Privacy Policy

PRIVACY POLICY
SYMCHECK VITALS APP

Last updated March 24, 2025 

This Privacy Notice for PRIMAHEALTH LLC (“we,” “us,” or “our“), describes how and why we might access, collect, store, use, and/or share (“process“) your personal information when you use our services (“Services“), including when you:

Visit website at https://symcheckvitals.ai , or any website of ours that links to this Privacy Notice

Download and use our mobile application (SymCheck Vitals), or any other application of ours that links to this Privacy Notice

Use PRIMAHEALTH SERVICES. USE SymCheck Vitals App.

Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this Privacy Notice will help you understand your privacy rights and choices. We are responsible for making decisions about how your personal information is processed. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at privacy@symcheckvitals.ai.

SUMMARY OF KEY POINTS

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use. Learn more about personal information you disclose to us.

Do we process any sensitive personal information? Some of the information may be considered “special” or “sensitive” in certain jurisdictions, for example your racial or ethnic origins, sexual orientation, and religious beliefs. We may process sensitive personal information when necessary with your consent or as otherwise permitted by applicable law. Learn more about sensitive information we process.

Do we collect any information from third parties? We do not collect any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Learn more about how we process your information.

In what situations and with which types of parties do we share personal information? We may share information in specific situations and with specific categories of third parties. Learn more about when and with whom we share your personal information.

How do we keep your information safe? We have adequate organizational and technical processes and procedures in place to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure so we cannot promise or guarantee that hackers cybercriminals or other unauthorized thir parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Learn more about how we keep your information safe.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Learn more about your privacy rights.

How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what we do with any information we collect? Review the Privacy Notice in full.

TABLE OF CONTENTS 

1. ​WHAT INFORMATION DO WE COLLECT?
2. ​HOW DO WE PROCESS YOUR INFORMATION?
3. ​WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
4. ​DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
5. ​DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?
6. ​HOW LONG DO WE KEEP YOUR INFORMATION?
7. ​HOW DO WE KEEP YOUR INFORMATION SAFE?
8. ​DO WE COLLECT INFORMATION FROM MINORS?
9. ​WHAT ARE YOUR PRIVACY RIGHTS?
10. ​CONTROLS FOR DO-NOT-TRACK FEATURES
11. ​DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
12. ​COLLECTION OF VITAL SIGNS DATA
13. ​RETENTION AND DELETION OF DATA
14. ​OPTIONAL IMAGE CAPTURE AND STORAGE
15. ​DATA SECURITY
16. ​DATA TRANSFER AND THIRD-PARTY SHARING
17. ​DO WE MAKE UPDATES TO THIS NOTICE?
18. ​HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
19. ​HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

 

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us. 

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses
• usernames
• passwords
• contact preferences
• contact or authentication data

Sensitive Information. When necessary, with your consent or as otherwise permitted by applicable law, we process the following categories of sensitive information:

• health data

Application Data. If you use our application(s), we also may collect the following information if you choose to provide us with access or permission:

Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera, and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model, and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our application(s), we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID, and information about the features of our application(s) you accessed.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

This information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics and reporting purposes.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.

Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

Data Not Linked to Your Identity. We collect certain anonymized data, such as device identifiers, app usage interactions, and crash diagnostics, to improve app performance, monitor security, and enhance the user experience. This data is not linked to user accounts and is strictly used for internal analysis.

Google API

Our use of information received from Google APIs will adhere to Google API Services User Data

Policy, including the Limited Use requirements.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

To facilitate account creation and authentication and otherwise manage user accounts. We may process your information so you can create and log in to your account, as well as keep your account in working order.

To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.

To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.

To protect our Services. We may process your information as part of our efforts to keep our Services safe and secure, including fraud monitoring and prevention.

To evaluate and improve our Services, products, marketing, and your experience. We may process your information when we believe it is necessary to identify usage trends, determine the effectiveness of our promotional campaigns, and to evaluate and improve our Services, products, marketing, and your experience.

To identify usage trends. We may process information about how you use our Services to better understand how they are being used so we can improve them.

To help user’s track wellness. We may process your information to help user’s track wellness measurements.

To improve your user experience. We may process your information to improve your user experience.

To enforce terms. We may process your information to enforce terms.

To contact you or provide service updates. We may process your information to communicate updates, provide support, or notify you of changes to our services.

To protect the app and users from misuse. We may process your information to detect, investigate, and prevent unauthorized access, security breaches, fraud, or violations of applicable laws.

To evaluate app performance and usage trends. We may analyze anonymized usage data to improve app performance and user engagement.

To respond to user inquiries and support requests. We may process personal information to provide customer support and address any user concerns.

3. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

The categories of third parties we may share personal information with are as follows:

• AI Platforms
• Cloud Computing Services
• Data Analytics Services
• Data Storage Service Providers
• Testing Tools
• User Account Registration & Authentication Services
• Website Hosting Service Providers

We also may need to share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

Business Partners. We may share your information with our business partners to offer you certain products, services, or promotions.

4. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to gather information when you interact with our Services. Some online tracking technologies help us maintain the security of our Services and your account, prevent crashes, fix bugs, save your preferences, and assist with basic site functions.

We also permit third parties and service providers to use online tracking technologies on our Services for analytics and advertising, including to help manage and display advertisements, to tailor advertisements to your interests, or to send abandoned shopping cart reminders (depending on your communication preferences). The third parties and service providers use their technology to provide advertising about products and services tailored to your interests which may appear either on our Services or on other websites.

To the extent these online tracking technologies are deemed to be a “sale”/”sharing” (which includes targeted advertising, as defined under the applicable laws) under applicable US state laws, you can opt out of these online tracking technologies by submitting a request as described below under section “DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?”

Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

5. DO WE OFFER ARTIFICIAL INTELLIGENCE-BASED PRODUCTS?

In Short: We offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies.

As part of our Services, we offer products, features, or tools powered by artificial intelligence, machine learning, or similar technologies (collectively, “AI Products”). These tools are designed to enhance your experience and provide you with innovative solutions. The terms in this Privacy Notice govern your use of the AI Products within our Services.

Use of AI Technologies 

We provide the AI Products through third-party service providers (“AI Service Providers”), including Microsoft Azure AI. As outlined in this Privacy Notice, your input, output, and personal information will be shared with and processed by these AI Service Providers to enable your use of our AI Products for purposes outlined in “WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”  You must not use the AI Products in any way that violates the terms or policies of any AI Service Provider.

Our AI Products

Our AI Products are designed for the following functions:

AI insights

How We Process Your Data Using AI

All personal information processed using our AI Products is handled in line with our Privacy Notice and our agreement with third parties. This ensures high security and safeguards your personal information throughout the process, giving you peace of mind about your data’s safety.

How to Opt-Out

We believe in giving you the power to decide how your data is used. To opt out, you can:

Log in to your account settings and update your user account

Contact us using the contact information provided

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information or if this is not possible (for example because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. HOW DO WE KEEP YOUR INFORMATION SAFE?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate and reasonable technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

8. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to minors. 

If you are under the age of 18, you do not have permission to use the Application. If a parent or guardian becomes aware that his or her child has provided us with personally identifiable information without their consent, he or she should contact us at support@symcheckvitals.ai. If we become aware that a minor has provided us with personally identifiable information, we will delete such information from our files.

9. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?” below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Log in to your account settings and update your user account.

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our legal terms and/or comply with applicable legal requirements.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services.

If you have questions or comments about your privacy rights, you may email us at privacy@symcheckvitals.ai.

10. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not- Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

11. DO UNITED STATES RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processd it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. More information is provided below.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

Category	Examples	Collected
A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name	YES
B. Personal information as defined in the California Customer Records statute	Name, contact information, education, employment, employment history, and financial information	YES
C. Protected classification characteristics under state or federal law	Gender, age, date of birth, race and ethnicity, national origin, marital status, and other demographic data	YES
D. Commercial information	Transaction information, purchase history, financial details, and payment information	NO
E. Biometric information	Fingerprints and voiceprints	NO
F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements	NO

G. Geolocation data	Device location	YES
H. Audio, electronic, sensory, or similar information	Images and audio, video or call recordings created in connection with our business activities	NO
I. Professional or employment- related information	Business contact details in order to provide you our Services at a business level or job title, work history, and professional qualifications if you apply for a job with us	NO
J. Education Information	Student records and directory information	NO
K. Inferences drawn from collected personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO
L. Sensitive personal Information	Account login information, health data and racial or ethnic origin	YES

We only collect sensitive personal information, as defined by applicable privacy laws or the purposes allowed by law or with your consent. Sensitive personal information may be used, or disclosed to a service provider or contractor, for additional, specified purposes. You may have the right to limit the use or disclosure of your sensitive personal information. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.

We may also collect other personal information outside of these categories through instances where you interact
with us in person, online, or by phone or mail in the context of:

Receiving help through our customer support channels;

Participation in customer surveys or contests; and

Facilitation in the delivery of our Services and to respond to your inquiries.

We will use and retain the collected personal information as needed to provide the Services or for:

Category A – As long as the user has an account with us

Category B – As long as the user has an account with us

Category C -As long as the user has an account with us

Category G – As long as the user has an account with us

Category H -As long as the user has an account with us

Category L – As long as the user has an account with us 

Sources of Personal Information

Learn more about the sources of personal information we collect in “WHAT INFORMATION DO WE COLLECT?”

How We Use and Share Personal Information 

Learn more about how we use your personal information in the section, “HOW DO WE PROCESS  YOUR INFORMATION?”

Will your information be shared with anyone else?

We may disclose your personal information with our service providers pursuant to a written contract between us and
each service provider. Learn more about how we disclose personal information to in the section,
“WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” of your personal information.

We have not sold or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We have disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

• Category L. Sensitive personal information

The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under
“WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?”

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California’s privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including Minnesota’s privacy law)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including California’s and Delaware’s privacy law)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including Minnesota’s and Oregon’s privacy law)
• Right to review, understand, question, and correct how personal data has been profiled (as permitted by applicable law, including Minnesota’s privacy law)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including California’s privacy law)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including Florida’s privacy law)

 

How to Exercise Your Rights 

To exercise these rights, you can contact us by submitting a data subject access reguest, by emailing us at userprivacy@symcheckvitals.ai, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at privacy@symcheckvitals.ai . We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

California “Shine The Light” Law

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us by using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS NOTICE?”

12. COLLECTION OF VITAL SIGNS DATA

The Application collects and processes vital signs data, including but not limited to heart rate (8PM), respiration rate (8PM), stress levels, HRV-SDNN (ms), and other calculated vital sign metrics. This data is collected solely for the purpose of tracking and maintaining historical measurement records for the user. The Application utilizes video input from a small, non-identifiable patch of skin on the user’s face or finger to obtain these measurements. No personally identifiable features, such as the user’s eyes, are captured or processed. All video data is processed in real-time, is neither retained nor transferred to our servers once the measurement is completed.

13. RETENTION AND DELETION OF DATA

Health-related data is stored only on the user’s device unless explicitly shared, while account and contact information is retained as long as the account remains active. Users can delete their measurement history or request full account deletion at any time via app settings or customer support. Upon deletion, data is permanently erased in compliance with applicable data protection regulations.

14. OPTIONAL IMAGE CAPTURE AND STORAGE

Users may choose to provide explicit consent for the Application to store image captures in order to enable advanced features, such as hydration and aging metrics analysis. A clear and informed consent prompt will be presented to users before any image captures are stored, explaining the purpose of the collection and storage of these captures. Users can revoke this consent and delete any stored image captures at any time through the Application’s settings. The Application will store these image captures locally on the user’s device or securely on servers, as authorized by the user, and they will not be transmitted to third parties without further explicit user consent.

15. DATA SECURITY

The Application employs industry-standard security protocols to protect all user data, including data encryption both in transit and at rest. These measures are designed to safeguard user data from unauthorized access, disclosure, or alteration. Only authorized personnel have access to this data, and any data processing is conducted in full compliance with applicable data protection regulations, including GDPR, CCPA, LGPD and other relevant privacy laws. All collected data is encrypted during transmission and storage where applicable, with access controls and authentication measures in place to protect user privacy. We do not transmit identifiable health data externally without user consent.

16. DATA TRANSFER AND THIRD-PARTY SHARING

The Application does not transfer any collected data to third-party servers unless explicitly authorized by the user. In cases where image captures or other data are processed on third-party servers, the data is encrypted and managed in full compliance with GDPR, CCPA, LGPD and cross-border data transfer requirements. Users will be informed of any such transfers and will be provided with an opportunity to consent prior to the transfer of their data. We do not currently integrate with Apple HealthKit, and any future integration will require explicit user consent. Users will always have full control over what data is shared and can manage permissions within their device settings.

PrimaHealth, LLC., as well as our licensors, vendors, partners, consultants and affiliates  (“PrimaHealth,” “we” or “us”) values your privacy. PrimaHealth offers telemedicine platform and Services (the “Services”). This Telehealth Privacy Policy applies to our website https://primahealth.tech (the “Site”), as well as the Services, which are accessible through PrimaHealth and/or the Site. Through our Services participating medical professionals and healthcare staff (“Healthcare Providers” or “Providers”) can provide health care services online to their clients and patients (“Patients”). In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our Site and users of our Services.

By visiting the Site or using our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Site and Services, and any dispute over privacy is subject to this Policy and our Terms of Service, including its applicable limitations on damages and the resolution of disputes. The PrimaHealth Terms of Service are incorporated by reference into this Policy.

WHAT INFORMATION DO WE COLLECT ABOUT YOU AND WHY?

We may collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Services.

Information We Collect Directly From You.

Users may browse the informational areas of the Site without registering with us. However, registration is required to use the Services. Once a Healthcare Provider has registered with us and subscribed to our Services, the Healthcare Provider can then invite Patients to use the Services. After receiving an invite, the Patient would then need to register for an PrimaHealth account to use the Services.

Healthcare Provider Registration. To register, Healthcare Providers must provide certain information about themselves and their practices including: the Healthcare Provider’s name, date of birth, gender, address, email, mobile and work phone; the Healthcare Provider’s practice name, address, phone number and fax number; and a user id and password.  We may also collect certain optional information, including: middle name or initial, bank account or other payment information and other contact details, picture and communication preferences.

 Patient Registration.  Patients must provide certain information, including: name, date of birth, gender, address, email, mobile and work phone, as well as a user id and password.  We may also collect certain optional information, including: middle name or initial, home phone and other contact info, pharmacy name and contact details, other demographic information, health insurance information, credit card number and billing details, picture and communications preferences.  In addition, the Patient can communicate other health-related information to the Healthcare Provider during a video consultation via the PrimaHealth app.

Other.  We also collect other information that you submit on our Site, such as comments and blog postings (see “User Generated Content” section below).  You must submit your name to post a comment to our blog and you may submit other optional information as well.

 Information We Collect From Healthcare Providers.  Certain features and Services are available to patients because their Healthcare Providers use our Services. Healthcare Providers may provide patient names and e-mail addresses to us so we may communicate with patients on their behalf about the availability of certain Services.

Information We Collect Automatically. We may automatically collect the following information about your use of our Site or Services through cookies, web beacons, and other technologies: your domain name; your browser type and operating system; web pages you view; links you click; your IP address; a time and date stamp and the length of time you visit our Site and or use our Services; the referring URL, or the webpage that led you to our Site; and your browser type. We may combine this information with other information that we have collected about you, including, where applicable, your user name, name, and other personal information. Please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information about our use of cookies and other tracking mechanisms.

HOW WE USE YOUR INFORMATION

We use the information that we gather about you for the following purposes:

To provide our Services.

To communicate with you about your use of our Services, to respond to your inquiries, to provide technical support and assistance and for other customer service purposes.

To communicate with you regarding the availability of Services on behalf of your Healthcare Provider, otherwise, we do not market to Patients.

To send you reminders and other information related to your care on behalf of your Healthcare Provider.

To tailor the content and information that we may send or display, to offer location customization, and personalized help and instructions, and to otherwise personalize your experiences while using the Site or our Services.

To send offers and other promotional communications to Healthcare Providers;

To display advertising on our Site.

To better understand how users access and use our Services, both on an aggregated and individualized basis, in order to improve our Site and Services and respond to user desires and preferences, and for other research and analytical purposes.

 HOW WE SHARE YOUR INFORMATION

We may share the information that we collect about you, including personally identifiable information, as follows:

Healthcare Providers. As a Patient, your information will be shared with Healthcare Providers as directed and consented to by you. Our Services make your Assessments and related information available to your Healthcare Provider.   We will not make information available to Healthcare Providers other than those with whom you have requested that we share your Assessments.  This Policy does not address how Healthcare Providers will use and disclose information obtained using PrimaHealth.  If you would like this information, you should ask your Healthcare Provider directly for a copy of his/her Notice of Privacy Practices.

Service Providers. We may disclose the information we collect from you to third party vendors, service providers, contractors or agents who perform functions on our behalf.

Business Transfers. If we are acquired by or merged with another company, if substantially all of our assets are transferred to another company, or if we are a part of a bankruptcy proceeding, we may transfer the information we have collected from you to the other Company.

In Response to Legal Process. We also may disclose the information we collect from you in order to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a subpoena in compliance with applicable privacy laws.

To Protect Us and Others. We also may disclose the information we collect from you, to the extent permitted by law, where we believe it is necessary to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms of Use or this Policy, or as evidence in litigation in which PrimaHealth is involved.

Aggregate and De-Identified Information. We may share aggregate or de-identified information about users with third parties for marketing, advertising, research or similar purposes.

OUR USE OF COOKIES AND OTHER TRACKING MECHANISMS

We use cookies and other tracking mechanisms to track information about your use of our Site or Services. We may combine this information with other information we collect from you.

 Cookies.  Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Site and Services, while others are used to enable a faster log-in process or to allow us to track your activities at our Site and Service.  Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site who disable cookies will be able to browse public areas of the Site, but the Services will not function.

 Clear GIFs (a.k.a. web beacons, web bugs or pixel tags).  Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (in connection with our Site to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about Site usage. We and our third party service providers also use clear GIFs in HTML e-mails to our customers, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.

 Third Party Analytics. We use automated devices and applications, such as Google Analytics, MixPanel, and Kissmetrics, to evaluate usage of our Site and Services and to help us personalize content on out Site and Services. We also may use other analytic means to evaluate our Services. We use these tools to help us improve our Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.

 Advertising. We may use network advertisers, such as AdRoll, to advertise our Site and Services on other websites, and we may do so based on your visits to our Site and to other third party Sites. These entities may use cookies and other tracking technologies to perform their services. We do not share your personal information with these third parties.  Our Site does not currently respond to browser “Do-Not-Track requests; however, you may find out more about targeted advertising in general, and opt out of targeted ads from many ad networks, including AdRoll, through the National Advertising Initiative (“NAI”) website, or the Digital Advertising Alliance (“DAA”) website.

USER GENERATED CONTENT

We may invite you to post content on our Site, including your comments PrimaHealth cannot prevent such information from being used in a manner that may violate this Policy, the law, or your personal privacy.  As a result, you should never post any sensitive information to our Site that you are not comfortable sharing publically (e.g., personal medical details).  PrimaHealth is not liable to you or any other person for any content or information you post to our Site or the use or disclosure of such content or information by other users or third parties.

THIRD-PARTY LINKS

Our Site and Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third party websites. We are not responsible for the information practices of such third party websites.

PATIENT HEALTH INFORMATION

The privacy and security of Patients’ individually identifiable health information provided to PrimaHealth in connection with Services may be protected by federal law (HIPAA, the HITECH Act, and their regulations) and state privacy laws, and GDPR regulations, because PrimaHealth provides Services to health care providers.  This health information is “protected health information” (“PHI”).  PHI may be used and disclosed by PrimaHealth as necessary to provide Services, for our own management and operations, to meet our legal obligations, and for any other purpose for which Patients have given consent.  We may share PHI with third parties for these purposes in compliance with applicable law.  We may de-identify PHI and aggregate it for purposes of monitoring and improving our products and services, for benchmarking purposes, and to provide customized services or technologies our customers.

SECURITY OF MY PERSONAL INFORMATION

We have implemented reasonable technical, physical, administrative, and organizational safeguards to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.  Please be aware that despite our efforts, no data security measures can guarantee 100% security.  You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.

Access To My Personal Information                                                              

You may modify registration information that you have submitted by logging into your account and updating your profile information. Please note that copies of information that you have updated, modified or deleted may remain viewable in cached and archived pages of the Site for a period of time.

MARKETING EMAILS

We may send periodic promotional or informational emails to Healthcare Providers. Healthcare Providers may opt-out of such communications by following the opt-out instructions contained in the e-mail. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving emails about recommendations or other information we think may interest you, we may still send you e-mails about your account or any Services you have requested or received from us.

CHANGES TO THIS POLICY

This Policy is current as of the Effective Date set forth herein. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on this page. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change, such as by highlighting the change on our Site, or emailing the email address of record for your account.

CONTACT US

We encourage you to contact us if you have any questions or concerns regarding the privacy aspects of our Services or would like to make a complaint. You may write us at:

PRIMAHEALTH
Attn: Privacy Policy
Email: privacy@primahealth.tech

EFFECTIVE AND REVISED 01/30/2023[/vc_column_text][/vc_column][/vc_row]