Privacy policy lhs1stg February 6, 2020
Legacy Health Strategies Website Privacy Policy

Version 2.0
Last Update: August 2022  

This notice describes how your privacy or Personal Data (defined below) about you may be used and disclosed and how you can obtain access to this information. Please review it carefully.  

INTRODUCTION

We at Legacy Health Strategies LLC (we”, “us”, “the Company, or Legacy Health Strategies) value your privacy and are committed to keeping your personal data confidential. This Privacy Policy describes how we collect, use, and disclose your information in the context of providing the Legacy Health Strategies website (www.legacyhealthstrategies.com),  including all relevant content and functionality associated with the website (collectively, the Website).  

Privacy Policy Applicability 

This Website Privacy Policy applies to personal data that Legacy Health Strategies collects from users of the Website (“Personal Data”). The term “Personal Data” includes any information that can be used on its own or with other information in combination to identify or contact one of our users. In this Website Privacy Policy, we provide you detailed information about our collection, use, maintenance, and disclosure of your Personal Data. The Website Privacy Policy explains what kind of information we collect, when and how we might use your Personal Data, how we protect Personal Data, and your rights regarding your Personal Data.   

For additional information related to how we use and disclose your Personal Data please contact us at privacy@legacyhealthstrategies.com.  

Note regarding third-party sites: Our Website may contain links to other sites that are not operated by Legacy Health Strategies. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the privacy policy(ies) of every site you visit. Legacy Health Strategies has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services. This Website Privacy Policy does not apply to your use of or access to any third-party sites or services. 

Agreement to Website Privacy Policy Terms 

BY ACCESSING AND/OR USING THE WEBSITE, YOU ARE ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS WEBSITE PRIVACY POLICY. IF YOU DO NOT AGREE, YOU MUST IMMEDIATELY CEASE USING THE WEBSITE.  

Website Privacy Policy Updates 

Please note that we occasionally update this Website Privacy Policy, and it is your responsibility to stay up to date with any amended versions. Any revisions to the Website Privacy Policy will be posted on the landing page(s) of the Website. Any changes to this Website Privacy Policy will be effective immediately upon providing notice via the Website landing page(s) and will apply to all Personal Data that we maintain, use, and disclose. If you continue to use the Website following such notice, you are agreeing to those changes.  

Questions or Concerns 

If you have any questions or concerns after reading this Website Privacy Policy, please do not hesitate to contact us at privacy@legacyhealthstrategies.com. We appreciate your feedback.  

COLLECTION AND USE OF PERSONAL DATA 

What Personal Data Does Legacy Health Strategies Collect? 

We collect three types of information from our Website users: (i) contact data; (ii) support data; and (iii) technology data. Each category of data is explained in depth below.   

  • Contact Data: Legacy Health Strategies collects contact data from users, which may include, but not be limited to, your name, phone number, and e-mail address. The collection of this demographic data is primarily used to contact you and provide consultations or demos of Legacy Health Strategies’ products and services.   
  • Support Data: If you contact us for support or to lodge a complaint, we may collect technical or other information from you through log files and other technologies, some of which may qualify as Personal Data (e.g., IP address). Such information will be used for the purposes of troubleshooting, customer support, software updates, and improvement of the Website in accordance with this Website Privacy Policy.  
  • Technology Data: We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain Personal Data from your computer or mobile device as you navigate our Website or interact with emails or other communications we have sent you. The information we collect may include your IP address (or proxy server), device and application identification numbers, location, browser type, Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage. This information is used to analyze overall trends, help us provide and improve our Website, and ensure the proper functioning and security of the Website.  

 How Does Legacy Health Strategies Collect Personal Data?  

  • Website Engagement: Legacy Health Strategies collects Personal Data through your engagement with the Website, such as when you contact Legacy Health Strategies through the Contact Us form, sign up to receive information from Legacy Health Strategies, schedule a consultation or demo, or sign up for a newsletter.  
  • Job Opportunities: If you apply for jobs through the Website, your application and any additional information that you provide may be used to assess your skills and interests against career opportunities at Legacy Health Strategies, and for reporting purposes that may be required by country- or state-specific laws. We may also use your information to communicate with you and to inform you of career opportunities.  
  • Browser or Device Information: Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type, screen resolution, operating system name and version, device manufacturer and model, language, and Internet browser type. We use this information to ensure that the Website functions properly.  
  • Clear GIFs: We employ a software technology called clear GIFs (also known as web beacons, web bugs, or pixel tags) along with other technologies such as e-tags and JavaScript that help us better manage content on our site by informing us what content is effective. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies that are used to track the online movements of web users. In contrast to cookies, which are stored on a user’s computer hard drive, clear GIFs, which are about the size of a period, are embedded invisibly on web pages. We do not tie the information gathered by clear GIFs, e-tags, or JavaScript to your Personal Data.  
  • SDKs and Mobile Advertising IDs: Our Website may include third-party SDKs that allow us and our third-party service providers to collect information about your activity. In addition, some mobile devices come with a resettable advertising ID (such as Apple’s IDFA and Google Advertising’s ID) that, like cookies and pixel tag, allow us and our third-party service providers to identify your mobile device over time for advertising purposes.  
  • Third-Party Plugins: The Website may include plugins from other companies. These plugins may collect information about the pages you visit and share this information with the company that created the plugin even if you do not interact with it. Legacy Health Strategies has no control over and assumes no responsibility for the content, privacy policies, or practices of any third-party sites or services. We strongly advise you to review the privacy policy(ies) of every site you visit. 
  • Third-Party Online Tracking: Legacy Health Strategies may also partner with certain third parties to collect, analyze, and use some of the information described in this section. For example, we may allow third parties to set cookies or use web beacons on the website or in email communications from us. This information may be used for a variety of purposes, including online website analytics and interest-based advertising.  

What Is Legacy Health Strategies’ Cookie Policy? 

Cookies are files that hold a small amount of data specific to a web application, which can later be used to help remember information entered, preferences selected, and movement within the application. We do not currently use cookies.  

How Can Users Opt-Out of Cookies? 

If you prefer, you can usually choose to set your browser to remove and reject cookies. If you enable a do not track signal or otherwise configure your browsers to prevent us from collecting cookies, certain features of the Website may not operate correctly, and you may also be unable to take advantage of some of the Website’s features.   

Do Not Track Disclosure 

Some web browsers may transmit do not track (“DNT”) signals to websites with which the user communicates. To date, there is no industry standard for DNT and users cannot know how a given company responds to a DNT signal they receive from browsers. Legacy Health Strategies is committed to remaining apprised of DNT standards. However, Legacy Health Strategies does not support DNT browser settings and does not currently participate in any DNT frameworks that would allow Legacy Health Strategies to respond to signals or other mechanisms regarding the collection of your personal information.  

How Will Legacy Health Strategies Use Your Personal Data?  

Legacy Health Strategies processes your Personal Data based on legitimate business interests, the provision of the Website to you, compliance with our legal obligations, and/or your consent. We only use or disclose your Personal Data when it is legally mandated or where it is necessary to fulfill those purposes described in this Website Privacy Policy. Where required by law, we will ask for your prior consent before disclosing your Personal Data to a third party.  

More specifically, Legacy Health Strategies processes your Personal Data for the following legitimate business purposes:  

  • Provide the functionality of the Website to you;  
  • Respond to your inquiries and fulfill your requests when you contact us via one of our online contact forms or when you send us questions, suggestions, compliments, or complaints about our Website;  
  • Manage and improve our operations and the Website, including the development of additional functionality; 
  • Respond to lawful requests from public and government authorities, and to comply with applicable state/federal law, including cooperation with judicial proceedings and court orders;  
  • Protect our rights, privacy, safety, or property, and/or that of you or others by providing proper notices, pursuing available legal remedies, and acting to limit our damages;  
  • Handle technical support and other requests from you; and  
  • Keep our Website safe and secure. 

Legacy Health Strategies may aggregate and/or anonymize Personal Data collected through the Website so that it will no longer be considered Personal Data. We do so to generate other data for our use, which we may use and disclose for any purpose, as long as it no longer identifies you or any other individual.  

Does Legacy Health Strategies Use Personal Data for Analytics? 

Legacy Health Strategies uses third-party service providers to monitor and analyze the use of the Website. The analytics services and techniques we may use include, but are not limited to, Google Analytics.  

Where Is Personal Data Processed? 

The Personal Data we collect through the Website will be stored on secure servers in the United States. Personal Data may be transmitted to third parties, which parties may store or maintain the data on their secure servers. These third parties are not permitted to transfer your Personal Data outside of the United States.  

With Whom Does Legacy Health Strategies Share Personal Data?  

We may share your personal information with the following categories of individuals/entities:  

  • Business Partners and Vendors: We share Personal Data with a limited number of partners, service providers, and other persons/entities who help run our business (“Business Partners”). Our Business Partners are contractually bound to protect your Personal Data and to use it only for the limited purpose(s) for which it is shared.  
  • Our Advisors: We may share your Personal Data with third parties that provide advisory services to Legacy Health Strategies, including, but not limited to, our lawyers, auditors, accountants, and banks (collectively, “Advisors”). Personal Data will only be shared with Advisors if Legacy Health Strategies has a legitimate business interest in the sharing of such data.  
  • Third Parties Upon Your Direction or Consent: You may direct Legacy Health Strategies to share your Personal Data with third parties.  
  • Third Parties Pursuant to Business Transfers: In the event of a reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of Legacy Health Strategies’ corporate entity, assets, or stock (including in connection with any bankruptcy or similar proceedings), we may share your Personal Data with a third party.  
  • Government and Law Enforcement Authorities: If reasonable and necessary, we may share your Personal Data to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that violate this Website Privacy Policy; or (iii) bring legal action against someone who may be causing intentional or unintentional injury or interference to the rights or property of Legacy Health Strategies or any third party, including other users of our Website.  

How Long Does Legacy Health Strategies Retain Personal Data? 

Legacy Health Strategies retains your Personal Data only as long as necessary and as required for our business operations, the provision of the Website, archival purposes, and/or to satisfy legal requirements.  

Except where requested by Legacy Health Strategies, we ask that you do not send to us through the Website or otherwise disclose to us any sensitive Personal Data, including social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometric or genetic characteristics, criminal background, or trade union membership.  

At the end of the applicable retention period, we will remove your Personal Data from our databases and will require that our Business Partners remove any identifiable Personal Data from their databases. If there is any data that we are unable to delete entirely from our systems for technical reasons, we will put in place appropriate measures to prevent any further processing of such data. Please note that once we disclose your Personal Data to third parties, we may not be able to access that Personal Data and we cannot force the deletion or modification of such information by third parties. 

What Happens to Personal Data Submitted by Minors? 

Legacy Health Strategies does not knowingly collect Personal Data from individuals under the age of eighteen (18). Additionally, our Website is not directed to individuals under the age of eighteen (18). We request that these individuals not provide Personal Data to us. If we learn that Personal Data from users under the age of eighteen (18) has been collected, we will take reasonable measures to promptly delete such data from our records. If you are aware of a user under the age of eighteen (18) accessing the Website, please contact us at privacy@legacyhealthstrategies.com. Please allow up to thirty (30) days for a response.  

If you are a resident of California under the age of eighteen (18) and have disclosed Personal Data to us, you may ask us to remove content or information that you have submitted through or to our Website.   

User Rights

What Rights Do Users Have Concerning Their Personal Data? 

As a user of Legacy Health Strategies’ Website, you have certain rights relating to your Personal Data. These rights are subject to local data protection and privacy laws, and may include the right to: 

  • Access Personal Data held by Legacy Health Strategies;  
  • Erase/delete your Personal Data, to the extent permitted by applicable data protection and privacy laws and to the extent technologically feasible;  
  • Receive communications related to the processing of your Personal Data;  
  • Restrict or object to the processing of your Personal Data to the extent permitted by law;  
  • Request that your Personal Data be transferred to a third party, if possible; and/or 
  • Rectify inaccurate personal information and ensure it is complete.  

To exercise any of the above rights, please contact us at privacy@legacyhealthstrategies.com.  

How Can Users Update, Correct, or Delete Personal Data?  

You have the right to request restrictions on the uses and disclosures of your Personal Data. While we are not required to agree to all restriction requests, we will attempt to accommodate reasonable requests when appropriate.  If you need to make changes or corrections to Personal Data, or if you wish to request deletion of your Personal Data, you may contact us at privacy@legacyhealthstrategies.com

PROTECTION OF PERSONAL DATA

Is Personal Data Secure? 

Legacy Health Strategies understands the importance of data confidentiality and security. We use a combination of reasonable physical, technical, and administrative security controls to: (i) maintain the security and integrity of your Personal Data; (ii) protect against any threats or hazards to the security or integrity of your Personal Data; and (iii) protect against unauthorized access to or use of such information in our possession or control that could result in substantial harm to you.  

While Legacy Health Strategies uses reasonable security controls, WE CANNOT GUARANTEE OR WARRANT THAT SUCH TECHNIQUES WILL PREVENT UNAUTHORIZED ACCESS TO YOUR PERSONAL DATA. YOU ASSUME THE RISK THAT UNAUTHORIZED ENTRY OR USE, HARDWARE OR SOFTWARE FAILURE, AND OTHER FACTORS MAY COMPROMISE THE SECURITY OF YOUR PERSONAL DATA AT ANY TIME.  

What If Legacy Health Strategies Experiences a Data or Security Breach? 

If Legacy Health Strategies experiences a data or security breach, we will promptly investigate the security incident and notify you of any data or security breaches as required by and in accordance with applicable law.  

CALIFORNIA PRIVACY RIGHTS

Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask for and obtain from us an annual list identifying the categories of personal customer information which we shared, if any, with our affiliates and/or third parties in the preceding calendar year for marketing purposes. This list will be provided free of charge. Contact information for such affiliates and/or third parties must be included. If you are a California resident and would like a copy of this notice, please submit a written request to the following address:  

Legacy Health Strategies 
3840 Via de la Valle, Suite 100 

Del Mar, CA 92014