Return to Work Terms of Service and Privacy Policy

Aduro^® RTW Terms of Service

Updated: November 25, 2020

Aduro, LLC (“Aduro”), also known as Aduro® or Aduro Life, was founded with the belief that personal technology can not only make life better, but specifically, healthier. Powered by research and behavioral science, Aduro is developing a family of health-driven products that help everyday people improve their overall wellbeing.

This is a legal agreement between you and Aduro and applies to your use of Aduro’s Return-to-Work service (including all of Aduro’s Return-to-Work website(s) and related products and services, collectively the “RTW Service”).

Please read this agreement carefully.  By using this site and our products and services, you agree to the terms of these Aduro® RTW Terms of Service (“ToS”).  If you do not agree, please do not use any of Aduro’s RTW Service.  Even if you only browse Aduro’s RTW Service and do not register, you must agree to these ToS. If you do not agree to the Terms, any use of Aduro’s RTW Service by you is unauthorized, and you should stop accessing Aduro’s RTW Service immediately. Your use of Aduro’s RTW Service will constitute your agreement to these ToS.  Registering as a user of any component of Aduro’s RTW Service will confirm your agreement to these ToS.  By checking the box to accept these ToS, you will become a registered user of the Service (a “Registered User”) and you agree to be bound by the terms and conditions of these ToS for as long as you continue to be a Registered User.

IF YOU DO NOT AGREE TO THESE ToS, PLEASE DO NOT REGISTER FOR OR USE THE SERVICE. If Aduro needs to make a material change to these ToS, we will provide notice to you by e-mail, by posting on the Aduro’s RTW Service, or by presenting you with an opportunity to confirm your agreement via checkbox. If you do not agree to any proposed changes, you may (as your sole remedy) discontinue your use of Aduro’s RTW Service and/or delete your information from our active files.

1. No Medical Advice or Diagnosis. All the contents presented in Aduro’s RTW Service (“Content) are for informational purposes only. The RTW Service and its results are not intended to provide or be a substitute for professional medical advice, diagnosis, or treatment. You should ask your doctor about any medical condition or potential symptoms. Do not disregard professional medical advice or delay seeking it because of something you have read on the RTW Service (including any result of an online symptom screening or questionnaire). If you think you need medical advice call your doctor.  If you believe you may have a medical emergency, call 911 immediately. Reliance on any information provided by Aduro, Aduro employees, others appearing on Aduro’s RTW Service at the invitation of Aduro, or other visitors to Aduro’s RTW Service is solely at your own risk.
2. Employers and Businesses & COVID-19 Potential Symptom Questionnaires.  You understand that Aduro provides the Aduro’s RTW Service in conjunction with and on behalf of employers and other businesses who desire to screen employees and other visitors to their facilities for potential COVID-19 symptoms. You understand and agree that Aduro will, as further described in its RTW Privacy Policy (available at www.adurolife.com/screening/terms), provide the information that you submit (including your name, contact information, and potential COVID-19 symptom questionnaire final result expressed as a red or green indicator, or similar binary result) through the Aduro’s RTW Service to the employer and/or other business(es) (each an “RTW Client” and collectively, “RTW Clients”) that you associate with your RTW Service account during your Aduro’s RTW Service registration process. You further agree to comply with each RTW Client‘s instructions (e.g., with respect to whether you may or may not enter their facilities) each time you submit a potential symptom questionnaire.  You further agree to (a) only enter your own information in your registered account, (b) to only use Aduro’s RTW Service to personally screen yourself for the purposes of evaluating whether you may enter an RTW Client’s facility, (c) when using Aduro’s RTW Service, to always provide truthful, accurate, and complete information, to the best of your knowledge; and (d) present only your screening result to each RTW Client facility you are required or invited to enter.
3. Data Accuracy. Data provided by Aduro’s RTW Service is not intended to be relied upon in situations where precise information is needed or where erroneous, inaccurate or incomplete location data may lead to death, personal injury, property or environmental damage. Neither Aduro, nor any of its content providers, guarantees the availability, accuracy, completeness, reliability, or timeliness of information or location data displayed by Aduro.
4. Offensive Material Warning. Aduro’s RTW Service may contain health- or medical-related materials that are offensive to some individuals. If you find these materials offensive, you may not want to use Aduro’s RTW Service.
5. Minimum Age to Use Aduro’s RTW Service. You must be 13 years or older to use Aduro’s RTW Service.  If you are not 13 years or older, please do not attempt to register as a Registered User or continue to access Aduro’s RTW Service.  The RTW Service is generally intended for use only by users 18 years or older.  Aduro’s RTW Service are not directed to children and we do not knowingly collect any personally identifiable information from children under 13 years of age through this site.
6. Consent to the Collection & Use of Data: You agree that Aduro may collect, aggregate and use personal data to deliver Aduro’s RTW Service, including but not limited to health and wellness data, technical information about your devices, system and mobile application software, and peripherals. Data is gathered automatically to help deliver Aduro’s RTW Service, facilitate the provision of software updates, product support and other related product delivery and support applications.  Aduro may use this information, as long as it is in a form that does not personally identify you, to improve its products or to provide Aduro’s RTW Service or technologies to you.
7. Personal and Exclusive Use. Your account is for your sole, personal use, you may not authorize others to use your account, and you may not assign or otherwise transfer your account to any other person or entity. You may not share your username or password with others.  No portion of Aduro’s RTW Service may be reproduced in any form or by any means. You agree not to modify, rent, lease, loan, sell, distribute, or create derivative works based on Aduro’s RTW Service, in any manner, and you shall not exploit Aduro’s RTW Service in any unauthorized way whatsoever, including but not limited to, by trespass or burdening network capacity. You further agree not to use the Aduro’s RTW Service in any manner to harass, abuse, stalk, threaten, defame or otherwise infringe or violate the rights of any other party, and that Aduro is not in any way responsible for any such use by you, nor for any harassing, threatening, defamatory, offensive or illegal messages or transmissions that you may receive as a result of using any Aduro’s RTW Service.
8. Online Conduct. The purpose of Aduro’s RTW Service is to provide wellness-related content, information and services, including COVID-19 potential symptom screening. As a Registered User, you agree that:
   1. You are solely responsible for the content or information you publish, display or otherwise communicate in any manner (hereinafter, “post”) while using Aduro’s RTW Service, or transmit to other Registered Users.
   2. You will not post on Aduro’s RTW Service, or transmit to other Registered Users, or otherwise communicate any defamatory, inaccurate, abusive, obscene, profane, offensive, sexually oriented, threatening, harassing, racially offensive, or illegal material, or any material that infringes or violates another party’s rights (including, but not limited to, intellectual property rights, and rights of privacy and publicity). Furthermore, you will not take actions to promote the physical harm or harassment of another person, engage in or promote spamming, provide information that you know is illegal, false or misleading, or designed to exploit those under 18 or otherwise provide instructional information about illegal activities including without limitation making or buying illegal weapons, identity theft, violating another’s right to privacy or providing or creating malicious computer programs (malware).
   3. You will use Aduro’s RTW Service in a manner consistent with any and all applicable local, state, national and international laws and regulations, including, but not limited to, United States export control laws. You are not located in, under the control of, or a national or resident of any country which the United States has (i) embargoed goods, (ii) identified as a “Specially Designated National”, or (iii) placed on the Commerce Department’s Table of Deny Orders. Participation in, and use of, Aduro’s RTW Service is void where prohibited.
   4. You will not provide inaccurate, misleading or false information to Aduro, the RTW Clients, or to any other Registered User. If information provided to Aduro, an RTW Client, or another Registered User, subsequently becomes inaccurate, misleading or false, you will promptly notify Aduro of such change.
   5. You will only create one unique profile with Aduro’s RTW Service.
   6. You will not engage in advertising to, or solicitation of, other Registered Users to buy or sell any products or services through Aduro’s RTW Service. You will not transmit any chain letters or e-mails that offer or promote commercial goods, services, business opportunities or the like to other Registered Users.
   7. You will not post, copy, modify, transmit, show in public or private, create any derivative works from, distribute or reproduce in any way any copyrighted material, trademarks, or other proprietary information without obtaining the prior consent of the owner of such proprietary rights.
   8. You understand that Aduro makes no guarantees, either express or implied, regarding your well-being through Aduro’s RTW Service.
   9. You will promptly report to Aduro any violation of the provisions of these ToS by other Registered Users of which you become aware.
9. Online Third-Party Content. Opinions, advice, statements, offers, or other information or content made available by third parties through Aduro’s RTW Service are those of their respective authors, and you rely on such content at your own risk. The authors are solely responsible for such content. Aduro DOES NOT: (i) GUARANTEE THE ACCURACY, COMPLETENESS OR USEFULNESS OF ANY INFORMATION ON THE SERVICE, AND (II) ADOPT, ENDORSE NOR ACCEPT RESPONSIBILITY FOR THE ACCURACY OR RELIABILITY OF ANY OPINION, ADVICE, OR STATEMENT MADE BY ANY PARTY OTHER THAN ADURO OR ITS SUBCONTRACTORS OR AGENTS. UNDER NO CIRCUMSTANCES WILL ADURO BE RESPONSIBLE FOR ANY LOSS OR DAMAGE RESULTING FROM ANYONE’S RELIANCE ON INFORMATION OR OTHER CONTENT POSTED ON THE SERVICE, OR TRANSMITTED TO OR BY ANY REGISTERED USERS.
10. Proprietary Rights. Aduro owns and retains proprietary rights in Aduro’s RTW Service. Aduro’s RTW Service contains copyrighted material, trademarks, and other proprietary information of Aduro, its licensors and licensees. Except for content that is in the public domain or for which you have been given permission to exercise specific rights, you agree not to copy, modify, publish, transmit, distribute, perform, display, or sell any such proprietary information.  The name “Aduro” and the Aduro Logo, and other trademarks that may be used on Aduro’s RTW Service, are trademarks of Aduro or its affiliates and may not be used in connection with the products or services of others in any manner that is likely to cause confusion. All other trademarks not owned by Aduro that appear on this site are the property of their respective owners.
11. General Privacy. Aduro takes commercially reasonable precautions to protect your information, as described in the Aduro RTW Privacy Policy. Users of the RTW Service expressly agree to the terms set forth in the Aduro RTW Privacy Policy, which describes how we may collect, use or disclose your information when you use Aduro’s RTW Service.
12. Security Obligations; Passwords and Control. You are responsible for taking all reasonable steps to ensure that no unauthorized person has access to your passwords or accounts. It is your sole responsibility to: (1) create and use complex passwords; (2) use only unique passwords that you have not used before and do not use on other systems; (3) regularly change your password; (4) control the dissemination and use of your login credentials (i.e., username and password); (5) authorize, monitor, and control access to and use of your activation codes and passwords; (6) promptly change your password if you become aware or suspect that your password has been compromised in any way; and (7) promptly inform Aduro and, if applicable, your third party service provider, of any need to deactivate a password and/or username. You agree that you are responsible for all use of your Account, including your login credentials (i.e., username and password) and activation codes and passwords. Aduro treats access to the Aduro Services through your account credentials as authorized by you.  It is your sole responsibility to terminate your session on Aduro’s RTW Service when completed to prevent unauthorized access and to secure devices on which you access Aduro’s RTW Service through additional layers of password or other protection (especially in the case of mobile devices). You grant Aduro and all other persons or entities involved in the operation of RTW Service the right to transmit, monitor, retrieve, store, and use your information in connection with the operation of Aduro’s RTW Service. Aduro cannot and does not assume any responsibility or liability for any information you submit, or your or third parties’ use or misuse of information transmitted or received using Aduro tools and services.
13. Disclaimer of Warranties. ADURO PROVIDES THE SERVICE ON AN “AS IS” BASIS AND GRANTS NO WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY OR OTHERWISE WITH RESPECT TO THE RTW SERVICE.  ADURO SPECIFICALLY DISCLAIMS ANY IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE OR NON-INFRINGEMENT.  Aduro does not warrant that your use of Aduro’s RTW Service will be secure, uninterrupted, always available, error-free or will meet your requirements, or that any defects in RTW Service will be corrected. Aduro DISCLAIMS LIABILITY FOR, AND NO WARRANTY IS MADE WITH RESPECT TO, THE CONNECTIVITY AND AVAILABILITY OF THE SERVICE.
14. Limitation of liability and exclusion of certain damages.
    1. IN NO EVENT SHALL ADURO BE LIABLE FOR ANY INCIDENTAL, SPECIAL, CONSEQUENTIAL OR INDIRECT DAMAGES ARISING OUT OF OR RELATING TO THE USE OR INABILITY TO USE THE RTW SERVICE, INCLUDING, WITHOUT LIMITATION, DAMAGES FOR LOSS OR CORRUPTION OF DATA OR PROGRAMS, SERVICE INTERRUPTIONS AND PROCUREMENT OF SUBSTITUTE SERVICES, EVEN IF ADURO KNOWS OR HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES.
    2. UNDER NO CIRCUMSTANCES WILL ADURO’S AGGREGATE LIABILITY, WITH RESPECT TO ANY FORM OF ACTION WHATSOEVER UNDER ANY LEGAL THEORY ARISING OUT OF OR RELATING TO THESE TOS OR THE RTW SERVICE, EXCEED THE PRICE PAID BY YOU FOR YOUR USE OF THE RTW SERVICE.
    3. IN NO EVENT SHALL ADURO BE LIABLE FOR ANY DAMAGES WHATSOEVER, WHETHER DIRECT, INDIRECT, GENERAL, SPECIAL, COMPENSATORY, CONSEQUENTIAL, OR INCIDENTAL, ARISING OUT OF OR RELATING TO THE CONDUCT OF YOU OR ANYONE ELSE IN CONNECTION WITH THE USE OF THE RTW SERVICE, INCLUDING WITHOUT LIMITATION, BODILY INJURY, EMOTIONAL DISTRESS, AND/OR ANY OTHER DAMAGES RESULTING FROM THE ACTS OR OMISSIONS OF OTHER REGISTERED USERS OF THIS SERVICE, ANY RTW CLIENT (INCLUDING YOUR EMPLOYER), OR ANY DOCTOR OR OTHER HEALTH CARE PROFESSIONAL USING OR RELYING UPON THE RTW SERVICE. YOU AGREE TO ASSUME THE RISK OF YOUR INTERACTIONS WITH ANY THIRD PARTIES THROUGH THE SERVICE.
    4. SOME STATES OR OTHER JURISDICTIONS DO NOT ALLOW THE EXCLUSION OFR LIMITATION OF LIABILITY FOR CERTAIN DAMAGES, SO THE ABOVE LIMITATIONS AND EXCLUSIONS MAY NOT APPLY TO YOU. THE LIMITATIONS AND EXCLUSIONS SET OUT IN THIS SECTION 14 APPLY TO THE EXTENT PERMITTED UNDER APPLICABLE LAW.
15. Indemnity by Registered User. You agree to indemnify, defend and hold harmless Aduro and its officers, directors, agents and employees from and against all fines, suits, proceedings, claims, causes of action, demands, or liabilities of any kind or of any nature, including attorneys’ fees, arising out of or in connection with your use of Aduro’s RTW Service, including any breach by you of the terms of this Agreement.
16. Complaints. To resolve a complaint regarding Aduro’s RTW Service, you should first contact Aduro via email at [email protected].
17. Account Termination. Either you or Aduro may terminate your account at any time, for any reason or no reason, without explanation or notice. Aduro reserves the right to immediately suspend or to terminate your access to Aduro’s RTW Service, without notice, if in Aduro’s sole discretion it believes you have violated any provision of these ToS which is brought to Aduro’s attention. In the event your access to Aduro’s RTW Service is suspended due to the breach of this Agreement, you agree that all fees then paid to Aduro by you, if any, shall be nonrefundable. Following any termination hereof, Aduro reserves the right to send a notice that you have been terminated to your employer and/or each RTW Client whose premises you have accessed by using Aduro’s RTW Service.
18. Links to Other Web Sites. The RTW Service may contain links to other websites that we think may be of interest to you. We do not endorse or sponsor any third-party websites or the information, products, or services contained on any third-party websites and we have no control over third party websites or their content. Remember that when you link to another site, that other site is governed by its own user agreement and privacy statement, which you should be sure to read. Access to and use of any third-party website is solely at your own risk.
19. Aduro’s RTW Services Availability and Support. You may access Aduro’s RTW Service if and when it is available. We do not guarantee availability of Aduro’s RTW Service or of materials on Aduro’s RTW Service at all times of the day. Without notice to you, Aduro’s RTW Service may occasionally be unavailable for service, upgrades, or for other reasons. We reserve the right to change, remove, delete, restrict, block access to, or stop providing any or all of Aduro’s RTW Service at any time and without notice. Except as may be provided in our customer agreements with RTW Clients, we have no obligation to provide support in relation to Aduro’s RTW Service.
20. Governing Law; Dispute Resolution. You agree that Washington State law, regardless of its conflicts of law principles, shall govern this Agreement, and that any dispute arising out of or relating to this Agreement shall be subject to the exclusive jurisdiction of the federal and state courts in the Western District of Washington, other than for actions to enforce any order or judgment entered by such courts.  These ToS, together with Aduro’s RTW Privacy Policy contain the entire agreement between you and Aduro regarding the access to and use of the RTW Service. Unless otherwise explicitly stated, these ToS will survive termination of your registration to Aduro’s RTW Service. If any provision of this Agreement is held invalid, the remainder of this Agreement shall continue in full force and effect.  YOU AGREE THAT ANY CAUSE OF ACTION ARISING OUT OF OR RELATED TO THE RTW SERVICE MUST COMMENCE WITHIN ONE (1) YEAR AFTER THE CAUSE OF ACTION ACCRUES; OTHERWISE, SUCH CAUSE OF ACTION IS PERMANENTLY BARRED.
21. Notice Regarding RTW Client’s “Return to Facility” Programs and “Building Entry Screening” Programs. Your employer or the business managing certain facility(s) (i.e., RTW Clients) may, as part of their operations, require their employees or other visitors to complete a potential COVID-19 symptom screening before entering their facilities and may require that their employees and visitors use Aduro’s RTW Service to do so. You understand that, as between Aduro and each RTW Client, the RTW Client is solely responsible for selecting, developing, implementing, managing, and enforcing such processes, practices, procedures, and rules (collectively, “Return-to-Facility Plans”).  If you have any questions or comments about any aspect of a Return-to-Facility Plan, you agree to direct them to the applicable RTW Client.
22. Protections from Disclosure of Medical Information. We maintain the privacy and security of your personally identifiable health information, as further described below and in our RTW Privacy Policy. When you complete a potential COVID-19 symptom screening via Aduro’s RTW Service, your final result (“Final Result”) will be expressed as a binary result (e.g., Red or Green, Go or No Go, etc.). Although, each time you complete such a screening, this Final Result will be shared with the RTW Client associated with your account, none of your answers to the screening questions (e.g., body temperature, exposure to someone diagnosed with COVID-19, presence of a cough, etc.) will be provided to an RTW Client. In general, your name, contact information, time and date of screening, and the Final Result will be provided to the RTW Client associated with your account for the purposes of their internal operations.
    1. Your personally identifiable health information will not be sold, exchanged, transferred, or otherwise disclosed except to the extent permitted by law (a) to carry out specific activities related to the RTW Service (as provided by Aduro to you and also to the applicable RTW Clients) and for an applicable RTW Clients’ internal operations, (b) for Aduro’s legitimate, internal business operations, or (c) as necessary to comply with  applicable law, regulation, court or government agency order, or a request from a public health official. 
    2. If you have questions or concerns regarding this notice, or about protections against discrimination and retaliation, please contact your employer.
23. Modifications to these ToS. We may modify these terms or any additional terms that apply to the RTW Service to, for example, reflect changes to the law or changes to Aduro’s RTW Service. You should look at the terms regularly. We’ll post notice of modifications to these ToS on this page. Changes will not apply retroactively and will become effective no sooner than one business day after they are posted. However, changes addressing new functions for the RTW Service or changes made for legal reasons will be effective immediately. If you do not agree to the modified terms for the RTW Service, you should discontinue your use of Aduro’s RTW Service.
24. Miscellaneous. These ToS control the relationship between Aduro and you with respect to Aduro’s RTW Service. They do not create any third-party beneficiary rights.  If you do not comply with these terms, and we do not act right away, this does not mean that we have waived any rights that we may have (such as taking action in the future).  If it turns out that a particular term of these ToS is unenforceable, this will not affect any other terms of these ToS.

If you have any questions or concerns about these Terms of Service, please feel free to contact us.

Aduro, LLC | 17425 NE UNION HILL ROAD, SUITE 100 | Redmond WA 98052 | [email protected]

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Aduro^® RTW Service Privacy Policy

Updated: July 23, 2020

Aduro, LLC (“Aduro,” “we,” “us,” or “our”) is dedicated to helping individuals enhance their well-being and achieve their goals. As a part of this mission, we have developed our infectious disease(s) symptom screening services, generally referred to as our Return-to-Work Service. Organizations can utilize these services to help maintain a safe environment at their facilities and workspaces. Similar to most businesses, we collect and use information from individuals who use our services, including our Return-to-Work Service (“RTW Service”).

We take individuals’ privacy seriously and act to respect privacy. In some situations, we might share information with other businesses to enable them to provide services to us, but our service providers are permitted to use individuals’ personally identifiable information only to support our business, not for other purposes, and we do not sell such personal information to third parties.

Our privacy practices are explained in greater detail in this RTW Privacy Policy (“Policy”), which we have prepared to inform users (“you” or “your”) about what information we collect about you, how we may use or disclose your information, and your rights to make requests about your information. This Policy applies to information collected through our RTW Service (including all websites and subdomains used to provide Aduro’s Return-to-Work services, as well as email, web-based, or telephone customer support or Help Desk support). 

Information that you may provide to us via our website, adurolife.com, and our site’s sub-domains (individually a “Site” and collectively “Sites”), and through other communications with us will be subject to our general Privacy Policy, available at https://adurolife.com/privacy-policy/.

Additionally, this Policy does not address information that is collected from individuals as part of their participation in an employer-sponsored human performance or wellness plan (“Wellness Plan”) operated on an Aduro platform, private labeled product variants, the Aduro mobile applications for iPhone OS and Android OS (each an “App” and together the “Apps”), and information collected through third party health, fitness, productivity or other applications (including from wearable devices), and from or through your health plan and its contractors.  To learn about our privacy practices specifically regarding information collected and used through these applications as part of a wellness plan under the Health Insurance Portability and Accountability Act (“HIPAA”), please review our Privacy Policy located available at https://adurolife.com/privacy-policy/.

1.  Policy Scope

Again, this Policy describes Aduro’s policies and procedures concerning the collection of personal information from individuals who use or receive our RTW Service. This Policy does not apply to our collection or processing of the personal information of individuals as part of their participation in a wellness plan operated on an Aduro platform. For our policies and practices regarding that type of information, please review our Privacy Policy located available at https://adurolife.com/privacy-policy/.

Although we might link to third-party websites, software, or services, this Policy applies only to our services. Please refer to the privacy policies on any third-party websites, software, or services to learn how they use your personal information. We encourage you to read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. We understand your use of the RTW Service to mean that you accept and consent to the use of your information as described in this Policy and that you likewise agree to our Aduro^® RTW Terms of Service (available at www.adurolife.com/screening/terms).

Limited Application of California Consumer Privacy Act. The RTW Service is limited to the collection of personal information of employees of organizations that have engaged our RTW Service (“Employee Personal Information”) and of individuals who have a business relationship with the organizations utilizing our RTW Service (“B2B Personal Information”). Because the information collected through the RTW Service is limited to Employee Personal Information and B2B Personal Information, certain provisions of the California Consumer Privacy Act (“CCPA”) do not apply to the collection and use of personal information through the RTW Service. Accordingly, this Policy does not include explanations of certain rights and procedures provided in the CCPA (e.g., consumer rights of access or deletion). If you have questions about the Policy, please contact us at [email protected].

2.  Our Relationship with Employers and Organizations Acting in Other Capacities.

Aduro provides its RTW Service to both individuals and organizations. To use the RTW Service, you will need to associate your account with at least one organization, either your employer or another organization whom you desire to visit and who has requested that you use the RTW Service prior to entering their facilities. You will associate your account (e.g., by entering a code or scanning a QR code provided by such organization) with your selected organization(s) when you (a) register your RTW Service account, (b) check-in at such organization’s facility, or (c) use another method (of associating your account) that is provided within the RTW Service.  Each Organization that you associate with your RTW Service account in this manner is referred to in this RTW Privacy Policy as an “RTW Client” and collectively they are referred to as the “RTW Clients”.  Aduro provides the RTW Service to individuals on behalf of RTW Clients.

3.  Summary of How We Use Your Personal Information

The table below lists categories of information we collect, how we use such information, and with whom we might share such information. In Section 4 of this Policy following this table, we explain in further detail the categories of information we collect.

How We Use Personal Information Collected

Information Type	How We Use It	Who We Share It With
User information (e.g., user contact information, user identifiers, user comments, etc.)	(1) to provide our products and services to you and RTW Clients associated with your account (2) to communicate with you about our products and services (3) to authenticate you and tailor content(4) to improve our products and services and create new products and services (5) for our internal accounting, security, and operational purposes (6) for purposes required by law	(a) with our service providers, including analytics providers, to help us deliver and improve our products and services (b) with RTW Clients associated with your account (c) with your employer’s Wellness Plan (only if your employer is an RTW Client and also operates an Aduro-supported Wellness Plan for which you are eligible) (d) our affiliates
Business account contact information (e.g., business name, position, telephone number, address, email, etc.)	(1) to provide our products and services to you (2) to communicate with you about our products and services (3) to authenticate you and tailor content (4) to improve our products and services and create new products and services (5) for our internal accounting, security, and operational purposes (6) for purposes required by law	(a) with our service providers, including analytics providers, to help us deliver and improve our products and services (b) with RTW Clients associated with your account (c) with your employer’s Wellness Plan (only if your employer is an RTW Client and also operates an Aduro-supported Wellness Plan for which you are eligible) (c) with business partners and resellers for support and our marketing purposes (d) our affiliates
Usage information (e.g., indicators of engagement with our website or usage of the RTW Service, IP address, device identifier, etc.)	(1) to improve our products and services and create new products and services (2) to better understand how our users use our services (3) for our internal accounting, security, and operational purposes (4) for purposes required by law	(a) with our service providers, including analytics providers, to help us deliver and improve our products and services (b) our affiliates

4.  Information We Collect

In general, the information we collect is of two types: (a) User Information (including symptom and other health data) and (b) Usage Information. We also collect business account information from some persons under the circumstances described below. Below is explanation of the categories of information we collect, including information collected in the last 12 months. Again, as explained above in Section 1, our RTW Service is limited only to the collection of Employee Personal Information and B2B Personal Information.

User information. “User Information” refers to information collected about users of the RTW Service and includes Personally Identifiable Information (“Personal Information”), which is information that can be used to identify an individual, such as an your name, email address, residential or mailing address, telephone number, online identifier, age or date of birth, employer or business affiliation, and job title. It also might include comments or questions you share with us.  If you contact our customer support or “Help” service, the User Information we collect will also include transcripts or recordings of your communications with our customer support or Help desk. 

Personally Identifiable Health-Related Information.  “Personally Identifiable Health-Related Information” refers to information that we collect that is personally identifiable to you and that also relates specifically to your health (i.e., all of your answers to a potential COVID-19 screening questionnaire/survey that are used to determine the final result of that screening, such as your body temperature, recent exposure to someone diagnosed with COVID-19, or any other typical symptoms (e.g., cough, difficulty breathing, and the like)). “Personally Identifiable Health-Related Information” also includes the final, binary result of any such screening (“Final Result”), which is typically expressed as Red/Green (or other similar binary result). “Personally Identifiable Health-Related Information” does not include information that has been anonymized or aggregated such that it no longer identifies you as an individual and cannot be combined with other information to readily identify you (or as otherwise required by applicable law).

Usage Information or Automatically Collected Information. “Usage Information” or “Automatically Collected Information” refers to information that we collect automatically when you use or interact with the RTW Service. This includes or can relate to your Personal Information. Usage Information may include your IP address or other device identifiers, the type of browser, device, or operating system a user employs, the URL that referred users to our website, how and when users interact with our website, and other similar information. In particular, we collect information about the manner in which our Sites are used, the devices on which they are used, and our website’s performance. Depending on your device or browser privacy settings, Usage Information or Automatically Collected Information can include location data, such as geographic information regarding the location of the accessing device. If we combine Usage Information with User Information, we will treat the combined data as User Information.

We use Usage Information or Automatically Collected Information internally to help us improve your experience on the RTW Service, including to create your profile and profiles of our users generally. We use the profiles and records to analyze trends, administer the RTW Service, track movements in the aggregate, and gather broad aggregate demographic information.

To do this, we use cookies and similar technologies, such as web beacons, to help us collect this information. Cookies are small computer files that we transfer to your computer’s hard drive that allow us to know how often you use the RTW Service and what activities you conduct on our RTW Service platform. Internet browser software generally can be set to reject all cookies, and most browsers offer instructions on how to reset the browser to reject cookies. If you reject our cookie, certain functions and conveniences we automatically provide for you on Aduro’s RTW Service may not work, but you do not have to accept our cookie to use these services. Similarly, web beacons are tiny graphic image files embedded in a web page or email that send information from your browser back to Aduro’s, or its service provider’s, server. We use the information cookies and web beacons collect to statistically monitor how many people are using our RTW Service or opening our emails.

Your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of cookie information. To completely “opt out” of the collection of any information through cookies or other tracking technology, you must manage the settings on your browser to delete and disable cookies and other tracking/recording tools. However, getting a “Do Not Track” signal to work as you might want is difficult. For example, not all tracking technologies can be controlled by browsers, and unique aspects of your browser might be recognizable even if you disable a tracking technology. In addition, not all settings will necessarily last or be effective, and even if a setting is effective for one purpose, data still may be collected for another. Even if one website observes a “Do Not Track” signal, that website usually will not be able to control other websites.

5. Methods for Collecting User Information. For information that is not automatically collected, you will be prompted to provide certain categories.

• Required Information. To provide the RTW Service – as well as support help inquiries – we require users to provide certain categories of information, such as your name, employer name, job title, a working email address, and a working telephone number. In certain cases, we may ask for other Personal Information such as name and date of birth. Further, to complete a potential COVID-19 symptom screening via the RTW Service, you will need to provide certain health-related information, such as current body temperature, recent possible exposure to someone diagnosed with COVID-19, and the presence of certain possible other symptoms (e.g., coughing, difficulty breathing, and the like). We use the Personal Information that you provide through registration to provide the RTW Service to you, your employer, and/or any other organization that you have identified within the RTW Service for desired access to their facilities.  We also may use the Personal Information to deliver relevant content and respond to questions from you, and/or inform you of material changes to this Privacy Policy. You can opt-out of receiving email or messages by making an unsubscribe request.

• Other Sources. We may also receive information about you from other sources.  We may collect personal information from you when you register to learn more about our products or services, provide comments and suggestions, sign up for newsletters, order Apps, products or services, request and utilize maintenance and support services, request white papers, sign up for events or seminars, submit content or send us feedback.  If you contact our customer support or sales leads on the telephone, we may collect User Information from you during your call to provide our services to you.  If you do not want us to collect this information, please do not provide it, but you may not be able to take advantage of our RTW Service or certain features of our RTW Service. 

6.  How We Use the Information We Collect

We use your Personal Information for a number of purposes that we believe to be consistent with your expectations when you interact with us and our RTW Service:

• To provide the RTW Service and support. We use your Personal Information to provide and manage the RTW Service, communicate with you about our RTW Service, and fulfill any contractual obligations we otherwise have with you or your employer (or other organization that you have identified in the RTW Service for such purposes. In addition, we use your personal information to support your use of the RTW Service and to ensure the quality and security of the RTW Service.
  • In response to inquiries or requests, we use your Personal Information to provide reports, information about our RTW Service, educational services, customer support, or other support services.
  • We may also use your personal information to provide you updates, notices, and security alerts along with support and administrative messages. 
  • We may record calls for support and keep records of your communications and ours to provide and improve customer service to you and others. 
  • We also use Personal Information to manage any account or profile created and to verify your identity.
  • We use your Personal Information to provide relevant product and service information via our websites, email, and telephone calls or voicemails.
  • We may also use your information to customize your interaction with our websites and carry out any other purpose for which you provided us with your personal information (subject to applicable data protection laws).

• Prevent improper or illegal activity.  We use Personal Information to protect, investigate, and deter against fraudulent, unauthorized, or illegal activity on or relating to our RTW Service, our platforms, and our other computer and network systems.

• To meet legal requirements. We may be required to use or discloses your Personal Information when necessary to comply with legally mandated reporting, subpoenas, court orders, or other legal process requirements (including, without limitation, as necessary to comply with the request of a public health authority having jurisdiction).

• To market and improve our products and services and to create new products and services. We use your Personal Information to:
  • conduct marketing activities to inform you about our products, services, and events; provided that we will not use your personally identifiable health-related information for such purposes.
  • conduct surveys about our RTW Service and your use of our RTW Service. 

• Administrative Notices. Aduro reserves the right to send you specific administrative notices about the RTW Service or to contact you if required by law. You may not opt-out of these kinds of communications.

• Emails and Newsletters: You may have the option of receiving emails, SMS texts, voice IVR messages and/or newsletters directly from Aduro. You may elect to opt-out of these communications by using one of the options we provide for opting out, such as clicking an unsubscribe link, responding unsubscribe, or placing a check mark beside a statement stating you do not want to receive these communications or to participate in these activities. 

• Analytics. Further, we may use information for analytics purposes and to operate, maintain and improve our products and services.  We may also use information to create new products and services.

• Aggregated and Anonymous Data.  We may anonymize and/or aggregate your Personal Information to create anonymous and aggregate data, which we may then use to create and publish white papers and reports or for any other lawful purpose.

• Other purposes. Except for your Personally Identifiable Health-Related Information, we may use your information for any other legal, business or marketing purposes that are compatible with this Policy.

7. How We Share Your Information with Other Parties.  Unless we receive your permission, Aduro will not sell, rent, or share your Personal Information to or with any third party not affiliated with or owned by Aduro, with the following exceptions:

• RTW Clients and Their Contractors.   As described above, Aduro provides the RTW Service to individuals on behalf of the RTW Clients. Thus, Aduro will provide your User Information, including each of your Final Results (but not your other Personally Identifiable Health-Related Information used to determine the Final Result), to each RTW Client that you associated with your account specifically for such RTW Client’s internal use in managing, improving, and operating its facilities, human resource, and similar internal administrative functions. Similarly, RTW Clients may request that Aduro provide this data to their contractors (“RTW Client Contractors”) solely to enable these contractors to provide the RTW Client with services that support such RTW Client functions. RTW Client Contractors will be subject to contractual restrictions and conditions between them and Aduro (and/or the RTW Client) that obligate them to safeguard the User Information and restrict them from using it in any way other than to provide such services to the RTW Client.

• Service Providers. Aduro may disclose your Personal Information to other businesses that support our provision of the RTW Service. These organizations range from the businesses that power and host parts of the RTW Service to firms that assist us with marketing communications and messaging interfaces, for example. We will disclose Personal information to these service providers only as necessary to enable them to provide the product or service, subject to contractual restrictions and conditions between Aduro and these Service  Providers that obligate them to safeguard the Personal Information and restrict them from using it in any way other than to provide services to us. Aduro will ensure that any agent, contractor, or other service provider with whom we share Personal Information agrees to safeguard it in a manner consistent with this Privacy Policy, but in any event in accordance with all applicable laws and regulations. Some of our service providers may be located outside of your country of residence, including in the United States of America, Canada, New Zealand, Australia and other countries from time to time. While outside of your country or residence, Personal Information will be subject to applicable foreign laws which may permit government, national security and regulatory authorities to access your Personal Information in certain circumstances.

• Transfer or Assignment in Connection with Business Transfers or Bankruptcy. In the event of a business transition, such as a merger, acquisition, reorganization, bankruptcy or other sale of all or a portion of our assets, any information owned or controlled by us may be one of the assets transferred to third parties. Aduro shall provide notice of such a business transition via prominent notice on our Sites.  We reserve the right, as part of this type of transaction, to transfer or assign your information and other information we have collected from customers and users of the RTW Service to third parties. Other than to the extent ordered by a bankruptcy or other court, or as otherwise agreed to by you, the use and disclosure of all transferred information will be subject to this Policy. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity in compliance with applicable laws and regulations.

• Response to Subpoenas, Public Health Authorities, or Court Orders; Protection of Our Rights; Safety. As required or permitted by law, regulation, legal process or other legal requirement, or when we believe in our sole discretion that disclosure is necessary or appropriate, to respond to an emergency or to protect our rights, protect your safety or the safety of others, investigate fraud, comply with a judicial proceeding or subpoenas, court order, public health authority, law-enforcement, or government request, including without limitation to meet national security, public health and safety, or law enforcement requirements, or other legal process and to enforce our agreements, policies and terms of use.

• Publicly Posted Content. If you post comments, images, and other content to a location which is public-facing, including any public-facing websites, Apps, storage locations, or social media, your posted information will be publicly viewable.

• With Your Consent. We may share some or all of your information to any other third party with your affirmative consent. With your consent we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at the address shown at the top of this policy.

• Anonymized or Deidentified Data.  We may share information that has been anonymized or deidentified with others for their own uses, in accordance with applicable laws and regulations.

8.  Personal Information of Children Under 13

The RTW Service is not directed to children, and we do not knowingly collect any Personal Information from children under 13 years of age through the RTW Service. If you think we have collected Personal Information from a child under 13 years of age for whom you are the parent or guardian, please contact us at the notice address provided below.

9.  Security

Aduro maintains administrative, physical, and technical safeguards to reasonably and appropriately protect the confidentiality, availability, and integrity of your Personal Information. For example, the file containing your Personal Information will be maintained in secure locations at our offices or on our servers (or those maintained by our service providers) with access limited to authorized employees, representatives and agents. Our employees receive training on our security practices and obligations. We encrypt sensitive data, such as Personal Information, using SSL or VPN when it is transmitted over the Internet and when it is stored on our servers and backup systems.  Our systems are configured to provide encryption for email when received by compatible systems; however, we cannot completely ensure the privacy of email to and from Aduro because we do not control all systems and software used within any given email transmission (end-to-end). You may be able to determine whether your emails with Aduro will be encrypted by asking your email provider whether their systems are configured for opportunistic TLS and checking the settings on your email software.

Given the nature of the Internet and the fact that network security measures are not infallible, we cannot guarantee the security of your Personal Information. In the event we become aware of a data security breach, we will provide you with notice as required by applicable federal, provincial and state laws. To the extent permitted by applicable law, Aduro will provide any such notice to you at the email address you provide with your registration, as updated from time to time. By using the RTW Service, you agree to accept such notice electronically.

Compliance with our security policies is periodically audited by our Chief Security Officer and we continually assess the adequacy of, and where appropriate improve, our security controls and procedures. Aduro employees and our third-party service providers must abide by this policy and those who violate it are subject to corrective action, up to and including termination of employment or other legal action as permitted by law.

When registering for access to a secure area of the RTW Service, you will need to select a username and password. As explained above, your “username” is a unique set of characters (alphabetic, numeric, and special characters) that you choose to identify you on the RTW Service upon registration. We encourage you to select a username that does not, by itself, identify you to others and to keep the username confidential because we may use the username to make various communications to individuals participating in programs available through the RTW Service. We likewise recommend you do not divulge your password to anyone so that others cannot access your Personal Information. We will never ask you for your password in an unsolicited phone call or in an unsolicited email.

You should sign out of the registered RTW Service and close your browser window when you have finished using the RTW Service so others cannot access your Personal Information and correspondence by using your desktop or laptop computer. If you access the RTW Service through the use of a smartphone or other mobile device, we expect you to use the security controls available on your device (such as setting a confidential password) to prevent unauthorized individuals from accessing your information. We further recommend that you terminate each session to reduce the risk of inappropriate access. If you remain continuously logged in, you assume the risk that unauthorized individuals may be able to access your information.

You should notify us promptly if you suspect someone has obtained unauthorized access to your Personal Information.

If you have any questions about the security at our Site, you can send a message to member support at [email protected].

10.  Notification of Changes

If we change this Policy, we will post the updated Policy and its effective date on this page, and we may post a notice on the Site’s main page and other pages to alert you about the change.

If the Privacy Policy changes materially so that we are going to use your Personal Information in a manner different from that stated at the time of collection, we will notify you by either sending you an email or by posting a notice on the Site’s main page. We reserve the right to make the changes to the Privacy Policy applicable to all previously collected Personal Information.

11.  Contact Information – Questions and Direct Marketing

Please contact us using the contact information listed below if you:

• Have a query or concern about this Privacy Policy or our Personal Information handling processes;
• Wish to make a complaint in relation to a breach of your privacy by Aduro; or
• Would like to opt out of direct marketing.

We will promptly investigate and respond.

Aduro, LLC
17425 NE Union Hill Road, Suite 100
Redmond, WA 98052
Attention: CTO/CPO
[email protected] Aduro will seek specific permission from you for any uses or disclosures not specified in this Privacy Policy. If you have not opted into receiving direct marketing from Aduro, Aduro will not send you direct marketing.