Renee Privacy Statement

Last Updated: October 17, 2022

SixD Inc. (d/b/a Renee) (“Renee”, “we”, or “our”) provides a web-based and mobile application personal health concierge service (“Platform”) for those managing chronic illness and other health conditions. The Platform helps users (“you”) self-manage your illness or condition. This Platform Privacy Statement (“Privacy Statement”) explains how we collect, use, disclose and otherwise process personal information on your behalf in connection with the Platform.

This Privacy Statement does not govern: (a) any websites, mobile applications, or other online services that do not link to this Privacy Statement; (b) the processing of personal information by any third parties outside of the Platform; or (c) our processing of the personal information in connection with any other service or product we offer.

Please carefully review this Privacy Statement.  If you are uncomfortable with or do not agree with any part of this Privacy Statement, you should immediately discontinue use of our Platform.

1. PERSONAL INFORMATION RENEE COLLECTS.
Information You Provide You may provide us with the following categories of information depending upon your relationship to the Platform:

  • Contact information, such as name, email and mailing addresses, and phone number;
  • Account information, such as username and password used to establish an online account with Renee;
  • Demographic information, such as your city, state, country of residence, postal code, date of birth, and age.
    Correspondence information, such as information provided in connection with questions, feedback or other interaction with us through the Platform;
  • Payment information, such as your credit or debit card number, the expiration date of your credit or debit card, the name on your credit or debit card, your billing address, and/or other information that you provide in order to pay for your use of the Platform. We use Stripe® to process your credit card transactions and your payment information will be processed according to their privacy policy (see https://stripe.com/privacy);
  • User-generated content information, such as comments, questions, messages, images, video, and other content or information that you generate, transmit, or otherwise make available on the Platform, as well as associated metadata such as when you comment on our online articles or complete surveys. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data;
  • Relationship information, such as familial or other relationships to third parties whose personal information you may provide to us, such as emergency contact information;
  • Health insurance information, such as your insurance carrier name and account details;
  • Health information, such as medical conditions or symptoms that you voluntarily provide via the Platform such as when you request an office visit, prescription, medication and dosage information, and test/lab results; and
  • Prescriptions. When you upload a prescription through the Platform, we will collect your name, e-mail address, home address, and prescription. In certain circumstances, such as when we are exchanging prescription information with a pharmacy or your healthcare provider, this information may be considered protected health information (“PHI”) and protected under the Health Insurance Portability and Accountability Act (“HIPAA”). We are required to maintain the privacy of PHI, to notify you of any breaches of your unsecured PHI, and to provide you with notice of our legal duties and privacy practices with respect to PHI. More information regarding patient’s HIPAA rights can be found here[Add hyperlink to HIPAA notice.

Information We Obtain from Third-Parties

  • Renee may receive certain information about you, such as, your contact information, health insurance information and other similar information, from the third-party that referred you to the Platform. Typically, this third party is an insurance broker you worked with who believes you may be interested in using the Platform.

2. HOW RENEE USES YOUR INFORMATION.
We primarily use your information to provide you with the Platform and our services. In addition, we may use your information for related purposes, such as to:

  • maintain, improve and develop our services and business;
  • enforce Renee’s terms and conditions, rights, safety or property and/or that of you or others;
  • provide information about the Platform such as updates or changes to the Platform and security alerts;
  • comply with law;
  • protect, investigate and deter against fraudulent, harmful, unauthorized, unethical or illegal activity; and
  • create anonymous, aggregated or deidentified data by removing from the records any identifiers (e.g., ID numbers, account numbers, names, etc.) that make the information personally identifiable to you. We may use and share this non-personal information for our lawful business purposes.

3. HOW RENEE SHARES YOUR PERSONAL INFORMATION.

  • At your direction. Renee may share your information with third parties to facilitate your use of the Platform and our services. For example, we may share you information to enable correspondence through the Platform.
  • With third-party or affiliate service providers. Renee may share your information with third-party or affiliate service providers that perform services for or on behalf of Renee for the purposes described in this Privacy Statement such as to: provide the Platform and our services, optimize the performance of the Platform and our services, provide technical support, and/or provide other services to Renee. We will only disclose your PHI to service providers who have agreed in writing to maintain the privacy of PHI as required by law.
  • In connection with corporate transactions. Renee may share some or all of your information in connection with or during negotiation of any merger, financing, acquisition, dissolution, or other transaction involving the sale, transfer, divestiture or disclosure of all or a portion of Renee’s business or assets. In the event of an insolvency, bankruptcy or receivership, your information may also be transferred as a business asset.
  • Other Disclosures. Regardless of any choices you may make regarding your information, Renee may disclose your information if Renee believes that such disclosure is necessary to (a) comply with relevant laws or to respond to subpoenas or warrants served on Renee; (b) protect and defend Renee’s rights or property, you or other users of the Platform; (c) comply with a legal investigation; and/or (d) to investigate or assist in preventing any violation or potential violation of law, this Privacy Statement or Renee’s terms of use.

We make commercially reasonable efforts to verify that the parties with whom our mobile application shares personal information provide a level of protection of personal information consistent with the practices described in this Privacy Policy, except that all such parties described above other than service providers and affiliates may, to the extent permitted by law, use personal information as described in their own privacy policies.

We do not disclose your contact information to third parties for their own marketing purposes.  Moreover, Renee does not sell your personal data under California or Nevada law, which defines certain disclosures of personal data for monetary or valuable consideration as “sales.”

Renee will determine your compliance with the Terms of Use in our sole discretion and our decision shall be final and binding. Any violation of the Terms of Use may result in restrictions or termination on your access to and use of all or part of the Service and may be referred to law enforcement authorities.

4. AGE LIMITATIONS.
Renee does not allow use of the Platform by anyone younger than 18 years old. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will take steps to delete such information from our files as soon as reasonably practicable.

5. INFORMATION SECURITY
Renee maintains physical, electronic, and procedural safeguards designed to safeguard the security of personal information. Renee cannot, however, guarantee that any safeguards or security measures will be sufficient to prevent an information security issue.

6. INFORMATION RETENTION

Renee retains your information only for so long as it needs to: (a) provide the Platform and our services; (b) comply with legal and accounting obligations; (c) resolve disputes; and (d) enforce the terms of relevant contractual agreements. When we no longer require the personal information that we have collected about you, we may, as permitted by applicable law, delete it, anonymize it, or isolate it from further processing.

7. INTERNATIONAL DATA TRANSFERS.

Renee is headquartered in the United States and may have service providers in other countries. Renee may transfer your information outside of the country in which you reside, including to the United States.

8. LINKS TO OTHER SITES OR APPLICATIONS.

The Platform may contain links to third-party websites or applications. When you click on a link to any other website or location, you will leave the Platform and go to another site or application operated by a third party. The third party may collect personal information about you. Renee’s provision of a link to any other website or location is for your convenience and does not signify Renee’s endorsement of such other website or location or its contents. Renee has no control over, does not review, and is not responsible for these third-party websites or their content. Please be aware that this Privacy Statement does not apply to these third-party websites or applications.

9. YOUR CHOICES REGARDING YOUR INFORMATION.

You may have several choices regarding use of your information on the Platform.

  • Accessing and Correcting Your Information. With respect to the collection of your information, if you do not want your personal information collected, please do not submit it to us. If you have already submitted information and would like to review or correct it, please contact us.
  • Marketing Messages.  We may send you marketing communications about our services that may interest you.  You can opt out of our marketing communications at any time by selecting the “unsubscribe” link in the e-mail or contacting us. Please note that some non-marketing communications are not subject to general opt-out, such as communications relating to services we are providing you, software updates and other support related information, patches and fixes.
  • Cookies. If you decide at any time that you no longer wish to accept Cookies from the Platform, then you can instruct your browser, by changing its settings, to stop accepting Cookies or to prompt you before accepting a Cookie from the Platform. Please consult your browser’s technical information to learn how to exercise this option. If you do not accept Cookies, however, you may not be able to use all or portions of the Platform.
  • How Renee Responds to Do Not Track Signals. Some Internet web browsers transmit “do not track” signals to the websites and other online services with which your web browser communicates. There is currently no standard that governs what, if anything, websites should do when they receive these signals. Currently, Renee does not take action in response to these signals. To find out more about “Do Not Track,” please visit 
http://www.allaboutdnt.com
  • Opting Out of SMS Communications. If you provide your phone number through the Platform, Renee may send you notifications by SMS, such as to alert you of a problem with your account or to send you certain reminders. You may opt out of SMS communications by responding “STOP” to any text message we send you.

10. CHANGES TO THIS PRIVACY STATEMENT.

Renee reserves the right to modify this Privacy Statement at any time. The Platform, laws, regulations and industry standards as well as our business operations may evolve which may make changes to this Privacy Statement appropriate. Renee will post the changes to this page. Renee encourages you to review the Privacy Statement to stay informed. In accordance with applicable law, Renee may notify you of any material changes by email or through a notice on our Platform. If you object to any such changes, you must notify Renee prior to the effective date of such changes that you wish to deactivate your account. Continued use of the Platform following the effective date of such changes indicates your agreeing to such changes.

11. HOW TO CONTACT US

If you have any question about this Privacy Statement, you can contact our privacy team at hello@renee.com.