Ada Health COVID-19 Risk Severity and Authorized Oral Antiviral Potential Eligibility Questionnaire Privacy Policy

Ada Health, Inc. is committed to protecting your privacy. This policy (the “Privacy Policy”), together with any other policies referenced herein, describes what type of Personal Information (as defined below) we collect about you when you use this COVID-19 Risk Severity and Authorized Oral Antiviral Potential Eligibility Questionnaire and connected services (“Questionnaire”), how and why we use it, how we secure it, and what are your legal rights relating to it.

Please read this Privacy Policy carefully before using this Questionnaire.

You must be at least 18 years of age and a resident of the United States of America to use this Questionnaire. Individuals outside of the United States should not use this Questionnaire or provide us with any of their Personal Information. By using this Questionnaire and providing us with your Personal Information, you acknowledge and agree that it may be transferred to, processed or stored outside of the United States of America.

By accessing or using this Questionnaire, you represent that you are to be bound by and comply with this Privacy Policy, and any other policies referenced herein. If you do not agree with this Privacy Policy, you should immediately discontinue the use of this Questionnaire.

Any capitalized terms not defined in this Privacy Policy have the same meaning as in the Terms and Conditions.

1. Personal information we collect about you

When you use this Questionnaire, we may collect, receive, and process information that can be used to identify you, either alone or in combination with other information, which may include “protected health information” as defined by the Health Insurance and Portability Act of 1996 (collectively, the “Personal Information”).  We collect this information directly from you, both automatically and when you provide it to us, and from third parties.

We may collect and process the following types of Personal Information about you:

• Website and Device Information. We collect information about your browser or device when you use this Questionnaire. This information includes IP address of the requesting device, date and time of access, name and URL of the requested file, browser used and, where applicable, your device’s operating system and the identity of your ISP.
• Usage Information. We may collect some information about your use of this Questionnaire. This information includes details of your visits to this Questionnaire; including length of visits to certain pages, drop off points, and page interaction information (such as scrolling, finger gestures, clicks, and mouse-overs). This information helps us ensure proper use, functioning, maintenance, and improvement of this Questionnaire as well as understand how our users interact with the Questionnaire (ie: how many users have used it) or ads for it and improve this Questionnaire as well as our marketing campaigns accordingly. To this end, we also use cookies and pixels such as the Microsoft ad, Meta and Google, and programmatic pixels or similar technology on our website. 
  The information collected includes: 
  — For cookies: version and browser type, website from which access is obtained (“Referrer URL”) , host name of the accessing device, time of server request, and where applicable your device’s operating system and the identity of your access provider.
  — For pixels or similar technology on our website: we collect type of operating system, screen resolution, type of device used, time of website visit, time of email read, type of website used, type of email used, IP address, activities performed on the site during a browsing session. Specifically, the Microsoft ads, Meta and Google pixels will collect information  about your access of the Questionnaire landing page as well as the start and completion of the Questionnaire.. In addition, the information collected is processed by the providers of those cookies and pixels according to their own privacy policies and terms and conditions and might be linked to you as a user of those provider’s other services. Ada will not use this information to identify you. For the avoidance of doubt: your input  in the Questionnaire (i.e. any your Health Related Information) is not shared with third parties.
• Health Related Information. We collect information relating to your health when you respond to questions in this Questionnaire. This information includes information about your ethnicity, COVID-19 symptoms, and other health-related information (e.g. smoking, pregnancy status,), underlying medical conditions). This Health-Related Information cannot and will not be directly linked back to you.

2. How we use your personal information

We may use your Health-Related Information for the following purposes:

• Provide you with a summary of your results based on your answers to this Questionnaire.
• Gather user insights and improve this Questionnaire.
• Ensure the Questionnaire and the Ada Platform maintain the highest medical quality and safety standards as may be required by regulatory authorities.  To the extent possible, we use anonymized data and when applicable, aggregated data to perform this task.  However, in rare circumstances we may need to utilize your individual Health- Related Information to meet our regulatory obligations.

Under no circumstances will Ada share any of your individual Health-Related Information you provide in this Questionnaire with the financial sponsor of this Questionnaire, Pfizer, Inc. (see Section 4 below). Ada may share with Pfizer aggregated Usage Information from the use of this Questionnaire which will be on a solely aggregated (not individual) basis only.

We may use your Other Personal Information for the following purposes:

• To perform research about the use of this Questionnaire including how visitors interact with this Questionnaire during use by collecting and reporting usage information.
• To gather user insights and improve this Questionnaire.
• To inform future activities or connected services related to this Questionnaire. (we will not use your Health-Related Information for this purpose.)
• To notify you about changes to this Questionnaire.
• To interact with you as necessary to provide the Questionnaire or connected services, e.g. for customer service needs regarding the use of this Questionnaire and to fulfill visitor’s data protection requests.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us.

3. Where we store your personal information

We store your Personal Information in the European Union.  Please note that your Personal Information may be transferred to and stored in the EU. We treat your Personal Information in accordance with United States laws and this Privacy Policy. If you live outside the United States, any Personal Information you provide is at your own risk.

4. How we share your personal information

We may share some of your Personal Information with our service providers to provide you with this Questionnaire. In such instances, we will impose contractual obligations of security and confidentiality on such third parties. We will not sell or share your input into the Questionnaire with third parties.

Specifically, we may disclose your Personal Information as follows:

• Our German entity, Ada GmbH. We are an international business headquartered in Germany, and we may thus share your Personal Information with our German Entity, Ada GmbH located at Neue Grünstraße 17, 10179 Berlin, Germany.
• Financial sponsor of this Questionnaire, Pfizer Inc. We may share some limited Usage Information of this Questionnaire in aggregate and in anonymous form with our financial sponsor for this Questionnaire, Pfizer, Inc., a company incorporated in Delaware, with its registered office at 235 E 42ND ST New York NY 10017 (“Pfizer”).
• Service providers. We may share your Personal Information with our other third-party service providers we use to support our business and provide this Questionnaire on the Ada Platform and who are bound by contractual obligations to keep Personal Information confidential and secure.
• Successor Entities.  We may disclose your Personal Information to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ada Health’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Ada Health about our users is among the assets transferred.
• To enforce or apply our Terms and Conditions and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Ada Health, our affiliates, service providers, business partners, customers, or others.

We will not sell, lease, or rent your Personal Information; opting out. That is, we will not provide your Personal Information to any third party in return for money. In this colloquial sense, we will not sell or share your Personal Information with third parties other than our service providers for their own business interests. Your input in the Questionnaire will only be used for the purpose of providing you with the Questionnaire and for nothing else.

We do use cookies, pixels or other technology (see section1 above and section 6 below) in our services to track certain parameters (never Health Related Data) such as how many people have started and completed our Questionnaire. Those events might be shared with the providers of the technology in a fashion that allows them to link those events to you. This type of disclosure may constitute “selling” or “sharing” of your personal information in a legal sense under data protections or privacy laws such as the CCPA/CPRA in California. These laws often provide you with a right to opt out of such “selling” or “sharing”. In that case, you can exercise your right by clicking on the Link “Do not sell or share my personal information” at the bottom of the Website or click here.

In addition, we will not share your Personal Information with any public databases or to an insurance company or your employer.  We will not provide your Personal Information to law enforcement or regulatory authorities unless required by law to comply with a valid court order, subpoena, or search warrant.

5. Security of your personal information

We take steps to secure the Personal Information you provide to us when using this Questionnaire. Ada maintains measures to ensure an adequate level of data security. These technical, contractual and organizational measures include encryption, password protection, access restriction etc.

Please note that although we do our best to protect your Personal Information, we cannot guarantee the security of all Personal Information during communication via the internet. Any such communication is at your own risk. By agreeing to this Privacy Policy, you expressly agree that the communication between you and us, may take place without restriction and without the use of additional encryption procedures via the e-mail address provided to us by you.

6. Our use of cookies

We use cookies, pixels and similar tools on its website to help provide you with a user-friendly, secure, and effective Questionnaire.

Cookies are small text files which a website may put on your device during your first visit. The cookie helps the website to recognize your device the next time you visit it. We use the term “cookies” in this policy to refer to all files that collect information in this way.

Generally, our cookies perform at least one of the following functions:

• Necessary. Necessary cookies are essential to provide you with this Questionnaire.  It enables basic functions like page navigation.
• Statistics and Performance. Statistic and performance cookies help us understand how visitors initially access the Questionnaire and how visitors interact with this Questionnaire during use by collecting and reporting usage information. It also informs future activities or connected services related to this Questionnaire.
• Marketing. Marketing cookies enable us to better understand through with channels users are accessing the Questionnaire.

7. California residents

If you reside in California, you may have certain additional rights regarding your “personal information” as defined under the California Consumer Privacy Act of 2018 (CCPA) or otherwise.  This section of our Privacy Policy supplements the information provided elsewhere in our Privacy Policy.

The below chart shows you where to find details about the information to which you may be entitled under the CCPA:

In addition, California consumers may have the following rights under the CCPA:

• To request that we disclose what Personal Information we collect, use, or disclose about you.
• To know the specific pieces of Personal Information we hold about you.
• To request the deletion of your Personal Information, with some exceptions.
• To request that we stop selling or sharing your personal information.

To exercise your rights under the CCPA, you may email us at [email protected].

8. Changes to this privacy policy

We may, in our sole discretion, change this Privacy Policy from time to time to reflect the changes to this Questionnaire Any changes will be effective upon the posting of the revisions on our website. Your use of this Questionnaire will be subject to the most current version of the Privacy Policy. Your continued use of this Questionnaire after such changes are implemented constitute your acknowledgment and acceptance of the changes. If you do not agree to any changes to this Privacy Policy, please immediately discontinue your use of this Questionnaire.

9. How to contact us

If you have questions about this Privacy Policy, or wish to submit a complaint, request or inquiry, please email our Data Protection Officer at [email protected].