Fabric Health Inc.

Privacy Notice; Media Release; and Giveaway Terms & Conditions

Last Updated: October 14, 2024

Fabric Health Inc. and its affiliates and subsidiaries (collectively “Fabric Health,” “we,” “our,” and “us”) is fully committed to protecting any personal information relating to an identified or identifiable natural persons (“Personal Data”) that we process.

This Fabric Health Privacy Notice; Media Release; and Giveaway Terms & Conditions (“Notice”) describes our collection, use, disclosure, and retention of Personal Data in relation to our website, marketing, provision of services, data collected through online surveys, WiFi management systems, our interactions with you in-person, by calling us, or by mail, and otherwise during the operation of our business. The Notice also explains the ways in which you may, under applicable laws, be able to control our processing of your Personal Data and exercise other rights. This Notice does not apply to Personal Data of members of our workforce in the context of that relationship or job applicants. Please read this Notice carefully to understand our policies and practices regarding your Personal Data and how we will treat it. If you do not agree with our policies and practices, your choice is not to use any Fabric Health services. By accessing or using our website or services, you agree to this Notice. This Notice may change from time to time. Your continued use of this our website and services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Depending on the way you interact with us, we may occasionally provide you additional information about our processing of your Personal Data addressing specific processing activities and circumstances. We refer to such notices here as “Supplemental Disclosures”. Supplemental Disclosures should be read together with this Notice. However, in the event of any conflict or inconsistency between the terms of the Supplemental Disclosure and this Notice, the Supplemental Disclosure will prevail, but only for the Personal Data processing subject to that disclosure.

Anonymous, de-identified, and aggregated data, as those terms may be defined under applicable law, are not considered “Personal Data” within the meaning of this Notice.

  1. Personal Data We Collect

  2. Why We Process Personal Data

  3. Lawful Bases of Processing

  4. Disclosures of Personal Data

  5. Cross-border Transfers of Personal Data

  6. Data Security and Retention

  7. Your Choices and Rights

  8. Children’s Data

  9. Media Release

  10. Giveaway Terms and Conditions

  11. Revisions to this Notice

  12. Contact Us

Please note that our website, surveys, WiFi management system, and other operations of our business may link to content provided by third parties that we do not control and for which we are not responsible. When you navigate to such content, the relevant third parties may process your Personal Data. We encourage you to read the third parties’ privacy and cookies notices when you leave our website.

1. Personal Data We Collect

Fabric Health or third parties acting on our behalf may collect Personal Data about you from a number of sources. We may also automatically collect Personal Data as you interact with us, such as through cookies and similar technologies on our website and used in the operations of our business, including information such as collecting the IP address from which you visited our site (see further discussion of cookies at the end of this section).

The types and amount of Personal Data that we collect about any particular individual would depend on the nature of our relationship with that individual and the purposes for which we use the individual’s Personal Data. We collect Personal Data from different categories of individuals, including but not limited to the following:

  • Visitors to our digital properties (such as our website and social media)

  • Workforce members and volunteers

Personal Data That You Provide

We collect Personal Data that you choose to provide us, among other interactions. Depending on your relationship with us, you might provide us the following categories of Personal Data when you register for our services, enter a giveaway sponsored by us, post material to our website or social media pages, or request further services:

  • Identifiers and Contact Data, such as your name, alias, postal address, email address, telephone number, city, state, and country of residence, government-issued identifiers (such as passport number or driver’s license), financial account numbers, and similar identifiers;

  • Demographic Data, such as your income levels, marital status, ethnicity, sex, gender, age, sexual orientation, national origin, disability status, citizenship, and work authorization status;

  • Commercial Data, such as invoices, payment terms and schedules, financial account information, and information about services rendered;

  • Images, Recordings, and Postings, such as images and recordings of your likeness or voice, social media postings, and other communications;

  • Personal health information, including your past, present or future physical or mental health or condition, and any health care you may have (in compliance with applicable legal requirements); and

  • Preferences and Survey Responses, such as your preferences regarding communication means and your responses to surveys.

Personal Data That We Collect Automatically

We may automatically collect information that constitutes Personal Data when you interact with us, such as when you visit our digital properties, read our marketing communications, including emails, contact us, or attend events that we are hosting, among other interactions.

Depending on your interaction with us, we might collect the following categories of Personal Data:

  • Identifiers and Contact Data, such as device identifiers (e.g., IP and MAC addresses, cookie identifiers, device advertising identifiers), email address, phone number, and similar identifiers; and

  • Usage and Device Data, such as websites visited, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the devices used to access our websites and apps, volume of transferred data, location data (e.g., inferred by IP address or obtained through GPS), and interactions with advertisements.

We may use cookies and related digital tracking technologies (“Cookies”) on our website or otherwise on our digital properties. This may involve us or third parties collecting Personal Data about online activities over time and across third party websites or online services. We may not respond to web browser Do Not Track signals or similar mechanisms.

Personal Data That We Collect from Third Parties

We may obtain Personal Data relating to you from third parties, such as when we obtain contact data from social media platforms.

The third parties from which we obtain Personal Data generally fall within the following categories:

  • Government sources

  • Publicly accessible data

  • Social media platforms

  • Marketing list suppliers

  • Advertising partners

  • Analytics providers

  • Payment processors

  • Data supplementation suppliers

  • Business partners, such as event co-sponsors

We collect the following categories of Personal Data from third parties:

  • Identifiers and Contact Data, such as name, postal address, email address, telephone number, general location (such as city, state, and country), username, and device identifiers (including cookie identifiers and device advertising identifiers);

  • Demographic Data, such as information about income levels, age, sex, gender, sexual orientation, national origin, and disability status;

  • Usage and Device Data, such as websites visited, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, other technology on the devices used to access our websites and apps, volume of transferred data, location data (e.g., inferred by IP address or obtained through GPS), and interactions with advertisement; and

  • Commercial Data, such as details of products and services purchased or sampled and inferences regarding the population segments to which you might belong.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible third party directly.

2. Why We Process Personal Data

The specific purposes for which Fabric Health processes an individual’s Personal Data differs based on our relationship with the individual. In general, Fabric Health processes Personal Data for the following purposes:

  • To conduct legitimate business activities, including but not limited to marketing, promotion, entering into contractual agreements, contracting with third party service providers, and procuring goods or services, as well as matching data for individuals with known health insurance portals or electronic health records in order to determine whether such individuals may be enrolled in certain insurance plans.

  • To send short message service (SMS or text messages) and electronic mail (e-mail), informing you about relevant events, services, opportunities, and processes related to you and your family. You may opt out of messaging at any time by replying to said messages with STOP

  • To deliver our products, goods, or services, including to fulfill your requested transactions and, where necessary, to confirm that you meet an eligibility criteria if the requested product, good, or service is limited to certain groups.

  • To communicate with individuals, including responding to questions, queries, and complaints from customers, users, donors, and other individuals, responding to requests for donations, sponsorships, scholarships, or charity, and informing individuals about opportunities with Fabric Health.

  • To provide information and advertising, such as digital advertising or direct marketing, about our mission, donation opportunities, goods, services, and products that we think may be useful, relevant, or of interest to you.

  • To provide training, education, and grants, such as our training and education programs that we provide.

  • To provide, maintain, develop, and improve our digital properties, including our websites and social media.

  • To maintain, improve, and investigate the security of our systems and website.

  • To comply with legal obligations.

  • To protect the rights, interests, and safety of us, you, and any third parties, and to exercise and defend our rights.

  • To create anonymous, deidentified, or aggregated datasets. Such datasets would not be “Personal Data” subject to this Notice. We may use anonymous, deidentified, or aggregated datasets for any purpose.

  • In any other way we may describe when you provide the information.

  • For any other purpose with your consent.

3. Disclosures of Personal Data

Where required by applicable law, Fabric Health does not rent, sell, or share Personal Data about you with non-affiliated persons for their direct marketing purposes unless we have your permission. Otherwise, however, we may store and disclose your Personal Data to the following categories of third parties without your consent as permitted by applicable law:

  • Contractors, Service Providers and other third parties, which Fabric Health uses to support our business.

  • Persons with legal rights to access Personal Data, including, as the case may be, law enforcement agencies, intelligence services, competent administrative and judicial authorities, and persons with validly issued subpoenas, warrants, or other forms of legal process;

  • Parties involved in potential business transactions, including potential acquirers and other stakeholders in the event of a merger or legal restructuring operation such as an acquisition, joint venture, assignment, spin-off, divestiture, or bankruptcy; and

  • Other Third Parties, as required or allowed by law.

  • For any other purpose disclosed by us when you provide the information.

  • To fulfill the purpose for which you provide it.

  • With your consent.

We may also disclose your Personal Data to third parties such as social networking and other sites if you direct us to share your Personal Data with such sites or to other entities that do not fall in one of the above categories with your permission.

4. Data Security and Retention

Fabric Health implements various technical, administrative, physical, and organizational measures to protect the security and confidentiality of Personal Data. While we take measures to safeguard your Personal Data, we cannot guarantee that the Personal Data we process will remain secure.

Where required by law, Fabric Health will retain Personal Data only for as long as necessary to accomplish the purposes for which the Personal Data was collected or for the period required by the applicable laws (whichever is longer).

To determine the appropriate retention period for your Personal Data, Fabric Health considers the following factors:

  • The volume, nature, and sensitivity of the Personal Data;

  • The potential risk of harm from its unauthorized use or disclosure;

  • The purposes for which we process it and whether we can achieve those purposes through other means; and

  • Applicable legal requirements.

When the retention of your Personal Data is no longer necessary for the purposes for which it was collected or our retention of such Personal Data is no longer allowed or required by law, we will delete, anonymize, deidentify, or aggregate the Personal Data such that it is no longer associated with you.

5. Your Choices and Rights

Some jurisdictions have provided individuals with certain rights in relation to the processing of their Personal Data. These rights are not available to everyone, and they do not necessarily apply in all contexts. Depending on applicable law and the context of the request, you may have the rights to:

  • Request access to or transfer of your Personal Data.

  • Request correction of your Personal Data (should your Personal Data be inaccurate, incomplete, or obsolete).

  • Request deletion of your Personal Data.

  • Withdraw your consent to processing (where we processed Personal Data on the basis of your consent). Please note that withdrawing your consent applies only to future processing activities.

  • Object to or request restrictions on the processing of your Personal Data.

  • Opt-out of certain transfers to third parties.

To exercise a right that you believe you may be entitled to under applicable law, please contact us as indicated below. We may need to verify your identity before we fulfill your request.

If you feel that we have failed to comply with your request or have not addressed a complaint that you have, please contact us at hello@fabrichealth.org. You may also have the right to complain to the competent data protection or other regulatory authority in your jurisdiction.

6. Children’s Data

We do not knowingly process Personal Data relating to individuals younger than 16 without the permission of the minor’s guardian, except where permitted under applicable law. If you have reason to believe that we are processing Personal Data relating to a minor without permission from the minor’s guardian, please notify us at hello@fabrichealth.org.

7. Media Release

I hereby grant to Fabric Health, their agents, successors, and their assignees the right to record the image and/or voice and use the artwork and/or written work of me and my children, on videotape, on film, on photographs, in digital media and in any other form of electronic or print medium and to edit such recording at their discretion. I further grant Fabric Health, their agents, successors, and their assignees the right to use, and to allow others to use, my image and/or voice as well the image and/or voice of my children on the internet, in brochures, and in any other medium, and hereby consent to such use. I hereby release Fabric Health, their agents, successors, and their assignees using my image and/or voice, artwork, and/or written work, as well as the image, voice, artwork, and/or written work of my children, pursuant to this media release form any and all claims, damages, liabilities, costs and expenses which I or my children now have or may hereafter have by reason of any use thereof. I understand that the provisions of this release are legally binding.

8. Giveaway Terms and Conditions Promotion Description

In order to be eligible you must be at least 18 years old. Fabric Health shall make the sole determination on eligibility. Although no purchase is necessary to participate in giveaways and/or other promotions and winners are chosen randomly, all potential winners are subject to verification by Fabric Health, whose decisions are final and binding in all matters related to such as giveaways (a “Giveaway”). The potential winner(s) may be notified by email or phone, including text message. If a potential winner of the prize cannot be contacted, or if the prize is returned as undeliverable, such potential winner forfeits the prize. In the event the prize winner is disqualified for any reason, Fabric Health will award the prize to an alternate winner. By the receipt of any prize, the winner agrees to release and hold harmless Fabric Health and its respective subsidiary, and affiliate companies, suppliers, distributors, and advertising/promotion agencies, as well as each such company's officers, directors, employees, and agents (collectively, the “Released Parties”) from and against any claim or cause of action, including, but not limited to, personal injury, death, or damage to or loss of property, arising out of participation in any Giveaway or receipt, use, or misuse of any prize. Except where prohibited or further consent is required, participation in any Giveaway constitutes winner’s consent to Fabric Health’s and its agents use of winner’s name, likeness, photograph, voice, opinion, and/or hometown and state for promotional purposes in any media, worldwide, without further payment or consideration. The winner’s name will be announced publicly. Fabric Health reserves the right to cancel, suspend and/or modify any Giveaway as determined by Fabric Health in its sole discretion. Fabric Health reserves the right, in its sole discretion to disqualify any individual, without compensation, it finds to be tampering with the entry process or the operation of a Giveaway or any other promotion or in an unsportsmanlike or disruptive manner. Any attempt by any person to deliberately undermine the legitimate operation of a Giveaway may be a violation of criminal and civil law, and, should such an attempt be made, Fabric Health reserves the right to seek damages from any such person to the fullest extent permitted by law. The Released Parties are not liable for: (1) any incorrect or inaccurate information, whether caused by entrants, printing errors, or by any of the equipment or programming associated with or utilized in the Giveaway; (2) unauthorized human intervention in any part of the entry process of a Giveaway; (3) technical or human error which may occur in the administration of the Giveaway or the processing of entries; or (4) any injury or damage to persons or property which may be caused, directly or indirectly, in whole or in part, from entrant’s participation in a Giveaway or receipt or use or misuse of any prize. Except where prohibited, entrant agrees that: (1) any and all disputes, claims, and causes of action arising out of or connected with a Giveaway or any prize awarded shall be resolved individually, without resort to any form of class action, and exclusively by a state or federal court located in Washington, D.C.; (2) any and all claims, judgments and awards shall be limited to actual out-of-pocket costs incurred, including costs associated with entering a Giveaway, but in no event attorney’s fees; and (3) under no circumstances will entrant be permitted to obtain awards for indirect, punitive, incidental, and consequential damages and any other damages, other than for actual out-of-pocket expenses, and any and all rights to have damages multiplied or otherwise increased.

9. Revisions to this Notice

We may update this Notice from time to time. You are encouraged to consult this Notice on a regular basis and check the date on which the Notice was last updated, as shown at the beginning of the Notice. When we make a material change to the Notice, we may notify you by placing a notice on our website or notice as otherwise required by law.

10. Contact Us

To exercise your rights or make a request concerning the processing of your Personal Data, you may contact us by: