Privacy Notice | Carrot

Privacy notice

Introduction

Carrot Fertility, Inc. (“Carrot Fertility”) and Carrot Medical, LLC (“Carrot Medical”) are committed to protecting your privacy. This Privacy Notice explains how your Personal Information is collected, used, stored, processed, transferred, and disclosed by Carrot Fertility and Carrot Medical (collectively, “Carrot,” “we,” “our,” or “us”).

This Privacy Notice applies to our website https://get-carrot.com (our "Website") and any other website, mobile application, or online service that links to this Privacy Notice (collectively, our "Service").

The Service may contain links to and from third party websites of our business partners, advertisers, and social media sites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We may also share a user ID with third-party websites allowing us and the third-party website provider to jointly track specified activities across both websites. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party sites.

Before accessing or using our Service, please ensure that you have read and understood our collection, storage, use, and disclosure of your Personal Information as described in this Privacy Notice.

HIPAA Applicability

This Privacy Policy does not apply to Carrot’s use and disclosure of Protected Health Information.

Carrot Medical uses and discloses Protected Health Information about Carrot Medical patients in accordance with its Notice of Privacy Practices. Carrot Medical uses and discloses Protected Health Information about Carrot Medical patients in accordance with its obligations as a HIPAA Covered Entity.

In addition, to the extent that you are subject to United States benefit and taxation laws, and that your employer has established a health reimbursement arrangement plan (“HRA”), Carrot uses and discloses Protected Health Information that it receives from or on behalf of the HRA as a Business Associate under a Business Associate Agreement with the HRA. Please review the HRA’s Notice of Privacy Practices for an explanation of how the HRA uses and discloses your Protected Health Information.

Important Terminology

Carrot is the “Data Controller” responsible for protecting your Personal Information, which means we determine and are responsible for how your Personal Information is handled. If your access to Carrot is sponsored by an employer, health plan, or other benefit sponsor (collectively, a "Plan Sponsor"), the Plan Sponsor will initially send us your name and eligibility information ("Eligibility File"). If you have queries regarding the information contained in the Eligibility File, please contact your Plan Sponsor.

"Personal information" encompasses all “Personal Data” as defined in Art. 4 (1) of the General Data Protection Regulation ("GDPR"), meaning any information that relates to an identified or identifiable individual; provided, that in such circumstance(s) that applicable data protection laws require otherwise, “Personal information” has the meaning ascribed to it in such law(s).

Geographic considerations

Supplemental information for certain states

If your state of residence has specific privacy requirements that go beyond the general scope of this Privacy Notice, it is listed below:

Please click here to see more detailed information.

If you are a resident of Washington, you can also click here.

If you are resident of Nevada, you can also click here.

Also, please note that we will update this list as necessary to address evolving operations and regulations.

If you are a resident of a state that is not listed above, please contact us at legal@get-carrot.com if you have any questions about this Privacy Notice.

Supplemental Information for certain countries

If your country of residence has specific privacy requirements that go beyond the general scope of this Privacy Notice, it is listed below:

Please click here to see more detailed information.

Also, please note that we will update this list as necessary to address evolving operations and regulations.

If you are a resident of a jurisdiction that is not listed above, please contact us at legal@get-carrot.com if you have any questions about this Privacy Notice.

International data transfers

In order to provide services, Carrot will store and process your Personal Information in the United States. To the extent that your local jurisdiction considers this an “international data transfer,” we will comply with that jurisdiction’s requirements for transferring Personal Information to other countries.

For Residents of the EEA, Switzerland, and the United Kingdom

When your employer sends us your name and eligibility information ("Employee Eligibility File"), we will store and process that information in the United States. To comply with applicable regulatory requirements (e.g., the GPDR) on “international data transfers,” we will sign appropriate contractual mechanisms with the “data exporter” (i.e., your employer). For instance, if you are an EEA resident, Carrot and your employer will sign Module 2 of the EU Standard Contractual Clauses (SCCs).

Use of Artificial Intelligence (AI) and Machine Learning (ML)

Overview and legal bases

We use Artificial Intelligence (AI) and Machine Learning (ML) technology in different ways across the Service. Our uses fall under two broad categories:

AI uses for which we rely on your consent. For certain AI uses, we will only process your Personal Information with your consent. You may withdraw consent at any time, and the withdrawal will not affect the lawfulness of processing carried out before withdrawal. For specific examples, please see the tables in the Sensitive Data section below.

AI uses for which we rely on performance of contract and/or our legitimate interests. For other AI uses (for instance, those that support the operation of the Service or our internal business purposes), we rely on performance of contract and/or our legitimate interests. For specific examples, please see the tables in the use section under fraud and payment.

Carrot Sprints

If you participate in Carrot Sprints, our fertility and metabolic health coaching program, AI technology — overseen by human moderators and configured to operate on de-identified inputs — supports personalized guidance based on the medical history, lifestyle data, and engagement patterns you provide. Direct identifiers (such as name, date of birth, address, or medical diagnoses) are not sent to the AI system used for personalization.

Human oversight and automated decision-making

We do not rely on AI alone to make decisions that have a legal or similarly significant effect on you without meaningful human review. For consumers in Colorado and Texas, we comply with applicable state laws governing the use of automated decision-making in consequential decisions, including the Colorado AI Act and the Texas Responsible AI Governance Act. If you are a Colorado resident and a decision about your services has been influenced by an automated system, you have the right to request human review of that decision and to correct inaccurate information used in that decision.

Collection, use, and disclosure of personal information

Collection

Personal information we collect from you and from third parties

How we collect Personal Information

We collect Personal Information about you when you voluntarily submit information to us when you use our Service. This can include information you provide to us when you register for an account, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications related to the Service, participate in a survey, or use some other feature of our Service.

We may also collect information about you from our third party partners, as further described here.

Your Choices and Preferences Regarding How we Collect your Information

For further information on your rights and choices regarding your information, see here.

We will indicate to you where the provision of certain Personal Information is mandatory and where it is optional. If you choose not to provide Personal Information marked as mandatory, we may not be able to provide you with requested products, services, or information.

Categories of Personal Information we Collect

The categories of Personal Information we collect may include, without limitation:

Linking and Combining Personal Information from Different Sources

We also link or combine your activities and information collected from you on our websites with information we collect automatically through tracking technologies. This allows us to provide you with a personalized experience regardless of how you interact with us.

A Note on Children’s Privacy

Carrot does not knowingly collect or solicit any information from anyone under the age of 18 on this Service. In the event that we learn that we have inadvertently collected Personal Information from a child under age 18, we will delete that information as quickly as possible. If you believe that we might have any information from a child under 18, please contact us using the contact details set out at the end of this Privacy Notice.

Personal information we collect through automated means

How we Collect this Information

When you use our Service, read our emails, or otherwise engage with us through a computer or mobile device, we and our third-party partners automatically collect information about how you access and use the Service and information about the device you use to access the Service.

We typically collect this information through a variety of tracking technologies, including cookies, location-identifying technologies, and similar technology (collectively, “tracking technologies”).

See here for more detail on the tracking technologies we use.

Third Party Data Collection of User Experience Information

When you use the Service, we may use third party tools to monitor user experience information. These tools automatically collect usage information, including mouse clicks and movements, page scrolling and any text keyed into website forms. We use this information for site analytics, optimization, and to improve website usability.

Health Data From Linked Sources

In connection with certain wellness and coaching programs, including our Carrot Sprints metabolic health initiative, you may choose to link third-party sources, such as a Withings scale or platforms like Apple HealthKit and Android Health Connect, to your Carrot experience. These third-party providers operate as independent data controllers, meaning they are responsible for collecting and processing your health data (e.g., weight, activity levels) in compliance with their own privacy policies and applicable regulations. Some of this data — for example, weight, body composition, or activity-derived measurements — may constitute biometric data under applicable laws, such as the Illinois Biometric Information Privacy Act and similar state laws. Because these third-party providers operate as independent data controllers, they are responsible for their own compliance with such laws. We support their compliance through appropriate contractual mechanisms.

Third-party benefit storefront and enrollment integrations

Some employers and benefit sponsors offer Carrot through third-party benefit storefronts and enrollment platforms — for example, Amazon Health, the UHC Store, and similar offerings. If you check your eligibility for, or enroll in, Carrot's Service through one of these integrations, we may receive limited personal information about you from the platform to confirm your eligibility and facilitate enrollment. We may also share back status updates so your dashboard or account on that platform reflects real-time information about your benefits.

Where required by law, we will obtain your explicit consent for collecting, processing, or disclosing sensitive data involved in any such integration. From time to time, we may add, change, or end integrations as our partnerships evolve.

Linking and Combining Personal Information from Different Sources

Information we collect automatically about you may be combined with other Personal Information we collect directly. For example, we may combine your location based on your IP address that we have collected automatically with your email address that you have provided.

Use

Overview of how and why we use personal information

This section sets out the categories of Personal Information we collect about you, and explains how and why we use that information. It also lists the legal bases on which we rely to process personal Information. You hereby expressly acknowledge and agree that the collection and processing described in this Privacy Notice are necessary for our performance of our obligations under the Terms & Conditions .

For further information on your rights and choices regarding your information, see here.

Contact and profile information

This category includes Personal Information we collect--such as your name, phone number, address, date of birth, and e-mail address, and your partner’s name, phone number, address, date of birth, and e-mail address--when you register for our Service, request a Carrot Card or any other product offered through the Service, or otherwise communicate or interact with us.

Sensitive data

This category includes sensitive information, such as your and your partner's gender identities, interest in various fertility health and family-forming options, any relevant diagnoses you may have received, Social Determinants of Health, biometric data, and any related health information.

Comments, chats, and opinions

When you contact us directly, e.g., by email, phone, mail, or by completing an online form or participating in online chat, we will record your comments and opinions. We will also record comments and opinions you express when responding to surveys we run.

Expense, payment, and transaction information

This category includes Information such as your Employee ID, your receipts for fertility care and other services, whether you or your partner received the care, the date of your or your partner’s treatments, and your payment information, such as your credit card or bank account details.

Location information

This category includes Information about your location. We may approximate your location based on your IP address.

Information provided by social networks

When you interact with our Service through various social media networks, we may receive information from those social networks including your profile information, picture, user ID associated with your social media account, friends list, and any other information you permit the social network to share with third parties.

Information about your communication preferences

You may select your preferences for notifications, marketing communications, and site display.

Information provided by third parties

We may receive information from third parties. This information may include sensitive information, such as health care claims history and health information.

Information about fraudulent or criminal activity related to your account

We will use information about fraudulent or criminal activity relating to your use of our Service for the purposes of detecting and preventing fraud or abuse.

Disclosure

How and why we may disclose your information

Your choices and control over your information

Your profile

You may update your profile information, such as your name, address, or bank account information.

California "Do Not Track (DNT)" disclosure requirements

Carrot Fertility does not currently honor the Do Not Track (DNT) browser signal.

How to control your communications preferences

To the extent provided in applicable data protection laws, we will only send you promotional and marketing emails, or contact you for promotional or marketing purposes by phone or SMS, if you have given us your explicit consent.

Your rights with respect to your information

Your rights under applicable data protection laws

You have the right to understand how your personal and health information is collected, used, shared, and protected.

Your right to lodge a complaint with data protection authorities

In addition to the rights listed above, you may have the right to lodge a complaint with the applicable data protection authority in your jurisdiction, if you consider that a processing of your Personal Information infringes the applicable data protection laws.

How we store and protect your information

Data storage and transfer

Your information collected through the Service will be stored and processed in the United States and may be processed in any other country in which Carrot or its affiliates or service providers maintain or have access to facilities.

Keeping your information safe

We care about the security of your information and employ physical, administrative, and technological safeguards designed to preserve the integrity and security of all information collected through our Service.

Retention of your information

Unless applicable law requires a longer retention period, we will retain your information only as long as necessary for the purposes outlined in this Privacy Notice and for a commercially reasonable time thereafter for backup, archival, fraud prevention or detection, or audit purposes.

Questions about and changes to this privacy notice

Questions about this privacy notice

If you have any questions about this Privacy Notice or the website, please contact us at legal@get-carrot.com.

Changes to this privacy notice

As a general practice, we plan to update this Privacy Notice once every six months. We may, however, update it more or less frequently, depending on operational and regulatory circumstances.