PRIVACY POLICY

Effective Date:

10/18/2022

Last Updated:

Transformative health and wellness (“us”, “we”, “our”) respect your privacy. This Privacy Notice describes the types of information we collect about users (“user”, “you”, your”) through our products and services, including, without limitation, your use of www.transformative360.com and user portal, mobile applications or other components which hyperlink to this Privacy Notice (collectively the “Service(s)”). We also describe in this Privacy Notice how we use your information, with whom we share it, the rights you may have, and how you can contact us regarding our privacy practices.

By accessing or using the Services, you signify that you have read, understood and agree to our collection, storage, use and disclosure of your Personal Information as described in this Privacy Notice.

1. When this Privacy Notice Applies

This Privacy Notice applies to your “Personal Information,” which includes information that may identify you, and that we collect or which is derived from your interactions with our Services. Examples of Personal Information may include your name, your address, or an online identifier that could identify you (such as an IP address). Depending on where you live, Personal Information may have a different definition according to the local privacy laws in your state.

This Privacy Notice does not apply to:

Users of our Services who are located outside of the United StatesMedical, health and/or treatment related information that is used to submit a claim to your health insurance, which is considered Protected Health Information (“PHI”) and is regulated by the Health Insurance Portability and Accountability Act (“HIPAA”). Instead, our Notice of Privacy Practices (NPP) will apply to PHI, which explains how PHI is used, disclosed, and what data rights exist.Third-party websites or services that may be linked within our Service. Any information you provide to those third-party websites are controlled by those third parties and are subject to their privacy policies. We encourage you to read their privacy policies carefully before giving them your information.

2. Types of Personal Information We Collect

We collect and generate different types of Personal Information depending on how you use or interact with our Services. The categories and sources of Personal Information we collect and generate about you may include:

Creating an account and onboarding. When you create a user account we collect information that enables you to register and onboard to use our products and services. Using the Service. When you use the Service, we collect additional information that you provide to us such as your preferences related to our Services and health care providers, information related to scheduling appointments and payment information.

Demographic and Contact Information: Demographic and contact information that you provide to us. For example, we may collect information such as your name, mailing address, e-mail address, and telephone and fax number.

Webforms and Requests: Information you submit to us through online or interactive forms available within our Services. For example, you may “contact us,” submit feedback, request additional information about the Services provided, sign up for a mailing or other type of newsletter, or reach out to us regarding a question or concern.

Websites: Information such as your username and password to enter certain sections of our websites or Services, unique identifiers, preference information (such as marketing preferences), browser type, Internet service provider (ISP), referring/exit pages, the files viewed on our site, operating system, date/time stamp, and clickstream data and other pieces of information. This is further described in Tracking Technologies subsection below.

Log Information: Usage details of our Services, including the address (or URL) where you came from before visiting us, which pages or features you visit or utilize, which browser you use, search terms you enter, and items you click on. We may also create usage statistics and monitor the traffic from your use or interaction with our Services. This includes information provided to the browser.

Internet Protocol (IP) Addresses: Internet protocol (IP) addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. We generally collect IP address information from visitors using or interacting with the Services and we log them for system administration purposes. In some cases, as described below, we may also use IP addresses to serve you ads on third party websites regarding our Services that may be of interest to you based upon your use or interaction with the Services if you have opted-in to certain types of cookies. You can always adjust your Cookie Settings or your individual browser’s settings.

Location Information: Your location information may be collected in a variety of ways depending on how you use or interact with our Services. For example, location information can be derived from your IP address, location information associated with your use of a device, your country or location selection, or other location-based components and content of our Services.

Business Interactions: Information derived from your business-related requests, communications, and dealings we have with you, or the company/organization you work(ed) for or are associated with. This may include your job title, business contact information (phone, email, fax, and address), information about products or Services you expressed an interest in or purchased from us, or that we have purchased from you or your company/organization, and other information needed to verify your ability to conduct business with us.

Financial and Payment Information: In certain circumstances, we may collect payment information. If a credit card is used to purchase, we may collect information necessary to process the credit card transaction, such as the credit card type, number, and expiration date.

Social Media: Our Services may link to our pages or accounts on third party social media networks (“social media”) but our Services do not use social media plug-ins. If you choose to interact with us on social media, we may collect the information you publish or submit. Note that this information is also governed by the privacy policies of the respective companies offering the social media service.

Forums and Blog: Some Services may link to blogs or forums (“forums”) that may or may not be owned or operated by us. If you choose to participate in forums, we may collect the information you submit to the forums. Note that such information may also be governed by the privacy policies of the respective companies offering the forums.

Video Recording and Photographs: If you choose to use certain portions of our Services which involve video and/or photography, we will collect this Personal Information from you in order to provide you with the Services you have requested.

Customer Support, Product Research, and Feedback: When you reach out to us such as to obtain support, give us feedback about the Service and our Providers, or participate in optional satisfaction surveys, product research (including user testing), we may also collect information that you choose to share.

Personal Information Obtained From Third Parties: We may also get Personal Information about you from other third parties, including your health care providers, where permitted by applicable law

Communications: We may collect your Personal Data via email, by phone, by text, by instant message, live chat, social media platforms, and through third party advertisers. We do not control our business partners’ use of Personal Data, and their use of your Personal Data will be in accordance with their own privacy policies.

User-Specific Information: Depending on the type of user you are, and which components of our Services you utilize, we may also collect additional types of Personal Information from you such as:

Users of Online Services:How you use and interact with our online Services, such as the date of your last login, the type of content that you viewed or accessed, pages you viewed, features you use, your browser and device type, error reports, and any links you click on to leave or interact with the Service.Patients:Health, medical and insurance related information, which is considered PHI and further described in the Notice of Privacy practices. Health Care Providers and Clinical Staff:Your professional credentials, affiliations, and other information needed to administer the Services and treat patientsProspective Candidates/Applicants or Employees:Information related to your prospective employment with us including but not limited to work history, education, the contents of your resume, references.

Cookies and Tracking Technologies:

Our Services may incorporate tracking technologies to provide you with certain functionalities, which collect or generate Personal Information about you when you interact with us.

Cookies and Pixels: A cookie is a small file placed on your hard drive by some of our web pages. HTML5 local stored objects may store larger amounts of information on your browser. When you access the Service, either through our mobile applications or website, certain information (including computer and connection information, mobile application use, browser type and version, operating system and platform details, and the time of accessing the Service) is automatically collected. We, or third parties we do business with, may use cookies to help us analyze our web page flow, customize the Service, content and advertising, measure promotional effectiveness, and promote trust and safety. This information will be collected every time you access the Service and it will be used for the purposes outlined in this Privacy Notice.

Tags: Pieces of code, or tags, which gather information about users. For example, tags are used on our websites to better understand online usage patterns and trends. We may also use tags in our emails or newsletters to count how many of those messages are read.

Widgets: Small components embedded within our Services which enable you to use certain functionalities.

Google Analytics: Google Analytics uses cookies to collect data such as time of visit, website pages visited, time spent on each website page, IP address, URL, and type of operating system. To learn more about how Google Analytics collects and processes Personal Information, please visit www.google.com/policies/privacy/partners. To opt out of having your activity available to Google Analytics, you can download the Google Analytics opt-out browser add-on.

Web Beacons: Web beacons are electronic images placed in the code of a webpage, application or email that allow us to monitor things such as user activity and site traffic. Web beacons may be used to track the traffic patterns of users from one page to another in order to maximize web traffic flow

Advertising: We may engage third party service providers who utilize tracking technologies to serve you advertisements that you may be interested in. Some of these advertisements may be personalized to you, meaning that the advertisements are intended to be relevant to you based on what we, or the third party service providers, know about you.

Your Settings and Preferences:

You can reduce the information cookies and other technologies collected from your device by “rejecting all” cookies on our banner, and/or by changing your browser settings to notify you when a cookie is being set or updated, or to block cookies altogether. Some browsers also allow you to control local stored objects through your browser settings. More information about how to do this may be found at www.allaboutcookies.org/manage-cookies or in the “Help” section of your browser. If you choose to block cookies, your use of the Service may be impacted.

If you would like more information about this and to know your choices about not having this information used by these companies, please visit: the Digital Advertising Alliance’s website, https://www.aboutads.info/, or the Network Advertising Initiative’s website, http://networkadvertising.org/consumer/opt_out.asp.

3. How We Use Personal Information

Depending on what Services you use and how you interact with us, we may use your Personal Information in the following ways.

To administer the Services;To manage business transactions;To respond to your inquires and provide information about the Services;To send you marketing information;To send you advertisements you may be interested in;To improve the Services and user experience;If we are involved in a merger, acquisition, or sale of our assets (or a portion thereof), it may impact how we process your Personal Information. In such an instance, we will comply with all applicable laws and treat your Personal Information accordingly;To maintain records relating to your account;To manage our relationship and communicate with you and our customers about new features and Services that we may offer;To respond to inquiries and resolve disputes;To carry out analytics, quality control, security processes and similar activities, in order to identify and develop potential improvements to the Services;To aggregate claim information and analyze outcomes for the Services;To measure your satisfaction with our company through surveys, feedback and ratings;To process payments from you in certain circumstances;To prevent, detect, and prosecute illegal or fraudulent activity on the Services;Other uses required to do so by law, for example in order to maintain accounting records, compliance with applicable retention obligations, for purposes of reporting obligations, to respond to lawful requests by public authorities, to investigate potential breaches and to protect our rights, property, safety and those of our users; andWhen permitted by law, we may also enhance or combine information about you, including your Personal Information, with information about you that we obtain from third parties for the same purposes described in this Privacy Notice.

4. How We Share Personal Information

We may share your Personal Information to the following third parties, and for the following reasons, in accordance with applicable law:

Health Care Providers: To the health care providers who are treating you.

Af iliates and Employees: To our related entity affiliates, and our employees, in order to provide you with the Services

Links to/From Third-Party Website: As a resource to our users, we may provide links to/from other unaffiliated websites or services within our Services. If you choose to visit such third-party websites or services, please note that any information you submit to them is not subject to this Privacy Notice.

For Legal Obligation or Safety Reasons: When we have a good faith belief that access, use, preservation or disclosure of Personal Information is reasonably necessary to (a) satisfy or comply with any requirement of law, regulation, legal process, or enforceable governmental request, (b) enforce or investigate a potential violation of the Terms of Use, (c) detect, prevent, or otherwise respond to fraud, security or technical concerns, (d) support auditing and compliance functions, or (e) protect the rights, property, or safety of our users, or the public against harm.

In the Case of a Merger or Sale: If and when we are involved in a merger, acquisition, or any form of transfer or sale of some or all of its business, whether as an ongoing concern or as part of bankruptcy, liquidation, or similar proceeding. Personal Information may be transferred along with the business. Where legally required, we will give you prior notice and if you have a legal right to do so, an opportunity to object to this transfer

To Service Providers: When we hire a service provider to help operate the Site or our business, we may give access to Personal Information as necessary to perform the service for us. This may include service providers that operate our Site, send our communications, or run our promotions.

To Business Partners: We may share Personal Information with our trusted business partners. For example, we may share your Personal Information with a company when we co-sponsor a promotion or service. These partners and affiliates may use your Personal Information to, among other things, send you information or contact you about their services and products.

5. How We Protect Personal Information

We have reasonable and appropriate security measures in place to protect against the loss, misuse, and alteration of any Personal Information we receive about you. We maintain reasonable security standards to protect the Personal Information that we maintain. If you have any questions about the security of your Personal Information, please contact us.

Do Not Track:

Your browser settings may allow you to automatically transmit a Do Not Track signal to websites and other online Services you visit. We do not alter our practices when we receive a Do Not Track signal from a visitor’s browser. To find out more about Do Not Track, please visit https://www.allaboutdnt.com.

How to control your communications preferences:

You can stop receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests.You can stop receiving text messages from us by texting “STOP”.

6. Your Rights

Depending on where you live, you may have certain rights regarding your Personal Information. We will handle any request to exercise your rights in accordance with applicable law, but please note that these rights may not be absolute and may not apply to you, depending on the circumstances, your relationship with us, and where you are located:

Right to Access your Personal InformationRight to Delete your Personal InformationRight to Correct or Revise your Personal InformationRight to Object or Withdraw Consent to Process your Personal InformationRight to Opt-Out of the Sale of your Personal Information

To exercise your Personal Information rights please contact us using the information in Section 12 below. If you are a resident of California, please see our California Privacy Policy.

7. Retention of Personal Information

We will retain your Personal Information for as long as necessary to fulfill the purposes for which it has been collected, as outlined in this Privacy Notice, or any longer retention period required by law.

8. Children’s Privacy

The Service is not directed to, and we do not knowingly collect personal information from, anyone under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us. We will delete such information from our files as soon as reasonably practicable. If you think that we have collected Personal Information via an online Service from a child under the age of 13, please contact us

11. Updates To Our Privacy Notice

Please note that we may modify or update this Privacy Policy from time to time, so please review it periodically. We may provide you with an updated Privacy Policy if material changes are made. Unless otherwise indicated, any changes to this Privacy Policy will apply immediately upon posting to the Site.

12. How to Contact Us

If you have questions about this Privacy Notice, our information practices, or how we handle your information or would like to exercise your rights, please reach out by contacting us at: [email protected]