PRIVACY NOTICE

Jaguar Health, Inc. (“Jaguar” or “we” or “us”) respects the privacy of every person who visits our websites, including but not limited to the Jaguar website, https://jaguar.health, and Neonorm™ website, https://neonorm.com (“Websites”). This Privacy Policy (the “Privacy Policy”) has been compiled to better serve those who are concerned with how their Personally Identifiable Information (PII) is being used online. PII, as described in US privacy law and information security, is information that can be used on its own or with other information to identify, contact, or locate a single person, or to identify an individual in context. Please read our privacy policy carefully to get a clear understanding of how we collect, use, protect or otherwise handle your PII in accordance with our website.

This Privacy Policy will also tell you how you can verify the accuracy of your personal information submitted to us through the website and how you can request that we delete or update personal information. We refer to our Website visitors as users (“Users”) of the Services. Please read our Legal Notice.

WHAT INFORMATION DO WE COLLECT?

Our primary goal in collecting personal information from you is to give you a meaningful, enjoyable and customized experience while using the Websites, and to develop new products and services which are relevant to consumers like you. Personal information also allows us to provide services and features that most likely meet your needs, and to customize service to make your online experience smooth and efficient.

Personal information received from you online will only be used for our internal technical, administrative, or marketing purposes, except as otherwise required by law or as we disclose to you when the information is collected.

  • Personal Information: When you visit our Websites, we will not collect any personal information about you (including, but not limited to, your name, address, telephone number, email address, and credit card number if you place an order with us) unless you provide it to us voluntarily. If you choose not to provide your personal information you can still access the Websites; however, you may be unable to participate in certain activities or place orders for products.
  • Aggregate and Statistical Data: We may collect certain aggregate data called web log information (such as your web browser, operating system, pages visited, etc.) and use cookies when you visit some of our web pages. For instance, when you visit our Websites, our web server will automatically recognize some non-personal information, including but not limited to the date and time you visited our site, the pages you visited, the referrer (the website you came from), the type of browser you are using (e.g., Firefox, Chrome, Internet Explorer), the type of operating system you are using (e.g., WinXP, Win10, or Mac OS), and the domain name and address of your Internet service provider (e.g., Comcast, AT&T, Verizon).

In some cases, we may also collect information about you that you voluntarily submit but which is not personal, such as general statistical information like age, gender, ZIP/postal code, preferences and interests.

WHAT DO WE DO WITH THE PERSONAL INFORMATION WE COLLECT? 

Jaguar does not require visitors to our Websites to provide personal information in order to obtain access. Jaguar collects personal information (including but not limited to your name, address, telephone number, and email address) from our visitors only on a voluntary basis.

At Jaguar Websites, you can sometimes enter contests, vote in polls or otherwise express an opinion, subscribe to one of our Services such as newsletters, or participate in one of our online contests. These programs require you to submit some information in order to participate. These programs and the types of information required are described in more detail below.

  • Registration: To fully use our Websites, visitors may need to register using our online registration forms, where visitors will be required to provide us with their personal information. Visitors may also be asked to provide an email address and password. You can further make choices about receiving email newsletters and alerts from Jaguar. You can always decide not to receive or stop receiving any email from Jaguar that you do not want.
  • Contests: Jaguar may run contests and other promotions on our Websites or through interactive banner ads. These events may ask you to provide personal information which is needed in order to administer the contest or promotion and to notify winners.
  • Referrals: Occasionally, visitors will have the opportunity to forward information on the Websites to friends/relatives or to send messages from our Websites to friends/relatives. This personal referral information you provide to facilitate this communication is used on a one-time basis and is not further retained by Jaguar, except in circumstances where we obtain consent from the people you have referred to receive communications from us.
  • Questionnaires, Surveys and Profile Data: Jaguar may occasionally ask visitors to complete surveys and opinion polls about their interests, needs, and attitudes. Surveys help us provide better services and products that meet customer needs. Participation is completely voluntary and these surveys are optional.
  • Consumer Services and Contact Information: If you provide our customer service representatives with feedback on your experiences with our products/services or otherwise submit questions to our customer service representatives or webmasters, you will be asked to supply personal information for our recordkeeping and follow-up.

COOKIES AND THIRD-PARTY TRACKING

Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the site’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we use cookies to help us remember and process the items in your shopping cart. They are also used to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future.

We use cookies to:

  • Help remember and process the items in the shopping cart.
  • Understand and save user’s preferences for future visits.
  • Keep track of advertisements.
  • Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.

You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies.

If you turn cookies off, some of the features that make your site experience more efficient may not function properly.

We also use the services of other companies to optimize our Websites and our Services. You will receive an overview of the Services we use in the following section.

  • Google Analytics: Our Websites use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies, text files stored on your computer, to help a website operator analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) is transmitted to and stored by Google on servers in the United States. Google uses this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators, and providing other services relating to website activity and internet usage to the website operator. Your IP address, which has been transmitted by Google Analytics, will not be associated with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that if you do this, you may not be able to use all functions of this website. Furthermore, you can prohibit Google from collecting and analyzing the cookie-generated data about your use of the website (including your IP address) by clicking here or downloading and installing the browser plugin available here http://tools.google.com/dlpage/gaoptout?hl=en. If you visit our Websites using a mobile device (e.g. a smartphone or tablet), you can refuse the future use of Google Analytics via this link. By activating the link, we will put a cookie in your browser, which signals to us that we should prevent Google Analytics from using your device. Please keep in mind that you will have to repeat the refusal process if you remove the cookies from your browser.
  • Google Remarketing: Our websites use Google’s remarketing technology. This technology enables users who have already visited our online Services and shown interest in our Services to see targeted advertising on the websites of the Google partner network. Likewise, users that are similar to the visitors of our Websites can receive targeted advertising. The advertising will be displayed using cookies. These are small text files saved on the user’s computer. The information generated by the cookie about the website use will be transmitted to and stored on servers in the United States by Google. In the event that the IP address is transferred, it will be reduced by the last 3 digits. Using cookies, the user behavior on a website can be analyzed and subsequently utilized to provide targeted product recommendations and advertising based on the user’s interests. If you would prefer to not receive any targeted advertising, you can deactivate the use of cookies for these purposes through Google by visiting the website: https://www.google.com/settings/ads/. Alternatively, users can deactivate the use of cookies by third party providers by visiting the Network Advertising Initiative’s deactivation website (http://www.networkadvertising.org/choices/). Please note that Google has its own data protection policy which is independent of our own. We assume no responsibility or liability for their policies and procedures. Please read Google’s privacy policy before using our Websites (https://www.google.com/intl/en/policies/privacy/).
  • Facebook Conversion Tracking Pixel: With your permission, our Websites utilize the Conversion Tracking Pixel service of Facebook, Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA (“Facebook”). This tool allows us to follow the actions of users after they are redirected to a provider’s website by clicking on a Facebook advertisement. We are thus able to record the efficacy of Facebook advertisements for statistical and market research purposes. The collected data remain anonymous. This means that we cannot see the personal data of any individual user. However, the collected data are saved and processed by Facebook. We are informing you about this matter according to our information at this time. Facebook is able to connect the data with your Facebook account and use the data for their own advertising purposes, in accordance with Facebook’s Data Use Policy found under: https://www.facebook.com/about/privacy/. Facebook Conversion Tracking also allows Facebook and its partners to show you advertisements on and outside Facebook. In addition, a cookie will be saved onto your computer for these purposes. Only users over 13 years of age may give their permission. If you are younger than this age, please consult your legal guardians. Please click here if you would like to revoke your permission: https://www.facebook.com/ads/website_custom_audiences/.
  • Facebook Login: We also offer you an easier way to register for our Services. You can use your existing Facebook account for this purpose. By clicking the Login with Facebook link, you can use this registration method via our online portal. To do this, you need to already have a Facebook account or have access to Facebook. If you would like to register for one of our Services via your Facebook account, the first step of the registration process will immediately redirect you to Facebook. Facebook will then ask you to log in or register. At no time will we have access to your personal login information (username and password). In a second step, you will connect your Facebook profile with the Service that you would like to register for. At this point, you will learn what data from your Facebook profile will be transmitted to us. This information is usually your “public information” on Facebook and information that you have made available to the public or authorized for the application in question. Information of this type generally includes your name, profile picture and cover photo, your networks, your username (Facebook URL), and your user ID number (Facebook ID). We will also use the email address you have saved with Facebook in order to contact you outside of Facebook. You can see an overview of the public information in your profile via the General Account Settings menu of your Facebook profile (https://www.facebook.com/settings?tab=applications). If you would like to remove our Service’s connection to Facebook via Facebook Connect, please log in to Facebook and make the required changes to your profile. We will then no longer have the right to use information from your Facebook profile for you.
  • Twitter Conversion Tracking: We use the Conversion Tracking service of Twitter Inc., 795 Folsom St., Suite 600, San Francisco, CA 94107, USA (“Twitter”). This tracking records if a user of our Websites clicks on a link posted by Twitter. In this way, both we and Twitter can see if a registration has taken place. The identity of the user remains anonymous. In addition, we use Twitter’s Tailored Audiences service. This enables us to appeal to our Websites’ users with targeted advertisements. To do this, Twitter uses a code snippet (tag) which we have integrated into our Websites. No personal data are collected during this process. Tailored Audiences is also used to create lookalike targeting lists. You can find more information about Twitter’s privacy policy in their data privacy statement (https://twitter.com/privacy?lang=en). You can adjust your privacy settings for tailored advertisements at this link: https://support.twitter.com/articles/20170405-your-privacy-controls-for-tailored-ads. Twitter also supports “Do Not Track” (DNT). If you have activated this option in your browser, Twitter will not receive any browser-related information (browser cookie ID) from web partners in order to tailor their advertisements to you.

HOW DO WE PROTECT THE PERSONAL INFORMATION WE COLLECT?

Jaguar maintains physical, electronic, and procedural safeguards to help guard personally identifiable information. Jaguar restricts authorized access to your personal information to those persons who have a legitimate purpose to know that information to provide products or services to you and those persons you have authorized to have access to such information. Please be aware, however, that any email or other transmission you send through the Internet cannot be completely protected against unauthorized interception. Unless you authorize unencrypted transmission, we will use industry standard encryption methods to protect your data transmission.

THIRD-PARTY DISCLOSURE

Jaguar does not sell, share or otherwise distribute your personal identifiable information with third parties for their marketing purposes unless we provide users with advance notice. Jaguar will share your personally identifiable information only in compliance with any obligations under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) and other applicable laws. If you engage in any transaction with us, we will only disclose this information to affiliates or our owner/operators with your consent. In the case of a survey or promotion, Jaguar may share your personal information with our affiliated companies and product co-promotion partners, which may only use your personal information for the purposes listed herein. Jaguar may use unaffiliated companies to help us maintain and operate our Websites or for other reasons related to the operation of our business, and those companies may have access to your personally identifiable information but only for the administrative purposes of monitoring and maintaining our Websites.

Jaguar may disclose personally identifiable information about you in connection with legal requirements, such as in response to an authorized subpoena, court order, warrant, or as otherwise permitted by law. If all or part of Jaguar is sold or merged into another entity, the information we have about you may be transferred to a third party as part of that transaction. We will try to assure that no personally identifiable information that is transferred will be used or shared in a manner inconsistent with this Privacy Policy without your consent. However, in the event of a sale or merger, your continued use of our Websites signifies your agreement to be bound by the Privacy Policy and other applicable terms of the subsequent owner or operator.

ACCESSING, CORRECTING, UPDATING AND DELETING YOUR PERSONAL INFORMATION

You are in control of the personal information you provide to Jaguar online. If you have submitted personal information to Jaguar through the Jaguar Websites or an interactive advertisement, or if someone else has submitted your personal information through the Jaguar Websites or an interactive advertisement, you can access, correct, update, or delete your personal information from our files by:

  • Sending us an email at hello@jaguar.health
  • Calling us at 415-371-8300
  • Logging in to your account
  • Sending a letter to:

Jaguar Health Customer Service
200 Pine Street, Suite 400
San Francisco, CA 94104

Be sure to include your name and address. You can include your email address if you want to receive a response by email. Otherwise, we will respond by postal mail within the time required by law.

Jaguar will use reasonable efforts to supply you with the information you requested to access and to correct any factual inaccuracies in this information.

COMPLAINTS

Jaguar is committed to working with our customers to obtain a fair and rapid resolution of any complaints or disputes about privacy. Please send us your questions or comments regarding our privacy practices by

Jaguar Health Customer Service
200 Pine Street, Suite 400
San Francisco, CA 94104

Be sure to include your name and address. You can include your email address if you want to receive a response by email. Otherwise, we will respond by postal mail within the time required by law.

Jaguar will be happy to respond to your questions and comments.

WHAT HAPPENS WHEN WE UPDATE OUR PRIVACY POLICY? 

Jaguar reserves the right to modify or supplement this Privacy Policy at any time. If we make any material changes to our Policy, we will post a notice about the change at a prominent location on our Websites.

CALIFORNIA ONLINE PRIVACY PROTECTION ACT

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. The law’s reach stretches well beyond California to require any person or company in the United States (and conceivably the world) that operates websites collecting Personally Identifiable Information from California consumers to post a conspicuous privacy policy on its website stating exactly the information being collected and those individuals or companies with whom it is being shared (See more at: http://consumercal.org/california-online-privacy-protection-act-caloppa/#sthash.0FdRbT51.dpuf).

According to CalOPPA, we agree to the following:

  • Users can visit our site anonymously.
  • Once this Privacy Policy is created, we will add a link to it on the home page of our Websites or, as a minimum, on the first significant page after entering our Websites.
  • Our Privacy Policy link includes the word “Privacy” and can easily be found on the page specified above.
  • You will be notified of any Privacy Policy changes on our Privacy Policy page.

You can change your personal information by:

  • Sending us an email at hello@jaguar.health
  • Calling us at 415-371-8300
  • Logging in to your account
  • Sending a letter to:

Jaguar Health Customer Service
200 Pine Street, Suite 400
San Francisco, CA 94104

Be sure to include your name and address. You can include your email address if you want to receive a response by email. Otherwise, we will respond by postal mail within the time required by law.

COPPA (CHILDREN ONLINE PRIVACY PROTECTION ACT)

When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.

The Websites are directed toward and designed for use by persons aged 13 or older. Jaguar does not solicit or knowingly collect PII from children under the age of 13. If Jaguar nevertheless discovers that it has received PII from an individual who indicates that he or she is, or whom Jaguar otherwise has reason to believe is, under the age of 13, Jaguar will delete such information from our systems. Additionally, a child’s parent or legal guardian may request that the child’s information be deleted from our files by requesting this through the email address on our contact page.

FAIR INFORMATION PRACTICES

The Fair Information Practice Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.

In order to be in line with Fair Information Practice Principles we will take the following responsive action, should a data breach occur:

  • We will notify you via email within 1 business day
  • We will notify you via letter within 7 business days
  • We will notify the users via in-site notification within 1 business day

We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.

CAN-SPAM ACT

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

  • Send information, respond to inquiries, and/or other requests or questions.
  • Process orders and to send information and updates pertaining to orders.
  • Send you additional information related to your product and/or service.
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.

To be in accordance with CAN-SPAM, we agree to:

  • Not use false or misleading subjects or email addresses.
  • Identify the message as an advertisement in some reasonable way.
  • Include the physical address of our business or site headquarters.
  • Monitor third-party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly.
  • Allow users to unsubscribe by using the link at the bottom of each email.

If at any time you would like to unsubscribe from receiving future emails, you can email us at hello@jaguar.health or follow the instructions at the bottom of each email and we will promptly remove you from ALL correspondence.

THIRD-PARTY LINKS

Our Websites may contain links to other websites. Jaguar is not responsible for the privacy practices or the content of such websites. We recommend you carefully read the privacy policies of each site you visit.

YOUR ACCEPTANCE OF OUR PRIVACY PRACTICES

By using our Websites or interactive banner ads, you signify your acceptance of this Privacy Policy, and you adhere to the terms and conditions posted on the Websites. If you do not agree with any of these terms, please do not use the Websites or submit any personal information.

If you have questions or concerns regarding this statement, please contact us by:

Jaguar Health Customer Service
200 Pine Street, Suite 400
San Francisco, CA 94104

Be sure to include your name and address. You can include your email address if you want to receive a response by email. Otherwise, we will respond by postal mail within the time required by law.

Revised 12/04/2017