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Privacy Policy

HealNavigator (“us“, “we” or “Company“) respects the privacy of its users (each, “you” or “User“) and is committed to protecting the privacy of Users who access, use, and/or register to our website or any other services we provide (collectively: the “Services“). We have published this Privacy Policy to outline our practices with respect to collecting, using and disclosing your information when you use the Services. We encourage you to read the Privacy Policy carefully and use it to make informed decisions.

By using the Services, you agree to the terms of this Privacy Policy and your continued use of the Services constitutes your ongoing agreement to the Privacy Policy. The Privacy Policy is a part of the Terms of Use and is incorporated therein by reference.

 

What Type of Information We Collect

We may collect two types of data and information from our Users. The first type of information is un-identified and non-identifiable information pertaining to you, which may be made available or gathered via your use of the Services (“Non-personal Information“). We are not aware of the identity from which the Non-personal Information is collected. Non-personal Information which is collected may include your aggregated usage information and technical information transmitted by your device, including certain software and hardware information about your device (e.g., the device you use, the type of browser and operating system your device uses, language preference, access time and the website’s domain name from which you linked to the Services, etc.), in order to enhance the functionality of the Services. We may also collect information about your activity on the Services (e.g., pages viewed, online browsing, clicks, actions, timestamps, etc.).

The second type of information is individually identifiable information, namely information that identifies an individual or may with reasonable effort identify an individual (“Personal Information“). Such information may include:

  • Account Information: When you register to the Services, you will be asked to provide us certain details about yourself, such as:
    • Your name, email address, phone number and the medical condition for which you register to our Services.
    • In cases where you register to our Services on behalf of another person, you will also be asked to provide information on such person, such as its name and medical condition.

All in order for us to provide you with the most relevant information through our Services.

  • Device Information: We may collect Personal Information from your device. Such information may include geolocation data, IP address, unique identifiers (e.g., MAC address and UUID) as well as other information which relates to your activity through the Services.

For the avoidance of doubt, if we combine Personal Information with Non-personal Information, the combined information will be treated as Personal Information as long as it remains combined.

Cookies and Tracking Technologies

We may use cookies and other technologies or methods of web and mobile analysis (e.g., pixels, beacons,  etc.) to gather, store, and track certain information related with your access to and activity through the Services, including when you visit our website. A “cookie” is a small piece of information that a website assigns to your device while you are viewing a website. Cookies are very helpful and may be used for various different purposes. These purposes include, among other things, allowing you to navigate between pages efficiently, enabling automatic activation of certain features, remembering your preferences and making the interaction between you and the Services quicker, easier and smoother. Our website may use the following types of cookies:

  • Strictly Necessary Cookies: These cookies are essential to enable you to login, navigate around and use the features of a website, or to provide a service requested by you, for example by remembering items you have placed in an online shopping basket. We do not need to obtain your consent in order to use these cookies.
  • Functionality Cookies: These cookies allow the website to remember choices you make (such as your user name, language, or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by using a cookie to store information about the region in which you are currently located, remember changes you have made to text size, fonts, and other parts of web pages that you can customize, and provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect remains anonymous and they cannot track your browsing activity on other websites.
  • Performance cookies: These cookies collect information about how you use a website, for example which pages you go to most often, and record difficulties you may experience while using the Website, for example error messages. All information collected by these cookies is aggregated and therefore anonymous. It is only used to improve the efficiency of the website.
  • Targeting Cookies or advertising Cookies: These cookies are used to deliver advertisements tailored to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organizations such as advertisers.

How to manage your cookie settings

There are various ways in which you can manage and control your cookie settings. Please remember that, by deleting or blocking cookies, some of the features of the Services may not work properly or as effectively.

Google Chrome

Internet Explorer

Mozilla Firefox

Safari (Desktop)

Safari (Mobile)

Android Browser

For other browsers, please consult the documentation that your browser manufacturer provides.

You can learn more and turn off certain third party targeting and advertising cookies by visiting the following third party webpages:

European Interactive Digital Advertising Alliance (EU)
Internet Advertising Bureau (US)
Internet Advertising Bureau (EU)

We also use a tool called Google Analytics to collect information about your use of the Services. Google Analytics collects information such as how often users access the Services, what pages they visit when they do so, etc. We use the information we get from Google Analytics only to improve our Services. Google Analytics collects the IP address assigned to you on the date you visit sites, rather than your name or other identifying information. We do not combine the information collected through the use of Google Analytics with personally identifiable information. Google’s ability to use and share information collected by Google Analytics about your visits to this site is restricted by the Google Analytics Terms of Service and the Google Privacy Policy.

 

Lawful Grounds for Processing

Processing of Personal Information is necessary for the performance of our contractual obligations towards you and providing you with our services, to protect our legitimate interests and to comply with our legal obligations.

 

How We Use The Information

We use and share Personal Information in the manners described in this Privacy Policy. In addition to the purposes listed above, the information we collect, which may include your Personal Information, is used for the following purposes:

  • To set up your account and to provide the Services.
  • To identify and authenticate your access to the Services.
  • To communicate with you and to keep you informed of our latest updates and newsletters.
  • To market our website, products, and the Services.
  • To serve you personalized advertisements when you use the Services.
  • To perform a research or to conduct analytics in order to improve and customize the Services to your needs and interests.
  • To support and troubleshoot the Services and to respond to your queries.
  • To investigate and resolve disputes in connection with your use of the Services.
  • To detect and prevent fraudulent and illegal activity or any other type of activity that may jeopardize or negatively affect the integrity of the Services; and
  • To investigate violations and enforce our policies, and as required by law, regulation or other governmental authority, or to comply with a subpoena or similar legal process or respond to a government request.

 

With Whom We Share the Information and For What Purpose

We do not rent, sell, or share your Personal Information with third-parties except as described in this Privacy Policy.

We may share Personal Information with the following recipients: (i) subcontractors and third-party service providers; (ii) our business partners (including clinics and health practitioners, with which we share your information per your request); (iii) auditors or advisers of our business processes; and (iv) any potential purchasers or investors in the Company.

In addition to the purposes listed in this Privacy Policy, we may share Personal Information with the above mentioned recipients for any of the following purposes: (i) storing or processing Personal Information on our behalf (e.g., cloud computing service providers); (ii) processing such information to assist us with our business operations; (iii) performing research, technical diagnostics, personalization and analytics.

We may also disclose Personal Information or any information you submitted via the Services if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our policies, including investigations of potential violations thereof; (iii) investigate, detect, prevent, or take action regarding illegal activities or other wrongdoing, suspected fraud or security issues; (iv) to establish or exercise our rights to defend against legal claims; (v) prevent harm to the rights, property or safety of us, our affiliates, our Users, yourself or any third-party; (vi) for the purpose of collaborating with law enforcement agencies; and (vii) in case we find it necessary in order to enforce intellectual property or other legal rights.

 

Third-Party Collection of Information

Our policy only addresses the use and disclosure of information we collect from you. To the extent that you disclose your information to other parties via the Services (e.g., by clicking on a link to any other website or location) or via other sites throughout the Internet, different rules may apply to their use or disclosure of the information you disclose to them. You acknowledge that we are not responsible for the products, services, or descriptions of products or services that you receive from third-party sites and parties, or to the content or privacy practices of those, and that this Privacy Policy does not apply to any such third-party products and services. You are knowingly and voluntarily assuming all risks of using third-party sites to purchase products and services. You agree that we shall have no liability whatsoever with respect to such third-party sites and your usage of them.

 

For How Long We Retain the Information

Please note that unless you instruct us otherwise we retain the information we collect for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our policies and agreements. Retention periods will be determined taking into account the type of information that is collected and the purpose for which it is collected, bearing in mind the requirements applicable to the situation and the need to destroy outdated, unused information at the earliest reasonable time. Under applicable regulations, we will keep records containing client personal data, account opening documents, communications and anything else as required by applicable laws and regulations.

 

EU Residents

This part of the Privacy Policy addresses the specific disclosure requirements under the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data (“GDPR”).

Rights of residents of the EU

If you are a resident of the European Union, please note that the following rights specifically apply regarding your personal information: (1) Receive confirmation as to whether or not personal information concerning you is being processed, and access your stored personal information, together with supplementary information; (2) Receive a copy of personal information you directly volunteer to us in a structured, commonly used and machine-readable format; (3) Request rectification of your personal information that is in our control; (4) Request erasure of your personal information; (5) Object to the processing of personal information by us; (6) Request to restrict processing of your personal information by us; (7) Lodge a complaint with a supervisory authority.

However, please note that these rights are not absolute, and may be subject to our own legitimate interests and regulatory requirements.

To exercise any of the above mentioned rights, you may contact us at: [email protected]

Transfer of Information Outside the EEA

Please note that some data recipients may be located outside the EEA. In such cases we will transfer your data only to such countries as approved by the European Commission as providing adequate level of data protection, or enter into legal agreements ensuring an adequate level of data protection.

 

California Residents

This part of the Privacy Policy addresses the specific disclosure requirements under the California Consumer Privacy Act of 2018 (Cal. Civ. §§ 1798.100–1798.199) and the California Consumer Privacy Act Regulations by the Attorney General (collectively, “CCPA“).

What Information we Process?

In the 12 preceding months, we have collected, and/or disclosed the following categories of Personal Information:

Category of Personal Information Collected

Personal Information Collected

Categories of recipients to whom Personal Information was disclosed

Identifiers

Full name, email address, IP address, MAC, UDID

Advertising networks

Service providers

Clinics and healthcare providers

Personal Information Categories listed in the California Customer Records Statute (Cal. Civ. Code § 1798.80(e))

Telephone number, general medical information

Clinics and healthcare providers

Internet or Other Electronic Network Activity Information

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

Advertising networks

Service providers

Geolocation Data

Geolocation

Advertising networks

Service providers

Sources of Personal Information

In the 12 preceding months, we have collected the above-mentioned categories of Personal Information from the following category of source: consumer directly, advertising networks.

Sale of Personal Information

We do not “sell” Personal Information. We only share information with our business partners (as described above), per your request, solely to allow us to provide you with our Services. We also allow certain third-party partners to collect information about consumers through our Services for purposes of site analytics, ad fraud detection and reporting and for serving ads that are more relevant. Please see our “Advertisements” and “Advertising ID and Advertising Identifier” sections below for more information.

User Rights under the CCPA

The CCPA provides consumers with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

  • Access to Personal Information

You may request, up to two times each year, that we disclose to you the categories and specific pieces of Personal Information that we have collected about you, the categories of sources from which your Personal Information is collected, the business or commercial purpose for collecting your Personal Information, the categories of Personal Information that we disclosed for a business purpose, any categories of Personal Information about you that we sold, the categories of third-parties with whom we have shared your Personal Information, and the business or commercial purpose for selling your Personal Information, if applicable.

  • Deletion Requests

You have the right to request that we delete any Personal Information collected from you and retained, unless an exception applies.

Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers, subcontractors, and consultants to delete) your Personal Information, unless an exception applies.

  • Right to Opt-Out of the Sale of Personal Information

We do not sell personal information and never will. In the event that we do sell your Personal Information, you have the right to submit a request to opt-out of the sale of your Personal Information. You may change your decision at any time and permit us to sell your Personal Information.

If you would like more information about how to opt-out of our Site’s use of tracking technologies, including interest-based advertising cookies, please use the browser mechanism and/or device mechanism and/or the links, as provided in the “Cookies and Tracking Technologies” section of this policy.   

Exercising Your Rights

You can exercise your rights by submitting a verifiable consumer request to our physical address (as written below in the “How to contact us” section) or to our email address: [email protected]

Only you or a person authorized to act on your behalf may make a consumer request related to your Personal Information.

The request must:

  • Provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it.
  • We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

You may only request a copy of your data twice within a 12-month period.

If you have any general questions about the Personal Information that we collect about you how we use it, please contact us at [email protected]

Designating Agents

You can designate an authorized agent to make a request under the CCPA on your behalf if:

  • The authorized agent is a natural person or a business entity registered with the Secretary of State of California; and
  • You sign a written declaration that you authorize the authorized agent to act on your behalf.

If you use an authorized agent to submit a request to exercise your right to know or your right to request deletion, please mail a certified copy of your written declaration authorizing the authorized agent to act on your behalf using the contact information below.

If you provide an authorized agent with power of attorney pursuant to Probate Code sections 4000 to 4465, it may not be necessary to perform these steps and we will respond to any request from such authorized agent in accordance with the CCPA.

Non-Discrimination

Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

 

How We Protect Your Information

We take great care in implementing and maintaining the security of the Services and your information. We employ industry standard procedures and policies to ensure the safety of your information and prevent unauthorized use of any such information. Although we take reasonable steps to safeguard information, we cannot be responsible for the acts of those who gain unauthorized access or abuse the Services, and we make no warranty, express, implied or otherwise, that we will prevent such access.

If you feel that your privacy was treated not in accordance with our policy, or if any person attempted to abuse the Services or acted in an inappropriate manner, please contact us directly at [email protected].

Corporate Transaction

We may share information, including Personal Information, in the event of a corporate transaction (e.g., sale of a substantial part of our business, merger, consolidation or asset sale of an asset or transfer in the operation thereof) of the Company. In the event of the above, the acquiring company or transferee will assume the rights and obligations as described in this Privacy Policy.

 

Minors

The Services are not intended for use by individuals under the age of 18. If you are under 18 years old, you should not use the Services, or provide any Personal Information to us. We reserve the right to access and verify any Personal Information collected from you. In the event that we become aware that an individual under the age of 18 has shared any information, we will discard such information. If you have any reason to believe that a minor has shared any information with us, please contact us at [email protected].

 

Updates or Amendments to The Privacy Policy

We may revise this Privacy Policy from time to time, in our sole discretion, and the most current version will always be posted on our website or Application (as reflected in the “Last Revised” heading. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of the Services, following such amendments, constitutes your acknowledgement and consent of such amendments to the Privacy Policy.

 

How to Contact Us

If you have any general questions regarding the Services or the information that we collect about you and how we use it, please contact us at: [email protected] Or 16 Stuyvesant Oval, #5G, NY 10009, New York

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