Privacy Policy - Effective July 10, 2024

Collection and Use of Personal Information

Personal information is data that can be used to identify or contact a single person.

As the Purchaser/Authorized User ("you") may be asked to provide your personal information anytime you are in contact with TULIP or a TULIP affiliated company. TULIP and its affiliates may share this personal information with each other and use it consistent with this Privacy Policy. They may also combine it with other information to provide and improve our products, services, content, and advertising. You are not required to provide the personal information that we have requested, but, if you chose not to do so, in many cases we will not be able to provide you with our products or services or respond to any queries you may have.

Here are some examples of the types of personal information TULIP may collect and how we may use it:

What personal information we collect

• When you create a TULIP account, we may collect a variety of information, including your name, mailing address, phone number, email address, contact preferences, device identifiers, IP address, location information, and credit card information.
• In certain jurisdictions, we may ask for a government issued ID in limited circumstances as required by law.

How we use your personal information

We may process your personal information: for the purposes described in this Privacy Policy, with your consent, for compliance with a legal obligation to which TULIP is subject or when we have assessed it is necessary for the purposes of the legitimate interests pursued by TULIP or a third party to whom it may be necessary to disclose information.

• The personal information we collect allows us to keep you posted on TULIP's latest product announcements and software updates. If you don't want to be on our mailing list, you can opt-out anytime by contacting TULIP.
• We also use personal information to help us create, develop, operate, deliver, and improve our products, services, content and advertising, and for loss prevention and anti-fraud purposes. We may also use your personal information for account and network security purposes, including in order to protect our services for the benefit of all our users, and pre-screening or scanning uploaded content for potentially illegal content. Where we use your information for anti-fraud purposes it arises from your conduct in utilizing TULIP. We limit our uses of data for anti-fraud purposes to those which are strictly necessary and within our assessed legitimate interests to protect our customers and our services.
• We may use your personal information, including date of birth, to verify identity, assist with identification of users, and to determine appropriate services. For example, we may use date of birth to determine the age of TULIP account holders.
• From time to time, we may use your personal information to send important notices, such as communications about purchases and changes to our terms, conditions, and policies. Because this information is important to your interaction with TULIP, you may not opt out of receiving these communications.
• We may also use personal information for internal purposes such as auditing, data analysis, and research to improve TULIP, and TULIP's and its affiliates', products, services, and customer communications.

Source of your personal information where they are not collected from you

We may validate the information provided by you when creating a TULIP account with a third party for security and fraud prevention purposes.

Collection and Use of Non-Personal Information

We also collect data in a form that does not, on its own, permit direct association with any specific individual. We may collect, use, transfer, and disclose non-personal information for any purpose. The following are some examples of non-personal information that we collect and how we may use it:

• We may collect information such as occupation, language, zip code, area code, unique device identifier, referrer URL, location, and the time zone where a TULIP product is used so that we can better understand customer behavior and improve our products, services, and advertising.
• We may collect information regarding customer activities on TULIP. This information is aggregated and used to help us provide more useful information to our customers and to understand which parts of our products and services are of most interest. Aggregated data is considered non-personal information for the purposes of this Privacy Policy.
• We may collect and store details of how you use our services. This information may be used to improve the relevancy of results provided by our services. Except in limited instances to ensure quality of our services over the Internet, such information will not be associated with your IP address.
• With your explicit consent, we may collect data about how you use your device and applications in order to help our application developers improve our applications.

If we do combine non-personal information with personal information the combined information will be treated as personal information for as long as it remains combined.

Cookies and Other Technologies

TULIP's websites, online services, interactive applications, email messages, and advertisements may use "cookies" and other technologies such as pixel tags and web beacons. These technologies help us better understand user behavior, tell us which parts of TULIP people are utilizing, and facilitate and measure the effectiveness of our products and services. We treat information collected by cookies and other technologies as non-personal information. However, to the extent that Internet Protocol (IP) addresses or similar identifiers are considered personal information by local law, we also treat these identifiers as personal information. Similarly, to the extent that non-personal information is combined with personal information, we treat the combined information as personal information for the purposes of this Privacy Policy.

TULIP and our partners also use cookies and other technologies to remember personal information when you use our products and services in order to customize or improve our products and services.

Check with your browser provider to find out how to disable cookies. Please note that certain features of TULIP will not be available once cookies are disabled.

As is true of most products and services available using the internet, we gather some information automatically and store it in log files. This information includes Internet Protocol (IP) addresses, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, and clickstream data. We use this information to understand and analyze trends, to administer the site, to learn about user behavior on the site, to improve our product and services, and to gather demographic information about our user base as a whole. TULIP may use this information in our marketing and advertising services.

In some of our email messages, we use a "click-through URL" linked to content on the TULIP affiliated websites. When customers click one of these URLs, they pass through a separate web server before arriving at the destination page on our website. We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click text or graphic links in the email messages. Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers.

Disclosure to Third Parties

At times TULIP may provide third parties with certain personal information to provide or improve our products and services, and the products and services of our affiliates, including to deliver products at your request, or to help TULIP, and its affiliates, market to consumers. When we do, we require those third parties to handle it in accordance with relevant laws. Personal information will never be shared with third parties for their marketing purposes unless they are an affiliate of TULIP.

Service Providers

TULIP shares personal information with companies who provide services such as information processing, managing and enhancing customer data, providing customer service, assessing your interest in our products and services, and conducting customer research or satisfaction surveys. These companies are obligated to protect your information and may be located wherever TULIP operates.

Others

It may be necessary - by law, legal process, litigation, and/or requests from public and governmental authorities within or outside your country of residence - for TULIP to disclose your personal information. We may also disclose information about you if we determine that for purposes of national security, law enforcement, or other issues of public importance, disclosure is necessary or appropriate. We may also disclose information about you, but only where there is a lawful basis for doing so, if we determine that disclosure is reasonably necessary to enforce our terms and conditions or protect our operations or users. This could include providing information to public or governmental authorities.

Additionally, in the event of a reorganization, merger, or sale we may transfer any and all personal information we collect to the relevant third party.

Protection of Personal Information

TULIP takes the security of your personal information very seriously. TULIP protects your personal information during transit using encryption such as Transport Layer Security (TLS). When your personal data is stored by TULIP, we use computer systems with limited access housed in facilities using physical security measures. Data is stored in encrypted form including when we utilize third-party storage.

The existence of Automated Decision-Making, Including Profiling

TULIP does not make any decisions involving the use of algorithms or profiling that significantly affects you.

Integrity and Retention of Personal Information

TULIP makes it easy for you to keep your personal information accurate, complete, and up to date. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy and our service specific privacy summaries. When assessing these periods, we carefully examine our need to collect personal information at all and if we establish a relevant need, we only retain it for the shortest possible period to realize the purpose of collection unless a longer retention period is required by law.

Access to Personal Information

You can help ensure that your contact information and preferences are accurate, complete, and up to date by signing into your TULIP account information page. For other personal information we hold, we will provide you with access (including a copy) for any purpose including to request that we correct the data if it is inaccurate or delete the data if TULIP is not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous/vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. We may also decline aspects of deletion or access requests if we believe doing so would undermine our legitimate use of data for anti-fraud and security purposes as described earlier. Requests may be made directly to TULIP.

Children & Education

We understand the importance of taking extra precautions to protect the privacy and safety of children. Children under the age of 13, or equivalent minimum age in the relevant jurisdiction, are not permitted to create their own TULIP account or to utilize TULIP products. If we learn that we have collected the personal information of a child under 13, or equivalent minimum age depending on jurisdiction, outside the above circumstances we will take steps to delete the information as soon as possible.

Location-Based Services

To provide location-based services on TULIP products, TULIP and our partners and licensees, such as maps data providers, may collect, use, and share precise location data, including the real-time geographic location of your device accessing a TULIP product or service. Where available, location- based services may use GPS, Bluetooth, and your IP Address, along with crowd-sourced Wi-Fi hotspot and cell tower locations, and other technologies to determine your devices' approximate location. Unless you provide consent, this location data is collected anonymously in a form that does not personally identify you and is used by TULIP and our partners and licensees to provide and improve location-based products and services. For example, your device may share its geographic location with application providers when you opt in to their location services.

Some location-based services offered by TULIP require your personal information for the feature to work.

Third-Party Sites and Services

TULIP websites, products, applications, and services may contain links to third-party websites, products, and services. Our products and services may also use or offer products or services from third parties and affiliates.

Information collected by third parties, or affiliates, which may include such things as location data or contact details, is governed by their privacy practices. We encourage you to learn about the privacy practices of those third parties or affiliates.

International Users

All the information you provide may be transferred or accessed by entities around the world as described in this Privacy Policy. TULIP may have a number of legal entities in different jurisdictions which are responsible for the personal information which they collect, and which is processed on their behalf by TULIP.

Our Companywide Commitment to Your Privacy

To make sure your personal information is secure, we communicate our privacy and security guidelines to TULIP employees and strictly enforce privacy safeguards within the company.

Privacy Questions

If you have any questions or concerns about TULIP's Privacy Policy or data processing, or if you would like to make a complaint about a possible breach of local privacy laws, please contact us. You can always contact us by phone through the TULIP customer service department.

When a privacy question or question about personal information received in response to an access request is received, we have a dedicated team which triages your contact to address your issue. Where your issue may be more substantive in nature, we may request more information from you. All such substantive contacts receive a response within seven (7) days wherever possible - providing a response on the issue raised, requesting additional information where necessary or indicating that a response will require additional time. If you are unsatisfied with the reply received, you may refer your complaint to the relevant regulator in your jurisdiction. If you ask us, we will endeavor to provide you with information about relevant complaint avenues which may be applicable to your circumstances.

Where your complaint indicates an improvement could be made in our handling of privacy issues we will take steps to make such an update at the next reasonable opportunity. In the event that a privacy issue has resulted in a negative impact on you or another person we will take steps to address that with you or that other person.

TULIP may update its Privacy Policy from time to time. When we change the policy in a material way, a notice will be posted on our website along with the updated Privacy Policy. We will also contact you via your contact information on file, for example by email notification or some other equivalent method.

Contact Us

If you have any questions about these Terms of Service, please contact us at: support@tuliphealth.com