Privacy Policy

Digital Therapeutics, Inc. (“Pelago”, “we”, ”our” or “us”) is committed to protecting and respecting your privacy. This Privacy Policy sets out who we are, how we collect, store, process, transfer, share and use data that identifies, is associated or could be associated with, or is linked to you (“personal information”) and how you can exercise your privacy rights.

If you have any questions or concerns about our use of your personal information, then please contact us using the contact details provided at the bottom of this Policy.

Pelago provides a platform and services for treating individuals with substance use management challenges through a combination of digital content, as well as coaching programs, cognitive behavioral therapy and medication assisted treatment delivered by our professional entities via the Pelago mobile application or its desktop equivalent (“App”). For information about how our professional entities provide services to you and handle information protected by the Health Insurance Portability and Accountability Act, please see our separate Privacy Policy and Notice of Privacy Practices when you register for services with our professional entities through the App or our registration website.

This Privacy Policy only applies when you:

• Access and use this corporate website www.pelagohealth.com (“Site”); please note the Site is Pelago’s commercial website and not subject to HIPAA;
• Communicate with us electronically, such as via email; or
• Apply for a job with us.

Please read this Privacy Policy and understand how we collect, store, use and disclose your personal information before accessing or using the Site.

Pelago is the controller of the personal information we hold about you in connection with your use of the Site. This means that we determine and are responsible for how your personal information is used. You may contact us using the information located in the {Contacting Us} section below.

2.1 We may have collected personal information about you:

• From You: We collect personal information that you voluntarily submit directly to us when you use the Site. This can include information you provide to us through the Site, correspond with us, subscribe to our mailing lists or other forms of marketing communications, report a problem with the Site, or use some other feature of the Site.
• From Your Use of Our Site: We also automatically collect personal information indirectly about how you access and use this Site, such as the device you use.

You have the choice whether to provide us with your personal information. In some circumstances, if you choose not to provide such personal information, we may not be able to respond to your requests.

3.1. Information you provide to us directly.

The table at Annex 1 describes the categories of personal information we collect about you, how we use that information, the third parties with to whom we may disclose that information, and for users based in the European Economic Area (“EEA”) and UK, the legal basis which we rely on to process the personal information.

3.2 Information we automatically collect.

The table at Annex 2 describes the categories of personal information we collect about you automatically, how we use that information, the third parties with to whom we may disclose that information, and for users based in the EEA and UK, the legal basis which we rely on to process the personal information.

3.3.

We may link or combine the personal information we collect about you and the information we collect automatically. This allows us to provide you with a personalized experience regardless of how you interact with us on this Site.

3.4.

We may anonymize and aggregate the personal information we collect (so that it does not directly identify you). We may use anonymized information for purposes that include testing our IT systems, research, data analysis, improving the Site, and developing new products and features. We may also share such anonymized and aggregated information with others such as our clients.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. In general, we keep information for as long as we are required to do so under applicable law, which can be as long as seven (7) years. Where we are not under a legal obligation to maintain information for a longer period, our general practice is to dispose of information after one (1) year from your last interaction with us.

We may share your personal information with the following parties (as described in Annexes 1 and 2):

• Service providers and contractors: we may share your personal information with service providers and contractors who perform services for us or on our behalf, which may include providing professional services (such as legal and accounting services), mailing, email, chat, or video services, fraud prevention, cloud or web hosting, analytic services. We contractually require service providers and contractors acting on our behalf to take reasonable steps to protect your personal information and to not use your personal information for any purpose other than that for which it was given to the service provider or contractor.
• In connection with a corporate business transaction: your personal information may be disclosed to third parties in connection with a transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business.
• Affiliates: Other companies owned by or under common ownership as Pelago, including our subsidiaries (i.e., any organization we own or control) ultimate holding company (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies will use your personal information in the same way as we can under this Privacy Policy.
• To federal, state, or local government agencies or to other third parties as required by applicable law or pursuant to a valid legal warrant, subpoena, court order, or other legal or regulatory mandate, or as necessary for us to defend or assert legal claims.
• Analytics companies. We use selected third parties to collect data about how you interact with our Site. This information may be used to, among other things, improve the functionality of our Site.
• From time to time, we may disclose your personal information to parties such as law enforcement or other government agencies when we, in good faith, believe you or others are acting unlawfully, when we believe it is necessary or appropriate to satisfy any law, regulation or other governmental request, to operate our business properly, to protect or defend our rights or the rights or well-being of our users, and when we believe disclosure is necessary or appropriate to protect the health and safety of our employees, other consumers, and the general public.

6.1.

From time to time we may contact you (by email, text or push notification) with information about our services. You consent to receive these messages when you agree to our {Terms of Use}.

6.2

We may also send you marketing messages. For some marketing messages, we may use personal information we collect about you to help us determine the most relevant marketing information to share with you. 

6.3.

If you are an EEA or UK-based user, we will only send you marketing emails, text messages or push notifications if you have given us your consent to do so.

6.4

To stop receiving marketing email or text message communications, you can follow the unsubscribe instructions in the communication. 

7.1. Safeguards.

We implement technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. The measures we use are designed to provide a level of security appropriate to the risk of processing your personal information. Specific measures we use include, depending on the type of data, encrypting your personal information in transit and at rest; protecting your information with firewalls, anti-malware and data loss prevention systems; conducting vulnerability scans and penetration tests on systems holding your information; training our employees on security awareness and data handling topics; and having a third-party audit of our security controls annually.

7.2. International Transfers of your Personal Information.

The personal information we collect may be transferred to and stored in countries outside of the jurisdiction you are in where we and our third-party service providers have operations, including in the United States. If you are accessing our Site from the EEA or UK, in the event of such a transfer, we ensure that either: (i) the personal information is transferred to countries recognized as offering an equivalent level of protection; or (ii) the transfer is made pursuant to appropriate safeguards, such as the Standard Contractual Clauses adopted by the European Commission or as may be applicable, the equivalent clauses approved by the UK Government. For more information on the transfer safeguards we rely on and where they have been made available you may contact us by using the details in the {Contacting Us} section below

8.1. Modifying or deleting your information.

If you have any questions about reviewing, modifying, or deleting your information, you can contact us at privacy@pelagohealth.com. We may not be able to modify or delete your information in all circumstances.

9.1. If you are residing in the EEA or the UK, you may have the following rights:

• Right of access. The right to obtain: (i) confirmation of whether, and where, we are processing your personal information; (ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods; (iii) information about the categories of recipients with whom we may share your personal information; and (iv) a copy of the personal information we hold about you.
• Right of portability. You have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
• Right to rectification. You have the right to obtain rectification of any inaccurate or incomplete personal information we hold about you without undue delay.
• Right to erasure. You have the right, in some circumstances, to require us to erase your personal information without undue delay if the continued processing of that personal information is not justified.
• Right to restriction. You have the right, in some circumstances, to require us to limit the purposes for which we process your personal information if the continued processing of the personal information in this way is not justified, such as where the accuracy of the personal information is contested by you.
• Right to withdraw consent. If you have provided consent for the processing of your personal information, you have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal. However, in certain circumstances, if you withdraw your consent, we might not be able to continue providing Services to you as a result.
• Right to opt-out of automated decision making. We use automated decision making to determine your eligibility for certain services. You can opt-out of our use of this form of decision making.

9.2.

You also have the right to object to any processing based on our legitimate interests where there are grounds relating to your particular situation. There may be compelling reasons for continuing to process your personal information, and we will assess and inform you if that is the case. You can object to marketing activities for any reason.

9.3.

If you wish to exercise one of these rights, please contact us using the details in the {Contacting Us} section below.

9.4.

Due to the confidential nature of data processing we may ask you to provide proof of identity when exercising the above rights. This may be done by a number of methods, including you providing a scanned copy of a valid identity document or a signed photocopy of a valid identity document.

9.5

You also have the right to lodge a complaint to your local data protection authority. If you are based in the EEA, information about how to contact your local data protection authority is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en#member-dk.

10.1

If you are a resident of California and to the extent our Services are covered by applicable state law, you may have additional privacy rights, which you can read about in {Annex 4}.  While we are not subject to CCPA and CPRA, we will honor your individual opt-out requests and associated privacy rights.

11.1

If you are a Nevada resident, you have the right to opt out of the sale of certain personal information, including your name and mailing address, to third parties. As of the date of this Privacy Policy, we do not sell any personal information to any third party.

13.1

Our Site uses cookies and similar technologies such as pixels and Local Storage Objects (LSOs) like HTML5 (together “cookies”) to distinguish you from other users. This helps us to provide you with a good experience and allows us to monitor and analyze how you use and interact with our Site so that we can continue to improve our performance. It also helps us and our advertising partners to determine products and services that may be of interest to you, in order to serve you targeted advertisements. Please see Annex 3 for our Cookie Notice.

13.2.

Although we do our best to honor the privacy preferences of our users, we are unable to respond to Do Not Track signals set by your browser at this time.

13.3

Our emails may contain tracking pixels that identify if and when you have opened an email that we have sent you, how many times you have read it and whether you have clicked on any links in that email. This helps us measure the effectiveness of our marketing email campaigns, make the emails we send to you more relevant to your interests and to understand if you have opened and read any important administrative emails we might send you. Most popular email clients will allow you to block these pixels by disabling certain external images in emails. You can do this through the settings on your email client – these generally give you the option of choosing whether emails will display “remote images”, ”remote content” or “images” by default.

14.1

Our Site may, from time to time, contain links to and from third party websites, including those of other users, our partner networks, advertisers, partner merchants, news publications, retailers and affiliates. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we are not responsible or liable for their policies, actions, or omissions. Please check the individual policies before you submit any information to those websites.

15.1

This Site is not directed at persons under 18 and we do not knowingly collect personal information from any persons under 18 on this Site. If you become aware that your child has provided us with personal information through this Site without your consent, then please contact us using the details in the {Contacting Us} section below so that we can take steps to remove such information. We do not sell or share the information of any person under 18.

16.1

We may update this Privacy Policy from time to time and so you should review this page periodically. When we change this Privacy Policy in a material way, we will update the “Last Updated” date at the top of this Privacy Policy. Changes to this Privacy Policy are effective when they are posted on this page. If we make material changes to this Privacy Policy we will make reasonable efforts to notify you of those changes to the extent required to do so by applicable law.

You can contact us with questions by emailing us at privacy@pelagohealth.com or writing us at:

United Kingdom
Digital Therapeutics, Ltd.
Peer House Ps.03, Third Floor
8-14 Verulam Street
Holborn, London WC1X 8LZ, GB

United States
Digital Therapeutics, Inc.
1632 1st Ave. #20163
New York, NY 10028

Category of personal information	How we may use it	EEA / UK legal basis for the processing	Third parties to whom the information may be disclosed
Identifiers and Information Subject to Protection under California Law such as your name, email address, mailing address, and phone number.
	We may use this information to deal with enquiries and complaints made by or about you relating to the Site.	The processing is necessary for our legitimate interests, namely administering the Site, and for communicating with you effectively to respond to your queries or complaints.	Third party analytics companies, our affiliates, and other third parties as required by applicable law.
Correspondence and comments. When you contact us directly about the Site, e.g. by email, phone, mail, respond to surveys or interact with our support services, we will record your comments and opinions.	To address and resolve your questions, issues and concerns.	This processing is necessary for our legitimate interests, namely, administering the Site and communicating with you in connection with the Site.	Our service providers, affiliates, and other third parties as required by applicable law.
Professional Information, including information relating to your role as a representative or agent of a company or business, such as your work title and contact information.	We use this information provided by clients, vendors, and other business partners in order to conduct business with them.	The processing is necessary for our legitimate interest, or performance of the employment contract with you.	Our service providers, affiliates, and other third parties as required by applicable law.
Your preferences, such as preferences set for notifications, marketing communications, how the Site is displayed and the active functionalities on the Site.	We use this information to provide notifications, send news, alerts and marketing communications and make the Site available in accordance with your choices.	The processing is necessary for our legitimate interest, namely ensuring users of the Site receive correct marketing and other communications, and that this is displayed in accordance with the user’s preferences. We will only send you marketing communications when we have your consent.	Our service providers, affiliates, and other third parties as required by applicable law.
	We use this information to ensure that we comply with our legal obligation to send only those marketing communications to which you have consented.	The processing is necessary for our legitimate interest, namely ensuring the user receives the correct marketing and other communications, and that this is displayed in accordance with the user’s preferences. We will only send you marketing communications when we have your consent.	Our service providers, affiliates, and other third parties as required by applicable law.
Internet and Other Electronic Activity Information, such as your browsing history, search history, information about your interactions with our website, use our mobile apps, or interact with our digital advertisements		Please see Annex 2	Please see Annex 2

In addition to the uses above, we may use the information we obtain from you:

• When you give us your consent;
• To comply with applicable law;
• To assert or defend our rights or those of others; or
• in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Category of personal information	How we may use it	EEA/UK legal basis for the processing	Third parties to whom the information may be disclosed
Information about how you access and use the Site. For example, how frequently you access the Site, the time you access the Site and how long you use it for, the approximate location that you access the Site from, whether you access the Site from multiple devices, and other actions you take on the Site.	We may use information about how you use and connect to the Site to present the Site to you on your device.	The processing is necessary for our legitimate interests and performance of a contract with you, namely to tailor the Site to the user’s preferences.	Our service providers, third party analytics companies, our affiliates and to other third parties as required by applicable law
	We may use this information to determine products and services that may be of interest to you for marketing purposes.	We will only process your data for marketing purposes when we have obtained your consent or when the processing is necessary for our legitimate interests.	Our service providers, our affiliates and to other third parties as required by applicable law
	We may use this information to monitor and improve the Site and our business, resolve issues and to inform the development of new products and services.	The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Site and to improve the Site generally.	Our service providers, third party analytics companies, our affiliates and to other third parties as required by applicable law
Log files and information about your device. We also collect information about the tablet, smartphone or other electronic device you use to access the Site. This information can include details about the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Site through the device, your mobile network, your IP address and your device identifier.	We may use information about how you use and access the Site to present the Site to you on your device.	The processing is necessary for our legitimate interests, namely, to tailor the Site to the user’s preferences.	Our service providers, third party analytics companies, our affiliates and to other third parties as required by applicable law
	We may use this information to determine products and services that may be of interest to you for marketing purposes.	The processing is necessary to provide a better experience to you by offering a personalized experience on the Site. We will only process your data for marketing purposes when we have obtained your consent or when the processing is necessary for our legitimate interests. The processing is necessary for us to make the Site available. We will only process your data for marketing purposes when we have obtained your consent.	Our service providers, our affiliates and to other third parties as required by applicable law.
	We may use this information to monitor and improve the Site and business, resolve issues and to inform the development of new products and services.	The processing is necessary for our legitimate interests in order to make the Site available, namely, to monitor and resolve issues with the Site and to improve the Site generally.	Our service providers, third party analytics companies, our affiliates and to other third parties as required by applicable law.
Non-specific geolocation, which we obtain from your devices that access the Site.	We may use this information to facilitate the timing of communications and display of currencies. Also to identify technical issues.	The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Site and to improve the Site generally.	Our service providers, third party analytics companies, our affiliates and to other third parties as required by applicable law.
Identifiers such as your IP address and device identifier	We may use this information to assess and diagnose technical issues, for performance monitoring.	The processing is necessary for our legitimate interests, namely to monitor and resolve issues with the Site and to improve the Site generally.	Our service providers, third party analytics companies, our affiliates and to other third parties as required by applicable law.

In addition to the uses above, we may use the information we obtain from you:

• When you give us your consent;
• To comply with applicable law;
• To defend our rights or those of others; or
• in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

This cookie notice (the “Cookie Notice”) describes how Pelago uses cookies and other similar technologies on our Site. It explains what these technologies are and why we use them, as well as your rights to control our use of them.

WHAT ARE COOKIES?

A cookie is a small text file that our Site stores on your computer or mobile device when you visit our Site.
Depending on their function and intended purpose, cookies are often classified in the following categories:

• “First party cookies” are cookies set by the website you are visiting. In addition, a website might potentially use external services, which also set their own cookies, known as “third-party cookies.”
• “Persistent cookies” are cookies saved on your computer and that are not deleted automatically when you quit your browser, unlike a “session cookie,” which is deleted when you quit your browser.
• “Essential cookies” are required so that you can navigate on a website and use its features. Without these cookies, functionalities cannot be ensured by the website.
• “Performance cookies” are cookies that collect information on how a website is used. These cookies do not retain any information that allows to identify the website user. The collected information will be aggregated and thus will be analyzed in a non-attributable way to a specific person. These cookies are used exclusively to improve the performance of a website and the user’s experience.
• “Functional cookies” are cookies that enable a website to save details that have already been provided and to offer the website user personalized functions. These cookies collect anonymized information and cannot track your traffic on other websites.
• “Cookies for marketing purposes” are cookies used to extract advertisements that are relevant to specific users and adapted to their interests. These cookies register whether you have visited a website or not, and this information can be shared with third parties.

Every time you visit the Site, you will be prompted to accept non-essential cookies. The purpose is to enable our Site to remember your preferences for a certain period of time.
Cookies can also be used to establish anonymized statistics about the browsing experience on our Site.

Which types of cookies do we use?

Type of cookie	Who Serves these cookies	Persistent / session	Purposes / Additional information	Change cookie settings
Essential	Amazon AWS	Persistent	These cookies are strictly necessary to provide you with services available through our Site and to use some of its features, such as access to secure areas.	Because these cookies are strictly necessary to deliver the Site to you, you cannot refuse them.
Analytical / performance	Google Analytics	Persistent	We use Google Analytics to gain insights into how users use our Service, and to improve the functionality of the Service.	To refuse these cookies, please follow the instructions below under the heading “How can you control cookies?” You can learn more about Google’s practices at http://www.google.com/policies/privacy/partners and view its currently available opt-out options at https://tools.google.com/dlpage/gaoptout.
Analytical / performance	Amplitude	Persistent	We use Amplitude to track user language, location, device and browser used, and user sign in and actions.	To refuse these cookies, please follow the instructions below under the heading “How can you control cookies?” You can learn more about Amplitude practices at https://www.amplitude.com/privacy

OTHER TRACKING TECHNOLOGIES

Cookies are not the only way to recognize or track visitors to a website. We may use other, similar technologies from time to time, like web beacons (sometimes called “tracking pixels” or “clear gifs”). These are tiny graphics files that contain a unique identifier that enable us to recognize when someone has visited our Site. In many instances, these technologies are reliant on cookies to function properly, and so declining cookies will often impair their functioning.

HOW CAN YOU CONTROL COOKIES?

The cookies we use are designed to help you get the most from the Site, but if you do not wish to receive cookies, most browsers and devices allow you to change your cookie settings. Depending on your mobile device and operating system, you may not be able to delete or block all cookies. Please note that if you choose to refuse all cookies you may not be able to use the full functionality of our Site. These settings will typically be found in the “options” or “preferences” menu of your browser.

In addition, most advertising networks offer you a way to opt out of targeted advertising. If you would like to find out more information, please visit http://www.aboutads.info/choices/” or http://www.youronlinechoices.com.

For mobile users, you have controls in your device Operating System that enable you to choose whether to allow cookies or share your advertising ID with companies like Pelago or our advertising service providers. To block the IDFA on your iOS mobile device, you should follow this path: Settings > General > About > Advertising and then turn on ‘Limit Ad Tracking’. To block Android ID on your Android device, you should follow this path: Google Settings > Ads and then turn on ‘Opt out of interest-based ads’. Please note that deleting or blocking cookies may not be effective for all types of tracking technologies, such as Local Storage Objects (LSOs) like HTML5.

HOW CAN THIS COOKIE NOTICE BE MODIFIED?

This Cookie Notice may be amended from time to time by Pelago, at its sole discretion. Any and all changes to this Cookie Notice will be reflected here and the date of the latest version of the Cookie Notice will be stated at the top of this Site. Any material changes to this Cookie Notice will be communicated on this Site.

HOW CAN YOU CONTACT US?

If you have any questions regarding our Cookie Notice, please contact us at privacy@pelagohealth.com.

In addition to the disclosures in our privacy policy, which identify how we collect personal information, how we use that information, the purposes of our use, to whom we may disclose that information, how long we retain information, and how we secure the information we collect, this section includes additional disclosures applicable to residents of California.

Shine The Light

California Civil Code Section 1798.83, also known as the “Shine The Light” law, allows California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below. However, please be aware that we are not sharing your information for any third party’s marketing purposes.

Selling and Sharing of Personal Information

Pelago has not sold consumers’ personal information in the preceding 12 months for any monetary value. However, our use of certain website cookies may be considered a “sale” of information under California law. In the past twelve months, we may have disclosed your internet activity or geolocation with third parties whose cookies are on our websites. These cookies are used to analyze usage of our website, provide you with relevant Pelago advertising and products, and provide additional, dynamic functionality to our websites. You can opt-out of the use of these cookies by using the “Do Not Sell My Personal Information” link in the footer of the web page. We also recognize opt-out preference signals contained in HTTP header fields.

Pelago does not “share” personal information as that term is used in the California Consumer Privacy Act.

We do not use or disclose your sensitive personal information for any purpose other than as permitted by applicable law. We do not sell or share your sensitive personal information as those terms are used in the California Consumer Privacy Act.

Financial Incentives

From time to time, we may offer financial incentives to consumers in exchange for the consumer sharing certain personal information with us. The specific instructions for how to participate and the rewards offered as incentives may vary and are set out within each program. Our good faith estimate of the value of your information is the value of the benefit we offer to you. We have calculated that value by using the expense to us of operating the program related to the benefit obtained by our running of the program. To participate in any incentive-based programs you can opt-in by signing up for the incentive when it is offered to you. Participation in our promotional programs is always optional, and you can terminate program participation at any time as explained in the applicable program terms. You can also contact us at privacy@pelagohealth.com to unsubscribe or cancel your participation in any program.

Privacy Rights

If you are a California resident, you are entitled to certain privacy rights relating to your personal information, subject to certain legal limitations. This section describes those rights and how you can exercise those rights.

Right to Access Personal Information

You have the right to access and know what personal information Pelago collects about you, and how it uses, discloses, sells such personal information. You also have the right to request, to the extent technically feasible, a portable set of your personal information.

Right to Request Deletion of your Personal Information

You have the right to request that Pelago delete the personal information it has about you. If we do not delete your personal information for reasons permitted under applicable law, we will let you know.

Right to Correct Inaccurate Personal Information

You have the right to request that Pelago correct inaccurate personal information that we maintain about you.

Right to Opt Out of Sale of your Personal Information

You have the right to opt out of the sale or sharing of your Personal Data as described above.

Exercising Your Privacy Rights

If you are a California Consumer, to exercise your rights, please submit a request using one of the following methods:

Calling us at 1 877-349-7755
Emailing us at privacy@pelagohealth.com

Pelago cannot respond to your request or provide you with personal information if we cannot verify your identity or your authority to make the request. When you submit a request, we will take steps to verify your identity by comparing it to data in our possession or other methods such as, if you have an account with us, sending an email to the email address we have on file for you asking you to confirm your identity and that you have authorized a request. You are not required to create an account with us to submit a request. If you don’t have an account with us, or if you do but we need further information to verify your identity, we may ask you to provide us with information about yourself in order to verify your identity.

We will only use personal information you provide in connection with identity verification to verify the requestor’s identity or authority to make the request and whenever feasible, we will attempt to match the information you provide with information we may already have about you.

If you wish to authorize a third party to make a request on your behalf through an authorized agent, you must contact us directly as provided above and you or your agent must provide a valid California power of attorney or comparable documentation of written permission from you and verification of your identity with Pelago. You may also make a privacy request on behalf of your minor child by contacting us as provided above.

Non-Discrimination

We will not discriminate or retaliate against you for exercising any of your privacy rights identified in this privacy policy.