Privacy Policy
Date Effective
September 1st 2023
Introduction
This Privacy Policy describes how Anterior, Inc. ("Anterior," "we", "us" or "our") handles personal information that we collect through:
- websites we operate that link to this Privacy Policy, including our site at co-helm.com (collectively, the “Website”), with respect to website visitors;
- our web-based application available at platform.co-helm.com (“Application”), with respect to the Application’s end users; and
- our marketing and other activities described in this Privacy Policy, with respect to current and prospective customers.
This Privacy Policy refers to our Website and Application, collectively, as the Service.
What this Privacy Policy does not cover. When providing the Application to our health plan customers, we process certain personal information on their behalf, including protected health information subject to the Health Insurance Portability and Accountability Act (HIPAA). This Privacy Policy does not apply to our processing of this information on behalf of those customers, which is restricted by our agreements with them. For information about how our health plan customers handle this information, you should consult the relevant health plan’s privacy notice or contact the health plan.
The Service is designed for health plans and is not intended for use by individuals for personal, family, or household purposes or to collect personal information for those purposes.
Personal information we collect
Information you provide to us. You may provide us with the following categories of personal information:
- Contact data. Your first and last name, email address, mailing addresses, professional title and company name, phone number and other contact details.
- Account data. Information you provide to create a Anterior account, including your name, company name and email.
- Profile data. Your name and other information you chose to add to your Application profile.
- User posts. Comments and other content you post to the Service.
- Communication data. The contents of your communications with us, whether through the Service, social media, events, or otherwise, including any feedback you provide about the Service and your responses to surveys.
If you provide other categories of personal information not listed above, we will use it as described in this Privacy Policy or as otherwise explained at the time of collection.
Automatic data collection. We and our service providers may automatically log the following information about you, your computer or mobile device, and your interaction over time with the Service and our communications:
- Device data. Your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 3G), and general location information associated with your IP address, such as your city/town.
- Online activity data. The pages you viewed, how long you spent on a page, the website you visited before browsing to the Service, navigation paths between pages, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
Cookies and similar technologies. The following technologies facilitate some of the automatic collection described above:
- Cookies. These are small data files that are placed on your computer or mobile device when you visit a website to help website operators understand site traffic and use, help you navigate between pages efficiently, remember your preferences, and generally improving your browsing experience. Cookies used on our Website include cookies that we serve as well as cookies served by third party vendors that we work with to enable the services they provide, such as website analytics services that track site traffic and usage. You can learn more about cookies and how to control them at www.allaboutcookies.org and you can set preferences for which cookies you wish to remove or reject in your browser.
- Browser web storage. Browser web storage (including via HTML5), also known as locally stored objects, function like cookies but enables the storage of a larger amount of data. Your web browser may provide functionality to clear your browser web storage.
- Pixels. We may use pixels (also known as web beacons and clear GIFs) on our Website and in our HTML formatted emails to track the actions of users on our sites and interactions with our emails, such as when an email was opened. Pixels are embedded invisibly in image files within webpages or HTML formatted emails. Most browsers and devices allow you to configure your device to prevent images and any pixels embedded in them from loading.
If you do block or reject these technologies, certain areas or features of the Service may not work or be accessible.
Third-party sources. We may combine personal information we receive from you or collect automatically when you use the Service with personal information we obtain from other sources, such as:
- social media platforms, company website bios and other publicly available websites;
- our business contacts who share details about their professional contacts, including potential customers and partners; and
- data brokers who provide contact details about potential customers and help us keep the contact details in our marketing database up to date.
How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and business operations. To provide and communicate with you about the Service, including through support and administrative communications, and to operate our business (including through IT operations and maintenance).
Marketing. To send you direct marketing communications. You may opt-out of our marketing communications as described in the Opt-out of marketing communications section below.
Research and development. For research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified and/or anonymized data from personal information we collect. We make personal information into de-identified or anonymized data by removing information that makes the data personally identifiable to you. We may use this aggregated, de-identified or otherwise anonymized data and share it with third parties for our lawful business purposes, including to analyze, improve and promote the Service and our business.
Compliance and protection. To comply with applicable laws, lawful requests, and legal process (such as to respond to subpoenas or requests from government authorities), and to protect our, your or others’ rights, privacy, safety, or property (including by making and defending legal claims), including by enforcing the terms and conditions that govern the Service, and taking steps to prevent, investigate and deter fraud, cyberattacks or other unauthorized, unethical, or illegal activity.
How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection.
Affiliates. Our corporate affiliates that we control, are controlled by, or with which we are under common control, for purposes consistent with this Privacy Policy.
Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as hosting, information technology, customer support, email delivery, marketing, customer research, analytics, artificial intelligence, chatbot functionality, cybersecurity).
Other Application users. Other Application users from your organization or team will be able to see any comments or other content that you chose to post to the Application, as well as your Application profile.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.
Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
Business transferees. Parties (and their advisors) to business transactions (and negotiations and due diligence preceding such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Anterior or our affiliates (including, in connection with a bankruptcy or similar proceedings).
Your choices
Access or update your information. You may review and update certain Anterior account information within your account.
Opt-out of marketing. You may opt-out of marketing emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. Please note that if you opt-out of promotional emails, you may continue to receive service-related and other non-marketing emails.
Cookies. The settings of most browsers let you remove or reject cookies. See the cookies and similar technologies section above for more information about your choices.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Other sites and services
The Service may link to or integrate with websites and other online services operated by third parties. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links and integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites or other online services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and online services you use.
Security
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies, and we cannot guarantee the security of your personal information.
International data transfers
We are headquartered in the United States and may use service providers that operate in the United States and other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.
Children
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a child from whom you believe we have collected personal information in a manner prohibited by law, please contact us. If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Privacy Policy indicates your acknowledgment that the modified Privacy Policy applies to your interactions with the Service and our business.
How to contact us
If you have questions or concerns about this Privacy Policy or our practices, please contact us at compliance@co-helm.com.