SSV Holdings

Privacy Policy, & Disclaimer

Disclaimer 

• SummaUp IS NOT INTENDED FOR USE DURING AN EMERGENCY. IF THIS IS AN EMERGENCY, SEEK IMMEDIATE IN-PERSON MEDICAL ATTENTION OR CALL 911.

• SummaUp may send you email or text message (including SMS) correspondence containing details of your treatment, provided you consent to such communications. Note that your carrier may charge fees for certain types of communications, and SummaUp is not responsible for any such fees.

• SummaUp will never request that you send us an email or text message containing any protected health or payment information, nor you should you voluntarily send it via those means.

• SummaUp's medical providers do not provide comprehensive medical services or screening aside from the listed services.

• SummaUp does not replace your existing relationship with your primary care provider or other in-person health care providers.

• SummaUp is not an insurance product.

• SummaUp operates subject to state regulations and may not be available in certain states, including your state of residence.

• SummaUp does not guarantee that a prescription will be written.

• SummaUp medical providers may refuse to prescribe specific DEA controlled substances, such as those containing opioids or amphetamines.

• SummaUp medical providers reserve the right to deny treatment if they believe a patient may be better served by an in-person provider, or for any other reason according to their professional judgment.

• SummaUp provides technological and other services to connect patients to licensed medical providers.

• SSV Holdings, LLC does not provide any medical services; medical services are provided by licensed medical providers of the Summa Up, LLC. and the members of a Affiliated Covered Entity, subject to change at any time.

SummaUp Privacy Policy

This Privacy Policy (“Privacy Policy”) is incorporated into our Terms of Use and Terms of Service, as applicable. Therefore, terms used in this Privacy Policy that have been previously defined will have the same meanings as provided in our Terms of Use or Terms of Service, as applicable. As with our Terms of Use and Terms of Service, if we make any changes to our Privacy Policy, we will post the revised Privacy Policy to the Site and update the “Last Revised” date of the Privacy Policy. Your use of our Site or Service following any such change means you accept the revised Privacy Policy.

We are committed to respecting the privacy of users of our Site and Service. We created this Privacy Policy to tell you how SummaUp collects, uses and discloses information in order to provide you with our Site or Service, as applicable.

By accessing or using our Site or Service, you accept the practices and policies outlined in this Privacy Policy, and you hereby consent that we will collect, use and disclose your information as set forth in this Privacy Policy. If you are using our Site or Service on behalf of an individual other than yourself, you represent that you are authorized by such individual to accept this Privacy Policy on such individual’s behalf. By agreeing to our Privacy Statement and Terms of Use and Terms of Service, you consent to the storing and processing of your information in the USA and countries outside of the country you live in.

WHAT INFORMATION DO WE COLLECT?

In general, you can visit the Site without telling us who you are or revealing any personally identifiable information about yourself. However, you should be aware that sections of the Service (including restricted portions of the Site) allow for the submission of and collection through use of the Service of personally identifiable information, including, but not limited to: (1) your name and contact data (such as your e-mail address, phone number, and billing and physical addresses); (2) your login and password; (3) demographic and health and wellness data (such as your gender, date of birth, wellness background, weight, height, lifestyle information, medication history, and zip code); (4) your communications with Practitioners conducted through the Service; and (5) any information you provide when you contact or communicate with us (credit card data). We may also collect information from you necessary to provide you with services you request from Practitioners utilizing the Service, which may include, but is not limited to: (a) payment information; (b) insurance information; and (c) health and medical data (such as previous doctors or other healthcare providers you visited, your reason for visiting a healthcare provider, date of visit, medical history and condition, medications, images or videos and other medical and health information you share with us).

To protect your security and privacy, we require that you or your legal representative (as opposed to a third party on your behalf) enter the personally identifiable information that we collect and that the information be current. SummaUp disclaims any legal duty to verify the accuracy of any personally identifiable information that you provide beyond what may be required by law for the particular purpose for which the information is to be used.

In addition to the information we collect directly from you, we may also collect certain information from the Practitioners who provide treatment or other services to you in connection with our Service. This information may include, but is not limited to, a Practitioner’s diagnoses, treatment plans (including prescription details) and notes. We may also receive information from third parties that pay for your care or provide you with treatment, laboratory care or prescription medication, which may include, for example, your prescription history, insurance policy, insurance eligibility and coverage, and laboratory test results.

We may automatically collect certain information from your device through which you access our Service. This information includes, but is not limited to, your language preferences, your phone number or other unique device identifier (the International Mobile Equipment Identity or the Mobile Equipment ID number), the IP address of your device, the manufacturer, model and operating system of your device, the name and version of our Service you are using, information regarding your browser and information that allows us to personalize our Service. We or our service providers may also collect information about how you interact with our Service and any of our websites to which our Service links, such as how many times you use a specific part of our Service, the amount of time you spend using our Service, how often you use our Service, actions you take in our Service and how you engage with our Service. For more details about this type of data collection, please refer to the section below on cookies and web beacons.

We will obtain information regarding your location or the location of your device through which you access our Service. Information regarding your location will be obtained directly from you when you provide us with your zip code. Alternatively, our Service may obtain precise information about the location of your device with your express consent. Once you have consented to the collection of the precise location of your device, you may adjust this consent by managing your location services preferences through the settings of your device.

We collect information you provide to us, for example when you create or modify your account, register to use our Site, purchase products or services from us, request information from us, contact customer support, or otherwise communicate with us. This information may include your: name; home and work address; billing address; shipping address; email address; telephone number; pictures that you upload or share with us, credit card or debit card number (solely for payment purposes); insurance card number and other information; date of birth; driver’s license or other government identification number; health information and medical history; sexual orientation or preferences; and other information you choose to submit to us. ##Cookies; Information We Collect Automatically Through Your Use of our Site Google Analytics and Similar Services We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of the Site. Google Analytics uses “cookies”, which are text files placed on your computer, to help the Site analyze how users use the site. You can find out more about how Google uses data when you visit our Site by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). We also use a similar service to Google Analytics called Amplitude, whose privacy policy can be found here https://amplitude.com/privacy. Separately, 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 how your online activity. 

Information Collected Through Cookies and Similar Technologies 

We and our service providers use cookies, web beacons, and other technologies to receive and store certain types of information whenever you interact with our Site through your computer or mobile device. A cookie is a small file containing a string of characters that is sent to your computer when you visit a website. When you visit the Site again, the cookie allows the Site to recognize your browser. Cookies may store unique identifiers, user preferences and other information. You can reset your browser to refuse all cookies or to indicate when a cookie is being sent. However, some Site features or services may not function properly without cookies. We use cookies to improve the quality of our service, including for storing user preferences, tracking user trends, and improving the quality of our Site and services.

Restrictions on Gathering Information from People Under Age 21 The Site and the services provided through the Site are only for users of the age of 21 or older. If you are under the age of 21, please do not attempt to register with us at this Site or provide any personal information about yourself to us at any time. If you are under the age of 21 and wish to create an account with SummaUp(“Account”), your parent or legal guardian must create the Account, submit your personal information, and agree to the Terms of Use and this Privacy Policy on your behalf. If we learn that we have collected personal information from someone under the age of 21, we will promptly delete that information. If you believe we have collected personal information from someone under the age of 18, please email us at support@summaup.com or call us at (415) 891-1090

HOW DO WE USE YOUR INFORMATION?

In connection with providing you with our Service, we and our affiliates may use, compile, analyze and save, your information for a number of purposes, including, but not limited to: (a) verifying your identity and administering your account, including processing your payments and fulfilling your orders; (b) communicating with you about our Service or your use of our Service, and sending you communications on behalf of the Practitioners; (c) ensuring quality customer service by providing you customer support, responding to your requests or concerns, ensuring that our Service functions properly for you, and tailoring our Service to meet your needs; (d) as applicable, facilitating the provision of healthcare services to you by a Practitioners, and ensuring the Practitioners the services and support necessary for health care operations; (e) sending you push notifications (notifications may be enabled or disabled through your device or app settings depending on your device type); and (f) detecting, preventing, investigating and responding to fraud, intellectual property infringement, violations of our Terms of Use, Terms of Service, or other misuse of our Service or a Practitioner’s services.

We use information regarding your location or the location of your device through which you access our Service for a number of purposes, including, but not limited to: (a) identifying Practitioners who may provide you with healthcare services; (b) providing you with a list of nearby pharmacies that may fulfill any prescriptions provided to you by your Practitioner; and (c) identifying other healthcare providers whom you may visit at the recommendation of your Practitioner.

HOW DO WE DISCLOSE YOUR INFORMATION?

We may disclose your information to third parties in connection with the provision of our Service or as otherwise permitted or required by law. For example, we may disclose your information to: (a) our third-party service providers that provide services such as the hosting of our Service, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing and other similar services; (b) Practitioners to schedule and fulfill appointments and provide health care services as part of the Service; (c) Practitioners to whom you send messages through our Service; (d) Practitioners for other treatment, payment or healthcare operations purposes upon your request; (e) third parties as we believe necessary or appropriate to comply with applicable laws; and (f) to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock. With respect to transfers to third party agents of SummaUp under the Privacy Shield, the Privacy Shield requires that SummaUp remain liable should those agents process your information in a manner inconsistent with the Privacy Shield Principles. There may also be instances where SummaUp may be required to share your information with third parties who have not been retained by SummaUp, during inspections or audits, in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, or as ordered or directed by courts or other governmental agencies. Many entities receiving your information under these conditions have privacy requirements that apply to their handling of your information.

SummaUp will not disclose your information to third parties for their own separate use unless you have consented to such sharing. However, we may share the information about you that you provide to us with other companies collecting and using the information you provide to us to better understand the offers, promotions, health and wellness benefits, insurance trends, employer related trends, and types of advertising that are most appealing to our customers. After the information is collected by these third parties, it is aggregated so it is not personally identifiable or tied to you or any other user. We also offer you the ability to choose (opt-out) whether your information is (a) to be disclosed to a non-agent third party or (b) to be used for a purpose that is incompatible with the purpose(s) for which it was originally collected or subsequently authorized by you. For sensitive information (i.e. personal information specifying medical or health conditions, racial or ethnic origin; etc.), you are given affirmative or explicit (opt in) choice if the information is to be disclosed to a third party or used for a purpose other than those for which it was originally collected or subsequently authorized by you through the exercise of opt in choice. 

We may also collect and group demographic and preferences information, responses to surveys and other personally identifiable information that we collect from you into an aggregate, nonpersonally identifiable form for disclosure to our existing or potential business partners, affiliates, sponsors, regulators as part of further product development, including as part of a pre-market submission with the FDA, or other third parties. However, please be assured that this aggregate data will in no way personally identify you or any other parties participating in the Service.

When you submit personally identifiable information to us as part of the Service, you may be given an opportunity to opt in to receiving additional information from or on behalf of SummaUp and/or selected third parties. If you opt in, you may be added to our list of Secure Users who will receive additional features, promotional and marketing communications from us, our partners and/or other third parties. If you initially opt in to receiving such communications and you later decide that you no longer want to receive them, you may opt out of receiving promotional and marketing communications from us and/or our partners and other third parties by contacting us at support@summaup.com. If you discontinue your use of the Service for a period of ninety days or more we may require you to re-register or otherwise stop communicating with you electronically.

Further, in the event that your access to the Site and use of the Services are offered in connection with a program offered or supported by your employer, we may disclose certain group health results with your employer, provided that this group health information is aggregated and not personally identifiable.

HOW DO WE STORE INFORMATION?

SummaUp will store archives of information subject to this Privacy Policy from Secure Users for no less than the required legal period, but may retain some or all of the information indefinitely in SummaUp’s sole discretion.

SECURITY OF YOUR INFORMATION

We use industry standard physical, technical and administrative security measures and safeguards to protect the confidentiality and security of your personal information. However, since the Internet is not a 100% secure environment, we cannot guarantee, ensure, or warrant the security of any information you transmit to us. There is no guarantee that information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. It is your responsibility to protect the security of your login information. Please note that certain emails and other communications you send to us through our Site may not be encrypted, and we strongly advise you not to communicate any confidential information through these means.

CAN YOU REQUEST A COPY OF INFORMATION SUBJECT TO THIS PRIVACY POLICY?

With respect to all active Secure Users of the Services, upon the detailed and reasonable written request of an active Secure User and the payment of any applicable fees SummaUp may charge to copy and distribute materials, SummaUp shall make copies of information subject to this Privacy Policy and identifying the requesting Secure User maintained by SummaUp to such Secure User within a reasonable time of the request.

USE BY MINORS

Our Service is intended for use by individuals 18 years of age or older. However, if you are a parent, legal guardian or personal representative of a minor child at least 13 years of age, you may, in compliance with the Terms of Service use our Service on behalf of such minor child. Any information you provide us on behalf of your minor child will be treated in accordance with this Privacy Policy. We do not knowingly collect information for individuals under the age of 13. If we learn that we have received any information for an individual under the age of 13, we will only use that information to respond directly to that child (or a parent, legal guardian or personal representative) to inform him or her that he or she cannot use our Service, and subsequently we will delete that information from our own servers.

THIRD PARTIES

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices, including data privacy and security processes and standards of any third parties, including Practitioners, the manufacturer of your mobile device, and any other third party mobile application or website to which our Service may contain a link. These third parties may at times gather information from or about you. We have no control over the privacy practices of these third parties. We encourage you to review the Notice of Privacy Practices of each Practitioner who provides you with services and the privacy policies of each website and application you visit and use.

Even though SummaUp is not a “covered entity” as defined in HIPAA, any Practitioner engaging through our Service may be a “covered entity” and therefore subject to the provisions of HIPAA from time to time. If a Practitioner has adopted a HIPAA Notice of Privacy Practices, it will describe how your Practitioner uses and discloses your protected health information (“PHI”). SummaUp has agreed that its collection, use and disclosure of your PHI on behalf of your Practitioner will be done consistent with your Practitioner’s HIPAA Notice of Privacy Practices except to the extent you have expressly authorized additional uses and disclosures.

COOKIES AND WEB BEACONS

Please note that we may use “cookies”—a small data file that we transfer to your computer’s hard drive—to collect certain information about you and your use of our Service, such as IP addresses (the Internet access of a computer), domain names, and the type of computer, smart phone device, and operating system being used. We may also use cookies to identify your computer or smart phone device when you revisit our Service to, for example, recall your authentication information or to track statistical information related to navigation throughout the Site or App, as applicable. We may use both “session” cookies and “persistent” cookies in order to better operate the Service to enhance your experience while using the Service. A session cookie enables certain features of the Service and is deleted from your computer or smart phone device, as applicable, when you disconnect from or leave the Site or App. If a portion of the Service requires a password, you are giving us explicit permission to use a persistent cookie, which is a small data file that is generated when, as a registered user of the Service, you enter your assigned user ID and password to access the password-protected area of the Service. This file is stored on your computer or smart phone device. You may adjust your browser to refuse to accept cookies, remove cookies or notify you when a cookie is set by editing your web browser preferences or options. (Each browser is different, so check the “Help” menu on your browser to learn how to change your cookie preferences.) You do not have to accept all cookies sent to you by the Service; however, depending on the particular cookie you reject, you may not be able to use some features of the Service or some features may not function properly.

Please note that linked third-party websites may also use cookies. We cannot control the use of cookies by these third-party websites. For example, when you link from the Service to a third-party website, that website may have the ability to recognize that you have come from our Service by using cookies. If you have any questions about how third-party websites use cookies, you should contact such third parties directly.

We may also employ software technology known as “web beacons” or “clear GIFs,” which helps us keep track of what content on our Service is effective. Web beacons are small graphics with a unique identifier that are used to track the online movements of Internet users. Web beacons are embedded in the web pages you review, so they are not stored on your hard drive. The web beacons we may use will not track or collect any personally identifiable information about you and they are in no way linked to your personally identifiable information.

SECURITY OF INFORMATION AND DISCLOSURES

SummaUp uses industry standard security measures to safeguard information concerning, and submitted by, users like you. Despite the security measures employed by SummaUp, you should be aware that it is impossible to guarantee absolute security with respect to information sent through the Internet or as part of a mobile application.

SummaUp will, to the extent possible, control your personally identifiable information, and, except as otherwise set forth in this Privacy Policy, we will not disclose your personally identifiable information to third parties. Although we are committed to maintaining the confidentiality of your personally identifiable information, if required by law, we reserve the right to disclose such information without first obtaining your consent.

We strive to use reasonable physical, technical and administrative measures to protect information under our control. However, you must keep your password secure and your account confidential, and you are responsible for any and all use of your account. If you have reason to believe that the security of your account has been compromised, please notify us immediately in accordance with the “Contacting Us” section below.

When using our Service, you may choose not to provide us with certain information, but this may limit the features you are able to use. You may also choose to opt out of receiving certain communications (e.g., newsletters, promotions) by emailing us your preference. Please note that even if you opt out, we may still send you service-related communications.

Please read this Privacy Policy carefully.  By accessing or using the Websites and Apps, you accept the practices and policies outlined in this Privacy Policy and you hereby consent that we will collect, use, and disclose your information as set forth in this Privacy Policy.  If any term in this Privacy Policy is unacceptable to you, please do not use the Websites or Apps or provide any personal information. This Privacy Policy may change from time to time (see Revisions to Our Privacy Policy) and your use of the Websites and Apps after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We collect several types of information from and about users of our Websites and Apps, including information:

·         by which you may be personally identified, such as name, e-mail address, telephone number, country, or any other information collection on the Websites or Apps that is defined as personal data or personally identifiable information under an applicable law (“personal information”);

·         that is about you but individually does not identify you, such as whether you are a current user, product interests, or information related to your inquiry or request;

·         about your internet connection, the equipment you use to access our Websites or Apps, and usage details; and/or

·         about your medical condition, treatment options, physician referrals, prescriptions, and lab results, including protected health information (“PHI”) or other related health information.

We collect this information:

·         Directly from you when you provide it to us.

·         Automatically as you navigate through the Websites.  Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.

·         From third parties intermediaries, for example, the physicians, medical professionals, and pharmacies with whom we partner to provide you with services.

Information You Give to Us.  The information we collect on or through our Websites or Apps may include:

·         Information that you provide on our Websites or Apps.  This includes information provided when you sign up for our Services; when we process or respond to your inquiries related to requests for treatment, payment, customer service; and when you provide feedback on our Websites or Apps.

·         Your responses to questions that we might ask you to complete for research purposes.

·         Details of transactions you carry out through our Websites and Apps and of the fulfillment of your inquiries or requests.

·         Your search queries on the Websites.

Information We Collect About You.  As with many other websites and mobile applications, as you navigate through and interact with our Websites or Apps, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

·         Details of your visits to our Websites or Apps, including traffic data, location data, logs, language, date and time of access, frequency, and other communication data and the resources that you access and use on the Websites or Apps.

·         Information about your computer and internet connection, including your IP address, operating system, host domain, and browser type.

·         Details of referring websites (URL). We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking).

The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information you provide to us or that we collect in other ways or receive from third parties.  It helps us to improve our Websites or Apps and to deliver a better and more personalized service, including by enabling us to:

·         Estimate our audience size and usage patterns.

·         Store information about your preferences, allowing us to customize our Websites or Apps according to your individual interests.

·         Speed up your searches.

·         Recognize you when you return to our Websites or Apps.

Cookies Used on the Websites.  Our Websites and Apps use two types of cookies: single-session (temporary) and multi-session (persistent).  Temporary cookies last only as long as your web browser is open, and are used for technical purposes such as enabling better navigation through our Websites or Apps.  Once you close your browser, the cookie disappears. Persistent cookies are stored on your computer for longer periods and are used for purposes including tracking the number of unique visitors to our Websites and information such as the number of views a page gets, how much time a user spends on a page, and other pertinent web statistics.  Cookies, by themselves, will not be used by SummaUp to disclose your individual identity. This information identifies your browser, but not you, to our servers when you visit the Websites or Apps. We do not respond to ‘do not track’ signals in your browser. We may also collect data by using “pixel tags,” “web beacons,” “clear GIFs,” or similar means (collectively, “pixel tags”) that allow us to know when you visit our Websites or Apps.  Through pixel tags, we obtain non-personal information or aggregate information that can be used to enhance your online experience and understand traffic patterns.

Information We Receive From Other Sources.  This is information we receive about you if you use any of the other websites we operate or the other Services we provide. We are working closely with third parties (including, for example, third parties intermediaries, such as the physicians, medical professionals, and pharmacies with whom we partner to provide you with services, sub-contractors in technical, advertising networks, analytics providers, and search information providers).

HOW WE USE YOUR INFORMATION

In connection with providing you with the Websites, Apps, and Services, we may use, compile, analyze, and save your information in the following ways:

·         To carry out the Services and, as applicable, facilitate the provision of health care services to you by physician or other health care provider and ensure that the physicians or health care providers have the services and support necessary for health care operations.

·         To communicate with you about the Websites, Apps, and Services, or your use of the Websites, Apps, and Services, and send you communications on behalf of physicians or other health care providers utilizing the Services to meet your needs.

·         To provide you with information that you have requested or to respond to your inquiries.

·         To provide you with technical support and to improve our Websites, Apps, and Services.

·         To verify your identity and administer your account, including processing your payments and fulfilling your orders.

·         In order to ensure that content from our Websites and Apps is presented in the most effective manner for you and for your computer or mobile phone, to allow you to participate in interactive features of our Services (when you choose to do so), and as part of our efforts to keep our Websites and Apps safe and secure.

·         To communicate with you about our products and Services and those of our subsidiaries, affiliates, and parent companies and any of their related businesses and those of our third-party partners.

·         To measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you.

·         In the event of a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation, we may transfer, sell, or assign to third parties information concerning your relationship with us, including, without limitation, personal information that you provide and other information concerning your relationship with us.

·         To notify you about changes to our Websites, Apps, or Services.

·         For any purpose where you have given your consent (where legally required).

·         To comply with applicable federal and state law.

Information We Receive From Other Sources.  We will combine information we receive from other sources with information you give to us and information we collect about you.  We will use this information and the combined information for the purposes set out above (depending on the types of information we receive).

DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated, de-identified information about our users, and information that does not identify any individual, without restriction.

We may disclose your personal information to third parties in connection with the provision of our Services or as otherwise permitted or required by law.  You agree that we have the right to disclose personal information that we collect or you provide as described in this Privacy Policy, including:

·         To any member of our group, which means our subsidiaries and affiliates, including our ultimate holding company and its subsidiaries.

·         To health care providers (i) to schedule and fulfill appointments and provide health care services as part of the Services, (ii) to whom you send messages through our Services, and (iii) for other treatment, payment or health care operations purposes, including pharmacy services, upon your request.

·         To health care organizations, pharmacies, contractors, service providers, and other third parties we use to support our business or in connection with the administration and support of the Services.

·         To our third party service providers that provide services such as the hosting our Websites or Apps, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing, and other similar services.

·         To any third parties we believe necessary or appropriate to comply with applicable laws.

·         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 SummaUp’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by SummaUp about our Website or App users is among the assets transferred.

·         To fulfill the purpose for which you provide it.  For example, if you email us asking us to contact a third party (including a medical professional), we may transmit the contents of your email to the recipient.

·         For any other purpose disclosed by us when you provide the information or with your consent.

·         If we are under a duty to disclose or share your personal information to comply with any legal obligation, or in order to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes; or to protect the rights, property, or safety of SummaUp, our customers, or others.  This may include exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information.

Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.  If you disable or refuse cookies, please note that some parts of the Websites or Apps may then be inaccessible or not function properly.

Do Not Track.  We do not currently respond to “do not track” signals as we do not track our customers across third party websites.

Promotional Offers from SummaUp. If you do not wish to have your contact information used by SummaUp to promote our own products or Services, you can check certain boxes on the forms we use to collect your data.  You can also always exercise your right to ask us not to process your personal information for marketing purposes by contacting us at the address below. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions.

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.

ACCESSING, CORRECTING & DELETING YOUR INFORMATION

You may contact us at the address below—or by emailing support@summaup.com—to request access to, correct, or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. If SummaUp deletes your user account, medical providers and other affiliates may still have the right to retain information as required by applicable law, regulations, or their own retention policy.  We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. Unless otherwise required by law, SummaUp will also erase personal information when the personal information is no longer necessary in relation to the purposes for which was collected or otherwise processed; when you withdraw your consent (where lawfulness of processing was based on your consent) and there is no other legal ground for the processing; when you object to the processing and there are no overriding legitimate grounds for the processing; when your personal information has been unlawfully processed; and when it is necessary to comply with legal obligations.

DATA SECURITY

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.  Where we have given you (or where you have chosen) a password that enables you to access certain parts of our Websites and Apps, you are responsible for keeping this password confidential.  We ask you not to share a password with anyone. The information you share in public areas may be viewed by any user of the Websites or Apps.

Unfortunately, the transmission of information via the internet is not completely secure.  Although we will do our best to protect your personal information, we cannot guarantee the security of your data transmitted to our Websites or Apps; any transmission is at your own risk.

THIRD PARTIES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices, including data privacy and security process and standards of any third parties, including physicians and other health care providers using the Services, the manufacturer of your mobile device and other IT hardware and software, and any other third party mobile application or website to which our Websites, Apps, or Services may contain a link.  These third parties may at times gather information from or about you. We have no control over the privacy practices of these third parties. Even though SummaUp may not be a “covered entity” as defined in HIPAA, any physician or other health care provider engaging through our Services may be a “covered entity” and therefore subject to the provisions of HIPAA from time to time.  

Please be aware that we are not responsible for the privacy practices of such other sites or third parties. We encourage you to be aware when you leave our Site and to read the privacy statements of each and every website that collects personal information.

USE BY MINORS

If you are under 18 years of age, we must obtain valid and verifiable consent by your parent or legal guardian to this Privacy Policy and our Terms of Use before you can use Websites, Apps, and Services.  Such consent will be obtained via reasonable methods, as determined by us in our sole discretion. If we determine that the consent obtained is inadequate, we will notify you and you may not use or access the Websites, Apps, or Services at any time or in any manner.  However, if you are a parent, legal guardian or personal representative of a minor child under 18 years of age, you may, in compliance with the Terms of Use use our Services on behalf of such minor child. Any information you provide us on behalf of your minor child will be treated in accordance with this Privacy Policy.  We do not knowingly collect information for individuals under the age of 18 for whom we have not obtained adequate consent pursuant to the above. If we learn that we have received any information for an individual under the age of 18 for whom we have not obtained adequate consent pursuant to the above, we will only use that information to respond directly to that child (or a parent, legal guardian or personal representative) to inform him or her that he or she cannot use our Service, and subsequently we will delete that information from our own servers.

REVISIONS TO OUR PRIVACY POLICY

We reserve the right to change this Privacy Policy at any time.  It is our policy to post any changes we make to our Privacy Policy posted on this page.  The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for periodically monitoring and reviewing any updates to the Privacy Policy.  Your continued use of our Websites or Apps after such amendments will be deemed your acknowledgment of these changes to this Privacy Policy.

CONTACTING US

If you have any questions about this Privacy Policy, please contact us by email at support@summaup.com or by regular mail at:

SummaUp, LLC

17200 Chenal Parkway

Suite 300-352

Little Rock, AR 72223

Last Revised: November 25, 2019