Privacy Policy

Last Updated July 13, 2020

Bloom Circle, Inc. d/b/a Lena (“Lena,” “we,” “our” or “us”) respects your privacy and is committed to protecting it through our compliance with this privacy policy. This privacy policy explains our policies and procedures regarding the collection, use, disclosure, and security of certain information that we receive, with a focus on information that would be considered “personal information,” including information by which you may be personally identified. It is our sincere hope that by explaining our practices for handling information, we will develop a trusting and long-lasting relationship with you.

Lena provides real human virtual companions (collectively, the “Companions”) that provide support and guidance (as modified from time to time, collectively, the “Companion Services”) to seniors facing health challenges on their own.

Please note that by accessing and using the Companion Services or visiting or using https://www.joinlena.com (the “Site”) and the various other related services, features, functions, software, applications and websites with the associated with the Site (together with the Companion Services and the Site, collectively, the “Lena Services”), you are accepting the practices described in this privacy policy. This privacy policy is incorporated by reference into the Terms of Service that govern your access and use of the Companion Services, the Site and the other Lena Services (the “Terms”).

This policy describes the types of information we may collect from you or that you may provide when you access or use the Companion Services, the Site, the other Lena Services or any of the other features, functions, services, and products, including our travel partners’ services and products, and our practices for collecting, using, maintaining, protecting and disclosing that information.

This policy applies to information we collect or may collect:

In accessing and using the Site.
In registering to access and use the Companion Services.
In accessing and using the Site and the other Lena Services.
When you engage with the Companion through the Companion Services.
From your healthcare provider.
In e-mail, text and other electronic messages sent through or use of the Site and the other Lena Services.
When you send any content through the Site or any of the other Lena Services.
Through services provided to us or to you by third-party companies, agents or contractors, including our travel partners.

It does not apply to information collected by:

Us offline or through any other means, including on any other website operated by Lena or any third party; or
Any third party, including through any link that may be accessible from or on the Site or any of the other Lena Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your only choice is not to access or use the Companion Services, the Site or any of the other Lena Services. By accessing or using the Companion Services or any of the other Lena Services, you agree to this privacy policy. This policy may change from time to time as described in the provision of this privacy policy entitled Changes to Our Privacy Policy.

Minors under the Age of 18

Neither the Companion Services nor any of the other Lena Services are intended for minors under 18 years of age. No one under age 13 may provide any information on or through the Site or the other Lena Services. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on or through any of the Lena Services or any of its features or register on the Site, use any of the interactive or public comment features of any of the Lena Services or provide any information about yourself to us, including your name, address, telephone number, e-mail address or any screen name, username you may use or any pictures of you. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe that we might have any information from or about a child under 13, please contact us at.

Information We Collect About You and How We Collect It

We collect or may collect several types of information from and about users of the Companion Services and the other Lena Services, including:

Information by which you may be personally identified, including personal information such as name, birthdate e-mail address, address and phone number;
Health information;
Information that you may disclose to your Companion when talking to your Companion or through the chat feature of the Companion Services;
Information that is about you but individually does not identify you, such as the date and time of visit;
When you report a problem or concern with the Companion Services, the Site or any of the other Lena Services;
Records and copies of your correspondence (including e-mail addresses), if you contact us; and/or
Details of transactions you carry out through the Site and any of the other Lena Services.

We collect this information:

Directly from you when you provide it to us.
From your healthcare provider.
From your Companion when you disclose information to your Companion.
From third parties, such as our customers, business partners and other third parties that provide us or you with certain services, including our travel partners.

Certain situations may also involve you calling us or our calling you. Please be aware that we may monitor, and in some cases, record such calls for staff training or quality assurance purposes.

You are also able to chat directly with your Companion through the Companion Services.

Data Minimization

We take every reasonable step to limit the volume of your personal information that we process to what is reasonably necessary.

We do not Engage in Automated Decision-making without Human Intervention

We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.

Consequences of not providing Personal information

You are not required to provide all personal information identified in this policy to access and use the Companion Services or to interact with us offline, but we may not be able to provide you the support and guidance through the Companion Services that we otherwise could if you do not provide this personal information.

Use of Cookies and Other Tracking Technologies.

We do not currently use cookies or other tracking technologies on the Site or any of the other Lena Services.

Do Not Track Policy

Your web browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. We do not honor any web browser “Do Not Track” signals or other mechanisms that provide you with the ability to exercise choice regarding the collection of personally identifiable information about your online activities over time and across third-party websites or online services. At present, no universally accepted standards exist on how companies should respond to do-not-track signals. In the event a final universally accepted standard is established, we will assess and provide an appropriate response to these signals.

Third-party Responsibilities and Services.

We may use or partner with other third-party companies, agents or contractors for various purposes in connection with our business and operations (“Service Providers”), including, your healthcare provider and care team members, relationship building, the marketing and growth of our business and the performance of services on our behalf, such as gathering and analyzing information and the provision of services to you. In the course of performing these responsibilities and providing such services, these other companies may have access to your information. We may also share information, including your information, with these Services Providers in order to enable them to perform these responsibilities and to provide these services. These Services Providers may have adopted their own privacy policies, which are not subject to control by Lena. You should always review the policies of these Service Providers to make sure that you are comfortable with the ways in which they collect, use, maintain, protect and disclose your information. We do not list our current Service Providers because they change from time to time. If you would like the names of any of Service Providers, please email us at support@lena.io.

The Service Providers may also transmit cookies to your computer or device when you click on ads that appear on or through the Service.

As a convenience to you, we may or may in the future also provide links to other third-parties from within our Service. If you click on one of these links, you will be redirected to that third-party’s site (via affiliate cookies) and such third party may also transmit cookies to you. We do not have any control over that or how they collect, use, maintain, protect and disclose your information. Please be aware that cookies placed by third parties may continue to track your activities online even after you are no longer using any of the Lena Services, and those third parties may not honor “Do Not Track” requests you have set using your web browser.

How We Use Your Information

We will only use information that we collect about you or that you provide to us, including any personal information for purposes described in this privacy policy and when applicable law allows us to do so. We will generally use your information on the following legal grounds:

Where the use of your information is necessary to provide the Companion Services or any of the other Lena Services;
Where the use is necessary for the purposes of our legitimate interests (or those of a third party);
Where we need to comply with a legal or regulatory obligation; or
Where you have given your consent (which can be withdrawn at any time).

We use information that we collect about you or that you provide to us, including any personal information:

To provide you the Companion Services.
To provide you the Site and the other Lena Services and the content that is on it.
To ensure that your healthcare providers and care team members are fully aware of any issues or concerns regarding your health.
To provide technical and other support to you.
To send you news or information about us or the Companion Services that may be of interest to you (if you have not opted-out).
To enable Service Providers, including the Companions, to perform certain responsibilities and provide certain services in connection with the Companion Services and the other Lena Services and our business and operations.
To fulfill any other purpose for which you provide it.
To provide you with notices about the Companion Services.
To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
To notify you about changes to any of the Companion Services, the Site and the other Lena Services.
To enhance the safety and security of all of the Lena Services.
To verify your identity and prevent fraud or other unauthorized or illegal activity.
In any other way we may describe when you provide the information.
For any other purpose with your consent.

Some of the information that we collect automatically may be statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties or you provide to us. It helps us to improve the Site and the other Lena Services, and to deliver a better and more personalized service, including enabling us to:

Estimate our audience size and better understand usage patterns.
Store information about your preferences, enabling us to customize the Site according to your individual interests.
Speed up your searches.
Recognize you when you return to the Site.

Storage and Transfer of Your Information

We may store any data or other information that we collect (personal or otherwise) ourselves or in databases and servers owned and maintained by us, our affiliates, agents or Service Providers. If you access or use the Site or any of the other Lena Services outside of the United States, information that we collect about you may be transferred to servers inside the United States and maintained indefinitely, which may involve the transfer of information out of countries located in the European Economic Area and other parts of the world unless otherwise prohibited by applicable law or agreed by Lena and you. By allowing Lena to collect information about you, you consent to such transfer and processing of such information without restriction. We may also store some information locally on your computer or other devices. For example, we may store information as local cache so that you can open the Site and view content faster.

Although users from all over the world may access the Site, keep in mind that no matter where you live or where you happen to use our services, you consent to us processing and transferring information in and to the United States and other countries whose data-protection and privacy laws may offer fewer protections than those in your home country.

Disclosure of Your Information

We may disclose aggregated information about our customers and users, and information that does not include any personal information, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

To our subsidiaries and affiliates.
To Service Providers, contractors and other third parties we use to support the Companion Services and the other Lena Services, including the Companions and our business but only to the extent necessary for them to provide this support.
To your healthcare provider and care team members.
To a potential or actual buyer, assignee or other successor (including its related advisors and agents) in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Lena’ assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Lena about users of the Site and the other Lena services is among the assets that may be or are actually transferred.
To fulfill the purpose for which you provide it.
For any other purpose disclosed by us when you provide the information.
With your consent.

We may also disclose your data information:

To comply with any court order, law or legal process, including to respond to any government or regulatory request.
To enforce or apply the Terms and other agreements, including for billing and collection purposes.
If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Lena, our customers or others.

Notwithstanding any of the foregoing, we will comply with all applicable state and federal laws and regulations including the privacy and confidentiality of patient records including but not limited to (i) The Health Insurance Portability and Accountability Act of 1996 (“HIPAA”); (ii) the Privacy and Security Standards (45 C.F.R. Parts 160 and 164) and the Standards for Electronic Transactions (45 C.F.R Parts 160 and 162) (collectively, the “Standards”) promulgated or as to be promulgated by the Secretary of Health and Human Services on and after the applicable effective dates specified in the Standards; and (iii) The Health Information Technology Economic and Clinical Health Act of 2009 (the “HITECH Act”). We will not disclose to any third party, except where required or permitted by law, any of your medical records or other patient information, and in such case, disclosures will be made in accordance with applicable policies of the parties and the Standards. All medical information and data concerning specific Users including but not limited to the identification of the Users, derived from the performance of duties and obligations of this Agreement shall be treated and maintained in a confidential manner.

We will not sell any of your personal information.

We may share information that is anonymized or in an aggregated form that does not include any personal information about you and we may use and share any such information for any purpose without restriction so long as it does not violate the terms of this privacy policy or any applicable law. We may use, disclose or sell that anonymized or aggregated information without restriction so long as we do not disclose any of your personal information or violate the terms of this privacy policy or any applicable law.

Choices About How We Use and Disclose Your Personal information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your personal information:

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that all or some parts of the Lena Services may then be inaccessible or not function properly.
Promotional Offers from Lena. If you do not wish to have your e-mail address/contact information used by Lena to market or otherwise promote our own or third parties’ products or services, you can opt-out through the unsubscribe mechanism at the bottom of the applicable email. This opt out does not apply to information provided to Lena as a result of a service or product purchase, warranty registration, product service experience or other transactions.

We do not control third parties’ collection or use of your information to serve interest-based advertising. You may be able to opt out of receiving personalized advertisements from companies who are members of the Network Advertising Initiative or who subscribe to the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising. For more information about this practice and to understand your options, please visit: http://www.aboutads.info and http://www.networkadvertising.org/choices/. You may also use TRUSTe’s Preference Manager at http://preferences-mgr.truste.com.

Accessing and Correcting Your Personal information

You may change, correct or delete any personal information that you have provided to us by emailing us at support@lena.io.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of the Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to support@lena.io or write to us at: Bloom Circle, Inc. d/b/a Lena¸2450 Holcombe Blvd. Ste X, Houston, TX 77021.

How Long We Store Your Personal information

We will only retain your personal information, in a form which permits us to identify you, for as long as necessary to fulfill the purposes we collected it for. We will retain and use your personal information as necessary to satisfy any legal, accounting or reporting requirements, to resolve disputes or to enforce our agreements and rights. Subject to the foregoing, we will delete your personal information upon your request. To dispose of personal information, we may anonymize it, delete it or take other appropriate steps. Data may persist in copies made for backup and business continuity purposes for additional time.

Information Security

We understand that the security of your personal information is important. We provide reasonable administrative, technical, and physical security controls to protect your personal information. However, despite our efforts, no security controls are 100% effective. Lena cannot ensure or warrant the security of your personal information. 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 Site or the other Lena Services.

The safety and security of your data also depends on you. Where you have chosen (or we have given you) a password for access to and use of your account, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the home pages of the Site for at least 30 days. If we make material changes to how we treat our users’ personal information that are materially less protective than provided in this policy, we will use reasonable efforts to notify you by e-mail to the e-mail address specified in your account and/or through a notice on the home pages of the Site and to attempt to get your consent to the changes. The date the privacy policy was last updated is identified above. You are responsible for ensuring that we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting the Site and this privacy policy to check for any changes. Like our Terms, of which this privacy policy is a part, your continued use, and/or continued use after our efforts to contact you, of the Companion Services, the Site or any of the other Lena Services, means that you agree to be bound by such changes.

Survival

The policies indicated in this privacy policy will remain effective, even if the Terms and the other agreements between us are terminated and you are no longer using the Site or any of the other Lena Services.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices or need to reach us for any other reason, you may contact us by e-mail at support@lena.io or by mail at Bloom Circle, Inc. d/b/a Lena¸ 2450 Holcombe Blvd. Ste X, Houston, TX 77021.