectly.
A. Information You Provide
We collect Personal Information as listed in the above Notice at Collection from you as follows:
When You Use our Services. We collect Personal Information from you when inquire about or create an account to use the Services.
When You Provide Information About a Third Party. When you provide us with Personal Information about dependents and family members.
When You Respond to Surveys or Provide Feedback. We periodically ask users to complete surveys asking about their experiences with features of the Services. Our surveys ask visitors for demographic information such as age, gender, and education, but will not request that users provide specific information about any medical condition. We use survey information for evaluation and quality improvement purposes, including helping Curative to improve information and services offered through the Site. In addition, users giving feedback may be individually contacted for follow-up due to concerns raised during the course of such evaluation.
B. Information We Automatically Collect
When you visit and interact with our Services, we and our service providers automatically collect certain information regarding your activity.
The information includes:
Device and Browser Information. This includes your device’s IP address and/or other unique identifiers, browser type, device type, internet service provider, and operating system.
Location Information. When you access our Services from a mobile device, your device’s approximate location (derived from your device’s IP address or other signals) may be collected.
Usage Information. When you interact with our Services, certain information may be collected, including the date and time of your visit, the pages you view immediately before and after you access our Services, the areas or pages of our Services that you visit, the amount of time you spend viewing or using our Services, recordings of chat sessions (including with the involvement of bots), and other Site usage information. We (or our third-party vendors) may use tools and software to monitor and record information (including screenshots and videos) about your interactions with our Services, including keystrokes, mouse movements, form field entries, and overall engagement with our Services.
Marketing Information. If you receive an email from us, information may be collected about your interactions with the message (e.g., whether you opened, forwarded, or clicked through to our Site).
Third-party analytics technologies. We may use third-party analytics tools to better understand who is using our Services, how people are using them, and how to improve their effectiveness as well as the effectiveness of any related content.
Cookies and Other Similar Technologies: “Cookies” are text files that are placed on your browser by the websites that you visit. Cookies are used for various purposes, including to distinguish you from other users, make your site navigation more efficient, help remember your preferences, enhance your browsing experience, and improve the use and functionality of our Sites and related content. They can also enable the delivery of relevant and personalized advertisements to you across the Internet.
Cookies (and other similar technologies) provided by third parties may be placed on our Sites and the providers of these technologies may combine information collected from your interaction(s) with our Services with information they collect from other sources and use the combined information for analytics and/or advertising purposes.
To learn more about your choices regarding the automatic collection and use of your information as you browse our Services, please see the Your Privacy Choices and Rights section below.
C. Information We Receive from Third Parties
We may receive Personal Information from other sources, including online advertising networks and analytics providers, social media platforms, and companies such as data aggregators that supplement the data that we collect from you.
D. Combination of Information
We may combine Personal Information that we receive from various sources. We use, disclose, and protect combined Personal Information as described in this Privacy Policy.
3. HOW WE DISCLOSE YOUR PERSONAL INFORMATION
We may disclose each category of your Personal Information that we collect to the following categories of recipients:
Our Service Providers. We disclose your Personal Information to our service providers that provide business, professional, marketing, analytics, or technical support services to us, help us operate our business and the Services, or administer activities on our behalf. We require our service providers to only use your Personal Information in connection with providing services to Curative.
In certain circumstances, we may disclose each category of your Personal Information to:
Competent Governmental, Regulatory, and Public Authorities. We may disclose your Personal Information to government and law enforcement authorities, in each case to comply with legal or regulatory obligations or requests.
Relevant Third Parties as Part of a Corporate Transaction. In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with a bankruptcy or similar proceeding), we may disclose or transfer your Personal Information to certain third parties, such as the acquiring entity and its advisers.
Other Third Parties. We will disclose your Personal Information to other third parties at your direction or with your consent. Additionally, we will disclose your Personal Information as we believe necessary or appropriate to: (a) comply with applicable law; (b) enforce our terms and conditions; (c) protect our operations; (d) protect our rights, privacy, safety, or property, and/or those of you or others; and (e) allow us to pursue available remedies or limit damages that we may sustain.
We may disclose your Personal Information for other reasons that we will describe at the time of information collection or prior to disclosing your information.
We may de-identify or aggregate Personal Information so that it is no longer Personal Information. Our use of de-identified or aggregated information is not governed by this Privacy Policy.
4. YOUR PRIVACY CHOICES AND RIGHTS
You have the ability to make certain choices about how we use your Personal Information, as follows:
A. Unsubscribing from our Marketing and Promotional Communications
From time to time, we may send you marketing and promotional communications. If you no longer wish to receive promotional and marketing emails from us, you may opt out at any time by following the instructions included in such messages.
B. Privacy Rights and Requests
Depending on your U.S. state of residence, you may have certain rights in relation to your Personal Information, including:
Right to Know: You may have the right to know what Personal Information we have collected about you, including the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information (including the names of such third parties), the categories of Personal Information disclosed to third parties, and the specific pieces of Personal Information we have collected about you. Please note that we may not be required to respond to your requests “to know” or access specific pieces of Personal Information more than twice in any 12-month period.
Right to Data Portability: You may have the right to access your information in a portable format.
Right to Delete: You may have the right to request that we delete Personal Information that we have collected from you, subject to certain exceptions.
Right to Correct: You may have the right to correct inaccurate Personal Information that we may maintain about you, subject to appropriate verification.
Right to Limit Use or Disclosure of Sensitive Personal Information: You may have the right to request that we limit the use or disclosure of your Sensitive Personal Information, subject to certain exceptions.
Where permitted under applicable law, we may decline a request (other than for opt outs) if we are unable to verify your identity (or an agent’s authority to make the request) and confirm the Personal Information we maintain relates to you.
If you are interested in exercising one or more of the rights outlined above, please contact us at privacy@curative.com or 855-428-7284. Please put the statement “Your Privacy Rights” in the subject field of your email. We may take steps to verify your identity before responding to your request by asking you a series of questions about your previous interactions with us. Submitting a privacy rights request does not require you to create an account with us.
We will not discriminate against you if you decide to exercise your privacy rights.
C. Agent Requests
Only you, or someone legally authorized to act on your behalf, may submit a request related to your Personal Information. You may also submit a request on behalf of your minor child.
Depending on your U.S. state of residence, you may authorize someone to make a privacy rights request on your behalf (an authorized agent). Authorized agents will need to demonstrate that you’ve authorized them to act on your behalf. Curative retains the right to request confirmation directly from you confirming that the agent is authorized to make such a request, or to request additional information to confirm the agent’s identity.
D. Right to Appeal
Depending on your U.S. state of residence, you may have the right to appeal a decision we have made in connection with your privacy rights request. To appeal a decision, please contact us at privacy@curative.com or 855-428-7284.
5. EXTERNAL LINKS
Our Services may have links to third-party services, which may have privacy policies that differ from our own. We are not responsible for the practices of such sites.
6. MINORS’ PRIVACY
Our Services are intended for a general audience. We do not direct our Services to individuals under eighteen (18), nor do we knowingly solicit or collect any Personal Information from minors.
7. DATA SECURITY
We have implemented physical, administrative, and technical safeguards to maintain the security, confidentiality, and integrity of your information. However, as no transmission of information over the internet is absolutely secure, we cannot guarantee the safety of your information.
8. REVISIONS TO THIS PRIVACY POLICY
We reserve the right, in our sole discretion, to change, modify, add, remove, or otherwise revise portions of this Privacy Policy at any time. When we do, we will post the change(s) to our Services. Your continued use of our Services following the posting of changes to these terms means you accept these changes. If we change the Privacy Policy in a material way, we will provide appropriate notice to you. Such notice may be provided via a temporary banner on our Site, an email sent to users for whom we have an email address, or by temporarily noting “UPDATED” next to the Privacy Policy link on the footer of our Site.
9. HOW TO CONTACT US
If you have any questions or concerns about this Privacy Policy or the practices described herein, you may contact us at privacy@curative.com or by phone at 855-428-7284 or by mail to:
Curative
ATTN: Privacy Officer
900 Congress Avenue, Suite 500
Austin, TX 78701