Privacy Policy

Last updated: 06/27/2018

This Privacy Policy discloses the privacy practices for www.avaaction.com, and the AVA Action LLC(“AVAAction”) mobile application(the“App”).
We care deeply about protecting your personal information and take great care in making sure it is kept private and secure. Subject to the terms of this Privacy Policy: 
– We will never, ever sell your personal data or personal health information. 
– Your information is securely stored and encrypted.
– Your information is ONLY shared with people to which you have given access to your account.
– If you have given someone access to your account, you can revoke such access at any time.
 
We will inform you of the following in this Privacy Policy:
– What personally identifiable information of yours is collected;
– What organization is collecting the information;
– How the information is used;
– With whom the information may be shared;
– What choices are available regarding collection, use and distribution of the information;
– What kind of security procedures are in place to protect the loss, misuse or alteration of information under our control; and,
– How you can correct any inaccuracies in the information.

About this Privacy Policy and Using the Site

This Privacy Policy applies to the website(the“Site”).Reference to“AVAAction” means AVA Action LLC, including any company that AVA Action LLC controls. AVA Action may share information among its subsidiaries or sites that it owns or controls, but such information will be protected under the terms of this Privacy Policy.
While you may use some of the functionality of the Site without registration, many of the specific tools and services on the Site require registration. If you use the Site without registering, the only information we collect will be Non-Personal Informationthrough the use of Cookiesor Web Beacons. If you choose to register with the Site for certain paid services, we may require you to submit Personally Identifiable Information. Depending on the paid service you select, we may also collect Personal Health Information. You are responsible for ensuring the accuracy of the Personally Identifiable Information and Personal Health Information you submit to SuperBetter. Inaccurate information will affect the information you receive when using the Site and our ability to contact you as described in this Privacy Policy.

Personally Identifiable Information We Collect And How It Is Used

We will never give away, sell or share your Personally Identifiable Information except as specifically authorized by you. We collect Personally Identifiable Information, like your name, email address, date of birth, and zip code, you provide to us when you register as a member of the App and/or when you update your member profile. We use the Personally Identifiable Information that you provide to respond to your questions, provide you the specific services you select, send you emails about App maintenance and updates, and inform you of significant changes to this Privacy Policy.
A. Newsletters & Emails to You
At the time of registration and at various times as you use the App, you may be given the option of receiving recurring newsletters via email from AVA Action and/or directly from third parties. These emails will not contain Personal Health Information. When you sign up for our email newsletters or at any time, you may be given the option to Opt-In to receiving additional promotional emails from AVA Action or our sponsors. In order to subscribe to AVA Action newsletters via email, we need your contact information, like name and email address. We will provide an option to unsubscribe from any newsletters we may send, for example, by clicking on an“unsubscribe”link at the bottom of an email newsletter. If you experience difficulties with an automated unsubscribe service we provide, please use our Contact Us Form. We will manually unsubscribe you from that newsletter as soon as reasonably practical. In some cases, when you click on a link or an advertisement on the App, in an email or newsletter, your browser may be momentarily directed to the web site of a third party which, acting on behalf of AVA Action(seeDisclosure to Third Party Contractor Web Apps, below), notes or“counts”your response to the email or newsletter before redirecting your browser to your selected destination; this redirection process may not be apparent to you.
B. Emails You Send to AVA Action
This Privacy Policy does not apply to content, business information, ideas, concepts or inventions that you send to AVA Action by email. If you want to keep content, business information, ideas, concepts or inventions private or proprietary, do not send them in an email to AVA Action.
C. Message Boards and other Public Forums
As a service to our users, the Site may feature message boards, Facebook groups, and other public forums where users with similar interests, medical conditions or health goals can share information and support one another. We may also offer online discussions moderated by medical or healthcare experts. Any information shared(includingPersonally Identifiable Information and Personal Health Information) that you reveal in a chat room, message board, Facebook group, social media, posting or online discussion is by design open to the public and is not a private, secure service. In addition, any videos, images or audio files you submit may be redistributed through the Internet and other media channels and may be viewed by the general public. You should think carefully before disclosing any Personally Identifiable Information or Personal Health Information in any public forum. Anything you have written, posted or uploaded may be seen, disclosed to or collected by third parties and may be used by others in ways we are unable to control or predict, including to contact you for unauthorized purposes. As with any public forum on any site, this information may also appear in third-party search engines like Google, Yahoo, MSN, etc. Your account name may be displayed to other users when you engage in certain activities on the App/the Site.
If you choose to add personal information to your account profile that is visible to other users(suchas a profile picture, your name, gender or other details), such information may be accessible to the general public.
We may use third parties to manage blogs or other services provided on the App. When you create an account with any such third party, they may share the information you have posted as necessary for us and the third party to provide continued service and to allow you to post your blogs or use such other service. Such third party will share ownership of your information as necessary to continue to implement the applicable service on the App and as described in their privacy policy. AVA Action will use your information as described in this Privacy Policy.
D. Paid Services
AVA Action may offer users the opportunity to register for paid services offered on a subscription or perpetual basis. A paid service may have its own service or member agreement that governs your use of the service and the information we collect to provide the service, including your credit card information. Any such service or member agreement will be disclosed to you at the time of registration for that paid service.
E. Children
We are committed to protecting the privacy of children. Neither AVA Action nor any of its services are designed or intended to attract children under the age of 13. We do not collect Personally Identifiable Information from any person we actually know is under the age of 13.
F. Research & Surveys
From time to time AVA Action, or contractors acting on its behalf, may conduct online research surveys in order to gather feedback about the App, our sponsors and opinions on important healthcare issues, through email invitations, surveys, online focus groups and other similar methods. When participating in a survey, we may ask you to submit Personally Identifiable Information. This Personally Identifiable Information is used for research purposes, and will never be used for sales solicitations. When a survey is sponsored by a third party, Aggregate Information of the survey results is reported to the sponsor. Personally Identifiable Information collected through market research will be used only by AVA Action and its service providers and contractors and will not be given or sold to a third party without your consent or as otherwise permitted by this Privacy Policy. For market research surveys we will not knowingly accept survey responses from or conduct interviews with any person under the age of 18. Some surveys may provide remuneration to participants such as a small cash fee for your time or an entry into a sweepstakes for a larger prize. Each survey will disclose whether or not it is a paid survey. In addition to collecting survey responses from our members, Cookies may be used to authenticate responses or to help you pick up where you left off in a survey. If you have Cookies disabled you may not be able to participate in some studies. Cookies may be used to connect survey data with App usage characteristics. You will be notified when we would like to use Cookies in this way and your consent will be requested for these Cookies.

Information Collected by Third Parties Not Acting on Behalf of AVA Action

Sponsors or advertisers on the App may use their own Cookies, Web Beacons or other online tracking technologies in the banner advertisements served on the App and in emails, special promotions or newsletters we send you. Some advertisers use companies other than AVA Action to serve their ads and to monitor users’ responses to ads, and these companies(“AdServers”) may also collect Non-Personal Information through the use of Cookies or Web Beacons on the App. In certain situations, information collection may be facilitated by momentarily directing your browser to the web site of an Ad Server or other third party acting on behalf of the sponsor, partner, or advertiser before redirecting your browser to its selected destination(e.g.,back to the App to show the ad, or to the advertiser’s website); this redirection process will not be apparent to you.
We do not control these third parties’ use of Cookies or Web Beacons, or how they manage the non-personal information they gather through them. You should review the privacy policies of other sites you visit or link to from the App to understand how these other sites use Cookies and how they use the information they collect through the use of Cookies or Web Beacons on their own sites. Certain Ad Servers allow you to prevent them from collecting data through the use of Cookies. In order to do so, you must Opt-Out of such data collection with each individual site.

Protecting Your Information

Except as described in this Privacy Policy or as specifically agreed to by you, AVA Action will never disclose any Personally Identifiable Information or Personal Health Information it gathers from you on the App. We may only release Personally Identifiable Information or Personal Health Information to third parties:(1)to comply with valid legal requirements such as a law, regulation, search warrant, subpoena or court order; or(2)in special cases, such as in response to a physical threat to you or others, to protect property or defend or assert legal rights. In the event that we are legally compelled to disclose your Personally Identifiable Information or Personal Health Information to a third party, we will attempt to notify you unless doing so would violate the law or court order. In addition, we may disclose Personal Information as described below.
A. Disclosure to AVA Action Operations and Maintenance Contractors
AVA Action operations and maintenance contractors may sometimes have limited access to your Personally Identifiable Information in the course of providing products or services to AVA Action. These contractors could include vendors and suppliers that provide us with technology, services, and/or content for the operation and maintenance of the App. Unless you have Opted-Out of receiving emails and newsletters from AVA Action, these contractors also may have access to your email address to send newsletters or special promotions to you on our behalf or to send emails to you for purposes such as conducting market research on our behalf. Access to your Personally Identifiable Information by these contractors is limited to the information reasonably necessary for the contractor to perform its limited function for AVA Action.
B. Disclosure to Third Party Contractor Web Sites
Certain content and services offered to you through the App may be provided by web sites hosted and operated by a company other than AVA Action(“ThirdParty Contractor Web Sites”). AVA Action will not disclose your Personally Identifiable Information to these Third Party Contractor Web Apps without your consent, but you should be aware that any information you disclose once you access these other web sites is not subject to this Privacy Policy. AVA Action does not endorse and is not responsible for the privacy practices of these Third Party Contractor Web Sites. You should review the privacy policy posted on Third Party Contractor Web Sites to understand how that Third Party Contractor Web Site collects and uses your Personally Identifiable Information. AVA Action will make an effort to make it obvious to you when you leave the App and enter a Third Party Contractor Web Site. AVA Action may also provide links to sites provided by Third Party Contractor Web Sites that have business arrangements with AVA Action to pay commissions based on sales of products or services generated through AVA Action.
C. Disclosure to Linked Sites
In addition to the Third Party Contractor Web Sites that you may access as described above, for your convenience the Site may contain links to Third Party Web Sites operated by companies that are not affiliated with the Site and that do not have contracts to provide content or services through the Site. These links may be found in advertisements, referenced within content, or placed beside the names or logos of sponsors. AVA Action does not disclose your Personal Information to these Third Party Web Sites without obtaining your consent. AVA Action does not endorse and is not responsible for the privacy practices of these sites. If you choose to link to one of these Third Party Web Sites, you should review the privacy policy posted on this other web site to understand how that Third Party Web Site collects and uses your Personally Identifiable Information.
D. Disclosure of Aggregate Information
AVA Action may provide Aggregate Information to third parties for educational or service-related purposes. Aggregate Information does not and never will contain Personally Identifiable Information or Personal Health Information. For example, we might inform third parties regarding the number of users of the App and the activities they conduct while on the App. We might inform third parties(thatmay or may not be an advertiser on the App) of statistical information, such as“25%of our users live in the western United States” or“15%of our users seek a second opinion before undergoing surgery.” We might also work with third parties to translate Aggregate Information into research reports. All research will be used for the specific goal of improving health, health care and wellness for individuals and communities. Depending on the circumstances, we may or may not charge third parties for this Aggregate Information.
E. Disclosure to Entities and Individuals You Designate
AVA Action may provide your Personally Identifiable Information or Personal Health Information with individuals and entities that you designate for the purpose of sharing your information on the App with others whom you choose. If you want to change your preferences with respect to individuals or entities to whom AVA Action may provide your Personally Identifiable Information or Personal Health Information, select the privacy option on our Contact Us Form.

How AVA Action Handles Privacy and Security Internally

Here are some of the security procedures that AVA Action uses to protect your privacy:
– Requiring both a personal username(log-inname) and a password in order for users to access their Personally Identifiable Information or Personal Health Information.
– Using firewalls to protect information held in our servers.
– Utilizing Secure Socket Layer encryption in transmitting Personally Identifiable Information to our servers. In order to take advantage of encryption technology, you must have an Internet browser which supports 128-bit encryption.
– Closely monitoring the limited number of AVA Action employees who have potential access to your Personally Identifiable Information.
– Requiring all AVA Action employees to abide by our Privacy Policy and to be subject to disciplinary action if they violate it.
– Backing-up our systems to protect the integrity of your Personally Identifiable Information and Personal Health Information.
AVA Action may require you to answer security questions. We will use the answers you provide to these questions to help you in the event you forget your username or password. In order to help maintain your privacy, we require an EXACT match against what you submitted during your registration process. Correct spelling and short answers can help ensure that you will succeed with retrieving your username or resetting your password.
Despite AVA Action’s efforts to protect your Personally Identifiable Information and Personal Health Information, there is always some risk that an unauthorized third party may find a way around our security systems or that transmissions of your information over the Internet may be intercepted.

Updating Your Information and Contacting AVA Action

A. Updating Your Personally Identifiable Information 
If we collect and store self-reported data for certain App functionalities, we will provide you with a method for correcting, updating or reviewing such information. We will store user submitted data(PersonallyIdentifiable Information and/or Personal Health Information) in an active database for a certain period of time and may later transfer such data to an inactive back-up medium.
B. Removing your Personal Information
If you have a complaint or problem, please use our Contact Us Form or send us a letter via U.S. mail to: AVA Action LLC, ATTN: Top Secret Office of Privacy, 8839 Knox Ave, Skokie, IL 60076. Our customer service department will forward your complaint to the appropriate internal AVA Action department for a response or resolution. If you want to(1)delete your Personally Identifiable Information from our systems,(2)update the Personally Identifiable Information that you have provided to us, or(3)change your preferences with respect to marketing contacts or other activities, select the privacy option on our Contact Us Form.
C. Limitations on Removing or Changing Information
Upon your request, we will delete your Personally Identifiable Information or Personal Health Information from our active databases and where feasible from our back-up media. You should be aware that it is not technologically possible to remove each and every record of the information you have provided to AVA Action from our servers.
D. Accountable Representative
Notwithstanding anything contained herein to the contrary, if you have any questions or concerns related to this Privacy Policy or AVA Action’s collection, storage and/or use of Personally Identifiable Information or Personal Health Information, you may contact AVA Action at 8839 Knox Ave, Skokie, IL 60076.
Changes to this Privacy Policy
A. Personally Identifiable Information
We will inform you of a material change to the Privacy Policy, which means a change that expands the permissible uses or disclosures of Personally Identifiable Information allowed by the prior version of the Privacy Policy. Your continued use of the App will indicate acceptance of the changes. You may of course choose to Opt-Out of continuing to use the App. Please exit the App immediately if you do not agree to the terms of this Privacy Policy or any revised policy.
B. Personal Health Information 
We will inform you if a material change in the Privacy Policy is made that involves the use of your Personal Health Information, and your express Opt-In authorization will be requested. If you choose to not accept the new privacy policy, then the current privacy policy conditions will remain in effect, so long as the respective functionality remains available. AVA Action reserves the right to discontinue or limit functionality in all its products and services.
C. Non-Significant Changes 
AVA Action may make non-significant changes to the Privacy Policy that do not affect Personally Identifiable Information or Personal Health Information at any time. AVA Action may not notify you of such non-significant changes.
We reserve the right to modify this Privacy Policy at any time. If we decide to change this Privacy Policy, we will post the revised policy on the App so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. Please review this Privacy Policy frequently. Your continued use of the App will indicate acceptance of any such changes.
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