Last Updated: December 4th, 2024
1. Who We Are and What We Do
At Getlabs, Inc. (“Getlabs”), we provide a technology platform to allow our users to schedule blood draws with mobile phlebotomists for the purpose of fulfilling their lab orders and delivering their samples to a diagnostic laboratory. This Privacy Policy explains our information practices, the kinds of information we collect, how we use and share that information, and your options.
2. Scope
This Privacy Policy applies to Personal Information Processed by us in our business, including on our website (each a “Site”), applications, and other online offerings (collectively, the “Services”). All Individuals whose responsibilities include Processing Personal Information for us are expected to protect it by following this Privacy Policy.
3. Transparency/Notice
3.1. Personal Information We Collect and How We Use It
The types of Personal Information we collect and our privacy practices depend on whether you are a customer, user, or visitor (together, “Individuals”) and the requirements of applicable law.
Communications with Us.
We may collect Personal Information from you such as email address, phone number, date of birth, payment card information, insurance policy information, or address when you request information about our Services, request customer or technical support, or otherwise communicate with us.
Automatic Data Collection
We may collect certain information automatically when you use the Services. This information may include your Internet protocol (IP) address, user settings, IMEI, MAC address, cookie identifiers, mobile carrier and other unique identifiers, details about your browser, operating system or device, location information, Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, and other information about how you use the Services. Information we collect may be associated with accounts and other devices.
Information from Other Sources.
We may obtain information about you from other sources, including through third party services and organizations to supplement information provided by you.
3.2. How We Use Your Information
We Process Personal Information about Individuals for a variety of business purposes, including:
To Provide Products, Services, or Information Requested
including to:
- Manage Individual information and accounts;
- Respond to questions, comments, and other requests;
- Provide access to certain areas, functionalities, and features of our Services, including without limitation the scheduling of phlebotomy services and processing of lab orders;
- Answer requests for customer or technical support; and
For Administrative Purposes
including to:
- Measure interest and engagement in our Site and Services;
- Conduct research and development;
- Improve our products and Services;
- Develop new products and Services;
- Ensure internal quality control;
- Verify Individual identity;
- Allow Individuals to participate in the interactive features on our Site;
- Communicate with you about your account, activities on our Site and Services and policy changes;
- Process your financial information and other payment methods for products or Services purchased; and
- Process applications and transactions;
To Market Our Products and Services
We may use Personal Information to provide you with materials about Services that may be of interest, including new content or Services. We may provide you with these materials as permitted by applicable law. Such uses include:
- To notify you about our products and services that may be of interest to you;
- To administer surveys, sweepstakes, promotions, and other contests;
- To send newsletters and other similar communications not specifically advertising our Services;
- To provide Services to you and our sponsors; and
- Other purposes you consent to or are disclosed when you provide Personal Information.
Your data (which includes your mobile information) will not be sold or distributed to third-parties for marketing purposes. You may contact us at any time to opt out of the use of your Personal Information for marketing purposes as described below.
De-identified and Aggregated Information Use.
We may use Personal Information and other information about you to create de-identified and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Site and Services, or other analyses we create. De-identified or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
Other Uses.
Getlabs may use Personal Information to pursue legitimate interests, such as direct marketing, research (including marketing research), network and information security, and fraud prevention, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
Information We Process for or on Behalf of Covered Entities (as Processors)
- Our Covered Entity (as defined under HIPAA) partners e.g. healthcare providers, health plans and/or laboratories, may choose to use our Services to Process certain data of their own, which may contain Protected Health Information (“PHI”). The PHI that we Process through our Services is Processed by us on behalf of the Covered Entity, and our privacy practices will be governed by the contracts (e.g. a business associate agreement) that we have in place with our Covered Entities, not this Privacy Policy.
- If you have any questions or concerns about how such data is handled or would like to exercise your rights, you should contact the person or entity (i.e., the Covered Entity) who has contracted with us to use the Service to Process this data. Our Covered Entity partners control the PHI in these cases and determine the security settings within the account, its access controls and credentials. We will, however, provide assistance to them to address any concerns you may have, in accordance with the terms of our contract with them.
3.3. Cookies, Pixel Tags/Web Beacons, and Analytics Information
We may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your computer, tablet, mobile phone, or other devices that allow us to record certain pieces of information whenever you visit or interact with our Site and Services.
Cookies
Cookies are small text files placed in visitors’ device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Services may not work properly.
Pixel Tags/Web Beacons
A pixel tag (also known as a web beacon) is a piece of code embedded on the Site that collects information about users’ engagement on that web page. The use of a pixel allows us to record, for example, that a user has visited a particular web page.
Analytics
We may also use third-party analytics services to collect information regarding user behavior on our Site and Services, such as Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Site. Google Analytics uses cookies, to help our Site analyze how users use our Site. You can find out more about how Google uses data when you visit our Platform by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). For more information, please visit Google and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
Additionally, we also use Facebook Pixel and Instagram, a web analytics and advertising service provided by Facebook Inc. (“Facebook”) on our Site. With its help, we and our customers can keep track of what users do after they see or click on a Facebook or Instagram advertisement, keep track of users who access our Site or advertisements from different devices, and better provide advertisements to our target audiences. The data from Facebook Pixel and Instagram is also saved and processed by Facebook. Facebook can connect this data with your Facebook or Instagram account and use it for its own and others advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. Please click here if you would like to withdraw your consent for use of your data with Facebook Pixel https://www.facebook.com/settings/?tab=ads.
Our uses of such Technologies fall into the following general categories:
Operationally Necessary
This includes Technologies that allow you access to our Site, Services, applications, and tools that are required to identify irregular site behavior, prevent fraudulent activity and improve security or that allow you to make use of our functions;
Performance Related
We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how our visitors use the Services;
Functionality Related
We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Site and Services. This may include identifying you when you sign into our Site or Services or keeping track of your specified preferences, interests, or past items viewed;
4. Onward Transfer—How We May Disclose Your Information
4.1. Information We Share
We may share your information as described in this Privacy Policy:
We Use Service Providers.
We may share any information we receive with service providers. The types of service providers (processors) to whom we entrust Personal Information include service providers for: (i) mobile phlebotomy services; (ii) laboratory order processing; (i) provision of IT and related services; (ii) provision of information and services you have requested; (iii) payment processing; (iv) customer service activities; and (v) the provision of the Site and Services.
Disclosures to Protect Us or Others.
We may access, preserve, and disclose your Personal Information, other account information, and content if we believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) respond to your requests; (iii) protect your, our or others’ rights, property, or safety; (iv) to enforce our policies or contracts; (v) to collect amounts owed to us; (vi) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation or prosecution of suspected or actual illegal activity; or (vii) if we, in good faith, believe that disclosure is otherwise necessary or advisable.
Merger, Sale, or Other Asset Transfers.
If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction as permitted by law and/or contract.
Compliance with the 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.
Enforcing Our Rights
We may share your Personal Information to enforce our Terms of Service and any other agreement, terms and conditions relating to your use of the Site. We also may share information as needed to ensure the safety and security of our Site and our users, and to detect, prevent, or otherwise address fraud, security, or technical issues.
5. Your Choices: Right to Object to Processing
5.1. General
You have the right to object to or opt out of certain uses of your Personal Information. Where you have consented to the Processing of your Personal Information, you may withdraw that consent at any time and prevent further Processing by contacting us as described below. Even if you opt out, we may still collect and use non-Personal Information regarding your activities on our Site or Services for other legal purposes as described above.
You can change the cookie settings that will be placed when you use our Site by changing the settings on your Internet browser. You can also block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. Please note that internet browsers allow you to change your cookie settings. These settings are usually found in the 'options' or 'preferences' menu of your internet browser. However, if you use your browser settings to block all cookies (including strictly necessary cookies), you may not be able to access or use all or areas and aspects of our Site.
5.2. Email and Telephone Communications
If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding the Services or updates to our Terms or this Privacy Policy).
6. Rights of Access, Rectification, Erasure, and Restriction
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are Processing your Personal Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic copy of Personal Information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) restrict our uses of your Personal Information; (v) seek correction or amendment of inaccurate, untrue, incomplete, or improperly Processed Personal Information; and (vi) request erasure of Personal Information held about you by Getlabs, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will Process such requests in accordance with applicable laws. To protect your privacy, Getlabs will take steps to verify your identity before fulfilling your request.
7. Data Retention
Getlabs retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.
8. Children’s Privacy
If you are under the age of 18 or you have a child under the age of 18 that would like to use our Site, we will need to obtain verifiable parental consent from the parent or guardian to request an appointment for our Services. If we learn that we have collected personal information from a child under the age of 18, without verifiable consent from a parent or guardian, we will promptly delete that information. If you believe we have collected personal information from a child under the age of 18, without consent of a parent or guardian, please Contact Us.
9. Security of Your Information
We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, the Internet cannot be guaranteed to be 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unintentional disclosure.
By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an e-mail to you.
10. Do Not Track signals
Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Service is not currently set up to respond to those signals.
11. California’s Shine the Light Law
California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Site and/or the Services that are California residents and who provide Personal Information in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Information and the names and addresses of those businesses with which we shared your Personal Information with for the immediately prior calendar year (e.g. requests made in 2022 will receive information regarding such activities in 2021). You may request this information once per calendar year. To make such a request, please Contact Us using the information below.
12. Changes to Our Privacy Policy
We may update our Privacy Policy periodically to reflect changes in our privacy practices, laws, and best practices. We will post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on our Site’s homepage. If we make material changes to our practices with regards to the Personal Information we collect from you, we will notify you by email to the email address specified in your account and/or through a notice on the Site’s home page. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically accessing our Site and reviewing this Privacy Policy to check for any changes.
13. Terms of Service
This Privacy Policy is incorporated by reference into the Getlabs Terms of Service (the “Terms”). All other terms not defined in this Privacy Policy will have the meanings set forth in the Terms. The terms “Getlabs,” “we,” and “us” include Getlabs and our affiliates and subsidiaries.
14. Contact Us
If you have any questions about our privacy practices or this Privacy Policy, please contact Getlabs at hello@getlabs.com.