Privacy Policy

Online Privacy Policy for Oula Health

Effective Date: September 23, 2024

Effective Date: August 19th, 2024

Oula Health, Inc. (“Oula Health,” “we,” “us,” or “our”) is a company that collects and provides information to users of our website www.oulahealth.com and any interactive mobile application that Oula Health may develop from time to time (the “App,” and collectively, the “Sites”) regarding obstetrics, prenatal and midwifery care. We value your relationship with us and are dedicated to protecting the privacy of your personal information.

The Sites are owned, operated, licensed, and controlled by Oula Health. This Privacy Policy (“Privacy Policy” or “Policy”) describes the types of personal information we collect from our customers, website visitors, and other individuals (collectively, “you”) when they visit our Sites. This Policy also describes how we use your personal information, under what circumstances we may share it and with whom, and your rights and choices regarding that information. For the purposes of this Privacy Policy, “personal information” means any individually identifiable information about an individual, including but not limited to name, e-mail address, telephone number, or any other identifier that permits the physical or online contacting of a specific individual.

Please note that your health and medical information and other personal information collected for purposes of providing healthcare is regulated by the federal Health Insurance Portability and Accountability Act (HIPAA) and similar federal and state laws (collectively “protected health information”), including the privacy and security protections of those laws. Accordingly, this Policy does not pertain to protected health information. Any coverage of protected health information in this Policy is incidental and provided merely to enhance your understanding of our data collection and use practices, and does not waive or override our obligations under other laws. Please visit our Patient Notice of HIPAA Privacy Practices for more information regarding collection and use of protected health information.

This Policy also does not apply to third-party sites, products, or services, even if they link to our Sites, and we encourage you to read the privacy policies of any third-party site with which you choose to interact. Where links to third-party sites are integrated in our Sites, we will make every effort to clearly mark them as such.

Table of Contents

This Privacy Policy explains the following information. Please click on each section for more detail.

1. Collection of Personal Information. We collect personal information when you register for our Sites or otherwise communicate with us.
2. How We Use Your Personal Information. We use your personal information in many ways, including to provide our Sites, communicate with you, maintain a safe and secure environment, and comply with legal obligations.
3. How We Share Your Personal Information. We share your personal information for several reasons, including for our own internal purposes and pursuant to legal obligations.
4. Cookie Policy. We use cookies and other tracking technologies to maintain and improve our Sites and related products and services.
5. Your Rights and Choices. You may have certain privacy rights relating to electronic communications, and California and Nevada residents may have other rights.
6. Data Security and Retention. We maintain technical, administrative, and physical safeguards to help protect the security of your personal information.
7. International Data Transfers. Our Sites are operated from the United States and intended only for individuals located in the United States.
8. Use by Children. We do not knowingly collect personal data from individuals under the age of 13 years without parental consent.
9. Links to Other Sites. This Privacy Policy does not apply to third-party websites and applications.
10. Changes to This Privacy Policy. We may update this Privacy Policy from time to time.
11. Contact Information. You may contact us in several ways.

1. Collection of Personal Information

We may collect the following categories of personal information about you that you choose to provide to us when you use the Sites, including when you contact us or respond to our communications, create a new account on our Sites, or participate in our events.

• Information We Collect Directly From You

• Account information. When you create an account with us, you will be asked to provide your first and last name, date of birth, gender at birth, preferred pronouns, pregnancy status, and expected due date. Once in the App, you will be provided the option to update your profile with your phone number and full address, and perform functions like creating a pregnancy care plan, book an appointment, or message with our care team.

• Contact information. When you sign up on our Sites to receive information from us or register for a virtual event, you will be asked to provide your first and last name, email address, and zip code.

• Communications information. When you communicate with us online by responding to our emails, messaging, or otherwise contacting or responding to us via online means, we may collect information about the communication and any personal information you choose to provide in the content of those communications.

• Information We Collect When You Use Our Site

We, our service providers, and our business partners may automatically collect information about you, your computer or mobile device, your activity over time on our Site and other online services, and your interactions with our communications, such as:

• Device information. We may collect information such as your device’s operating system type and version, manufacture, and model, browser type, screen resolution, device type (e.g., phone, tablet), IP address, language settings, mobile device carrier, radio/network information (e.g., WiFi, LTE, 3G), and geolocation data.

• Online activity information. We also may collect information concerning the pages or screens you viewed, how long you spent on a page or screen, the website you visited before our Site, navigation paths between pages or screens, and whether you have opened our emails.

• Information We Receive From Third Parties

• Information from your other accounts. We may also provide the option for you to register for our Services by linking your account at a third party, such as Apple or Google. If you register for our Services by linking your account at a third party, you are consenting to have the information in those accounts (“Third-Party Account Information”) transmitted into your account with us, and that Third-Party Account Information is covered by this Policy.

• Information collected through our service providers. We also obtain information from and/or through other sources, such as analytics service providers and security service providers, who provide us with information to secure our systems, prevent fraud and help us protect the security of our Site and Services.

• Social media platforms. We may collect personal information from third-party social media platforms and sites, such as when you engage with our social media pages, online communities and forums, and when you mention us on your own or other social media pages, online communities or forums.  Please note that online forums may be publicly accessible and other users may view information you post in the forums.

• Aggregated, De-identified, or Anonymous Data

We may create aggregated, de-identified, or anonymous information from personal information by removing certain data components (such as your first and last name, email address, or linkable tracking ID) that makes the data identifiable, or through aggregation, obfuscation, or other means.  For example, we may use aggregated, de-identified, or anonymized information to understand how to improve or enhance our Site. Subject to applicable law, our use of such aggregated, de-identified, or anonymized information is not personal information subject to this Policy.

• Combined Information

Finally, we may combine information that we collect through our Site and Services with information that we receive from other sources, both online and offline, and use such combined information in accordance with this Policy.

• How We Use Your Personal Information

We may use the personal information that we collect about you online for the following purposes:

• Provide you with the services, products, or information that you request
• Provide you with customer service and other communications
• Provide you with information about our services and other opportunities that we believe may be of interest to you, and to personalize, measure, and improve such offers
• Conduct analytics to improve our Sites, products, and services, and for new products and services
• Maintain and improve the quality of our Sites
• Protect ourselves, you, and others, prevent fraud, and create and maintain a trusted and secure online environment
• Comply with our legal obligations, respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims
• Self-auditing and other internal business operations

We may combine personal information collected from you via the Sites with other information we obtain from our business records or third-party sources in order to provide you with a better experience and to provide and improve and maintain our Sites and the products and services we offer. Additionally, personal information collected about you from a particular browser or device may be linked to personal information collected from another computer or device that we believe relates to you.

• How We Share Your Personal Information

We may share personal information collected online with our vendors, partners and other entities, consistent with the circumstances in which we have collected the information as follows:

• Our business associates and other vendors, as necessary to provide services on our behalf such as website hosting, analytics, site optimization, communications,, technical support, and customer support. We will not sell or share information, including mobile data, with third parties for marketing purposes.

• Public health authorities or other governmental authorities for public health-related purposes, health oversight activities or national security purposes as disclosed in our Patient Notice of HIPAA Privacy Practices.

• For legal compliance and harm prevention, including to respond to legal process (such as subpoenas, court orders, or search warrants, etc.) or to establish or exercise our legal rights or defend against legal claims. We also may provide information in order to investigate, prevent, or take action regarding illegal activities or wrongdoing; to protect the rights, property, or safety of Oula Health, its customers, and others; to enforce our agreements and policies; or as otherwise required by law.

• For business transactions, subject to applicable law, in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets.

• Cookie Policy 

The Sites may use cookies and similar technologies to improve user experience, for performance and analytics, and to customize and enhance our content, products, and services. A “cookie” is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to that server (for example, when requesting a web page from the same domain that created the cookie).

The general purpose of cookies is to remember a browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may track the personal information users provide when they interact with a site, and may store such personal information. We use first-party and third-party cookies to ensure that our Sites function properly, to understand how individuals use and engage with our Sites and to analyze and improve our Site.

Most browsers are initially set up to accept cookies, but you can reset your browser to block or delete all cookies in your browser’s settings using the links provided below. Please note that if you block essential cookies, certain parts of the Sites may not function properly.

• Chrome: https://support.google.com/chrome/answer/95647?hl=en
• Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
• Safari: https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac
• Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer
• Opera: https://help.opera.com/en/latest/web-preferences/#cookies

• Do-Not-Track

The Sites do not support Do-Not-Track functionality. Do-Not-Track is a preference you can set on your web browser to inform websites that you do not want to be “tracked” by third parties. We do not respond to Do-Not-Track Signals as we do not track you when you leave the Sites. Our third party service providers, such as those who provide web analytics services to us, may not respond to Do-Not-Track signals. If you come to the Sites with a Do-Not-Track signal enabled on such user’s browser, we do not look for the Do-Not-Track signal or respond to it.

• Interest-Based Advertising

We do not engage in interest-based advertising. Interest-based advertising (also known as targeted advertising) refers to the practice of collecting information from a computer or device regarding a visitor’s web-browsing activities across non-affiliated websites over time to deliver advertisements that may be of interest to that visitor based on their browsing history. We do not authorize the collection of personal information from our users for third party use through advertising technologies.

• Your Rights and Choices

• Electronic Communications

If you would like to stop receiving our emailed newsletter or other electronic messages and notifications, you may do so by following the unsubscribe instructions that appear in our email or text communications. We will endeavor to comply with these requests as soon as reasonably practicable. Please be advised that you may not be able to opt-out of receiving certain service or transactional email messages from us that are required to provide you with our Services. You have the option to opt out of receiving automated calls or texts from us at any time. To do so, simply reply with STOP via text message to any text message we send you. Upon receiving your request, we will cease sending automated calls or texts to the phone number from which you sent the opt-out request. Please note that standard message and data rates may apply.

1. California “Shine the Light” Law

California residents additionally have the right to request information regarding third parties to whom Oula Health has disclosed certain categories of personal information during the preceding year for those third parties’ direct marketing purposes under California’s “Shine the Light” Law.  Note, however, that we do not disclose Personal Information for marketing purposes.  Personal information under this California law means any information that identified, described, or was able to be associated with an individual at the time of disclosure. We do not disclose this type of personal information to third parties for their own purposes, and we permit you to opt-out of any disclosures of non-identifiable personal information. However, if you are a California resident and would like to inquire further, please contact us. You must include your full name, email address and postal address in your email or mail request so that we can verify your California residence and respond.

1. Your Nevada Privacy Rights

Nevada residents have the right to request to opt out of any “sale” of their personal information under Nevada SB 220. You may request to opt out of the future sale of your personal information. If you are a Nevada resident and would like to make such a request, please contact us. You must include your full name, email address and postal address in your email or mail request so that we can verify your Nevada residence and respond. In the event we sell your personal information after the receipt of your request, we will make reasonable efforts to comply with such request.

• Data Security and Retention

The privacy and security of your personal information is deeply important to us. To that end, Oula Health maintains technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, misuse or disclosure. Your personal information is accessible to only a limited number of personnel who need access to the information to perform their duties. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.

• International Data Transfers

Oula Health offers its obstetrics, prenatal and midwifery care, and related products and services, to individuals in the United States only. As such, our Sites are operated from the United States and intended only for customers and web visitors located in the United States. Any collection of personal information from individuals located outside the United States is unintentional and/or incidental.

That said, it is possible that your personal information is transferred outside of your state, country, or other governmental jurisdiction in order for Oula Health to render the collection, use, and sharing practices disclosed elsewhere in this Privacy Policy. Those jurisdictions may have data protection rules that are different from those of your jurisdiction. If so, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal information remains protected to the standards described in this Privacy Policy. Personal information transferred to another country may be subject to lawful access requests by courts, law enforcement agencies, or other government authorities in those other countries.

• Use by Children

Our Sites are not directed toward individuals under the age of 13 (“Children”). We do not knowingly collect personal information from Children, and no personal information should be submitted to our Sites by Children. If we learn we have collected or received personal information from a Child, we will delete that personal information as permitted by law. You must be old enough to consent to the processing of your personal information in your country, and you must be at least 18 years of age to use our services. If you believe we may have any collected personal information from a child under the age of 13 without parental consent, please submit a written request via the email to privacy@oulahealth.com.

1.  Links to Other Sites

Our Sites may contain links or otherwise provide access to third-party sites, which may include websites or mobile applications. These links are maintained for your informational purposes only and to point you toward the products and services of third parties that we believe may be of interest to you. Please note that we have no control over and are not responsible for third-party sites, their content, or any products or services available through the third-party sites. Our Privacy Policy does not apply to third-party sites. We encourage you to read the privacy policies of any third-party sites with which you choose to interact.

• Changes to This Privacy Policy

We may update this Privacy Policy from time to time. The date this Privacy Policy is current as of the Effective Date above. If we make material changes to this Privacy Policy that expand our rights to collect new personal information or to use differently any personal information that we have previously collected about you, we will use our available contact information about you to reasonably notify you of the updates and provide you with the new disclosures by posting it on our Sites and/or via email. We encourage you to review this Privacy Policy often to stay informed of how we may process your personal information.

• Contact Information

If you have any questions or concerns about this Privacy Policy or our privacy practices, please do not hesitate to contact us. You can email us, write to us, or call us using the information below:

Oula Health, Inc.

109 Montague Street

Brooklyn, NY 11201

Email:  privacy@oulahealth.com