Privacy Policy

Effective date: June 12, 2020

We are Shadow Health, Inc., a company incorporated in Florida, United States. In this Privacy Policy ("Privacy Policy") we may be referred to as "Shadow Health," "we," "our," or "us." We are a developer of educational simulation products. We own and operate all websites under the domain of shadowhealth.com, collectively referred to as "Sites" in this Privacy Policy. We also own and operate a web platform we use to deliver our simulation products to our users, including https://app.shadowhealth.com, referred to as the "Service."

In this Privacy Policy, "you" and "your" refers to you as a visitor of one of our Sites, a user of the Service, or a customer or potential customer who is contacted by us.

Please additionally review our Terms of Service that govern your use of our Sites as well as our Access Agreement for users of the Service. By accessing our Sites or using our Service, you consent to the collection, use and sharing of your data as described herein, and you agree to be bound by our Terms of Service, the Access Agreement, if applicable, and any other terms and conditions set forth on our Sites or agreed to by you. This Privacy Policy does not apply to third-party websites, products, or services, even if they link to our Sites or Service.

What Data We Collect from You and How We Use It

The collection and processing of data described below is essential to our ability to provide our Sites and Service and to keep the Sites and Service secure.

Personal Data. We collect "Personal Data," which is data that identifies, or could reasonably be used to identify, an individual. We collect Personal Data when you provide it to us directly, such as when you create an account on the Service, when you use and interact with our Service, when you submit a "contact us" request, when you make a purchase through our Sites or Service, or when you fill out another form through our Sites or Service. Personal Data we may collect includes your name, affiliated academic institution, email address, and phone number.

Surveys. As part of your use of the Service, we may ask you to complete surveys to measure the effectiveness of our Service. Your survey responses may be linked with your account and we may use your responses to improve our Service and share your responses with your academic institution.

Simulation Product Data. When you use our simulation products Service, for example by attempting and/or completing a course assignment, we collect data input by you during the simulation, such as questions you ask our virtual patients and documentation you enter in the virtual patient's chart. This data is used to provide you and your institution's faculty with a record of your performance in the simulations, to measure the effectiveness of our Service, and for our legitimate business purposes to ensure the security of our systems, identify usage trends, and improve the Service.

Usage Data. We collect "Usage Data" that is tracked and gathered when your web browser or software communicates certain information to us through tracking technologies (such as cookies, pixel tags, web beacons, or digital fingerprinting) we employ when you use our Sites or Service. Usage Data is non-personally identifiable information, such as page load times, the URL that referred you to our Sites or Service, browser and operating system vendor and version, screen resolution, and approximate IP address. To the extent we combine any Usage Data or other non-personally identifiable information with Personal Data, we will treat such combined data as Personal Data.

Cookies are a common tracking technology used to collect Usage Data. Cookies are data files that websites write into computer hard drives for record-keeping purposes. As a convenience feature, cookies simplify the process of recording personal information, so that, for example, users do not have to enter names, addresses or passwords repetitively. To learn more about cookies that may be used on our Sites and Service, and to learn how you can control our use of cookies, please see our Cookies Policy, which is hereby incorporated as part of this Privacy Policy by reference.

Information Shared With Third Parties

We may rely on other companies and individuals to perform functions on our behalf. Examples include payment platforms, data analysis firms, customer support specialists, and web-hosting companies. We may share Personal Information with such third parties as appropriate for them to perform their functions, but they may not use such information for any other purpose.

Payment Information

If you make a purchase through our Sites or Service, we require that you provide your payment information, including credit or debit card and billing address. All payment information that you submit through the Sites or Service is collected directly by our third-party payment processor, Stripe. Shadow Health receives only a non-personally identifiable token to indicate the success of the payment transaction, and does not collect or retain any of your payment information. When you make a purchase through our Sites or Service, you are subject to Stripe's Privacy Policy. Accordingly, please be sure to review Stripe's policy carefully before submitting any payment information through the Site or Services.

Analytics Services

We may use third-party analytics services that track details about your online activities over time and across different sites, such as Google Analytics. These services help us to improve our Sites and Services. These analytics services may also allow us and others to provide you with targeted advertisements or other content that you may be interested in based on your online activities. If you would like to learn more about targeted ads that may be based on your online activities, and the choices that you may exercise for certain sites and advertisers, you may wish to visit the Network Advertising Initiative or the Digital Advertising Alliance. To opt out of being tracked by Google Analytics across all websites, visit Google Analytics Opt Out.

Third-Party Tracking and Do Not Track

Third parties may use tracking technologies in connection with your use of our Sites and Services, which may include the collection of information about your online activities over time and across third-party websites. This Privacy Policy does not apply to these third-party technologies because we do not control them and are not responsible for them. Do Not Track is a technology that enables users to opt out of tracking by websites they do not visit. As there is presently no industry standard for recognizing Do Not Track browser signals, we do not take any action with respect to Do Not Track signals.

How Long We Keep Your Personal Data

When we collect your Personal Data, we will maintain and store it for as long as we determine reasonably necessary to provide the Sites and Service to you or to comply with applicable legal requirements. If your Personal Data is provided to us by your academic institution or your academic institution requires you to register and use the Service, the Personal Data that we have collected from you is governed by our agreement with your academic institution and we will maintain and store your data for the duration specified in that agreement.

How We Secure Your Personal Data

We comply with applicable laws to provide an adequate level of data protection for the transfer of Personal Data, including encryption of data in-transit using TLS and encryption of Personal Data at-rest. Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure. Although we apply commercially reasonable security practices to protect your Personal Data, we cannot guarantee the security of data you transmit to us, and you use our Sites or Service and provide us with your data at your own risk. If you believe that the security of your account with Shadow Health has been compromised, please contact support@shadowhealth.com immediately.

Where We Store and Transfer Your Personal Data

Shadow Health's business operations are based in the United States. Data we collect, including Personal Data, may be stored and processed in any country in which we have operations or in which we engage third-party processors. Data that is collected from users in other countries may be transferred to, and stored at, a destination outside your country, including the United States.

How We Share Your Data and Why

Shadow Health does not sell or rent Personal Data to marketers or unaffiliated third parties.

We share your Personal Data with trusted third parties including, your academic institution and our third-party service providers.

To the fullest extent permitted by applicable law, we may also disclose your data if we believe in good faith that doing so is necessary or appropriate to protect or defend the rights, safety, or property of Shadow Health, or to comply with legal and regulatory obligations, such as law enforcement inquiries, subpoenas, and court orders. To the fullest extent permitted by applicable law, we have sole discretion in electing to make or not make such disclosures.

EU-U.S. and Swiss-U.S. Privacy Shield Frameworks

We comply with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom and Switzerland to the United States ("Privacy Shield"). Shadow Health has certified to the Department of Commerce that we adhere to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this Privacy Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification please visit https://www.privacyshield.gov/.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. European Union and Swiss individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us at privacy@shadowhealth.com or by mail to:

Shadow Health, Inc

Attn: Data Protection Officer

201 SE 2nd Ave, Ste. 201

Gainesville, FL 32601, USA

We have further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact JAMS or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you. If your concern continues to be unresolved, you may pursue binding arbitration through the Privacy Shield Arbitration Panel. To learn more about the Privacy Shield Panel, click here.

The Federal Trade Commission has jurisdiction over Shadow Health's compliance with the Privacy Shield.

As explained here we sometimes share Personal Data with third parties to process the data on our behalf. If we transfer Personal Data received under the Privacy Shield to a third party, the third party's access, use, and disclosure of the Personal Data must also be in compliance with our Privacy Shield obligations, and we will remain liable under the Privacy Shield for any failure to do so by the third party unless we prove we are not responsible for the event giving rise to the damage.

Your California Privacy Rights

In accordance with California's "Shine the Light" law, California Civil Code 1798.83, we will not share Personal Data of our users with third parties for their direct marketing purposes.

If you are a resident of California your Personal Data is subject to our Privacy Policy for California Residents (the "CCPA Privacy Policy"). To the extent the provisions of this Privacy Policy conflict or are inconsistent with the provisions set out in the CCPA Privacy Policy, the provisions in the CCPA Privacy Policy shall control.

Users Registered Through an Academic Institution

Your institution may offer the ability to create an account with Shadow Health directly through your institution's learning management system or other website. If you use this mechanism to create an account with Shadow Health, your use of our Sites and Services will be governed by this Privacy Policy as well as any terms and conditions of your institution's learning management system. To the extent the provisions of this Privacy Policy conflict or are inconsistent with the provisions set out in your institution's learning management system or website, this Privacy Policy shall control when you use the Sites or Service.

If you are a registered student user of the Service, your Personal Data and certain Usage Data, such as your scores on assignments taken within the Service, are shared with authorized course faculty at your institution so that they may evaluate and incorporate your use of the Service into your course credit or grade. We also share your Personal Data and Usage Data with authorized course faculty at your institution when you violate our Terms of Service, Access Agreement, Acceptable Use Policy or to resolve academic honesty disputes.

Children's Personal Information

Our Sites and Service are not intended for individuals under the age of majority in their jurisdiction. If you are under the age of majority in your jurisdiction, you are not permitted to use our Sites and Service and should not provide Personal Data through the Sites or Service. If we become aware that an individual under 13 years of age has provided us with Personal Data, we will dispose of that data in accordance with the Children's Online Privacy Protection Act and other applicable laws and regulations. If you become aware that an individual under 13 years of age has provided us with Personal Data, please contact us at support@shadowhealth.com and we will take reasonable steps to ensure that data is deleted.

Business Transfer

In the event of a sale, merger, or similar transaction, your Personal Data may be transferred as part of that transaction. This Privacy Policy will apply to your Personal Data as transferred to the new entity.

Updates to this Privacy Policy

We may revise this Privacy Policy from time to time. The most current version of the Privacy Policy will govern our processing of your Personal Data and will always be available at https://shadowhealth.com/privacy.

When we revise the Privacy Policy, any changes will be effective immediately upon the posting of the revised Privacy Policy. Registered users of the Service will be prompted to consent to the updated version when accessing their Shadow Health account for the first time after a Privacy Policy change. By continuing to access or use our Sites or Service after any changes to our Privacy Policy are posted, you agree to be bound by the revised Privacy Policy.

Contact Us

Questions, comments, and requests regarding this Privacy Policy are welcomed and should be addressed to our Data Protection Officer at privacy@shadowhealth.com or by mail at:

Shadow Health, Inc

Attn: Data Protection Officer

201 SE 2nd Ave, Ste. 201

Gainesville, FL 32601, USA

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