Effective Date: August 3, 2023
Hinge Health, Inc. and our affiliates (collectively, “Hinge Health,” “we,” or “our”) are deeply committed to protecting the privacy and security of our customers’ - and our employees’, applicants’, and independent contractors’ (collectively “Personnel”) data. This Personnel Privacy Notice (the “Notice”) describes how Hinge Health collects, uses, and discloses (collectively, “Processes”) personal information about Hinge Health Personnel.
WHO DOES THIS NOTICE COVER?
Where we refer to “Personnel,” “employment” or “engagement” in this Notice, we do so for convenience only, and these terms should in no way be interpreted as purporting to confer employment status on non-employees such as applicants or independent contractors to whom this Notice also applies. This Notice does not form part of any contract of employment or engagement, does not confer any employment status or contractual right on any Personnel, and does not place any contractual obligation on us.
This policy does not apply to the actions of any company or entity that we do not control and to individuals who we do not directly employ or manage.
Should you have any questions about this policy or our practices or to get a copy of our Notice of Privacy Practices, please send an email to email@example.com.
ARE OTHER NOTICES APPLICABLE TO YOU?
WHAT PERSONAL INFORMATION DOES HINGE HEALTH COLLECT ABOUT YOU?
We collect personal information in order to manage our relationship with you during the course of your application, employment, or engagement with us.The categories of personal information we collect include:
Identifiers, such as a name, alias, postal address, signature, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, date of birth, citizenship, and other similar identifiers;
Eligibility to work information, such as citizenship, work permit, or visa application information;
Financial information, such as banking and direct deposit forms, salary, tax forms, and expense reimbursement records;
Information related to health insurance and other benefits, which relates to the application for, changes to, and enrollment in employee health and welfare benefits, life insurance, and retirement accounts, details on such benefits such as contribution and deferral levels, the names and other legally required information of beneficiaries, information about your spouse, partner, and dependents, and emergency contact information;
Characteristics of protected classifications under state or federal law, such as age and gender, marital status, race or ethnicity, sexual orientation, veteran status, and disability status;
Internet or electronic network activity information, including, but not limited to, browsing history, search history, information regarding your interaction with our websites, applications, and platform, and other information collected via cookies, web beacons and similar technologies;
Geolocation data when you use certain Hinge Health-issued devices on Hinge Health properties, such as our distribution centers;
Audio, visual, or similar information, such as photos and information gathered via cameras and CCTV;
Professional and employment-related information, such as performance reviews and disciplinary reports; your applications, resumes, curriculum vitae, and cover letters, personal information provided by references or included in criminal background checks, and our assessment of recruitment information; job title, picture, and employee number; work-related documentation including records, forms, logs, and agreements and benefits elections;
Health and health-related information, such as medical conditions and health records or information related to symptoms of, or risk of exposure to, certain illnesses (e.g., contact with others who may be sick or relevant travel history);
Education information, such as names and graduation dates of educational institutions attended;
Employee-only social networking platform interactions, including, but not limited to, profile information, content submitted to the platform, and usage activity; and
Monitoring: We reserve the right to monitor the use of our premises, equipment, devices, computers, network, applications, software, and similar assets and resources. In the event such monitoring occurs, it may result in the collection of personal information about you. Some Hinge Health facilities are equipped with surveillance equipment, such as cameras and CCTV, which may capture your image or information about your movements, and which may be used to protect the safety of Hinge Health staff, visitors, and property, to monitor and troubleshoot issues with equipment or technology, or otherwise for any lawful purpose. In addition, any and all telephone conversations or transmissions, electronic mail or transmissions, or internet access or usage by Personnel by any electronic device or system, including but not limited to the use of a computer, telephone, wire, radio, or electromagnetic, photoelectronic, or photo-optical systems may be subject to monitoring at any and all times by any lawful means. This is not meant to suggest that all Personnel will in fact be monitored, but to alert you that, when using Hinge Health equipment and resources, you should not have any expectations of privacy with respect to your use of such equipment or resources. We will ensure that any personal information generated by this monitoring is treated in accordance with this Notice.
Sensitive Information: In some cases, we may collect sensitive personal information about Personnel, which requires a higher level of protection. Please note that, where permitted by law, we may collect, store, and use sensitive personal information about you, including race, ethnicity, veteran status, disability status, gender, sex, age, marital status, and health and medical conditions. We collect this information for specific purposes, such as to accommodate a disability or illness, provide benefits, comply with legal obligations such as anti-discrimination or diversity regulations (where applicable), protect the health and safety of our employees, and facilitate internal programs relating to diversity, equity, inclusion, and anti-discrimination. Please be assured that we will only use such sensitive information for the purposes set out in this Notice, or as otherwise described to you at the time such information is collected -- and in accordance with applicable law.
WHERE DOES HINGE HEALTH OBTAIN YOUR PERSONAL INFORMATION?
Generally, we collect personal information directly from you in circumstances where you provide it (for example, when you applied to work for us, during the onboarding process and benefits enrollment, as part of health or safety screenings, and through participation in voluntary employee programs or platforms).
We may also collect personal information automatically, such as when monitoring the use of our premises, equipment, devices, computers, network, applications, software, or similar assets and resources. We may also obtain personal information from your previous employers or educational institutions, from other employees (e.g. performance reviews), third-party service providers (e.g. benefit providers), your named references, medical professionals, legal bodies, and publicly accessible sources such as your LinkedIn profile and other social media platforms. Once we have obtained your personal information, we may store it outside of the United States in accordance with our data privacy and security policies.
HOW DOES HINGE HEALTH USE YOUR PERSONAL INFORMATION?
We use personal information for human resources and other business purposes, including establishing, managing, and terminating employment relationships and to manage our business, keep our systems secure, and to comply with specific legal obligations. In particular, we use personal information for the following purposes:
Recruitment purposes, such as communicating with you about your interest in a role with Hinge Health, job opportunities, and your job applications; processing job applications; assessing your suitability for a role with Hinge Health; identifying candidates for open roles with Hinge Health; to conduct a background check on you, but only after extending a conditional offer of employment;
Personnel management, such as monitoring assignments, evaluating performance, making compensation determinations, training Personnel, communicating with you and responding to your requests, inquiries, and comments, carrying out disciplinary and grievance investigations, hearings, and appeals, making and recording disciplinary decisions, and considering those decisions in subsequent relevant employment and business decisions;
Operational purposes, such as distributing payroll and company benefits, updating Personnel files, conducting audits and training, reimbursing business expenses, providing IT support, facilitating participation in voluntary employee programs and platforms, and managing shifts, working hours, and attendance;
Benefits administration purposes, such as administering and maintaining group health insurance benefits and additional wellness programs, retirement plans, life insurance, disability insurance, leave programs, and other Hinge Health-offered benefit programs;
Marketing activities, such as using Personnel photos, videos, social media posts, and other content for internal and external marketing activities;
Statistical and analytical purposes to understand and improve worker satisfaction, engagement, and performance;
Administration of our applications, software and systems, including ensuring the security of our workforce, guests, property and assets and to monitor and audit network traffic and information in such applications, software and systems as permitted under applicable law;
Legal and compliance purposes, such as implementing internal policies, detecting, investigating, and responding to suspected fraud, security incidents, or other activity that is illegal or violates Hinge Health’s policies, protecting Hinge Health’s and others’ rights and property, exercising a legal claim, cooperating with law enforcement investigations and complying with applicable laws, regulations, legal processes, or governmental requests;
To protect the health, safety, and vital interests of Personnel or of another natural person, such as during an emergency where the health or security of Personnel is in danger, to prevent physical harm or financial loss, or to comply with our legal obligations or public health recommendations;
To comply with legal obligations and internal policies relating to diversity, inclusion, and anti-discrimination;
As necessary and appropriate to provide reasonable workplace accommodations;
As necessary for the performance of a contract or in order to take steps at the request of our Personnel prior to entering into a contract (if you do not provide certain information when requested, we may not be able to perform the contract we entered into with you, such as paying you or providing a benefit); and
To enable solely internal uses in a lawful manner that are reasonably aligned with expectations of Personnel based on our work relationship and that are compatible with the context in which the information was provided to Hinge Health.
TO WHOM DOES HINGE HEALTH DISCLOSE YOUR PERSONAL INFORMATION?
Within Hinge Health: We disclose personal information to Personnel and affiliates who need to know the information for the purposes described above, including Human Resources, Payroll, and Information Technology departments. We also disclose personal information with legal affiliates to the extent necessary.
Third-Party Service Providers: We use third party service providers and contractors to perform services on our behalf. For example, we disclose certain information with service providers who assist with talent acquisition, the administration of payroll, pension, benefits, performance management, training, communication platforms, and expense management, and facilitate internal programs relating to diversity, inclusion, and anti-discrimination.
Professional Advisors: We disclose information with our professional advisors, including accountants, auditors, lawyers, insurers, and bankers, if needed. We only permit these advisors to Process your personal information for specified purposes and, as appropriate, in accordance with our instructions and the provisions of this Notice and applicable law. Law Enforcement, Government Authorities, Regulators, and Similar Third Parties: We disclose personal information to courts, government authorities, independent external advisers, and internal compliance and investigation teams if we believe such disclosure is in accordance with, or is otherwise required by, any applicable law regulation, or legal process. Other Third Parties: In certain limited circumstance, we may disclose personal information with other third parties, including (a) to comply with our legal obligations, to protect the rights and property of Hinge Health, our customers and the public, to cooperate with law enforcement investigations, and to detect and respond to suspected illegal activity and threats to the health or safety of any person or of our systems or services; (b) in connection with, or during negotiations of, any merger, joint venture, sale of company assets, financing, or acquisition of all or a portion of our business, assets or stock by another company (including in connection with any bankruptcy or similar proceedings); and/or (c) with your consent and at your direction. In certain circumstances and only as necessary in connection with business operations, work contact details may be provided to customers, potential customers, and other third parties, where the disclosure is required by role. We may also disclose aggregated or de-identified information, which cannot reasonably be used to identify you. Hinge Health Processes, maintains, and uses this information only in a de-identified fashion and will not attempt to re-identify such information except as permitted by law.
QUESTIONS AND QUERIES
If you have any questions regarding this Notice or questions regarding your privacy rights, please contact us at firstname.lastname@example.org or (855) 902-2777.
We may change this Notice from time to time. Each version of this Notice is identified by its effective date. If we make changes to this, we will notify you by revising the date at the top of this Notice. If we make material changes, we will provide you with additional notice, such as by sending you a notification.
HINGE HEALTH, INC. ADDENDUM AND NOTICE AT COLLECTION FOR CALIFORNIA PERSONNEL
This Hinge Health Addendum for California Personnel (“Addendum”) supplements the Hinge Health Personnel Privacy Notice (“Notice”) and provides additional information about our privacy practices and your privacy rights, as required by California law. If you are a California resident, this Addendum applies to you.
In the preceding 12 months, we have collected the following categories of personal information: identifiers; characteristics of protected classifications under California or U.S. law; internet and electronic network activity; geolocation data; audio, visual, or other sensory information; professional or employment-related information; education information; and sensitive personal information. We collect such categories of personal information directly from you when you submit information to us, indirectly from parties such as references and emergency contacts, automatically through surveillance equipment or other devices, and we also develop data during our interactions with you.
We collect, use, and disclose personal information for the following business purposes: general administration of Personnel, payroll processing, recruiting and hiring, human resources purposes, benefits administration, to protect the interests of Hinge Health and others, legal compliance purposes, to operate third party relationships to conduct our business, and as otherwise explained in our Notice. We do not use or disclose your sensitive personal information for purposes other than those expressly permitted by California law.
In the preceding 12 months, we have disclosed the following categories of personal information for business purposes to the following categories of recipients:
Category of Personal Information
Categories of Recipients
Identifiers, such as your name, mailing address, and email address
Recruitment and personnel management service providers, benefits providers, payroll providers, fraud detection and security service providers
Characteristics of protected classifications under state or federal law, such as your gender and race
Recruitment and personnel management service providers, and benefits providers
Commercial information, such as your bank account and routing number
Recruitment and personnel management service providers, and payroll providers
Internet or electronic network activity information, such as your use of our intranet, email, and other collaboration platforms
Fraud detection and security service providers
Geolocation data, such as where you clock in for a shift
Fraud detection and security service providers
Audio, visual, or similar information, such as video data from CCTV
Recruitment and personnel management service providers, fraud detection and security service providers
Professional and employment-related information, such as your resume, employment application, and performance reviews
Recruitment and personnel management service providers, benefits providers, immigration services providers, and payroll providers
Sensitive personal information, such as your race, ethnicity, and veteran status
Recruitment and personnel management service providers, benefits providers, payroll providers, government authorities, and regulators
YOUR PRIVACY RIGHTS
California residents have certain rights with respect to their data, including the following:
Right to Access: You may ask us to confirm whether we are processing your personal information and, if so, to provide you with a copy of the personal information we hold about you (along with certain other details).
Right to Correction: If the personal information we hold about you is inaccurate or incomplete, you are entitled to ask for correction or completion.
Right to Deletion: You may ask us to delete or remove your personal information in some circumstances—for example, if we no longer need it.
To request access, correction, or deletion of your personal information, please contact us at email@example.com, (855) 902-2777, or via mail at 455 Market Street, Suite 700, San Francisco, CA 94105. You may designate an authorized agent to exercise privacy rights on your behalf by providing the authorized agent signed permission to submit the request on your behalf. If an authorized agent submits a request on your behalf, we may need to contact you to verify your identity and protect the security of your personal information. If you are an authorized agent seeking to make a rights request, please contact us at firstname.lastname@example.org or (855) 902-2777.
Any request to exercise one of these rights will be assessed by Hinge Health on a case-by-case basis. There may be circumstances in which we are not legally required to comply with your request because of a relevant legal exemption provided for under applicable law. We will not discriminate or retaliate against you for exercising your privacy rights. If you choose not to disclose certain personal information, this may limit our ability to perform certain activities, such as administer your payroll or benefits.
“SALES” AND “SHARING” OF PERSONAL INFORMATION
We do not “sell” or “share” your personal information as those terms are defined under California law. We also do not have any knowledge of any “sales” or “sharing” of the personal information of minors under 16 years of age.
The length of time we retain your personal information depends on the status of our relationship with you and the requirements of applicable law. We will retain your personal information for as long as your employment or engagement with us lasts and for a certain period thereafter, after which point it will be deleted or archived in accordance with applicable law. To determine that period, we take into account a number of factors, including our legal and regulatory obligations (such as financial reporting obligations and equal opportunity or anti-discrimination reporting obligations) and whether we may need to retain personal information to resolve disputes, make and defend legal claims, conduct audits, pursue legitimate business purposes, and/or enforce our agreements.
Last updated August 3, 2023
Toll-free telephone number: 1-855-902-2777
Postal Address: Hinge Health Attn: Compliance 455 Market Street, Suite 700 San Francisco, CA 94105