Strive Health’s Privacy Policy

Author: Strive Health

Strive Health and its affiliates (collectively, “Strive,” “we,” “us,” or “our”) are committed to respecting your privacy. This Privacy Policy (“Policy”) describes how we collect, use, and disclose personal information directly from you or that we collect through the Strive website (collectively, “Site”). By accessing our Site, you agree to the terms of this Policy, including the collection, use, and disclosure of your personal information as described in this Policy.

If you are a California resident, please see the California Notice of Collection and Other California Resident Rights section of this Policy.

We do not knowingly collect or process protected health information on our Site. For information about how Strive and its affiliates may use and disclose protected health information about you, how you can get access to this information, and other rights under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”), please review our Notice of Privacy Practices.

Personal Information We Collect Through the Site

Personal Information You Provide to Us Directly

We may collect certain personal information from you (e.g., your name, address, phone number, email address, or other demographic information) when you request additional information, search for and apply for a job with Strive, fill out a contact form, submit feedback to Strive, or otherwise engage with us. We use this personal information to operate, maintain, and provide you with superior Site user experience and to provide you with information about Strive.

If you apply for a job at Strive, you may choose to provide personal information about yourself, such as your demographics, employment history, equal employment opportunity data, educational history, degrees, certifications, credentials, references, locations, and other information included in your resume and in the application you submit.

Personal Information We May Receive from Third Parties

We may also collect personal information regarding how you interact with our Site and other websites. For example, if you apply for a Strive job via a third-party website, we may collect personal information related to that interaction. In some cases, we may receive personal information about you from third parties. 

Analytics Information

Our Site uses analytics to provide you the best possible experience and offerings. We may combine this data with other personal information collected to measure your interest in Strive, improve our offerings and marketing campaigns, and to tailor our interactions with you.

We use analytic vendors to better understand usage of our Site, or for offerings to audiences and general marketing campaigns. These tools collect personal information sent by your browser or mobile device, including the pages you visit and other personal information that assists us in improving our Site and offerings. 

Opt-out options are provided in our cookie banner.

Cookies

A “cookie” is a small text file that may be transferred to your computer’s hard drive to personalize our services for you and collect information regarding usage of our services. Each computer is assigned a different cookie that contains a random and unique identifier. Our Site may use two different types of cookies: a “session” cookie and a “persistent” cookie.  A session cookie is temporary and expires after you end a session and close your browser. On the other hand, a persistent cookie remains on your hard drive. 

Strive and select third parties may use cookies and other online technologies to collect personal information such as your internet browser type, Internet Protocol (IP) address, device ID operating system version, location, and demographics. It may also collect the areas of the Site you visit, the content you interact with, and the time of your visit.

We may combine this information with other personal information we obtain about you, such as information obtained from third parties. We, or third parties, may collect personal information about your online activities over time and across different online services when you use our Site.

We use cookies to help us tailor our Site to visitors in our offerings, marketing, and advertising. Some features of our Site may not work as intended if you decline or deactivate cookies. Further information regarding cookies may be available from your internet service provider, operating system, or browser provider. You may set your web browser’s “do not track” or other similar browser-level or device-level mechanism, to signal to our Site a request to disable certain cookies. Refer to the browser or device mechanism for more information on how the mechanism interacts with distinct types of cookies, and note that by disabling certain types of cookies, some features on our Site may no longer function. We do not control these browser-level or device-level opt-out mechanisms, and therefore, our Site will adhere to such signals to the extent reasonably technologically viable.

Log File Information

When you access or use our Site, we may track information to administer our services and analyze its usage. Examples include the:

  • pages or information you viewed;
  • number of links you click;
  • state or country from which you accessed our Site;
  • date and time of your visit;
  • IP address;
  • kind of browser you use;
  • name of your internet service provider; and
  • address of website you came from prior to our Site.

We use this information to analyze and improve our Site, monitor traffic and usage patterns for information security purposes, and to make our Site more useful to visitors.

Web Beacons

A web beacon is a small image file on a web page that may be used to collect certain personal information from your device. This personal information may include IP address, time of access, browser, and identification of cookies. Strive, or its service providers, may utilize web beacons to track visitor statistics and manage cookies.

Location Data

When you access the Site by or through a browser or mobile device, we may utilize a feature that accesses, collects, monitors, and remotely stores location data. It may include GPS coordinates or similar personal information regarding the location of your device. This data may be used to convey information about how you browse and use the Site, as well as provide you with personalized information based on your location data, such as the appropriate cookie banner. You may opt-in or opt-out of sharing location data from your computer.

Personal Information of Minors

We do not target minors and do not knowingly collect or process personal information of individuals under 18 years of age. If we learn that personal information of minors has been collected, we will take reasonable measures to delete such information from our records. If you become aware of any personal information that we may have collected from minors, please contact us at privacy@strivehealth.com.

Links to External Websites 

Our Site may have links to external internet pages, such as websites that might have information on health topics of interest to you. We do not make any guarantee, warranty, or representation regarding the accuracy of the personal information contained on external websites, and we have no control over the privacy or security practices of external websites. You should read and understand the policies of all websites with respect to these practices. These links are provided for your general information and education only and should not be relied upon for personal diagnosis or treatment. Please contact your clinician if you have health-related questions.

Use and Disclosure of Personal Information

We may use your personal information:

  • to track and analyze use of our Site;
  • to prevent, detect, and investigate misuse, fraud, and illegal activities;
  • to enhance and maintain our Site, services, and products;
  • to contact you. For example, sending you a newsletter or other informational materials, offers, announcements, or surveys;
  • to manage business relationships, the employment lifecycle, and other business-to-business and employment purposes;
  • to communicate with you about our services, products, and Site, including to follow-up on requests or questions you submit;
  • to send you emails or text messages regarding upcoming events, newsletters, etc. If you do not wish to receive these communications, you may opt-out by using the unsubscribe process stated in the message;
  • to provide marketing and advertising communications;
  • for any lawful and legitimate business purpose; and
  • as otherwise necessary to perform the services we provide.

We may disclose your personal information:

  • to our service providers who perform certain services or functions on our behalf. For example, we may share your personal information with our Site’s hosting service provider, or with a benefits administrator for employee benefit purposes;
  • in the event of a change in ownership or control, such as a sale or merger; 
  • in accordance with your consent or direction, as permitted by law;
  • as required to comply with applicable laws and legal process, including law enforcement requests;
  • to investigate and defend our and others’ rights and property (including intellectual property rights); and
  • to protect the personal safety of us and others.

If you use our Site from outside the United States, you consent to the transfer of your personal information to the United States, and the use and disclosure of your personal information as permitted under United States laws.

We may combine personal information collected through different portions of our Site. In the event we combine personal information collected through our Site with your protected health information, we will use and disclose such combined information as described in our Notice of Privacy Practices, which outlines our use and disclosure of protected health information.

California Notice of Collection and Other California Resident Rights

Under the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act (collectively, “CCPA”), this section only applies to California residents (“Consumers”) whose Personal Information is covered by the CCPA. For the purposes of this section only, “Personal Information” means information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular Consumer or household. It includes Personal Information gathered on our Site or offline, such as hard copies.

Under CCPA and subject to certain exceptions, California Consumers may have the following rights with respect to our processing of their Personal Information:

  • Right to Access. You have the right to request that we disclose the following information to you:
    • The categories of Personal Information that we collected about you.
    • The categories of sources from which the Personal Information is collected.
    • The business or commercial purpose for collecting, selling, or sharing Personal Information.
    • The categories of third parties to whom we disclosed Personal Information.
    • The specific pieces of Personal Information that we have collected about you.
    • The categories of Personal Information that we disclosed about you for business purposes.
    • The categories of Personal Information that we sold or shared about you.
    • For each category of Personal Information identified, the categories of third parties to whom the information was disclosed or sold.
  • Right to Delete. You have the right to delete Personal Information about you, subject to certain exceptions.
  • Right to Opt-out of Sale. You have the right to request that we do not sell your Personal Information. Please note that Strive does not sell your Personal Information for monetary payments.

You may exercise these rights by completing the California Consumer Privacy Rights Request Form or by emailing your request to privacy@strivehealth.com. Once you have submitted a valid request and we are able to verify your identity, we will respond within the timeframe permitted. We may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law.

Personal Information We Collect, How We Use It, and With Whom We May Share It

The categories of sources from which we collect Personal Information include:

  • directly from Consumers;
  • cookies, beacons, and other technologies on our Site;
  • service providers; and
  • other sources, such as companies that help us maintain the accuracy and completeness of our data and help enhance our records. 

The chart below identifies the categories of Consumer Personal Information that we collected and sold within the past 12 months. The specific pieces of Personal Information vary depending on the nature of your interactions with us and may not include all examples listed below.



Category of Personal Information

Examples

Collected

Sold

Identifiers

Name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Yes

No

Personal Information categories described in Cal. Civ. Code § 1798.80(e)

Name, signature, Social Security Number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.

Yes

No

Characteristics of protected classifications under California or federal law

Age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

Yes

No

Commercial information

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Yes

No

Biometric information

Voice recognition, fingerprint and palm print scanning, facial recognition, iris recognition, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

No



No

Internet or Electronic Network Activity Information

Internet or other similar activity: browsing history, search history, information on a Consumer’s interaction with a website, application logs, device data and registration, social media account information or advertisement.

Yes

No

Geolocation data

Any information that can be used to identify the physical location of a device.

Yes

No

Audio, electronic, visual, thermal, olfactory, or similar information

Photographs, video recordings, and voice or call recordings.

No

No

Professional or employment-related information

Current or past job history or performance evaluations.

Yes

No

Non-public education information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99)

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, record of attendance, disciplinary records, or other information relating to your secondary and post-secondary education.

No

No

Inferences drawn from any Personal Information identified to create a profile about a Consumer

A profile created about a Consumer reflecting the Consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Yes

No

Sensitive Personal Information

Government identifiers, precise geolocation, information concerning sexual orientation, racial or ethnic origin, religious or philosophical beliefs, union membership, and citizenship and immigration status.

Yes

No



The categories of recipients with whom we may share Personal Information:

  • Service providers. We transfer Personal Information to third-party service providers to perform tasks on our behalf and to assist us in providing our services. For example, we may use third-party service providers for Site analytics and security. 
  • Business transfers. In the event of a merger, sale, divestiture or change of control, we may transfer or assign Personal Information to a third-party entity that acquires or is merged with us.
  • Third parties. We may sell or share Consumer Personal Information to third parties for cross-context behavioral advertising and other marketing and advertising services that we utilize on our Site.
  • Legal process. We may disclose Personal Information in response to subpoenas, warrants, court orders, government inquiries or investigations, or to comply with relevant laws and regulations. We may also disclose information to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to act on possible illegal activities or violations of our policies. 

Minors

We do not sell or share the Personal Information of Consumers who are less than 16 years of age. However, if we ever have actual knowledge that the Consumer is under 13 years of age, we will receive the Consumer’s parental or guardian affirmative authorization to disclose Personal Information. If the Consumer is between 13 and 16 years of age, we will receive the Consumer’s affirmative authorization to disclose Personal Information.

Retention of Your Personal Information

The retention periods for each category of Consumer Personal Information vary depending on the type of business record in which it is maintained. The retention period is based on the length of time we need the record for: 

  • its original purpose;
  • other operational purposes, such as audits and reporting; and
  • legal and regulatory compliance, such as maintenance of opt-out or opt-in lists, tax obligations, and legal holds.

California Direct Marketing Privacy Rights

Under California’s “Shine the Light” law (Civil Code Section § 1798.83), California residents have the right to request in writing from businesses with whom they have an established business relationship:

  • A list of the categories of personal information, such as name, e-mail and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes.
  • The names and addresses of all such third parties. 

To request the above information, please email privacy@strivehealth.com and reference the California Direct Marketing Privacy Rights. We will respond to requests within 30 days following email receipt. If we receive your request at a different email address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each California resident once per calendar year.

Revisions to this Policy

We may periodically revise this Policy as state and federal laws change, or as we change the ways we collect, use, share, or sell your personal information. We will post changes to this Policy on our Site. Your continued use of our Site following the posting of changes will mean that you accept those changes.

Questions, Concerns, and Contact Information

For questions or concerns about our privacy practices, please contact Strive’s Privacy team by emailing privacy@strivehealth.com or calling 720-729-8885.

Effective Date: 12/28/2023