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Wrango Website Privacy Policy

Wrango Inc., a Clue Digital Company and its authorized agents (“Wrango,” “we” or “us”) respect your preferences concerning the treatment of information we may collect about you through our Services (as defined below).

This Privacy Policy (“Policy”) lets you know how we collect, use, and disclose information collected from the Wrango applications that link or refer to this Policy (such as our websites, computer software applications, subscription services, HTML-formatted e-mail messages, and any other tools, products, or services provided by Wrango that link to or reference this Policy) (collectively, the “Services”), as well as information provided to us through offline sales and marketing activities that we associate with users of the Services. However, this Policy does not apply to information collected from our employees, contractors, or vendors.

The Services may provide links to or the ability to connect with non-Wrango websites, services, or applications. Clicking on those links or enabling those connections may allow the third party to collect or share information about you. Those third-party websites or services are beyond our control, and this Policy does not apply to those third-party websites or services.

We encourage you to check the privacy policies and terms of use of any non-Wrango web-sites or services before providing your Personal Information (as defined below) to them.

Finally, if you (or your company, if you are accessing and using certain Services for the benefit of a legal entity for whom you work) have entered into a Confidentiality and Non-Disclosure Agreement with Wrango that governs your use of certain Services and contains privacy or confidentiality terms that are more stringent than those in this Policy (“NDA”), then the applicable terms of such NDA will control over this Policy solely with respect to the Services covered by the NDA.

Consent

By accessing or using our Services, you consent to this Policy. If you do not agree with this Policy, please do not access or use the Services. Information gathered through the Services may be transferred, used, and stored in the United States or in other countries where our service providers or we are located. If you use the Services, you agree to the transfer, use, and storage of your Personal Information (as defined below) in those countries. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. You agree that all transactions relating to the Services or Wrango are deemed to occur in the United States, where our servers are located.

Personal and Other Information

Wrango collects Personal Information provided to us through your interaction with, use of, and registration for the Services. “Personal Information” is information that can identify or reasonably be linked to an individual, such as name, physical address, telephone number, e-mail address, login information, company affiliation, and associated interests. “Personal Information” also includes device information that is automatically collected and logged by our systems when users interact with the Services, such as IP address, browser type and version, time zone setting, browser plug-in types and versions, and operating system and platform, to the extent that any such information can identify or reasonably be linked to an individual.

If you are a healthcare provider, “Personal Information” may also include your individual National Provider Identifier number (“Individual NPI Number”), which is made available by the Centers for Medicare & Medicaid Services of the U.S. Government (“CMS”) and other third parties in connection with healthcare insurance claim data that is published by CMS and such third parties. For clarity, “Personal Information” does not include a National Provider Identifier number that is associated with a clinic or organization, and not an individual. We may associate your Individual NPI Number with data sets, insights, and/or reports that are available through the Services (collectively, “Insights”). However, Insights do not contain any other types of Personal Information.

We collect Personal Information that you voluntarily give us through your interaction with and use of the Services, including Personal Information contained in:

  • Forms you fill out on our websites;
  • Content of your electronic correspondence with us;
  • Disclosures made by you during offline sales and marketing activities conducted by us in which you participate, which we associate with your activities on the Services; and
  • Any other Personal Information you voluntarily send to us through our Services (or offline and that we associate with you as a user of the Services).

You may choose not to provide Personal Information (subject to the controls offered by your device’s operating system), but this may prevent you from receiving certain features of the Services. We also collect certain types of non-Personal Information about your interaction with and use of the Services, that is, information that does not personally identify an individual. Examples of the non-Personal Information we collect are:

  • Information about your visit to our Services, including the full URL clickstream to, through and from our site (including date and time); and pages you viewed or searched for; page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.

Information collected by the Services may be collected by us or one of our Service Providers or Online Tool Providers (as each are defined below).

We may also receive information about you from third parties who we partner with in order to build and operate our communities, including, for example, business partners, sub-contractors, and analytics providers, and may receive information about you from them. To the extent we associate this information with users of the Services, we will treat this as Personal Information.

We will not use non-Personal Information to try to identify you, and if we associate any non-Personal Information with Personal Information, then we will treat the combined information as Personal Information. As discussed in more detail below, we sometimes use cookies and other automatic information gathering technologies to gather non-Personal Information.

How We Use and Share Your Information

Wrango may use the Personal Information and other information it collects via the Services (unless otherwise restricted by law) to:

  • Provide the Services to you
  • Personalize your experience and allow us to deliver the type of content and product offerings in which you are most interested;
  • Improve our Services and related services in order to better serve you;
  • and Respond to your correspondence.

We may disclose Personal Information to provide the Services, or when you authorize or instruct us to do so, for example when you use the Services to submit content or profile information.

We may share your Personal Information with Service Providers. By “Service Providers”, we mean companies, agents, contractors, service provider, or others engaged to provide services on our behalf (such as processing of payments, provision of data storage, hosting of our website and other Services, marketing of our products and services, and conducting audits). These Service Providers have access to Personal Information and non-Personal Information needed to perform their services for us, but we require that such Service Providers may not use it for other purposes except as required by applicable law.

Additionally, we may share Insights with third parties for marketing purposes. As described above, if you are a healthcare provider, such Insights may contain your Individual NPI Number. If you wish to opt-out from having your Individual NPI Number included in any Insights that we share with third-parties for marketing purposes, please see the Transparency and Choice section below.

Except for Individual NPI Numbers that may be contained in Insights, and our limited sharing of information with Product Partners as we have described it above, Wrango does not share your Personal Information with third parties for the third party’s own marketing purposes.

We may also disclose Personal Information and non-Personal Information to Online Tool Providers. By “Online Tool Provider” we mean a licensor of software that we include in, or use with, the Services, including an API or SDK, that provides a specialized function or service to us and that requires the transmission of Personal Information and/or non-Personal Information to the Online Tool Provider. Online Tool Providers may have the right to use Personal Information and non-Personal Information about you for their own business purposes. Use and disclosure of Personal Information and non-Personal Information by an Online Tool Provider is described in its privacy policy. Some of the key Online Tool Providers we use are described below.

Wrango also may disclose your Personal Information to third parties when we believe, in good faith and in our sole discretion, that such disclosure if reasonably necessary to: (1) protect the legal rights, privacy or safety of Wrango or its employees, agents and contractors; (2) protect the rights, property, safety, and/or security of visitors to our websites or other properties, or of other third parties; (3) protect against fraud or other illegal activity or for risk management purposes; (4) respond to inquiries or requests from government or public authorities; (5) pursue available remedies or limit the damages that we may sustain and to enforce or apply the terms and conditions of the Services, including to investigate potential violations thereof; and/or (6) comply with the law or any judicial proceeding, court order, or other legal process served on us.

Wrango also may transfer any and all information that we collect about you (including your Personal Information) to third parties in the event of any merger, sale, joint venture, assignment, transfer, bankruptcy, or other disposition of all or any portion of Wrango’s assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).

Lastly, we may also disclose non-Personal Information, aggregated with information about our other users, to our clients, business partners, merchants, advertisers, investors, potential buyers and other third parties if we deem such disclosure, in our sole discretion, to have sound business reasons or justifications.

How We Protect Your Information

We implement reasonable administrative, technical, and physical safeguards that are designed to protect your Personal Information from unauthorized access, use, or disclosure. For example, sensitive information that is transmitted over the Internet is encrypted via Secure Socket Layer (SSL) or similar technology. However, no data transmission over the Internet and no method of data storage can be guaranteed to be 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its security. All payment transactions occurring through the Services are processed through a third-party gateway provider and are not stored or processed on our servers.

Transparency and Choice

You may request access to your Personal Information by sending an email to info@wrango.io We will try to locate and provide you with your Personal Information and give you the opportunity to correct this data, if it is inaccurate, or to delete it, at your request. But, in either case, we may need to retain it for legal reasons or for legitimate business purposes. You may also remove any data that you upload to the Services using any deletion or removal options within the Services. However, we (and you) are not able to control information that you have already shared with other users or made available to third parties through the Services.

We ask individual users to identify themselves and the information requested to be accessed, corrected, or removed before processing such requests, and we may decline to process requests that are unreasonably repetitive or systematic, require disproportionate technical effort, jeopardize the privacy of others, would be extremely impractical (for instance, requests concerning information residing on backups), or relate to information that is not associated with your Personal Information. In any case, where we provide information access and correction, we perform this service free of charge, except if doing so would require a disproportionate effort.

Please be aware that if you request us to delete your Personal Information, you may not be able to continue to use the Services. Also, even if you request that we delete your Personal Information, we may need to retain certain information for a limited period of time to satisfy our legal, audit and/or dispute resolution requirements.

We support the development and implementation of a standard “do not track” browser feature that provides customers with control over the collection and use of information about their web-browsing activities. Once a standardized “do not track” feature is released, we intend to adhere to the browser settings accordingly.

You can opt out of receiving marketing e-mails from us by clicking on the “unsubscribe” link in the e-mails. Please note that it may take up to ten (10) business days for your opt-out request to be processed. Also, even if you opt out of marketing e-mails, we may continue to send you certain account-related e-mails, such as notices about your account and confirmations of transactions you have requested.

If you are a healthcare provider, you can opt out from having your Individual NPI Number included in the Insights that we share with third parties for marketing purposes. You can opt out by sending an email to info@wrango.io with “Individual NPI Number – Opt Out” in the subject line. Please note that it may take up to ten (10) business days for your opt-out request to be processed, and we are not able to remove your Individual NPI Number from any such Insights that we distributed prior to our processing of your opt-out request. Additionally, even if you opt out from having your Individual NPI Number included in the Insights that we share with third parties for marketing purposes, your Individual NPI Number will remain associated with Insights that other users may access, use, and export using the Services.

California Residents

This California Privacy Notice only applies to residents in the State of California (“consumers”). We adopt this notice to comply with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (CPRA) (collectively, CCPA) and any terms defined in the CCPA have the same meaning when used in this Policy.

Information We Collect

We have collected the following categories of personal information from consumers within the last twelve (12) months:

  • Identifiers (such as name, postal address, online identifier, IP address, email address, or other similar identifiers)
  • Customer records information (such as financial information)
  • Commercial information (such as records of products or services purchased, obtained, or considered)
  • Internet or other similar network activity (such as browsing history, information on your interactions with our website, application, or advertisements)
  • Geolocation data
  • Professional or employment-related information (such as current or past job history)
  • Inferences (such as a profile reflecting your preferences, characteristics, behavior, attitudes, or abilities)

We obtained the categories of personal information listed above from the categories of sources listed in the “Personal and Other Information” section above.

Uses of Personal Information

We may use or disclose the personal information we collect for one or more of the purposes listed in the “How We Use and Share Your Information” section above.

Sharing Personal Information

We may share your personal information with the categories of third parties listed in the “How We Use and Share Your Information” section above. We do not sell personal information.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Right to Know and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:

The categories of personal information we collected about you.

  • The categories of sources for the personal information we collected about you.
  • Our business or commercial purpose for collecting or selling that personal information.
  • The categories of third parties with whom we share that personal information.
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing sales, if any, identifying the personal information categories that each category of recipient purchased, and disclosures for a business purpose, if any, identifying the personal information categories that each category of recipient obtained.
  • The specific pieces of personal information we collected about you (also called a data portability request).

Right to Delete

You are entitled to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or de-identify personal information not subject to one of these exceptions from our records, and will direct our service providers to take similar action.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please contact us at info@wrango.io. Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. You may only submit a request to know twice within a 12-month period. Your request to know or delete must provide sufficient information to allow us to reasonably verify you are the person about whom we collected personal information or an authorized representative. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Any disclosures we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not deny you goods or services; charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

Your Privacy Rights Under State Laws

In accordance with state privacy laws, residents of Colorado, Connecticut, Virginia, Utah, Washington, Nevada, and Florida have the right to:

  • Access personal data we have collected.
  • Request correction of inaccurate personal data.
  • Request deletion of personal data.
  • Opt out of the sale of personal data or targeted advertising.

To exercise these rights, please contact info@wrango.io. We will verify your identity before processing such requests as required by law.

Cookies and Other Automatic Information Gathering Technologies

Cookies are small files that a website operator (or its service provider) or a third party whose content is embedded in that website, transfers to your web browser (if you allow) that enables the website operator or, as applicable, the third party to recognize your browser and capture and remember certain information when you visit the Services. A cookie may also refer to web-browser-based storage provided by Adobe’s Flash plugin. A web beacon, pixel or tag is a small, usually-transparent image placed on a web page that allows the operator of that image, which may be the operator of the website you visit or a third party, to read or write a cookie. They are used to help us understand your preferences based on previous or current activity on the Services, which enables us to provide you with an improved experience on the Services and save your preferences for future visits. We also use cookies to help us compile aggregated non-Personal Information about site traffic and site interaction so that we can offer better site experiences and tools in the future.

Your operating system and web browser may allow you to erase information stored in cookies, flash cookies, and local browser storage. But if you do so, you may be forced to login to the Services again and you may lose some preferences or settings. You may also be able to set your browser to refuse all website storage or to indicate when it is permitted, but some features of our Services may not function properly without it. Cookie management tools provided by your browser may not affect flash cookies. To learn how to manage privacy and storage settings for your local browser storage, please refer to the end user documentation for your browser.

An Online Tool Provider may collect information automatically, in which case Personal Information and non-Personal Information it receives are subject to the Online Tool Provider’s privacy policy. Some Online Tool Providers may allow you to opt out of certain collection and/or uses of your information.

Children

Our Services are not intended for use by children under 13 years of age and are not targeted to children. Wrango does not knowingly collect personal information from children under 13 years of age, and we do not authorize users under 13 years of age to use the Services. However, if you believe that your child under 13 years of age has submitted information to us through interaction or use of any of our Services without your permission, you may contact us at info@wrango.io and we will use commercially reasonable efforts to delete the information as quickly as possible.

Changes to Our Privacy Policy

We reserve the right to amend this Policy at any time, with or without prior notice. We will post the revised Policy on this page or announce the change on the home page of our Services. You can determine when the Policy was revised by referring to the “Last Updated” date on the top of this Policy. Any changes will become effective upon the posting of the revised Policy on the Services. If we make any material changes to this Policy, we will notify you by reasonable means, which may be by e-mail or posting a notice of the changes on our Services prior to the changes becoming effective.

By continuing to use any of our Services following such changes, you will be deemed to have agreed to such changes. IF YOU DO NOT AGREE WITH THE TERMS OF THIS POLICY, IN WHOLE OR PART, YOU MUST STOP USING OR INTERACTING WITH ANY SERVICE AFTER THE EFFECTIVE DATE OF SUCH CHANGES (WHICH IS THE “LAST UPDATED” DATE OF THIS POLICY).

More Information

If you would like to contact us for any reason regarding our privacy practices or this Policy, e-mail us at the following address:

Wrango Inc. – info@wrango.io