Fold Health - Privacy Policy

Fold Health, Inc., and our affiliates (“Fold”,“we”, or “us”) provides a platform, mobile applications and related sites (the“Platform”) that facilitate administration of health care services (together, the “Services”) on behalf of health care providers (each, a “Provider“). We also operate websites www.fold.health, www.foldhealth.io (each, a “Site”) to promote our services to current and prospective Providers.

This Privacy Policy explains:

1. How we handle your personal information on behalf of your Provider when you use the Platform to obtainServices from your Provider; and

2. How we collect, use, and share personal information about users of our Site and Platform.

1.  Providers and Health Information

Our Platform allows Providers to offer the Services to you. Your Provider is responsible for the information we process on its behalf. This section describes how we handle personal information on behalf of your Provider when you use the Services.

The information we handle on behalf of Providers is subject to the Health InsurancePortability and Accountability Act (“HIPAA”) and we are a “business associate” of the Provider. Your Provider may present a separate privacy notice that addresses how they handle the personal information they collect through the Platform. If you have questions about how your Provider uses and shares personal information, and your rights and choices in relation to such personal information, please contact your Provider directly.

How we handle personal information (including health information) on behalf of Providers. We may use personal information, including health information, to facilitate the Services you receive from theProvider. This may include providing functionality that allows you to: schedule and manage bookings; teleconference, video chat, or message with your Provider; connect and integrate fitness trackers and wearables to track your health activities; and purchase products, services, membership plans, and lab services.

Information we handle on behalf of Providers.In order to facilitate the Services, our Platform may process the following categories of personal information depending on the features you use:

• Appointment and task management information, including scheduling and booking records, records of assignments and due dates, and reviews you provide of your interactions;
• Medical records and other health-related information, including medical files, responses to intake forms and risk screening questionnaires, information relating to your treatments and consultations, and information about your insurance coverage and preferred pharmacists, specialists and other providers;
• In-app purchases, including orders, transactions and payment information;
• Information from health fitness trackers and connected devices that you choose to connect to the Platform, including body measurements such as heart rate and blood sugar levels, and information about compliance with medical regimens and associated tasks; and
• Information about family members and dependents, including emergency contacts and relevant health and medical records.

2.  Fold’s Collection, Use, and Sharing of Personal Information

This section describes how Fold collects, uses and shares personal information when you visit the Site or use the Platform.

Personal Information We Collect

We collect the following categories of personal information:

• Information you provide on our Sites, such as inquiries and other communications with us, marketing preferences, and any other information you provide.
• Automatic data collection, including information that we automatically log about your interaction over time with our Sites and the Platform, including via cookies and other similar technologies, such as pixel tags, web beacons, and software development kits. This information includes:
  - Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our emails or clicked links within them.
  ‍- Device data, such as your computer’s or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, device type (e.g.,phone, tablet), IP address, unique identifiers, language settings, and general location information (derived from IP address) such as city, state/province or geographic area.

How We Use Personal Information

We use personal information for the following purposes:

• Operating and administering the Sites and the Platform. This includes:
  - Providing, operating and improving the Sites and Platform;
  - Responding to inquiries, providing customer service, communicating with you, and addressing your questions and feedback; and
  - Understanding your needs and interests, and personalizing your experience and our communications.‍
• Research and development. We may use personal information for research and development purposes, including to develop aggregated or de-identified statistics, to analyze and improve the Sites and Platform, to identify usage trends, and to operate and expand our business activities.
• ‍Compliance and protection. We may use your personal information to:protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims); audit our internal processes; comply with applicable laws, lawful requests, and legal process; and prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How We Share Your Personal Information

We may share personal information with the following parties:‍

• Service providers. Companies and individuals that provide services on our behalf or help us operate the Platform or our Sites (such as hosting, information technology, customer support, email delivery, and analytics services).
• Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
• Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
• Business transferees. Acquirers and other relevant participants in business transactions (or negotiations for such transactions)involving without limitation, a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Fold Health (including, in connection with a bankruptcy or similar proceedings) in accordance with applicable law.

Your Choices

Opt out of marketing communications. You may opt out of our marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you.

Online tracking opt out. There are a number of ways to opt out of having your online activity and device data collected on our Sites, which we have summarized below:

• Blocking cookies in your browser. Most browsers let you remove or reject cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.    
• Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
• Using privacy plug-ins or browsers. You can block our websites from setting     cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
• Platform opt outs. The following advertising partners offer opt out features that let you opt out of use of your information for interest-based advertising:
  - Google: www.adsettings.google.com
  - Facebook: www.facebook.com/about/ads
  - Twitter: www.twitter.com/settings/personalization
• Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
  - Digital Advertising Alliance for Websites: optout.aboutads.info
  - Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices
  - Network Advertising Initiative: optout.networkadvertising.org/?c=1  

Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, so you will need to opt out on every browser and device that you use.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. You may request the following in relation to your personal information:

• Information about how we have collected and used your personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
• Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.‍
• Correction of personal information that is inaccurate or out of date.
• Deletion of personal information that we no longer need to provide you access to the Platform or for other lawful purposes.

To make a request, please email us as provided in the “Contact Us” section below. We may ask for specific information from you to help us confirm your identity. California residents can empower an “authorized agent” to submit requests on their behalf.We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

Your choices above maybe limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the “Contact Us” section below.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Children

Our Sites are not intended for children under the age of 18. If we learn that we have collected personal information from children, we will take reasonable measures to promptly delete such data from our records.If you become aware of any data we have collected from children, please contact us as provided in the “Contact Us” section below.

Changes to This Privacy Policy

We may modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Site and Platform.

How to Contact Us

If you have questions regarding our Privacy Policy, please contact our legal@fold.health

‍