Privacy Policy
***PLEASE READ CAREFULLY***
Last updated: May 14, 2021
RSV Opco 5, Inc. d/b/a Kinto (“Kinto”, “Company”, “we”, or “our”) respects your privacy. Kinto offers a multi-faceted service through the use of a mobile application, technology platform, website, services and procedures (collectively, the “Services”) to support caregivers of older adults. The Company’s Terms of Use can be found at https://www.kinto.care/terms-of-use. This Privacy Policy sets forth how we collect and use information we gather from you when you access and use the Services and how we share information with third parties, including national and local organizations which focus on caregiving, life science companies, health care systems, and public and private research institutions (“Partners”). By using our application and/or website (together, our “Platform”) and/or other Services, you are accepting Kinto’s Terms of Use and you consent to the collection, use, storage, and disclosure of information as outlined in this Privacy Policy.
Use of our Services does not constitute the provision of health care and does not replace the need for you to seek consultation, guidance, or care from a health care provider if needed.
Acceptance and Updates to this Privacy Policy
We may update this Privacy Policy from time to time by posting changes on this website or by otherwise notifying you directly. Any Privacy Policy changes will be effective for all information that we maintain, even information in existence before the change. Your use of the Services following any changes to the Privacy Policy signifies your acceptance of those changes. If you do not agree to the terms of this Privacy Policy, do not use our Services.
Why Personal Information is Important
Our goal is to support caregivers of older individuals (“Care Recipients”) through personal care coaching services and a multi-faceted technology platform. We recognize the importance of gathering a wide body of information in order to improve the knowledge about the unique challenges of caring for older individuals and to provide successful tools and support for those who care for the elderly. We believe that collaborating with research institutions, life science companies, national and local associations with a particular focus on issues related to older adults, and similar organizations is critical to advance our society’s understanding about caring for older adults generally and, in particular, to provide methods and resources for caregivers.
Users Under the Age of 18
Our Services are not intended for children under 18 years of age. By using our Platform and other Services, you warrant that you are 18 years of age or older.
Types of Information
Data and information are treated in a variety of ways, depending on how it is classified. In this Privacy Policy, we refer to the several types of information, defined as follows:
Caregiver Personal Information means basic contact information about you which you provide when you register and use the Services, such as your name, address, phone number, email address, photograph, and similar information by which you may be personally identified.
Care Recipient Personal Information means information about the person whose care is being managed through the Platform, which may include but is not limited to the following types of information: date of birth, photographs, family and health care provider contact information, medical history and current health conditions, diagnostic test results, medical treatment instructions, medical appointments, medications and refill information, allergies, notes on symptoms and similar journal information, insurance information, contact information of third parties who provide direct support services, such as a physical therapist or counselor, andpersonal history (birthplace, occupation, etc.), notes on symptoms and behaviors and similar journal information, daily routines, activities of daily living, triggering events, likes/dislikes, care goals, and information about the existence and terms of legal documents such as an advance directives, powers of attorney, a final will and last testament and similar instruments.
Personal Information means, collectively, Caregiver Personal Information and Care Recipient Personal Information and may, but need not, include Health Information.
Health Information means Personal Information related to an individual’s medical history, including symptoms, diagnoses, clinical information, notes, treatment, and diagnostic test results. Health information falls into two categories, namely Protected Health Information and Basic Health Information.
Protected Health Information means Health Information which is individually identifiable health information created or received by or on behalf of a covered entity (for example, a health care provider or health plan) and which relates to the past, present or future physical or mental health or condition of an individual, the provision of health care to an individual, or the past, present or future payment for the provision of health care to an individual. Protected Health Information is further defined by the Health Insurance Portability and Accountability Act of 1996, as amended from time to time, together with the regulations adopted thereunder (“HIPAA”) and is subject to the protections of HIPAA.
Basic Health Information means Personal Information which is a subset of Health Information that does not fall within the category of Protected Health Information above. For example, this would encompass information which was not created or received by Kinto from (or on behalf of) a covered entity, such as a list of current medications which you enter into the Platform.
Personally-Identifiable Data means Personal Information for which an individual’s identity can be reasonably traced, regardless of whether or not it is Health Information.
General Data which means Personal Information that cannot be used to readily distinguish or trace an individual’s identity. General Data may include Basic Health Information but does not at any time include Protected Health Information. References in this Privacy Policy to General Data apply to all de-identified, anonymized or pseudonymized data.
Information We Collect About You
Information you provide to us
When you register and use the Services, we may collect Caregiver Personal Information and Care Recipient Personal Information. You are solely responsible for ensuring that you have any and all necessary consents and authorizations to share Care Recipient Personal Information with Kinto and to permit Kinto use that information in connection with our business activities.
You may also provide us with information about a third-party caregiver, such as a family member. If you elect to invite a third party to access Personal Information in connection with your use of the Services, you will provide us with the third-party caregiver’s name, phone number and/or email address. We store the third-party caregiver’s name and phone number and email address for the purpose of sending that individual an invitation for that individual to register for our Services. You may only provide us with such third-party caregiver’s information if you obtain in advance any and all necessary consents and authorizations to do so from them.
We also may collect additional information from you, including, for example, employment status and history, health care insurance information, and demographic data.
We may collect other data you may submit when using our Services, including Personal Information you provide about yourself or the Care Recipient, or that you may submit to us directly such as when you request customer support.
Information you publicly post to the Platform
You also may provide information to be published or displayed on public areas of our Platform. You may keep your contributions anonymous to other users of the Platform simply by not posting information that identifies you. You acknowledge and agree, however, that when you post or transmit any information through the Platform, you do so at your own risk. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to interact with or share your information. Therefore, we cannot and do not guarantee that your information will not be viewed by unauthorized persons.
Information we automatically collect
Kinto and third-party organizations with whom we have a business relationship (such as analytics service vendors) may automatically collect certain information in connection with your use of the Services, including:
· Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, user ID, and the device's telephone number.
· Usage Details. We may automatically collect certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Platform. We may also automatically record when specific features of the Platform or other aspects of our Services are used. We collect and store usage (i.e., analytics) information to help us improve our Services.
· Location. We may, with your consent, collect information while you are using the Application, including the location of your device, provided you have opted in to activate this feature
· Tokens. We use various technologies to collect information about your use of our website, including tokens and other tracking mechanisms. We gather this information to allow you to access and use the Platform more easily and to improve our services to you more generally. For example, we use these tools to save user preferences, preserve session settings and activity, help authenticate users, allow users to auto-fill pages of websites they frequently visit, and debug and evaluate the performance of our Platform.
· Stored Information and Files. Kinto may access metadata and other information associated with other files on your device if you grant access to such files and information to the Platform. This may include, for example, recorded chat sessions, audio and video exchanges, photographs, and personal contacts.
Our third-party service providers also may collect information about your online activities over time and on other websites or apps. We do not control these third parties' tracking technologies or how they may be used. You may be able to disable certain tracking and cookies, and change browser settings to block and delete cookies when you access our Platform, however doing so may affect its functionality. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
Information we collect from third party sources
We may also obtain information about you and Care Recipients from organizations with whom we do business, including Partners, service providers and other sources, such as when you authorize us to retrieve and import information from family members or other third parties.
At times, we may obtain Personal Information (which may include Health Information) from third parties who provide health care and clinical and other support services to you and/or the Care Recipient, such as Partners and the Care Recipient’s health care providers and other individuals or organizations who assist in providing care and support to the Care Recipient. We may collect Basic Health Information in connection with the Platform and our Services.
How We Use Personal Information
We may use information we collect for a variety of overall purposes, including:
· To provide, operate, maintain, improve, promote, and personalize our Services to you
· To facilitate communication with Care Recipient’s health care providers and other individuals and entities who provide direct support services to you and the Care Recipient
· To tailor the educational and other content and information we offer, to personalize help and instructions, and to otherwise tailor your experiences while using the Platform and/or our other Services
To better understand how users access and use the Platform and other Services, to analyze trends, to gather demographic information about our user base
To engage with our Partners to conduct research on issues affecting the elderly such as dementia as well as caregiver behaviors and practices
· To communicate with you, including responding to your comments and questions and providing customer service and support, to provide you with information about our Services, including technical notices, security alerts, changes in our terms, administrative messages, or advertising or marketing messages, and to provide other news or information about us and our Partners
· To monitor and analyze trends, usage, and activities in connection with our Services to better understand how users access and use our Services and the Platform, both on an aggregated and individualized basis, in order to improve our Services to our customers, and for other research and analytical purposes. We may combine and compile (i.e., aggregate) Personal Information with other individuals’ information and analyze the aggregated data we have collected
· To investigate and prevent unauthorized access to our Services and other illegal activities
· To enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose Personal Information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. We will never sell, share, or use your Personal Information for non-Kinto advertising purposes.
· To fulfill any other purpose for which you provide it, in any other way we may describe when you provide the information, or for any other purpose with your consent
Use of information depending on classification
Depending on its type, we may use information that we collect about you and/or the Care Recipient or that you provide to us in additional ways.
At times, Kinto may de-identify Personally-Identifiable Data, meaning that we use an established process to remove data elements so that an individual’s identity cannot be reasonably determined; when we use this de-identification process, such information is no longer Personally-Identifiable Data and is instead treated as General Data.
Kinto may collect, aggregate or statistically analyze Personally-Identifiable Data and General Data, including from more than one caregiver and/or Care Recipient, in which case such resulting aggregated or statistically analyzed data shall be treated as General Data.
We may use Personally-Identifiable Data internally, for research, for maintenance and operation of the Platform, to create the best possible tools and experience for caregivers, and for similar purposes.
We may use and/or disclose Protected Health Information and Basic Health Information to provide the Services as described in this Privacy Policy, except to the extent our use and disclosure of Protected Health Information is further limited by HIPAA.
When We Share Information
Kinto applies reasonable and appropriate measures to safeguard the confidentiality, integrity, and availability of Personal Information we store and process on behalf of you.
We may share Personal Information in the following ways:
With your consent
We may disclose a Care Recipient’s Personal Information to a Care Recipient’s health care provider or to another third party who provides direct support services to Care Recipient. We may sell or share Personal Information when we have your prior proper consent and/or authorization to do so, such as in the case of special research projects and studies or for media interviews of a caregiver.
With our Partners
Kinto may provide General Data, in individual and aggregate form, to Partners for use in scientific research and market research. In instances when Kinto sells information, we de-identify information and, where possible, we require that Partners do not re-identify the individual about whom the information relates.
With vendors and other third parties
We may share General Data with third party vendors, service providers, contractors or agents who perform functions or services on our behalf and require access to such information to do that work and perform our business, in each such case in compliance with applicable law. We may share aggregate or other General Data that does not directly identify you with third parties in order to improve the overall experience of the Platform and the other Services. Examples include data analysis, payment processing, hosting services, marketing and advertising services, and customer support functions. Such third-party service providers will only have access to General Data as necessary to perform their functions and pursuant to agreements they enter into with us that require them to fully comply with our data protection policies and this Privacy Policy.
In order to comply with laws and protect our rights
We may use and disclose Personal Information to a third party if: (i) we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; (ii) to enforce our agreements, policies and terms of service; (iii) to protect our operations and the security or integrity of Kinto’s products and services; (iv) to protect the property, rights, and safety of Kinto, you, Care Recipients, other customers or the public from harm or illegal activities; or (v) to investigate and defend ourselves against any third-party claims or allegations and to allow us to pursue available remedies or limit the damages that we may sustain.
In the event of a sale of the business
We may share or transfer Personal Information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. In the event of such an event, an acquiring company will be responsible for informing you about material changes to the way your data is used.
How we secure your information
Maintaining the privacy and security of Personal Information is important to us. We have implemented reasonable security measures designed to protect your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. Kinto has implemented appropriate safeguards to prevent unlawful use or disclosure of information. These include administrative, physical, and technical security safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of information we receive, maintain, or transmit. We comply with all local, state, and federal privacy laws regulating the transmission, processing and storing of information, including Protected Health Information, consistent with HIPAA. All information you provide to us is stored in an encrypted format and hosted on secure servers. These facilities may be operated by us or by our third-party service providers. By using the Platform, you consent to having your Personal Information stored, transferred, and processed by these facilities. Any payment transactions will be encrypted using SSL technology.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Platform like message boards. The information you share in public areas may be viewed by any user of the Platform.
Unfortunately, the transmission of information via the Platform and computing devices is not completely secure. Although we strive to protect Personal Information, we cannot guarantee the security of your personal information transmitted on our Platform. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform.
Information retention
Information maintained to provide our Services is retained only for as long as we have a valid business purpose and in accordance with applicable law. Kinto may retain Personal Information as necessary to comply with legal obligations, resolve disputes and enforce our agreements and other authorized uses under this Privacy Policy. Upon termination of your account, you can request deletion of Personal Information. For accounts that have been dormant with no activity for an extended period of time, we will contact individuals directly prior to removing the account and associated information. Please note that closing your account affects only Personal Information that is stored on Kinto servers. It does not affect, alter, or accomplish the deletion of any of Personal Information that is stored or maintained on other systems, such as those of healthcare providers or others that may have, with your permission, provided us with Personal Information.Kinto indefinitely stores non-Personal Information.
Access and changes to your information
You can review and change your Personal Information by logging into your account and visiting your profile page. You may also send us an e-mail at support@kinto.care to request access to, correct or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account and use of the Services, and you agree that we will not be liable to you for such termination. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Although we will use reasonable efforts to do so, you understand that it may not be technologically possible to remove from our systems every record of your Personal Information. The need to back up our systems to protect information from inadvertent loss means a copy of your Personal Information may exist in a non-erasable form that will be difficult or impossible for us to locate or remove.
If you delete any contributions you have made or posted, copies of such contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Platform users. Proper access and use of information provided on the Platform is governed by our Terms of Use.
You may discontinue use of the Services and Kinto’s use of Personal Information by contacting support@kinto.care. In the event you withdraw your consent for use of Personal Information, Kinto will retain your Personal Information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or allowed by law.
If you have used our Services to share information with another user or a third party, you will not be able to access, update, or delete that shared information. You will need to contact that other user or third party directly. Further, if another user of our Services submits information that identifies you, you will not be able to access, update, or delete that information. We also retain copies of data stored by our Platform for indefinite periods of time for disaster recovery and business continuity purposes.
International users
Our Platform is hosted in the United States and our Services are intended for users located within the United States. No one located outside of the United States should access our Platform, use our Services, or provide us with individually identifiable information.
California privacy rights
California Civil Code Section § 1798.83 permits users of our Platform who are 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 send an e-mail to support@kinto.care.
Third party websites
We are not responsible for the practices employed by websites linked to or from our Platform nor the information or content contained therein. Often links to other websites are provided solely as pointers to information on topics that may be useful to the users of our Services. Please remember that when you use a link to go from our Platform to another website, our Privacy Policy is no longer in effect. Your browsing and interaction on any other website, including websites which have a link on our Platform, is subject to that website’s own rules and policies. Please read over those rules and policies before proceeding.
Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at: support@kinto.care.