Effective and last updated on July 30, 2021.
IKONA Inc. (“IKONA”, “us”, “we”, or “our”) knows that you care about how your personal information is collected, used, processed, and shared, and we take your privacy seriously. We are committed to protecting and respecting your privacy through our compliance with this policy.
When we refer to “you” or “your” or similar terms, we are referring to you as a user of our Services (as defined below).
This policy describes the types of information we may collect or that you may provide when you visit, purchase, download, install, register with, access, or use the websites, including www.IKONA.health (the “Websites”), and the mobile device applications (“Apps”) owned and operated by us, and our practices for collecting, using, maintaining, protecting, processing, and disclosing that information. We may refer to the Websites and the Apps collectively as the “Sites”. We refer to the information and services made available through the Websites and the Apps, including information communicated through messages, text, and email, collectively as the “Services”.
This policy DOES NOT apply to information that you provide to or is collected by any third party (see Ads, Analytics, and Third-Party Information Collection).
Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not accept our policies and practices, do not access, download, register with, purchase, or use the Sites or Services. This policy is incorporated into and made a part of our terms of use (https://www.IKONA.health/terms) (“Terms of Use”). By visiting, accessing, downloading, purchasing, registering for, or using the Sites or Services, you consent to our use, processing, and sharing of your information as described in this policy. You may withdraw your consent to such use, processing, and sharing at any time by contacting us at support@ikona.health, in which case we will delete your account pursuant to such request (see Your Choices About Our Collection, Use, and Disclosure of Your Information).
For more information about your rights and choices with respect to your information, please see Your Rights to Access, Modify, and Erase Personal Information and Your Choices About Our Collection, Use, and Disclosure of Your Information.
This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Sites and Services after we revise this policy means you accept those changes, so please check this policy periodically for updates.
We collect the following information from and about users of our Sites and other Services:
Information You Provide to Us
When you visit, download, register with, subscribe to, purchase, access, or use the Websites, Apps, or other Services, we may ask you to provide (or if not required, you may choose to provide) information:
By which you may be personally identified, such as your name, date of birth, home or business postal address, city or town, email address, telephone number, videos, photos, stories, GIFs, personal information of individuals for whom you purchase gift subscriptions or refer to our Sites or other Services, usernames, passwords, medical conditions, other health information (including illnesses, symptoms, treatments, and feelings about your medical conditions and/or yourself), any other identifier by which you may be contacted online or offline, and other data that you provide when using our Sites or the other Services (collectively, “personal information”).
This information includes:
Information Shared Through IKONA Online Communities
IKONA’s Websites and Apps feature programs that offer online and virtual group discussions, question and answer sessions and coaching sessions facilitated by both licensed professionals and professionals who are not licensed (collectively, “Virtual Group and Coaching Programs”). Users participate in Virtual Group and Coaching Programs through virtual communication methods that may permit your voice or likeness to be shared with IKONA facilitators and other Site users, including video and audio conference calls and virtual meetings. Virtual Group and Coaching Programs are intended to provide users with an opportunity to discuss topics related to chronic pain management and related topics such as support and suggested resources for further exploration. Accordingly, users of Virtual Group and Coaching Programs will likely share or discuss their personal experiences during such programs. You choose and control whether to participate in Virtual Group and Coaching Programs and what, if any, information (including personal information) you share in any Virtual Group and Coaching Programs (collectively, “User Program Contributions”). Certain Virtual Group and Coaching Program sessions may be recorded by IKONA and made available elsewhere on the Site. IKONA will give advance notice of which sessions will be recorded, and you may choose to participate or not. By participating in any Virtual Group and Coaching Program, you consent to such recording and transmission, distribution, performance, and display by IKONA on its Sites.
User Program Contributions are considered public, non-confidential Public Submissions (as defined in our Terms of Use at https://www.ikona.health/terms). Although our Terms of Use requests users of Virtual Group and Coaching Programs not to share or disclose other’s User Program Contributions, including personal information, without their permission, please be aware that we cannot control the actions of other users of the Services and third parties with whom you may choose to share your User Program Contributions. Therefore, we cannot and do not guarantee that your User Program Contributions, including personal information, will be kept private, nor viewed or used by unauthorized persons, nor used for unauthorized purposes, including for purposes of contacting you.
IKONA may also feature online message boards, chats, or other forums through the Sites and other Services, including through our Facebook page, groups, and communities (collectively, “Public Forums”). Users may choose to share personal information through Public Submissions, including comments, questions and answers, posts, messages, and other similar methods on or through the Public Forums. All User Submissions (as defined in our Terms of Use at https://www.ikona.health/terms), including personal information, you share through our Public Forums are public and not private and are shared with and transmitted to others at your own risk.
Notwithstanding the foregoing, User Submissions you share with IKONA solely through non-public Services (e.g., chatbots, email, text messages, private Facebook Groups and phone calls with IKONA) will not be shared by IKONA except in compliance with this Privacy Policy; provided, that if you also share such information through any Public Forum, including through Virtual Group and Coaching Programs or Facebook, such information will be considered Public Submissions.
Automatically Collected Information and Online Tracking
When you visit, download, access, and use the Sites, we may use technology to automatically collect:
Tracking Technologies
The technologies we use for automatically collected information may include:
Ads, Analytics, and Third-Party Information Collection
We partner with third-party analytics providers to help us collect statistical information about your use of the Sites and Services and traffic on the Sites. Six of the analytics providers we currently use are Google, Segment, Wix, Intercom, Thinkific and Jotforms. When you use the Sites or its content, these third parties may use automatic tracking technologies to collect information about you. We share your email addresses with these third-party providers in order for them to deliver the services we require of them. In addition, the information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. You may review Google’s privacy policy here: (https://policies.google.com/privacy), Segment’s privacy policy here: (https://segment.com/legal/privacy/), Wix’s privacy policy here: (https://www.wix.com/about/privacy), Intercom’s privacy policy here: (https://www.intercom.com/legal/privacy), Thinkific’s privacy policy here: (https://www.thinkific.com/privacy-policy/), and JotForm’s privacy policy here: (https://www.jotform.com/privacy/). For information about how you can opt out of receiving targeted advertising from third-party providers, see Your Choices About Our Collection, Use, and Disclosure of Your Information.
We may also engage other third parties, such as web hosting and storage service providers, including Google, and payment processing providers, including Stripe, to provide services to us so that we may provide the Sites and Services, and such service providers will have access to your personal information in connection with their provision of those services subject to each third party provider’s own terms of use and privacy policies.
Notwithstanding anything to the contrary in this policy, we do not control any third party sites that you link to through our Sites. If you click a link to any third party website or service, that third party may also transmit cookies to you or automatically collect tracking or other information about you. Before using such third party sites or their services, you must review and accept the terms of use and privacy policies for those sites and services. We are not responsible or liable with respect to any third party sites, policies, or practices, including the availability, reliability, content, functions, performance, accuracy, legality, appropriateness, services, materials, or any other aspect of any third party sites. This policy governs only information collected on our Sites or through our Services. When you access any third party sites, you do so at your own risk, and you understand and agree that you are solely responsible for reading and understanding any terms of use and privacy policies that apply to such third party sites and release IKONA and its affiliates and partners from any liability with respect to such third party sites.
What Is A Cookie?
“Cookies” are small data files that are stored on the hard drive of the device you use to view a website. Each device that accesses a Site is assigned a different cookie by IKONA.
Session cookies are specific to a particular visit and carry information as you view different pages within a Site. Session cookies expire and delete themselves automatically in a short period of time, e.g., when you leave the website or when you close your browser.
Persistent cookies enable us to recognize you when you visit a Site and remember your preferences. Persistent cookies are stored on your browser or mobile device until you choose to delete them, and otherwise typically delete themselves at expiration.
Third-party cookies are placed by someone other than IKONA, and may gather browsing activity across multiple websites and sessions. They are usually persistent cookies and are stored until you delete them or they expire based on the time period set in each third-party cookie.
“Web Beacons” (also referred to as clear gifs, pixel tags, and single-pixel gifs) are small electronic files embedded in a page of a website that permit us to monitor activity and collect information such as counting users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain Site content and verifying system and server integrity). Web beacons send back to its home server (which can belong to the host site, a network advertiser, or some other third party) information from your browser, such as the IP address, the URL of the page on which the Web Beacon is located, the type of browser that is accessing the site, and the ID number of any cookies on your computer previously placed by that server.
“Application SDKs” are mobile application third-party software development kits that are embedded in mobile applications. These app SDKs permit the collection of information about the app itself, activity in the app, and the device the application is running on.
Why We Use Cookies
We use cookies and other tracking technologies to recognize individual users when they access the Services, remember user preferences, keep track of users’ access to and use of the Services, track whether our emails opened and whether links are clicked, ensure that the Services are functioning properly, track and analyze usage and other trends, improve users’ experience on the Sites, and personalize the Services so that they are relevant to an individual user’s interests which may be inferred based on location, prior activity on the Sites, and other information that we or our partners may have about our users.
IKONA Cookie Uses
The cookies used on the Sites are used for one of the following purposes:
Your Options for Managing Cookies
You can typically control the use of cookies at the individual browser level. Most browsers can be set to refuse all or some cookies, or to alert you when cookies are being sent. If you choose not to activate cookies or to later disable them, you can still visit and use our Sites and Services, but some parts of the Sites or their functionality or features may then be limited, inoperable, inaccessible, or not function properly.
In addition, certain third party analytics or advertising networks, including Google, allow users to opt out of or customize preferences associated with your internet browsing.
We use information that we collect about you or that you provide to us, including any personal information, to:
IKONA shall have the right, but not the obligation, to record or monitor for quality assurance and training purposes all telephonic, e-mail, and other forms of communication, and to monitor or disclose in accordance with this policy any User Submissions and other communications made in, on, or through the Site or other Services. By visiting, accessing, downloading, purchasing, registering for, or using the Sites or Services or otherwise consenting to our Terms of Use, you consent to any such recording, saving, monitoring, or disclosure.
We may also use your information to contact you about our third parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, you may unsubscribe from receiving those communications (please see Your Choices About Our Collection, Use, and Disclosure of Your Information).
We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.
User Program Contributions, including personal information, you choose to share through our Virtual Group and Coaching Programs are available to the facilitators and other users of such Virtual Group and Coaching Programs and may be available to our administrators, moderators, and other staff and are considered Public Submissions (as defined in our Terms of Use [www.ikona.health/terms]). We cannot guarantee that User Program Contributions will not be shared by other users, used by unauthorized persons, or used for unauthorized purposes.
User Submissions that you share through any other Public Forum, including through our Facebook page, groups, and communities, are Public Submissions and are available to the general public and are not private.
User Submissions you share with IKONA solely through non-public Services (e.g., chatbots, email, text messages, and phone calls with IKONA) will not be shared by IKONA except in compliance with this Privacy Policy; provided, that if you also share such information through any Public Forum, including through Virtual Group and Coaching Programs or Facebook, such information will be considered Public Submissions.
In addition, we may disclose personal information that we collect or you provide:
We employ industry standard administrative, physical, and technical measures designed to safeguard and protect your personal information under our control from accidental loss and from unauthorized access, use, alteration, and disclosure.
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 Sites, you are responsible for keeping this password confidential. We ask you not to share your password with anyone and we suggest that you limit access to your computer and browser by signing off after you have finished accessing your IKONA account. We urge you to be careful about giving out information in public areas of the Sites like message boards. The information you share in public areas may be viewed by any user of the Sites.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure, and we cannot and do not guarantee the security or confidentiality of your personal information transmitted through any of our Sites. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide.
We will make all legally required disclosures of any breach of your unencrypted, electronically stored “personal information” or “medical information” (as defined in applicable state statutes or other applicable laws on security breach notification). To the extent permitted by applicable laws, we will disclose any such breach to you via email or a conspicuous posting on your private profile on the Sites in the most expedient time practicable and without unreasonable delay, subject to and as consistent with (a) the legitimate needs of law enforcement, or (b) any measures necessary to determine the scope of the breach and restore the reasonable integrity of our data system.
If you have any questions about data security, you can contact us at info@IKONAhealth.com.
You can review, correct, and update personal information you have submitted when you registered with our Sites by visiting the settings option within the applicable Site’s main menu. You may also contact us to correct or update inaccurate information in your user account or profile by sending an email to us at support@ikona.health. We may retain a copy of the original or unrevised information in our records for a period of time. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or our Terms of Use.
You may request to receive your personal information by emailing us at support@ikona.health. IKONA will use commercially reasonable efforts to provide you access to your personal information within thirty (30) days of such request, but may not provide access under certain circumstances, including but not limited to instances where the information cannot legally be disclosed, where such access would compromise others’ privacy or other legal rights, where it would be unduly burdensome or expensive to provide such access as balanced against the risks to your privacy, or where the information is subject to confidentiality or proprietary restrictions.
Editing or deletion of personal information is handled in the following ways:
If you delete or edit your personal information as provided herein, copies may remain viewable in cached and archived pages, or might have been copied or stored by other Site users, and complete removal of all traces of personal information is not guaranteed. Proper access and use of information provided on or through the Sites, including User Submissions, is governed by our Terms of Use.
We strive to provide you with choices regarding the personal information you provide to us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.
We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
We will retain the personal information we receive from you as described in this policy for as long as you use the Sites or other Services or as long as necessary to fulfill the purposes for which such personal information was collected, to provide our Services, to resolve disputes and prepare for, defend against, and otherwise conduct any legal action or process, to conduct audits, to pursue our legitimate business purposes, to enforce or comply with contracts, and to comply with applicable laws.
The Sites and Services are not designed or intended for children under 18 years of age, and we do not knowingly collect personal information from children under 18. If you are under the age of 18, you may not create an account through, and must not use, our Sites or other Services. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that user’s account. If you believe we might have any information from or about a child under 18, please contact us at support@ikona.health.
IKONA and our (or our service providers’) servers containing personal information are located in the United States. If you are located outside of the United States, your personal information must be transferred or transmitted to the United States for storage and processing in compliance with this policy. By using our Sites and other Services, you consent to such collection, storage, and processing in the United States. Please be advised that the United States or such other countries may not afford the same level of data protection as is required in your own country. Pursuant to legal process made in the United States, your personal information may be available to the United States government or its agencies.
We collect, use, process, and share your personal information as described in this policy. Our legal bases to process your information include (a) carrying out our legitimate interests in providing, maintaining, and improving the Sites and other Services, (b) performing any contractual obligations under the Terms of Use or under contracts entered into between you and us, (c) complying with applicable law, (d) fulfilling our obligations to our service providers and partners, and (e) where you have consented to the processing, which consent you can withdraw at any time by requesting to delete your IKONA account, subject to the other terms of this policy (although a withdrawal of consent shall not affect the lawfulness of processing your personal information at any time prior to the date of such withdrawal) (see Your Choices About Our Collection, Use, and Disclosure of Your Information). Notwithstanding any other terms of this policy, where the EU General Data Protection Regulation (Regulation (EU) 2016/679) (the “GDPR”) requires our compliance with applicable provisions thereof, we will undertake commercially reasonable efforts to comply with all lawful requests made pursuant to and in accordance with the GDPR, as it may be amended from time to time.
If you are a user of Services who is located in an EU member state or a European Economic Area, you may contact us at support@ikona.health to inquire whether we are processing your personal information. You may request that IKONA cease processing your personal information by emailing us a request at support@ikona.health, in which case IKONA will delete your account pursuant to such request (see Your Choices About Our Collection, Use, and Disclosure of Your Information).
If you are a user of Services who is located in an EU member state or a European Economic Area and you believe that we have not complied with applicable data protection laws, you may file a complaint with your local supervisory authority.
We may update our privacy policy, our Sites, and our other Services from time to time in our sole discretion. If we make material changes to how we treat our users’ personal information, we will post the new privacy policy on this page with a notice that the privacy policy has been updated or by sending you an email to the email address specified in your account with us. By continuing to use our Sites or other Services, you agree to the most recent privacy policy and Terms of Use. If you do not accept the terms of this privacy policy, do not register with us or access, download, purchase, subscribe to, or use the Sites or Services. We recommend that you check this page from time to time for the latest information on our privacy practices.
The date the privacy policy was last revised is identified at the top of the page.
If you have any questions or concerns regarding privacy on our Sites or with respect to our Services, please send us a detailed email to support@ikona.health or contact us at the address below:
IKONA Inc. 135 Madison Avenue 5th Floor, New York, NY 10016