Embold Health Privacy Policy

Effective: June 1, 2020

Latest revision: June 1, 2020

Introduction

Emboldhealth.com (our “Website“) is owned by Embold Health, Inc. (“Embold Health” or “We“). We respect your privacy and are committed to protecting it through our compliance with this Privacy policy and the Health Insurance Portability and Accountability Act of 1996 (HIPAA). HIPAA requires that access to Protected Health Information (PHI) shall be managed to guard the integrity, confidentiality, and availability of PHI.

This Privacy Policy describes the types of information we may collect from you or that you may provide when you use Embold Health, visit our Website, communicate with us via our Website, or visit another website that is operated by Embold Health that displays a link to this privacy policy, and our practices for collecting, using, maintaining, protecting and disclosing that information. It does not apply to information collected by us offline or through any other means, including on any other website operated by us that does not link to this privacy policy or any outside entity that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. By accessing or using the Website, you agree to this privacy policy, where permitted by law.

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, where permitted by law, so please check the policy periodically for updates.

Information We Collect About You

We collect the following information from users of our Website:

Your name, e-mail address, telephone number and company information when you request information from our site;
Demographic information, such as National Provider Identifier (NPI), geographic area, and preferences for health care professionals requesting a provider performance report; and
Information about your Internet connection, the equipment you use to access our Website, and usage details, such as browsing activity.

We collect this information when you fill in forms on our Website, including when you create an account, complete a survey for research purposes, or request further services, such as to view

healthcare provider information, or otherwise communicate with us. We also may ask you for information when you report a problem with our Website.

Information We Collect Automatically

As you navigate through and interact with our Website, we use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including your Internet protocol address, browser type, domain names, access times, and operating system, and details of your visits to our Website, including traffic data, location data, logs and other communication data, and the resources that you access and use on the Website. We also use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

We collect this information in order to improve our 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 our Website according to your individual interests; or
Recognize you when you return to our Website.

The technologies we use for this automatic data collection 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 our 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 our Website. You must accept cookies to access Embold Health as a registered user.
Web Beacons. Pages of the Website and our e-mails contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit Embold Health, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Web Analytics. We use analytics software to track aggregate and anonymous user behavior on our Website.

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 our Website and its content to you;

To provide you with information, products or services that you request from us, including information about providers or facilities and notices about your account;

To notify you about changes to our Website or any products or services we offer;
To fulfill any other purpose for which you provide it; or
For any other purpose with your consent.

How We Share Your Information

Embold Health will only disclose aggregated data about our users, and data that does not identify any individual, with those who have a legitimate need for it. Whenever we permit a third party to access aggregated data, we will make sure the aggregated data are used in a manner consistent with this notice (and any applicable internal data handling guidelines consistent with the sensitive and classification of the data). Aggregated data about our users may be shared with third parties, including service providers, for legitimate purposes as follows:

To enable third parties to provide services to us;
To comply with our legal obligations, regulations or contracts, or to respond to a court order, administrative or judicial process, such as a subpoena, government audit or search warrant. Categories of recipients would include counter-parties to contracts, judicial and governmental bodies;
In response to lawful requests by public authorities (such as national security or law enforcement);
To seek legal advice from external lawyers and advice from other professional advisers such as accountants, management consultants, etc.;
As necessary to establish, exercise or defend against potential, threatened or actual litigation (such as adverse parties in litigation);
Where necessary to protect rights, property, or safety of Embold Health, our customers, your vital interests, such as safety and security, or those of others;
In connection with the sale, assignment or other transfer of all or part of our business (such as a potential purchaser and its legal / professional advisers); or
Otherwise in accordance with your consent.

Please note that where legal requirements limit the sharing of your data, Embold Health will respect such requirements.

Accessing and Correcting Your Information

You can review and change your personal information by sending us an e-mail to [email protected] to request access to, correct, or delete any personal information that you have provided to us. 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.

California Residents Only

Residents of the state of California have the right to request information regarding other companies to whom we have disclosed certain categories of information during the preceding

year for those companies’ direct marketing purposes. At this time, Embold Health does not disclose any information to companies for direct marketing purposes. If you are a California resident and would like to make such a request, please email [email protected] or write to us at 1801 West End Avenue, Suite 800, Nashville, TN 37203.

Our Practices Regarding Children’s Information

Our Website is intended for users age 18 and older. We do not knowingly collect information from children. If we discover that we have inadvertently collected information from anyone younger than the age of 18, we will delete that information.

Do Not Track

Do Not Track is a privacy preference that users can set in their web browsers. When a user turns on the Do Not Track signal, the browser sends a message to websites requesting them not to track the user. Currently, Embold Health does not respond to Do Not Track browser settings or signals. In addition, we deploy cookies, web beacons, and other technologies on our Website. Those tools may be used by us, our customers, and third parties to collect information about you and your Internet activity, even if you have turned on the Do Not Track signal.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

Unfortunately, the transmission of information via the Internet is not completely secure. While data are encrypted during the transmission or use of our Website and although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our 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 the Website.

Cross-Border Transfer

If you use our Website outside of the United States, you understand that we collect, process, and store your information in the United States. The laws in the United States regarding your information may be different from the laws of your jurisdiction. By using our Website, you consent to the collection, international transfer, storage, and processing of your data, where permitted by law.

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’s home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for periodically visiting our 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].

1801 West End Avenue, Suite 800, Nashville, TN 37203