Last Updated: September 3, 2025
At Adley Health Inc. (“Adley Health” or the “Company”), the operator of Adley Health™ and related websites, applications, services and mobile applications, we are committed to protecting your privacy. It is our policy to respect the confidentiality of information and the privacy of individuals and organizations that engage in our services. This document describes the privacy policy for our website, application and services owned and operated by the Company (collectively, the “Services”).
This policy explains how we collect personal information, the treatment of personal information that we collect when you are on our websites, and when you use our Services, and the use and disclosure of that information. This policy also applies to the Company’s treatment of any personal information. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use, and share your information in the ways described herein. If you use the Services on behalf of someone else, you represent that you are authorized by such individual to accept this Privacy Policy on the individual’s behalf.
This policy is provided to:
This policy also provides for mechanisms to:
Company recognizes that it has both internal and external risks. These risks include, but are not limited to:
The Company recognizes that this may not be a complete list of the risks associated with the protection of protected information. Since technology growth is not static, new risks are created regularly. Accordingly, the Company will actively monitor for new risks. The Company believes the current safeguards in place are reasonable and, in light of current risk assessments are sufficient to provide security and confidentiality to protected information maintained by the Company.
Data input is voluntary and is associated with accounts that are accessible only after a user accepts our terms and conditions or signs up for the Services. It is the Company’s usual practice to collect this personal information directly from you through the use of the Services. In addition, the Company may receive personal information about you through the use of third party vendors utilized by you for Services.
You acknowledge that if you use our Services, such use constitutes your express consent to our use of your personal information in accordance with this policy as amended from time to time, including the receipt of communications in connection with such services in accordance with all applicable laws.
Personal information that we collect, and hold is information that is reasonably necessary for the proper performance of our Services and technology platforms. We collect the following types of information based on the entity, individual or service:
Protected information shall include, but is not limited to, any of the following categories of information and data:
“Personal Information” shall mean “any information concerning a natural person which, because of name, number, personal mark, or other identifier, can be used to identify such natural person.”
The Personal Information that you submit to the Company will be used internally, and for the benefit of other third parties associated with the Company who might require access to your personal information, as applicable:
We may also receive Personal Information from trusted third parties. We may ask to see scanned photographic ID, including a passport or other relevant documentation where we need to verify your identity.
The Company may use Personal Information collected differently depending on whether you are an entity or individual and based on the type of service to be provided as follow:
In addition, each of the above referenced categories of Personal Information may be collected, used, and disclosed with the government, including law enforcement, or other parties to meet certain legal requirements and enforcing legal terms including: fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities; protecting the rights, property or safety of you, the Company or another party; enforcing any agreements with you; responding to claims that any posting or other content violates third-party rights; and resolving disputes.
We may use information you provide us to contact you about our Services that we believe may be of benefit to you. You explicitly agree to receive communications from the Company in connection with such Services in accordance with all applicable laws. We will never sell your information to any third parties for marketing purposes. We comply with the requirements of anti-spam legislation and will give you the option of unsubscribing to email that is not essential to perform our intended business purpose.
Personal information is held in our technology platforms until the time it is no longer needed for any purpose for which it may be used or disclosed. At this point it will be anonymized or destroyed, provided that it is lawful for us to do so. We take a range of measures to protect your Personal Information from:
We adopt a number of procedures to protect the information that we hold from unauthorized access, including but not limited to:
All privacy data related to the services Company is hosted and managed by: [ENTITY]. All data will be hosted by [ENTITY].
Your Personal Information may be disclosed to employees, clients and licensees of the Company and trusted third parties include those in countries that we provide services to, regarding possible work placements or to assist us in providing our services to you, professional associations or registration body that have a legitimate interest in the disclosure of your personal and sensitive information and any person with a lawful entitlement to obtain the information.
We will also send information about you to other companies or people when we:
If you do not give us the information we seek we may be limited in our ability to assist you.
The Company may take such steps to make appropriate corrections, deletions and additions, in the circumstances that are reasonable to ensure that Personal Information is accurate, up to date and not misleading. If you have created a profile with the Company via our Services, you are able to review and edit your Personal Information at any time by logging into your account and reviewing your profile. You can delete your Personal Information or close your account via the prompts on our website. If you do choose to close your account with the Company, we may retain Personal Information from your account as and where required by law.
If you wish to obtain access to your Personal Information you should contact us via this form[ADD HYPERLINK].
You will need to be in a position to verify your identity.
For your convenience, we will retain your information for as long as eight years after the last time that you were an active member of the Company’s Services. The Company will securely dispose of any information that is beyond our retention policy, or that is no longer required. Where required by applicable law, we will notify you when such information has been disposed of. Pursuant to data privacy laws, you may have the right to have your information removed from our systems, entirely. You may do so by using our data privacy form [ADD HYPERLINK] .
You have the right to withdraw your consent at any time or to access and request that we rectify or remove your Personal Information from our system(s). Local laws may give you additional rights, such as the right to request the information in your file, in a commonly readable format, at any time.
If you need assistance accessing, updating, correcting or removing your Personal Information from our System, or if you no longer desire our services, please complete this form[ADD HYPERLINK]. Please note that we will request proof of identity prior to acting on any request. In certain circumstances (for example where required or permitted by law) we might not be able to provide you with access to some of your Personal Information, but where appropriate, we will notify you of the reasons for this.
Please be aware that our Services may contain links to third-party websites. This Policy applies solely to information collected through our Services. If you land on our website from other websites (or move to other sites from our website) you should read their separate privacy policies.
The California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (“CCPA”), provides California residents with specific rights regarding their Personal Data. Please contact us to exercise these rights. This section describes your CCPA rights and explains how to exercise those rights. If you have any questions about this section or whether any of the following applies to you, please contact us at [EMAIL] and indicate “California Rights” in the subject line of your communication. Because of the minimal Personal Data we collect and retain about you, certain rights may not be afforded to you (as further described below). Additionally, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request. Lastly, we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a “service provider” under the CCPA, you may need to contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.
As described in the “Tracking Tools, Advertising, and Opt-Out” section above, we have incorporated Cookies from certain third parties into our Services. These Cookies allow those third parties to receive information about your activity on our Services that is associated with your browser or device. Those third parties may use that data to serve you relevant ads on our Services or on other websites you visit. Under the laws of the CCPA, “sharing” of a User’s web analytics is also considered “selling.” You can opt out of such data selling and/or sharing by following the instructions in this form [ADD HYPERLINK]
We share Personal Data with the following categories of third parties:
Once you have submitted an opt-out request, we will not ask you to reauthorize the sharing of your Personal Data for at least 12 months. To our knowledge, we do not share the Personal Data of minors under 16 years of age.
If you are a resident of Virginia, Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, Washington State (solely with respect to consumer health information) or another state with a similar comprehensive consumer privacy law, you may have certain rights regarding your information. Please contact us to exercise these rights. Please note that in some cases, we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a “processor” (or similar term) under the applicable privacy law, you may need to contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data. Also, because of the minimal Personal Data we collect and retain about you, certain rights may not be afforded to you (as further described below). Lastly, please note that these rights are subject to certain conditions and exceptions under applicable law, which may permit or require us to deny your request.
If you have any questions about this section or whether any of the following rights apply to you, please contact us at [EMAIL] and indicate “State Rights” in the subject line of your communication.
Our compliance department is responsible for coordinating, maintaining and updating this Policy.
During employee orientation, each new employee in departments that handle protected information will receive proper training on the importance of confidentiality of protected information. Each new employee will also be trained in the proper use of computer information and passwords. Further, each department responsible for maintaining protected information will provide ongoing updates to its staff. These training efforts should help minimize risk and safeguard covered data and information security.
The Company has addressed the physical security of protected information by limiting access to only those employees who have a business reason to know such information. Existing policies establish a procedure for the prompt reporting of the loss or theft of protected information. Offices and storage facilities that maintain Protected Information limit access and are appropriately secured.
Protected information in electronic form that is no longer needed is securely erased so that the protected information cannot be read or reconstructed. Paper documents that contain protected information are shredded at time of disposal.
Information systems include network and software design, as well as information processing, storage, transmission, retrieval, and disposal. The Company has policies, standards, and guidelines governing the use of electronic resources and firewall and wireless policies. The Company will take reasonable and appropriate steps consistent with current technological developments to make sure that all protected information is secure and to safeguard the integrity of records in storage and transmission. The Company will develop a plan to protect all electronic protected information by encrypting it for transit.
The Company will maintain effective systems to prevent, detect, and respond to attacks, intrusions and other system failures. Such systems may include maintaining and implementing current anti-virus software; checking with software vendors and others to regularly obtain and install patches to correct software vulnerabilities; maintaining appropriate filtering or firewall technologies; alerting those with access to covered data of threats to security; imaging documents and shredding paper copies; backing up data regularly and storing back-up information off site, as well as other reasonable measures to protect the integrity and safety of information systems.
Due to the specialized expertise needed to design, implement, and service new technologies, vendors may be needed to provide resources that the Company determines not to provide on its own. In the process of choosing a service provider that will maintain or regularly access protected information, the evaluation process shall include the ability of the service provider to safeguard protected information. Contracts with service providers may include the following provisions:
The Company will regularly test and monitor the effectiveness of key controls, systems and procedures of this policy. This policy will be subject to periodic review and adjustment, especially when due to the constantly changing technology and evolving risks. The Company will review the standards set forth in this policy and recommend updates and revisions as necessary. Accordingly, it may be necessary to adjust this policy to reflect changes in technology, the sensitivity of employee/customer data and internal or external threats to information security.
You have a right to complain about our handling of your Personal Information if you believe that we have interfered with your privacy. Complaints can be initiated by this form.
If you are making a complaint about our handling of your Personal Information, it should first be made to us in writing using our contact form, or writing to:
Adley Health Inc.Any information we hold will be governed by the most current version of the privacy policy.