Privacy Policy

Effective Date: August 21, 2024

QHLTH, Inc. and our affiliates and subsidiaries (collectively, “QHLTH”, “we”, “us”, or “our”), operate the QHLTH software-as-a-service platform and related mobile or web-based applications (collectively, the “Platform”), which is designed to facilitate communications between health care providers, QHLTH clinical support teams, and patients and their caregivers. This Privacy Policy is meant to inform you about how QHLTH collects, uses, shares, and otherwise processes the Personal Information (as defined below) we collect about you when you access or use the Platform.

Please read this Privacy Policy carefully before using the services offered through the Platform (the “Services”) or submitting your Personal Information to us. From time to time, we may supplement this Privacy Policy with additional information about our privacy practices related to the Platform or Services.

If you use the Platform as a patient of a health care provider, then we may collect protected health information (“PHI”) about you, on your health care provider’s behalf, that is regulated by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations (collectively, “HIPAA”). Where this is the case, we act as a “business associate” of your health care provider, and your health care provider’s HIPAA Notice of Privacy Practices and our agreements with your health care provider govern the use and disclosure of your PHI, not this Privacy Policy. If you have any questions about the use and disclosure of your PHI, then please contact your health care provider.

What Personal Information We Collect

When you access, use, or interact with the Platform, we may collect certain Personal Information directly from you or automatically from the devices you use to access the Platform. “Personal Information” is information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your household.

Depending on how you use the Services, we may collect the following types of Personal Information from or about you:

• Direct identifiers, such as your first and last name, address, email address, and phone number;
• Demographic information, such as your age, sex, gender, race, marital status, and date of birth;
• Geolocation data, which is based on your IP address and other information made available through your device, depending on your device settings;
• User account information, such as the username and password associated with your Platform user account;
• Usage and other electronic activity information, such as information about how you access and interact with the Platform, your IP address, and information about the device and web browser you use to access the Platform;
• Other information you may provide when you create a Platform user account or use the Services.

We also may collect sensitive information, such as information about your health and medical conditions.

Sources of Personal Information

Depending on how you use the Platform and Services, we may collect your Personal Information from the following sources:

• Directly from you, such as when you register for a Platform user account, upload or submit content to the Platform, and otherwise use the Services;
• Through the use of cookies and other data collection technologies that we have installed on the Platform. For more information on our use of cookies and similar technologies, please review the “Cookies and Data Collection Technologies” section below; and
• From third parties with your consent, according to your instructions, or as permitted by applicable law.

How We Use Your Personal Information

Depending on how you use the Platform and Services, we may use your Personal Information as outlined below:

• Provide the Services. We may use your Personal Information to validate and complete your Platform user account registration; provide, maintain, and improve the Platform and Services; respond to your questions and comments; and send you communications about the Platform and Services.
• Build and maintain our relationship with you. We may use your Personal Information to send you messages about the Services or other products and services that may be of interest to you, conduct surveys, and obtain and respond to your feedback, questions, and comments. We may also draw inferences from the Personal Information we receive about you, such as information about your preferences, characteristics, and interest in the Services.
• Improve the Services. We may use your Personal Information to facilitate the operation of the Platform and Services; conduct internal research and development designed to improve the Platform and Services or develop new Services, including testing and training any artificial intelligence/machine learning models we use to deliver certain Services; assess user engagement with the Services; perform market research and analysis; analyze how the Services are being used and accessed; improve the functionality of the Platform and your user experience; conduct quality assurance activities, and perform internal business reviews.
• Create de-identified information. We may use your Personal Information to create de-identified information, which we may use to provide and maintain the Platform and Services; conduct internal research and development designed to improve the Platform and Services or develop new Services, including testing and training any artificial intelligence/machine learning models we use to deliver certain Services; or for other purposes permitted by applicable law.
• Maintain the security of the Platform. We may use your Personal Information to maintain the security and integrity of the Platform, detect security incidents, protect the Platform against fraudulent and illegal activity, and enforce our terms of use.
• Comply with legal obligations and respond to legal proceedings. We may use your Personal Information to comply with our legal obligations, including maintaining records of our compliance with federal and state law requirements. We may also use your Personal Information to establish, exercise, or defend legal claims.

We may also use your information for other purposes consistent with the context of the collection of your Personal Information, as otherwise disclosed to you at the time your Personal Information is collected, or with your consent.

How We Disclose Your Personal Information

Depending on how you use the Platform and Services, we may disclose your Personal Information as outlined below:

• Amongst our corporate family. We may disclose your Personal Information to our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership.
• Our service providers. We may disclose your Personal Information to service providers and vendors that perform tasks on our behalf, such as marketing and analytics activities and the operation and maintenance of the Platform.
• Business partners. We may disclose your Personal Information to our third-party business partners, such as health care providers or other collaborators.
• Public and governmental authorities. We may disclose your Personal Information to entities that regulate or have jurisdiction over QHLTH, such as regulatory authorities, law enforcement, public bodies, and judicial bodies.
• Business transfers.We may share your Personal Information in relation to a merger, sale, acquisition, divesture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control (whether in whole or in part).
• Legal obligations. We may share your Personal Information, if reasonable and necessary, to (i) comply with legal processes or enforceable governmental requests, or as otherwise required by law; (ii) cooperate with third parties in investigating acts or omissions that violate this Privacy Policy or our terms of use; or (iii) bring legal action against someone who may be violating our terms of use or who may be causing intentional or unintentional injury or interference to the rights or property of QHLTH or any third party, including other users of the Services.
• Other third parties. We may share your Personal Information with other third parties as permitted by applicable law or with your consent.

We do not disclose your sensitive information to third parties except as required by law, in accordance with your consent/authorization, or as needed to provide and improve our Services.

Text Messaging and Mobile Information

We do not share mobile information, including phone numbers, with third parties or affiliates for marketing or promotional purposes. All text messaging originator opt-in data and consent are excluded from sharing with any third parties.

Text Messaging Terms and Conditions: Message frequency varies per user. Message and data rates may apply. Text HELP for help. Text STOP to unsubscribe. Carriers are not liable for delayed or undelivered messages.

Cookies and Other Data Collection Technologies

We may use “cookies” and other data collection technologies to collect certain information about you on the Platform. Cookies are small data files that are sent to a web browser and stored on a device. Cookies are commonly used by website operators to store information about website visitors and allow website operators to authenticate visitors, recognize visitors, save visitors’ preferences, and analyze the use of a website.

We may partner with certain third parties to collect and analyze information about your use of the Platform and the Services through cookies and other data collection technologies. This information helps us troubleshoot Platform malfunctions and improve accessibility and usability of certain Platform features and the Services. For example, we use Google Analytics to help us improve our Services, performance and user experiences. Google Analytics may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners. You may prevent Google Analytics from recognizing you on our website by deleting or disabling the relevant cookies.

To learn more about cookies and similar technologies, please visit www.allaboutcookies.org. Most web and mobile device browsers automatically accept cookies. If you prefer, you can change your browser to prevent that or to notify you each time a cookie is set. You may also choose to opt out of receiving interest-based advertising by visiting the Network Advertising Initiative’s Opt-Out Tool.

Opting Out of Communications

We may communicate with you by email or through Platform messages, telephone, or SMS text message about the Platform or Services. If you have opted in or otherwise qualify to receive these forms of communication, and no longer wish to receive such communications, you may opt-out or unsubscribe by following the instructions that are included in the communication or discontinuing your use of the Platform. For more information, please contact us using the information provided in the Contact Us section below.

Retention of Your Personal Information

As a general matter, we may keep your Personal Information for as long as necessary to fulfill the purpose for which it was collected. If a law requires us to retain your Personal Information for a longer period of time, we will comply with that law. We may also retain your Personal Information as necessary to protect our legal rights.

Security of Your Information

We maintain administrative, technical, and physical safeguards designed to protect against unauthorized access, use, modification, and disclosure of your Personal Information in our custody and control. No data, on the Internet or otherwise, can be guaranteed to be 100% secure. While we strive to protect your information from unauthorized access, use, or disclosure, QHLTH cannot and does not ensure or warrant the security of your information.

Do Not Track

Some web browsers have “Do Not Track” or similar features that allow visitors to tell each website they visit that they do not want their activities on that website tracked. At present, the Platform does not respond to “Do Not Track” signals.

Children’s Privacy

QHLTH does not knowingly collect Personal Information from children under the age of 18 through the Platform. If you believe a child under 18 years of age has provided us with Personal Information, please contact us at the information provided in the Contact Us section below with a brief description of your concern.

Information for Users Located Outside of the United States

If you use or access the Platform and its Services or provide us your information from outside the United States, your Personal Information will be transferred to, stored and processed in the United States and other countries where QHLTH or its service providers operate in accordance with this Privacy Policy and applicable laws. Please note that data protection and consumer protection laws of the United States and such other countries may differ from the data protection or consumer protection laws in your country. By using or accessing the Platform and its Services or providing us with your Personal Information, you understand that your information will be collected from and processed in the United States and other countries where QHLTH or its service providers operate, and acknowledge that your Personal Information may be subject to access by law enforcement and other government entities, including courts and tribunals, in accordance with laws applicable in those jurisdictions.

To inquire about exercising any of the rights listed above, please contact us using the information provided in the Contact Us section below.

Notice to Nevada Residents

If you are a Nevada resident, you have the right to opt out of the sale of certain Personal Information, including your name and mailing address, to third parties. QHLTH does not sell your Personal Information. If that were to change in the future, we will provide Nevada residents with a method to opt-out of those transactions.

Third-Party Links

The Platform may contain links to other websites that we do not own or control. If you visit a third-party website, we encourage you to review that website’s privacy policy to understand how that website operator will treat your information. Our Privacy Policy does not apply to these third-party websites.

Changes to this Privacy Policy