Privacy Policy

Last updated on August 21, 2023

This Privacy Policy applies to any website, application, feature, widget or other online service that is owned or controlled by Spacial Health Inc., its parent company (Hoberman Rockets LLC), subsidiaries and affiliated companies (collectively “Spacial,” “we” or “us”), that posts a link to this Privacy Policy (collectively, the “Websites,” each a “Website”) (and by Spacial offline, unless expressly governed by a different privacy policy you are provided notice of). For the purposes of this Privacy Policy, "you" and "your" means you as the visitor of the Websites.

By accessing, using, or otherwise interacting with any part of our Websites, or by otherwise providing personal information to Spacial, you agree to be bound by the terms of this Privacy Policy and the applicable Terms of Use which govern your use of any Website. IF YOU DO NOT AGREE TO THE TERMS OF THIS PRIVACY POLICY AND THE APPLICABLE TERMS OF USE, DO NOT ACCESS OR USE THE WEBSITES OR PROVIDE PERSONAL INFORMATION TO US THROUGH ANY WEBSITES.

Scope of this Privacy Policy

This Privacy Policy describes the types of Personal Information we collect from visitors of our public Websites and our practices for using, maintaining, sharing, and protecting it. It also describes the rights and choices you may have with respect to your Personal Information and how you may contact us.

This Privacy Policy does not apply to information collected from visitors who register and log-in ("Members") to the password-protected and secure portions of our Websites, including login pages and registration pages ("Secure Platforms"). The Secure Platforms allow eligible Members to use Spacial services. All information collected and stored by Spacial or added by our Members (or independent healthcare professionals on their behalf) into such Secure Platforms is considered Protected Health Information ("PHI") and/or medical information and is governed by laws that apply to that information, for example the Health Insurance Portability and Accountability Act (HIPAA). The independent healthcare professionals who deliver healthcare services through Spacial are typically covered entities under HIPAA, and Spacial operates as a business associate of such covered entities under the terms of a business associate agreement in compliance with applicable law. How Spacial and the independent healthcare professionals who deliver health care services through Spacial use and disclose such PHI is in accordance with the Spacial Healthcare Professionals Notice of Privacy Practices [live link]. Spacial will not use or disclose PHI for advertising, marketing, or other use-based data mining purposes and will not combine it with other data and will not sell it. The Spacial Healthcare Professionals Notice of Privacy Practices (and not this Privacy Policy) also applies to Personal Information collected on our Websites if such information constitutes PHI under HIPAA.

This Privacy Policy also does not apply to the collection and use of certain employment-related information. If you are a current or former Spacial job applicant, employee, owner, director, officer, or contractor, please contact us at privacy@spacialhealthcare.com for the appropriate notice.

1. TYPES OF PERSONAL INFORMATION WE COLLECT

While using our Websites, you may provide us with certain information about you. We or our advertising partners also may automatically collect information through the use of cookies and other tracking technologies (see below).

Some of the information we collect is “Personal Information”, which we consider to be information that is linked to a specific, identifiable individual (such as your full name and email address). We will treat other information, such as IP addresses and cookie identifiers, as “Personal Information” where required by applicable law and we will treat certain Personal Information as “sensitive personal information” as required by applicable law.

Personal Information that we collect through your use of the Websites may include IP Address, device ID, and online identifier. We may use that Personal Information and link it to Internet or other electronic network activity information, and we may draw inferences about you from the information we collect. We may also collect your name, title, personal and business contact information, phone number, date of birth, state, country, zip code, your health plan, email address or login identification information only if you provide such information directly to us when you begin registration to use a Secure Platform or complete a web form or send an email seeking more information. If you are a Member such information may be considered PHI and governed by our Spacial Healthcare Professionals Notice of Privacy Practices.

Note that we may de-identify or pseudonymize your Personal Information so as to make it non-personal, either by combining it with information about other individuals and/or by hashing the information or otherwise removing characteristics that make the information personally identifiable to you. We will treat de-identified or pseudonymized information as non-personal to the fullest extent allowed by applicable law. We maintain and use de-identified information without attempting to re-identify it, except where permitted by applicable law, such as to determine whether our de-identification processes satisfy legal requirements. If we combine non-personal information with personal information, then we will treat the combined data as Personal Information under this Privacy Policy. We may share non-personal information with third parties for any purpose in our discretion and as permitted by law, including for advertising, research and marketing purposes.

2. HOW WE COLLECT PERSONAL INFORMATION

We may collect Personal Information using the following methods:

• Directly from you when you provide it to us (such as information you enter into web forms, emails, inquiries, responses, activity on the Websites, and during registration to use a Secure Platform). We may also collect Personal Information from you through Social Features as described below.
• Automatically through tracking technologies such as cookies, web beacons (also known as pixels) and log files, including over time and across our own and third-party websites or other online services.
• From third parties, such as analytics and email marketing service providers, data aggregators, affiliate programs and other service providers.

Cookies: "Cookies" are small files that a website stores on a user's computer or device. The Websites may use cookies for various purposes, including to keep the information you enter on multiple pages together. Some of the cookies we use are "session" cookies, meaning that they are automatically deleted from your hard drive after you close your browser at the end of your session. Session cookies are used to optimize performance of the Websites and to limit the amount of redundant data that is downloaded during a single session. We also may use "persistent" cookies, which remain on your computer or device unless deleted by you (or by your browser settings). We may use persistent cookies for various purposes, such as statistical analysis of performance to ensure the ongoing quality of our services. We and third parties may use session and persistent cookies for analytics and advertising purposes, as described herein. Most web browsers automatically accept cookies, but you may set your browser to block certain cookies (see below). As required under applicable laws, we will obtain your consent necessary for utilizing cookies or similar tracking technologies.

Web Beacons: Small graphic images or other web programming code called web beacons (also known as “pixel tags,” “1x1 GIFs,” or “clear GIFs”) may be included in our web pages and email messages. Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a web page or email can act as a web beacon. Web beacons or similar technologies may be used for several purposes, including, without limitation, to count visitors to a Website, to monitor how users navigate the Website, to count how many emails that were sent were opened or to count how many particular links were actually viewed.

Embedded Scripts: An embedded script is programming code that is designed to collect data about your interactions with the Websites, such as the links you click on. The code is temporarily downloaded onto your device from our server or a third-party service provider, is active only when you are connected to a Website and is deactivated or deleted thereafter.

Data Collection from Mobile Devices: We use embedded scripts and similar tools to collect data from mobile devices such as the hardware model, operating system and version, identification numbers assigned to your mobile device, such as the ID for Advertising (IDFA) on Apple devices, and the Advertising ID on Android devices, mobile network information, and website usage behavior. In addition, we may use a variety of other technologies that collect similar device and device interaction information for security, fraud detection, and maintenance purposes.

Session Replay Technology: We may record through session replay technology your interactions with the Websites, such as what pages you visit on the Websites, how long you visit those pages, and any links you click or information you provide. We use this data for our internal business purposes, such as for website analytics, to improve the Websites and our products and services, and to address functionality issues.

We may also use a variety of other technologies that collect similar data for security, fraud detection, site functionality and operational and maintenance purposes.

We use Google Analytics, which use cookies and similar technologies to collect and analyze information about the use of the Websites and report on activities and trends. This service may also collect information about the use of other websites, apps, and online services. You can learn about Google's practices, and opt out of them by downloading the Google Analytics opt-out browser add-on.

For more information about how we use Personal Information collected through tracking technologies and the ways you may be able to manage it, see below.

3. HOW WE USE YOUR INFORMATION

We may use your Personal Information for the following purposes:

• Operate, maintain, supervise, administer, and enhance the Websites, including monitoring and analyzing the effectiveness of content on the Websites, aggregate site usage data, and other usage of the Websites such as checking your eligibility and assisting you in completing the registration process.
• Provide you with a tailored and user-friendly experience as you navigate our Websites.
• Promote and market our Websites to you, including for contests and sweepstakes.
• To complete the activity you specifically asked for, e.g., register on a Secure Platform, obtain more information, request a demo, or respond to RFPs.
• Conduct research on users' demographics, interests, and behavior based upon information provided during use of our Websites.
• Aggregate information for analytics and reporting.
• Respond to law enforcement requests and court orders and legal process and carry out our legal and contractual obligations and enforce our rights.
• Authenticate use, detect potential fraudulent use, and otherwise maintain the security of the Websites and safety of users.
• Develop, test, improve, and demonstrate the Websites.
• Business Transitions (in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, including during due diligence)
• Any other purpose notified to you at collection or with your consent.

4. HOW WE SHARE YOUR INFORMATION

We may share Personal Information with third parties including service providers in certain circumstances or for certain purposes, including:

• For business purposes. We may share your Personal Information with vendors and service providers, including our data hosting and data storage partners, analytics and advertising providers, technology services and support, and data security. We also may share Personal Information with professional advisors, such as auditors, law firms, and accounting firms. We may disclose your name, email address, date of birth, phone number, and address if you provided it to us via a form on a Website or during an incomplete or failed registration to service providers.
• With your direction or consent. We may share your Personal Information with third parties if you request or direct us to do so. This includes your use of social media widgets on our Websites.
• With affiliates within our corporate group. We may share your Personal Information with any subsidiaries or affiliates within our corporate group.
• Compliance with law. We may share your Personal Information to comply with applicable law or any obligations thereunder, including cooperation with law enforcement, judicial orders, and regulatory inquiries.
• In the context of a transaction. We may share your Personal Information in connection with a merger, acquisition, consolidation, bankruptcy, or other corporate transition, including during due diligence.
• For other business reasons. We may share your Personal Information to enforce any applicable Terms of Use, and to ensure the safety and security of the Websites and/or our users.
• For advertising. Using cookies and web beacons, we may disclose Personal Information regarding your activity on our Websites to third-party advertising partners to optimize marketing. See Section 7 for additional details.

We also may disclose deidentified information. Note that if you make any Personal Information publicly available on the Websites, anyone may see and use such information.

5. SOCIAL FEATURES

Certain features of the Websites permit you to initiate interactions between the Websites and third-party services or platforms, such as social networks ("Social Features"). Social Features include features that allow you to click and access Spacial's pages on certain third-party platforms, such as Facebook, Instagram, Twitter and LinkedIn as applicable, and from there to "like" or "share" our content on those platforms. Use of Social Features may entail a third party's collection and/or use of your data. If you use Social Features or similar third-party services, information you post or otherwise make accessible may be publicly displayed by the third-party service you are using. Both Spacial and the third party may have access to information about you and your use of both the Websites and the third-party service. Spacial has no control over and is not responsible for the privacy practices of such third parties. This Privacy Policy does not apply to the extent Spacial does not own or control any linked websites or features you visit or use. We recommend that you familiarize yourself with the privacy practices of those third parties.

6. THIRD PARTY WEBSITES AND LINKS

Our Websites may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your information. Information you provide on public or semi-public venues, including information you share on third-party social networking platforms (such as Facebook, Instagram, LinkedIn or Twitter) may also be viewable by other users of the Websites and/or users of those third-party online platforms without limitation as to its use by us or by a third party. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Websites. We expressly disclaim any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of Personal Information by third parties. Any information submitted by you directly to these third parties is subject to that third party's privacy policy.

7. COOKIES AND INFORMATION USED FOR ADVERTISING

As discussed above, on our Websites we may collect and disclose Personal Information about your online activities for use in providing you with advertising about products and services tailored to your individual interests. This section of our Privacy Policy provides details and explains how to exercise your choices. You may see certain ads on other websites because we participate in advertising networks. Ad networks allow us to target our messaging to users through demographic, interest-based and contextual means. These networks track your online activities over time by collecting information through automated means, including through the use of cookies, web server logs, and web beacons (also known as pixels). The networks use this information to show you advertisements that may be tailored to your individual interests. The information our ad networks may collect includes information about your visits to websites that participate in the relevant advertising networks, such as the webpages or advertisements you view and the actions you take on the websites. This data collection takes place both on our Websites and on third-party websites that participate in the ad networks. This process also helps us track the effectiveness of our marketing efforts.

You may disable or delete browser cookies through your browser settings. Cookies generally are easy to disable or delete, but the method varies between browsers. If you disable or delete cookies, or if you are running third-party software that intercepts or deletes cookies, please note that some parts or functionality of our Websites may not work properly.

Each type of web browser offers ways to restrict and delete cookies. For more information on how to manage cookies visit the appropriate link below.

Microsoft Internet Explorer
Microsoft Edge
Mozilla Firefox
Google Chrome
Apple Safari

You can opt out of third parties collecting your Personal Information for targeted advertising purposes in the United States by visiting the National Advertising Initiative's (NAI) opt-out page and the Digital Advertising Alliance's (DAA) opt-out page.

Your browser settings also may allow you to transmit a "Do Not Track" signal when you visit various websites. Some of the Websites may not be configured to respond to "Do Not Track" signals received from browsers. To learn more about "Do Not Track" signals, you can visit here.

If you have further questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.

8. CHILDREN'S PRIVACY

Our Websites are not intended for children under 13 years of age, and we do not knowingly collect or sell Personal Information from children under 13. If you are under 13, do not use or provide any information on these Websites without your parent first providing consent. If you are the parent or guardian of a child under 13 years of age whom you believe might have provided us with their Personal Information, you may contact us using the below information to request that it be deleted.

9. SECURITY OF PERSONAL INFORMATION

We take steps to secure Personal Information through appropriate administrative, technical, and physical safeguards designed to protect against the risk of its accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use. Unfortunately, we cannot guarantee the security of information transmitted through the Internet, and where we have given you (or where you have chosen) a password, you are responsible for keeping this password confidential.

10. RETENTION OF PERSONAL INFORMATION

We generally retain records only as long as necessary and as required for our business operations, for archival purposes, and/or to satisfy legal requirements and otherwise as reasonably necessary for the purposes set out in this Privacy Policy. When determining the appropriate retention period for Personal Information, we take into account various criteria, such as the amount, nature, and sensitivity of the Personal Information; potential risk of harm from unauthorized use or disclosure; purposes for which we process your Personal Information; whether we can achieve those purposes through other means; and business operations and legal requirements. Because we maintain our Websites to protect information from accidental or malicious loss and destruction, residual copies of your Personal Information may be retained in our backup and archival systems for a limited period of time, after which the information will be automatically deleted or, where deletion is not feasible, protected from further processing.

11. INTERNATIONAL USERS

The Websites are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any information you provide to us through use of our Websites may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of personal information as the one in which you reside. However, we will handle your Personal Information in accordance with this Privacy Policy regardless of where your Personal Information is stored/accessed.

12. YOUR CHOICES WITH RESPECT TO PERSONAL INFORMATION

As described above, you may adjust browser settings or take other measures to limit the information we or third parties collect automatically, although such measures may adversely impact the functionality of our Websites. You may opt out of marketing communications and request correction or deletion of Personal Information as set forth below. 

Email Marketing.  You may unsubscribe from any marketing email we may send you through the opt-out mechanism included in each such email, or you can communicate your preferences to us by emailing us at privacy@spacialhealthcare.com.  We reserve the right to send you certain communications relating to your use of the Websites or Spacial services, service announcements, notices of changes to this Privacy Policy or other terms, or similar administrative or transactional messages, and such messages will be unaffected by any choice to opt out of marketing communications. 

Correction and Deletion. If you are registered with or have an account with Spacial you may have the ability to access, correct or delete certain information through such registration or account. You may also request correction or deletion of your information by contacting us at privacy@spacialhealthcare.com or by mail as provided in the "How to Contact Us" section below. Please identify yourself in any such communication and provide a reasonably detailed description of your request. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you in order to protect against fraudulent requests.

13. UPDATING THIS PRIVACY POLICY

This Privacy Policy may be updated periodically to reflect changes in our privacy practices. It is your responsibility to review the Privacy Policy from time to time to view any such changes.

14. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Policy, please email us at privacy@spacialhealthcare.com or contact us at:

Spacial Health Inc.‍

‍3000 Royal Court, Unit 3308‍

‍North Hills, NY 11040‍

‍Attn: Data Privacy