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Privacy Policy

Privacy Rights:
Your privacy rights as a participant in My Pathway to Health are respected and supported throughout our systems and programs. The information you provide or authorize for disclosure is protected by My Pathway to Health program representatives. My Pathway to Health operates as an independent agent on behalf of your company’s health and wellness program. By agreeing to provide information about your health status, you acknowledge that you understand that your personal health information will be held by My Pathway to Health . Any individually identifiable health risk information will be maintained and protected as confidential. All information is stored and maintained in the most secure technical manner that technology allows. Your health information will not be viewed, scrutinized or inspected by your employer, health plan or any government entities. Only My Pathway to Health will have access to your personal information. Otherwise, your information will not be released without your consent. If you have questions or concerns about how personal information will be handled, contact My Pathway to Health at ohsecure@orthushealth.com or your employer.

EFFECTIVE DATE: OCTOBER 31, 2018

Orthus Health Inc. respects the privacy of its users. We want you to understand the types of information we collect, how we protect that information, and how we use or share it. This Privacy Policy applies to the MyPathwaytoHealth.com website and the My Pathway to Health mobile application (collectively, the “Services”). This Privacy Policy describes how Orthus Health will collect and use your personal information when you interact with the Services as a registered user (“User”). Throughout this Privacy Policy, we refer to information that personally identifies you as “personal information.” By using the Services, you indicate that you have read and accept the terms of this Privacy Policy (and any updates) and agree to our collection, use, and disclosure of your personal information in accordance with this Privacy Policy.

Information We Collect or Receive
We collect the following personal information from Users in order to provide and enhance the Services:

  1. Information We Collect or You Provide.
    1. Contact Information. We may ask for your contact information, such as your email address, and phone number. We may use the contact information to communicate with you regarding your questions or requests or to send you updates or reminders as part of the Services.
    2. Demographic and Fitness Information. You may also provide demographic information such as your age, date of birth, or gender and fitness information to help us provide customized features of the Services. Such information could include nutritional data, information related to your goals for health management, and exercise information you enter or allow us to obtain from your fitness tracker such as Fitbit and JawBone.
    3. Health Information. Depending on which features you choose to use, we may also collect your health information, such as results from your wellness exam or lab results, such as your height, weight, or blood sugar, blood pressure, or cholesterol levels. You may also provide us with information about your health conditions, treatment, and medical procedures.
    4. Log-in Credentials. When you create an account to access the Services, we collect your unique user name and password to authenticate you as a registered User and to help protect the security of your account.
    5. Location Information. We may collect the IP address of the computer or device used to access the Services as described further below. We may also use location services from Apple or Android to track your location but will only do so after obtaining user permission. We use your location data to improve our services and your user experience.
  2. Information Collected Automatically. We collect some information automatically when you use the Services and may aggregate such data and use it in a statistical form rather than using it to identify individual Users. Examples include cookies, web beacons, or web logs that may collect the type of Internet browser you are using, the type of computer operating system or mobile device you are using and the domain name of the website from which you linked to our Services. We use this information, which remains in aggregate form, to understand how our Users navigate the Services so that we may improve Services. If a combination of information we collect does identify you as an individual, we will treat the combined information as personal information. The following are examples of how we use information automatically collected through our Services:
    1. Cookies: When you view our website Services, we may store some information on your computer. This information will be in the form of a “cookie” or similar file that collects information to help us improve the Services and your experience when you visit the website Services. We do not permit third parties to use cookies or other tools to collect personal information through the website Services concerning your online activities over time across different websites.
    2. IP Addresses and Device IDs: An Internet Protocol (IP) address is a set of numbers that is automatically assigned to your computer whenever you log on to your Internet service provider or through your organization's local area network (LAN) or wide area network (WAN). Web servers automatically identify your computer by the IP address assigned to it during your session online. The IP address can be used to tell us your general location. We may also collect your device ID which tells us information about the device you use to access the Services, such as the make, model, and operating system.
    3. Google Analytics: The website Services use a web analytics tool provided by Google, Inc. called Google Analytics. Google Analytics uses cookies to help us analyze how users use the website Services. The information generated by the cookie about your use of the website Services (including your IP address) will be transmitted to and stored by Google. To learn more about Google Analytics and how you may be able to opt out, visit https://tools.google.com/dlpage/gaoptout.
  3. Information of Former Users. If you are a former User, we protect your information in the same manner that we treat personal information about current Users. We maintain and/or destroy personal information in accordance with our then-current data retention and destruction policies, or as otherwise required by applicable law or contract.

Using and Sharing Information
We use the information we collect for a variety of reasons, including to understand the needs of our Users and to provide and enhance the Services. We do not sell or disclose your information to third parties except as described in this Privacy Statement, as necessary for us to provide the Services. We may provide certain aggregate User information to the employer or health plan who is sponsoring your participation in the Services, but such information will generally not identify you as an individual. However, depending on the range of Services your employer or health plan has asked us to provide, some of your personal information, including health information, may be shared with your employer or health plan when you agree to use certain features of the Services. We may also use or share your information to:

  1. Personalize your experience, store your preferences, and provide user-experience features of our Services and to operate our business, including sharing information with Orthus Health subsidiaries, as needed.
  2. Respond to your questions/requests or to communicate with you to provide you with newsletters or other updates and information related to our Services we think may be of interest to you or that you have requested.
  3. Engage with select third-party business partners who provide support services in connection with our Services. Such parties may, from time to time, have access to your personal information to enable them to provide those services. All business partners are contractually required to protect your information and are prohibited from using the information for other purposes or for their own marketing activities.
  4. Conduct data analysis and related activities.
  5. Protect safety when we have reason to believe that disclosing the information is necessary to identify, contact or bring legal action against someone who may be causing injury to you, or otherwise injuring or interfering with our rights, property or operations, other Users of the Services, or anyone else who could be harmed by such activities.
  6. Comply with legal obligations, such as when required by law, or in response to any demand by law enforcement authorities in connection with a criminal investigation, or civil or administrative authorities in connection with a pending civil case or administrative investigation.
  7. Maintain the security of our Services, resolve or troubleshoot technical issues.

We also reserve the right to transfer information, including your personal information, in connection with an actual or potential sale or transfer of all or a portion of our business assets, including transfers made as part of insolvency or bankruptcy proceedings.

"Do-Not-Track" Signals
Some web browsers may transmit “do not track” signals to the website Services. There is no standard that governs what, if anything, websites should do if they receive these signals. We do not currently respond to “do not track” browser signals or similar mechanisms.

Your Rights and Choices
You can choose not to give us personal information we request but in some cases, we will not be able to provide the Services or respond to your request without such information. You may also contact us using the contact information at the bottom of this Privacy Policy to exercise your choices which include the following:

  • You may contact us to access personal information we maintain about you or to amend such information if you believe it is incorrect or incomplete. You may also make adjustments to your personal information by updating your User profile within the Services.
  • You can opt-out of receiving emails from us, including newsletters or other messages, by unsubscribing via the “Unsubscribe” link included in our email communications. You can opt-out of other notifications or messages from the Services by adjusting your preferences in your account profile in the Services.
  • You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the features of the Services.

Children’s Privacy
Our Website is not directed to children (or anyone under age 18). We do not knowingly or intentionally collect information from children. If you are a parent or guardian and you believe your child has provided us with information, please contact us using the contact information provided below and we will delete such information from our systems.

Securing Information
We maintain reasonable safeguards, including administrative, technical, and physical security measures intended to protect against loss, misuse, or unauthorized access, disclosure, alteration, or destruction of the information collected through the Services.

Links to Other Websites and Services
We are not responsible for the practices employed by websites or services linked to or from our Services, including the information or content contained therein. Please remember that when you use a link to go from our Services to another website or service, our Privacy Policy does not apply and we do not have any control over those third-party websites or services. Your browsing and interaction on any third-party website or service are subject to that third party’s rules and privacy policies. In addition, you agree that we are not responsible and we do not have control over any third-parties or third-party sites that you authorize to access your information or user content. If you are using a third-party website or service (like Facebook or other social media platforms) and you allow such a third-party access to your information or user content, you do so at your own risk.

Changes
This Privacy Policy may be updated or changed in accordance with new laws, procedures or for reasons we deem necessary. We encourage you to periodically review this Privacy Policy to stay informed about our most current privacy practices related to information we collect. Any updates to this Privacy Policy will be posted on our website and we will indicate the effective date at the top of this Privacy Policy. Your continued use of the Services after any such updates take effect will constitute your acceptance of those changes.

Contact Us
If you have any questions or comments about this Privacy Policy, or if you would like to exercise one of your rights under this Privacy Policy, you may contact us at ohsecure@orthushealth.com