Privacy Policy

1. Introduction

This Privacy Policy (our “Privacy Policy”) supplements Priority Private Opco, LLC and/or its subsidiaries’ (“Company,” “we,” “us,” and “our”) Terms and Conditions (“Terms”) and describes how Company and Medical Groups collect, use, maintain, protect, and disclose Personal Data about you through the use of the Services. By “Personal Data,” we mean information that is personally identifiable to you.

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

2. Protected Health Information

Please see the Medical Groups’ Notice of Privacy Practices to understand how we protect, use and disclose your protected health information as defined under the Health Insurance Portability and Accountability Act of 1996 and related laws and regulations (“HIPAA”). If your Personal Data is protected health information, we treat the protected health information in accordance with HIPAA and the Notice of Privacy Practices. To the extent this Privacy Policy conflicts with our HIPAA obligations or the Notice of Privacy Practices, we comply with HIPAA obligations or the Notice of Privacy Practices.

3. Children Under the Age of 18 and Majority

The Services are available for use by children (under 18 years of age) but children are not authorized to become Members nor use the Services without the supervision and verifiable consent of a parent or legal guardian. If you register as the parent or legal guardian on behalf of a minor, you understand that as part the services, we will collect the Personal Data of the child. Your consent is required for the collection, use, and disclosure of the child’s information. We will not knowingly collect your child’s Personal Data without your consent to the Clinical Services and Practice Policies Agreement and by agreeing to this Privacy Policy. However, if you do not give your consent, your child may not use our services. We collect information about the child’s use of the services (as supervised and authorized by a parent or legal guardian), including information sent by the mobile device or computer used by the child (e.g., IP address, unique device identifiers, website usage information, etc.) and information sent by the mobile device(s), and location information. Any health information relating to children will be handled in accordance with our Notice of Privacy Practices. If we learn that we have collected the Personal Data of a child under 18 outside of the above circumstances, we will take steps to delete the information as soon as possible to the extent permitted by law. If you believe we might have any Personal Data from a child under the age of 18, please contact us at privacy@sollishealth.com.

If you access or use the Services, you represent and warrant that you are either at least 18 years old or otherwise have adequate authority and capacity to consent to use the Services under applicable state laws, federal laws or the authorization of a parent or legal guardian who agrees to be bound by the Terms and this Privacy Policy. If you are under 18 and lack sufficient authority to access or use the Services, do not use or provide any information on the Services.

4. Personal Data We Collect About You

We collect different types of Personal Data about you. This section is intended to describe the Personal Data that we may collect about you.

We collect the following types of Personal Data from and about Users of the Services:

• Information you provide to us, or grant us access to, when you access or use the Services;

• name, postal address, billing address, shipping address, e-mail address, mobile telephone number, insurance information, including number, photo, and other associated information, date of birth, credit or debit card number (for payment purposes only), photos of you, your medical history, and health information;

5. How We Collect Your Personal Data

We collect Personal Data:

• directly from you when you provide it to us, such as:

  • information that you provide by filling in forms on the Services (this includes information provided at the time of registering to use the Services, using Medical Groups Provider consultation services, purchasing products, reporting a problem with the Services, or requesting further services), and your User Contributions (as described in Section 8);

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

  • details of transactions you carry out through the Services and of the fulfillment of your requests (you may be required to provide financial information before placing a request through the Services).

• automatically as you navigate through the Services (information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies) – see additional detail in Section 6 below; and

• from third parties, for example, our business partners.

6. Personal Data Collected Through and Use of Automatic Data Collection Technologies

As you navigate through and interact with the 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 the Services, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to the Services, error information, clickstream data, and other communication data and the resources that you access and use on the 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 the 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 the Services according to your individual interests; or

• recognize you when you return to the Services.

The technologies we use for this automatic data collection include, among others:

• Cookies (or browser cookies) and Similar Technologies. We and our service providers may use “cookies” and other technologies to collect data that enable us to better understand and improve the usability, performance and effectiveness of our Services. For instance, we may use session cookies (which expire once you close your browser) or persistent cookies (which stay on your mobile device until you delete them) to provide you with a more personal and interactive experience on our Services. Please refer to our Cookies Policy. for more information and options to activate and deactivate certain cookies.

• Third-Party Analytics and Advertising. We use third parties’ analytic and tracking tools to better understand who is using the Services, how people are using the Services and how to improve the effectiveness of the Services and its content, and to help those third-parties serve more targeted advertising to you across the Internet or help us serve more targeted advertising to you. Those third-party companies may use cookies, pixel tags or other technologies to collect and store information such as time of visit, pages visited, time spent using the Services, device identifiers, type of operating system used and other website(s) you may have visited. Please note that these parties do not collect data revealing any information about your health or that can be used to infer health information about you when engaging in these activities. They might combine information they collect from your interaction with the Services with information they collect from other sources. We do not have access to, nor control over, third parties’ use of cookies or other tracking technologies. For more information about how to opt out of these third parties’ use of your information, please see “Choices About How We Use and Disclose Your Personal Data” below.

7. How We Use Your Personal Data

We use your Personal Data for the business purposes described below:

• provide the Services to you;

• provide products and Services to you;

• provide you with information you request from us;

• enforce our rights arising from contracts;

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

• notify you about changes;

• provide you with newsletters, advertisements, and other promotional communications (in accordance with applicable legal requirements);

• to conduct internal research, reporting, and data analytics

• to contact you in response to a request;

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

• for any other purpose with your consent;

• as required or permitted by law; and

• provide you with notices about your Account.

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 or by contacting us at privacy@sollishealth.com.

We may also combine information that we collect from you with information we obtain about you from third parties. We may aggregate and/or de-identify any information collected through the Services. We may use de-identified and/or aggregated data for any purpose, including without limitation for research and marketing purposes and to improve users’ experience on the Services, and may also disclose such data to any third parties.

8. Disclosure of Your Personal Data

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy.

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

• to 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);

• 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 Company about the Service Users are among the assets transferred;

• to fulfill the purpose for which you provide it (for example, we may disclose your personal information to a health care provider);

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

In addition, we may disclose aggregated information about our Users, and information that does not identify any individual, without restriction.

You also may provide information (hereinafter, “posted”) to other users of the 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.

9. Choices About How We Use and Disclose Your Personal Data

We offer you choices on 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 strive to provide you with choices regarding the Personal Data you provide to us. We have the following 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 the Services may then be inaccessible or not function properly.

• Promotional Offers from Company. If you do not wish to have your email address used by Company to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or by contacting us. This opt out does not apply to information provided to Company as a result of a Service purchase or your use of our Services.

• Targeted Advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Allianceand the Network Advertising Initiative websites (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.

• Online Analytics. We may use third-party web analytics services on our Services, such as those of Google Analytics. These vendors use the sort of technology previously described in Section 6 to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

We do not control the collection and use of your information collected by third parties as described in our Terms. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

10. Your Rights Regarding Your Personal Data

You can review and change your Personal Data by logging into the Services and changing your Account information. You may also contact us at privacy@sollishealth.com regarding any of your rights under applicable state laws; 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 may 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.

See state-specific sections below on your rights under specific state laws.

11. Do Not Track Signals

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. At this time, we do not honor such signals.

12. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. The safety and security of your information also depends on you. Where you have chosen a password for the use of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

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.

Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Services. 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 Services or in your operating system.

13. California Individuals.

If you are a California resident, you have rights under the California Consumer Privacy Act of 2018 (“CCPA”). Please see additional information below that is intended to satisfy our obligations under the CCPA to disclose certain information to you: (1) the purpose for which we use each category of “personal information” (as defined in the CCPA) we collect; and (2) the categories of third parties to which we (a) disclose such personal information for a business purpose, (b) “share” personal information for “cross-context behavioral advertising,” and/or (c) “sell” such personal information. Under the CCPA, “sharing” is defined as the targeting of advertising to a consumer based on that consumer’s personal information obtained from the consumer’s activity across websites, and “selling” is defined as the disclosure of personal information to third parties in exchange for monetary or other valuable consideration. Our use of third-party analytics services and online advertising services may result in the sharing of online identifiers (e.g., cookie data, IP addresses, device identifiers, and usage information) in a way that may be considered a “sale” under the CCPA. The following chart details our practices in this regard.

You have the right to opt out of our sale/sharing of your personal information for purposes of certain online analytics and advertising by visiting the link available in the footer of our Services: “Your Privacy Choices.” If you have a legally-recognized browser-based opt out preference signal turned on via your device browser, we recognize such preference in accordance with applicable law.

How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing Services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;

• To show that we treated you fairly; or

• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so by contacting us at privacy@sollishealth.com.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

To exercise your rights, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address, and account information);

• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and

• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with you request will be used solely for the purposes of verification.

15. International Users

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any information you provide to us through use of the Services may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of personal data as the one in which you reside. However, we will handle your Personal Data in accordance with this Privacy Policy regardless of where your Personal Data is stored/accessed.

16. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. If we make material changes to how we treat our Users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Services’ home page and invite you to review (and accept, if necessary) the changes. 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 email address for you and for periodically visiting the Services and reviewing this Privacy Policy to check for any changes.

17. Contact Information

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.

How to Contact Us:

If you have any questions about this Notice, please contact Sollis Health at (646) 687-7600. Our Privacy Officer is available during normal business hours to discuss your privacy questions. They can be reached at privacy@sollishealth.com.