Privacy Policy
Flagler Health
Privacy Policy
Last Updated: 5/14/2026
1. Introduction
Flagler Health, Inc. (“Flagler” or “we”) is a Delaware corporation headquartered in New York City. We provide AI-enabled clinical operations and care management services to healthcare organizations. This Privacy Policy describes how we collect, use, disclose, and protect personal information when you visit our website at www.flaglerhealth.io (the “Site”), submit information through our contact or demo request forms, apply for employment, or otherwise interact with us online.
This Privacy Policy does not apply to our processing of protected health information when we provide services to our healthcare clients under separate agreements. Information processed in the course of those services is governed by our client agreements, Business Associate Agreements, and applicable HIPAA regulations.
2. Information We Collect
The following describes the personal information collected by Flagler, including in the 12 months preceding the “last updated” date of this Privacy Policy.
2.1 Information You Provide Directly
We collect personal information you voluntarily provide when you:
- Request a demo or contact us: name, email address, phone number, company name, job title, and any message content you include.
- Apply for a job and work for us: name, email address, phone number, resume or CV, employment history, education, and any other information you choose to include in your application materials.
- Interact with us in a commercial capacity: name, contact information.
2.2 Information Collected Automatically
When you visit our Site, we may automatically collect certain information, including:
- IP address and approximate geographic location
- Browser type, operating system, and device information
- Pages viewed, referring URL, and site interaction data
- Date and time of your visit
We may use cookies, pixels, and similar tracking technologies to collect this information. See Section 7 (Cookies and Tracking Technologies) below for details.
2.3 Information from Third Parties
We may receive information about you from publicly available sources (such as LinkedIn) or from business partners to supplement our records for sales and marketing purposes.
3. How We Use Your Information
We use the personal information we collect for the following purposes:
- To respond to your inquiries and demo requests
- To evaluate your job application and communicate with you about employment opportunities
- To operate, maintain, and improve our Site
- To send communications (including marketing communications) about our services
- To analyze Site usage and trends to improve user experience
- To detect, prevent, and address security incidents and fraudulent activity
- To comply with legal obligations, enforce our Terms of Use, and protect our rights
We do not use personal information collected through this Site to make automated decisions that produce legal or similarly significant effects on individuals.
4. How We Disclose Your Information
We do not sell your personal information. We may disclose your information to the following categories of recipients:
- Service providers and contractors: Third parties that perform services on our behalf, such as website hosting, analytics, email delivery, applicant tracking, and customer relationship management. These providers are contractually bound to use your information only for the services we engage them to perform.
- Professional advisors: Attorneys, accountants, auditors, and other professional advisors as needed.
- Legal compliance and protection: When required by law, regulation, legal process, or governmental request, or when we believe disclosure is necessary to protect our rights, safety, or property, or that of our users or the public.
- Business transfers: In connection with a merger, acquisition, reorganization, or sale of assets, your information may be transferred as part of that transaction. We will notify you of any such change via prominent notice on our Site.We may also share your information with investors as part of the fundraising process.
We do not share personal information with third parties for cross-context behavioral advertising. If we change this practice in the future, we will update this Privacy Policy and provide appropriate opt-out mechanisms, including honoring Global Privacy Control (GPC) signals.
5. Data Retention
We retain personal information only as long as reasonably necessary for the purposes described in this Privacy Policy:
- Contact and demo request data: Up to 24 months following your most recent interaction with us, unless an ongoing business relationship is established.
- Job applicant data: Up to 24 months after the conclusion of the application process, unless you consent to a longer retention period for consideration for future positions.
- Commercial contacts data: Up to 24 months after the conclusion of the commercial relationship.
- Automatically collected data: Up to 13 months for analytics purposes.
After the applicable retention period, we will delete or de-identify your personal information. We may retain information for longer periods if required by law or to resolve disputes.
6. Your Privacy Rights
Depending on your state of residence, you may have the following rights regarding your personal information:
- Right to know / access: You may request confirmation of whether we process your personal information and obtain a copy of the specific information we hold about you.
- Right to delete: You may request that we delete your personal information, subject to certain exceptions.
- Right to correct: You may request that we correct inaccurate personal information.
- Right to data portability: You may request your information in a portable, readily usable format.
- Right to opt out of sale or sharing: We do not currently sell or share personal information for cross-context behavioral advertising. If this changes, you will have the right to opt out.
- Right to opt out of targeted advertising: You may opt out of the use of your personal information for targeted advertising purposes.
- Right to opt out of profiling: You may opt out of profiling that produces legal or similarly significant effects.
- Right to non-discrimination: We will not discriminate against you for exercising your privacy rights.
- Right to appeal: If we deny your privacy request, you may appeal our decision. We will respond to appeals within the timeframe required by applicable law.
Certain state laws provide specific timeframes for responding to appeals. We will respond to appeals within 45 days (or 60 days for California residents). If we need additional time, we will notify you of the extension and the reason for the delay. If we deny your appeal, we will provide you with information on how to contact your state attorney general or other applicable regulatory authority to submit a complaint.
6.1 How to Exercise Your Rights
To exercise any of the rights described above, please contact us at legal@flaglerhealth.io or by mail at the address listed below. We may need to verify your identity before processing your request by matching information you provide with information we have on file. You may also designate an authorized agent to submit a request on your behalf; we may require the authorized agent to provide proof of written permission and may still require you to verify your identity directly with us.
We will acknowledge receipt of your request and respond within 45 days (or such other period as required by applicable state law). If we need additional time to respond (up to an additional 45 days, or such other extension period as permitted by applicable law), we will notify you of the extension and the reason for the delay.
6.2 Universal Opt-Out Mechanisms
We honor Global Privacy Control (GPC) and similar browser-based universal opt-out signals as valid opt-out requests where required by applicable state law. When we detect a GPC signal, we will treat it as a request to opt out of any sale or sharing of personal information associated with that browser.
7. Cookies and Tracking Technologies
Our Site may use the following categories of cookies and similar technologies:
- Strictly necessary cookies: Required for the Site to function properly (e.g., security, load balancing). These cannot be disabled.
- Analytics cookies: Help us understand how visitors interact with our Site by collecting information about pages viewed, time spent, and navigation patterns. This data is aggregated and anonymized where possible.
- Functional cookies: Enable enhanced functionality and personalization, such as remembering your form preferences.
We do not currently use advertising or retargeting cookies. If we adopt such technologies in the future, we will update this policy and implement appropriate consent and opt-out mechanisms.
You can control cookies through your browser settings. Disabling certain cookies may affect your experience on our Site.
8. Data Security
We implement and maintain reasonable administrative, technical, and physical safeguards designed to protect your personal information from unauthorized access, disclosure, alteration, and destruction. These measures are consistent with industry standards and our SOC 2 Type 2 certification.
However, no method of electronic transmission or storage is completely secure. While we strive to protect your personal information, we cannot guarantee absolute security.
9. Health Information Disclaimer
This Site is not part of our HIPAA-regulated service environment. Flagler is a HIPAA-compliant Business Associate for the clinical services we provide to our healthcare clients. However, personal information collected through this Site (such as contact form submissions and job applications) is not Protected Health Information (PHI) and is not governed by HIPAA.
Do not submit patient data or protected health information through this Site. If you are an existing client, please use the secure communication channels provided under your service agreement. If we inadvertently receive PHI through this Site, we will securely delete it and notify you promptly.
This Site does not provide medical advice, diagnosis, or treatment. Nothing on this Site should be construed as establishing a provider-patient or clinical care relationship.
10. Children’s Privacy
Our Site is not directed to children under the age of 13, and we do not knowingly collect personal information from children under 13. If we learn that we have collected personal information from a child under 13, we will promptly delete it. If you believe we may have collected information from a child under 13, please contact us at the address below.
11. Additional State Disclosures
If you are a California resident, you may have certain rights under the California Consumer Privacy Act (“CCPA”). The following disclosures supplement the information provided elsewhere in this Privacy Policy. In the preceding 12 months:
- Categories of personal information collected: Identifiers (name, email, phone, IP address); professional or employment-related information (company name, job title, resume data); internet or electronic network activity (browsing data, Site interaction data).
- Sources: Directly from you; automatically through your use of our Site; from publicly available sources.
- Business purposes for collection: Responding to inquiries; evaluating job applications; Site operations and improvement; marketing communications; security and fraud prevention; legal compliance.
- Categories of third parties receiving information: Service providers (hosting, analytics, CRM, applicant tracking); professional advisors; government entities when required by law.
- Sale or sharing: We have not sold or shared personal information in the preceding 12 months.
- Sensitive personal information: We do not collect sensitive personal information as defined by the CCPA through this Site.
California residents also have the right to limit the use and disclosure of sensitive personal information to purposes necessary for providing the goods or services reasonably expected.
We do not offer financial incentives or price or service differences in exchange for the retention or sale of personal information.
We do not process personal data for purposes of targeted advertising, as defined under applicable state privacy laws. If we change this practice in the future, we will update this Privacy Policy and provide appropriate notice and opt-out mechanisms.
We do not engage in profiling in furtherance of decisions that produce legal or similarly significant effects concerning consumers, as defined under applicable state privacy laws.
We do not knowingly collect or process sensitive personal data (including data revealing racial or ethnic origin, religious beliefs, mental or physical health diagnosis, sexual orientation, citizenship or immigration status, genetic or biometric data, personal data of known children, or precise geolocation data) through this Site.
We may use de-identified data that cannot reasonably be used to infer information about, or otherwise be linked to, an identified or identifiable individual. We maintain and use such data in de-identified form and do not attempt to re-identify the data, except as permitted by applicable law to determine whether our de-identification processes are adequate.
12. Contact Us
If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:
Flagler Health
Attn: Legal
429 Broome Street, 4th Floor
New York, NY 10013
Email: legal@flaglerhealth.io
13. Consumer Protection Agencies
If you exercise your right to appeal our determination with respect to your data subject rights, and we deny your appeal, you may have the right to submit a complaint to your regulator. Information for your relevant regulator is provided below:
- California Residents: You may contact the California Privacy Protection Agency here (https://cppa.ca.gov/webapplications/complaint) and the California Attorney General here (https://oag.ca.gov/contact/consumer-complaint-against-business-or-company).
- Colorado Residents: You may contact the Colorado Attorney General here (https://complaints.coag.gov/s/contact-us).
- Connecticut Residents: You may contact the Connecticut Attorney General here (https://portal.ct.gov/ag/contact-the-attorney-generals-office/contact-the-attorney-generals-office).
- Delaware Residents: You may contact the Department of Justice here (https://attorneygeneral.delaware.gov/fraud/cmu/complaint/).
- Iowa Residents: You may contact the Iowa Attorney General here (https://www.iowaattorneygeneral.gov/for-consumers/file-a-consumer-complaint).
- Indiana Residents: You may contact the Indiana Attorney General here (https://www.in.gov/attorneygeneral/consumer-protection-division/file-a-complaint/).
- Maryland Residents: You may contact the Consumer Protection Division here (https://www.marylandattorneygeneral.gov/pages/cpd/complaint.aspx).
- Minnesota Residents: You may contact the Minnesota Attorney General here (https://www.ag.state.mn.us/office/complaint.asp).
- Montana Residents: You may contact the Montana Attorney General here (https://dojmt.gov/agooffice/).
- Nebraska Residents: You may contact the Nebraska Attorney General here (https://www.nebraska.gov/apps-ago-complaints/).
- Kentucky Residents: You may contact the Kentucky Attorney General here (https://www.ag.ky.gov/Resources/Consumer-Resources/Consumers/Pages/Consumer-Complaints.aspx).
- Nevada Residents: You may contact the Nevada Attorney General here (https://ag.nv.gov/Complaints/CSU_Complaints___FAQ/).
- New Hampshire Residents: You may contact the New Hampshire Attorney General here (https://www.doj.nh.gov/citizens/consumer-protection-antitrust-bureau/consumer-complaints).
- New Jersey Residents: You may contact the Division of Consumer Affairs here (https://www.njconsumeraffairs.gov/Pages/Consumer-Complaints.aspx).
- Oregon Residents: You may contact the Oregon Attorney General here (https://www.doj.state.or.us/oregon-department-of-justice/contact-us/).
- Rhode Island Residents: You may contact the Rhode Island Attorney General here (https://riag.ri.gov/).
- Tennessee Residents: You may contact the Tennessee Attorney General here (https://www.tn.gov/attorneygeneral/working-for-tennessee/consumer/file-a-complaint.html).
- Texas Residents: You may contact the Texas Attorney General here (https://www.texasattorneygeneral.gov/contact-us).
- Utah Residents: You may contact the Utah Attorney General here (https://attorneygeneral.utah.gov/).
- Virginia Residents: You may contact the Virginia Attorney General here (https://www.oag.state.va.us/contact-us/contact-info).