Privacy Policy

OVERVIEW

Welcome! You have arrived at an online service location (e.g. website), including any interactive features, widgets, plug-ins, applications, content, downloads and other online service  (collectively the “Service”) that is owned or operated by Innovaccer, Inc or one of our  subsidiaries or affiliates  (collectively referred to herein as “Innovaccer”). Our affiliates and subsidiaries include:

• Innovaccer, Inc (innovaccer.com)
• Cured, Inc (Cured) (cured.health)
• Pharmacy Quality Solutions, Inc (PQS) (pharmacyquality.com)
• Humbi LLC (Humbi) (humbi.ai)
• Gravity by Innovaccer (get-gravity.ai)
• Flow by Innovaccer (go-flow.ai)
• Comet by Innovaccer (comethealth.ai)

This Privacy Notice applies to the Service or where Innovaccer posts or shares a link to this Privacy Notice regardless of how you access or use the Service, whether via a personal computer, mobile device or other electronic media. The Service was created to provide information about Innovaccer and the services we provide. This Privacy Notice sets forth our policy with respect to the information, including personally identifiable data (“Personal Information”) and other information that is collected from visitors and users of the Service. We are dedicated to the responsible collection, use, maintenance, and disclosure of Personal Information and are committed to comply with applicable privacy rules and regulations. This Privacy Notice explains how we collect, use, and share information, including personal information, collected from the Service so that you can make informed decisions.

This Privacy Notice is incorporated into and subject to the Innovaccer Website Terms of Use.  To the extent we provide you notice on the Service of different or additional privacy policies (e.g. at the point of collection) those additional terms shall govern such data collection and use.

You understand and agree that Innovaccer and its authorized business partners, affiliates, subsidiaries or agents may collect, maintain, and process information provided by you, on and through the Services. You represent and warrant that you have permission to share any information, including Personal Information, you elect to provide to Innovaccer, you consent to such information being shared with third parties as described herein and that such information is accurate, current, non-misleading, consistent and relevant for the purpose for which you are providing the information.

INFORMATION WE COLLECT

The Personal Information we collect depends on how you interact with the Services you use and the choices you make. We collect Personal Information about you from different sources and in various ways when you use the Services, including name, email addresses and other contact information you provide directly, information collected automatically, information from third-party data sources, and information we infer or generate from other data.

If you contact us, subscribe to our newsletter, download or request printed materials, access podcast recordings or articles, utilize our ACO Compare Tool, request a demo, or utilize the chat or other live communication option, you may be required to provide your name, email address, phone number, the name of your organization, and any additional information in order to facilitate the request. If you send us correspondence, such as emails or letters or otherwise communicate with us, or if other users or third parties send us correspondence about your activities, we collect such information. Further, you may provide us with Personal Information if you attend one of our networking events or conferences or if you make employment inquiries.

By voluntarily providing Innovaccer with Personal Information, you are consenting to our use of it in accordance with this Privacy Notice. If you provide Personal Information to the Services, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Innovaccer and the authorized third parties referred to herein.

Information we collect when you use the Service

If you visit the Service or contact Innovaccer directly, the data and information collected may include:

• Information you provide to Innovaccer, such as:

• Personal information, such as your name and contact information; surveys, transcripts, and recordings of your communication with us;
• Information you provide or content you upload or submit to the Service; and
• Business information, including business contact information.

• Automatic information, such as:

• Web browser and usage information, including IP address;
• Geographic region;
• Browser types;
• Page view tallies;
• Time spent on each page;
• Browsing information; and
• Operating system and type of device used.

Information obtained from third parties

If you register for our Service on another website, use a website providing a product or service from Innovaccer, or use a website that helps facilitate your activity on the Service, that website may provide information about you and your transactions back to us.

If you choose to submit comments, photos, or content to our pages on third-party platforms, such as X, Facebook, YouTube, or LinkedIn (“Third Party Platform”), you may choose to include Personal Information. This is your choice. If you choose to share Personal Information on such a Third Party Platform, we may receive information about you, including your profile photo, name, and other information you choose to provide. If you want to limit the information available to us, it is your responsibility to review and/or adjust your privacy settings of such Third Party Platforms.  

We may receive additional information about you from other third parties, such as data from our marketing partners, and combine it with other information we have about you.

Non-Identifiable Data

Innovaccer may receive and store non-identifiable information itself, or such information may be included in databases owned and maintained by its affiliates, agents or service providers. The Service may use such information and pool it with other information to track, for example, the total number of visitors to the Service or downloads, the number of visitors to each page of the Service, and the domain names of our visitors’ Internet service providers.

COOKIES & OTHER TRACKING TECHNOLOGIES

Cookies: In operating the Service, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Service gives to your browser when you access the Service. Our cookies help provide additional functionality to the Service and help us analyze Service usage more accurately. For instance, the Service may set a cookie on your browser that allows you to access the Service without needing to remember and then enter a password more than once during a visit to the Service. When cookies are used to collect Personal Information, we do so in accordance with applicable law and regulation within the United States based on where you are located. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off.

Types of cookies we may utilize:

Log Files: Like many internet and mobile services, we may automatically gather certain information about our Service traffic and store it in log files. This information includes mobile device identifiers, browser type, IP address, mobile or internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data. We use this information, which does not identify individual users, to analyze trends, to administer the Service, to track users’ movements around the Service, and to gather demographic information about our user base.

We may use third-party tracking services that use log files, cookies, and possibly other techniques to track non-Personal Information about visitors to the Service in the aggregate. These services capture usage and volume statistics as well as geographical location data to compile usage reports and maps for optimization and troubleshooting purposes.

Pixel tags (also called beacons or pixels): these are first- or third-party tags installed on (or called by) a webpage or application. Pixel tags can retrieve certain information about your device and browser, including device type, operating system, browser type and version, website visited, time of visit, referring website, IP address and other similar information. Innovaccer uses pixel tags to identify conversions of users on our website and to assess certain website activity or events, such as when a user fills out a form or clicks on a link.

Software Development Kits (also called SDKs): function like pixels and cookies but operate in the mobile application context where pixels and cookies cannot always function. The application developer can install pieces of code (the SDK) into the application to collect certain information about user interaction with the application and information about the user device and network information.

Google Tag Manager: This is used to manage various tracking codes and marketing tags on our Service. This tool allows us to implement third-party tags from services like Google Analytics, which may collect user data such as IP address and browsing activity to help us understand website usage and improve the  Service.

Aggregated Personal Information: In an ongoing effort to better understand and serve the users of the Service, Innovaccer may conduct research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregate basis, and Innovaccer may share this aggregate data with its affiliates, agents and business partners. This aggregate information does not identify you personally. Innovaccer may also disclose aggregated user statistics in order to describe our services to current and prospective business partners, and to other third parties for other lawful purposes.

HOW TO CONTROL COOKIES & OTHER TRACKING TECHNOLOGIES

Web browsers are usually set to accept cookies. However, if you prefer not to receive cookies, you can modify your settings in most web browsers to accept or deny cookies or to request your permission each time a site attempts to set a cookie. You may also adjust your cookie preferences on the Service by utilizing the cookie preferences pop-up window when you visit the Service. Note that if you choose to disable cookies, not all functionality offered by the Service will be available or will work as effectively for you. Configuring how your browser handles cookies will not affect the use of other web tracking technologies such as pixel tags. Please note that online opt-outs are device and browser-specific. You may still see personalized ads from us while using a different device or browser, unless you also opt-out using that device or browser.

For further information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, you can visit www.youronlinechoices.com.

HOW WE USE INFORMATION WE COLLECT

We use the information we collect through the Service:

• To facilitate the products and services you request;
• To provide, maintain, improve, and enhance the Service;
• To communicate with you, provide you with updates and other information relating to the Service, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• To resolve disputes and troubleshoot problems including Service functionality issues;
• To facilitate transactions and payments or otherwise enable commercial transactions;
• For marketing purposes, such as to measure consumer interest in the products and services provided by us, develop and inform you about online and offline offers, products, services, and updates that may be useful, relevant, valuable or otherwise of interest to you;
• To customize your experience on the Service such as presenting tailored content;
• To detect and protect against error, fraud and other criminal activity, and respond to trust and safety issues that may arise;
• For compliance purposes, including to enforce the Terms of Use, or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency;
• To de-identify and aggregate information and use it for any lawful purpose; and
• For other purposes as otherwise described to you at the time of collection

HOW WE SHARE THE INFORMATION WE COLLECT

Innovaccer shares data as provided for herein or with your permission. Innovaccer does not disclose the content of transcripts, surveys, or recordings other than:

• To service providers performing services on behalf of Innovaccer;
• As provided in this Privacy Notice; or
• With your consent.

We may share any information that you provide through the Service in the following circumstances:

To deliver and improve the Service: We may de-identify information so that it is not personally identifiable and use and share such de-identified information for training and quality assurance purposes and to deliver and improve our Service.

Subsidiaries and Affiliates: We may share any information we receive with our subsidiaries and affiliates worldwide for any purposes described in this Privacy Notice.

Vendors and Service Providers: We may share any information we receive with third-party vendors and service providers who facilitate one or more aspects of the business, product and service operations that we provide to you through the Service (e.g., search technology, discussion boards, bill collection, affiliate and rewards programs). These vendors and service providers may access, process, or store Personal Information in the course of providing services to Innovaccer.

Analytics Partners: We use analytics services such as Inspectlet to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources.

Advertising Partners: We work with third-party advertising partners to show you ads that we think may interest you. These advertising partners may set and access their own cookies, pixel tags and similar technologies on the Service and they may otherwise collect or have access to information about you which they may collect over time and across different online services. Some of our advertising partners are members of the Network Advertising Initiative or the Digital Advertising Alliance. If you do not wish to receive personalized ads, please visit Network Advertising Initiative (http://optout.networkadvertising.org) or the Digital Advertising Alliance (http://optout.aboutads.info/) to learn about how you may opt out of receiving web-based personalized ads from member companies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.

Legal Requests: We may share your information if we reasonably believe that it:

• Is necessary to comply with a legal process (such as a court order, subpoena, or search warrant) or other legal requirement of any governmental authority;
• Would potentially mitigate our liability in an actual or potential lawsuit;
• Is necessary to enforce this Privacy Notice or the Terms of Use or any User Agreement;
• Is necessary to investigate and prevent unauthorized transactions or other illegal activities; and/or
• Is otherwise necessary or appropriate to protect our rights or property or the rights or property of any person or entity.

Merger, Sale of Business or other Asset Transfers: We may disclose and transfer information about you to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company, or we sell, liquidate, or transfer all or a portion of our business or assets.

Consent: We may also disclose information from or about you or your devices with your permission.

MARKETING COMMUNICATIONS

We may send you electronic newsletters, notification of account status, and other communications, such as marketing communications, on a periodic basis. In any communication from Innovaccer, we will offer you appropriate consent mechanisms, such as opt-out, for marketing and certain other communications and an unsubscribe option. As examples, you may opt-out as provided for in a specific email communication or contact us as described below in the section “Contact Us.” Please be aware that opt-outs may not apply to certain types of administrative communications, such as account status, website updates, or other communications.

YOUR CHOICES AND RIGHTS

Innovaccer is committed to respecting the legal rights individuals have regarding their Personal Information.

CHILDREN'S PRIVACY

The Service is not directed to individuals under 18. If you are under the age of 18, you may not use the Service or provide any personal information to use without a valid parental or legal guardian consent. Innovaccer does not knowingly collect personal information from individuals under the age of 18. If you learn that a child has provided us with personal information in violation of this Privacy Notice, please alert us at compliance@innovaccer.com.

If you are a parent or guardian of an individual under 18 and believe your child has provided personal information to Innovaccer, or if you are a California resident under the age of 18 and wish to remove content you have made publicly available, please contact us at compliance@innovaccer.com, where you may request to exercise your applicable access, rectification, cancellation, and/or objection rights.

Innovaccer reserves the right to immediately delete the information of any individual, to the extent permitted by law, who it believes is under the age of 18.

ACCESS OR UPDATE INFORMATION

To protect your privacy and security, we will verify your identity before granting access or making changes to your information. If you have registered a profile with Innovaccer, your Innovaccer ID and password are required in order to access or update your profile information through your profile settings.

THIRD PARTIES

Our Service may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Notice does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy notices before providing any information to them.

SECURITY

We make reasonable efforts to prevent unauthorized access, maintain data accuracy, and ensure correct use of information by employing reasonable security practices and procedures, including Internet security methods and technologies. However, as our Service is hosted electronically, we make no guarantees as to the security or privacy of your information.

INTERNATIONAL VISITORS

Our Service is hosted in the United States and intended for visitors located within the United States. If you choose to use our Service from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are consenting to transferring information from or about you or your devices outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Service. By providing any information, including information from or about you or your devices as provided for herein, on or to the Service, you consent to such transfer, storage, and processing.

YOUR CONSENT

By using our Service and/or by providing your information, you consent to the collection and use of the information you disclose on the Service by Innovaccer in accordance with this Privacy Notice. If you do not agree, please do not use, browse, communicate with, or access our Service.

EFFECTIVE DATE

The effective date of this Privacy Notice is August 1, 2025.

We may change this Privacy Notice and will post any changes on this page. The revised version will be effective when it is posted. We will also provide appropriate notice and choices to you, through the Service, by email, or other communication, if we materially change the ways in which we use or share personal information previously collected from you through the Service. We encourage you to visit this Privacy Notice periodically to learn of any updates.

CONTACT US

At Innovaccer, we are committed to resolving concerns about your privacy and our collection or use of your Personal Information. For any questions or inquiries, you may contact Innovaccer at compliance@innovaccer.com or write to us at our offices at 201 Mission Street, Suite 2900 San Francisco, CA 94105, Attn: Wendy Rubas, Data Protection Officer.

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CALIFORNIA PRIVACY NOTICE

This California Privacy Notice (the “Notice”) supplements the Privacy Notice set forth above with respect to specific rights granted under the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively the “CCPA”) to natural person California residents and provides information regarding how such California residents can exercise their rights under the CCPA. This Notice is only relevant to you if you are a resident of California as defined under the CCPA.

For the purposes of this notice, “Personal Information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, or as otherwise defined by the CCPA.  

The chart below provides the categories of Personal Information we have collected, disclosed for a business purpose, sold, or used for business or commercial purposes in the preceding 12 months. The examples of Personal Information provided for each category may not reflect all of the specific types of Personal Information associated with each category.

In the preceding twelve months, we have not sold any California resident’s Personal Information.

PURPOSES AND SOURCES

We collect Personal Information for the business or commercial purposes and from the sources set forth in “Information we collect” and “Information we collect when you use the Service” and “Information obtained from third parties” respectively, as outlined in the Privacy Notice above. We retain the categories of personal information set forth above in the Categories of Personal Information section of this Notice only as long as reasonably necessary for those business or commercial purposes set forth in “How we use Information we collect” in the Privacy Notice, except as may be required under applicable law, court order or government regulations.

DISCLOSURE OF PERSONAL INFORMATION

We share your Personal Information with affiliates and subsidiaries, third party service providers and contractors, and trusted business partners that support our provision of the Services.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may exercise the following rights:

• Notice at Collection: At or before the time of collection, you have a right to receive a notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information or used, whether such information is sold or shared, and how long such information is retained. You can find those details in this Notice and in the Sections “Information we Collect”, “Information we collect when you use the Service”, “Information obtained from third parties” and “How we use Information we collect”.
• Right to Know and Access: Subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations, you may submit a verifiable request for information regarding the: (1) Categories of Personal Information collected, sold, or disclosed by us; (2) Purposes for which categories of Personal Information are collected or sold by us; (3) Categories of sources from which we collect Personal Information; and (4) Specific pieces of Personal Information we have collected about you during the past 12 months.
• Right to Delete: Subject to our ability to reasonably verify your identity in light of the information requested and pursuant to relevant CCPA requirements, limitations, and regulations, as well as subject to certain exceptions, you may submit a verifiable request that we delete Personal Information about you that we have collected;
• Right to Correction: You can request to have your personal information and special personal information corrected.
• Right to Know About and/or Opt-out of Automated Decision Making: You can learn about automated decision making and choose to say ‘no’ to your personal information and special personal information being used in profiling for behavioral advertisement online.
• Right to Equal Service and Price: You have the right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain limitations.
• Shine the Light: You may request information once per calendar year about our disclosures of certain categories of Personal Information to third parties for their direct marketing purposes. Such requests must be submitted to us in writing using the How to Contact Us section below.

How to exercise your CCPA rights

To exercise your rights under the CCPA, please contact us at compliance@innovaccer.com.

To authorize an agent to make a request to know, delete, or opt out on your behalf, please send a written authorization signed by you and the authorized agent to us at compliance@innovaccer.com. If you designate an agent through a power of attorney, requests through an agent will be processed in accordance with California law pertaining to powers of attorney. Further, to provide, correct, or delete specific pieces of personal information we will need to verify your identity to the degree of certainty required by law. We will verify your request by asking you for two pieces of personal information and attempting to match those to information we maintain about you.

No Discrimination

We will not discriminate against you for exercising your rights under the CCPA, including by denying service, suggesting that you will receive, or charging, different rates for services, or suggesting that you will receive, or providing, a different level or quality of service to you.

COLORADO PRIVACY NOTICE

If you are a Colorado resident and the processing of personal information about you is subject to the Colorado Privacy Act (“CPA”), you have certain rights with respect to that personal information.

• Right to Know: The right to confirm whether or not we are processing your personal information and to access such data;

• Right to a Copy:  The right to a portable copy of the personal information we have collected from you;

• Right to Delete: The right to request deletion of personal information about you, subject to certain exceptions;  

• Right to Correct: The right to request correction of inaccurate personal information about you, taking into account the nature of personal information and purposes of processing such information;        

• Right to Opt-Out of Targeted Advertising: The right to request we stop future processing of personal information about you for such purposes; and

• Right to Opt-Out of the Sale of Personal Information: The right to request we stop future processing of personal information about you for such purposes.  

HOW TO EXERCISE YOUR CPA RIGHTS

To exercise your CPA rights, contact us at compliance@innovaccer.com.  We will respond to such requests within 45 days from when we receive your request, although we may be allowed to take longer to process your request under certain circumstances.  If we expect your request is going to take us longer than normal to fulfill, we will let you know.

You can opt out of the sale of your personal information or the use of your personal information for targeted advertising by contacting us at compliance@innovaccer.com.

In some cases, the law may allow us to refuse to act on certain requests.  When this is the case, we will endeavor to provide you with an explanation as to why.

APPEALING OUR DECISIONS MADE IN RESPONSE TO YOUR REQUESTS

In some cases, we may not act on your requests (for example, if another law applies that prevents us from deleting a piece of personal information). When this is the case, we will explain our reasons for not providing you with the information or taking the action you requested.    

Additionally, you have the right to appeal our decision by contacting us at compliance@innovaccer.com within 30 days after you receive our decision.  As part of your appeal, we request you provide us with information that we need (e.g., reference number) to identify denial of request.  We will respond to your appeal within 45 days of our receipt of the request, unless we need additional time to do so (up to 60 additional days), in which case we will notify you.  

ADDITIONAL INFORMATION ABOUT COLORADO PRIVACY RIGHTS

You may designate an agent to submit opt-out requests on your behalf under the CPA.  If you use an agent to submit such requests on your behalf, we will need to verify your identity, and the agent will need to provide us with your signed permission indicating they have been authorized to submit the request on your behalf.  

Further, to provide, correct, or delete specific pieces of personal information we will need to verify your identity to a reasonable degree of certainty. We will verify your request by asking you for two pieces of personal information and attempting to match those to information we maintain about you.  

Finally, you have a right to not be discriminated against for exercising these rights set out in the CPA.