Privacy Policy

Effective Date: 5/2/2024

This Policy applies to all visitors, data subjects, and others who access our Apps and Services ("User(s)" or “You/r”) including persons buying for teams (“Subscribers”). Nabi Health Inc. (“Nabi”, “Callie”, “We”, “Us”, or “Our”) operates the website (joincallie.com and domains), the Callie mobile and web-based applications (“Callie App” or “App/s” or “Mobile Software/s”).

You may use our Apps to access one or more of our services and offerings (collectively the "Service(s)" or “Callie Service”): 

• AI chatbot (“AI Coach”)
• Services offered over SMS (available in the United States only)
• Services purchased from our website and web pages

Where applicable, you must agree to the Terms of Services and Privacy Policies of Callie. This page informs you of our policies regarding the collection, use, and disclosure of your personal information when you use our App and service. This Privacy Policy aims to fulfill our obligation towards your Right to be Informed. We use your data to provide and improve the service. We will not use or share your data with anyone except as described in this Privacy Policy. We align our data protection practices to the key principles prescribed by General Data Protection Regulation (GDPR) and other Data Protection Laws. By using our Apps and services, you agree to the use of information as per this privacy policy and cookie policy. Unless otherwise, the terms used in this Privacy Policy have the same meanings as in our Terms of Service. 

Updates 

We may amend this privacy notice from time to time to keep it up to date. We will notify you via in-app notifications and on our policy webpage when we make any changes to the Privacy Policy. Please regularly check these pages for the latest version of this notice.

Do Note : 

• If in a crisis or emergency, please call the relevant emergency number in your country or the approved helplines provided by Your Institution. 
• The App and service is not to be used by children under 13 years. Callie does not take responsibility for any misrepresentation of age and use. If you are between 13 and 18 years, read the Privacy Policy and Terms of Service with your parents or legal guardian and agree before use. Where requested by us, ask them to provide their consent to use the services at support@joincallie.com. 
• We do not require any personal identifiers or sensitive data hence we do not ask for it. We may collect personal data where your Institution asks us to do so. You have the option to not share your personal data, your medical data and any other sensitive data when you use the Callie App and Services. 
• Your interaction with the AI Coach is with an Artificial Intelligence system and not a human. Hence, AI Coach is restricted in the means of response. 
• The App is not intended to provide a diagnosis, prognosis, treatment or cure of a condition or disease. The App will not offer medical or clinical advice and only suggest that you seek medical help. Callie App is designed to offer general self-care advice and support and cannot offer condition specific advice for complex medical conditions such as complex long term illness, cancer, infertility or genetic disorders among others. 
• Your data may be stored in databases maintained by us and third parties located in countries other than your country of residence. Some of them may have data protection laws that may be less stringent than those in your country. 

Information we may store

In order to provide you the Services, and to continuously improve our products for mental health, physical health, and well-being outcomes, we may store the information outlined here. We want you to be able to understand what we are storing, when, and why, so you can feel as comfortable as possible with the Services. If we haven’t done a good enough job explaining any of the following, please contact us (support@joincallie.com).

Personal Information from you we may store:

• Identification Information: If you choose to provide it, we will store your name, email address, phone number (in hashed form), mailing/billing addresses, and birthday. With your permission, we may also connect with your phone’s address book and if you choose to share Callie with a friend, the contact information (e.g. phone numbers or emails) of the contacts you choose will be accessed and may be temporarily stored. 
• Financial Information: Our payment processor(s) will collect the financial information necessary to process your payments, such as your payment card number and authentication details. Please note, however, that we store only a tokenized version of such information and do not maintain payment card information on our servers. -
• Communication Information: We may collect information when you contact us with questions or concerns and when you voluntarily respond to questionnaires, surveys or requests for market research seeking your opinion and feedback. 
• Commercial Information: We may retain a history of the products you browse and/or purchase using the Services..
• Social Media Information: We maintain a social media presence on platforms like Instagram, Facebook, TikTok, Discord, and LinkedIn (“Social Media Pages”). When you interact with us on social media, we may receive personal information that you provide or make available to us based on your settings, such as your contact details. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
• Writing and Content Information: If you choose to enable a feature that lets you create an account in order to access your account on different devices or fully recover your account, we may store the full content you write in conversations, custom goals, or custom journeys on our servers in an encrypted way. 

Internet Activity Information: 

When you use the Services, we may automatically log the following information: 

• Device Information: The manufacturer and model, operating system, browser type, IP address, and unique identifiers of the device you use to access the Services. The information we collect may vary based on your device type and settings. All of this happens pretty much automatically for every service and product you use that connects to a server on the internet, not just ours, but we are required to include a notification about it here in the Privacy Policy. 
• Usage Information: Information about how you use our Services, such as the types of content that you view or engage with, the features you use, the actions you take, and the time, frequency, and duration of your activities. We may use third-party services to help us with analysis.
• Location Information: We may derive a rough estimate of your location from your IP address when you use the Services.
• Email Open/Click Information: We may collect information about the date and time you open or click links in emails we send.  

We may use the following technologies to collect Internet Activity Information: 

• Cookies, which are text files stored on your device to uniquely identify your browser or to store information or settings in the browser to help you navigate between pages efficiently, remember your preferences, enable functionality, help us understand user activity and patterns, and facilitate online advertising.
• Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications. 
• Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.

Use of information 

We use the information we store for the following purposes:

Service improvement:

• Improving the Services and creating new features
• Personalizing your experience
• Creating and deriving insights from de-identified and aggregated information. 
• For example, when you use the Services, we may store information related to your activity, such as counts of activities you have done or selected. We aggregate and analyze this information across the people using the Services in order to better understand how people are using our products, and to determine how we can better deliver existing and new features and services that help us meet our mission statement and improve people’s mental health, physical health, growth, and well-being. As a concrete example, by storing how often people use two different version of a feature we make available, we can understand which version best helps people and best meets our mission statement. 

Communicating with you:

• Sending you updates about administrative matters such as changes to our terms or policies.
• Providing user support, and responding to your requests, questions and feedback. 

Service delivery:

• provide, operate, maintain, and secure the Services; - create, maintain, and authenticate your account; and - process transactions through our third party payment processors. 

We want to specifically describe our invite feature, since that is one that, if you choose to use it, requires use of specific personal information to operate. You may choose to share your phone number, connect your address book, or otherwise share your contacts with us to use our invite feature. In order to protect and respect the desires of receivers of invite, and to protect the privacy of senders, when you share your information with us for these purposes, we transform your phone number and any additional phone numbers or email addresses of contacts you select for a block list into a random set of characters and numbers into a cryptographic hash function. We then store that random set of characters and numbers on our servers, so we do not have the original phone numbers or your contacts’ email addresses on our servers, but we can still use them to support the ability to block messages without us storing your real phone number. When you ask us to send invites for you to your contacts, we then access the contact information on your device to send the messages through a third-party service provider and may temporarily store contact information on our own servers as needed to send the invite, but we do not permanently store the contact information on our own servers. 

Marketing and advertising: 

• Direct Marketing: To send you marketing communications, including notifying you of special promotions, offers and events via email and other means.
• Promotional Campaigns: To help more people learn about the Services and do our best to help more people, we may run promotional campaigns with third-party service providers. To make sure that these are working, that we do not lose money on the campaigns, and that we’re reaching people who may be helped by the Services, we may share the minimum information possible to effectively run, improve, and learn about the performance of these campaigns with service providers. 

Compliance and Protection: 

• To comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
• To protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
• To audit our compliance with legal and contractual requirements and internal policies; and - prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

Sharing of information 

Our sharing: We do not sell, rent, license, or lease your personal information to third parties. However, we may share personal information with: 

• Service Providers: hosting services, email services, advertising and marketing services, payment processors, customer support services, and analytics services. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your personal information.
• Professional Advisors: lawyers and accountants, where doing so is necessary to facilitate the services they render to us. 
• Business Transaction Recipients: counterparties and others assisting with a merger, acquisition, financing, reorganization, bankruptcy, receivership, dissolution, asset sale, or similar transaction, and with successors or affiliates as part of or following that transaction. 
• Government Authorities: where required to do so for the Compliance and Protection purposes described above. 
• Affiliates: We may share personal information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with Finch Care. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy. 

Your sharing: Through the Services, you may be able to make your personal information available to others if you choose to do so, including: 

• Other users and the public, when you share or post content, or chose to engage in public transactions through the Services.
• Social media platforms, when you choose to share content on social media
• In other ways with your permission,** if you have given your explicit consent to do so.

We do not run ads for other companies on the Services, so we do not need to share the data companies that do run ads on their products need to. The company is supported by subscriptions and other ways people directly contribute to the company. We do not sell your information to third parties for money. 

Personal information retention 

We keep personal information until we no longer need it to satisfy the purposes described in this Privacy Policy and we have no legal obligation to keep it. 

Children 

Our Services are not directed to children who are under the age of 13. We do not knowingly collect personal information from children under the age of 13. If we learn that we have collected personal information from a child under the age of 13 without the consent of the child’s parent or guardian as required by law, we will delete that information. While we would like to make some of the Services available to children under 13, various countries have laws and regulations that require significant investment and cost on our part to demonstrate compliance, even if the Services would already be beneficial to people of this age. In the future we hope to have the resources to make some of our Services meet these requirements. 

Notice to California residents 

Where provided for by law and subject to any applicable exceptions, California residents may have the following rights: 

• Know: You can request to know the categories of personal information that Finch Care has collected about you, the business purpose for collecting your personal information, the categories of sources from which the personal information was collected, whether Finch Care has disclosed your personal information for business purposes, the categories of personal information so disclosed, and the categories of third parties to whom we have disclosed your personal information (we provide this information in the Personal Information Collection, Use, and Sharing sections above).
• Access: You can request access to the specific pieces of personal information that Finch Care has collected about you.
• Delete: You can request that we delete the personal information we collected from you.
• Opt out: We may share Identification Information and Internet Activity Information with social media platforms and other advertising partners for the purpose of serving you personalized advertisements from us on social media platforms and other third party websites, such as to prevent showing advertisements from us if you already use the Services – under certain regulations such sharing may be considered a “sale” of personal information. To opt out, please follow the steps in the below in addition to contacting us. 

If you would like to exercise any of these rights, have any questions, or want an alternative form of this Privacy Policy, please contact us (support@joincallie.com). We want to be as clear as we can with you about your options and the consequences of exercising certain options. After we receive your request, we may request additional information from you to verify your identity. Your authorized agent may submit requests in the same manner, although we may require the agent to present signed written permission to act on your behalf, and you may also be required to independently verify your identity with us and confirm that you authorized the agent to submit the request. We will not treat you differently for exercising your rights.

Links to other websites

The Services may contain links to other websites not operated or controlled by Finch Care, including social media services (“Third Party Sites”). The information that you share with Third Party Sites will be governed by the specific privacy policies and terms of service of the Third Party Sites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these sites. Please contact the Third Party Sites directly for information on their privacy practices and policies. 

Keeping your information secure 

One of the best way to keep information secure is not to store it at all, and that’s why we do our best to only store data that’s necessary to provide you our Services and to meet our mission statement to maximize positive impact on the world’s health and well-being. When we do store information, we employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, we cannot guarantee the 100% absolute security of your personal information and you use the Services at your own risk. ## 

Deleting your information 

You can delete your information at any time directly from the Services. Contact us (support@joincallie.com) and we will delete your information within 90 days of completion. 

Your Rights And Choices

Update or Correct Personal Information: You can contact us (support@joincallie.com) and request any updates or corrections needed to keep your personal information accurate, current, and complete.

Opt Out of Marketing Communications: You may opt out of marketing communications by following the opt out or unsubscribe instructions in any marketing email we send you. Please note, however, that you may continue to receive communications as described in the Communicating with You section after opting out of marketing communications. 

Limit Online Tracking: You also have controls at your disposal to limit online tracking, a common use of which is to opt out of receiving personalized ads served by service providers we may engage with. Recall that we may run promotional campaigns with third-party service providers. To make sure that these are working, that we do not lose money on the campaigns, and that we’re reaching people who may be helped by the Services, we may share the minimum information possible to effectively run, improve, and learn about the performance of these campaigns with service providers. While we believe that advertising, when done responsibly and with reliable third party services, serves to enable small businesses and mom-and-pop shops to have a chance to succeed and compete with much larger companies, with minimal risk to privacy, we understand that you may not agree and that there are companies that can abuse this ability, so we want to outline ways you can limit online tracking. In all cases below, even if you take these actions, you will still see advertisements, but they will likely be less relevant to you and it will likely make it more difficult for small and medium sized businesses to succeed. - 

• Block Cookies:Most browsers let you remove or reject cookies, including cookies used for interest-based advertising or online tracking. These are typically known as third party cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. 
• Online tracking opt-out: You can opt out of interest-based advertising anytime.
• Limit the Use of Advertising ID:** You may be able to limit use of your mobile device’s advertising ID for interest-based advertising purposes through your device’s settings. Both Google and Apple have ways to do this for their platforms that we’ll link to further down, but they are related to: 
• “Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices 
• "Limit Ad Tracking" on iOS devices 
• Use Privacy Plug-Ins or Browsers:** You can block the setting of cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers. You can also install a browser add-on to opt out of Google Analytics. 
• Advertising Industry Opt-Outs: You can also use these opt-out options to limit use of your information for interest-based advertising by participating companies: 
• The NAI's opt-out platform: http://www.networkadvertising.org/choices/ 
• The EDAA's opt-out platform http://www.youronlinechoices.com/ 
• The DAA's opt-out platform: http://optout.aboutads.info/?c=2&lang=EN - 

In all likelihood, most of the sites and apps you know and love that show ads are probably using interest-based advertising to try to earn enough to stay in business. And many small and medium sized businesses and apps that you may frequent or use can only exist, find customers, and succeed with the help of interest-based advertising. While bad actors certainly exist, we believe that the third party services above strike a good balance of preserving your privacy while enabling you to see relevant advertising through personalization for products and services you actually want, and that also helps support small businesses and competition around the world. And unfortunately much of how this works is not well understood. But it is your choice, and we want you to be able to make changes easily with the information linked above. Keep in mind that you will still see advertisements in all these cases, but they will be less relevant to you. 

Personal information requests: We also offer you choices that affect how we handle the personal information that we control. You may request the following in relation to your personal information: 

• Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy. 
• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format. 
• Correction of personal information that is inaccurate or out of date. 
• Deletion  of personal information that we no longer need to provide the Services or for other lawful purposes. 
• Additional rights, such as to **object** to and request that we **restrict** our use of your personal information, and where applicable, you may **withdraw** your consent. 

You can delete your information by contacting us (support @joincallie.com). We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Limits on your choices. In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us (support@joincallie.com) 

International data transfers 

Since we are based in the United States, you will provide your data directly to us in the United States. We may transfer your personal information to our affiliates and service providers in the United States and other jurisdictions. Please note that such jurisdictions may not provide the same protections as the data protection laws in your home country. In these instances we will ensure that relevant safeguards are in place to afford adequate protection for your personal information and we will comply with applicable data protection laws, in particular by relying on an EU Commission or UK government adequacy decision or on contractual protections for the transfer of your personal information. For more information about how we transfer personal information internationally, please contact us (support@joincallie.com).

Changes to the privacy policy 

The Services and our business may change from time to time. As a result we may change this Privacy Policy at any time. When we do, we will post an updated version on this page, unless another type of notice is required by applicable law. By continuing to use our Services or providing us with personal information after we have posted an updated Privacy Policy, or notified you by other means if applicable, you consent to the revised Privacy Policy and the practices described in it. 

Contact Us

 If You have any questions, comments, or concerns about this Agreement or practices, please contact us at support@joincallie.com or by writing to: 

Nabi Health Inc.

169 Madison Ave STE 2820,

New York, 10016, USA