PRIVACY POLICY

Last Updated: November, 2019

INTRODUCTION  

Nursing Without Walls, Inc. (“Nursing Without Walls,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use Nursing Without Walls Platform (the “Platform”) through Nursing Without Walls’ website at www.gento.io (the “Website”) or Nursing Without Walls’ mobile application (the “App”). 

Nursing Without Walls is committed to protecting the privacy of its Users whose information is collected and stored while using Nursing Without Walls’ Platform through our Website or App.  

The capitalized terms have the same meaning as ascribed in our Terms of Use, unless otherwise noted here. 

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING OR USING OUR WEBSITE, APP, AND PLATFORM, YOU AGREE TO ACCEPT ALL THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE, APP, AND PLATFORM. 

IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN EMAIL AT info@gento.io.  

WHAT INFORMATION DO WE COLLECT?  

When you register to use or create an account on our Website, App, or Platform, we collect personal information (also referred to as personally identifiable information or “PII”) which may include your first and last name, physical address, online contact information such as your email address or user name, phone number, social security number, driver’s license or ID card number, education information (such as your degrees, majors, schools attended, etc.), professional or employment-related information (such as medical associations, employer, business title, business address, etc.), user name or email address combined with a password or security question and answer, photographs or video/audio files of non-minors, credit card information, personal health information (“PHI”) as defined under Health Insurance Portability and Accountability Act (“HIPAA”), and other personal information. We may also collect information that does not personally identify you such as your geolocation.  The information so collected will be stored on our servers. Users are able to change their personal information via email by contacting us at info@gento.io.  

HOW DO WE COLLECT INFORMATION? 

We collect personal information from you in the following ways: 

1. At registration or account creation on our Platfom;
2. In email, text, and other electronic messages between User and our Platform; 
3. Through mobile and desktop applications that User downloads from our Platform, which provides dedicated non-browser based interaction between the User and Platform;  
4. When User interacts with our advertising and applications on third-party websites and services, if those applications or advertising include a link to this Privacy Policy; 
5. From User placing an order, which includes details of transactions User carries out on our Platform; 
6. From User’s responses to a survey;  
7. From forms filled out by User;  
8. From records or copies of correspondences (including email addresses) if User contacts us;  
9. From search queries on our Platform; and 
10. When User posts information to be published or displayed on our Platform.

HOW DO WE USE YOUR INFORMATION? 

We use the information that you provide to: 

1. Personalize User experience in using our Platform;  
2. Provide Users with information, products, or services requested from us; 
3. Present our Website, App, and Platform and their contents to Users; 
4. Provide Users with notices about account and/or subscription, including expiration and renewal notices; 
5. Carry out obligations and enforce rights arising from contracts entered into between Users and us, including billing and collection;  
6. Notify Users about changes to our Website, App, and Platform and any products or services;  
7. Allow Users to participate in interactive features on our Website, App, and Platform;  
8. Improve the Website, App, and Platform;  
9. Improve our customer service; 
10. Administer contests, promotions, and surveys or other Website, App, and Platform features;  
11. Process transactions; 
12. Anonymize data and aggregate data for statistics; 
13. Contact Users about our products and services that may be of interest; and 
14. Send User periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section 12, via the email address provided by User to (i) send information, respond to inquiries, and/or other requests or questions; (ii) process orders and send information and updates pertaining to such orders; (iii) send additional information related to User’s product and/or service; and (iv) market to our mailing list or continue to send emails to User after the original transaction has occurred. 

OUR COOKIE POLICY AND TRACKING POLICY 

Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as “Cookies.”  

We do not currently use Cookies, but we may in the future. If you disable Cookies in your browser, it will not affect User experience.  We honor Do Not Track (“DNT”) signals and, if one is in place, we will not track, plant Cookies, or use advertising.  We also do not allow third party behavioral tracking, but we allow links to third party web pages.    

HOW DO WE PROTECT INFORMATION WE COLLECT? 

1. Security Measures.  Our Website and App use an SSL certificate as one security measure.  We also require username and passwords for our employees who can access the personal information of Users that we store and/or process on our Platform and servers. In addition, we actively prevent third parties from getting access to the personal information of Users that we store and/or process on our Platform and servers.  We accept payment by credit card and use a third party credit card processor.  We will implement reasonable security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c) register, or (d) access our Platform, on our Website and App.  Furthermore, we require a personal identification number (“PIN”) before accessing PHI.   
2. Financial Information. We store financial information on our servers, including credit card information on our servers, but we will not keep such sensitive information for longer than is needed.  We will also delete such information within fourteen (14) days of the cancelation or termination of service.   
3. Health and Medical Information.  We store personal information such as PHI on our servers, and such information is stored indefinitely.  We will provide you with a list of such personal information we keep on you upon requeSt.  We will delete all such personal information upon requeSt. 

DATA SECURITY MEASURES. 

1. Security Measures.  We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.  The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Platform. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website, App, and/or Platform.  
2. Fair Information Practice Principles.  In the event of a data breach, we will notify the User within seven (7) days via (i) email and/or (ii) our Platform notification system on our Website and/or App.  We will also notify the FTC, FCC, and/or state regulatory agency as necessary. We agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.

DISCLOSURE OF PERSONAL INFORMATION 

Disclosure of Personal Information.  

1. We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide you with advance notice.  This does not include website hosting partners and other parties who assist us in operating our Website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential.   
2. We may disclose aggregated information about our Users that does not identify any individual without restriction. 
3. We disclose personal information to contractors, services providers, and other third parties. We use third parties who have access to our Users’ personal information to perform some of the operational functions, such as billing and collection, to provide full service to our Users. 
4. We require all contractors, service providers, and other third parties to whom we disclose Users’ personal information to be under contractual obligations to keep personal information confidential and to use it only for the purposes for which we disclose them. 
5. We will disclose personal information in the event of a merger, sale of business, etc. 
6. We require all third parties to whom we disclose Users’ personal information to be under contractual obligations to keep personal information confidential and use such personal information only for the purposes for which we disclose it to them. 
7. We disclose personal information to fulfill the purpose for which the User provided it, for instance, if the User gave Nursing Without Walls an email address to use the “email a friend” feature of the Platform. 
8. We disclose personal information for any other purpose for which the User provided it. 
9. We will only disclose personal information as described in this Privacy Policy or with the written consent of the User.  

Other Disclosure of Personal Information.  

1. We will disclose personal information (i) to comply with any court order, law or legal process, including to respond to any government or regulatory request; (ii) to enforce or apply our Online Agency Agreement, Online Contractor Agreement, and Website Terms of Use;  (iii) if we believe it is necessary or appropriate to protect the rights, property, or safety of Nursing Without Walls, our customers or others; and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of Nursing Without Walls, our customers, or others, and this includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction. 

Disclosure of Users’ Information for Third-Party Advertising.   

1. Users can opt-out (i) by checking the relevant form when we collect the data; (ii) by logging into our Website, App, or Platform and adjusting their preferences in their account profile; or (iii) by emailing us their request at info@gento.io.   
2. Users receiving promotional email can opt-out by sending a return email requesting to be omitted from future promotional email distributions. This opt-out will not apply to information provided by Nursing Without Walls for product purchases, warranty registration, or other transactions.     

 GOOGLE ANALYTICS 

We currently use Google Analytics to collect and process certain Website usage data. To learn more about Google Analytics and how to opt–out, please visit www.policies.google.com/privacy/partners.  

YOUR CALIFORNIA PRIVACY RIGHTS  

Nursing Without Walls does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the term is defined under the California Civil Code Section § 1798.82(h).  Additionally, California Civil Code Section § 1798.83 permits Users of our Website, App, or Platform that are California residents to request certain information regarding our disclosure of their Personal Information to third parties for their direct marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal Information in all our systems that we store on you, please send an email to info@gento.io or write us at Nursing Without Walls, Inc., 17031 Chatsworth St. Granada Hills, CA 91344. 

Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our services to you and (ii) we may need to keep such Personal Information for a while during the shutting down and billing process. If you would like to discuss our Personal Information storage and processing process with us, please send us an e-mail at info@gento.io or write us at Nursing Without Walls, Inc., 17031 Chatsworth St. Granada Hills, CA 91344. 

 COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY) 

The Children’s Online Privacy Protection Act (“COPPA”) is a legislation that applies to entities that collect and store personal information from children under the age of 13. We are committed to ensure compliance with COPPA. Our Website, App, and Platform are not meant for use by children under the age of 13. Our Website, App, and Platform do not target children under the age of 13, but we do not age screen or otherwise prevent the collection, use, and personal disclosure of persons who are under 13.  If you would like to know more about our practices and specifically our practices in relation to COPPA compliance, please email us at info@gento.io.  

IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE, APP, AND PLATFORM.  

CAN-SPAM ACT OF 2003  

The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have businesses stop emailing them, and spells out penalties for violations.  Per the CAN-SPAM Act, we will: 

1. not use false or misleading subjects or email addresses;  
2. identify the email message as an advertisement in some reasonable way;  
3. include the physical address of Nursing Without Walls, Inc., which is located at 17031 Chatsworth St. Granada Hills, CA 91344;  
4. monitor third-party email marketing services for compliance, if one is used; 
5. honor opt-out/unsubscribe requests quickly; and 
6. give an “opt-out” or “unsubscribe” option.     

If you wish to opt–out of email marketing, follow the instructions at the bottom of each email and we will promptly remove you from all future marketing correspondences.  

TERRITORIAL RESTRICTION 

Our Website, App, and Platform are only available for use and download outside the European Union. Our Website, App, and Platform are not available for use or download by residents of, visitors to, or employees of our customers, who reside in the European Union (collectively a “European”). If you are a European, please do not download, register, and/or use the Website, App, or Platform. If you are a resident in the United States of America (“US”), you must comply with this Privacy Policy and the Online Agency Agreement or the Online Contractor Agreement.   If you are a resident of any other country, please ensure compliance with all local laws prior to using our Website, App, or Platform. 

If you have any questions regarding this section, please email us at info@gento.io. 

MODIFICATIONS TO OUR PRIVACY POLICY 

Nursing Without Walls reserves the right, at its sole discretion, to change or modify this Privacy Policy at any time. In the event, we modify this Privacy Policy, such modifications shall be binding on you only upon your acceptance of the modified Privacy Policy.  We will inform you about the modifications on our Privacy Policy page. Your continued use of our Website, App, or Platform shall constitute your consent to such changes.  

 LIST OF THIRD-PARTY SERVICE PROVIDERS 

Nursing Without Walls uses the following third-party service providers for the provision of services as detailed under the Online Agency Agreement and Online Contractor Agreement. 

Additionally, if you have any questions or concerns about our third-party service providers, please email us at info@gento.io.  

COPYRIGHT INFRINGEMENT/DMCA NOTICE 

If you believe that any content on our Website, App, or Platform violates your copyright, and you wish to have the allegedly infringing material removed, the following information in the form of a written notification (pursuant to 17 U.S.C. § 512(c) (“DMCA Takedown Notice”) must be provided to our designated Copyright Agent.  

• Your physical or electronic signature; 

• Identification of the copyrighted work(s) that you claim to have been infringed; 
• Identification of the material on our Website, App, or Platform that you claim is infringing and that you request us to remove; 
• Sufficient information to permit us to locate such material; 
• Your address, telephone number, and email address; 
• A statement that you have a good faith belief that use of the objectionable material is not authorized by the copyright owner, its agent, or under the law; and 

• A statement that the information in the notification is accurate, and under penalty of perjury, that you are either the owner of the copyright that has allegedly been infringed or that you are authorized to act on behalf of the copyright owner. 

Nursing Without Walls’ Copyright Agent to receive DMCA Takedown Notices is Victor Gajendran at info@gento.io or at Nursing Without Walls, Inc., Attn: DMCA Notice, 17031 Chatsworth St. Granada Hills, CA 91344.  You acknowledge that for us to be authorized to take down any content, your DMCA takedown notice must comply with all the requirements of this Section.  Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of material fact (falsities) in a written notification automatically subjects the complaining party to liability for any damages, costs and attorney’s fees incurred by us in connection with the written notification and allegation of copyright infringement.  

 CONTACT US.  

To ask questions or comment about this policy and our privacy practices, contact us at: 

• Privacy Officer 
• Email: info@gento.io 
• Address: Nursing Without Walls, Inc., 17031 Chatsworth St. Granada Hills, CA 91344. 
• Phone Number: (844) 414-9218. 

PLEASE NOTE: IF YOU USE OUR WEBSITE, APP, AND/OR PLATFORM, YOU HAVE AGREED TO AND ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF USE AND EITHER THE ONLINE AGENCY AGREEMENT OR THE ONLINE CONTRACTOR AGREEMENT.  IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, THE TERMS OF USE, THE ONLINE AGENCY AGREEMENT, OR THE ONLINE CONTRACTOR AGREEMENT, PLEASE DO NOT USE OUR WEBSITE, APP, AND/OR PLATFORM.