PRIVACY POLICY

Sahaa Solutions, LLC (d/b/a EHR 2.0, databrackets)

Effective December 3, 2019

Protecting your private information is our priority. This “Privacy Policy” applies to databrackets.com, the databrackets mobile applications and Sahaa Solutions, LLC (d/b/a EHR 2.0, databrackets) (“databrackets”, “our”, “we” and/or “us”) and describes our data collection and usage practices. The databrackets website is an Online Assessment software as a service platform. By using the databrackets website, you consent to the data practices described in this Privacy Policy. Data you provide or make available to databrackets will also be governed by databrackets’s Terms of Use.

SECTIONS OF PRIVACY POLICY

COLLECTION OF YOUR PERSONAL INFORMATION

You may give us data about you when you: (a) set up an account with databrackets, such as your username and password; (b) access or use our website or mobile application, such as information about the organization you represent and the services provided by such organization, contact information, postal address, email address, phone number, and certain financial information (“Customer Information”); or (c) contact or correspond with us (for example via phone or email).

We may be given information about you, the organization you represent, or a third party, such as information the organization you represent provides to us when it uses services provided by databrackets or registers for an account in connection with such services.

We do not record the names or email addresses of visitors who do not register as databrackets users unless such users subscribe to receive information via electronic mail.

databrackets employs Braintree Payments™ as a payment intermediary service to receive payment from users, and do not request or store any of your financial information, such as your bank routing or account numbers, or your debit or credit card account numbers. This information is used to complete the purchase transaction.

databrackets may collect information about you such as: (a) information about your use of the databrackets services even if you are not a registered user; and/or (b) certain technical information, for example the hardware (and its unique device identifier) and operating system you use to access the website or mobile application, mobile network information and platform, your login information, your IP address, browser type and version, browser plug-in types and versions, domain names, full Uniform Resource Locator (URL), time-zone setting, access times, pages you viewed, page response times, download errors, page interaction information (such as scrolling, clicks and mouse-overs), methods used to browse away from the page and clickstream to, through, and from the databrackets website. This information is used for the operation of the databrackets services, to maintain the quality of the service, and to provide general statistics regarding use of the databrackets services.

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data through databrackets’s public message boards, this information may be collected and used by others.

databrackets encourages you to review the privacy statements of websites you choose to link to from databrackets so that you can understand how those websites collect, use, and share your information. databrackets is not responsible for the privacy practices, statements or other content on websites outside of the databrackets website.

 

USE OF YOUR PERSONAL INFORMATION

databrackets collects and uses your Customer Information and personal information to operate its website(s) and deliver the services you have requested.

With your consent, databrackets may also use your Customer Information and personal information to inform you of other products or services available from databrackets and its affiliates. databrackets may also contact you via surveys to conduct research about your opinion of current services or of potential new services that may be offered.

databrackets does not sell, rent, or lease Customer Information or personal information to third parties.

databrackets may share Customer Information and personal information with trusted business partners, suppliers, sub-contractors or agents, for example, to perform statistical analysis for improvement and optimization of the databrackets services to send you email or postal mail, to provide customer support, or to arrange for deliveries. We may also share Customer Information and personal information with our professional advisors (including our lawyers, bankers, auditors, and insurers) and our analytics and search engine providers that assist us in the improvement and optimization of the databrackets services. All such third parties are prohibited from using your personal information except to provide these services to databrackets, and they are required to maintain the confidentiality and security of your information.

databrackets may keep track of the websites and pages our users visit within databrackets, in order to determine what databrackets services are the most popular. This data may be shared with third parties in aggregated and/or anonymized form in order to deliver customized content and advertising within databrackets to customers whose behavior indicates that they are interested in a particular subject area.

 

SPECIAL CASES IN WHICH WE SHARE PERSONAL INFORMATION

databrackets may share your Customer Information and personal information with a third party in connection with a merger, sale, or acquisition, or bankruptcy.  Also, we may disclose your information to affiliated legal entities and businesses with whom we are under common corporate control.

All of our affiliated legal entities and businesses that receive your information from us will comply with the terms of this Privacy Policy with respect to their use and disclosure of such information.  Whenever your information is disclosed under this paragraph, we may also disclose such information on a non-aggregated, non-anonymous basis.

databrackets will disclose your Customer Information and personal information, without notice, only if required to do so by law, judicial or other government subpoenas, warrants, or orders. In such circumstances, you acknowledge databrackets may disclose such information to the extent necessary to comply with such legal requirements. databrackets may also disclose your Customer Information and personal information pursuant to a good-faith belief that such action is necessary to: (a) protect and defend the rights or property of databrackets; and/or (b) act under exigent circumstances to protect the personal safety of users, employees or agents of databrackets, or the public. When your information is disclosed under this paragraph, we may also disclose such information on a non-aggregated, non-anonymous basis.

 

THIRD-PARTY COMMUNICATIONS

When you are involved in a transaction as a result of your use of the databrackets services, each party involved in such transaction may obtain access to certain Customer Information or personal information, for example, the other party’s name, email address, phone number, postal address and other contact information. We cannot guarantee the privacy or security of your information when you deal with such third parties.

 

PURPOSE AND LEGAL BASIS FOR PROCESSING YOUR DATA AND CUSTOMER INFORMATION

databrackets has lawful bases to collect, use and share your Customer Information and any personal data we receive from, collect or maintain about you.  Lawful bases include your consent (as provided for in this Privacy Policy and the Terms of Use), contract (where processing is necessary for the performance of a contract with you), and other legitimate interests including, but not limited to, were processing is necessary to: (a) comply with laws that apply to databrackets; (b) protect the vital interests of a natural person, such as in an emergency or to protect you or databrackets from threats (such as security threats or fraud); (c) enable us to administer our business, such as for quality control and customer service; (d) manage corporate transactions; and/or (e) understand and improve our business and customer relationships generally.

Where we have a legal basis to use your personal data without consent, this Privacy Policy fulfils our duty to process personal data fairly and lawfully and in a manner that you would expect given the nature of our relationship with you, by giving you appropriate notice and explanation of the way in which your personal data will be used.  Where consent is required for our use of your personal data as described above, you have the right to withdraw or decline your consent and cease your use of the databrackets services.

Notwithstanding Customer Information and other data, you choose to allow other users to view and access, your Customer Information will be kept confidential and will be used to support your relationship with us.  Except as otherwise set forth in this Privacy Policy or the Terms of Use, we will not sell, rent or lease to others your Customer Information or any other personal information we receive from, collect or maintain about you.

As indicated above, if you email us, we may keep your message, email address, and contact information to respond to your message.  In certain instances, our response may be provided to other databrackets users or third parties as necessary to address certain problems, comments, and requests.

Following termination or deactivation of your account with databrackets, we may retain information, including profile information and Customer Information, in order to comply with applicable law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce our rights under our agreements with you, for backup, audit or regulatory purposes, and for other actions permitted by law. Otherwise, we will only retain your personal data for as long as reasonably necessary to fulfill the purposes we originally collected it for.  To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and applicable legal, regulatory, tax, accounting or other requirements.

 

DATA SUBJECT RIGHTS

In addition to the rights of access, correction, amendment or deletion described in the sections below, if you live in the European Economic Area (“EEA”), you may have some or all of the following rights with respect to your personal information:

(a)        to restrict processing of your personal data if the data is inaccurate, the processing is unlawful, or we no longer need it for the purpose for which we hold it;

(b)        to transmit your data (as provided by you, directly or otherwise collected by us in connection with your use of the databrackets services) in machine-readable format to you or to a third party when we justify our processing on the basis of your consent or the performance of a contract with you;

(c)        to withdraw your consent to our processing of your personal data (where that processing is based on your consent);

(d)        to obtain, or see a copy of the appropriate safeguards under which your personal data is transferred to a third country or international organization;

(e)        to object, at any time, to the processing of your personal information, on legitimate grounds, except if otherwise permitted by applicable law;

(f)        to erase your personal data (in limited circumstances, such as where it is no longer necessary in relation to the purposes for which it was collected or processed); and

(g)        to file a complaint with your local supervisory authority for data protection.

You can exercise the above rights by email sent to info@databrackets.com; or (ii) mail sent to databrackets at info@databrackets.com or mail 150, Cornerstone Drive, Ste. #202 Cary, NC 27519.

If you establish a membership account with databrackets, you may make changes to the Customer Information related to your account by accessing your account settings.

Please note that if you ask us to stop processing your personal data in a certain way or erase your personal data, and this type of processing or data is needed to facilitate your use of the databrackets services, you may not be able to use the databrackets services as you did before, or at all.  This does not include your right to object to direct marketing, which can be exercised at any time without restriction.

Please note that the rights mentioned above do not extend to non-personal data.  Please also note that it may be necessary to retain your personal data for the purposes of assessing and verifying data that is submitted to and/or processed in connection with the databrackets services, and to otherwise manage the databrackets services; your rights under applicable law may be limited accordingly.

 

INTERNATIONAL TRANSFERS

From time to time, personal information we collect from data subjects in the EEA may be transferred to, stored, processed or accessed by, us and other entities who may be based outside of the EEA, for example, the United States.  Also, we may allow our service providers or assistance providers, who may be located outside the EEA, to access your personal data.  In addition, we may make other disclosures of your personal data outside the EEA, for example, in the event we receive a legal or regulatory request from a foreign law enforcement body.

We will always take steps to ensure any transfer of such information to entities based outside the EEA is carefully managed to protect your rights and interests by implementing appropriate safeguards to protect your personal information.  Your personal data may be transferred to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. Where there is no adequacy decision by the European Commission in respect of a country (to the extent that they are outside the EEA), which means it is not deemed to provide an adequate level of protection to your personal data, we will ensure your personal data receives an adequate level of protection.  For example, each such transfer to a third party will be protected by contractual commitments and further assurances (where appropriate) such as the European Commission’s approved Standard Contractual Clauses.

If you would like to find out more about these safeguards in respect of processing your personal data, please contact us at info@databrackets.com.

 

USE OF COOKIES

The databrackets website may use “cookies” to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize databrackets pages, or register with databrackets site or services, a cookie helps databrackets to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same databrackets website, the information you previously provided can be retrieved, so you can easily use the databrackets features that you customized.

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

 

SECURITY OF YOUR PERSONAL INFORMATION

databrackets secures your personal information technical, organizational, administrative, and physical security measures designed to protect against the loss, misuse and alteration of data used by, or transmitted to or from, our system. No data transmissions over the Internet, however, are guaranteed to be completely secure.  While we strive to protect your data from unauthorized use or disclosure, databrackets does not warrant or guarantee the security of the data that you provide to us; any transmission is at your own risk.

You are responsible for maintaining the security of any password, biometrics, user ID or other forms of authentication involved in obtaining access to password protected or secure areas of any of our digital services.  In order to protect you and your data, we may suspend your use of the databrackets services without notice, pending an investigation, if any breach of security is suspected.

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol.

 

CHILDREN UNDER THIRTEEN

databrackets does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you must ask your parent or guardian for permission to use this website.

 

DISCONNECTING YOUR databrackets ACCOUNT FROM THIRD PARTY WEBSITES

You will be able to connect your databrackets account to third party accounts. BY CONNECTING YOUR databrackets ACCOUNT TO YOUR THIRD-PARTY ACCOUNT, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE CONSENTING TO THE CONTINUOUS RELEASE OF INFORMATION ABOUT YOU TO OTHERS (IN ACCORDANCE WITH YOUR PRIVACY SETTINGS ON THOSE THIRD PARTY SITES). IF YOU DO NOT WANT INFORMATION ABOUT YOU, INCLUDING PERSONALLY IDENTIFYING INFORMATION, TO BE SHARED IN THIS MANNER, DO NOT USE THIS FEATURE. You may disconnect your account from a third-party account at any time. Users can disconnect from third party sites by clicking on the disconnect button. Users may also contact us via email or telephone.

 

CONTROL, OPT-OUT & UNSUBSCRIBE

You have control over certain Customer Information and other personal information related to your use of the databrackets services.  Accordingly, you may access, review, add, modify, correct, delete or update such Customer Information or other personal information at any time.

If you receive one or more emails from us, it means one of two things: (a) your email address is on our list of customers or prospective customers, or (b) you have provided us your email address so that we could contact you.

You have the right to ask us not to collect, use, process or disclose your Customer Information in any of the manners described herein.  This will affect your user experience.  You can notify us of your intention to halt the collection, use, processing, or disclosure of your Customer Information at any time by contacting us at info@databrackets.com.

Some personal information is automatically collected via the use of data analytics tools.  If you object to such collection, your only choice is not to access the databrackets Services.

We respect your privacy and give you an opportunity to opt-out of receiving marketing communications from us at any time. Users may opt-out of receiving marketing or any and all communications from databrackets by contacting us here:

CHANGES TO THIS POLICY

databrackets will occasionally update this Privacy Policy to reflect company and customer feedback. databrackets encourages you to periodically review this Privacy Policy to be informed of how databrackets is protecting your information.

 

GOOGLE ANALYTICS

databrackets may use Google Analytics and similar web analytics services. Google Analytics is used to track unregistered users on the databrackets website, to record multiple visits by unregistered users to the databrackets website, and to record all the pages that unregistered users visit at the databrackets website. If and when an unregistered user registers with databrackets, all of his or her previous visits and activity on the databrackets website will be associated with their registered user profile. Google Analytics tracks registered users’ visits to the databrackets website whenever they return.

databrackets will not (and will not allow any third party to) use Google Analytics to track, collect or upload any data that personally identifies an individual (such as a name, address, or billing information), or other data that can reasonably be linked to such information by Google.

databrackets may use all features of Google Analytics for Display Advertisers. That includes obtaining specific visitor cookie data, such as the source, medium, and keyword used to visit the databrackets website. Google Analytics does not store any visitor specific data, and databrackets will not use specific data regarding users in any way related to Google Analytics, Google Adwords, and Remarketing.

databrackets may use remarketing with Google Adwords and analytics to display content-specific advertisements to users that have previously visited the databrackets website when those visitors go to other websites that have Google Display Network implemented.

databrackets and other third-party vendors, including Google, use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve ads based on users’ past visits to the databrackets website.

databrackets will not facilitate the merging of personally identifiable information with non-personally identifiable information that is collected through any Google advertising product or feature unless you have specifically and affirmatively provided databrackets with your consent to that merger of personally identifiable and non-personally identifiable information.

You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using Google’s Ads Settings.

You can also opt-out of Google Analytics for Display Advertising, to prevent your data from being used by Google Analytics, by going to the Google Analytics opt-out page.

 

NOTICE TO EEA DATA SUBJECTS

Please be aware your Customer Information and personal information may be transferred to, processed, and stored in a country different from your country of residence.  Data protection laws in such a country may be different from those of your country of residence.  You consent to the transfer of your information, including Customer Information and personal information, to such a country as set forth in this Privacy Policy by using the databrackets services.

 

CONTACT INFORMATION

databrackets welcomes your questions or comments regarding this Privacy Policy. Such comments or questions should be addressed to databrackets at:

Sahaa Solutions, LLC (d/b/a EHR 2.0, databrackets)
150, Cornerstone Drive
Ste. #202

Cary, NC 27519

Email Address: info@databrackets.com
Telephone number: 866-276 8309