Privacy Policy

MOBILE APP PRIVACY POLICY 
CONVEY HEALTH SOLUTIONS, INC.
Last Updated: May 22, 2019
 
CONVEY HEALTH SOLUTIONS, INC., (“we” or “us” or “our”) respects the privacy of our users (“user” or “you”). This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you visit our mobile application (the “Application”) for our Over-the-Counter (“OTC”) products. Please read this Privacy Policy carefully. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY POLICY, PLEASE DO NOT ACCESS THE APPLICATION. 

DO NOT USE THIS APP OR ITS DIGITAL SERVICES FOR MEDICAL EMERGENCIES. CALL 911 IMMEDIATELY IF YOU EXPERIENCE A MEDICAL EMERGENCY, OR HAVE SOMEONE TAKE YOU TO AN EMERGENCY ROOM IF YOU OR ANOTHER PERSON NEEDS IMMEDIATE MEDICAL ASSISTANCE. YOU AGREE THAT WHS IS NOT RESPONSIBLE OR LIABLE IN ANY WAY FOR ANY DELAYS OR BARRIERS TO CARE ACCESS AND/OR TREATMENT CAUSED BY USE OF THIS APP, AND THAT WHS NOT BE HELD RESPONSIBLE FOR ANY DAMAGES ARISING FROM USE OF THIS APP. IF YOU’RE DISSATISFIED WITH THIS APP, YOUR SOLE REMEDY IS TO STOP USING IT.

This App is not a substitute for medical advice and does not imply the delivery of medical advice or any assistance with any type of diagnosis. Users should not use the App as a substitute for a consultation with a healthcare provider.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the “Last updated” date of this Privacy Policy. You are encouraged to periodically review this Privacy Policy to stay informed of updates. You will be deemed to have been made aware of, will be subject to, and will be deemed to have accepted the changes in any revised Privacy Policy by your continued use of the Application after the date such revised Privacy Policy is posted. 

This Privacy Policy does not apply to the third-party online/mobile store from which you install the Application , which may also collect and use data about you. We are not responsible for any of the data collected by any such third party.

COLLECTION OF INFORMATION
We may collect information about you in a variety of ways. The information we may collect via the Application depends on the content and materials you use, and includes: 

Derivative Data
Information our servers automatically collect when you access the Application, such as your native actions that are integral to the Application, including liking, re-blogging, or replying to a post, as well as other interactions with the Application and other users via server log files. 

Geo-Location Information
We may request access or permission to and track location-based information from your mobile device, either continuously or while you are using the Application, to provide location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Access
We may request access or permission to certain features from your mobile device, including your mobile device’s [bluetooth, calendar, camera, contacts, microphone, reminders, sensors, SMS messages, social media accounts, storage,] and other features. If you wish to change our access or permissions, you may do so in your device’s settings.

Mobile Device Data
Device information such as your mobile device ID number, model, and manufacturer, version of your operating system, phone number, country, location, and any other data you choose to provide.

Third-Party Data
Information from third parties, such as personal information or network friends, if you connect your account to the third party and grant the Application permission to access this information


USE OF YOUR INFORMATION
Having accurate information about you permits us to provide you with a smooth, efficient, and customized experience. Specifically, we may use information collected about you via the Application to:
  1. Assist law enforcement and respond to subpoena.
  2. Compile anonymous statistical data and analysis for use internally or with third parties. 
  3. Create and manage your account.
  4. Email you regarding your account or order.
  5. Fulfill and manage purchases, orders, and other transactions related to the Application.
  6. Generate a personal profile about you to make future visits to the Application more personalized.
  7. Increase the efficiency and operation of the Application.
  8. Monitor and analyze usage and trends to improve your experience with the Application.
  9. Notify you of updates to the Application.
  10. Perform other business activities as needed.
  11. Prevent fraudulent transactions, monitor against theft, and protect against criminal activity.
  12. Request feedback and contact you about your use of the Application. 
  13. Resolve disputes and troubleshoot problems.
  14. Respond to product and customer service requests.
  15. Required by law.
  16. Requests from a government agency or investigatory body. 
DISCLOSURE OF YOUR INFORMATION
We may share information we have collected about you in certain situations. Your information may be disclosed as follows: 

By Law or to Protect Rights
If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction.

Third-Party Service Providers
We will not share your information with third party with any third party outside of our organization, other than the sponsoring health plan and as necessary to fulfill your request. However, we may have third party service providers that perform services for us or on our behalf, including data analysis, email delivery, hosting services and customer service., which is facilitated through our OTC member portal. 

The Application does not directly provide Convey Health Solutions, Inc. with any protected health information (PHI”) about a user. If you decide to access such third party sites or other third party tools through the Application, please note that you leave the Application, and be subject to the terms, conditions and policies with those applications, and those applications may provide Convey Health Solutions, Inc with PHI.

Affiliates
We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

TRACKING TECHNOLOGIES
Cookies and Web Beacons
We may use cookies, web beacons, tracking pixels, and other tracking technologies on the Application to help customize the Application and improve your experience. When you access the Application, your personal information is not collected through the use of tracking technology. Most browsers are set to accept cookies by default. You can remove or reject cookies, but be aware that such action could affect the availability and functionality of the Application. You may not decline web beacons. However, they can be rendered ineffective by declining all cookies or by modifying your web browser’s settings to notify you each time a cookie is tendered, permitting you to accept or decline cookies on an individual basis.

Website Analytics 
We may also partner with selected third-party vendors to allow tracking technologies and remarketing services on the Application through the use of first party cookies and third-party cookies, to, among other things, analyze and track users’ use of the Application, determine the popularity of certain content, and better understand online activity. By accessing the Application, you consent to the collection and use of your information by these third-party vendors. You are encouraged to review their privacy policy and contact them directly for responses to your questions. We do not transfer personal information to these third-party vendors. However, if you do not want any information to be collected and used by tracking technologies, you can install and/or update your settings for one of the following: 
  • [Adobe Privacy Choices Page]
  • [Clicktale Opt-Out Feature]
  • [Crazy Egg Opt-Out Feature]
  • Digital Advertising Alliance Opt-Out Tool
  • [Flurry Analytics Yahoo Opt-Out Manager]
  • [Google Analytics Opt-Out Plugin] 
  • [Google Ads Settings Page]
  • [Inspectlet Opt-Out Cookie]
  • [Kissmetrics Opt-Out Feature]
  • [Mixpanel Opt-Out Cookie]
  • Network Advertising Initiative Opt-Out Tool 
You should be aware that getting a new computer, installing a new browser, upgrading an existing browser, or erasing or otherwise altering your browser’s cookies files may also clear certain opt-out cookies, plug-ins, or settings.

SECURITY OF YOUR INFORMATION
We use administrative, technical, and physical security measures to protect your personal information and reduce the risk of loss or misuse. While we take reasonable steps to secure the personal information you provide to us, please be aware that despite our efforts, Internet data transmissions cannot be guaranteed against interception or potential misuse. 
 
POLICY FOR CHILDREN
We do not knowingly solicit information from or market to children under the age of 13. If you become aware of any data we have collected from children under age 13, please contact us using the contact information provided below.
 
CONTROLS FOR DO-NOT-TRACK FEATURES
Most web browsers and some mobile operating systems [and our mobile applications] include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

OPTIONS REGARDING YOUR INFORMATION
Account Information
You may at any time review or change the information in your account or terminate your account by:
● Logging into your account settings and updating your account
● Contacting us using the contact information provided below
Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.]

Emails and Communications
If you no longer wish to receive correspondence, emails, or other communications from us, you may opt-out by:
● Noting your preferences at the time you register your account with the Application;
● Logging into your account settings and updating your preferences;
● Opting out of emails once received;
● Contacting us using the contact information provided below.

If you no longer wish to receive correspondence, emails, or other communications from third parties, you are responsible for contacting the third party directly.


CALIFORNIA PRIVACY RIGHTS
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Application, you have the right to request removal of unwanted data that you publicly post on the Application. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Application, but please be aware that the data may not be completely or comprehensively removed from our systems.
 
CONTACT US
If you have questions or comments about this Privacy Policy, please contact us at:

Convey Health Solutions, Inc
100 SE 3rd Avenue Ste 2600
Fort Lauderdale, FL 33394
(954) 903-5057
complianceofficer@conveyhs.com