HEALTHSLATE PRIVACY POLICY

Effective July 5, 2016 Version 1.1

I. OUR COMMITMENT TO PRIVACY

This HealthSlate Privacy Policy (“Policy”) sets forth the information privacy practices of Informational Media Brands, LLC (collectively “HealthSlate” “we” or “us”) in connection with your use of the HealthSlate mobile applications (Apps,) health management services, and websites (collectively, the “Services.”) HealthSlate respects your privacy and is committed to ensuring that your personal information is respected and protected consistent with this Policy. This Policy discloses the information we gather through the Services, the ways we process, share and secure such information and how you can correct or change it. This Policy addresses our privacy practices relating to the use of the Services. Anyone who visits, browses or otherwise uses the Services (collectively, "you" or “user”) is subject to this Policy. Before using and submitting any information to the Services, please read this Policy. By using the Services, including the submission of any personal information, you acknowledge that you accept the practices and policies outlined in this Policy and consent to having your data transferred to and/or processed in the United States. If you do not agree to this Policy, you are not permitted to use the Services.

II. THE INFORMATION WE COLLECT

We do not require you to submit any more information than is necessary to use the Services effectively. We may collect the following three categories of information from you: (a) Personally Identifiable Information (PII); (b) Non-Personal Information; and (c) Passive Anonymous Information. All three of these categories are collectively referred to as “Information” in this Policy.

Personally Identifiable Information Collected from Individuals

We may receive and store any information you enter through the Services that is intended to allow us or third parties to identify you personally, contact you or identify other individuals. This information is referred to as PII. The PII you provide to us only will be used by HealthSlate in accordance with this Policy. Examples of PII we may collect from you: • Your first and last name, email address, postal address, user name, or telephone number; • PII you provide about yourself or others when you send us an e-mail, contact support or otherwise communicate with us. Sometimes HealthSlate will aggregate and/or anonymize PII so that it becomes non-personal information and is not intended to be used to personally identify you.

Non-Personal Information

From time to time, we may also ask you to provide us with non-personal information which is data that alone is not intended to allow us to identify you personally, such as just your first name or zip code. We may also collect information that you choose to provide concerning specific health indicators, such as blood pressure readings; however, such information is not linked with or otherwise associated with PII.

C. Passive Anonymous Information Gathered Electronically

We and our third party partners may automatically collect certain types of passive, anonymous information whenever you use the Services, such as information about your device, your computer, and online activities. For instance, we may automatically collect Services usage information, such as the numbers and frequency of users of the Services, pages visited and similar data. This data is used in the aggregate, that is, as a statistical measure, and not in a manner that HealthSlate intends to use to identify you personally. If we collect this information, it will be done passively through the use of certain electronic technologies, such as cookies, web beacons, pixels, clear GIFs (and similar technologies) and location information from your wireless equipment.

III. INFORMATION SHARED WITH HEALTHSLATE BY OTHERS

As part of the Services, third parties, including physicians, health clinics and health educators (collectively, “Covered Entities”) may share with HealthSlate certain patient information, including protected health information, as that term is defined in the Health Insurance Portability and Accountability Act (HIPAA). This information is collected by the Covered Entities and subject to any privacy notice provided by the Covered Entities to the user. HealthSlate does not collect this information but has access to it as part of the services it provides to Covered Entities and is obligated to protect such information pursuant to HIPAA. Any other information that HealthSlate receives about a user from a third party is subject to that third parties’ privacy notice and practices.

IV. HOW WE USE INFORMATION

We may use your Information for a number of purposes, including:

  • To allow you to use the Services and to administer your account;
  • To facilitate communication between HealthSlate and you including, without limitation, responding to your questions or comments, sending e-mails concerning our products and services, to contact you for feedback regarding us, advertisers or business partners, or to communicate with you for customer support;
  • To provide you with information about products or services that we think you will find valuable;
  • For our marketing and promotional activities and to statistically analyze the use of the Services;
  • To provide a report for us or to our business partners that tells them who responded to a particular offer or to facilitate the fulfillment of an order that you have made with an business partner;
  • To provide you with important functionality changes to the Services, new HealthSlate services and special offers from HealthSlate that we think you will find valuable;
  • To customize, personalize, analyze, evaluate, adjust and improve the Services to meet the needs and expectations of you, HealthSlate, our affiliates and our advertisers or business partners;
  • To sign you up for our email newsletter, or with your permission enter you into a sweepstakes;
  • To anonymize or aggregate PII for various purposes like market analysis or traffic flow analysis and reporting and other internal purposes;
  • To enforce our agreements with you, prevent fraud and other prohibited or illegal activities, for other legally permissible purposes and generally to ensure that we comply with applicable laws.

V. ADVERTISING AND DO NOT TRACK

The Services may include contextual advertisements based on your use of the Services, information that you provide to HealthSlate, or information that we obtain from third parties. HealthSlate does not respond to Internet browser “Do-Not-Track” signals because it does not engage in the activities that Do-Not-Track signals are intended to address, namely, the tracking of users over time and across third party websites (such as through the use of cookies or similar technologies). In addition, HealthSlate does not permit third parties to engage in such tracking on the Services.

VI. DISCLOSURE OF INFORMATION TO THIRD PARTIES

The privacy and confidentiality of your Information is important to HealthSlate. We only share your Information with third parties if we have your permission or under the following circumstances.

Service Providers. We may share Information with third parties who perform services on our behalf. These third party service providers are contractually required or bound by law to protect your PII and only are permitted to use it in accordance with the terms of our service agreements with them.

Business Transfers. Information may be disclosed as part of any merger, acquisition, sale of company assets or transition of service to another provider. In the unlikely event of an insolvency, bankruptcy or receivership, Information also may be transferred as a business asset. If HealthSlate is involved in a transition of service to another provider, merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a conspicuous notice on or through the Services, which will include any choices you may have concerning your Information. Protection of HealthSlate and Others. We may access, monitor, use or disclose your Information or communications to do things like: (i) comply with the law or respond to lawful requests or legal process; (ii) protect the rights or property of us, our agents, members, our customers, and others including to enforce our agreements, policies and terms of use; (iii) respond to emergencies; (iv) initiate, render, bill, and collect for services; or (v) facilitate or verify the appropriate calculation of taxes, fees, or other obligations due to a local, state, or federal government requirement, if any.

Passive Anonymous and Aggregated Non-Personal Information. You agree that we may share with third parties passive, anonymous and non-personal information about you that is aggregated and is not intended to allow these third parties to identify you. This non-personal information is usually obtained through the use of electronic technologies as described in Section II.C. above. HealthSlate does not share your PII with third parties for their direct marketing purposes unless you have provided explicit permission to do so.

VII. FINANCIAL INFORMATION

HealthSlate does not collect, store or otherwise maintain any financial information, including credit, debit or similar information from individuals who purchase any products or services through the Services. Financial information is collected by a trusted third party, who processes the credit, debit or ACH transaction.

VIII. ACCESSING OR CHANGING YOUR PII

HealthSlate allows you to change or correct inaccuracies in your PII by contacting us.

IX. IMPORTANT DISCLOSURES, PRACTICES AND CONTACT INFORMATION

  1. Third Party Links
  2. The Services may contain links to third-party websites or applications. Please be aware that HealthSlate cannot control and is not responsible for the information collection practices of such websites or applications, which may differ from those of HealthSlate. We encourage you to review and understand the privacy policies and terms and conditions of these web sites applications before providing any information to them.

  3. Data Security
  4. We maintain a variety of commercially reasonable safeguards designed to protect your Information from unauthorized access and disclosure. For example, we use industry accepted tools and techniques to protect against unauthorized access to our systems. You should be aware, however, that HealthSlate has no control over the security of other websites or applications that you might visit or use even when a link to those websites or applications is available in or through the Services. If you share your computer or wireless device or use a computer or wireless device that is accessed by the general public, remember to sign off and close the Services when you have finished your session. This will help to ensure that others cannot access your PII. We want you to feel confident using the Services. However, no system can be completely secure. Therefore, although we take commercially reasonable steps to secure your Information, we do not promise, and you should not expect, that your Information or other communications always will remain secure. In the event of a breach of the confidentiality or security of your PII, we will notify you if reasonably possible and as reasonably necessary so that you can take appropriate protective steps. We may notify you under such circumstances using the e-mail address(es) we have on record for you. You should also take care with how you handle and disclose your PII. Please refer to the Federal Trade Commission's Web site for information about how to protect yourself against identity theft.

  5. Marketing Preferences
  6. If you sign up to receive email newsletters or other marketing communications from HealthSlate and no longer wish to receive such correspondence, you may follow the instructions in each email on how to unsubscribe or by sending an email with your unsubscribe request to privacy@atozhealth.com.

  7. Children
  8. The Service is not intended for persons under the age of 13. HealthSlate does not knowingly market to, or solicit information, accept service or collect information from any person under the age of 13. If HealthSlate becomes aware that any person submitting information to the Services is under the age of 13, we will attempt to delete the account and any related information as soon as possible. We require that only persons 13 years of age or older use the Services. By using the Services, you hereby represent that you are at least 13 years old. Any ratings for Services provided by a third party shall have no bearing on this limitation.

  9. Changes to this Privacy Policy
  10. We may occasionally update this Policy to reflect changes in our practices. When we post changes to this Policy, we will revise the updated date and version number at the top of this Policy. If we make any material changes to our Policy, we will notify you by sending an e-mail to the e-mail address(s) you provided to us, and by prominently posting notice of the changes on or through the Services. We will give you an opportunity to opt-out of any materially changed Policy or alternatively, delete the information you have provided to us. We recommend that you check the Services from time to time to inform yourself of any changes in this Policy or any of our other policies. Any non-material changes to the Policy will not be sent to you via email; a notice of such non-material changes will be posted on or through the Services.

  11. Contacting Us
  12. If you have any questions about HealthSlate generally, this Policy or the Services, please feel free to contact us either by sending an email to privacy@atozhealth.com or by writing to us at: HealthSlate, LLC, Attn: Privacy Office, 13818 Wright Circle, Tampa FL 33626

  13. Users From Outside the United States
  14. The Services are hosted in the United States and is governed by United States law. If you are using the Services from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties with whom we share it as described in this Policy.

  15. No Rights of Third Parties
  16. This Policy does not create rights enforceable by third parties.