Aquila Health PBC (“Aquila,” “we,” “us,” or “our”) respects the privacy of visitors to our public websites. This Website Privacy Policy explains how we collect, use, disclose, and otherwise process information when you visit a public Aquila website that links to this policy, including aquilahealth.com and related public webpages operated by Aquila.
This policy applies only to Aquila’s public websites. It does not apply to:
- The Aquila customer portal
- The TREUE™ platform, patient-facing services, or TREUE APIs
- Information Aquila processes for a customer under a contract, data processing agreement, or business associate agreement
- Employment records or internal workforce systems
- A third-party website or service linked from an Aquila website
- A separate service that displays or links to a different privacy notice
Separate privacy policies apply to the Aquila customer portal and the TREUE platform and APIs.
Information We Collect
Information You Provide
We may collect information you voluntarily submit through a website form, email, event registration, survey, newsletter request, or other communication. This may include:
- Name
- Business email address
- Telephone number
- Employer, job title, or professional role
- Areas of business interest
- Communications, questions, or requests you send us
- Event or meeting registration information
- Any other information you choose to provide
Please do not submit protected health information, medical records, patient data, Social Security numbers, financial account credentials, or other sensitive personal information through a general website form or unencrypted email.
The public website is not intended to collect or provide access to protected health information. If sensitive information is submitted through an unintended channel, Aquila may delete it, restrict access to it, redirect it to an approved channel, or take other reasonable action appropriate to the circumstances.
Information Collected Automatically
When you visit the website, Aquila and its service providers may automatically collect limited technical and usage information, such as:
- Internet Protocol address
- Browser and device type
- Operating system
- General geographic area inferred from an IP address
- Pages viewed and links selected
- Referring and exit pages
- Date, time, and approximate duration of a visit
- Cookie or similar technology identifiers
- Website performance and diagnostic information
- Security-related events or suspected malicious activity
This information is generally used to operate, secure, maintain, and understand use of the website.
Information From Other Sources
We may receive professional or business contact information from:
- Event organizers
- Business partners
- Publicly available sources
- Professional networking services
- Customer relationship management providers
- People who refer or introduce you to Aquila
We may combine this information with information you provide directly when reasonably necessary for a legitimate business purpose.
Cookies and Similar Technologies
The website may use cookies, pixels, local storage, and similar technologies to:
- Maintain essential website functions
- Remember preferences
- Prevent fraud or malicious activity
- Measure website performance
- Understand general website usage
- Evaluate the effectiveness of Aquila communications
Aquila does not use health information or information submitted through TREUE for website advertising.
Aquila does not sell website visitor information for monetary consideration. Aquila does not disclose website activity for cross-context behavioral advertising unless a separate notice and legally required choice mechanism are provided.
You may be able to manage nonessential technologies through the website’s cookie preference tool at [Cookie Preferences Link]. Browser settings may also allow you to block or delete cookies, although doing so may affect website functionality.
Where required by applicable law, Aquila will recognize legally valid browser-based opt-out preference signals.
How We Use Website Information
Aquila may use website information to:
- Operate, maintain, and secure the website
- Respond to inquiries and requests
- Schedule meetings or demonstrations
- Provide requested materials or communications
- Manage business relationships
- Conduct business-to-business marketing
- Understand and improve website functionality
- Diagnose technical problems
- Detect fraud, abuse, or cybersecurity threats
- Protect Aquila, its users, customers, and others
- Comply with law, legal process, or contractual obligations
- Establish, exercise, or defend legal claims
- Complete a corporate transaction
- Create aggregated or de-identified information
Where permitted by law, Aquila may use aggregated or de-identified information for analytics, research, benchmarking, service improvement, or other lawful business purposes. Aquila will not attempt to re-identify information that Aquila maintains as de-identified except as permitted by law to evaluate the effectiveness of the de-identification process.
How We Disclose Website Information
Aquila may disclose website information to the following categories of recipients:
Service Providers
We may use service providers for hosting, cybersecurity, website analytics, customer relationship management, email delivery, event registration, communications, professional services, and related business functions.
Service providers may process information only for the services they perform for Aquila, subject to applicable contractual restrictions.
Business Partners
We may disclose business contact information to a partner when necessary to jointly respond to an inquiry, coordinate an event, conduct an authorized business activity, or pursue a relationship you have requested or would reasonably expect.
Legal and Safety Purposes
We may disclose information when we reasonably believe disclosure is necessary to:
- Comply with applicable law, regulation, court order, subpoena, or legal process
- Respond to a lawful government request
- Investigate fraud, security incidents, or violations of applicable terms
- Protect the rights, property, or safety of Aquila or another person
- Establish, exercise, or defend legal claims
Corporate Transactions
Information may be disclosed as part of a merger, acquisition, financing, reorganization, bankruptcy, sale of assets, due diligence review, or similar corporate transaction. Any successor’s handling of personal information will remain subject to applicable law and the commitments applicable to the information at the time of transfer, unless an appropriate new notice or consent is provided.
At Your Direction
We may disclose information to another party when you request or authorize the disclosure.
Retention
Aquila retains website information only for as long as reasonably necessary for the purposes described in this policy, including to:
- Respond to your request
- Maintain business records
- Manage an existing or prospective relationship
- Protect the website and Aquila systems
- Comply with legal, accounting, contractual, or reporting requirements
- Resolve disputes
- Enforce agreements
Retention periods vary depending on the nature of the information, the purpose for which it was collected, and applicable legal or contractual requirements.
Information stored in backups or security records may remain for a limited period after deletion from active systems. Aquila may retain aggregated or de-identified information where the information can no longer reasonably be associated with an identifiable individual.
Security
Aquila maintains a risk-based information security and privacy program informed by recognized frameworks, including applicable elements of the NIST Privacy Framework and NIST Cybersecurity Framework.
Safeguards may include administrative, technical, and physical controls appropriate to the sensitivity and context of the information, such as access controls, encryption, logging, security monitoring, personnel controls, and vendor oversight.
No website, network, or storage system can be guaranteed to be completely secure. You are responsible for using reasonable care when transmitting information online.
Privacy Rights
Depending on your state of residence and whether applicable law covers Aquila’s processing, you may have the right to request that Aquila:
- Confirm whether it processes your personal information
- Provide access to certain personal information
- Correct inaccurate personal information
- Delete certain personal information
- Provide a portable copy of certain personal information
- Disclose categories of information collected or disclosed
- Opt you out of certain targeted advertising, sales, or qualifying profiling
- Review an appeal of a prior privacy request
These rights are subject to applicable definitions, thresholds, exemptions, verification requirements, and limitations. Aquila does not extend a statutory right to circumstances where the law does not require it.
To submit a request, contact [Privacy Email] or use [Privacy Request Form].
Aquila may need to verify your identity before acting on a request. We may deny or limit a request where permitted by law, including when:
- Aquila cannot reasonably verify the requester
- The information is exempt from the applicable law
- Aquila must retain the information
- Compliance would adversely affect another person’s rights
- The request is fraudulent, excessive, or abusive
- Aquila is processing the information solely on behalf of another organization
An authorized agent may submit a request where permitted by law, but Aquila may require proof of the agent’s authority and may independently verify the request with the individual.
Aquila will not unlawfully discriminate against you for exercising an applicable privacy right.
Email Communications
You may unsubscribe from promotional email communications using the unsubscribe link in the message. Aquila may continue to send nonpromotional communications, including responses to requests, legal notices, security notices, or messages relating to an existing business relationship.
Children
The website is intended for a professional and general adult audience and is not directed to children under 13. Aquila does not knowingly collect personal information online from a child under 13 through the public website.
If you believe a child has submitted personal information through the website, contact privacy@aquilahealth.com
Third-Party Websites
The website may contain links to third-party websites or services. Aquila does not control and is not responsible for the privacy, security, content, or practices of a third party. Review the third party’s policies before providing information.
United States Operations
The website is operated from the United States and is primarily directed to a United States audience.
Information may be processed and stored in the United States.
The website is not intended as an offer of goods or services specifically directed to residents of another country unless Aquila states otherwise.
Changes to This Policy
Aquila may update this policy to reflect changes in law, technology, or website practices.
Nonmaterial changes become effective when the updated policy is posted. If a change materially alters how previously collected personal information will be used or disclosed, Aquila will provide additional notice or obtain consent when required by applicable law.
The “Last Updated” date identifies the most recent revision.