Privacy Policy
Privacy Policy for The Comma Collective, Inc.
Effective Date:January 17, 2024
At The Comma Collective (“we,” “our,” or “us”), we are committed to protecting your privacy and ensuring the confidentiality of your personal information. This Privacy Policy outlines how we collect, use, disclose, and protect your information when you visit our website at [yourcomma.com] (the “Site”) or when you access Sara™ (together with the Site, the “Services”).
1. HIPAA Applicability
Comma is not a covered entity as defined by the Health Insurance Portability and Accountability Act (HIPAA) and as such, is not required to follow HIPAA. However, we are committed to protecting the privacy and security of any health-related information you choose to share with us.. This Privacy Policy describes our practices regarding the collection, use, and disclosure of your information in connection with the Services. If you have any questions regarding our protection, use, and collection of your information in connection with your use of Sara, please view the FAQ [LINK] or Sara Privacy Policy [LINK}.
2. Information We Collect
We may collect the following types of information:
Personal Information: This includes information that identifies you personally, such as your name, email address, phone number, and any other information you provide when creating an account or interacting with our services.
Health Information: If you choose to voluntarily provide health-related information (e.g., medical history, symptoms), we will handle this information with care in accordance with this Privacy Policy, although it does not fall under the protections of HIPAA.
Usage Data: We may collect information about how you use our Services, including your IP address, browser type, device information (including unique device identifiers), pages visited, and time spent on our Site and in Sara.
Cookies and Tracking Technologies: We use Google Analytics, cookies and similar technologies to enhance your experience and analyze usage of the Services. You can manage your cookie preferences through your browser settings. We currently do not authorize the collection of personal information from our members for third-party use through targeted advertising without explicit consent. We therefore do not respond to Do Not Track signals.
3. How We Use Your Information
We use your information for the following purposes:
To Provide Services: To manage your account and provide our Services effectively.
Communication: To communicate with you regarding your account, updates, promotions, and respond to your inquiries.
Health Management: To support your health and wellness goals by providing personalized content and recommendations.
Research and Improvement: To analyze trends, improve our services, and conduct research.
Legal Compliance: To comply with applicable laws and regulations.
4. Disclosure of Your Information
We may disclose your information in the following circumstances:
Third-Party Service Providers: We may share your information with third-party vendors who assist us in operating our Site and providing our Services, including AWS, Google Analytics, and Comma’s engineering team which is responsible for building and maintaining Sara™. These service providers are required to protect your information and comply with applicable privacy laws.
Legal Requirements: We may disclose your information when required by law or to respond to legal requests.
5. Your Rights Regarding Your Information
Depending on your state of residence you may have certain rights regarding your personal information. If you are a California resident, the California Consumer Privacy Act and the California Privacy Rights Act (collectively, the “CCPA”) provide you with the following rights.
Right to Know: You have the right to request that we disclose certain information about our collection and use of your personal information over the past twelve months.
o The categories of personal information we collected about you.
o The categories of sources for the personal information we collected about you.
o The categories of personal information that we have disclosed for a business or commercial purpose.
o Our business or commercial purposes for collecting, selling, or sharing personal information.
o The categories of third parties with whom we share or disclose that personal information.
o The specific pieces of personal information we collected about you (i.e., a data portability request).
Right to Limit the Use of Your Sensitive Personal Information: You have the right to limit the use and disclosure of sensitive personal information as necessary to perform our services. We do not collect or process sensitive information for the purpose of inferring characteristics about you and therefore do not offer the choice to limit the use of disclosure of sensitive personal information at this time.
Right to Delete: You have the right to request that we delete the personal information that we collected from you and retain, subject to certain exceptions. Once we receive and verify your request, we will delete (and direct our service providers/contractors to delete) your personal information from our records, unless an exception applies.
Right to Correct: You have the right to correct or amend the personal information we have on file (“Right to Correct”). You may correct or amend your personal information by contacting us using the information below.
Right to Opt-Out of Sale or Sharing: You have the right to opt-out of the “sale” or “sharing” of their personal information. In the last 12 months, we have not sold or shared any categories of personal information.
Right to Non-discrimination: We will not discriminate against you for exercising any of your rights under California law.
As of the effective date of this policy, several other states have also enacted laws providing at least some of the rights described above to their residents. This includes Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. If you are a resident of one of those states, these disclosures are also intended to provide you with the requisite information.
Exercising Your Rights
If you have any questions about the rights described in this section, or wish to exercise them,please email us at feedback@comma-collective.com.
We will respond to all valid requests within the time required by applicable law. Depending on your state of residence, you may have the right to complain to a competent supervisory authority if you feel that we are not complying with our data protection obligations.
Authorized Agents
You may authorize an agent to make a request on your behalf. To designate an agent, please provide a written and signed document by both you and the agent that authorizes the agent to act on your behalf. You may also use a power of attorney. We will still require you to provide information to allow us to reasonably verify that you are the person about whom we collected personal information.
6. Data Security
We implement reasonable technical and organizational measures to protect your personal information from unauthorized access, use, or disclosure. However, please be aware that no method of transmission over the internet or electronic storage is completely secure, and we cannot guarantee absolute security. This includes the security of information You provide to us when using our Services.
7. Data Retention
We retain your personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. When your information is no longer needed, we will securely delete or if it is retained, anonymize it.
8. Children’s Privacy
Our services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that we have collected such information, we will take steps to delete it.
9. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. We will notify you of any changes by posting the new policy on this page and updating the effective date. We may also notify users with valid accounts of material changes to this policy by email. Your continued use of the Services after changes are posted constitutes your acceptance of the new Privacy Policy.
10. Contact Us
If you have any questions or concerns about this Privacy Policy or our privacy practices, please contact us at:
The Comma Collective, Inc.
Email: legal@comma-collective.com
11. International Users
If you access our Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and privacy laws in the United States may not be equivalent to those in your country.