Privacy Policy

‍Effective Date: 9/28/2023
Last Updated: 9/5/2024

This Privacy Notice describes how RubyWell collects, uses, and shares Personal Data. For example, we collect, use, and share Personal Data so that we can provide our products and services and operate our business, develop and improve our products and services, and advertise products and services. Please read this Privacy Notice carefully. 

RubyWell, Inc. together with its subsidiaries and affiliates (collectively, “RubyWell”, “we “, “us”, or “our”) is committed to protecting the privacy of Personal Data (i.e., information reasonably related to a specific individual). This Privacy Notice describes how we process Personal Data collected through our websites, social media accounts, mobile applications, and other online interactions and communications such as email (collectively, our “Digital Properties”) and other online and offline interactions.

Scope of this Privacy Notice. This Privacy Notice does not apply to the data about our own employees, contractors, agents, and job applicants. Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us or provide information about one of your friends or family members, you must obtain their consent (or have the legal authority without consent) to share their Personal Data with us.

Changes to this Privacy Notice. We may update this Privacy Notice from time to time. Any updated Privacy Notice will be effective when posted. Please check this Privacy Notice periodically for updates. If required by law, we will contact you directly to provide you with an updated Privacy Notice.

1. Sources of Personal Data

We collect Personal Data about you from the following sources:‍

  • Directly from you. We may collect Personal Data you provide to us directly, such as when you use or contact us through our Digital Properties, interact with us in person or over the phone, sign up for offers or newsletters, communicate with us or other users of our Digital Properties, or sign up for an account.
  • Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you, such as through cookies and other tracking technologies, when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information.
  • From third parties. We may collect Personal Data from third parties, such as friends or family members who provide your Personal Data to us, service and content providers, our affiliated companies and subsidiaries, business partners (such as Medicare brokers or other entities that offer products or services to caregivers and those family members or friends in their care), data brokers, social media companies or other parties who interact with us.
  • From publicly available sources. We may collect Personal Data about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Privacy Notice, including third party sources, and use or disclose the combined information for the purposes identified below.

2. Types of Personal Data We Collect

We may collect the following types of Personal Data:

  • Identifiers, such as your name, email address, physical address, telephone number, business contact information, and device identifiers (e.g., cookie IDs and IP address).
  • Records about you, such as signatures, the content, timing and method of communications you have with us, such as online chats, calls, and emails, and information you share with or upload to our Digital Properties, such as reviews and comments.
  • Demographic information, such as age (including birthdates) and gender.
  • Commercial information, such as information related to your transactions with us and products or services purchased, obtained, or considered.
  • Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Digital Properties.
  • Non-precise geolocation data, such as your location as derived from your IP address.
  • Audio, electronic, visual, or other sensory information, such as photographs and audio/video recordings.
  • Professional or employment-related information, such as job title; organization; professional licenses, credentials, or affiliations; and other professional information.
  • Education information.
  • Inferences drawn from any of the information we collect about your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers.
  • Sensitive Personal Data, such as Information about health and health insurance.

3. How We Use Personal Data

We may use Personal Data for the following purposes:

  • To provide you products and services, such as making our Digital Properties, products and services available to you; registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you request, including facilitating offers and other rewards programs; providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); hosting informational webinars; and providing similar services or otherwise facilitating your relationship with us.
  • For our internal business purposes, such as day-to-day operation of our business; maintaining internal business records, such as accounting, document management and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration.
  • For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; improving our products or services; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
  • For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity.
  • In connection with a corporate transaction, such as if we acquire assets of another business, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
  • For marketing and targeted advertising, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Personal Data we collect to personalize advertising to you (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us or our Digital Properties; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe to our email marketing via the link in the email or by contacting us using the information in Section 9 (Contact Information) below.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

4. How We Disclose Personal Data

We may disclose Personal Data to third parties, including the categories of recipients described below:

  • Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
  • Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
  • Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
  • Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
  • Law enforcement, government agencies, and other recipients for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our Terms of Use and other agreements or policies, and to protect our,our customers’, or third parties' safety, property, or rights.
  • Other entities in connection with a corporate transaction, such as if we acquire assets of another entity, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
  • Business partners that may use Personal Data for their own purposes, such as:
    • Business partners, such as Medicare brokers, prescription discount plans or other entities that offer products or services through our Digital Properties to caregivers and those family members or friends in their care.
    • Health insurance companies responsible for paying for health care services received by you or your friends or family members.
    • Advertisers, ad platforms and networks, and social media platforms.
    • Third parties whose cookies and tracking tools we use.
    • Commercial data partners to whom we make information available for their own marketing purposes.
    • Partners who work with us on promotional opportunities, including co-branded products and services.

    Where recipients use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.

  • The public, such as when you have an opportunity to make comments regarding us or our products that we may share with the public, including comments on blog posts and reviews on product pages. Any Personal Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public.
  • Entities to which you have consented to the disclosure.

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.

5. Cookies and Other Tracking Technologies

We and our third-party partners use cookies and other data collection technologies on our Digital Properties. A “cookie” is a small text file that is placed on your computer or mobile device when you visit a website. Other data collection technologies we may use include “pixels,” a code that is embedded on a website or in an email; “session replay tools,” which record your interactions with websites; “embedded scripts,” which are scripts temporarily downloaded to a device from a web server; and “local storage,” which generally refers to other places on a browser or device where information can be stored. Some cookies and other data collection technologies are deleted when you end your session, while others are stored between sessions.

The data collection technologies we may use change from time to time, but we generally use them for the following purposes:

  • Strictly necessary. These technologies are needed to make our Digital Properties run correctly.
  • Functionality. We use these technologies to help us remember you and personalize features and content for you on our Digital Properties.
  • Analytics. We use these technologies to compile statistics and analytics about our users, including traffic, usage, and trend data. For example, we use Google Analytics to help us understand how users engage with our Digital Properties. This information helps us improve our online services. To learn more about how Google Analytics uses your data, please visit www.google.com/policies/privacy/partners.
  • Advertising. We use these technologies to place advertisements and other content on our Digital Properties and third-party websites. These technologies may track your activity over time and across properties to understand and to advertise to your interests (“interest-based advertising”).

You may be able to disable or delete cookies using your web browser’s settings. If you do, you may not be able to access or use certain features on our Digital Properties. You may also be able to opt out of certain interest-based advertising using tools provided by the Digital Advertising ("DAA") and Network Advertising Initiative ("NAI"). For more information, please visithttp://www.aboutads.info/choices/ and https://optout.networkadvertising.org/.

You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Digital Properties’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.

Do Not Track. Some browsers have incorporated Do Not Track (“DNT”) preferences.  At this time, we do not honor Do Not Track signals.

6. Data Security and Data Retention

Although we maintain reasonable security safeguards, no security measures or communications over the Internet can be 100% secure, and we cannot guarantee the security of your information.

Your Personal Data will be retained as long as necessary to fulfill the purposes we have outlined above unless we are required to do otherwise by applicable law. This includes retaining your Personal Data to provide you with the products or services you have requested and interact with you; maintain our business relationship with you; improve our business over time; ensure the ongoing legality, safety and security of our services and relationships; or otherwise in accordance with our internal retention procedures. Once you have terminated your relationship with us, we may retain your Personal Data in our systems and records in order to ensure adequate fulfillment of surviving provisions in terminated contracts or for other legitimate business purposes, such as to enable easier future user onboarding, demonstrate our business practices and contractual obligations, or provide you with information about our products and services in case of interest.

7. Children's Privacy

‍Our Digital Properties are intended for individuals 18 years of age and older. The Digital Properties are not directed at, marketed to, nor intended for, children under 18 years of age. As a general rule, we do not knowingly collect any information, including Personal Data, from children under 18 years of age. If you believe that we have inadvertently collected Personal Data from a child under the age of 18, please contact us at the address in Section 9 (Contact Information) below, and we will take prompt steps to delete the information.

8. External Links

Our Digital Properties may contain links to external sites or other online services that we do not control, including those embedded in third party advertisements or sponsor information. We are not responsible for the privacy practices or data collection policies of such third-party services. You should consult the privacy notices of those third-party services for details on their practices.

9. Contact Information

If you have questions regarding this Privacy Notice, please contact us at legal@rubywell.com.

10. Supplemental U.S. State Privacy Disclosures

‍State Consumer Privacy Laws. Certain states have enacted generally applicable consumer privacy laws (e.g., California, Colorado, Connecticut, and Virginia). These laws do not apply to us at this time.

Nevada residents. If you are a Nevada resident, you may contact us using the contact information in Section 9 to inquire about your right to opt out of the sale of your Personal Data.

‍California Shine the Light. California's "Shine the Light" law (Civil Code Section § 1798.83) permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us using the contact information in Section 9. We do not currently disclose Personal Information (as defined in the Shine the Light law) of California residents to third parties for their direct marketing purposes.

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