Last Updated Date: June 16, 2023

Contexture (the “Company,” “we” or “us”) is committed to protecting your privacy and using technology that gives you a powerful and safe online experience. This Privacy Policy applies to the Company’s public website located at www.contexture.org (“Website”) and describes how we collect, use, store and share your personal information we collect from you when you visit the public Website. This Privacy Policy does not apply to the information we obtain in connection with the services we provide to our customers, such as our health care provider and health plan participants in our health information exchange.

Your use of the Website indicates your acceptance of this Privacy Policy. We reserve the right to change this Privacy Policy by posting an updated version to the Website at any time. Your continued use of the Website indicates your agreement to any updated Privacy Policy. Accordingly, we urge you to review this Privacy Policy at the start of each use of the Website.

IF YOU DO NOT AGREE WITH ALL OF THE PROVISIONS OF THIS PRIVACY POLICY, THEN YOU MUST EXIT THE WEBSITE IMMEDIATELY.

Table of Contents

COLLECTION OF YOUR PERSONAL INFORMATION

Personal information is information that can be used to identify you either directly or indirectly. What is considered to be personal information may depend on where you live and the laws that apply to the data we may collect about you. Your personal information does not include any de-identified information we collect. De-identified information is data that does not contain any personal information about you and for which there is not a reasonable basis to believe that it can be used to identify you.

Some personal information may also contain particularly sensitive personal information about you. Sensitive personal information generally means personal information that reveals racial or ethnic origin, religious beliefs, a mental or physical health condition or diagnosis, sex life or sexual orientation, citizenship or citizen (immigration) status, genetic or biometric data that may be processed for the purpose of uniquely identifying an individual, or personal data from a child known to be under thirteen (13) years old.

We collect personal information that you provide to us when you use the Website or request specific services through the Website, including but not limited to account creation and event registrations. For example, if you provide it to us, we may collect:

  • Identity and contact information, such as your first name, last name, physical address, electronic address (such as your email address), date of birth, and phone numbers (home, work or cell); or
  • Marketing information, such as your responses to surveys we might ask you to complete.

We do not knowingly collect sensitive personal information on the Website. Please do not share your sensitive personal information with us through the Website.

You may refuse to provide your personal information to us, but this may lead to our inability to provide you with certain products or services.

We or our business partners may also automatically collect technical and usage information about your computer hardware and software, and how you navigate the Website. This information may include: your IP address; operating system; browser type; domain names; the pages within the Website you visit; access times; referring websites or addresses; and approximate location data. This other information may or may not identify you, but in most instances it will not.

We may also obtain information about you from third parties, such as our service providers, contractors and other third parties in connection with our Website or through other means if they are permitted by the laws that apply to them to share this information with us. For example, if in the future we create user profiles from information submitted to our Website, we may include other publicly available information in that profile.

USE OF YOUR PERSONAL INFORMATION

We may use your personal information and other information we collect from you when you use our Website for any of the following activities and purposes, including without limitation to:

  • Operate the Website;
  • Administer your account;
  • Store information about your preferences, allowing us to customize the Website according to your individual interests;
  • Speed up your searches;
  • Deliver the services or process the transactions you have requested;
  • Recognize you when you return to the Website;
  • Communicate with you. For example, if you identify yourself to us by sending us an email with questions or comments, we may use your personal information to respond to your questions or comments;
  • Protect from loss and prevent fraud through the Website;
  • Maintain and improve the Website and our services;
  • Enforce our Terms of Use;
  • Perform data analytics, such as determining which Website pages are the most popular;
  • Comply with applicable law, such as to satisfy reporting obligations;
  • Notify you about changes to the Website or products and services we offer through it; and
  • For any purpose described to you through the Website, that you consent to or that is otherwise permissible under the laws that apply to us.

We may use your personal information to inform you of other products or services available from us and our affiliates. We may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered. We may, from time to time, contact you on behalf of business partners about a particular offering that may be of interest to you. However, we do not sell your personal information to third parties. In those cases, your personal information is not transferred to the third party.

We may use de-identified information for any purpose that is permitted by applicable law.

We will not collect additional categories of personal information or use the personal information we collect for materially different, unrelated, or incompatible purposes without first providing you notice and, when applicable obtaining your consent.

DISCLOSURES OF YOUR PERSONAL INFORMATION

We may share your personal information and other information we collect from you when you use our Website with:

  • Anyone authorized by you to have access to it; and
  • People who help us with the Website and related services, including without limitation third-party business partners who perform certain functions on our behalf, such as analytics companies that help us to perform statistical analysis or that help us communicate with you, such as by sending you e-mail or postal mail; IT contractors that provide customer service or IT support; or shipping companies that assist us by arranging for deliveries.

We may also share this information to fulfill any purpose for which you provided it, including without limitation to provide services to you. We may further share specific personal information and other information about you in special cases, such as if there is an attempted breach of Website security or a physical threat to you or others.

We may also disclose any of your personal information and other information for the following legal and business purposes:

  • In response to subpoenas, court orders, requests from law enforcement, or other legal process;
  • To establish or exercise our legal rights, or to report unlawful conduct to law enforcement or other appropriate government authorities;
  • To defend against legal claims;
  • To a buyer or other successor of the Company in the event of a merger, divestiture, restructuring, reorganization, change of control, dissolution, or other sale or transfer of some or all of the Company’s assets, including as part of a bankruptcy, liquidation, or similar proceeding; or
  • To a third party to whom we are required by law to disclose this information.

We reserve the right at any time to update this Privacy Policy to include other instances in which we may disclose your personal information as permitted by the laws that apply to us.

We may disclose de-identified data for any purpose that is permitted by applicable law. We reserve the right to convert, or permit others to convert, your personal information into de-identified data, which we may share with third parties.

EMAIL COMMUNICATIONS POLICY

When you send an email to us, you are communicating with us electronically. You thereby consent to receive communications from us electronically. We will communicate with you by email or by posting notices on the Website. All agreements, notices, disclosures and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.

USE OF COOKIES AND PIXELS

Cookies. When you visit the Website, we may store or recognize some information on your computer in the form of a “cookie” or similar file. A cookie is a text file that is placed on your computer’s hard disk by a web page server, using functions provided by your web browser.

We may use “cookies” to collect information about the pages you visit on the Website and to help you personalize your online experience. For example, some cookies are required for us to provide a specific feature or service through the Website; they allow us to display the Website in the proper format or language or to authenticate registrations and transactions. Other cookies provide a convenience feature to save you time. For example, if you enter information on a form on the Website or register for an event or other service, a cookie allows the Website to recall your specific information and save you time on subsequent visits.

You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser settings to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Website or other websites you visit.

Pixels. Pages of the Website and our emails may also contain small electronic files known as pixels (also called web beacons, pixel tags, and single-pixel gifs). Pixels generally work in conjunction with cookies to register when a particular computer visits a particular page. They also allow us to personalize your experience on the Website. For example, we use pixels for counting users who have visited pages on our Website; for monitoring the popularity of Website content; and for verifying system and server integrity.

Website Analytic Vendors. The cookies and pixels we use are provided to us by third party companies, and we may share the information we collect with them for the purposes described above. For example, we may use Google Analytics to collect certain information relating to your use of the Website.

DNT Signals. Please also note that some website browsers have a “do not track” (DNT) feature that lets you tell other websites that you do not want to have your online activities tracked. No uniform technology standard for recognizing and implementing DNT signals has been finalized. We do not currently respond to a browser’s DNT signal.

LINKS TO THIRD-PARTY WEBSITES

The Website may include links to third-party websites as a resource. We do not have control over third-party websites and those third-party websites do not operate under this Privacy Policy. We are not responsible for their actions. We encourage you to review the privacy policies of third-party websites you choose to link to from the Website to understand how those third-party websites collect, use, and share your information.

SECURITY OF YOUR PERSONAL INFORMATION

We take reasonable administrative, technical, and physical steps to keep your personal information secure and to protect against the loss, misuse, or alteration of your personal information that we collect and maintain from the Website. Although we have these security measures in place, they cannot guarantee your privacy. You are responsible for maintaining the privacy and security of your account credentials (such as your username, password and security answers or tokens, if applicable), and agree that Company cannot be held responsible for any loss or harm associated with the use of your account.

CHILDREN’S PRIVACY

The Website is not directed at and not intended to be used by any children under the age of 18. The Website is intended for adults aged 18 and older and is not intended to attract children. You must not use the Website if you are a child under the age of 18. We will not collect personal information from any person we actually know to be under 13 years old. If we learn we have collected or received personal information from a child under 13, we will delete that information.

USING THE WEBSITE OUTSIDE OF THE UNITED STATES

We intend the Website to be used by residents of the United States. This Website is not intended for use by individuals who are not located in the United States. If you are visiting the Website from outside the United States, please be aware that your personal information and other information will be transferred to, stored, and processed in the United States, where our servers are located, and our central database is operated. The data protection and other laws of the United States might not be as comprehensive as those in your country. By using the Website, you understand and agree that your personal information and other information may be transferred to, processed by, and stored at our facilities in the United States and those third parties with whom we share it as described in this Privacy Policy.

RETENTION OF YOUR PERSONAL INFORMATION

We retain your personal information only as long as needed to accomplish the purposes we describe in this Privacy Policy and to the extent necessary to comply with our legal obligations (such as record retention laws that apply to us), resolve disputes, and enforce our legal agreements and policies.

TERMS OF USE

Your use of the Website is also subject to Company’s Terms of Use. Any disputes related to this Privacy Policy will be governed by the applicable provisions of the Terms of Use, which are incorporated into this Privacy Policy by reference.

PRIVACY POLICY CHANGES

We may change this Privacy Policy at any time and for any reason. We encourage you to periodically review this Privacy Policy to stay informed of how we protect and use your information. You can also contact us for a copy of this Privacy Policy. Unless we specify otherwise, all changes will be effective upon being posted on the Website. The “Last Updated Date” is posted at the top of this Privacy Policy. You agree to any changes to this Privacy Policy by your continued use of the Website after the Last Updated Date. If you do not agree to the changes, you must exit the Website immediately.

DATA RIGHTS FOR COLORADO RESIDENTS

This Privacy Policy describes how we collect, use, and share your personal information as a “Controller” under the Colorado Privacy Act (CPA) and the rights you have with respect to your personal information, including sensitive personal information. For the purposes of this section, we intend for our definitions of “personal information” and “sensitive personal information” to cover the full scope of data subject to the CPA and to not include information excluded from the scope of the CPA. Because the personal data we collect about you will vary based on how you interact with the Website and the information you provide us, we may not collect all of the potential categories of personal information described in this Website Privacy Policy. Additionally, we may receive information about you from other sources, such as from companies that use public data to make predictions, or we may collect or use additional types of information after you consent for us to do so when required by the CPA. Your rights related to your personal information, to the extent our collection, use, and storage of it is subject to the CPA, are described below.

1. What Personal Information Do We Collect, Process, and Share?

Please refer to COLLECTION OF YOUR PERSONAL INFORMATION, USE OF YOUR PERSONAL INFORMATION and DISCLOSURES OF YOUR PERSONAL INFORMATION above for detailed descriptions of the personal information we collect, our purposes for processing that personal information, and the third parties with whom we share that personal information (when applicable).

2. What Are My Rights?

Right to Access or Obtain a Copy of Personal Information

You have the right to request access to the personal information we collect about you and information about the purposes for which we collect it and the third parties with whom we share it, if any. You also have the right to request a copy your personal information in a portable format, but no more than twice per calendar year.

Right to Correction and Deletion of Personal Information

You have the right to correct inaccurate or incomplete personal information in our records. You also have the right, in some circumstances, to request that we delete the personal information we have collected directly from you or from a third party. We may have a reason under the CPA or other laws to deny your request, either in whole or in part. If so, we will explain that reason to you in our response.

Right to Opt Out

The CPA gives you the right to opt out of processing for certain purposes (each as defined under the CPA), including targeted advertising based on your personal information obtained from your activities over time and across other websites or applications; the sale of your personal information to third parties; or profiling. We do not knowingly conduct any of these activities.

Right to Appeal

If we decline to take the action you request through a data rights request, or act in a more limited way, you have the right to ask us to reconsider our response by contacting us as described below. You must ask us to reconsider our decision within forty-five (45) days of receiving our decision. You also have the right to contact the Colorado Attorney General if you have concerns about the result of your appeal.

3. How Do I Exercise My Rights?

You may exercise any of these rights by submitting a request through our Colorado Privacy Act Data Rights Request Form or by contacting us through the methods described in HOW TO CONTACT US IF YOU HAVE A QUESTION OR COMPLAINT below. If you send an email, please help us locate your personal information by including information about the pages of the Website you accessed when you provided your information and any email address you used to create your account, if applicable.

4. What Must I Provide To Exercise My Rights?

Authentication

To protect consumers’ personal information and comply with the CPA and other privacy laws, we will use an authentication process to confirm your identity before we act on your request. You or your authorized agent may make an authenticated consumer request related to your personal information. If an authorized agent makes the request on your behalf, we may require that you provide the agent written permission to do so, and that you provide us a copy of the authorization or a copy of a power of attorney. We will employ reasonable measures to authenticate requests in order to detect fraudulent requests and prevent unauthorized access to your personal information. To meet our obligations, we are required to associate the information you provide in your request with the personal information we previously collected. If we suspect fraudulent or malicious activity, we may decline a request or ask that you provide further authenticating information. You are not required to create an account with us to make an authenticated consumer request. We will only use personal information you provide to authenticate your data rights request to authenticate your identity or authority to make the request.

Fees

We charge no fee for your first data rights request but will charge a reasonable fee for each subsequent data rights request within a 12-month period.

HOW TO CONTACT US IF YOU HAVE A QUESTION OR COMPLAINT

If you have a question about this Privacy Policy, wish to make a complaint, or believe that your rights under this Privacy Policy may have been violated, please contact us at: 720.285.3200 or 2000 S Colorado Blvd, Suite 12000, Denver, CO 80222 or hello@contexture.org.