Privacy Policy

Allara Digital Services Privacy Policy

Last modified: 5/12/21

1. Introduction

This Privacy Policy describes how Allara collects and uses Personal Data about you through the use of our Website and through e-mail, text, and other electronic communications between you and Allara.

Astrid Health, Inc. d/b/a Allara (“Allara,” or “we,” “our,” or “us”) respects your privacy, and we are committed to protecting it through our compliance with this policy.

This Privacy Policy (our “Privacy Policy”) describes the types of information we may collect from you or that you may provide when you visit or use our website located at allarahealth.com (our “Website”) and our practices for collecting, using, maintaining, protecting, and disclosing that information. For purposes of this Privacy Policy, our Website, and all related services and functionality that we provide through them are referred to as our “Digital Services.

”This policy applies to information we collect:

• on our Digital Services;
• in e-mail, text, and other electronic messages between you and our Digital Services; and
• when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this policy.
  It does not apply to information collected by:
• us offline or through any other means, including on any other website operated by Allara or any third party; or
• any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Digital Services.
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Allara is not a medical group. Any telemedicine consults obtained through our Digital Services are provided by independent medical practitioners including, but not limited to, Allara Medical Group, P.A. (“Allara Medical”), an independent medical group with a network of United States based health care providers (each, a “Provider). Allara Medical (or your own medical provider if you do not use an Allara Medical Provider) is responsible for providing you with a Notice of Privacy Practices describing its collection and use of your health information, not Allara. If you do not agree to be bound by those terms, you are not authorized to access or use our Digital Services, and you must promptly exit our 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 our Digital Services. By accessing or using our Digital Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Digital Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

1. Children Under the Age of 18

Our Digital Services are not intended for children under the age of 18 and children under the age of 18 are not permitted to use our Digital Services. We will remove any information about a child under the age of 18 if we become aware of it.Our Digital Services are not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Digital Services. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on or in our Digital Services or on or through any of their features, including your name, address, telephone number, e-mail address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from a child under 18, please contact us at hello@allarahealth.com or call us at (240) 988-3611.

1. Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our others users’ information. This includes information that we collect directly from you or through automated collection technologies.

Generally

We collect several types of information from and about users of our Digital Services, specifically information:

• by which you may be personally identified, such as first and last name, home address, work address, billing address, shipping address, e-mail address, home, work, and mobile telephone numbers, date of birth, credit or debit card number (for payment purposes only), driver’s license number, government, national and/or state identification, medical history, health information, user generated content, and information pertaining to your racial or ethnic origin (“Personal Data”);
• that is about you but individually does not identify you, such as traffic data, logs, referring/exit pages, date and time of your visit to or use of our Digital Services, error information, clickstream data, and other communication data and the resources that you access and use on or through our Digital Services; or
• about your Internet connection, the equipment you use to access or use our Digital Services and usage details.

We collect this information:

• directly from you when you provide it to us;
• automatically as you navigate through or use our Digital Services. Information collected automatically may include estimated or precise geo-location, usage details, IP addresses, and information collected through cookies and other tracking technologies; and
• From third parties, for example, our business partners.

Information You Provide to Us

The information we collect on or through our Digital Services is:

• Personal Data such as the data identified above;
• information that you provide by filling in forms on our Digital Services. This includes information provided at the time of registering to use our Digital Services, using our services or other services available through the Digital Services, purchasing products, or requesting further services. We may also ask you for information when you report a problem with our Digital Services;
• records and copies of your correspondence (including e-mail addresses), if you contact us; and
• details of transactions you carry out through our Digital Services and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Digital Services.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Digital Services or transmitted to other users of the Digital Services 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 the Digital Services 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 our Digital Services, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, specifically:

• details of your visits to our Digital Services, such as traffic data, location, logs, referring/exit pages, date and time of your visit to or use of our Digital Services, error information, clickstream data, and other communication data and the resources that you access and use on or in the Digital Services; and
• information about your computer, mobile device, and Internet connection, specifically your IP address, operating system, and browser type.

The information we collect automatically may include Personal Data or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Digital Services and to deliver a better and more personalized service by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences, allowing us to customize our Digital Services according to your individual interests; and
• recognize you when you return to our Digital Services.

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

• Cookies (or browser cookies). We and our service providers may use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Digital Services through your computer or mobile device. A cookie is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access or use certain parts of our Digital Services. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
• Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Website. Google Analytics uses “cookies”, which are text files placed on your computer, to help our Website analyze how users use the site. You can find out more about how Google uses data when you visit our Website by visiting “How Google uses data when you use our partners’ sites or apps”, (located at www.google.com/policies/privacy/partners/). We may also use Google Analytics Advertising Features or other advertising networks to provide you with interest-based advertising based on your online activity. For more information regarding Google Analytics please visit Google’s website, and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
• Facebook Pixel. We use Facebook Pixel, a web analytics and advertising service provided by Facebook Inc. (“Facebook”) on our Website. With its help, we and our customers can keep track of what users do after they see or click on a Facebook or Instagram advertisement, keep track of users who access our Website or advertisements from different devices, and better provide advertisements to our target audiences. The data from Facebook Pixel is also saved and processed by Facebook. Facebook can connect this data with your Facebook or Instagram account and use it for its own and others advertising purposes, in accordance with Facebook’s Data Policy which can be found at https://www.facebook.com/about/privacy/. Please click here if you would like to withdraw your consent for use of your data with Facebook Pixel https://www.facebook.com/settings/?tab=ads#_=_.
• Hotjar. Our Website uses Hotjar’s services, a third party service provider, which helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and enables us to build and maintain our Website and services with user feedback. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device’s IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website). Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

1. How We Use Your Information

We use your Personal Data for various purposes described below, including to:

• provide our Digital Services to you;
• provide products and services to you;
• provide you with the information you request from us;
• enforce our rights arising from contracts;
• notify you about changes; and
• provide you with notices about your account.

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

• to provide our Website and its functionality, contents and services to you;
• to provide our products and services to you;
• to provide you with information, products, or services that you request from us or that may be of interest to you;
• to process, fulfill, support, and administer transactions and orders for products and services ordered by you;
• to provide you with notices about your Allara account;
• to contact you in response to a request;
• 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 our Digital Services or any products or services we offer or provide though them;
• to notify you about changes to our Digital Services or any products or services we offer or provide though them;
• 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 goods and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications. In addition to other advertising partners and services, we use Google AdWords remarketing, an advertising service provided by Google, to help provide such communications to you. If you wish to restrict the information Google uses to show you these communications, you can find out more about how you can control the information Google uses from our Digital Services by visiting “How Google uses information from sites or apps that use our services”, (located at www.google.com/policies/technologies/partner-sites). For more information, see Choices About How We Use and Disclose Your Information. For more information, see Choices About

How We Use and Disclose Your Information.

Some information Allara collects constitutes protected health information (“PHI”) under the U.S. Health Insurance Portability and Accountability Act (“HIPAA”). As set forth above, Allara Medical (or your own medical provider if you do not use an Allara Medical Provider) will provide you with a Notice of Privacy Practices describing its collection, use, and disclosure of your health information, not Allara. Allara will use and disclose PHI only as permitted in Allara’s agreements with Allara Medical (or your own medical provider if you do not use an Allara Medical Provider) and we only collect the PHI we need to fully perform our services and to respond to you or your Provider. We may use your PHI to contact you to the extent permitted by law, to provide requested services, to provide information to your Providers and insurers, to obtain payment for our services, to respond to your inquiries and requests, and to respond to inquiries and requests from your Providers and benefits program. We may combine your information with other information about you that is available to us, including information from other sources, such as from your Providers, insurers or benefits program, in order to maintain an accurate record of our participants. PHI will not be used for any other purpose, including marketing, without your consent.

1. Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We disclose your Personal Data to a few third parties, including:

• our affiliates and third party service providers that we use to support our business;
• to a company we merge, acquire, or that buy us, or in the event of change in structure of our company of any form;
• to comply with our legal obligations;
• to enforce our rights; and
• with your consent

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

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

• to affiliates, contractors, service providers, and other third parties we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, and ordering, marketing, and payment processing services (Our payment processors’ privacy policies may be found at http://stripe.com/us/privacy);
• 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 our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Allara about our Digital Services users are among the assets transferred;
• 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 Data:

• 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 Allara, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

1. Choices About How We Use and Disclose Your Information

We offer you choices of how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising. We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Advertising. You can set your browser or operating system to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Digital Services may then be inaccessible or not function properly.
• Promotional Offers from Allara. If you do not wish to have your e-mail address used by Allara to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any e-mail or other marketing communications you receive from us or logging onto your Account Preferences page. This opt out does not apply to information provided to Allara as a result of a product purchase, or your use of our services. You may have other options with respect to marketing and communication preferences through our Digital Services.
• Text Messages from Allara. If you do not wish to receive informational text messages from Allara, you can opt out at any time by texting the word STOP in response to any text messages you receive. We may confirm your opt-out by text message.
• Targeted Advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. 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 also opt out of receiving targeted ads from members of the NAI on its website.

1. Your Rights Regarding Your Information and Accessing and Correcting Your Information

You may contact us to access or change you Personal Data. you may also be able to review and change your personal information by logging into the Digital Service and visiting your Account Preferences page.

You can Contact Us to access and/or find out what information we have about you, and to correct that information. You may also notify us through the Contact Information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your account. We cannot delete your personal information except by also deleting your account with us. We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.With respect to any PHI Allara may obtain, you have certain rights under HIPAA to access your data, to restrict use and disclosure of it, to request communication methods, to request corrections to your data, to receive an accounting of disclosures and to receive notice of any breach. See the Notice of Privacy Practices provided to you by your Provider for more information.

1. Do Not Track Signals

We currently do not honor do-not-track signals that may be sent by some browsers.

We also may use automated data collection technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. Because there is no standard for these signals at this time, we currently do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

1. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Website confidential.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.

The safety and security of your information also depends on you. Where you have chosen a password for the use of our 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 work diligently to try and protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website or in your operating system.

1. California Privacy Rights for California Residents

Under some circumstances, California law may provide you with the right to obtain a list of third parties (if any) that we provide your Personal Data to for their own direct marketing purposes.

CALIFORNIA PRIVACY RIGHTS

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Digital Services that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the immediately prior calendar year (e.g. requests made in 2021 will receive information regarding such activities in 2020). You may request this information once per calendar year. To make such a request, please contact us using the Contact Information below.

1. Changes to Our Privacy Policy

We will not post any changes to our Privacy Policy on our Website. If we make material changes to our Privacy Policy, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes.

We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on the Website’s home page. If we make material changes to how we treat our users’ Personal Data, we will notify you by e-mail to the e-mail address specified in your account and/or through a notice on the Website’s home page. The date this 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 e-mail address for you, and for periodically visiting our Website and reviewing this Privacy Policy to check for any changes.

1. Contact Information

You may contact us through the contact information below.If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact Us” page on or in our Digital Services.

How to Contact Us:

Allara

769 Broadway #1019

Manhattan, NY 10003

E-mail: hello@allarahealth.com