Privacy Policy

Last updated: September 6, 2024

Freeley Health LLC (DBA Freeley) (“Freeley Health LLC (DBA Freeley),” “we,” “us,” or “our”) respects your privacy and is committed to protecting it though compliance with this Privacy Policy. This Policy describes the types of information we may collect from you or that you may provide when you visit our Site or use our Services, and our practices for collecting, using, maintaining, protecting and disclosing that information. We also describe the measures we take to protect the security of the information and how to contact us about our privacy practices.

This Privacy Policy is part of and incorporated into the Terms and Conditions, found at Terms and Conditions which is a legally binding agreement between you and Freeley Health LLC (DBA Freeley).

Please review this Privacy Policy carefully. If you do not agree with our policies and practices, you may choose not to use our Site or our Services. By accessing and using the Site or our Services, you accept and agree to this Privacy Policy, whether or not you register for an account through the Site.

Personal Information We Collect: “Personal Information” is any information relating to a natural person who is, or can be, identified either directly or indirectly from such information and includes information such as a user’s name, address, telephone number, email address, Internet activity (such as browsing history), or other information directly linked to that person. We collect Personal Information when you register on our Site, use our Services, and when you choose to provide information through our Site. The types of Personal Information you may provide include:

Contact information (e.g., name, postal address, email address, and phone number); Demographic information (e.g., date of birth, gender); Physical attributes (e.g., height, weight); Medical history; Lifestyle information (e.g., smoking and drug use); Payment information (e.g., payment card number, expiration date, and billing address); Photographic images submitted for identification or non-diagnosis purposes, including photographs of your driver’s license or passport; Username and password. In addition, when you visit our Site, we may collect certain Personal Information by automated means, such as cookies and web beacons. The information we obtain in this manner includes: IP address; browser characteristics; device characteristics; operating system; referring URLs; geographic location; information on actions taken on our Site; and dates and times of website visits. A “cookie” is a text file that websites send to a visitor’s computer or other Internet-connected device to uniquely identify the visitor’s browser or to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Through these automated collection methods, we obtain “clickstream data,” which is a log of content on which a visitor clicks while browsing a website.

As you click through the Site, a record of the action may be collected and stored. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Site.

Finally, the Medical Practices are regulated as “covered entities” under the Health Insurance Portability and Accountability Act (“HIPAA”). Please be aware that this Privacy Policy id distinct from the Medical Practices’ Notice of Privacy Practices, which describes in detail how your protected health information is used and disclosed. If you would like to review a copy of the Medical Practices’ Notice of Privacy Practices, please request a copy directly from your Provider.

Some of our business partners with whom we contract to carry out the Services (e.g., website providers) may use their cookies on our Site. Although we may not have direct access to or control over such cookies, this Privacy Policy governs the use of cookies by us and such business partners on our Site. We may also allow social media companies (e.g., Facebook) to put “widgets” on our websites. These third-party tools may also be used to track you across websites. For example, so long as you are logged in to Facebook, every time you land on a webpage that has a Facebook widget, Facebook will know you are on that webpage. We do not control the privacy practices of these third parties.

Some internet browsers allow you to limit or disable the use of tracking technologies that collect unidentified information, such as a “Do Not Track” (“DNT”) setting. Currently, we do not respond to DNT signals.

How We Use the Personal Information We Collect Freeley Health LLC (DBA Freeley) may use the Personal Information we collect to:

create and manage your account; offer and provide information and Services to you; display content on the Site; facilitate telehealth and related services; communicate with you about, and administer your participation in, surveys, events, programs, newsletters, promotions and other Site features; respond to and communicate with you about your inquiries and requests, and provide Services, information, and products you request; send periodic emails to market and promote our products and Services and for non-marketing or administrative purposes; operate, evaluate and improve our business (including developing new products and services; enhance and improve our Services; manage our communications; analyze our products; conduct targeted advertising for our products; perform accounting, auditing, billing reconciliation and collection activities and other internal functions); perform data analyses and processing (including market and consumer research, trend analysis, financial analysis, anonymization, encryption and tokenization of personal information); protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and comply with and enforce applicable legal requirements, relevant industry standards and our policies. In addition, we may use Personal Information collected online through cookies, web beacons and other automated means for purposes such as: (i) customizing our users’ visits to our Site; (ii) delivering content tailored to our users’ interests and the manner in which our users browse our Site; and (iii) managing our business. We may also use this information to help diagnose technical and service problems, administer our Site, identify users of our Site, and gather demographic information about our users. We may use clickstream data to determine how much time users spend on web pages of our Site, how users navigate through our Site, and how we may tailor our Site to better meet the needs of our users.

We may use third party service providers to assist us in better understanding our Site visitors. These service providers use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the Site. The information collected through these means (including IP address) is disclosed to these service providers, who use the information to evaluate use of the Site.

Personal Information We Share: We do not sell, trade, or otherwise share Personal Information about you, except as described in this Privacy Policy. We may share your Personal Information with third party health care providers to provide you with health care services as part of our Services and for other treatment, payment, and health care operations purposes. We may share Personal Information with other third parties, including health care organizations and pharmacies, who perform services on our behalf. These third parties are not authorized by us to use or disclose the Personal Information except as necessary to perform services on our behalf or comply with legal requirements. We also may share the Personal Information we obtain with our affiliates, subsidiaries and partners.

We may disclose Personal Information about you:

If we are required to do so by law or legal process; to law enforcement authorities or other government officials based on a lawful disclosure request; when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity; when you authorize us to do so. We reserve the right to transfer any information we have about you in the event we sell, transfer, or merge all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

Aggregate and De-identified Information: We sometimes aggregate or de-identify Personal Information we collect, and the types of systems and browsers of users for internal purposes, so that we may better understand the Freeley Health LLC (DBA Freeley) user population. Personal Information does not include “aggregate” or “de-identified” information. Aggregate or de-identified information is data we collect about a group of users, from which individual identities have been removed. In other words, information about how you use the Services, or the results of such use, may be collected and combined with similar information from others, but no Personal Information will be included in the resulting aggregate or de-identified data. We can extract statistical data from your content in order to provide it to other users or partners without connecting it to any personal data such as name or email address. Aggregate or de-identified data helps us understand trends and user needs so that we can better consider new products and services, and tailor existing products and services to customer desires. You understand that we may commercialize aggregate or de-identified information by any and all means, and that you will receive no payment or other consideration in respect of such use. In addition, we may share and disclose aggregate or de-identified information for any purpose.

Personal Information Retention: We are subject to multiple laws on the retention of Personal Information and will retain your Personal Information, even if you have closed your account, for as long as is reasonably necessary to comply with our business and legal obligations, meet regulatory requirements, resolve disputes, maintain security, prevent fraud and abuse, or fulfill your request to “unsubscribe” from further messages from us. Similarly, our third party partners may retain your Personal Information for as long as is necessary for them to comply with their legal and business obligations.

How We Protect Your Personal Information: We take reasonable and appropriate measures to protect your Personal Information from accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We implement certain physical, administrative, and technical safeguards that are designed to protect the integrity and security of your Personal Information.

Unfortunately, no methods used to transmit Personal Information via the internet or methods of data storage are completely secure. Although we do our best to protect your Personal Information, we cannot guarantee that Personal Information may not be accessed, disclosed, altered, or destroyed by a breach of any of our physical, technical, or administrative safeguards. Any transmission of information is at your own risk. You agree that Freeley Health LLC (DBA Freeley) is not liable for the unauthorized release of your Personal Information, unless such release was the result of gross negligence or willful misconduct on the part of Freeley Health LLC (DBA Freeley).

The safety and security of your Personal Information also depends on you. You are responsible for maintaining the confidentiality of your password and account, and are fully responsible for all activities that occur under your password or account. You should not share your password with anyone. When accessing your account from a public or shared computer, you should use particular caution so that others are not able to view or record your password or your other information. Please notify Freeley Health LLC (DBA Freeley) immediately of any unauthorized access or use of the Site or the loss or unauthorized use of your account information (e.g., username or password).

Links to Other Websites: Our Site may provide links to other websites for your convenience and information. These websites are not operated or controlled by us and may have their own privacy policies, which we strongly suggest you review if you visit any linked websites. We are not responsible for the content, privacy policies, or practices of any third parties. Where possible, we will warn you when you are leaving our Site and connecting to a site operated by a third party.

Age and Geographic Restriction: Our Site is intended for individuals who are 18 years of age or older. Freeley Health LLC (DBA Freeley) will never knowingly request information from anyone under the age of 18. Any person who provides their information through the Site represents that they are 18 years of age or older.

Freeley Health LLC (DBA Freeley) is concerned about the safety and privacy of children online. Because of this, we will make all efforts to comply with the Children’s Online Privacy Protection Act of 1998 (“COPPA”). COPPA and its accompanying FTC regulations establish United States federal law that protects the privacy of children using the internet. We do not and will not knowingly contact or collect Personal Information from children under 13. Our Site is not intended to solicit information of any kind from children under 13, and we will develop our Site with the capacity to block acceptance of information from children under 13 whenever age-related information is requested.

It is possible that by fraud or deception by others we may receive Personal Information given to us or pertaining to children under 13. If you believe the information of anyone under the age of 13 has been provided to Freeley Health LLC (DBA Freeley), and you are the parent or guardian of that individual, you may contact us to request that we delete any such information, at Info@Freeley.com.

Our Site is intended to comply with the laws and regulations of the United States of America. We make no representations that our Site is appropriate or available for use in any location outside of the United States. If you are a resident of another country, or are accessing the Site from outside of the United States, please note that you are transferring your data to the United States of America which does not have the same data protection laws as the European Union and other regions.

Consent to Communications: By using the Services and providing your contact information, such as your name, phone number, and email address, you consent to receiving emails, phone calls, and text messages to tell you about our Services, such as important information about your requested Service(s) and reminders to log back in to complete surveys and forms that you left incomplete. We may share your contact information with partner organizations whose products or services are important for our Service objectives. For example, we may provide your contact information to third parties that assist Freeley Health LLC (DBA Freeley) with hosting our databases, for data processing services, or so they can contact you with information that you requested as part of the Services. However, we do not exchange, trade, rent, or give phone or email lists to unaffiliated third parties, and third parties that receive your contact information from Freeley Health LLC (DBA Freeley) are restricted from using this information in any way other than to provide services to Freeley Health LLC (DBA Freeley), or services for a collaboration in which they and Freeley Health LLC (DBA Freeley) are engaged. You may opt-out from receiving email communications at any time by emailing Info@Freeley.com. You may opt out from receiving text message communications at any time by replying to the text message with “STOP”. At that time, we will send a final text message confirming receipt of your opt-out notification. Opt-out requests will be honored promptly.

Your Choices Your use of our Site and Services is voluntary. We offer you certain choices about how your Personal Information is collected, used, and shared, from deleting or correcting Personal Information you include in your profile to advertising opt-outs and communication controls. You can review and change your preferences by logging into your account. You may also update your preferences, remove your Personal Information, or deactivate your account at any time.

You can review and change your Personal Information by contacting us at Info@Freeley.com to request access to correct or delete any Personal Information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

Notice for California Residents: If you are a California resident, this section supplements the information above regarding the collection, use, and disclosure of your Personal Information.

The California Consumer Privacy Act of 2018 (“CCPA”) gives California consumers the right to know what Personal Information is collected about them, how it will be used and to whom it is disclosed. The CCPA gives California consumers the right to request access to and deletion of their Personal Information, and the right to request that their Personal Information not be sold to the extent applicable under the CCPA.

The purpose of this notice is to describe our practices regarding the collection, use, disclosure, and sale of Personal Information and instructions for submitting CCPA data privacy requests. Some of the Personal Information that we collect, use, and disclose may be exempt from the CCPA because it is regulated by other federal and state laws that apply to us.

We collect Personal Information from you when you interact with us online through our Site. The Personal Information we may collect from you will depend on the nature of our interaction with you. In the last 12 months, we have collected the following categories (as described in the CCPA) of Personal Information: identifiers, protected classification information, commercial information, internet/network information, geolocation data, audio and visual information, professional or employment information, and inferences drawn from the foregoing categories of information to create a profile about you. For further details, see the “Personal Information We Collect” section above. We collect this information for the purposes described in the “How We Use the Personal Information We Collect” and “Personal Information We Share” sections above.

Your Rights

The CCPA provides you (as a California resident) with specific rights, subject to certain exceptions.

Right to Know: You have the right under the CCPA to request that we disclose what Personal Information we collect, use, disclose, and sell. The process for exercising this right is described below in the “How to Submit a Data Privacy Request” section. Please note that we may not be required to provide you access to the specific pieces of information we have collected about you or delete information if we are unable to verify your identity. Right to Deletion. You have the right under the CCPA to request deletion of any Personal Information about you that we have collected from you. The process for exercising this right is described below under the “How to Submit a Data Privacy Request” section. We may not be required to delete Personal Information under certain circumstances. Specifically, the CCPA includes exemptions that provide that we do not have to delete information that, for example, is necessary to comply with legal obligations including those pertaining to the quality, safety or effectiveness of a product or activity regulated by the Food and Drug Administration (FDA), complete a transaction, detect security incidents, or for certain other internal purposes. Right to Opt-Out. You have the right under the CCPA to opt-out of the sale of your Personal Information. The CCPA defines “sale” broadly to include sharing, transferring, disclosing or otherwise communicating Personal Information with a third party for monetary or other valuable consideration. We do not sell your Personal Information. Right to Non-Discrimination. You have the right under the CCPA not to be discriminated against for exercising your rights. 1. How to Submit a Data Privacy Request You may exercise your Right to Know and Right to Deletion by emailing us at Info@Freeley.com or by calling us at . To process your request to exercise your Right to Know and Right to Deletion, we must be able to verify your identity to a reasonable degree of certainty. To verify your identity, we will ask you to provide your contact information and additional identifiers based on your relationship with us. Before we process your request, we will match these data points with data points we currently maintain to verify your identity and your relationship with us.

You may designate an authorized agent to make a request to exercise your Right to Know or Right to Deletion on your behalf. When you use an authorized agent to submit such a request, you must provide the authorized agent with written permission to do so, and, in certain circumstances, we may ask you to verify your own identity directly with us. We may deny a request from an authorized agent that does not submit proof that they have been authorized by you to act on your behalf.

Changes to Our Privacy Policy: At our sole discretion, we may make changes to this Privacy Policy at any time. When changes are made, we will post an updated Privacy Policy on our Site. The changes will apply to all Personal Information we have about you. All changes are effective immediately upon posting; the date the Privacy Policy was last revised is identified at the top of the page. If you access and use our Site or Services after the date on which the Privacy Policy has changed, Freeley Health LLC (DBA Freeley) will treat your use as acceptance of the updated Privacy Policy. You are expected to check this page from time to time so you are aware of any changes, as they are binding on you.

Questions and Comments: Freeley Health LLC (DBA Freeley) commits to resolve questions and comments about your privacy and our collection and use of your information. Individuals with inquiries or comments should contact Freeley Health LLC (DBA Freeley) at: Info@Freeley.com.

Freeley Health LLC (DBA Freeley)

When you visit or log in to our website, cookies and similar technologies may be used by our online data partners or vendors to associate these activities with other personal information they or others have about you, including by association with your email or home address. We (or service providers on our behalf) may then send communications and marketing to these email or home addresses.