At Phreesia, Inc. (“Phreesia,” “we,” “us” and words of similar import), we know you care about your privacy. This Privacy Policy (“Policy”) describes how Phreesia may collect, use, and disclose information as it relates to our website,  www.phreesia.com (“Site”), customers, potential customers and health care providers, service providers, events, and interactions you may have with us or third parties.

This Policy only applies to Phreesia’s activities and this Site. This Policy does not apply to third-party websites that are accessible through this Site nor third-party services utilized by this Site or Phreesia. If you submit your information to any third-party sites or services, your information will be governed by their privacy policies and not this Policy. To learn how third-party sites collect and use your information, you should read their privacy policies.

In general, we collect and use information about you for the purposes of contacting you to provide information about Phreesia’s products and services, to create our products, to provide services to you, or to share other Phreesia-related information. We do not sell, rent or otherwise share or disclose your private, personally identifiable information to third parties without your consent, or as otherwise explained in this Policy. (See “Information You Provide to Us” and “Restrictions on Disclosing Information to Third Parties” below).

Because of the nature of our business, our services and benefits are not designed to appeal to minors. We do not knowingly attempt to solicit or receive any information from children. If you are under age 13, please do not register on this Site, make any purchases through this Site, or send any information about yourself to us. In the event that we learn that we have collected personally identifiable information from a child under age 13, we will delete that information and terminate the child’s account from our databases. If you believe that we might have any information from or about a child under age 13, please contact us at: support@phreesia.com.

Phreesia collects specific information through several different points, including but not limited to the following:

On our “Contact Us” page and “Request a Demo” section, the following information is required: your first and last name, your organization’s name, your business telephone number, your business email address, and your organization type. You may also provide this information or other information to us by completing a separate form, submitting a request for information, subscribing to an email list, providing feedback, requesting information about conferences and tradeshows, giving us a business card, signing up for or interacting with us at events, tradeshows, conferences or conventions, or communicating with us through the Site. There also may be other, similar ways that you provide us with information that are not listed above. Submitting this information will allow you to find out if you are eligible for Phreesia’s products and services, and will help us to better serve you in follow-up communications regarding our products, services, and other Phreesia-related information. If you are a Phreesia client or an employee or contractor of a Phreesia client, we may collect your information from you to provide you with our services.

If you correspond with us via email, the postal service or any other form of communication, we may retain such correspondence and the information contained therein and use it to respond to your inquiry and/or notify you of Phreesia products and services, conferences, company news or other Phreesia-related opportunities. Importantly, your email and postal address information is never sold, given or otherwise shared or disclosed to third parties except as set forth herein.

If you no longer desire our services, you may deactivate them (subject to the terms and conditions of any separate agreement you may have with Phreesia) by emailing our Customer Support team at: support@phreesia.com. You also may call us at (888) 654-7473. Our Customer Support team additionally can assist you in updating your personally identifiable information through any of these methods.

If you no longer wish to receive promotional communications from Phreesia, you may opt out of future messages by following the instructions included in each communication, or by emailing us at: support@phreesia.com. You may also opt out by contacting us at (888) 654-7473.

We will retain and use your information for as long as your account is active, or as needed to provide our services to you. We will also retain and use your information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

We may post customer testimonials, comments or reviews on our Site that may contain personally identifiable information. We do obtain customer consent prior to posting testimonials. If you wish to update or delete a testimonial, contact us at: support@phreesia.com.

Phreesia’s website includes social media features, including links to our Facebook, LinkedIn and Twitter accounts. Social media websites are hosted by third parties. Your interactions with various social media features are governed by the privacy policies of the companies that provide them.

Subject to their third party’s privacy policies, these social media websites may collect your internet protocol (IP) address and identify which pages you visit on our Site. Social media websites also may set cookies to enable their features to function properly.

Our Site offers publicly accessible blogs. You should be aware that any information you provide within these blogs may be read, collected and used by those who access them. To request the removal of any personal information you submit to openly viewable parts of the Site, please contact us at: privacy@phreesia.com. However, please be aware that in some cases, we may not be able to remove the information you have submitted. We will notify you if that is the case. Alternatively, if you used a third-party application to post your information, you can delete it by either logging on to the third-party application and removing it directly, or by contacting the third-party application company.

Some of our pages utilize framing techniques to serve content to and from our partners while preserving the look and feel of our Site. Please be aware that you are providing your personal information to these third-party partners and not to www.phreesia.com.

We use service providers and other third parties for the purposes described in this Policy and also for marketing or ad measurement purposes. We may receive information from third parties, like lead generation providers, content sponsors, social media platforms, or others. This information may include marketing or demographic information, your business or contact information, information about you from social media platforms that you use to interact with us or the Site and other information. We may combine this information with other information you provide to us or that we collect from you or from public sources.

Tracking technologies such as cookies, beacons, tags and scripts are used by Phreesia and our analytics providers. These technologies are used to administer the Site, enhance users’ web-browsing experience, analyze trends, gather information about users’ activities on this Site and gather demographic information voluntarily provided by users. We may receive reports on the use of these technologies from their companies on both an individual and aggregate basis.

Cookies further help improve our Site and personalize your web-browsing experience by giving us a better understanding of your interests and needs as they relate to our Site. You can control our use of cookies by changing your browser settings to block some or all cookies. If you block cookies, you may still use our Site, but your ability to use some features or areas of the Site may be limited.

As is true of most websites, we automatically gather certain information and store it in log files. This information may include browser types, internet service providers (ISPs), referring/exit pages and operating systems.

We do not automatically link this data to other information we collect about you. Our cookies do not enable us to collect or aggregate data that can identify you or your household unless you willingly choose to engage with and/or identify yourself through one of our technologies, such as our web forms or chatbot.

We use Local Storage (LS) such as HTML5 to store content information and preferences. Third parties with whom we partner to provide certain features on our Site also may use LS such as HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 Local Storage Objects (LSOs).

We may monitor and record inbound and outbound calls that are received or placed by us for quality assurance, training, and/or educational purposes. You will be notified that the call may be recorded prior to the recording. If you do not want to be recorded, you may end the call or let the caller know of your preference. We may collect personal information that you elect to disclose on the call. We ask that you limit the amount of sensitive information you disclose. Call recordings are stored on Phreesia’s secure network and/or systems of Phreesia’s service providers supporting these business activities. Our internal teams, third parties who support our business operations, and other third parties as required or permitted by law may access call recordings. These recordings will be used solely for the purposes specified in this policy.

We may disclose all of the information that we collect as stated above and in accordance with the terms set forth in this Policy. We do not reveal personally identifiable information about you to third parties for their independent use unless: (1) you request or authorize it; (2) the information is provided to comply with the law (for example, to comply with a search warrant, subpoena or court order), to enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (3) the information is provided to agents, vendors or service providers that perform functions on our behalf; (4) the information is provided to address emergencies or acts of God; (5) the information is provided in the event (whether prospective or actual) of a merger, acquisition or any form of sale of some or all of Phreesia’s assets, in which case, personal information about you that is held by us may be among the assets transferred to the (prospective) buyer, and you will be notified via email and/or a prominent notice on our Site of such an ownership change or uses of your personally identifiable information, as well as of any choices you may have regarding the use of your personal information; or (6) the information addresses disputes or claims, or must be disclosed to persons holding a legal or beneficial interest. We may also gather aggregated data about our members and Site visitors and disclose the results of such aggregated information to our partners, service providers, advertisers and/or other third parties.

We follow generally accepted security standards to protect personally identifiable information submitted to us, both during its transmission and after we receive it. However, no internet transmission method or electronic storage practice is 100-percent secure. Therefore, we cannot guarantee its absolute security. If you have any questions about security on our Site, contact us at: privacy@phreesia.com.

If you are a California resident, as defined in the California Code of Regulations, you have rights under the California Consumer Privacy Act of 2018 (“CCPA”). Below, we provide a description of your rights and disclosures about your personal information.

Personal information has the meaning defined in CCPA. Personal information includes information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked—directly or indirectly—to you. According to California law, personal information does not include publicly available information from government records or de-identified or aggregated consumer information.

1. Collection, Uses and Disclosures of Your Personal Information

   We collect categories of personal information described in this Privacy Policy from the sources identified in this Privacy Policy.

   We may use your personal information for our legitimate business purposes, as described in our Privacy Policy. In addition, during the past twelve months, we may have disclosed these categories of personal information for a business purpose to vendors with which we work.
   Phreesia does not sell your personal information.

2. Your Rights and How to Exercise Them
   1. Right to Know and Access the Personal Information We Collect and Share

      The CCPA gives you the right to request that we disclose the specific pieces of personal information we have collected about you, which we will do after we receive and validate your request.

      When you make a request to receive your personal information, we will send you a list of the categories of personal information that we may have disclosed about you, as well as the categories of third parties to whom your personal information may have been disclosed.

      You have the right to make two free requests within any 12-month period. We will make the disclosure within 45 days of receiving your request, unless we request an extension. In the event that we reasonably need a 45-day extension, we will notify you of the extension within the initial 45-day period.

   2. Right of Deletion

      You have the right to request that we delete your personal information, subject to certain exceptions. After we receive and validate your request, we will delete your personal information, as well as direct our service providers to delete your personal information, unless an exception applies.

   3. Right of Correction

      You have a right to request that we correct inaccurate personal information, which we will do after we receive and validate your request.

   4. Right to Non-Discrimination

      You have the right not to be subject to discriminatory treatment for the exercise of your privacy rights under the CCPA. We will not discriminate or retaliate against you for exercising your privacy rights.

3. Retention of Personal Information

   We may retain your personal information for as long as it is necessary for fulfilling the purposes for which we collected it, to satisfy legal and regulatory requirements, or as required or permitted by applicable law.

4. How to Contact Us and Exercise Your Rights

   If you or an authorized agent have questions about, or wish to exercise, your rights under this notice, you may reach us at privacy@phreesia.com or by calling 844-520-0002 toll-free and leaving a voicemail message.

   We may ask you for additional information to verify your identity, such as the date you submitted information to our website or a copy of government-issued identification.

We reserve the right to modify this Policy at any time, so please review it frequently. The provisions contained herein supersede all previous notices or policies regarding our privacy practices and any previous terms and conditions that governed the subject matter covered herein.

If you have any questions about our Policy, any concerns about privacy at Phreesia, or the use of this Site in general, please contact us at privacy@phreesia.com, or send correspondence to the following address:

Phreesia, Inc.
Attn: Privacy Officer
1521 Concord Pike
Suite 301, PMB 221
Wilmington, DE 19803