Patient Privacy Policy

1. SCOPE AND PURPOSE:
‍This privacy policy (“Policy”) describes how Assort Health, Inc. and our, subsidiaries, and affiliated companies (“Assort”, “we”, “us”, or “our”) may collect, use, and share information about you that we obtain through our website and other websites and applications that link to this Policy (collectively, the “Sites”). This Policy also applies to any information we collect offline, or in other contexts in which we make this Policy available to you. This Policy does not apply to third party websites to which we provide links. We do not control and are not responsible for the privacy practices of the websites of other entities and we urge you to review any applicable third-party privacy policies for yourself.

‍2. WHAT DOES ASSORT DO?
‍We offer a software-as-a-service technology platform (referred to herein collectively as the “Platform”). The Platform is designed to use sophisticated machine learning algorithms and artificial intelligence capabilities to communicate with the patient and enable workflow automation with a physician or non-physician provider across voice, text and internet modalities. We process data you provide on behalf of our healthcare provider customers. Our data processing is governed by the agreements we have with our customers, which may include Business Associate Agreements as applicable and required under the Health Insurance Portability and Accountability Act (“HIPAA”). Your healthcare provider may also have its own privacy practices and/or policies that govern its collection and use of your data. We are not responsible for how your healthcare provider treats your information, and we recommend you review their privacy policies.

‍3. WHAT PERSONAL INFORMATION DO WE COLLECT?
‍Personal information is data that can be used to identify you. The types of personal information that we collect depend on your interactions with us. Over the last 12 months, we have collected personal information that generally fall into the following categories: Identifiers, such as your name, email address, or IP address. Information contained in our customer records, or that you provide, such as postal address or telephone number. Health information required to schedule an appointment. Internet or other electronic network activity information, such as how you interact with our website. The people you have scheduled appointments with.

‍4. HOW DO WE COLLECT YOUR INFORMATION?
‍We may collect information from you in the following ways: • We automatically collect your phone number if you are calling into our application. We collect information you provide to us when you enter information into fields on the Sites, share information during phone calls with Assort’s technology, sign up for or request certain services or information, or call our customer service. This information may include your name, gender, insurance information, your provider’s name, address, email address, your telephone number. If you have an account with us, we may also collect your username or other login information you use to log into or access your account. • We may also collect information from other sources, such as lead generation companies, social networks, and business partners that offer co-branded services or help us sell or distribute our products. We may also collect information from other users of our services or from available sources.
‍5. HOW DO WE USE YOUR INFORMATION?
‍We use your information:
• To schedule or modify appointments with the providers you request. You also authorize us to disclose the information you provide to us to your provider, or other providers as necessary to provide the services and keep their electronic health records up to date and accurate.
• To provide, enhance and improve our services, and our Sites’ functionality.
• To identify and authenticate you. To determine and validate whether you are an existing user.
• To enable you to use your account on more than one device. If you use multiple browsers on a single device, or use various devices (such as desktops, smartphones, and tablets), your information may be used to connect these various accounts or profiles so you can easily access your account(s) from multiple devices.
• To communicate with you. To confirm your scheduled appointments, send you emails, updates, and information relevant to our services.
• To secure our Sites and services, and for our own internal legal compliance purposes.
• To protect the personal information of our personnel, clients, guests, and the general public.
• For other purposes explained at the time of collection, or for other business purposes consistent with the context of the collection of your information. We may create, use, and share deidentified, anonymized, and aggregated data that cannot be used to identify you for any legal purpose.

‍6. HOW DO WE SHARE YOUR INFORMATION?We may disclose identifiers, commercial information, and internet activity, for commercial purposes as follows:
• With service providers and vendors that provide services to us, such as to provide analytics, manage our content, administer ads, provide insights to us related to marketing needs, for market research purposes, and to analyze our marketing efforts.
• Where you have given us your consent to share or use information about you for example to schedule an appointment with a provider;
• To provide a service that you have requested from us or from others; • As required by law or legal process to disclose information, and if required, in response to a lawful request by public authorities;
• Where we believe that it is necessary to avoid liability or violations of the law; • To protect our rights, property, life, health, security;
• To a buyer or potential buyer (and/or its agents and advisers) in connection with any sale or proposed purchase, merger, or acquisition of our business to which your information relates.
• Per your request or direction; or
• To any other person with notice to you and your consent to the disclosure. We may disclose deidentified patient information to third parties only when permissible under our contracts with our customers and in accordance with Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) requirements or other applicable law. 

‍7. RETENTION AND PROTECTION OF DATA
‍We protect your information using administrative, physical, and technical safeguards. When we collect sensitive information, we encrypt the collection and transmission. However, we cannot guarantee the information we collect will be 100% secure. We retain information for varying time periods depending on the reason we collect and use the information. We retain information the minimum amount of time required for our purposes, unless a longer time is required by law. There may be technical or other operational reasons where we are unable to delete or de-identify your information. If this happens, we will take commercially reasonable measures to prevent further use or disclosure your information.

‍8. STATE CONSUMER PRIVACY RIGHTS
‍Rights for Residents of states with state specific legislation. If you are a resident of a state with its own specific consumer privacy legislation, you may have the following rights:
• To confirm if we process your personal information.
• To access your personal information.
• To correct inaccuracies in your personal information.
• To delete your personal information.
• To receive a copy of your personal information.
• To opt out of the sale or sharing of your personal information.
• To opt out of the processing of your personal information for purposes of (i) targeted advertising or (ii) automated decision-making or profiling in furtherance of decisions that produce a legal or similarly significant effect on you.

If you live in a state that requires specific consent prior to processing your sensitive personal information, we will obtain the required consent and you may withdraw your consent at any time. Residents of applicable states may exercise the above rights by:
• Submitting a request to info@assorthealth.com
• Calling us at 651-285-3335 We may ask you to provide us with information to verify your identity before responding to your request. We will consider all requests and provide our response within the time required by applicable law. Some information may be exempt from state specific requests. If we deny your request, you may have the right to appeal the decision. If we deny your request and you have the right to appeal we will provide you with information regarding the appeals process.
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‍California Resident Privacy Notice
Below are the information categories we may have collected about you in the last twelve (12) months, the purposes for the collection, and the third parties with whom your personal information may have been disclosed, or shared. For more information on these practices, please see Sections III-VI.

If you are a California resident, you may have you may have the following rights with respect to the personal information we process about you:
• To request information about the categories of personal information we have collected about you, the categories of sources from which we collected the personal information, the purposes for collecting or sharing the personal information, the categories of third parties with whom we have shared or sold your personal information, and the specific pieces of personal information we have collected about you.
• To request that we delete personal information that we have collected from you. • To request that we correct inaccurate personal information that we maintain about you.
• To opt out of the sale or sharing of your personal information. California residents may exercise the above rights by:
• Submitting a request to info@assorthealth.com
• Calling us at 651-285-3335 Only you, or someone you legally authorize, may make a consumer request regarding your personal information. You may also make a verifiable consumer request on behalf of your minor child. You may be required to verify your identity before we respond to your request. We may require you to use your email address to verify your identity. We will consider all requests and provide our response within the time required by law. Certain information may be exempt from your requests. If we deny your request we will provide you with information explaining the appeals process. You may only make a consumer request for access or data portability twice within a 12-month period. We will not discriminate against you for exercising any of your rights.

Response Timing and Format
We intend to respond to a consumer request within forty-five (45) days of receipt. If we require more time we will notify you in writing. Any disclosures we provide will only cover the 12-month period preceding the consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. Other California Privacy Rights California's ”Shine the Light” law (Civil Code Section § 1798.83) permits users of our Sites that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes in particular: Customers who are residents of California may request (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To make this request, please email us at info@assorthealth.com or call us at (213) 286-1410. We may require additional information from you to allow us to verify your identity and we are only required to respond to requests once during any calendar year.
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‍9. MINORS
‍The Sites are intended for a general audience and are not intended for minors under the age of eighteen (18). We do not want to obtain any information from or about minors through our Sites. If you are under eighteen (18) years old, do not use the Sites. We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) about children under the age of 13. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us by email at info@assorthealth.com or calling us at 651-285-3335 We do not knowingly “sell,” as that term is defined under the CCPA, the personal information of minors under 16 years old who are California residents.

‍10. INTERNATIONAL TRANSFER
‍We are based in the U.S. and the information we collect is governed by U.S. law. If you are accessing the Sites from outside of the U.S., please be aware that information collected through the Sites may be transferred to, processed, stored, and used in the U.S. and other jurisdictions. Data protection laws in the U.S. and other jurisdictions may be different from those of your country of residence. Your use of the Sites or provision of any information therefore constitutes your consent to the transfer to and from, processing, usage, sharing, and storage of information about you in the U.S. and other jurisdictions as set out in this Policy.

‍11. UPDATES TO THIS PRIVACY POLICY
‍We reserve the right to make updates and revisions to this Policy at our discretion and at any time. When we make changes to this Policy, we will post the updated notice on https://www.assorthealth.com/ and update the effective date. Any changes will be effective as of the “Effective” date. Your continued use of our Sites following the posting of changes constitutes your acceptance of such changes.