Privacy Policy

Last modified: May 24, 2023

Introduction

Digital Health Navigation Solutions, Inc. (the “Company” or “we”) respects your privacy and is committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit the website www.mpathhealth.com, including any subdomains thereof (this “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

· on this Website;

· in email, text, and other electronic messages between you and the Company; or

· through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

It does not apply to information collected by:

· the Company offline or through any other means, including on any other website operated by the Company or any third party; or

· any third party, including through any application or content (including advertising) that may link to or be accessible from this Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use this Website. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see “Changes to Our Privacy Policy”). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children Under the Age of 16

This Website is not intended for children under 16 years of age. No one under age 16 may provide any information to or on this Website. We do not knowingly collect personal information from children under 16. If you are under 16, do not use or provide any information on this Website or through any of its features, register on this Website, make any purchases through this Website, use any of the interactive or public comment features of this Website, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 16 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 16, please contact us at [email protected]

California residents under 16 years of age may have additional rights regarding the collection and sale of their personal information. Please see “Your State Privacy Rights” for more information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of this Website, including information:

· by which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);

· that is about you but individually does not identify you; and/or

· about your internet connection, the equipment you use to access this Website, and usage details.

We collect this information:

· directly from you when you provide it to us;

· automatically as you navigate through the site, which may include usage details, IP addresses, and information collected through cookies, web beacons and other tracking technologies; and

· from third parties, for example, our healthcare provider partners.

Information You Provide to Us

The information we collect on or through this Website may include:

· information that you provide by filling in forms on this Website, which includes information provided at the time of registering to use this Website;

· information you provide when you report a problem with this Website;

· records and copies of your correspondence (including email addresses) if you contact us;

· your responses to surveys that we might ask you to complete;

· details of transactions you carry out through this Website and of the fulfillment of your orders, which may include financial information; and

· your search queries on the Website.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of this Website, or transmitted to other users of this Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of this Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with this Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

· details of your visits to this Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website; and

· information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve this Website and to deliver a better and more personalized service, including by enabling us to:

· estimate our audience size and usage patterns;

· store information about your preferences, allowing us to customize this Website according to your individual interests;

· speed up your searches; and

· recognize you when you return to this Website.

The technologies we use for this automatic data collection may include:

· Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of this Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to this Website.

· Flash Cookies. Certain features of this Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on this Website. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see “Choices About How We Use and Disclose Your Information”.

· Web Beacons. Pages of this Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on this Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use this Website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see “Choices About How We Use and Disclose Your Information”.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

· to present this Website and its contents to you;

· to provide you with information, products, or services that you request from us;

· to fulfill any other purpose for which you provide it;

· to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;

· to notify you about changes to this Website or any products or services we offer or provide though it;

· to allow you to participate in interactive features on this Website.;

· to allow research publications

· in any other way we may describe when you provide the information; and

· for any other purpose with your consent.

We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you do not want us to use your information in this way, please adjust your user preferences in your account profile. For more information, see “Choices About How We Use and Disclose Your Information”.

We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

We do not sell, rent, disclose, or use protected health information (PHI) as defined under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) without authorization or unless permitted or required by law.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

· to our subsidiaries and affiliates;

· to contractors, service providers, and other third parties we use to support our business;

· to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about this Website users is among the assets transferred;

· to third parties to market their products or services to you if you have consented not opted out of these disclosures;

· to fulfill the purpose for which you provide it;

· for any other purpose disclosed by us when you provide the information; and

· with your consent.

We may also disclose your personal information:

· to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

· to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and

· if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others.

We will not disclose your PHI to any third party, unless required by law or to a third-party subcontractor with an executed Business Associate Agreement.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

· Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Website may then be inaccessible or not function properly.

· Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your personal information with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by emailing [email protected].

· Targeted Advertising. If you do not want us to use information that we collect or that you provide to us to deliver advertisements according to our advertisers’ target-audience preferences, you can opt-out by emailing [email protected].

We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Residents of certain states, such as California, Nevada, Colorado, Connecticut, Virginia, and Utah, residents may have additional personal information rights and choices. Please see “Your State Privacy Rights” for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada Revised Statutes Chapter 603A may submit a request to this designated address: [email protected]. However, please know we do not currently sell data triggering that statute’s opt-out requirements.

Accessing and Correcting Your Information

You can review and change your personal information by logging into this Website and visiting your account profile page.

You may also send us an email at [email protected] to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users.

HIPAA

We are considered a “business associate” under HIPAA, which is defined as an individual or entity that is not a member of the “covered entity” and performs certain functions involving the use or disclosure of PHI on behalf of the covered entity.

We will enter into a Business Associate Agreement with each covered entity for the protection of all communications containing PHI and will enter into a Business Associate Agreement with any subcontractors of the Company that have access to PHI.

Access to PHI is secured through password protection and can only be accessed by authorized users. All PHI is stored on SOC2 compliant cloud-based servers. Within the database, information is fully encrypted and additionally secured through transport layer security.

We may be directed by your healthcare provider to communicate with you and perform other services or activities on behalf of your healthcare provider. As a patient, you have the right to consent or decline engagement with our mPATH platform. We will collect, retain, and use your information as permitted by your healthcare provider and as described in this privacy policy.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To exercise any applicable state privacy rights, please send an email to [email protected].

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of this Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to this Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on this Website.

As required by various state and federal laws, we may send you notice of security breaches or suspected security breaches that impact your personal information and PHI.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting this Website and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: [email protected]