PRIVACY POLICY

Renée & Co. Privacy Policy

Renée & Company and all related companies

August 07, 2022

Who We Are

Renée & Company ("R&Co") and Scroll.care is a care concierge service providing both human and technology support to families and individuals. With our single gateway technology, we provide the spectrum of care services through vetted resources in the communities we serve.

Scope of Policy

This Privacy Policy explains how Renée & Company and Scroll.care., and its affiliates ("we," "our," "us") collect, use, and share information collected through our technology, applications, platforms, websites, content, products, and services (the "Services"). This Privacy Policy applies generally to the information We collect about You as a: consumer; another person for whom You have the legal authority to represent, such as Your family member, friend, or client; Care Professional ("Providers"); other employee; or partner (collectively "You," "Your").

If your data is collected, used, or shared in connection with your status as a Provider or employee, Your use and access to Services are subject to the terms of the offer letter which you signed at hire and all employment policies, procedures, handbooks, rules, agreement(s) and written requirements, which will control in the event of any conflict.

This Privacy Policy does not apply to any protected health information covered by the Health Insurance Portability and Privacy Act ("HIPAA"), and its implementing regulations.

Policy Updates

This Privacy Policy may change from time to time. This Privacy Statement is in effect as of the date above. If we change this policy, we will post the revised version here and change the "effective date" to show the date from which the new policy will apply. We may also contact You directly where we deem it appropriate to do so under applicable law. If you object to any changes, you must cease using the Services immediately. We encourage You to check here regularly for the most up-to-date version.

Consent

By utilizing our Services or providing information about You, You acknowledge and consent to the terms of this privacy policy. You agree not to provide us with information about any other person unless You have that person’s consent or other legal authority.

Your telephone communications with Us may be recorded or monitored for quality control purposes. By communicating with Us in this manner, You expressly consent to the recording for such purposes.

By providing Us with Your contact information, such as email or telephone number, You agree to be contacted by Us and by the providers we have contracted with to contact You on our behalf. You agree to be contacted by telephone call or text message at the telephone number You provided using automatic telephone dialing systems, even if You previously registered on a Do Not Call registry. Your consent is not a condition of purchase.

Cookie Consent

When You first visit our site, a cookie banner will appear and request consent to place cookies. Our website only places optional cookies when You consent by clicking "accept" in the cookie banner.

"Cookies" are small pieces of data, stored in text files, that are stored on Your computer or other devices when websites are loaded in a browser. They are widely used to "remember" You and Your preferences, either for a single visit (through a "session cookie") or for multiple repeat visits (using a "persistent cookie"). They ensure a consistent and efficient experience for visitors and perform essential functions such as allowing users to register and remain logged in. Cookies may be set by the site that You are visiting (known as "first party cookies"), or by third parties, such as those who serve content or provide advertising or analytics services on the website ("third party cookies").

What Cookies Do We Use?

Strictly Necessary Cookies. These cookies are essential in order to enable You to move around the website and its features, such as accessing secure areas of the website. These cookies cannot be switched off in our systems. Without these cookies, the services You have asked for cannot be provided.
Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by a third party provider whose services we have added to our pages. If You do not allow these cookies then some or all of these services may not function properly. We generally consider these cookies to be in the "strictly necessary" category.
Performance Cookies. These cookies collect information about how visitors use a website, for instance, which pages visitors go to most often, and if they get error messages from web pages. All information these cookies collect is aggregated and used to improve how a website works. If You do not allow these cookies we will not know when You have visited our site and will not be able to monitor its performance.
Social Media Cookies. These cookies are set by a range of social media services that we have added to the site to enable You to share our content with Your friends and networks. They are capable of tracking Your browser across other sites and building up a profile of Your interests. This may impact the content and messages You see on other websites You visit. If You do not allow these cookies You may not be able to use or see these sharing tools.
Targeting Cookies. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of Your interests and show You relevant adverts on other sites. They do not store directly personal information but are based on uniquely identifying Your browser and internet device. If You do not allow these cookies, You will experience less targeted advertising.

If You consent to Cookies and then change Your mind, You may opt-out of the placement of optional cookies going forwards via our Cookie Preferences using this link:
Cookie Settings

Data We Collect

There are four main ways we collect personal information:

Data You Provide: Data You provide to Us;
Automated Data: Data collected through electronic/automated means; and
Partner Data: Data we are authorized to access as an affiliate and as the parent company of Scroll.care; and
Other Data Sources: Data from other sources (such as our service providers or public sources).

Data You Provide

We collect data You provide to Us when You use our Services, including, but not limited to, communicating with Us over the telephone, through our mobile application(s), email, SMS, or complete a website form. This includes personal information, which identifies, (whether directly or indirectly), a particular individual. Personal information You provide includes the types of data listed below (with examples).

Identifiers. Name, postal address, phone number, or email address.
Customer Personal information under California. Civ. Code § 1798.80(e). Name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
Personal characteristics of protected classes. Age, gender and other information You choose to provide, such as marital status, medical condition, physical or mental disability.
Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
Financial Information. Banking information, account numbers, routing numbers, revenue, payments, invoices, expenses.
Profile. Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, abilities, engagement, skill and business acumen, referral source(s), schedule preferences, orientations and training completed, family, friends, relationships, habits, behaviors, opinions, feedback, living environment and conditions, service and customer service records, and inferences made from this data.
Professional or employment-related information. We may receive employment-related information, including: current and past employer name, positions held, physical demands of positions held, and wage information; availability of reliable transportation; recruitment information, qualifications, references, information contained in Your resume/CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves, date of death; location of employment and workplace, job titles, work history, experience working with specific health conditions, work hours, licensure and certification, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military; and performance record, compensation history, disciplinary and grievance information (including related legal matters).
Sensitive Personal Information. Information that reveals: a social security, driver’s license, state identification card, or passport number; a racial or ethnic origin, religious or philosophical beliefs, or union membership; information collected and analyzed concerning a consumer’s health; the contents of mail, email, and text messages.
Website/Application interaction or similar network activity–information. You provide Us in our website contact forms, applications or through any chat functionality.
Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, body temperature, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data that can be used to identify an individual.
Sensory data. Audio or similar information, such as recording phone calls for quality assurance.
Health & Physical Characteristics. Medical conditions, diagnosis, care needs, and other similar information You provide. In the case of injury, illness, or potential disability we may also collect doctor’s notes and assessments, work status reports, or other medical information to clear you for work or arrange alternative work.

Automated Data

As is true of most websites and applications, we gather certain information about Your usage, patterns and location. We, our affiliates, and third-party vendors/service providers use technologies such as cookies, flash cookies, pixels, tags, scripts, software development kits, application program interfaces, and web beacons.

These technologies may be used for many purposes including, for example, to:

Provide useful features to simplify Your experience when You return to or navigate our websites or applications (for example, remembering the contact information You entered so You don’t need to re-enter it)
Deliver relevant content and advertising based on Your preferences, usage patterns and location;
Monitor, evaluate, and optimize the use and operation of our websites and applications; and
Analyze traffic on our websites, applications and on the sites of third parties.

We may receive reports from our third-party vendors/service providers based on the use of these technologies that contain personal information, aggregate information, or anonymous information. Personal information we may automatically collect includes the types of data listed below (with examples).

Identifiers. Online identifier, Internet Protocol (IP) address, or unique device identifiers.
Site interaction or similar network activity. Interaction with our website or advertisements including logs and session data, and browser, network, device and operating system information. We also collect information about how You interact with our mobile applications, including how much time You spend in particular parts of the mobile applications. We may also track the site You visited prior to our website or what website You visit when You leave us.
Geolocation data. Physical location, such as country or state from which You access the website or application(s).

We generally use local storage ("LS") also referred to as HTML5 to store web content information and preferences. Third parties with whom we partner to provide certain features on our website or to display advertising based upon Your web browsing activity use local storage to collect and store information. Various browsers may offer their own management tools for removing HTML5 LS.

Partner Data

We may partner with one or more third party advertisers, search providers and/or ad networks to either display advertising on our website, help us improve the quality of our website, or to manage our advertising on other websites. Each such third party advertiser, search provider and ad network partner may use cookies and web beacons to collect information about Your activity on our website, on devices associated with You, and on third-party sites and applications. Tracking data collected by these advertisers and third parties is used to decide which ads You see both on our websites and applications and on third-party sites and applications. Service providers that collect tracking data on our behalf may provide an opportunity for You to choose not to be tracked online.

Other Data Sources

Identifiers. Name, postal address, phone number, or email address.
Customer Personal information under California. Civ. Code § 1798.80(e). Name, physical characteristics or description, address, telephone number, medical information, or health insurance information.
Personal characteristics of protected classes. Age, gender and other information You choose to provide, such as marital status, medical condition, physical or mental disability.
Commercial information. Records of products or services purchased, obtained, or considered, insurance payor sources and benefits, private payment sources and budgets, or government payment sources and benefits information (Medicaid, Veteran’s Benefits, etc.)
Profile. Profile reflecting a person's preferences, characteristics, predispositions, behavior, attitudes, abilities, engagement, skill and business acumen. Information regarding family, friends, relationships, habits, behaviors, attitudes, preferences, opinions, feedback, living environment and conditions, service and customer service records, and inferences made from this data.
Professional or employment-related information. We may receive employment-related information, including: current and past employer name, positions held, physical demands of positions held, and wage information; recruitment information, qualifications, references, CV/cover letter or as part of application process; employment data such as dates of service, promotions, leaves, date of death; location of employment and workplace, job titles, work history, work hours, licensure and certification records, professional memberships; termination records, correspondence between us and You; Your membership in public service, including military; and performance record, compensation history, disciplinary and grievance information (including related legal matters). Background and identity verification information is collected on our behalf by a third party background check provider that employees consent to during the application process.
Sensitive Personal Information. Information that reveals a social security, driver’s license, state identification card, or passport number; an account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account, precise geolocation, racial or ethnic origin, religious or philosophical beliefs, the contents of a consumer’s mail, email, and text messages, and information collected and analyzed concerning a consumer’s health.
Biometric Information. Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, body temperature, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Website/Application interaction or similar network activity. Information You provide Us in our website contact forms, applications or through any chat functionality.
Sensory data. Audio or similar information, such as recording phone calls for quality assurance.
Health & Physical Characteristics. Medical conditions, diagnosis, care needs, and other similar information You provide.
Financial Information. Banking information, account numbers, routing numbers, revenue, royalties, payments and invoices.

Data Use

For each type of data we collect, we use such Personal Information for the business purposes set forth below:

Verify and enhance quality of products and Services. For example, we may use personal information to remind Providers of care policies during a client visit or to obtain feedback regarding the quality of care or client visits.
Administration of our business. For example, we may use employees’ personal information for customary HR functions like payroll, reports, complaints, compensation reviews, and performance management.
Anonymizing Your data for further internal and external use in a manner that does not identify You.
Enhancing security and preventing fraud or illegal activity. For example, we may use personal information to verify your identity when you access our application or submit a data request.
Verification and onboarding of care professionals onto the Scroll.care platform.
Performing our contractual duties and obligations or entering into an agreement.
Ensuring compliance with legal obligations. For example, state licensure requirements may require us to maintain a client’s personal information, including details about care.
Facilitation of online or platform interactions. For example, we may use personal information for our application’s self-service features.
Consumer engagement & customer service.
Identifying and testing business innovations. For example, we may review application usage data to determine the success of a new application function.
Market research. For example, we may use basic information about our employees or clients to determine where we should focus future advertising and marketing efforts.
Providing educational resources/learning management. For example, we may document employee orientations and trainings for the purposes of confirming compliance with our requirements, payroll, or compliance with regulatory requirements.
Advertising/marketing for employment, recruitment, products and Services. Use of data for advertising/marketing of our products and Services may also be of a commercial purpose for which You may have the right and ability to opt-out.

We may use the information we collect about You in other ways, which we will tell You about at the time we collect it or before we begin using it for those other purposes. In certain instances You will have an opportunity to limit our uses at the time Your Personal Information is collected. You may also have the right to request deletion of Your data, depending upon Your state of residence, as provided below.

We will retain and use Your Personal Information for as long as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Once data is aggregated, de-identified, or anonymized, it may be retained for a longer period as permitted by law.

Data Sharing

We may share information for the purposes described above under "Data Use," with third-parties as follows:

Partners, Subsidiaries and Affiliated Care Agencies. We may share Personal Information with our partners and affiliates such as the provider agencies that have partnered with R&Co to jointly provide services to clients. We may also share with corporate subsidiaries.
Service Providers. We may share Personal Information with service providers to facilitate our business purposes, as identified above in "Data Use." These may include, but are not limited to, disclosures to our auditors and advisors, or technology and software service providers who help us administer our business or provide data security. These also include providers of website functionality, such as our chat feature. We generally require such providers to provide contractual assurances that they will safeguard data and limit their use of data to what is required to fulfill the purpose of our arrangement with them.
Third-party Vendors. We may share Personal Information with third-party vendors to facilitate our own commercial purposes, as identified above in "Data Use." These may include, but are not limited to, online marketing, advertising or analytics providers who help us understand trends and patterns among those who access our website and Services. When these vendors are not service providers described above or utilize non-essential cookies on our website, You may have the right and ability to opt-out of such sharing.
Legal Purposes, Authorities, Officials and Courts. We may disclose Personal Information where we believe it is necessary to comply with the law in special cases when we have reason to believe that disclosing this Personal Information is necessary to identify, contact or bring legal action against someone who may have breached our Terms or who may be causing (whether intentionally or unintentionally) injury to or interference with our rights or property, other website or application users, or anyone else who could be harmed by such activities. We may also disclose Personal Information to law-enforcement personnel and agencies when requested to do so, as required by law, such as to comply with a subpoena.
Business Transfers. We may disclose Personal Information as part of any merger, acquisition, debt financing, sale of company assets, or other business transaction, or in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, provided that we inform such third parties that they must use Your Personal Information only for the purposes disclosed in this Privacy Policy.
As Aggregated, De-identified, or Anonymized Information. We may disclose information that cannot reasonably be used to identify You, as permitted by law.
Upon Your request. We may otherwise disclose Your Personal Information to third-parties with Your consent or at Your direction, where permitted or required by law.

Links to Other Websites and Social Media

Our Site may offer links to websites that are not run by us but by third parties. If You visit one of these linked websites, Any information You give to those organizations is subject to their privacy policy, terms and conditions, and other policies. We are not responsible for the policies and practices of third parties. You understand and agree that by clicking on a link to a third party site You have left the Site, and this Privacy Policy is no longer in effect.

We may maintain profiles or accounts with various third-party social media providers, which may include Facebook, Twitter, Instagram, LinkedIn, YouTube, and Google+. While our collection, use, and disclosure of information obtained through the Social Media Properties and/or the Features is governed by this Privacy Policy to the same extent as information gathered through the Site, the information third-party social media providers collect or access through Your use of the Social Media Properties is governed by such third-party’s privacy policy. We encourage You to review the social media provider’s privacy policy before interacting with a Social Media Property and/or Feature.

Your Data Privacy Choices

Managing and Controlling Cookies

Browser Settings
You may wish to restrict the use of cookies or completely prevent them from being set. Most browsers provide ways to control cookie behavior such as the length of time they are stored – either through built-in functionality or by utilizing third-party plugins. If You disable cookies, please be aware that some of the features of our Site may not function correctly.
To find out more on how to manage and delete cookies, visit allaboutcookies.org. For more details on Your choices regarding use of Your web browsing activity for interest-based advertising visit optout.aboutads.info (US based) or Youradchoices.ca (Canada based). On a mobile device, You may also be able to adjust Your settings to limit ad tracking (e.g. "Limit Ad Tracking" on iOS or "Opt Out of Interest-Based Ads" or "Opt Out of Ads Personalization" on Android). If You are seeing one of our advertisements on a third-party site, such as a social media site, You may also have the option to opt out of such behavioral advertising through that site’s preference settings. Even if You opt out of personalized advertising, You may still see ads based on factors such as Your general location derived from Your IP address, Your browser type, and Your search terms.
You can opt-out of Google Analytics by installing Google’s opt-out browser add-on.

Do Not Track
Do Not Track is a web browser privacy preference that causes the web browser to broadcast a signal to websites requesting the user's activity that such activity will not be tracked. If You are using a "do not track" function on Your web browser, our cookie manager software may block cookies, such as those that are not strictly necessary. Learn about Do Not Track.

Site Preferences
To personalize Your cookie settings, You may visit our web preference center here:

Cookie Settings

Opt-Out or Unsubscribe
You may choose to have Your name taken off of our registration list, cease marketing communications or newsletters from us by using the opt-out option in any marketing emails or text messages You receive from us or contact us using the information provided at the bottom of this Privacy Policy. We will respond to Your request within 10 days or as otherwise required by law.

Opting out of one form of communication does not mean You have opted out of other forms as well. For example, if You opt-out of receiving marketing emails, You may still receive marketing text messages if You have opted-in to receive them. However, if You submit a general opt-out request on this Site, we will take action to unsubscribe You based on the information provided. For example, if You provide Your name, email address, and phone number we will unsubscribe You from any lists linked to either Your name, email address or phone number.

Security

In order to prevent unauthorized access or disclosure, we have put in place physical, electronic and managerial procedures to safeguard and secure Your Personal Information.

We use standard Transport Layer Security (TLS) certificates to secure pages used for inputting users' Personal Information. However, unless we expressly advise You otherwise, the functionality on our Site does not provide a means for completely secure and private communications between us. Due to the open communication nature of the Internet, we cannot guarantee that communications between us will be free from unauthorized access by third parties.

If You believe that the Personal Information You have provided us has been compromised, or if You become aware of a potential security vulnerability in our Platform, please contact us using the contact information provided below.

International Service Users

Our website and applications are hosted in the United States. They are not currently intended for users residing or located in other countries, including those within Canada or the European Economic Area. Please be aware that as a user of our Services Your personal information may be transferred to and maintained on servers or databases located outside Your state, province or country and that such information may be processed and stored in the United States. By providing Your personal information, You confirm Your consent to having such personal data hosted and accessed in the United States.

To the extent that We collect and access data regarding individuals outside of the United States via our affiliates and subsidiaries, we will act in accordance with their applicable Privacy Policy(ies) under which the data was collected.

Nevada Resident Privacy Rights

Nevada law (SB 220) requires website operators to provide a way for Nevada consumers to opt out of the sale of certain information that the website operator may collect about them. We do not sell Your personal information to third parties as defined in Nevada law, and will not do so in the future without providing You with notice and an opportunity to opt-out of such sale as required by law.

California Resident Privacy Rights

If You are a California resident, then state law provides You rights with regard to the personal information collected online or offline. These rights are not absolute and in certain cases are subject to conditions or limitations as specified in California privacy law. We will not unlawfully discriminate against You because You exercised any of Your rights under California privacy law.

Exercising Your Rights Under Applicable Law

Verification Process

To protect Your privacy, we will verify Your identity prior to responding to a request for data. The request form will require some initial contact information that we will compare against our records. Upon submission of the form, You will be required to confirm Your request via email. You may receive an email from "On Behalf of Our Privacy Team" to which You must respond in order to verify Your identity and access our response(s). If You request disclosure of specific pieces of personal information, we may take additional steps as permitted or required by law. For example, we may call You to verify Your request, in addition to matching at least three pieces of personal information, You provide with information we maintain, and require a signed declaration, under penalty of perjury, that You are requesting Your own personal information.

If an authorized agent is submitting on Your behalf, we will require submission of either 1) a written authorization, signed by You, that authorizes that agent to make the specific request on Your behalf; or 2) other valid legal authorization.

Any personal information collected from You in connection with the verification of Your request will be used solely for the purposes of verification.

Contact Information

If You have any questions about this Privacy Policy, the practices of the Site, or Your dealings with the Site, please contact us via the following methods:

Renée & Company
Attn: Privacy Team
3 Sego Court
Sacramento, CA 95835

Toll-free: 1.844.661.2369

We will not retaliate against any person for filing a privacy complaint. Your privacy and confidence in our abilities is of utmost importance to us.