Introduction

 

QC-Health, Inc. (“QC-Health” or the “Company”) is affiliated with Aventria Health Group (“Aventria”). Data collected through the Platform (as defined below) may be shared between these affiliated entities for the purposes described in this Privacy Policy, including Platform analytics and provider-level data derived from Notification Program activity; QC-Health is the controller of data collected through the Platform and notification programs. The Company and Aventria are implementing an intercompany data sharing agreement that restricts Aventria’s use of any shared data to specified business purposes and prohibits the sale or re-sharing of such data. Platform analytics shared with Aventria are provided at an aggregated level. Where provider-level information (for example, at the National Provider Identifier (NPI) level) is made available to Aventria, it is processed only for the purposes described in this Privacy Policy and is not sold or further shared.

 

You are required to affirmatively agree to this Privacy Policy before you have permission to use the Platform.

 

1. What Is the Scope of this Statement? This Privacy Policy sets forth the principles under which the Company collects, uses, processes, retains, and discloses personal data and/or sensitive data in the United States from individuals, including by and through our websites located at https://www.qc-health.org, https://www.qsasupport.com, and https://www.ogesupport.com, including use of any “Search” function, our Blog, our Webinars, and any mobile or desktop application (together, the “Website”), our ReCaptRx™, SignalTx™, QSA™, and Outcome Guided Engagement® notification and clinical-information programs (the “Notification Programs”), and any communications we deliver via email, fax, SMS/MMS text message, electronic health record (“EHR”) message, or FHIR-based message (collectively, “Electronic Communications”), (the Website, the Notification Programs, and the Electronic Communications are collectively referred to as the “Platform”), and information you provide to us based upon information from the Platform (i.e., if you send us an e-mail at an e-mail address identified on the Website) or through the Platform (i.e., using the Contact Us form, registering for a Notification Program, or other information provided on or through the Platform). This Policy covers information received in electronic and all other formats.

 

The Platform and our services are intended for use by healthcare providers and their authorized staff located in the United States. We do not knowingly collect or process personal data from individuals located in the European Economic Area, the United Kingdom, or Switzerland. Please do not visit or use the Platform from any of these jurisdictions.

 

This Privacy Policy does NOT apply to other websites to which we may otherwise link, or to other companies, third-party vendors who provide services to us, or entities who might be listed as third-party contacts on the Platform, each of which may be governed by their own privacy policies. This Privacy Policy also does not apply to information we may obtain from other sources about you. By using the Platform and/or by contacting us and providing any personal information, you consent to the collection, transfer, storage, disclosure, and use of information by us in accordance with this Privacy Policy. If we decide to change our Privacy Policy, we will post those changes on this page.

 

2. Terms

 

The terms “we”, “us” and “our” refer to the Company, and its officers, directors, owners, employees and agents.

 

The term “Healthcare Provider” or “HCP” means a physician, pharmacist, nurse, or other credentialed healthcare professional who registers for or uses the Platform or any Notification Program, and includes authorized members of such provider’s care team (each, a “Care Team” member).

 

The term “personal data” means any data which relates to a natural person (as opposed to a business or corporate entity) that makes you identifiable. As used herein and in connection with our business, the term personal data may include:

 

• Names and contact information, including phone number, physical address, fax and e-mail, all only to the extent provided by you (or on your behalf) to us;

 

• Your NPI number;

 

• Your password if you create an account with us;

 

• Any information you provide to us through our “Contact Us” page on the Website (whether such information is provided through the Website, submitted by mail or by calling one of the phone numbers listed on the Website);

 

• Any information you provide to us by signing up for our Webinar Series on the Website;

 

• Any information you provide to us on or through any of our social media pages as linked on the Website, including but not limited to LinkedIn, Facebook, or Twitter/X;

 

• Any information you provide by using the “Apply Now” button for any positions with us through the Website or other information you provide to us if you seek employment through the Website;

 

• Any information you provide to us by using the “Apply Now” button to be considered for our Board of Clinical Advisors;

 

• Any comments you submit to any Blog posting on the Website;

 

• Your web browser, IP address, approximate geolocation derived from your IP address, time zone, cookie information, what search terms you use and how you interact with the Platform;

 

• Any information you provide to us in response to communications from us;

 

• Your communication channel preferences (e.g., email, fax, SMS, EHR) and Notification Program selections (e.g., therapeutic categories, notification types);

 

• Your Care Team designations, including names and contact information of Care Team members you authorize to receive notifications on your behalf;

 

• Interaction data from Electronic Communications we deliver to you, including opens, clicks, and delivery confirmations;

 

• Any other similar information provided to us by you in connection with our services or through the Platform.

 

The term “processing” means any operation or set of operations performed on personal data. Processing includes, but is not limited to, the collection of data, the organizing of data, the recording or saving/storage of data, the altering of data, the using of data, the disclosing or transfer of data, the deleting or destruction of data, or the making available of data.

 

3. What Information We Collect About You

 

We may collect all types of personal data about you as described in Section 2 above under the definition of “personal data.”

 

You agree that we may collect and process all such personal data that you provide to us, or that you make publicly available, to market and provide our services, and provide the information identified and contained on the Platform, and to provide services related thereto (collectively, the “Services”). In addition, these Services may also include Services in connection with the use and management of the Platform and all content and services therein.

 

You also hereby consent that we may use your personal data for the following additional purposes which may be included in, or part of, the Services:

 

• Updating our records;

• In connection with any application for employment with the Company;

• Internal analysis for our business management purposes;

• Any statutory or regulatory purpose which requires the processing of your personal data;

• Legal and regulatory compliance;

• Fraud and crime prevention;

• Internal or external audits; and

• Any other purpose for which valid consent is obtained.

 

Please do not supply the following to us:

 

• Notifications and data transmitted through the Platform do not contain patient-level Protected Health Information (“PHI”) as defined under the Health Insurance Portability and Accountability Act (“HIPAA”) or the Health Information Technology for Economic and Clinical Health Act (“HITECH”). All prescription-event data is received by the Company in de-identified form from licensed data sources, and the Company is contractually prohibited from re-identifying, or attempting to re-identify, such data. Accordingly, in submitting any information to the Company or through the Platform, you may NOT:

 

• Submit any of your, or any third-party individual’s, “Protected Health Information,” which includes demographic information, medical histories, test or laboratory results, mental health conditions, insurance information, or other personal data that a healthcare professional collects or may collect to identify an individual and determine appropriate care; nor

 

• Submit any other information which may be, or may be used to specifically identify, any Protected Health Information of an individual. For example, you may be able to seek information on the Application concerning a particular medical condition, but you should not ever state whether you or any other identified individual suffers from or does not suffer from such medical condition.

 

• Any other person’s personal data, unless the Company explicitly asks you to do so;

 

• Any categories of your personal data that have not been explicitly requested by the Company;

 

• Any confidential, proprietary, secret or legally protected information which you are not explicitly requested by the Company to provide;

 

• Any false or misleading information; or

 

• Any confidential, proprietary, secret or legally protected information which are under any legal obligation to not provide to or share with the Company.

 

4. How We Collect Information About You

 

We collect information about you (including personal data) when:

 

• You Give Us Information.

 

• We Collect Information Automatically – We automatically collect certain types of information when you visit our website (as explained below).

 

We Collect Information From Other Sources – We may also obtain information about you from outside sources. For example, we may obtain commercially available information about you from third-parties, including publicly available data from the CMS National Provider Directory (NPPES). We may also receive information from third-parties who provide services for us through web-beacons and other technologies described in this Privacy Policy.

 

5. Use of Cookies

 

We use cookies and similar technologies on the Website. Our cookie consent banner identifies the cookies used on the Website and allows you to adjust your cookie preferences at any time. Our Cookie Notice, available at https://www.qc-health.org/cookie-notice, describes the categories of cookies we use, the purposes for which we use them, the service providers and vendors that place cookies through the Website, our use of mobile advertising identifiers, and how you can manage cookies through your browser or device settings. Rejecting non-essential cookies does not by itself exercise your rights under applicable state privacy laws; please see “Providing Your Personal Data To Others” and “Your Rights” below for information about our sharing practices and the opt-outs available to you.

 

6. Search Queries on Our Website

 

We may provide you with options to search for information on our Website. If you enter information in a search query box, we may store that information and we may aggregate that information with other information we may have about the browser and/or IP address from which the search query originated.

 

7. Social Media Platforms

 

We may link to certain Company social media platforms on Twitter/X, LinkedIn, Facebook and/or other platforms. When you engage with our content at or through these social media platforms, you may be asked to share certain information about these interactions with us. Please review the privacy policies/notices and privacy settings with each such social media platform you use so you understand how this data and information may be used, and to choose your options for the sharing of such data and information.

 

8. How We Use Your Personal Data

 

• We process your personal data identified in this Privacy Policy to provide the Services as defined above.

 

• We may process your personal data to provide you with notifications and messages related to our Notification Programs, which may include but are not limited to: (i) ReCaptRx notifications concerning prior authorization rejections, prescription capture alerts, Rx refills, and related prescription-support matters; (ii) SignalTx notifications concerning therapeutic and diagnosis updates, evidence-based clinical information, and pharmaceutical program sponsor communications; (iii) routing notifications to Care Team members you have designated; and (iv) generating aggregated, de-identified analytics on notification delivery and engagement.

 

• We may process your personal data identified in this Privacy Policy where necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution or in an administrative or out-of-court procedure.

 

• We may process your personal data identified in this Privacy Policy where necessary for the purposes of managing risks, or obtaining professional advice.

 

• We may process your personal data identified in this Privacy Policy where such processing is necessary or advisable for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

• We may also use the information we collect internally in our business for many business purposes, such as to: (i) provide the Services you may seek or which are available on the Platform; (ii) provide aggregated or other data to third parties concerning the results of your reporting and monitoring on and through the Platform, with or without other aggregated data; (iii) analyze trends and conduct research; (iv) provide support and respond to questions from our users, Platform visitors and customers; (v) improve our Platform; (vi) learn about users’ and customers’ needs; (vii) contact users for research, informational, and marketing purposes, including customizing our Platform; (viii) track traffic patterns and Platform usage; (ix) provide customer service and technical support; (x) correlate information with other commercially available information to identify demographics, reporting and monitoring needs, trail conditions, user impact and any other service or information offered on or through the Platform; (xi) provide specific relevant marketing, promotional, or other information to you; (xii) address information security and/or privacy practices, network functioning, engineering, and troubleshooting issues; (xiii) investigate claims and/or legal actions, violations of law or agreements, and compliance with relevant applicable laws and legal process; (xiv) comply with law, or based on our good faith belief that it is necessary to conform or comply with the law, or otherwise to disclose information to prevent fraud to reduce credit risks, to cooperate with police and other governmental authorities, or to protect the rights, property or safety of visitors to the Platform, our partners or customers, or the public; and (xv) process or engage in a sale of all or part of our business/organization(s), or if we go through a reorganization or merger.

 

• We may also share personal data and non-personally identifiable information externally with our affiliates as well as with other third-party service providers who help us provide operational services for the Platform, which might include, but is not necessarily limited to: business entities that provide e-mail address management and communication contact services, network equipment and application management providers and hosting entities, judicial, administrative and/or legal or financial accounting providers in the event that information must be reviewed or released in response to civil and/or criminal investigations, claims, lawsuits, or if we are subject to judicial or administrative process (such as a subpoena) to release your information or to prosecute or defend legal actions, and other service providers which may be involved in the other types of services and activities otherwise discussed in this Privacy Policy.

 

9. Providing Your Personal Data To Others

 

• We may disclose your personal data to our officers, directors, employees, and agents insofar as reasonably necessary for the purposes, and on the legal basis, set out in this Privacy Policy, including to provide or potentially provide Services to you or for your benefit.

 

• We may disclose your personal data to our professional advisers insofar as reasonably necessary for the purposes of managing risks, obtaining professional advice, or the establishment, exercise or defense of legal claims, whether in court proceedings, ADR or in an administrative or out-of-court procedure.

 

• We may disclose certain of your personal data to our suppliers and subcontractors pursuant to separate consent provided by you to us.

 

• We may disclose certain of your personal data to our vendors and subcontractors in connection with providing our Services or our other permitted uses as set forth herein.

 

• The foregoing disclosures are made insofar as reasonably necessary, and only to the extent required, for assisting us in providing our Services to you, storing data and in connection with the administration of our business.

 

• In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defense of legal claims, whether in court proceedings, alternative dispute resolution, or in an administrative or out-of-court procedure.

 

• We may disclose your personal data to a purchaser, successor, or assignee in connection with any merger, acquisition, reorganization, financing, sale of all or substantially all of our assets, or similar transaction, or in connection with any bankruptcy, insolvency, or receivership proceeding. In any such transaction, your personal data will remain subject to the commitments made in this Privacy Policy, and we will provide notice before your personal data becomes subject to a materially different privacy policy.

 

• We do not sell your personal data. We may share aggregated, de-identified data and analytics derived from Platform usage with pharmaceutical program sponsors and strategic partners. Such analytics are aggregated above the individual healthcare-provider level and do not include results identifiable to any individual provider (for example, at the National Provider Identifier (NPI) level). We may also disclose personal data to service providers who assist in operating the Platform, as described in this Privacy Policy. We may also use aggregated and de-identified information regarding the use and effectiveness of the Platform and our Services for internal purposes and for external purposes, including product development, sponsor reporting, and marketing of our Services.

 

10. Retaining And Deleting Personal Data

 

• This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.

 

• Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.

 

• We will retain your personal data:

 

• to the extent your personal data that we hold was obtained from data you knowingly, intentionally and manifestly made public or which is in the public domain independent of any act or action of us, it will be retained in that form for as long as it is needed or required for the purposes for which we obtained the information from the public record, or as otherwise required by applicable law;

 

• to the extent your personal data that we hold was pulled by us and separated from data you knowingly, intentionally and manifestly made public or which is in the public domain independent of any act or action of us, it will be retained by us for as long as required by us for the purpose for which it was obtained and as required by our contractual requirements with third-party clients or as otherwise required by applicable law.

 

• In some cases, it is not possible for us to specify in advance the periods for which your personal data will be retained. In such cases, we will determine the period of retention based upon the performance of our Services, and any applicable industry and governmental standards. Where we cannot state a specific retention period in advance, we determine the applicable period using the following criteria: the nature and sensitivity of the personal data; the purposes for which we process it; the duration of our relationship with you and your continued use of the Platform; our contractual obligations to third-party clients; and any legal, regulatory, accounting, or reporting requirements to which we are subject.

 

• We may also retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.

 

11. Amendments

 

• We may update this Privacy Policy from time to time by publishing a new version on our website.

 

• You should check this page occasionally to ensure you are aware of and in agreement with any changes to this Privacy Policy.

 

• We may notify you of significant changes to this Privacy Policy by email or through the private messaging system on our website.

 

The following disclosure is made to residents of states whose laws address browser-based opt-out signals: 

 

14.  Your Rights - FOR CALIFORNIA, COLORADO, CONNECTICUT, NEW JERSEY, OREGON, NEVADA, TEXAS, UTAH, VIRGINIA, AND OTHER APPLICABLE STATE RESIDENTS

 

If you are a resident of California, Colorado, Connecticut, New Jersey, Oregon, Nevada, Texas, Utah, Virginia, or any other state with an applicable consumer privacy law, and to the extent such state law(s) is applicable to us, your state law may provide you with additional rights regarding our use of your personal information. To learn more about your privacy rights, visit:

 

• (California) https://oag.ca.gov/privacy/privacy-laws;

• (Colorado) https://coag.gov/resources/colorado-privacy-act/;

• (Connecticut) https://portal.ct.gov/AG/Sections/Privacy/The-Connecticut-Data-Privacy-Act;

• (New Jersey) https://www.njleg.state.nj.us/bill-search/2024/S332;

• (Oregon) https://olis.oregonlegislature.gov/liz/2023R1/Downloads/MeasureDocument/SB619/Enrolled;

• (Nevada) https://www.leg.state.nv.us/NRS/NRS-603A.html;

• (Texas) https://statutes.capitol.texas.gov/Docs/BC/htm/BC.541.htm#C;

• (Utah) https://le.utah.gov/~2022/bills/static/SB0227.html;

• (Virginia) https://law.lis.virginia.gov/vacodefull/title59.1/chapter53/.

 

Requests for Information – CALIFORNIA RESIDENTS

 

Under Section 1798.83 of the California Civil Code, residents of California have the right to request from a business, with whom the California resident has an established business relationship, certain information with respect to the types of personal information the business shares with third parties for those third parties’ direct marketing purposes, and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at privacy@qc-health.org with “REQUEST FOR CALIFORNIA PRIVACY INFORMATION” in the subject line and explicitly makes such request. Be sure to provide in the request sufficient information to properly identify you and/or the members of your family to whom the request applies.

 

Do Not Track Disclosure – CALIFORNIA, COLORADO, CONNECTICUT, OREGON, NEVADA, TEXAS, UTAH, and VIRGINIA RESIDENTS

 

The following disclosure is made to residents of states whose laws address browser-based opt-out signals: As required by Section 22575 of the California Business and Professions Code, the following disclosure is made to California residents and to residents of other states, including Colorado, Connecticut, New Jersey, Oregon, Nevada, Texas, Utah, Virginia, and any other state with an applicable consumer privacy law:

 

Where required by applicable state law (including Colorado and Connecticut), we are implementing recognition of browser-based universal opt-out signals such as the Global Privacy Control (“GPC”). When we detect a GPC or similar signal from a jurisdiction that requires it, we will treat it as a valid opt-out of the sale or sharing of personal data. In states where no such requirement applies, the Platform does not alter its behavior in response to Do-Not-Track signals. As described herein, we use cookies and other tools to collect information about you when you visit our Website to, among other things, better tailor the features, performance and support of our products, services and Website. After you leave or close-out from the Website, we do not track your online activity on other apps or websites, but third parties (such as PulsePoint, Google Analytics) and their affiliates may use information collected through cookies and tracking technologies on the Platform in connection with their own services.

 

Marketing – CALIFORNIA, COLORADO, CONNECTICUT, NEW JERSEY, OREGON, NEVADA, TEXAS, UTAH, VIRGINIA, AND OTHER APPLICABLE STATE RESIDENTS

 

Under applicable state privacy law, you may make a written request to us to disclose the categories of personal data we have shared with third parties for direct marketing purposes during the prior year, and we will provide you with a cost-free means to opt out of such sharing.

 

If you would like to exercise any of these rights, please send your written request to the e-mail address or postal address below. Please include your state of residency in your request. We will respond within the timeframe required by applicable law.

 

E-mail Address:

privacy@qc-health.org

Attention: PRIVACY OFFICER

 

Postal Address:

QC-Health, Inc.

111 Town Square Pl,

Suite 1238, Unit 43599,

Jersey City, NJ 07310

Attention: PRIVACY OFFICER

 

Phone:

862-375-0059

 

Your Privacy Rights Under Applicable State Law

 

To the extent applicable state privacy law applies to our processing of your personal data, and subject to any applicable exemptions (including data subject to federal regulation such as HIPAA, GLBA, FCRA, and DPPA), we provide residents of California, Colorado, Connecticut, New Jersey, Oregon, Nevada, Texas, Utah, Virginia, and any other state with an applicable consumer privacy law, with the following rights with respect to their personal data (excluding de-identified or aggregate data):

 

(1) The right to know whether your personal data was collected by us.

 

In large part, the personal data we collect is set forth above in this Privacy Policy.

 

(2) The right to request the categories and specific pieces of personal data that we have collected about you in the past 12 months, the categories of sources for which that information is collected, the business purposes for collecting or selling/sharing the information, and the categories of third parties with whom the information is shared or sold.

 

In large part, these categories and specific pieces of personal data that we have collected is set forth above in this Privacy Policy.

 

(3) The right to know what information we are collecting about you and the purposes for which it is being used.

 

In large part, the type of information we collect and the purpose for which it is collected is set forth above in this Privacy Policy.

 

(4) The right to not allow us to sell or share any of your personal information.

 

We do not sell your personal information. We may share certain personal information (such as device identifiers, IP address, and browsing activity on the Platform) with third-party service providers, such as PulsePoint, that use cookies and tracking technologies to help us deliver clinical notifications and measure whether Healthcare Providers engage with our resources. Because these service providers may use such information for purposes beyond our direct relationship with you, this activity may be considered “sharing” for cross-context behavioral advertising under California and certain other state privacy laws. You may opt out of this sharing by contacting us at privacy@qc-health.org.

 

(5) The right to limit our use of your sensitive personal information.

 

We do not use sensitive personal information for purposes other than those permitted under applicable state privacy laws. You may limit certain uses of your sensitive personal information by contacting us at privacy@qc-health.org.

 

(6) The right to have your personal information deleted, subject to certain exceptions.

 

These exceptions may include:

 

Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

 

Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

 

Debug products to identify and repair errors that impair existing intended functionality.

 

Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

 

Comply with applicable electronic communications privacy laws.

 

Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research achievement, if you previously provided informed consent.

 

Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

 

Comply with a legal obligation.

 

Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

 

(7) The right to have your personal information corrected, subject to certain exceptions.

 

(8) The right to know the length of data retention.

 

Unless indicated otherwise elsewhere or required pursuant to any applicable law, we retain your personal information for as long as reasonably necessary to fulfill the purposes described in this Privacy Policy, to comply with our legal and contractual obligations, and to resolve disputes.

 

(9) The right to not be discriminated against for exercising any of the above rights.

 

We will not discriminate against you if you exercise any of the above rights. However, as explained, some or all of our Services necessarily require us to process your personal information, and share your personal information with certain third parties in connection with providing the Services. Therefore, and as explained above, exercise by you of certain of the above rights may impact our ability to provide the Services to you.

 

TO THE EXTENT APPLICABLE, AND TO EXERCISE ANY OF THE ABOVE RIGHTS, PLEASE CONTACT US AT ANY OF THE BELOW AND INCLUDE THE WORDS “EXERCISE MY RIGHTS” IN ALL CAPS IN THE SUBJECT LINE, OR BE CLEAR BY PHONE THAT YOU WANT TO EXERCISE YOUR RIGHTS and CLEARLY LET US KNOW: (1) Your address and state of residency; and (2) the rights you seek to exercise.

 

E-mail Address:

privacy@qc-health.org

 

Postal Address:

QC-Health, Inc.

111 Town Square Pl,

Suite 1238, Unit 43599,

Jersey City, NJ 07310 (United States)

Attention: PRIVACY OFFICER

 

Phone:

862-375-0059

 

15. Your Choices About Information We Collect

 

• If you do not consent to the way in which we may use your personal information, please do not submit any personal information to us. Please note that if you do not provide us with certain personal information the Company may be unable to provide you with its Services, or those Services may not be as good as they otherwise could be.

 

• If you do not wish to receive other marketing materials from us and/or if you do not want us to share your personal information with other entities as stated in this Privacy Policy, please provide us with your exact name and address and advise us that you wish to opt-out for any information sharing or receiving information from us or both as the case may be. Please note that de-identified and aggregate data including your personal information may still be shared, but it will not be identified or identifiable to you. Please direct your opt-out request to the following contacts:

 

QC-Health, Inc.

111 Town Square Pl,

Suite 1238, Unit 43599,

Jersey City, NJ 07310 (United States)

Attention: PRIVACY OFFICER (privacy@qc-health.org)

 

With a copy (including the words “QC-Health - Privacy” in the subject line) to:

 

OlenderFeldman LLP

641 Lexington Avenue, 13th Floor

Summit, NJ 07901 (United States)

Attention: Shoshana E. Rosenberg, Esq. (srosenberg@olenderfeldman.com)

 

You may opt out of our various communications as follows:

 

E-mail Communications: (1) click the unsubscribe link located in our emails, or (2) by emailing us at privacy@qc-health.org with Unsubscribe request in the subject line, or (3) by calling us at 862-375-0059 and clearly setting forth your request.

 

Third-Party Sharing: (1) e-mail us at privacy@qc-health.org with the words “THIRD-PARTY E-MAIL REMOVAL” in the subject line, or (2) by calling us at 862-375-0059 and clearly setting forth your request.

 

• Note that removal from third-party lists may take up to 6 months to be effective.

 

SMS/MMS Text Message Consent and Opt-Out: If you choose, you can provide your mobile phone number to receive SMS/MMS text message alerts from the Company. By providing your mobile phone, you are consenting to receive automated SMS/MMS text messages from us, but you can always access our products or services from the Website without providing this consent. Message and data rates may apply, and you should check the rates of your mobile carrier. You can opt out from further SMS/MMS text message communications by texting STOP to the SMS number used by the Company to contact you. WE DO NOT SELL, RENT, LOAN, TRADE, LEASE, OR OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR CUSTOMER INFORMATION COLLECTED THROUGH THE PROGRAM TO ANY THIRD PARTY. We may share your mobile phone number with our service providers to help us deliver mobile messages and carry out the activities described above, but not for their own marketing. We do not guarantee availability or performance of this SMS/MMS text message service, including liability for transmission delays or message failures.

 

Fax Message Opt-Out: If you no longer want to receive any fax messages, you should follow the instructions on the fax or contact Company at:

 

E-mail Address:

privacy@qc-health.org

Attention: PRIVACY OFFICER

 

Postal Address:

QC-Health, Inc.

111 Town Square Pl,

Suite 1238, Unit 43599,

Jersey City, NJ 07310 (United States)

Attention: PRIVACY OFFICER

 

Phone:

862-375-0059

 

SMS/MMS MOBILE MESSAGING PROGRAM

 

We reserve the right at all times to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property. When you complete forms online or otherwise provide us information in connection with the Program, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If, in our sole discretion, We believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the Program for an ulterior purpose, we may refuse you access to the Program and pursue any appropriate legal remedies.

 

Please note that even once we comply with any of your requests as set forth above, de-identified and aggregate data derived from your personal data may still be used and shared as described in the section titled “Providing Your Personal Data To Others,” but it will not be identified or identifiable to you.

 

16. Privacy of Children Who Visit the Website

 

We recognize the importance of children’s safety and privacy. The Platform is not designed to attract children, and is not intended for use by any children under the age of 18. We do not request, or knowingly collect, any personally identifiable information from children under the age of 18. If you are under age 18, you do not have permission to use the Platform or our Services.

 

17. Links

 

For your convenience, the Platform may contain links to other websites. We are not responsible for the privacy practices, advertising, products, or the content of such other websites. None of the links should be deemed to imply that we endorse or have any affiliation with the links. You should review the privacy policies and Terms of Use of all other websites or links you visit.

 

18. Security

 

We believe in providing a safe and secure experience for all of our online visitors. To that end, we have implemented security measures to protect the information collected from you. We maintain reasonable physical and electronic safeguards designed to limit unauthorized access to your personally identifiable information, and to protect you against the criminal misuse of that information. We host our Platform infrastructure with Google Cloud Platform and manage access controls through a Principle of Least Privilege policy.

 

While we use the foregoing security measures to protect your information, please note that no data transmitted over the Internet or stored and utilized for business purposes can be guaranteed to be completely secure. No security measures are perfect or impenetrable. We cannot guarantee that only authorized persons will view your information. We cannot ensure that information you share on the website will not become publicly available. You can reduce these risks by using common sense security practices such as choosing a strong password, using different passwords for different services, and using up to date antivirus software.

 

19. Questions / Changes in Notice

 

If you have questions or concerns with respect to our Privacy Policy, you may contact us at privacy@qc-health.org. We may elect to change or amend our Privacy Policy; in such event, we will post the changes in our Privacy Policy on the Website.