Privacy Policy

Xolv Technology Solutions™, LLC (“Company“, “we” or “us”) respect your privacy and are committed to protecting it through our compliance with this Privacy Policy (“Privacy Policy“).  Please carefully read this Privacy Policy, as it describes our policies and practices regarding your information, and the type of information that we may collect from you or that you may provide the Company.

By downloading, registering with, or using the myBrightlink app (the “App“), you acknowledge and accept this Privacy Policy and are subject to its terms.  If you do not agree with our policies and practices, do not download, register with, or use the App.  This Privacy Policy may change periodically.  Your continued use of the App after we revise this Privacy Policy means you accept those changes, so please check this Privacy Policy periodically for updates.  The date this Privacy Policy was last revised is identified at the top of the page.

The App may include links to third-party websites, plug-ins, and applications (such as https://www.xolv.org/).  Clicking on those links or enabling those connections may allow third parties to collect or share data about you.  We do not control these third-party websites and are not responsible for their privacy statements.  You should check the privacy policies or terms of service for such other websites or applications.

If you are using the App on behalf of someone other than yourself, you represent that you are authorized by such individual to act on their behalf and that such individual acknowledges the practices and policies outlined in this Privacy Policy.

Scope of This Policy

This Privacy Policy details (i) the types of information we may collect or that you may provide us when you download, install, register with, access, or use the App; and (ii) our practices for collecting, using, maintaining, protecting, and disclosing such information.

This Privacy Policy does not apply to information that:

• We collect offline or on any other Company apps or websites, including websites you may access through the App.
• You provide to or is collected by any third party.
• Is collected from you by your health plan or health insurer, the Behavioral Health Provider Network, or any behavioral health care provider you or a relative may engage.

Our websites, other apps, and linked third parties are not governed by this Privacy Policy and may have their own privacy policies, which we encourage you to read before providing information on or through them.

Children Under the Age of 18

We do not direct our App to individuals under 18 years of age.  Personal Information (defined below) regarding individuals under 18 years of age is meant to be collected through a parent or guardian over 18 years of age.  If you become aware that your child has provided their Personal Information through the App, please contact us at the contact information provided at the end of this Privacy Policy.  If we obtain actual knowledge that we have collected Personal Information through the App from a person under 13 years of age without the consent of a parent or guardian, we will delete such Personal Information.

Information We Collect and How We Collect It

When you use the App, we collect certain information from and about you, including Personal Information.  “Personal Information,” as used in this Privacy Policy, means information that identifies you or can be reasonably linked to information that identifies you or may be specifically defined in the jurisdiction in which you reside.  As explained in further detail below, information is collected from and about users of our App in a variety of ways, including:

• Directly providing information to us either from you or a member of your household.
• Automatically when you use the App.
• From records held by Catalight Care Services, but only when you authorize us to have access to such information.

We collect the following categories of Personal Information:

• Identifiers: Name (including caregiver name), initials, address, phone number, email address, account identifier, and device or online identifiers.
• Demographic Information: Gender, age, date of birth, and language preferences.
• Sensitive Information: Medical and health information, such as physical or psychological state of health, clinical data, medical conditions, disease state, medical history, medical treatment or diagnosis by a healthcare professional, and medical chart history (including labs, vitals, and chief complaints for current and past visits).
• Location Data: Precise geolocation data.
• Audio, Visual, and Other Sensory Information: Images and videos you may post.

If you provide Personal Information to us about someone else (such as a child or family member), you acknowledge and affirm that you are authorized to disclose that information to us and that, without taking any further steps, we may collect, use, store, and disclose that information as described in this Privacy Policy, as if it were disclosed to us directly by such other person.

Information You Directly Provide to Us

Depending on the services and features of the App you use, we collect Personal Information from you in various ways, including when:

• You authorize information you provide to Catalight Care Services to be integrated into the App.
• You fill in forms in the App, including at the time of registering to use the App, subscribing to our service, and posting material and requesting further services.
• You directly input or revise Personal Information on the App.
• You reporting a problem with the App.
• You contact us or other users, we record and retain your correspondence (including in-app communications with other users or the Company).
• You respond to surveys that we might ask you to complete for research or other purposes.
• You complete transaction through the App so that we can process and fulfill your requests.
• You search queries on the App.

You may also decide to provide your Personal Information for publication or display (“Posted“) on public areas of websites you access through the App maintained by Xolv or Catalight Care Services (collectively, “User Contributions“).  Your User Contributions are Posted and transmitted to others at your own risk.  Please be aware that no security measures are perfect or impenetrable.  Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions.  Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Automatically

When you download, access, and use the App, it may use technology to automatically collect:

• Usage Details:When you access and use the App, we may automatically collect certain details of your access to and use of the App, including traffic data, logs, and other communication data and the resources that you access and use on or through the App.
• Device Information:We may collect information about your mobile device and internet connection, including the device’s unique identifier, the make and model of the device’s IP address, operating system, browser type and language, mobile network information, the device’s telephone number, dates and time stamps for visits to the App, App crashes, and SDKs/APIs.
• Stored Information and Files:The App may access metadata and other information associated with other files stored on your device.  This may include, for example, photographs, audio and video clips, personal contacts, and address book information.
• Location Information:The App does not collect real-time information about the location of your device, but it does collect precise geolocation data, which can be adjusted in the user device settings of the App.

When you use the App or its contents, certain third parties may use automatic information collection technologies to collect information about you or your device.  These third parties include:

• Google Firebase.

Events posted on the App may be hosted by third parties, which may have privacy policies that differ from our own.  You should be aware that the collection, retention, and use of any data you provide on these websites will be governed by the privacy policy of the company providing the website and not by this Privacy Policy.  To the extent that you disclose your Personal Information to third parties, including to any third-party website linked from our App or to third parties providing integrated services, you are subject to the privacy policies of those third parties.  We encourage you to review those privacy policies before you disclose any Personal Information to such third parties.  WE DO NOT CONTROL AND ARE NOT RESPONSIBLE FOR WHAT THIRD PARTIES DO IN CONNECTION WITH THEIR WEBSITES, OR HOW THEY HANDLE YOUR PERSONAL INFORMATION.  PLEASE EXERCISE CAUTION AND CONSULT THE PRIVACY POLICIES POSTED ON EACH THIRD-PARTY WEBSITE FOR FURTHER INFORMATION.

Records held by Catalight Care Services

When you give us permission to do so, we collect and integrate information that you provide to Catalight Care Services, including your name (including caregiver name), initials, address, phone number, email address, account identifier, and device or online identifiers.  We use this information in order to help facilitate and manage health services via the App.

How We Use Your Information

We use your Personal Information in order to:

• Create a centralized portal of information for our patients and providers.
• Create and maintain your account and provide you with the App and its contents, and any other information, products, or services that you request from us.
• Carry out promotional operations, direct marketing surveys, or provide you updates regarding our own and third-party goods and services that may be of interest to you.
• Give you notices about your account or subscription, including expiration and renewal notices.
• Carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• Notify you when App updates are available, and of changes to any products or services we offer or provide through it.
• Create and administer surveys and conduct research.
• Maintain, improve, and develop services we provide.
• Analyze your use of our products and services so that we can improve and develop new products and services.
• Conduct business analysis, such as analytics, projections, and identifying areas for operational improvement.
• Respond to your inquiries, complaints, and provide customer service.
• Support care and requests with members and interface with many of the systems/services described above to streamline care.
• Fulfill our legal obligations by complying with valid legal requests and address legal issues and disputes.
• Protect the security and integrity of our App and business, and investigate and respond to suspected illegal activities or fraud.
• Update and improve our technical operations, including detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Protect or enforce our rights and property, or the rights and property of others (which may include you).

Disclosure of Your Information

We may de-identify your information and use and collect such de-identified information, for any business or other purpose not prohibited by applicable law.  In addition, we may disclose Personal Information that we collect or you provide:

• To our subsidiaries and affiliates, such as Catalight Care Services.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Information confidential and use it only for the purposes for which we disclose it to them.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by the Company about our App users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us before you provide the information.
• With your consent.
• To law enforcement or regulatory agencies or in connection with an investigation on matters related to public safety, as permitted by law, or otherwise as required by law.
• To enforce our rights arising from any contracts entered into between you and us, including the App Terms of Use Agreement,.
• To insolvency administrators in the event of bankruptcy.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
• To professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary, in the course of the professional services that they render to us.
• To social media services if you have enabled features or functionality that connect the Services to such services (such as by logging in to the Services using your account with the third party, providing your API key or similar access token for the Services to a third party, or otherwise linking your account with the Services to a third party’s services).

Data Retention

We may retain your information for as long as we believe is necessary for any legitimate legal or business purpose, including, but not limited to, as long as is needed to comply with its legal obligations, resolve disputes, and enforce an agreement and as long as is needed to provide you with the products and services you have requested.  We retain the right to dispose of or delete your Personal Information at any time, except as set forth in any other agreement or document executed by the Company or as required by law.

To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting, or other requirements.  Details of retention periods for different aspects of your Personal Information are available in our Records Retention Policy, which you can request from us by contacting us at the details provided in the Contact Details section below.

In some circumstances, we will anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the Personal Information you provide to us.  This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

• Tracking Technologies:You can set your browser to refuse all or some SDKs, including those provided by third parties.
• Location Information: You can choose whether or not to allow the App to collect information about your device’s precise location through the device’s privacy settings.
• Company Updates:If you do not want us to use your email address to inform you of updates to the App and how to use the App, you should uninstall the App and request that we delete your account by emailing [email protected].
• Opt-Out from Marketing Communication: You can opt out of receiving our marketing emails by following the instructions for unsubscribing contained in the emails or by emailing [email protected] and asking to be removed from the mailing list.  Please allow us 10 business days from when the request was received to complete the removal.  Please note that even if you unsubscribe from commercial email messages, we may still email you non-commercial emails related to your account and your transactions via the App.
• Targeted Advertising by the Company:The Company does not engage in targeted advertising.
• Disclosure of Your Information for Third-Party Advertising and Marketing:The Company does not disclose your Personal Information to non-agent third parties for advertising and marketing purposes.

We do not control third parties’ collection or use of your information to serve interest-based advertising.  However, these third parties may provide you with ways to choose not to have your information collected or used in this way.  For example, you can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Do Not Track

Because there is not yet an accepted standard for how to respond to Do Not Track signals, our App does not currently respond to such signals.  If you want to restrict ads in general on your devices, you may opt out from ad tracking by enabling “Limit Ad Tracking” or “Opt Out of Ads Personalization” (as applicable to your device) in your device settings.

Accessing and Correcting Your Personal Information

You can review and change your account information by logging into the App and visiting your account profile page.

You may also send us an email at [email protected] to request to delete any Personal Information that you have provided to us.  We cannot delete your Personal Information except by also deleting your user account.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the App, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other App users.  Proper access and use of information provided on the App, including User Contributions, is governed by our Terms of Use Agreement

Care Team Communication

By using the App you authorize us and more specifically, the Catalight Care Services care team, to communicate directly with you. You understand that the use of the App is entirely voluntary. You further agree that all communication through the App will be about you, or another user if you are the parent, guardian or you are an authorized care team participant. You acknowledge the content of any communication will be collected and may be stored. We do not assume responsibility for Personal Information of other persons other than App users or guardians.

California Privacy Rights

California consumer privacy laws provide California residents with additional rights regarding our use of California residents’ Personal Information.  To learn more about California residents’ privacy rights, visit https://oag.ca.gov/privacy/ccpa.  California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our App 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 email to [email protected].

Data Security

We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you.  Where we have given you (or where you have chosen) a password for access to certain parts of our App, you are responsible for keeping this password confidential.  We ask you not to share your password with anyone.  We urge you to be careful about giving out information in public areas of the App, like message boards.  The information you share in public areas may be viewed by any user of the App.

Unfortunately, the transmission of information via internet and mobile platforms is not completely secure.  Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through our App.  Any transmission of Personal Information is at your own risk.  We are not responsible for circumvention of any privacy settings or security measures we provide.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, please contact us at:

E-mail:                  [email protected]

Phone:                  (925) 266-8500

Mail:                     Xolv Technology Solutions, LLC

2730 Shadelands Drive, Building 10

Walnut Creek,       CA 94598

Attention: Content Manager / Office of Risk Management