Privacy Policy

PRIVACY POLICY HIGHLIGHTS

Odela Health (“Odela”, “we”, or “us”) understands that your time is valuable. Therefore, we have set out below some important highlights of our Privacy Policy. You can obtain more information about how we collect, use, disclose and protect your Personal Data by reviewing our full Privacy Policy. We encourage you to read our full Privacy Policy, as it contains important information for you.

What Personal Data do we collect?

• We collect information that you provide to us (or our affiliates, business partners or service providers) directly, or that you authorize family members or personal representatives to provide to us (or our affiliates, business partners or service providers), including:
  • your name, contact information (address, phone number, email address), signature and demographic information (i.e., age, date of birth, sex, gender, national origin, citizenship, race, ethnicity, marital status, sexual orientation);
  • user name and password;
  • information related to your employment (i.e., name of your employer, job title, office location, employee identification number);
  • insurance information (i.e., policy or plan number, member ID, insurance carrier, health plan eligibility, enrollment and coverage, and information regarding your dependents);
  • health and wellness information (i.e., weight, height, pregnancy information, lifestyle information, medication history, healthcare providers visited, information regarding visits to such healthcare providers, medical history and condition, diagnoses, treatment plans, disability status, genetic information, prescription information, laboratory results, and other health-related information that you provide);
  • physiological, biological and behavioral characteristics;
  • payment data (including credit and debit card information);
  • geolocation; and
  • other information provided in your communications with us, including information collected in the course of providing customer support, and your responses to our surveys.
• We (or our affiliates, business partners or service providers) collect additional information in the course of our interactions with you or your authorized representative, including information regarding services purchased, service history and tendencies.
• We (or our affiliates, business partners or service providers) also collect audio recordings, videos, images, and photographs.
• We (or our affiliates, business partners or service providers) use cookies and other tracking technologies on our Site, which automatically collect certain information about your online activities, including IP address, browsing history, domain name, operating system, search history, clickstream patterns, session information, browser and operating system type, navigation paths, date/time stamps, time zone, cookie identifiers, language preferences, GPS data (with your express consent), and other device information (including device identifiers) and information about how you interact with our Site.
• We (or our affiliates, business partners or service providers) may also collect certain information from third parties, with consent where required by applicable law, including:
  • Information provided to us by your employer (e.g., your name, contact information and/or other identifying information used to confirm your eligibility to use the Site and receive Services), and other information as identified further below in this Privacy Policy, as applicable.
  • Information provided by your in-person healthcare provider (e.g., your name, contact information, and other information necessary to help coordinate your care upon request), as applicable.
  • Information collected from publicly available sources, third-party platforms and sites, when you engage with our Site, social media pages, online communities and forums, and when you mention us on your own or other social media pages, online communities, or forums, or when you interact with advertisements related to our Site and the Service. Such information includes identifiers, information regarding services purchased, service history and tendencies, information collected via cookies and other tracking technologies, geolocation data, and professional and employment-related information.
  • Information collected from your health plan, insurer or payor, including name, contact information, employee or member identification number, policy or plan number, as well as health and wellness information and demographic information (each as described above).

The information that we collect may also be used to make inferences about you, including regarding your preferences, behaviors, characteristics, location, and number of persons in your household.

Why do we collect Personal Data and how is it used?

We use the information that we collect for the purposes of: verifying identity and eligibility to use the Site and Service; providing, performing and personalizing the Site and the Service (including sign-up/registration, providing non-medical digital healthcare services, and providing clinical services); communicating with you (including providing customer support and technical assistance); processing payments and insurance claims; operating, maintaining, evaluating and improving the Site and Service, and enhancing your experience when visiting our Site; marketing, advertising and promotional activities, to the extent permitted by applicable law, unless you opt-out; monitoring and improving the security of our Site, Service, systems and networks, and to protect against illegal activity; and legal and regulatory compliance (including to detect and prevent fraud).

Without limiting the above:

• The information that is collected automatically when you visit our Site or use the Service is used to perform data analytics and provide relevant advertising to you based on your online activities and interests, unless you opt-out of this use of your data.
• Audio recordings, videos, images, and photographs are collected for the purposes of providing services to you.
• GPS location information is collected for the purpose of locating services in your vicinity upon request.
• The information that we collect from employers is used to provide services to you, including but not limited to determine your eligibility for services that are paid for by your employer and/or covered by your employer’s insurance plan(s).
• Information provided by your in-person healthcare provider (where applicable) is used only to help coordinate your care upon request.

We may also use de-identified or anonymized data for research and development, internal business purposes (such as improving our products and services), as well as scientific research purposes, as permitted by applicable law.

Is Personal Data shared or disclosed?

• We share your Personal Data with our affiliates, business partners and service providers for the same purposes described above, including organizations that provide services related to: maintaining, operating, hosting and improving the Site and the Service; payment processing; customer service; sending emails; fulfilling orders; technical support; data analytics; and marketing and advertising.
• We may disclose your Personal Data to wellness professionals and facilities offering their services via the Site or Service (the “Practitioners”), with your consent, so that they may provide virtual consultations to you as part of the Service and for other treatment, payment, or healthcare operations purposes. In addition, when you communicate with us or submit information through the Site or Service, we may share that information with Practitioners to enable them to communicate with you and provide the Service.
• Our Site includes social network sharing widgets that transmit certain information to social networks and other third-parties about your interactions with our web pages, including an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where the widget appears.
• In the event that you or your personal representative choose(s) to file an individual rights request under HIPAA or other applicable laws, we may share your or your personal representative's name, and the date that the request was received and resolved with your Group Health Plan Sponsor, subject at all times to applicable HIPAA regulations or other applicable laws.
• We may also share Personal Data with your health plan, insurer, or payer in order to verify eligibility to use our Site and Service and to process payments or submit claims. Such information includes your name, address, employee or member ID, employer name, and/or other information provided by your health plan, insurer, or payer for this purpose.
• We may disclose your Personal Data in the event of a bankruptcy, merger, acquisition, or sale of all or part of our business, subject to compliance with applicable legal requirements.
• Personal Data may also be disclosed: to law enforcement, courts and regulatory authorities; to detect and protect against security incidents and unlawful conduct; and/or as otherwise required or permitted by applicable law.

We may also share certain aggregated and statistical information with clearinghouse entities, program administrators, academic and institutional review boards, and/or your employer.

What are the risks?

• Although we take steps to safeguard the Personal Data under our control, "perfect security" does not exist, and we cannot guarantee “perfect security.” In particular, we cannot guarantee the security of information communicated to us or from us via email. Email is not necessarily a secure way of transmitting information and it is possible that third parties may unlawfully intercept or access such information. We encourage you to not send us information you believe is sensitive or confidential via email. We also encourage you to create a strong and unique password for your Odela account that is not shared with anyone.

What else should you know?

• Odela and its affiliates, business partners and service providers process Personal Data in the United States. This means that your information may be transferred to, or stored in, the United States and accessible to U.S. courts, law enforcement and national security authorities.
• You have the choice to opt-out of any collection, use or disclosure of your Personal Data for non-essential purposes, such as marketing purposes and/or to improve our Site or Service and/or your experience on our Site or using our Service. You may contact us, at any time, for more information or to inform us of your choices.
• You may contact our Privacy or Security Officer at concierge@odelahealth.com if you have questions about the collection, use or disclosure of your Personal Data, including questions about our service providers in the United States (or to obtain written information regarding our policies and practices with respect to same), or to exercise any rights you may have to access and rectify your information (where applicable).

FULL PRIVACY POLICY

Odela Health (“Odela”, “we”, or “us”) is committed to respecting the privacy of users of our services (including both Site and App as defined below, the “Service”). This Privacy Policy (“Privacy Policy”) is intended to describe how Odela collects, uses and discloses information in order to provide you with our marketing site, www.piquehealth.co (the “Site”), and our web and mobile application (the “App”) and Service, and your rights in connection with that information.

The Service provides individuals accessing it with general information on health care and other general content pertaining to health and wellness topics and access to wellness professionals and facilities offering their services via the Service (the “Practitioners”). This Privacy Policy applies to anyone accessing our Site or Service (collectively, “you”), including (a) casual visitors to our Site who do not sign up for an account (“Site Visitors”) and (b) individuals who have registered to use our Site or Service (“Registered Users”). This Privacy Policy is incorporated into our Terms of Use, 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, as applicable. As with our Terms of Use, if we make any changes to our Privacy Policy, we will post the revised Privacy Policy to the Site and update the “Last Updated” date of the Privacy Policy.

Please note that certain rights, requirements, and disclosures in this Privacy Policy may be subject to exemption or otherwise may not apply to you based, for example, on applicable law or regulations.

1. INFORMATION WE COLLECT

As described in this Privacy Policy, we may collect certain Personal Data from or about you in connection with your use of, or your submissions to, the Site and the App, and the provision of the Service. You are not required to provide all Personal Data identified in this Privacy Policy; however, please be advised that if you do not provide the Personal Data requested, we may be unable to provide some or all of the Services to you.

1.1 Categories of Personal Data

“Personal Data,” for purposes of this Privacy Policy, generally includes information that may be used to identify you. We may collect the following categories of Personal Data:

1.2 Special Categories of Personal Data. We generally do not require you to submit special categories of Personal Data in order to visit our Site. However, as our Service provides general information on health care and other general content pertaining to health and wellness topics through the App, we may need to collect certain special categories of Personal Data, such as health information, in order to provide the Service. In the event we need to collect data that would constitute special categories of Personal Data in order to provide a specific service to you, we will obtain your consent as required by law.

1.3 Precise Location Data. As set forth in the chart above, we may collect certain location data. We may obtain information regarding your location or the location of your device through which you access our Service. For example, we collect general location data when you provide us with your zip code. In addition, if you use our mobile applications, 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 revoke this consent by managing your location services preferences through the settings of your device.

1.4 Cookies and Similar Technologies. We may collect certain Personal Data using cookies and other technologies, such as web beacons, device IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising. When you visit the Site, we may also automatically collect certain data about your device, including information about your web browser, IP address, time zone, language preferences, and information regarding your device and browser, including device identifiers. Additionally, as you browse the Site, we may collect information about the individual web pages or services that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. Our “Use of Cookies and Similar Technologies” section contains more information and options to control or opt-out of certain data collection or uses related to cookies and similar technologies. For more information about cookies and similar technologies, please see the section below entitled “USE OF COOKIES AND SIMILAR TECHNOLOGIES.”

1.5 De-identified and Anonymous Data. We may create de-identified or anonymous data from Personal Data by removing data components (such as your name, email address, or linkable tracking ID) that makes the data personally identifiable to you or through obfuscation or through other means. For example, we may use de-identified or anonymized data for research and development and scientific research purposes pursuant to applicable law. Our use of anonymized data is not subject to this Privacy Policy, if it cannot be reverse engineered or linked back to you.

2. SOURCES OF INFORMATION AND PURPOSES OF COLLECTION

The following is intended to describe the various sources through which we may collect Personal Data and the purposes for which we collect it:

3. USE OF COOKIES AND SIMILAR TECHNOLOGIES

The Site may use cookies and similar technologies to improve user experience, for performance and analytics, and to improve our content and the Service. A “cookie” is a small text file that a web server stores in browser software. The purpose of cookies is to remember the browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may serve to track Personal Data previously entered by a web user on the Site. Cookies can remember login information, preferences, and similar information. We may use cookies to collect certain information about you and your use of our Service, such as IP addresses, domain names, and the type of device and operating system being used. We may also use cookies to identify your device when you revisit our Service to, for example, recall your authentication information or to track statistical information related to navigation throughout the Site. Cookies, as well as other tracking technologies, such as HTML5 local storage, and Local Shared Objects (such as “Flash” cookies), and similar mechanisms, may record information such as a unique identifier, information you enter in a form, IP address, and other categories of data. We may also use web beacons or “pixels,” and in certain circumstances may collect IP address, screen resolution and browser software and operating system types, clickstream patterns, dates and times that our site is accessed, and other categories of data.

We generally use our own first-party and third-party cookies on our Site to provide you with our Service, including to customize and improve our Service, perform business analytics, and to market, advertise, and promote our Service. In particular, we use the following third-party cookies and other similar technologies: Google Ads, Google Analytics, CrazyEgg, Facebook, Hubspot, LinkedIn, Terminus, Twitter, and Zoominfo. While we use these third party tools to provide us with their services, we encourage you to learn more about how they collect and process Personal Data by visiting their respective privacy policies.

For Google Analytics, you can read more about how Google Analytics processes Personal Data at http://www.google.com/policies/privacy/partners. You can also opt out of Google Analytics by following the instructions located here: http://tools.google.com/dlpage/gaoptout.

For CrazyEgg, you can read more about how CrazyEgg processes Personal Data at https://www.crazyegg.com/privacy and utilize its opt-out tool at https://www.crazyegg.com/opt-out.

Most browsers allow you to control cookies, including whether or not to accept them, and how to remove them. 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 you should refer to the settings menu on your browser to change your cookie preferences.) Please note that if you choose to erase or block your cookies, you may not be able to use some features of the Site, or certain features may not function properly.

In addition to cookies preferences and browser settings described above, the online advertising industry provides tools that permit you to opt-out of certain interest-based advertising based on cookies. For more information about these programs and tools, you can visit www.aboutads.info/choices and www.networkadvertising.org/choices for US users, www.youradchoices.ca/choices for Canadian users, and www.youronlinechoices.com for European users.

4. HOW WE USE AND SHARE THE INFORMATION WE COLLECT

We may use and share Personal Data for a variety of different purposes as set out in further detail in this Privacy Policy. In some cases, we may ask for your consent so that we may process your Personal Data. However, in certain circumstances, applicable data protection laws allow us to process your Personal Data without needing to obtain your consent. Subject to applicable law, the purposes for which we use and process Personal Data, and the legal basis for such processing, are set forth below.

Generally, we may share your Personal Data in the following circumstances:

• We share your Personal Data with our affiliates, business partners and service providers for the same purposes described above, including organizations that provide services related to: maintaining, operating, hosting and improving the Site and the Service; payment processing; customer service; sending emails; fulfilling orders; technical support; data analytics; and marketing and advertising.
• We may disclose your Personal Data to wellness professionals and facilities offering their services via the Site or Service (the “Practitioners”), with your consent, so that they may provide virtual consultations to you as part of the Service and for other treatment, payment, or healthcare operations purposes. In addition, when you communicate with us or submit information through the Site or Service, we may share that information with Practitioners to enable them to communicate with you and provide the Service.
• Our Site includes social network sharing widgets that transmit certain information to social networks and other third-parties about your interactions with our web pages, including an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where the widget appears.
• In the event that you or your personal representative choose(s) to file an individual rights request under HIPAA or other applicable laws, we may share your or your personal representative's name, and the date that the request was received and resolved with your Group Health Plan Sponsor, subject at all times to applicable HIPAA regulations or other applicable laws.
• We may also share Personal Data with your health plan, insurer, or payer in order to verify eligibility to use our Site and Service and to process payments or submit claims. Such information includes your name, address, employee or member ID, employer name, and/or other information provided by your health plan, insurer, or payer for this purpose.
• We may disclose your Personal Data in the event of a bankruptcy, merger, acquisition, or sale of all or part of our business, subject to compliance with applicable legal requirements.
• Personal Data may also be disclosed: to law enforcement, courts and regulatory authorities; to detect and protect against security incidents and unlawful conduct; and/or as otherwise required or permitted by applicable law.

We may also share certain aggregated and statistical information with clearinghouse entities, program administrators, academic and institutional review boards, and/or your employer.

5. WITHDRAWING YOUR CONSENT

In most cases, we need to process certain of your Personal Data in order to fulfil our contractual obligations to you and for our legitimate interests. Where the basis of processing is legitimate interests, you have a right to object to the processing of your Personal Data. Please note that, subject to applicable law, we may continue to process your Personal Data even where you object if there are compelling legitimate grounds for processing that override your interests and rights, or where processing is necessary to establish, exercise, or defend legal claims. Where consent is the basis of processing, you may at any time withdraw the consent you provided for the processing of your Personal Data for the purposes set forth in this Privacy Policy by contacting us at concierge@odelahealth.com, provided that we are not required by applicable law or professional standards to retain such information. If you would like to stop receiving newsletters or other marketing or promotional messages, notifications, or updates, you may do so by following the unsubscribe instructions that appear in these e-mail communications, or you may contact us at concierge@odelahealth.comto opt-out of direct marketing. Please be advised that you may not be able to opt-out of receiving certain service or transactional messages from us, including legal notices. Please note that if you do not provide consent, if you withdraw your consent or object to processing, or if you choose not to provide certain Personal Data, we may be unable to provide some or all of the Service to you.

6. DO-NOT-TRACK

Do-Not-Track is a public-private initiative that has developed a “flag” or signal that an Internet user may activate in the user’s browser software to notify websites that the user does not wish to be “tracked” by third-parties as defined by the initiative. Please note that the Site does not alter its behavior or use practices when we receive a “Do Not Track” signal from browser software.

7. SOCIAL NETWORK WIDGETS

Our Site may include social network sharing widgets that may provide information to their associated social networks or third-parties about your interactions with our Site's web pages that you visit, even if you do not click on or otherwise interact with the plug-in or widget. Information is transmitted from your browser and may include an identifier assigned by the social network or third party, information about your browser type, operating system, device type, IP address, and the URL of the web page where the widget appears. If you use social network tools or visit social networking sites, we encourage you to read their privacy disclosures to learn what information they collect, use, and share.

8. USE BY MINORS

Our Service is intended for use by individuals 13 years of age or older. We do not knowingly collect information from individuals under the age of 13 years without parental consent. However, if you are a parent, legal guardian, or personal representative of a minor child, you may, in compliance with the Terms of Use, 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. If we learn that we have received any information from an individual under the age of 13 without parental consent, we will take steps to remove the data as permitted by law. If you believe an individual under 13 years of age has provided us with Personal Data without parental consent, please contact us at concierge@odelahealth.com or by postal mail at the contact information listed in the “Contacting Us” section.

9. LINKS TO OTHER SITES

Our Site or App may contain links or otherwise provide access to another website, mobile application, or Internet location (collectively “Third-Party Sites”). For example, when you choose to contact a medical professional in response to your request for a recommendation, you are providing information (including Personal Data) directly to third parties outside of Odela. Please note that we have no control over and are not responsible for Third-Party Sites, their content, or any goods or services available through the Third-Party Sites. Our Privacy Policy does not apply to Third-Party Sites. We encourage you to review the Notice of Privacy Practices of each Practitioner who provides you with services and the privacy policies of any website or application with which you interact.

10. SECURITY OF INFORMATION

We implement technical, physical, administrative and organizational security measures designed to safeguard Personal Data. Please note, however, we cannot fully eliminate security risks associated with the storage and transmission of Personal Data. You also must keep your password secure and your account confidential. 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.

11. DATA RETENTION

We will retain your Personal Data for as long as is necessary to fulfill the purposes for which we obtained the Personal Data, including to provide the Service, or for such longer period as may be required or permitted by applicable law. We will also retain your Personal Data as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the purposes for processing your Personal Data and associated legal bases; (iii) the existence of a legal obligation as to the retention period; and (iv) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).

12. TRANSFER OF DATA TO THE U.S.

Please note that if you are visiting the Site or App from outside of the United States, your information will be transferred to, stored, and/or processed in the United States. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. If you are located outside of the United States, the transfer of Personal Data may be necessary to provide you with the requested information and Service and/or to perform any requested transaction. By using any portion of the Site or the App, you acknowledge and consent to the transfer of your information to our facilities in the United States.

13. ADDITIONAL DISCLOSURES FOR DATA SUBJECTS IN THE EUROPEAN UNION, EUROPEAN ECONOMIC AREA, SWITZERLAND, AND THE UK

13.1 DATA SUBJECT RIGHTS

Data subjects in the European Economic Area, European Union, Switzerland, United Kingdom, and certain other jurisdictions have certain rights under applicable data protection law, including the right to request confirmation from us as to whether or not we are processing your Personal Data. Where we are processing your Personal Data, subject to applicable law, you also have the right to:

• Request access to, modification or rectification, or deletion. You have the right to request access to, modification of, or deletion of your Personal Data we maintain. Registered Users can also make changes to their profile by logging into their account and adjusting information through the settings.
• Request restriction of processing. You have the right to request that we restrict processing of your Personal Data in certain circumstances, such as where you believe that the Personal Data we hold about you is inaccurate or our processing is unlawful.
• Object to processing. In certain circumstances, you may have the right to request that we stop processing your Personal Data, such as a request to stop sending you direct marketing communications. To opt-out of direct marketing communications, please see the instructions in the “Withdrawing Your Consent” section of this Privacy Policy.
• Data portability. In certain circumstances, you may have the right to receive the Personal Data concerning you that you provided to us or to request that we transmit your Personal Data to another data controller.
• Lodge a Complaint. You have the right to lodge a complaint with a supervisory authority.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests. To exercise your rights, submit your request in writing using the email address concierge@odelahealth.com or by postal mail at the contact information listed in the “Contacting Us” section.

We will respond to authorized and verified requests as soon as practicable and as required by law. In addition, the above rights are subject to various exclusions and exceptions under the law, and, under certain circumstances, we may be unable to implement your request. We will advise you of any reason for denying or restricting a request.

14. ADDITIONAL DISCLOSURES FOR CALIFORNIA RESIDENTS

This section applies to California residents when and if the California Consumer Protection Act is applicable to the Service about whom we have collected Personal Data, including through use of our Site or App, by purchasing or utilizing our Service, or by communicating with us electronically, in paper correspondence, or in person. For purposes of this section, the term “Personal Data” includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California consumer or household.

We do not sell your Personal Data that is collected.

We may disclose the following types of Personal Data to third parties for a business or commercial purpose, as further described in the chart above:

• Identifiers
• Medical and health insurance information
• Protected classifications under applicable law
• Commercial information
• Biometric information
• Internet or similar network activity
• Geolocation data
• Sensory data
• Professional or employment-related information
• Inferences from other Personal Data

You may be entitled by applicable law to exercise the following rights with respect to your Personal Data:

• Right to Know. You have the right to request what Personal Data we collect, use, disclose, and/or sell, as applicable.
• Right to Delete. You have the right to request that we delete the Personal Data that we have collected about you.
• Right to Opt-out of the Sale of Personal Data. You have the right to request to be opted-out from the sale of your Personal Data; however, as set forth above, we do not sell Personal Data that is collected through use of the Odela App.
• Right to Non-Discrimination. You have the right not to receive discriminatory treatment by us for the exercise of the privacy rights described above.

You may also authorize someone to exercise the above rights on your behalf. If you have provided us information on your minor child, you may exercise the above rights on behalf of your minor child.

In addition, residents of California also have the right to request once per calendar year certain information with respect to the types of personal information (as defined by California law) we share with third parties for those third parties' direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year.

The above rights are subject to our being able to reasonably verify your identity and authority to make these requests by providing verifiable information such as the following;

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you.

To exercise your rights, submit your request in one of the following ways:

• By phone at (424) 394-1016
• By email at concierge@odelahealth.com
• By postal mail at the contact information listed in the “Contacting Us” section

We will respond to authorized and verified requests as soon as practicable and as required by law. In addition, the above rights are subject to various exclusions and exceptions under the law, and, under certain circumstances, we may be unable to implement your request. We will advise you of any reason for denying or restricting a request.

15. ADDITIONAL NOTICES FOR CANADIAN USERS

We will obtain your consent to collect, use or disclose your Personal Data, except where consent is not required by applicable law. Consent may be express or implied (including by your acceptance of this Privacy Policy), in accordance with applicable laws.

Your Personal Data will be stored electronically by us and our service providers (including Google, on the Google Cloud Platform) in Iowa, North Carolina and Oregon. Your information will be accessible to marketing, IT, data analytics, engineering, and Care Team personnel, as well as Practitioners, who have a need to access such information for the purposes of providing the Site and/or the Service.

As indicated above in the “Transfer of Data to the U.S.” section, your Personal Data may be transferred to, stored, and/or processed in the United States by us and our service providers, affiliates and business partners. Accordingly, such information may be accessible to courts, law enforcement and national authorities in the United States. You may contact our Privacy Officer, as set out below, if you have questions about the collection, use, disclosure or storage of Personal Data by our service providers outside Canada (including any relevant affiliates), or to obtain access to written information about our policies and practices with respect to service providers outside Canada.

You may have certain rights with respect to your Personal Data, including the right to:

• require deletion of your Personal Data if it was not collected in accordance with applicable law;
• access, correct, rectify or update your Personal Data;
• be informed of the existence, use, and disclosure of your Personal Data, and to challenge the accuracy and completeness of such information and have it amended as appropriate;
• withdraw consent to continued collection, use or disclosure of Personal Data;
• require that Odela cease disseminating information or de-index any hyperlink that provides access to the information by technological means, if the dissemination contravenes the law or a court order (and in certain other circumstances); and/or
• address a challenge concerning compliance with applicable privacy laws to Odela’s Privacy Officer at concierge@odelahealth.com, which is the person(s) designated as being accountable for Odela’s compliance with such laws

Please note that these rights: (a) may vary depending upon the jurisdiction within Canada where you are located; (b) may be subject to certain restrictions, requirements and limitations, as required or permitted by applicable law; and/or (c) may be subject to providing us with proof of identity, where appropriate. You may contact us, as described below under the “Contacting Us” Section, to submit a request to exercise your rights.

16. UPDATES TO THIS POLICY

We may update this Privacy Policy from time to time. The most recent version of the Privacy Policy is reflected by the version date located at the top of this Privacy Policy. We encourage you to review this Privacy Policy often to stay informed of how we may process your information. If we are required to do so by applicable law, we will also notify you of any material changes to our Privacy Policy that impact your Personal Data, if we have the ability to do so (e.g., if you have an active account, or we have contact information for you) and/or we will obtain your consent to any such changes.

17. CONTACTING US

If you have any questions about this Privacy Policy, please contact us by email at concierge@odelahealth.com