Last Updated: December 1, 2022
Thirty Madison also manages medical groups that provide treatment to Thirty Madison customers and pharmacies that fill prescriptions for Thirty Madison customers. When Thirty Madison handles protected health information (“PHI”) on behalf of the medical groups and the pharmacies, Thirty Madison follows the medical group Notice of Privacy Practices and not this Policy. The medical group Notice of Privacy Practices, can be found at: http://keeps.com/legal/kmg-privacy.
2. COLLECTION OF PERSONAL INFORMATION
Information You Provide to Us. We collect information you provide to us when you create or modify your account, register to use our websites (including, https://www.withcove.com/, https://www.keeps.com/, http://www.facetcare.com, https://river.thirtymadison.com/, or https://picnic.thirtymadison.com/) (collectively, with our mobile application(s), the “Site”), purchase products or services from us, post comments or reviews on our Site, request information from us, contact customer support, or otherwise communicate with us.
Information We Obtain Indirectly. We may receive certain information about you through companies that provide us with such information as part of their relationship with us, including Meta, Google Analytics, Google Ads, Hotjar, Hubspot, Microsoft Bing Ads, Mixpanel, Stripe, and other third party tools. We may also receive information about you from your social media accounts if you use those accounts to sign-in to your account with us.
Aggregate Information. We may combine information we receive from other sources with information you give to us and information we collect about you. Depending on the types of information received, we will use the information received from other sources or the combined information for the purposes described in this Policy.
3. CATEGORIES OF PERSONAL INFORMATION AND PURPOSE FOR COLLECTION
Thirty Madison only collects and processes the minimum amount of personal information from you necessary for our information processing activities, which includes the following categories of personal information: (1) contact information, including your name, address, email address, mailing address, postal address, and telephone number; (2) authentication information, including the user name and hashed password that you use to register an account on the Site; (3) financial information, which may include your debit or credit card number, its expiration date, and its security code for payment processing purposes; (4) personal characteristics, including date of birth, photographs of your ID and insurance card, general medical history, and other information relevant to diagnosis and treatment; (5) comments, reviews, and suggestions; (6) personal preferences, including product preferences, online preferences, and interests; (7) online behavior information including details of your visits to our Site, online activity, time spent viewing features, traffic data, location data, logs, language, date and time of access, frequency, and other communication data and the resources that you access and use on the Site; (8) and operating system, host domain, browser type, IP address, mobile network information, or device information. Our information processing activities include: conducting our business; customer communications and support; user verification; payment processing; shipping; quality management services; Site maintenance and improvements; designing, developing, and communicating with you about our features, products, and services; any purpose where you have given your consent (where legally required); enforcing our legal rights or subject to any consents or authorizations that are required by applicable law, including those of our subsidiaries, affiliates, etc. and any of their related businesses and those of our third-party partners; and complying with legal requirements. Where applicable, if Thirty Madison intends to further process your personal information for any other purpose, we will provide you with any relevant information on such additional purpose and obtain your consent, to the extent required by applicable law.
4. DISCLOSURE OF PERSONAL INFORMATION
Thirty Madison does not trade, rent, or sell your personal information to third parties. We may share or disclose de-identified information for any purpose without restriction and may share or disclose your personal information for the following limited purposes.
Healthcare Providers. We share your personal information with health care providers, including without limitation, clinicians, health care facilities and organizations, pharmacies, and laboratories. Health care providers will follow a separate Notice of Privacy Practices in how they use and disclose your personal information.
Vendors and Services Providers. We may provide information to third party vendors and service providers that perform services and functions on our behalf, such as to help us operate and manage our Service and the Site, process orders, and fulfill and deliver products and services that you purchase from us. These vendors and service providers may have access to your personal information in order to provide these services to us, but when this occurs, we implement contractual protections to limit their use of that information to help us provide our Service and support our interactions with you.
Your Consent to Have Your Personal Information Shared. We may also share personal information with companies, organizations, or individuals outside of Thirty Madison when we have your consent to do so.
5. ACCESS TO YOUR INFORMATION AND CHOICES
Contact Us. You can access and update certain information we have relating to your online account by signing into your account and going to the Account section of our Site. If you have questions about personal information we have about you or need to update your information, you can contact us at,
Social Media Account Sign On. To the extent that you choose to use a social media account application (such as Google, Facebook, or Apple) to create your online account on the Site or otherwise sign into the Site, you understand that if another person has access to your social media account, they will also have access to your account on the Site. That means that other person could access any personal information contained on the Site. It is your decision about whether to give another person access to your social media account and whether to use that account to sign on to the Site. Also, if you use a social media account application to sign into the Site, you understand that the social media account application may send information from your social media account to Thirty Madison.
6. SECURITY OF YOUR INFORMATION
We have taken steps and implemented administrative, technical, and physical safeguards designed to protect against the risk of accidental, intentional, unlawful, or unauthorized access, alteration, destruction, disclosure, or use. The Internet is not 100% secure and we cannot guarantee the security of information transmitted through the Internet. Thirty Madison cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your personal information. Where you have been given or you have chosen a password, it is your responsibility to keep this password confidential.
The sharing and disclosing of information via the internet is not completely secure. We strive to use best practices and industry standard security measures and tools to protect your data. However, we cannot guarantee the security of Personal Information transmitted to, on, or through our Services. Any transmission of Personal Information is at your own risk. We are not responsible for the circumvention of any privacy settings or security measures contained on our Site, in your operating system, or mobile device. Accordingly, it is your responsibility to protect the security of your login information, including your username and password.
7. COOKIES AND OTHER TECHNOLOGIES
We also collect information automatically as you navigate through our Site. We use the following technologies to automatically collect data:
9. CHILDREN’S PRIVACY
If you are under the age of 18, please do not attempt to register with us at this Site, engage our Service, or provide any personal information about yourself to us. If we learn that we have collected personal information from someone under 18, we will promptly delete that information. If you believe we have collected personal information from someone under the age of 18, please contact us at:
10. SPECIAL NOTE TO CALIFORNIA RESIDENTS
In compliance with California law, we provide California residents with certain information and access upon request (“Consumer Request”). If you are a resident of California, the California Consumer Privacy Act (“CCPA”) provides you with additional rights regarding your Personal Information. This section describes the Personal Information we collect about you, how we use and disclose it, and how you can exercise your privacy rights under the CCPA.
Your privacy rights under the CCPA do not apply to all information that we might collect, use, or disclose. For example, the CCPA does not apply to PHI governed by the Health Insurance Portability and Accountability Act (“HIPAA”), “medical information” governed by the California Confidentiality of Medical Information Act (“CMIA”), or other patient information we maintain in the same manner as PHI or “medical information.” The CCPA also excludes other categories of information. When we collect, use, or disclose information not covered by the CCPA, we do so as described in this Policy (excluding this Section) and applicable Notice of Privacy Practices. If you would like to learn more about how we collect, process, or disclose your information that is not covered by the CCPA, or to exercise the rights that may be available to you under HIPAA and other laws, please review this Policy (excluding this Section) and applicable Notice of Privacy Practices.
For your Personal Information covered by the CCPA, your rights are outlined below, including how California residents can request the information and what you can receive. If you would like to submit a Consumer Request related to the CCPA, you or your authorized agent can contact us at:
If you choose to submit a Consumer Request, you must provide us with enough information in your request to identify you. Thirty Madison will only use the information you provide to respond to your request. Thirty Madison will not be able to disclose information if it cannot verify that the person making the Consumer Request is the person about whom we collected information, or someone authorized to act on such person’s behalf. “Personal Information” means information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. “Personal Information” does not include publicly available information.
Request to Access. You may submit a Consumer Request to obtain a copy of or access to the Personal Information that Thirty Madison has collected on you. You also may designate an authorized agent to make a request for you. To use authorized agent, you or your authorized agent must: submit proof that the authorized agent is registered with the California Secretary of State and that you have authorized be able to act on your behalf, submit evidence that you have provided the authorized agent with power of attorney pursuant to the California Probate Code; or provide the authorized agent written and signed permission to act on your behalf, verify your identity with us, and directly confirm with us that you have provided the authorized agent permission to submit the request. We may deny a request from an authorized agent who does not submit sufficient proof to act on your behalf.
Request to Correct Inaccurate Personal Information. You may submit a Consumer Request to correct inaccurate personal information. Thirty Madison will use commercially reasonable efforts to comply with such requests and correct inaccurate Personal Information.
Request to Know. You may submit a Consumer Request to receive information about Thirty Madison’s Personal Information collection practices. You may request information on: the categories of Personal information Thirty Madison has collected about you; the categories of data collection sources; Thirty Madison’s business or commercial purpose for collecting, using, or selling that Personal Information; the categories of Personal Information that Thirty Madison has sold or shared; the categories of third parties with whom Thirty Madison shares Personal Information, if any; and the specific pieces of Personal information we collected about you. Thirty Madison is not required to retain any information about you if it is only used for a one-time transaction and would not be maintained in the ordinary course of business. Thirty Madison is also not required to reidentify Personal Information if it is not stored in that manner already, nor is it required to provide Personal Information to you more than twice in a twelve-month period. If you would like to know if the Thirty Madison has disclosed information about you to specific third parties, you may receive information about the categories of Personal Information that we disclosed to third parties for their direct marketing purposes by contacting us at:
You may receive the names and addresses of those third parties, and you may request this information for the year prior to your request. Note that these particular requests may only be made once per calendar year. Additionally, please be aware that only sharing activities covered by California law will be included in our response to your request.
Request to Delete. You may request that Thirty Madison delete your Personal Information. Subject to certain exceptions set out below, upon receipt of a verifiable Consumer Request we will delete your Personal Information from our records and direct any service providers to do the same. We will also notify all third parties with whom Thirty Madison has shared your Personal Information of your request to delete your Personal Information. Please note that we may not delete your Personal Information if it is necessary to: complete the transaction for which the personal information was collected; provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us; detect security incidents, protect against malicious, deceptive activity, and take all necessary and appropriate steps to mitigate current and future risk; debug and repair internal information technology as necessary; undertake internal research for technological development and demonstration; exercise free speech, ensure the right of another consumer to exercise his/her/their right of free speech, or exercise another right provided for by law; comply with the California Electronic Communications Privacy Act; engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent; enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us; comply with an existing legal obligation; or otherwise use your Personal Information, internally, in a lawful manner that is compatible with the context in which you provided the information.
Thirty Madison may not, and will not: treat you differently because of your Consumer Request or Opt-Out activity; deny goods or services to you; charge different rates for goods or services; provide a different level of quality of goods or services; or suggest any of the preceding will occur. However, we can and may charge you a different rate, or provide a different level of quality, if the difference is reasonably related to the value provided by your Personal Information. Further, some Service functionality and features may change or become unavailable upon deletion or restriction on use of your Personal Information.
11. SPECIAL NOTICE FOR NEVADA RESIDENTS
Thirty Madison does not sell, rent, or lease your Personal Information to third parties. However, if you are a resident of Nevada and would like to submit a request not to sell your personally identifiable information, you may do so by contacting us at:
12. LINKED SITES
The Site may contain links to third party owned or operated websites, including, without limitation, social media websites (each a “Linked Site”), as a convenient method of accessing information that may be useful or of interest to you. This Policy and the practices that we follow under this Policy do not apply to Linked Sites. We are not responsible for the content, accuracy, or opinions expressed on any Linked Site or for the privacy practices or security standards used by third parties on such Linked Sites. These Linked Sites have separate privacy and data collection practices, and we have no responsibility or liability relating to them. Accordingly, if you use Linked Sites through our Site, to login to our Site, or to share information about your experience on our Site with others, these Linked Sites may be able to collect information about you, including information about your activity on our Site. In accordance with their own privacy policies, the Linked Sites may further notify your social media connections about your use of our Site. You understand and agree that by clicking on a link to a Linked Site or using a Linked Site as described above, this Policy, as stated on the Site, is no longer in effect because you have either left our Site or used a Linked Site to interact with our Site.
13. USER CONTENT
Some features of our Service may now or in the future allow you to provide content, such as written comments or reviews, to be published or displayed on public areas of the Site (“User Content”). Be careful about giving out information in public areas of the Site. The information you share in public areas may be read, collected, or used by any user of the Site. We cannot control the actions of other users of the Site with whom you may choose to share your User Content.
14. CONSENT TO PROCESSING OF PERSONAL DATA IN UNITED STATES
This Site is intended for use only by residents of the United States (“U.S.”) . If you are a citizen of the European Economic Area (“E.E.A.”) or other jurisdiction outside of the U.S., please note that in order to provide our Site and Service to you, we may send and store your personal information (also commonly referred to as personal data) outside of the E.E.A., including the U.S. Accordingly, your personal information may be transferred outside of the country where you reside or are located, including to countries that may not or do not provide the same level of protection for your personal information. By using and accessing our Site, users who reside or are located in countries outside of the U.S. agree and consent to the transfer to and processing of personal information on servers located outside of the country where they reside, including to the U.S., and that the protection of such information may be different than required under the laws of their residence or location.
16. QUESTIONS AND HOW TO CONTACT US
If you have any questions, concerns, complaints, or suggestions regarding this Policy, please contact us:
Or write us by U.S. postal mail at the following address:
Thirty Madison, Inc.
82 Nassau St #61392
New York, NY 10038