Effective August 17, 2021
Protecting our consumer and customer information is very important. We safeguard the information of those we serve. AbleTo handles and safeguards Personal Information (as defined below), and we understand the information we hold represents real people and life events.
If you have questions about the AbleTo Privacy Program, please go to our Contact Us section below to connect with us.
We recognize that the privacy of your Personal Information is important. The purpose of this policy is to let you know how we handle the information collected through the use of this website. Portions of this website may describe privacy practices applicable to specific types of information or to information provided on specific web pages.
This policy does not apply to information collected through other means such as by telephone or in person, although that information may be protected by other privacy policies. As used in this policy, terms such as “we,” “us,” “our,” and “Company” refer to AbleTo and its current and future affiliated and associated entities.
The Company may use various technologies, including cookies, tokens, tags, web logs, web beacons, scripts, and web server logs to gather automatically collected information and may aggregate this information from our website visitors or to enable certain features of our website. This information may include demographic data, technical information about the technology (e.g., phone, computer) used to connect to our website, web browser information, your IP address, and browsing behavior such as pages visited and how often they are visited (“Activity Information”). We may also use third-party analytics companies to provide these services.
We may use Personal Information for a number of purposes such as:
- To respond to an email or particular request from you.
- To personalize the website for you.
- To administer surveys and promotions.
- To provide you with information that we believe may be useful to you, such as information about health products or services.
- To perform analytics and to improve our products, websites, and advertising.
- To comply with applicable laws, regulations, and legal process.
- To protect someone’s health, safety, or welfare.
- To keep a record of our transactions and communications.
- As otherwise necessary or useful for us to conduct our business, so long as such use is permitted by law.
We may use Personal Information to contact you through any contact information you provide through this website, including any email address, telephone number, cell phone number, text message number, or fax number. Please see the section below titled “Our Online Communications Practices.”
We may also share Personal Information within the Company, and we may combine Personal Information that you provide us through this website with other information we have received from you, whether online or offline, or from other sources such as from our vendors. For example, if you have purchased a product or service from us, we may combine Personal Information you provide through this website with information regarding your receipt of the product or service.
In our capacity as a HIPAA “Business Associate” we may share your Health Information to various health plans. As a HIPAA Business Associate, AbleTo may only collect, use and disclose your Health Information in the ways permitted by HIPAA and health plan partners that we are performing work for.
We will only share your Personal Information with third parties as outlined in this policy, the Notice of Privacy Practices (as applicable), and as otherwise permitted by law.
We may share Personal Information if all or part of AbleTo is sold, merged, dissolved, acquired, or in a similar transaction.
We may share Personal Information in response to a court order, subpoena, search warrant, law or regulation. We may cooperate with law enforcement authorities in investigating and prosecuting activities that are illegal, violate our rules, or may be harmful to other visitors.
We may also share Personal Information with other third-party companies that we collaborate with or hire to perform services on our behalf. For example, we may hire a company to help us send and manage email, and we might provide the company with your email address and certain other information in order for them to send you an email message on our behalf. Similarly, we may hire companies to host or operate some of our websites and related computers and software applications.
We may permit you to view your profile and related Personal Information and to request changes to such information. If this function is available, we will include a link with a heading such as “Profile” or similar words. Clicking on the link will take you to a page through which you may review your visitor profile and related Personal Information.
We will not disclose, share, sell, or otherwise disclose your information to unaffiliated third parties for their own marketing unless so authorized by you, your employer or association, group or benefit program sponsor.
Our third-party affiliates, service providers and successors to whom we disclose information are required by law and/or contractual requirements to keep your personal information confidential and secure. These parties may not use or disclose it except as reasonably necessary to provide services to you, on our behalf, or on behalf of your employer or association, group of benefit program sponsor, or to comply with or as permitted by applicable law.
We may disclose De-Identified Information. “De-Identified Information”, means information that is neither used nor intended to be used to personally identify an individual.
We maintain reasonable administrative, technical and physical safeguards designed to protect the information that you provide on this website. However, no security system is impenetrable and we cannot guarantee the security of our website, nor can we guarantee that the information you supply will not be intercepted while being transmitted to us over the Internet, and we are not liable for the illegal acts of third parties such as criminal hackers.
We may send electronic newsletters, notification of account status, and other communications, such as marketing communications, on a periodic basis to various individuals and organizations. We may also send email communications regarding topics such as scheduling reminders, service announcements, privacy notices, administrative notices and other general health topics. We offer you appropriate consent mechanisms, such as opt-out, for marketing and certain other communications. As examples, you may opt out as provided for in a specific email communication or contact us as described below in the section “Contact Us.” Please be aware that opt-outs may not apply to certain types of communications, such as account status, website updates, or other communications.
We will not intentionally collect any Personal Information from children under the age of 13 through this website without receiving parental consent. If you think that we have collected Personal Information from a child under the age of 13 through this website, please contact us as described below in the section “Contact Us”.
Privacy Notice and Disclosures for California Residents
Your Rights and Choices: The CCPA provides consumers with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
You have the right to request that AbleTo disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable request, we will disclose to you: (i) the categories of personal information we collected about you; (ii) the categories of sources for the personal information we collected about you; (iii) our business or commercial purpose for collecting or selling that personal information; (iv) the categories of third parties with whom we share that personal information, if any; (v) the specific pieces of personal information we collected about you (also called a data portability request); (vi) if we sold or disclosed your personal information for a business purpose, two separate lists disclosing: (a) sales, identifying the personal information categories that each category of recipient purchased; and (b) disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
You have the right to request that AbleTo delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to: (i) complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you; (ii) detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities; (iii) debug products to identify and repair errors that impair existing intended functionality; (iv) exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law; (v) comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.); (vi) engage in public or peer-reviewed research in accordance with Section 1798.105 (d)(6) of the CCPA; (vii) enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us; (viii) comply with a legal obligation; or (ix) make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us as described below in the section “Contact Us”.
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information.
You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must: (i) provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative; and (ii) describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
To contact us regarding this policy and our related privacy practices, please email us or write to us at:
320 W. 37th Street, 4th Floor
New York, NY 10018
Attn: Chief Privacy Officer
If you believe we or any company associated with us has misused any of your information, please contact us immediately and report such misuse.
We may change this policy. If we do so, such change will appear on this page of our website. We will also provide appropriate notice and choices to you, on this website and in other appropriate locations, based on the scope and extent of changes. You may always visit this policy to learn of any updates.
Protecting Personal Information is important to AbleTo. It is our policy to protect the confidentiality of Social Security numbers (“SSNs”) that we receive or collect in the course of business. We secure the confidentiality of SSNs through various means, including physical, technical, and administrative safeguards that are designed to protect against unauthorized access. It is our policy to limit access to SSNs to that which is lawful, and to prohibit unlawful disclosure of SSNs.