Privacy Policy

1. Introduction

This Privacy Policy (our “Privacy Policy”) supplements the Terms of Service of Telegenix LLC and/or its subsidiaries’ (“Telegenix,” “Company,” “we,” “us,” and “our”) and describes how Company and Medical Groups collect, use, maintain, protect, and disclose Personal Data about you through the use of the Services. By “Personal Data,” we mean information that is personally identifiable to you.

This Privacy Policy explains how Telegenix collects, uses, discloses, and protects information when you visit our websites, create an account, complete an intake, communicate with us, or use our services (collectively, the “Services”). For purposes of this Privacy Policy, references to “Medical Groups” include licensed clinicians and applicable professional medical entities involved in providing telehealth or clinical services through the Services.

Please read this Privacy Policy carefully to understand our policies and practices regarding your Personal Data and how we will treat it. If you do not agree with this Privacy Policy, your choice is to not use the Services. By accessing or using the Services, you agree to this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

This Privacy Policy applies to information we collect about individual consumers, such as general website visitors (“Individuals”) as well as information we collect about the personnel of our business partners, including vendors and business customers, in business-to-business interactions (“Business Contacts”). However, this Privacy Policy does not apply to information about our current/former employees, applicants, and other individuals who interact with us for employment-related purposes. This Privacy Policy also does not apply to data that we handle on behalf of and under the instructions of our business customers (as a processor).

Whenever you interact with us on behalf of another individual or entity, such as if you refer a friend to us, you must obtain their consent (or have the legal authority without consent) to share their Personal Data with us.

2. Protected Health Information

Please see the Medical Groups’ Notice of Privacy Practices to understand how we protect, use and disclose your protected health information as defined under the Health Insurance Portability and Accountability Act of 1996 and related laws and regulations (“HIPAA”). If your Personal Data is protected health information, we treat the protected health information in accordance with HIPAA and the Notice of Privacy Practices. To the extent this Privacy Policy conflicts with our HIPAA obligations or the Notice of Privacy Practices, we comply with HIPAA obligations or the Notice of Privacy Practices.

If you use telehealth or clinical services through the Services, the information you submit may include Protected Health Information (“PHI”). We handle PHI using administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of PHI. We share PHI only as permitted or required to support your care, including with licensed clinicians, pharmacies, labs, and vetted vendors supporting the platform under appropriate agreements. For more detail on PHI uses and disclosures and your HIPAA rights, please also review the applicable Notice of Privacy Practices.

3. Children Under the Age of 18 and Majority

The Services are not intended for children under the age of 18. Children under the age of 18 are strictly prohibited from using the Services. We do not knowingly collect Personal Data from persons who are under the age of 18. If you are under the age of 18, do not use or provide any information on the Services or on or through any of their features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under the age of 18, we will delete that information. If you believe we might have any Personal Data from a child under the age of 18, please contact us at support@telegenix.com.

If you access or use the Services, you represent and warrant that you are either at least 18 years old or otherwise have adequate authority and capacity to consent to use the Services under applicable state laws, federal laws or the authorization of a parent or legal guardian who agrees to be bound by the Terms and this Privacy Policy. If you are under 18 and lack sufficient authority to access or use the Services, do not use or provide any information on the Services.

4. Personal Data We Collect About You

We may collect the following types of Personal Data about you. Except as otherwise specified, we may collect this Personal Data from both Individuals and Business Contacts.

• Identifiers, such as your name, email address, physical address, telephone number, business contact information, and device identifiers (e.g., cookie IDs and IP address). Contact details may include your name, email, phone number, and mailing address.
• Records about you, such as signatures; physical characteristics or a description of you; the content, timing and method of communications you have with us, such as online chats, calls, and emails; and information you share with or upload to our Digital Properties, such as reviews and comments. Communications may include emails, chat messages, support requests, and form submissions.
• Demographic information, such as age (including birthdates) and gender.
• Commercial information, such as information related to your transactions; products or services purchased, obtained, or considered; subscription information; or other purchasing or consuming histories or tendencies. This may include billing address and transaction details. Payment card data is typically processed by a third-party payment processor.
• Internet or other electronic network activity information, such as your browsing history, search history, preference information (including marketing and purchasing preferences), account settings (including any default preferences), and other information regarding your interactions with and use of the Digital Properties. For more information about cookies and other device data, please see the section titled “Personal Data Collected Through and Use of Automatic Data Collection Technologies and Cookies.” This may include device and usage data such as browser type, device identifiers, pages viewed, timestamps, and referring URLs.
• Non-precise geolocation data, such as your location as derived from your IP address.
• Audio, electronic, visual, or other sensory information, such as photographs and audio/video recordings.
• Professional or employment-related information (for Business Contacts), such as job title; organization; professional licenses, credentials, or affiliations; and other professional information.
• Education information (for Business Contacts).
• Inferences drawn from any of the information we collect about your preferences or behavior, including to assess the level of interest in our products and services based on frequency of visits and contact and determine your preferred frequency for receiving offers.
• Sensitive Personal Data, including the following:
  • Social Security number, driver’s license number, or passport number.
  • Account log-in information, login credentials, and profile details.
  • Precise geolocation.
  • Racial or ethnic origin, political opinions, religious or philosophical beliefs, or union membership.
  • Content of mail, email, and text messages where we are not the intended recipient (such as messages that we host as a Controller but are not sent to us).
  • Genetic data.
  • Biometric data processed for the purpose of uniquely identifying you.
  • Information about your health, including health and intake information you submit, such as medical history, symptoms, medications, allergies, vitals, goals, and other information you voluntarily provide.
  • Medical or health insurance information, including insurance policy number.
  • Information concerning your sex life or sexual orientation.
  • Citizenship, citizenship status, or immigration status.

5. How We Collect Your Personal Data

We collect Personal Data about you from the following sources:

• Directly from you. We may collect Personal Data you provide to us directly, such as when you contact us through our Digital Properties; interact with us in person; sign up for offers or newsletters; communicate with us; place or customize orders; or sign up for an account or other services. This includes information you provide when you create an account, complete an intake, submit health or goals information, or otherwise use telehealth or clinical workflows through the Services.
• Data collected automatically and through tracking technologies. We may automatically collect information or inferences about you; such as through cookies and other tracking technologies, when you interact with our Digital Properties. This may include information about how you use and interact with our Digital Properties, information about your device, and internet usage information. For more information about cookies and other tracking technologies, please see the section titled “Personal Data Collected Through and Use of Automatic Data Collection Technologies and Cookies.”
• From third parties. We may collect Personal Data from third parties, such as service and content providers, our affiliated companies and subsidiaries, business partners, data brokers, social media companies or other parties who interact with us. This may include information from service providers that support our platform, such as hosting, analytics, customer support, payment processing, and security providers, and from clinical providers, pharmacies, labs, or other care partners involved in delivering services to you, as applicable.
• From publicly available sources. We may collect Personal Data about you from publicly available sources, such as public profiles and websites.

We may combine information that we receive from the various sources described in this Privacy Policy, including third party sources, and use or disclose the combined information for the purposes identified below.

6. Personal Data Collected Through and Use of Automatic Data Collection Technologies and Cookies

Our Digital Properties and authorized third parties use cookies and other tracking technologies to collect information about you, your device, and how you interact with our Digital Properties. This section contains additional information about:

• The types of tracking technologies we use and the purposes for which we use them
• The types of information we collect using these technologies
• How we disclose or make information available to others
• Choices you may have regarding these technologies

Types of cookies and tracking technologies we use

We and the third parties that we authorize may use the following tracking technologies:

• Cookies, which are a type of technology that install a small amount of information on a user’s computer or other device when they visit a website. Some cookies exist only during a single session and some are persistent over multiple sessions over time.
• Pixels, web beacons, and tags, which are types of code or transparent graphics. In addition to the uses described below, these technologies provide analytical information about the user experience and help us customize our marketing activities. In contrast to cookies, which are stored on a user’s computer hard drive, pixels, web beacons, and tags are embedded invisibly on web pages. Tracking technologies used in connection with the Services may include Google tags or pixels, Google Analytics or advertising tools, Meta Pixel, and other comparable analytics, advertising, or measurement technologies, to the extent enabled.
• Session replay tools, which record your interactions with our Digital Properties, such as how you move throughout our Digital Properties and engage with our webforms. In addition to the uses described below, this information helps us improve our Digital Properties and identify and fix technical issues visitors may be having with our Digital Properties.
• Embedded scripts and SDKs, which allow us to build and integrate custom apps and experiences on our Digital Properties.

Purposes for using these technologies

We and authorized third parties use these technologies for purposes including:

Consistent with the Telegenix website disclosure, these technologies may be used to remember preferences and improve site functionality, understand site usage and performance, secure the site, and prevent abuse.

• Personalization, such as remembering language preferences and pages and products you have viewed in order to enhance and personalize your experience when you visit our Digital Properties;
• Improving performance, such as maintaining and improving the performance of our Digital Properties;
• Analytics, such as analyzing how our websites are used. For example, we use Google Analytics to help us improve the user experience. Google Analytics may use cookies and other tracking technologies to perform their services. To learn how Google Analytics collects and processes data, please visit www.google.com/policies/privacy/partners;
• Advertising, such as conducting advertising and content personalization on our Digital Properties and those of third parties; tracking activity over time and across properties to develop a profile of your interests and advertise to you based on those interests (“interest-based advertising”); providing you with offers and online content that may be of interest to you; and measuring the effectiveness of advertising campaigns and our communications with you, including identifying how and when you engage with one of our emails; and
• Security, such as preventing fraud and malicious behavior.

Information collected

These tracking technologies collect data about you and your device, such as your IP address, location (both approximate and precise) cookie ID, device ID, Ad ID, operating system, browser used, browser history, search history, and information about how you interact with our Digital Properties (such as pages on our Digital Properties that you have viewed).

Disclosures of your information

We may disclose information to third parties or allow third parties to directly collect information using these technologies on our Digital Properties, such as social media companies, advertising networks, companies that provide analytics including ad tracking and reporting, security providers, and others that help us operate our business and Digital Properties.

Your choices

Some of the third parties we work with participate with the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”). The DAA and NAI provide mechanisms for you to opt out of interest-based advertising performed by participating members at http://www.aboutads.info/choices/ and https://optout.networkadvertising.org/. We adhere to the DAA’s Self-Regulatory Principles for Online Behavioral Advertising. You may also click on the AboutAds icon on a Telegenix advertisement and follow the instructions on how to opt out.

You can also refuse or delete cookies using your browser settings. If you refuse or delete cookies, some of our Digital Properties’ functionality may be impaired. Please refer to your browser’s Help instructions to learn more about how to manage cookies and the use of other tracking technologies. If you change computers, devices, or browsers; use multiple computers, devices, or browsers; or delete your cookies, you may need to repeat this process for each computer, device, or browser. Opting out of interest-based advertising will not opt you out of all advertising, but rather only interest-based advertising from us or our agents or representatives.

Some browsers have incorporated Do Not Track (“DNT”) preferences. At this time, we do not honor Do Not Track signals.

7. How We Use or Disclose Your Personal Data

We may disclose Personal Data to third parties, including the categories of recipients described below:

We do not sell your Personal Data for monetary consideration. However, certain disclosures or uses of cookies, pixels, analytics, advertising tools, or similar technologies may be considered a “sale” or “sharing” under some privacy laws, including the CCPA, as described in the California section below.

• Affiliates and subsidiaries, including parent entities, corporate affiliates, subsidiaries, business units, and other companies that share common ownership.
• Service providers that work on our behalf to provide the products and services you request or support our relationship with you, such as IT providers, internet service providers, web hosting providers, data analytics providers, and companies that provide business support services, financial administration, or event organization.
• Clinical providers and care partners, such as licensed clinicians, pharmacies, labs, and other care partners involved in evaluation, prescribing, fulfillment, treatment, or related care coordination, as applicable.
• Professional consultants, such as accountants, lawyers, financial advisors, and audit firms.
• Vendors necessary to complete transactions you request, such as shipping companies and logistics providers.
• Law enforcement, government agencies, and other recipients, when required by law for legal, security, or safety purposes, such as when we share information to comply with law or legal requirements, to enforce or apply our Terms of Service and other agreements or policies; and to protect ours, our customers’, or third parties’ safety, property, or rights.
• Other entities in connection with a corporate transaction, such as if we acquire, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
• Business partners that may use Personal Data for their own purposes, such as:
  • Advertisers, ad platforms and networks, and social media platforms;
  • Third parties whose cookies and tracking tools we use as described in the section titled “Personal Data Collected Through and Use of Automatic Data Collection Technologies and Cookies”;
  • Partners who work with us on promotional opportunities, including co-branded products and services.

Where required by law, we will obtain your consent prior to disclosing your Personal Data to our business partners. Where recipients use your Personal Data for their own purposes independently from us, we are not responsible for their privacy practices or personal data processing policies. You should consult the privacy notices of those third-party services for details on their practices.

• The public, such as when you have an opportunity to make comments regarding us or our products that we may share with the public, including comments on our blog posts and reviews on our product pages. Any Personal Data in comments, reviews, or other content that you share in public areas of our Digital Properties may be read, collected, or used by other users or the public.
• Entities to which you have consented to the disclosure.

We may use Personal Data for the following purposes:

• To provide products and services to you, making our Digital Properties, products and services available to you; such as registering, verifying, and maintaining your account with us; providing and delivering you the goods and services you request; providing customer service; processing or fulfilling orders and transactions (including processing payments); verifying customer information and eligibility for certain programs or benefits; communicating with you (including soliciting feedback or responding to requests, complaints, and inquiries); hosting informational webinars; and providing similar services or otherwise facilitating your relationship with us. This includes facilitating telehealth workflows, such as routing your intake to a licensed clinician for evaluation, coordinating fulfillment if prescribed, and supporting related care, pharmacy, lab, and customer support workflows.
• For our internal business purposes, such as operating our Digital Properties and customizing the content; maintaining internal business records, such as accounting, document management and similar activities; enforcing our policies and rules; management reporting; auditing; and IT security and administration. This also includes monitoring, troubleshooting, and securing our systems.
• For our internal research and product improvement purposes, such as verifying or maintaining the quality or safety of our products or services; improving our products or services; designing new products and services; evaluating the effectiveness of our advertising or marketing efforts; and debugging and repairing errors with our systems, networks, and equipment.
• For legal, safety or security reasons, such as complying with legal, reporting, and similar requirements; investigating and responding to claims against us, our personnel, and our customers; for the establishment, exercise or defense of legal claims; protecting our, your, our customers’, and other third parties’ safety, property or rights; detecting, preventing, and responding to security incidents and health and safety issues (including managing spread of communicable diseases); and protecting against malicious, deceptive, fraudulent, or illegal activity. This also includes processing transactions, preventing fraud, complying with legal or clinical obligations, and enforcing our Terms.
• In connection with a corporate transaction, such as if we acquire, or sell or transfer all or a portion of our business or assets including through a sale in connection with bankruptcy and other forms of corporate change.
• For marketing and targeted advertising, such as marketing our products or services or those of our affiliates, business partners, or other third parties. For example, we may use Personal Data we collect to personalize advertising to you (including by developing product, brand, or services audiences and identifying you across devices/sites); to analyze interactions with us or our Digital Properties; or to send you newsletters, surveys, questionnaires, promotions, or information about events or webinars. You can unsubscribe to our email marketing via the link in the email, or by contacting us using the information in the Contact Information section below.

We may use anonymized, de-identified, or aggregated information for any purpose permitted by law.

8. Choices About How We Use and Disclose Your Personal Data

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for our advertising to you, and other targeted advertising.

We strive to provide you with choices regarding the Personal Data you provide to us. We have the following mechanisms to provide you with control over your Personal Data:

• Tracking Technologies and Advertising. You can set your browser or operating system to refuse all or some cookies or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of the Services may then be inaccessible or not function properly.
• Promotional Offers from Telegenix. If you do not wish to have your email address used by Telegenix to promote our own products and services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or by contacting us. This opt out does not apply to information provided to Telegenix as a result of a Service purchase or your use of our Services.
• Targeted Advertising. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. We do not control third parties’ collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can also opt out of receiving targeted ads from members of the NAI on its website.

We do not control the collection and use of your information collected by third parties as described in our Terms. These third parties may aggregate the information they collect with information from their other customers for their own purposes.

9. Communications Preferences (Email/SMS)

You may opt out of promotional emails by using the unsubscribe link included in the email or by contacting us at support@telegenix.com. If you receive SMS messages from us, you may opt out by replying STOP. Message and data rates may apply. Service, account, care-related, transactional, or administrative messages may still be sent when necessary.

10. Your Rights Regarding Your Personal Data

You can review and change your Personal Data by logging into the Services and changing your Account information. You may also contact us at support@telegenix.com regarding any of your rights under applicable state laws; any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible; or to delete your Account. We may not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect. Depending on your location and the nature of your relationship with us, you may have rights to request access to or a copy of your information, request correction of inaccurate information, request deletion subject to legal and clinical retention obligations, object to or restrict certain processing where applicable, and withdraw consent where processing is based on consent. HIPAA rights for PHI are described in the applicable Notice of Privacy Practices.

See state-specific sections below on your rights under specific state laws.

11. Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. The safety and security of your information also depends on you. Where you have chosen a password for the use of the Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. We use encryption technology for information sent and received by us.

Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to the Services. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Services or in your operating system.

12. Data Retention

We retain Personal Data for as long as needed to provide the Services, maintain required business records, comply with legal and clinical obligations, resolve disputes, and enforce agreements. Retention periods may vary depending on the type of information and applicable requirements. When it is no longer necessary to retain Personal Data, we will delete or anonymize it in accordance with applicable law.

13. California Individuals

For individuals in California, you have rights under the California Consumer Privacy Act of 2018. Please see additional information below that is intended to satisfy our obligations under the CCPA to disclose certain information to you.

Personal Information We Collect About You. In the preceding 12 months, we have collected the following categories and specific types of consumer personal information:

How Your Personal Information is Collected. We collect most of this personal information directly from you—in person, by telephone, text or email and/or via our website and apps. See How We Collect Your Personal Data and Personal Data Collected Through and Use of Automatic Data Collection Technologies.

Why We Use Your Personal Information. We collect and/or share consumer personal information for the business purposes described in How We Use or Disclose Your Personal Data.

Who We Share Your Personal Information With. In the preceding 12 months, we have sold or shared consumers’ personal information as described in Disclosure of your Personal Data.

Categories of Personal Information We Sold or Shared. In the preceding 12 months, we have sold or shared the following categories of personal information: identifiers; Information that identifies, relates to, describes, or is capable of being associated with, a particular individual as described in Disclosure of your Personal Data. While we do not intentionally sell your personal information for monetary consideration, it is possible that some of our data sharing practices could be deemed a sale under the CCPA.

Categories of Personal Information We Disclosed for a Business Purpose. In the preceding 12 months, we have disclosed the following categories of personal information for a business purpose: identifiers; Information that identifies, relates to, describes, or is capable of being associated with, a particular individual as described in Disclosure of your Personal Data.

How Long Your Personal Information Will Be Kept. We will keep your personal information while you have an account with us or while we are providing Services to you. Thereafter, we will keep your personal information for as long as is necessary:

• To respond to any questions, complaints or claims made by you or on your behalf;
• To show that we treated you fairly; or
• To keep records required by law.

We will not retain your personal information for longer than necessary for the purposes set out in this policy. Different retention periods apply for different types of personal information.

When it is no longer necessary to retain your personal information, we will delete or anonymize it.

Your Rights Under the CCPA. You have the right under the California Consumer Privacy Act of 2018 (CCPA), and certain other privacy and data protection laws, as applicable, to exercise free of charge:

How to Exercise Your Rights. If you would like to exercise any of your rights as described in this Privacy Policy, you can do so by contacting us at support@telegenix.com.

Please note that you may only make a CCPA-related data access or data portability disclosure request twice within a 12-month period.

To exercise your rights, you will need to provide us with:

• Enough information to identify you (e.g., your full name, address, and account information);
• Proof of your identity and address (e.g., a copy of your driving license or passport and a recent utility or credit card bill); and
• A description of what right you want to exercise and the information to which your request relates.

We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

Any personal information we collect from you to verify your identity in connection with your request will be used solely for the purposes of verification.

14. Individuals in Other States

You may have rights under other state consumer privacy laws, including Colorado, Connecticut, Oregon, Texas, Utah, and Virginia. Please contact us at support@telegenix.com if you have questions or would like to exercise a right under these laws.

15. International Users

The Services are controlled and operated by us from the United States and are not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States. Any information you provide to us through use of the Services may be stored and processed, transferred between and accessed from the United States and other countries that may not guarantee the same level of protection of personal data as the one in which you reside. However, we will handle your Personal Data in accordance with this Privacy Policy regardless of where your Personal Data is stored/accessed.

16. Changes to Our Privacy Policy

We may change this Privacy Policy at any time. If we make material changes to how we treat our Users’ Personal Data, we will notify you by email to the email address specified in your account and/or through a notice on the Services’ home page and invite you to review (and accept, if necessary) the changes. The date this Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you and for periodically visiting the Services and reviewing this Privacy Policy to check for any changes.

17. Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below:

Telegenix LLC
7957 N University Dr Suite 160
Parkland, FL 33067
support@telegenix.com