PLEASE READ THIS POLICY CAREFULLY BEFORE USING THE KINSA SERVICES.

You must be 16 years or older to use our services.

Protecting your data, privacy and personal information is important to Kinsa Inc. and our affiliates (“Kinsa”, “us”, “we”, or “our”). At Kinsa, we strongly believe that companies have a social responsibility to help society; provided that they can do so without sacrificing user privacy. We believe that the spread of illness is one of the biggest problems the world faces, and to stop it, we must know where and when it is starting. We believe that fully anonymized illness data should be used to benefit society, and that personally identifiable information should not be used without a user’s permission and ongoing awareness.

This privacy policy (“Privacy Policy”), together with our Terms of Use and Conditions, represents Kinsa’s privacy practices as it pertains to our websites, smart thermometers (“Smart Thermometers”), mobile applications, and any other online services Kinsa may provide (collectively, the “Services”).  Please read this Privacy Policy carefully. By accepting this Privacy Policy or otherwise accessing, visiting or using the Services, you acknowledge and consent to the data collection and use practices described in this Privacy Policy.

When using Kinsa Services, you will be asked to acknowledge and, where appropriate, to give consent to the practices laid out in this policy.  

If you are providing personal information about another individual, please make sure you have their consent to provide such information.

About Us

Kinsa’s Smart Thermometers are regulated as class II medical devices by the U.S. Food and Drug Administration (FDA). Kinsa’s Smart Thermometers are intended to measure human body temperature and are reusable for clinical or home use on individuals of all ages. Kinsa also develops and shares population health insights (for example, the percent of people in a county who are ill) which are aggregated from data collected by our Services.

All personal information obtained and maintained by Kinsa will be in compliance with applicable state and federal laws and regulations governing the security and confidentiality of such information.

Information Collected or Received

Kinsa aims to collect the least amount of personal information needed for specified, explicit and legitimate purposes. In operating our Services, we may collect and process the following types of information about you:

DATA WHEN (examples) WHY
Device information and product usage data such as traffic data, IP address, device ID, cookies, or which pages you viewed or features you interacted with When you use our Services To help identify and troubleshoot any technical or performance issues; to provide a seamless experience for users across sessions
Health data such as temperature, symptoms, medications taken, diagnosis, time of incidence of the illness or symptoms, or treatment seeking behavior When you use a Kinsa Smart Thermometer or enter information into our Services To allow you to track your health history over time and to provide personalized illness guidance; to aggregate geographic illness trends; to use, solely in de-identifiable form, for research purposes
Account information such as e-mail address, username, or password When you sign up to use our Services  To allow you to back up your data and access it on multiple devices; to communicate with you
Profile information such as birthdate, gender, or name When you create a user profile within the Services To provide personalized illness guidance and a customized app experience
Geolocation If you permit our Services to access it To enable syncing of readings from the thermometer to the Services; to aggregate geographic illness trends
Relationships to people or places such as which school your child attends or your place of employment If you sign up to participate in specific programs like Kinsa’s FLUency schools program or WellTogether program To manage program logistics such as delivering thermometers; to provide de-identified and aggregate information on the health situation at a certain location
Other information you may provide directly to Kinsa For example, when you fill out forms or if you contact customer support  As necessary to fulfill your request

Use of Personal Information 

Kinsa collects personal information for two primary purposes:

Creating Aggregated Illness Signals: Kinsa uses illness information to help track and curb the spread of disease. In particular we use illness information to generate aggregated “Illness Signals”, which help inform where and when illness is spreading. For example, our Illness Signals may indicate an estimated share of the population in a particular geography (e.g. county, state, etc.) that is sick with influenza-like illness.  We also use de-identified health data for research purposes to better predict and stop the spread of infectious disease. 

Personalizing Your Kinsa Experience: In our Services you can enter or share personal information (e.g. illness history, name, age, gender, location) in order to keep a record of you and/or your family’s health information over time and receive guidance on how severe an illness may be and what to do next. You can also create an account by entering your email address or user identifier, in order to access your data on multiple devices or in the event your device is lost or stolen.

In the event that you receive your Kinsa Smart Thermometer via your employer, health plan, health providers, or educational institution, our Services may recognize that your thermometer is associated with that particular entity and may provide customized guidance and resources. We will not share your health data nor your personal information with such entity without your explicit permission – and then only in limited or specified ways that you consent to.

We may send you communications through push notifications, email, and SMS relating to our products and Services.  You may opt-out of such notifications by changing the settings in the Services or on your device, or otherwise by contacting us as set forth below. In particular, you can opt-out from receiving marketing-related emails by following the unsubscribe instructions provided in each email. If you can sign-in to your Kinsa account, you may be able to change your communication preferences under the relevant section of the Services. 

Additionally, we may use personal information from or about you:

  1. To provide you the Services, respond to your inquiries, and fulfill your requests;
  2. To send you important information regarding our relationship with you or regarding our Services, changes to our terms, conditions, and policies and/or other administrative information; and
  3. For our internal business purposes, such as data analysis, audits, research, developing new products or services, improving our Services, identifying Services usage trends, and determining the effectiveness of our Services.

How we Share or Disclose Information

Kinsa may share user information with third parties in the following scenarios:

  • To our third party service providers (e.g., Mixpanel, Crashlytics, Braze, and Google Analytics) who provide services such as website hosting and moderating, mobile application hosting, data analysis, infrastructure provision, IT services, email services, marketing services, auditing services, and other services, in order to enable them to provide services (one example is that we share email, profile name and age with a third party so that we can send personalized communications to users); 
  • Kinsa may provide research institutions certain de-identified health data for research purposes to better predict and stop the spread of infectious disease (provided that we take reasonable steps to ensure such research institutions cannot personally identify the source of such health data);
  • To a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in connection with any bankruptcy or similar proceedings); 
  • If you opt-in to receiving offers or communications from any of our third-party partners, we will share your name, email, and title (if applicable) with such third-party partner so they may provide you with such offers or communications. We will only share your information with the specific third-party partner(s) you have opted-in for.  We may use this opt-in process with our FLUency school program, in which Kinsa thermometers and software are provided free of charge to participants (which include parents, school nurses and teachers) in an effort to reduce illness levels in school communities.  When you register as part of FLUency under this program you may be given an opportunity to receive certain offers and communications from the sponsoring organization helping us provide this program to the participants; or
  • When we otherwise have your consent.

In addition, we use and disclose personal information collected through the Services as we believe to be necessary or appropriate: (a) as required by applicable law, including laws outside your country of residence; (b) to comply with any legal process; (c) to enforce our Terms of Use; (d) to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or others; and (e) to allow us to pursue available remedies at law. 

How We Secure Your Information

Kina is committed to protecting all data according to applicable laws, regulations and security best practices. We have put in place reasonable and current security methods, including physical, electronic, and managerial procedures designed to prevent misuse, unauthorized access, use, or disclosure of your information.  However Kinsa cannot eliminate all security risks, as mistakes and breaches may happen. Please use the instructions provided below to contact us with any questions.

Your California Privacy Rights 

California law permits California residents to request from us certain information regarding the disclosure of certain categories of personal information to third parties for their direct marketing purposes within the immediately preceding calendar year.  A company may also comply with the law by disclosing in its privacy notice that it provides consumers choice (opt-out or opt-in) regarding sharing personal information with third parties for those third parties’ direct marketing purposes (as we do), and information on how to exercise that choice.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to us via the email address or the mailing address set forth below.  Please put the statement “Your California Privacy Rights” in the subject field of your email or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and zip code. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

California Consumer Privacy Act (CCPA)

To the extent the California law is applicable to our collection of information that identifies or relates to you or your household, you as a user have the following rights:

  • Right to know: Gives the user the right to request disclosure of information collected and shared, and the right to disclosure of categories of information sold by Kinsa. Please use the contact information below for inquiries. 
  • Right to delete: As a user you have the right to delete your user profile and associate personal information (name, email). Please use the contact information below for inquiries. 
  • Right to opt-out: Kinsa does not sell personal information (name, email) to third parties unless the user gives direct permission and consent. Please use the contact information below for inquiries. 
  • Right to nondiscrimination: Kinsa does not use any technology to profile a user or make decisions based on automated detection and data analyzed. Please use the contact information below for inquiries. 

Your Privacy and Our Global Operations

Kinsa operates in multiple jurisdictions. We process data both inside and outside the United States and Europe and we may share your data among service providers based in countries other than your country of residence. Data entered in the Kinsa Services may be transferred to, processed and stored in the United States. 

Safeguards in place to ensure an adequate level of data protection.

Information collected within the European Economic Area and Switzerland (“EU”) may be transferred, processed, or stored outside the EU as described in this Privacy Policy. If we transfer, process, or store personal information from the EU to or in a country outside the EU, we ensure that safeguards are in place to ensure an adequate level of data protection. These safeguards may be based on a determination by the European Commission or Swiss Federal Data Protection and Information Commissioner that a country outside the EU has an adequate level of data protection, or on the use of model contract clauses approved by European Union or Swiss data protection authorities.

Global Data Protection Rights (GDPR)

In the EU, “Personal Data” is defined very broadly and includes any information about a natural person, who can be identified, directly or indirectly, from data that we hold about them or from data that is combined with other information. EU data protection law requires us to have a legal basis before processing any Personal Data about you. The legal basis’ for us processing your Personal Data for the above purposes may be because: (i) you have provided your consent; (ii) it is necessary to for the performance of a contract with you; (iii) the processing is necessary for our compliance with a legal obligation; or (iv) the processing is in our legitimate interests. Under GDPR you have various rights in relation to your personal data (as listed below). All personal data collected, processed and stored by Kinsa requires consent from the user. 

  • Right to know and collect: The user has the right to request a copy of all personal information collected by Kinsa in a format that can be shared with another company. Please use the contact information below for inquiries. 
  • Right to delete: The user has the right to request deletion of their personal data, Kinsa will remove all personal data but under GDPR Article 17 (3) (c) and (d) we will be keeping the aggregated data.
  • Right to update: All users of the Kinsa application have the right to update personal information and profiles within the application. Please use the contact information below for inquiries. 
  • Right to opt-out: Kinsa does not sell any personal information with third parties unless the user gives explicit consent. Please use the contact information below for inquiries.

While we hope that we can resolve any query or concern you raise about our use of your information, the General Data Protection Regulation also gives you right to lodge a complaint with a supervisory authority, in particular in the European Union (or European Economic Area) state where you work, normally live, or where any alleged infringement of data protection laws occurred.

Kinsa’s designated data protection officer informs and advises Kinsa staff how to comply with our obligations, including the assignment of responsibilities, awareness-raising and training of staff involved in processing operations, and related audits.

You may contact Kinsa’s data protection officer regarding any issues related to processing of your personal information and to exercise your rights under applicable law regarding the processing of your personal information.

Contact Information:

ATTN: Data Protection Officer

Kinsa Inc.

535 Mission Street, 18th Floor

San Francisco, CA 94105

dpo@kinsahealth.co 

How We Use Cookies

A “cookie” is a piece of text which asks permission to be placed on your computer’s hard drive. Once you agree, this cookie file is stored on the hard drive of your computer. They help us and our affiliates to improve our Services and ensure that the content from our Services is presented in the most effective manner for you and your computer.

Devices have the ability to decline cookies. This can be done by activating the setting on your browser which enables you to decline the cookies. Please note that should you choose to decline cookies, you may be unable to access particular parts of our Services.

The third parties who distribute or sell our Services may also use cookies, over which we have no control. Such cookies (if used) would be downloaded once you click links from our Services or purchase and/or use our Services through other third party interfaces.

Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information for analytic and internal purposes. The only way to completely opt out of the collection of any information through cookies or other tracking technology is to actively manage the settings on your browser or device to delete and disable cookies and other tracking/recording tools. Please note, depending on your type of device or browser, it may not be possible to delete or disable all tracking mechanisms on your device.

We permit third-party partners to use the foregoing tracking technologies to collect information about your browsing activities over time and across different websites when you use the Services. For example, we may use advertising services provided by third-party ad partners, such as Google, to market our service to you on other websites and online services. Through a process called “retargeting,” each service places a cookie on your browser when you visit the Services so that they can identify you and serve you ads on other sites around the web based on your browsing activity. We use third party analytics packages like Google Analytics and in some cases we share personal information with these services. We, along with third-party vendors such as Google, use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions and other ad service functions as they relate to our Services. To avoid use of this information for these third-party partners, you can change your browser settings to reject cookies or to notify you when cookies are set and you could select the Do Not Track option on your browser, though we have no control over and cannot confirm whether these third-party partners honor the Do Not Track browser signal. Additionally, many advertising companies are members of the NAI or DAA and/or provide opt outs on those industry pages at networkadvertising.org/choices or aboutads.info/choices. Users can set preferences for how Google and other third party advertisements using the Google Ad Settings page.

Links to Third Party Sites

Our Services may contain links to third party websites or services, hosted and operated by a company other than Kinsa. If you follow a link to any of those third-party websites, please note that they have their own privacy policies and that we do not accept any responsibility or liability for their policies or processing of your personal information. Kinsa does not disclose or share personal information with third-party sites without your consent. If you disclose any information to a third-party after following a link to their services, this Privacy Policy no longer applies. 

Compliance

Kinsa will use a self-assessment approach to verify compliance with this Privacy Policy and periodically verify that the Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, implemented, and accessible. If you believe that your personal information has been processed or disclosed in violation of this Privacy Policy, Kinsa encourages you to raise any concerns using the contact information provided in this Privacy Policy. Kinsa will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of personal information.

Your Preferences

Our mobile applications may ask you to share your location information with Kinsa. Note that this is the location reported from your phone’s operating system and typically utilizes your phone’s GPS system. You may opt out of sharing your phone’s location services by changing the settings on your phone.

If you do not want to receive communications from Kinsa, you may opt out of further communications at any time. Please note that Kinsa can only comply with requests relating to communications provided by Kinsa. We will seek to comply with your request(s) as soon as reasonably practicable.

If applicable, and you would like to review, correct, update, or delete certain personal information that you have provided via the Services, please contact us. We will seek to comply with your request as soon as reasonably practicable.

Minors

Our Services are designed and intended for those who have reached 16 years of age. By using our Services, you affirm that you are at least 16 years of age or older. No one under age 16 is authorized to submit or post any information, including personal information, on our Services. Parents or guardians may use the Applications on behalf of their child and in doing so share their child’s personal information with the Kinsa system, but a child under the age of 16 may not use the Application themselves. For clarity, consent must be given or authorized by the holder of parental responsibility over the child before providing personal information of a child below the age of 16 years.

Updates to Our Policy

We reserve the right to change, add, modify or remove portions of our Privacy Policy at any time.  Any changes to our Privacy Policy will become effective immediately and communicated through our Services via the last updated date set forth above.  Please continue to check our Privacy Policy from time to time to learn about any changes to our privacy practices. Information collected before changes are made will be secured according to the previous Privacy Policy.

Contact Us

For all inquiries please contact us using the email or phone number provided below. 

Email: privacy@kinsahealth.com

Phone:  (+1) 917-426-3860

Last Updated: June 23, 2020