Last revised May 1, 2023
3. Information we collect about you and how we collect it.
We collect different types of information about you, including information that may identify you either directly or when combined with other information, information that is about you but does not identify you, and information that we combine with information about our other users.
Examples of the types of information we collect from and about users of our Digital Services:
- information that is about you as a person, such as, where relevant to the Digital Services, name, address (e.g., home, office, billing), date of birth, gender, contact information (e.g., e-mail, phone), professional information (e.g., if you are a Clinician, including license information and NPI number), insurance information, medical history, and other health information or other information supplied by you; and
- information that is about your usage of the Digital Services, including:
- technical information, such as IP address data, traffic data, logs, referring/exit pages, date and time of your visit to or use of our Digital Services, error information, clickstream data, session recordings, location data, and other communication and interaction data and the resources and equipment (e.g., device, browser and other software information, operating system, Internet connection) that you access and use on or through our Digital Services; and
- interaction information, such as information you provide when communicating to us (e.g., including to request a service or report a problem), information about the resources, content, materials, information, and other aspects of the Digital Services that you request or access, information about how you access and use the Digital Services (e.g., information and documentation about how you navigate and use the Digital Services, such as session recordings), and records and copies of your correspondence and other interactions with the Digital Services.
We collect this information:
- directly from you when you provide it to us, such as through e-mail, phone calls, text messages, website forms, and our webchat function on our Digital Services, including via the use of third party applications, services, and products that we integrate into our Digital Services;
- automatically as you navigate through or use our Digital Services; and
- from third parties, for example, our clients, service providers, and business partners.
In addition to collecting data directly from you, we also use the following technologies in connection with our Digital Services:
- Analytics Providers. We and our service providers and clients may use analytics service providers, including Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Digital Services. Google Analytics also utilizes cookies for this purpose. You can find out more about how Google uses data directly from Google, for instance on Google’s website. We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity.
- Pixels and Tags. We and our service providers and clients may use pixels, tags, and similar technologies (i) to help identify what users do after they see or click on an element of our Digital Services and/or an advertisement or other content prior to reaching our Digital Services; (ii) identify users who interact with our Digital Services from different devices; (iii) connect users’ activities across platforms and devices, including enabling online to offline activity connections; and (iv) better understand the effectiveness of our Digital Services and our clients’ and partners’ user initiatives, and improve the content (including advertisements) provided to targeted audiences of interest to us, our clients, and our business partners. Examples of these technologies including (a) Facebook’s pixel and Instagram’s web analytics and advertising service, both provided by Meta Platforms, Inc. (“Meta”) and (b) Adstra tag and matching services provided by Adstra, LLC (“Adstra”). Data provided to Meta, Adstra, and other service providers in connection with your use of the Digital Services is saved and processed by those third parties, and may be used for their own and others’ purposes in accordance with those companies’ policies and applicable laws. For more information, including how to adjust your privacy preferences or exercise your privacy rights with those companies, please visit their websites direction (e.g., Meta’s privacy center; Adstra’s privacy center).
4. How we use your information.
We may use information that we collect about you or that you provide to us to:
- provide you with the Digital Services, including our Website and our other products and services;
- provide you with other information, products, or services that you request from us or that we believe may be of interest to you;
- provide services, including Digital Services, to and on behalf of our clients;
- administer surveys, sweepstakes, promotions, and contests;
- develop, support, maintain, secure, audit, review, and improve our Digital Services and other products and services that we may develop from time to time;
- fulfill any other purpose for which you provide such information or otherwise consent to, including as we may describe to you when you provide the information;
- for recruiting and human resources purposes, in particular with respect to candidates who interact with us through our Website or other Digital Services;
- carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
- notify you about changes to our Digital Services or any products or services we offer or provide though them;
- analyze data and information about the provision, use, activity, and performance of our Digital Services and any other products and services, including those that we may develop or provide in the future, as well as of their users, including you;
- create Information Assets (as described below) and provide access, sell, disclose, and otherwise use them and related analytics products and services as described above, in whole or in part, including to our clients and other partners as part of the services we offer to them;
- protect the safety, health, rights, property, or security of Ostro, our users, employees and workforce members, third parties, members of the public, and/or the Digital Services.
- communicate with you about any of the above, including to provide you with notices relevant to your use of or changes in the Digital Services and to respond to your requests of us;
5. Disclosure of your information.
We may disclose your information in any of the following circumstances:
- to our affiliates, contractors, service providers, and other third parties in connection with our business. The services provided by these organizations include:
- IT and infrastructure support services;
- information and cybersecurity services;
- payment processing services;
- data analytics services;
- information, product marketing, or content fulfillment services;
- patient safety, including adverse event or adverse reaction reporting services, including on behalf of our clients;
- internal infrastructure and support services, including communications, product development, user support, and quality assurance;
- recruiting and human resources support services; and
- targeted communications and marketing to you, including regarding products and services that our clients or their partners believe that you may find of interest.
- to a buyer or other successor in interest of our business in the event of an actual or contemplated merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which user information is among the assets subject to such transaction or otherwise part of the due diligence of such a transaction;
- to fulfill the purpose for which you provide it;
- for any other purpose disclosed by us when you provide the information; and
- with your consent.
We may also disclose your information:
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- to you or your designated agent to allow you to exercise your individual choices under applicable laws with respect to your data;
- to third parties to market their products or services to you;
- however, data obtained through the SMS short code program will not be shared with any third-parties for their marketing reasons/purposes; and
- the foregoing limitation does not apply to sharing with our customers and clients on whose behalf we may send SMS communications as part of the SMS short code program.
- if we believe disclosure is necessary or appropriate to protect the security, health, rights, property, or safety of us, our clients, our users, any member of the public, or others. This includes exchanging information with government agencies and authorities, other companies and organizations for the purposes of fraud protection, information security, credit risk reduction, health and safety, and other lawful purposes.
6. Use and disclosure of deidentified and/or aggregated information.
We collect and create information assets (“Information Assets”) from a variety of sources, including information about and generated by your use of our Digital Services. We may use these Information Assets for any lawful purpose, including to share, sell, or otherwise disclose to our clients and business partners, to support, develop, improve, and enhance our Digital Services and other products and services, and to perform quality assurance and other security testing and monitoring with respect to our Digital Services and our business.
7. Choices about how we use and disclose your information.
In addition, we strive to provide you with choices regarding the information that you provide to us. This includes the following mechanisms:
- Tracking technologies. On your device, you may be able to choose to be alerted and/or to refuse to accept some or all cookies or other tracking technologies by activating the appropriate setting in your browser and/or device settings. However, refusing these technologies, including cookies, may cause certain parts of our Digital Services to be unavailable to you or to not work as intended.
Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, while you can disable cookies and/or other tracking technologies as described above, we do not honor or recognize when your browser sends “do not track” signals. We do not modify what information we collect or how we use that information based on whether such a signal is broadcast or received by us.
- Email communications. By providing your e-mail address, you are agreeing to be contacted by or on behalf of Ostro at the address you have provided to receive informational, transactional, product or service related, or marketing communications relating to the Digital Services. If you do not wish to have your e-mail address used by us to communicate with you, with respect to marketing or promotional communications, if any, you can opt-out at any time by clicking the unsubscribe link at the bottom of any e-mail or by contacting us at firstname.lastname@example.org. Please note that this opt out does not apply to transactional communications between you and us regarding your use of the Digital Services. For such communications, you may access your User Account (described below) or contact us at email@example.com to update your communications settings, including your e-mail address. Please be advised, however, that some Digital Services will not operate fully or as intended if we are unable to communicate with you and we may be restricted by applicable law from disabling certain communications.
- User account settings. For some Digital Services, you may have created a user account (“User Account”) to allow you to access information, communicate with us, and otherwise access and use certain features of the Digital Services that are available only to registered users. If you have created a User Account, you may also adjust certain communication and privacy preferences and settings directly via your User Account.
8. Your choices regarding your information.
As a user, you may contact us to ask us to identify what information we have about you, and to correct that information if it is inaccurate, or to ask us to delete that information. If you have created a User Account, you may also be able to make and/or carry out such requests directly via your User Account.
Please understand that, in some instances, we may not be able to accommodate your request, including because:
- of the way we collect and process your information, including our application of the data minimization principle where appropriate, which may result in our having information about you that is not identified with you;
- we believe it would violate Privacy Laws or another legal requirement or cause the information to be incorrect; and/or
- your request falls within a specific exception under Privacy Laws.
In situations where we are unable to accommodate your request but we believe that a third party may be able to, such as where we act as a service provider to one of our clients, we may share your request with such third party so that they may review and, if appropriate, accommodate your request.
Finally, we may ask you for additional information in order to better understand and validate your request, including information as reasonably necessary and permitted by Privacy Laws to verify your identity and your right to access and take action with respect to the requested information.
9. Information security.
We have implemented measures designed to secure your information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology, multifactor authorization, and various authentication and identity management tools to safeguard the information sent and received by us.
The safety and security of your information also depends on you. Where you have chosen a password for the use of our Digital Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. If you believe that your password may have been compromised please access your User Account and reset it immediately. If you believe that your information may have been compromised or misused, please contact us immediately at firstname.lastname@example.org.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your information, we cannot guarantee the security of your information when it is transmitted to, on, or through our Digital Services or otherwise disclosed to us. Any transmission or disclosure of your information is at your own risk.
10. No medical advice or care.
Ostro is not a medical group. We do not provide medical advice or care. Information communicated to you through our Digital Services is not a substitute for a discussion with a licensed medical practitioner and should never be applied or interpreted as medical advice or any form of personal treatment plan.
11. Not intended for children.
13. Ethical conduct.
We pride ourselves on ethically empowering people like you to navigate their health. If you see or suspect any unethical or illegal activity of any kind in connection with the Digital Services we would appreciate it if you would report it to us immediately so that we may promptly investigate. Please contact us at email@example.com.
14. Contact us.
How to Contact Us:
382 NE 191st St
Miami, Florida 33179-3899