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Pearl Website and Service Privacy Policy Last Updated: August 29, 2017 Thank you for using Pearl!

Privacy Policy

This Privacy Policy explains how information about you is collected, used and disclosed by Pearl Healthcare Technologies, Inc. ("Pearl"). This Privacy Policy applies to information we collect when you register for an account or use our websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, the "Services"). Please Read Carefully Prior To Using Our Services. By entering and using this Site, you affirm that you have read and understood Pearl’s Website Privacy Policy and Terms of Use that you agree to abide by them. If you do not agree to abide by Pearl’s Terms of Use and this Privacy Policy, you may not enter, access, or otherwise use our Services. The use of our Services is conditioned upon your acceptance of the terms and conditions contained in this Privacy Policy which is part of and incorporated by reference into the Terms of Use of the Site. We may change this Privacy Policy from time to time. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our homepage or sending you an email notification). We encourage you to review the Privacy Policy from time to time to stay informed about our information practices and the ways you can help protect your privacy.

HIPAA Notice of Privacy Practices

To read more about our privacy practices that apply specifically to the health and insurance information that we collect with respect to your Pearl User Account, please see section below titled “HIPAA Notice of Privacy Practices.”

Collection of Information

Information You Provide to Us

We collect information you provide directly to us. For example, we may collect information when you search for a healthcare provider, use our booking feature, fill out a form, register for an account, submit a review, respond to a survey, request customer support, or otherwise communicate with us. The types of information we may collect include your name, contact information (such as email address, postal address, phone number, and mobile number), age, date of birth, gender, health insurance information, location, provider preferences, availability, the health condition for which you are seeking a doctor, provider feedback, and other information you choose to provide including such unique identifiers such as passwords.

Information We Collect Automatically When You Use the Services

When you access or use our Services, we automatically collect information about you, including: Log Information: We log information about your use of the Services, including the type of browser you use, access times, pages viewed, search terms, your IP address, and the page you visited before navigating to our Services. Device Information: We collect information about the computer or mobile device you use to access our Services, including the hardware model, operating system and version, device identifiers, and mobile network information. Location Information: We may collect information about the location of your device each time you access or use one of our mobile applications or otherwise consent to the collection of this information. For more details, please see "Your Choices" below. Information Collected by Cookies and Other Tracking Technologies: We use various technologies to collect information, and this may include sending cookies to your computer or mobile device. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. We may also collect information using web beacons (also known as "tracking pixels"). Web beacons are electronic images that may be used in our Services or emails and help deliver cookies, count visits, understand usage and campaign effectiveness, and determine whether an email has been opened and acted upon. For more information about cookies, and how to disable them, please see "Your Choices" below.

Collection and Use of Real Time Location from Mobile Devices

If you use our Mobile Application or our Mobile Web Application, we may use GPS technology (or other similar technology) to determine your current location in order to determine the city you are located within and display a location map with relevant information. We will not share your current location with other users or partners. If you do not want us to collect and use your location for these purposes, you should turn off the location services for the mobile application or your browser located in your account settings or in your mobile device settings and/or within the mobile application or browser.

Collection and Use of Anonymous Information

We use analytics tools and other third party technologies (such as Google Analytics and Mixpanel) to track and analyze your usage of our sites through the use of cookies, pixel tags/web beacons, and similar technologies. These technologies collect information that relates to, but is not limited to, how certain features of our Services are used, pages viewed, time spent on pages, links clicked, the general region from which our visitors are contacting us, and how many people visit our website at any given time. The information collected on our behalf by these third parties is anonymous, and does not include your name, address, phone number, insurance number or email address. Pearl uses this information to, among other things, analyze and track data, determine the popularity of certain content, deliver content targeted to your interests, improve the Services and better understand your use of the Services. You may opt out of the tracking by these analytics service providers on their websites: Google’s privacy policy and various privacy controls and opt-outs, please see www.google.com/analytics/learn/privacy.html. Mixpanel: You can opt out of Mixpanel tracking your behavior on your computer or mobile device by visiting: https://mixpanel.com/optout/.

Use of Information

We may use information about you for various purposes, including to: Provide, maintain, and improve our Services; Process transactions, make appointments, ask for feedback, and send you related information, including confirmations and reminders; Send you technical notices, updates, security alerts, and support and administrative messages; Respond to your comments, questions, and requests, and provide customer service; Communicate with you about products, services, offers, promotions, rewards, and events offered by Pearl and others and provide news and information we think will be of interest to you; Monitor and analyze trends, usage, and activities in connection with our Services, and to develop new services; Detect, investigate, and prevent fraudulent transactions and other illegal activities, and protect the rights and property of Pearl and others; Personalize and improve the Services and provide content or features that match user profiles or interests; Process and deliver contest entries and rewards; Link or combine with information we get from others to help understand your needs and provide you with better service; and Carry out any other purpose for which the information was collected. Pearl is based in the United States and the information we collect is governed by U.S. law. By accessing or using the Services or otherwise providing information to us, you consent to the processing and transfer of information in and to the U.S. and other countries.

Sharing of Information

We may share personally identifiable information about you as follows or as otherwise described in this Privacy Policy: With vendors, consultants, and other service providers who need access to such information to carry out work on our behalf and who are not permitted to use such information for other purposes (“Service Providers”) With doctors and other providers with whom we are arranging appointments or otherwise communicating with on your behalf, such as in connection with our booking service; In response to a request for information if we believe disclosure is in accordance with any applicable law, regulation or legal process, or as otherwise required by any applicable law, rule or regulation; If we believe your actions are inconsistent with the spirit or language of our user agreements or policies, or to protect the rights, property and safety of Pearl or others; In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business to another company; and With your consent or at your direction, including if we notify you through our Services that the information you provide will be shared in a particular manner and you provide such information. Please see our HIPAA Notice of Privacy Practices for more information about how we may use and share personally identifiable information we collect with respect to your Pearl or Pearl Plus User Account. We may also share aggregated or anonymized information that does not directly identify you.

Security

Pearl takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction.

Your Choices

Account Information

You may update, correct or delete information about you at any time by emailing us at [email protected], but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.

Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services.

Promotional Communications

You may opt out of receiving promotional emails or text messages from Pearl by following the instructions in those emails or text messages or by emailing us at [email protected]. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

Children’s Privacy

We are committed to protecting the privacy of children. Neither this Site, nor any of the Services offered on this Site is intended or designed for use by children under the age of 13. We do not collect personally identifiable information from any person we actually know is a child under the age of 13.

HIPAA Notice of Privacy Practices

Privacy is Pearl’s top priority and we work hard to make sure that your information remains anonymous and secure. This notice describes how health-related information about you may be used and disclosed and how you can get access to this information. Please review it carefully.

Information This Notice Applies To

This notice applies to information about you that is protected under a federal law called HIPAA (the Health Insurance Portability and Accountability Act), called “protected health information.” Protected health information includes information that we collect, create or maintain as part of the Pearl User and Pearl Plus accounts, that could potentially be used to identify who you are, such as: Personal information you provide to us when you register for an account such as your name, age and gender Information related to your health, such as the condition or procedure search terms you use to find a doctor Information about your health insurance benefits (such as your insurance co-pay or remaining deductible) that we collect with your permission

How We Can Use and Share Your Protected Health Information

We typically use and share your protected health information in the following ways: Treatment

  • We can use your health information to notify you about treatment options. Example: We give you options for healthcare providers in your area based on, among other things, your gender, age and location. We can share your health information with other professionals who are treating you. Example: We share your health information with the doctor’s office when we make an appointment for you. Run our organization
  • We can use and share your health information to improve our service and contact you when necessary. Payment
  • We can use and share your health information for payment purposes. Example: If we charged you for our services, we would be allowed to share your health information so that we could receive payment for them.
  • Contractors We use contractors to provide certain services for us. These contractors are required by law and their contracts with us to protect your information the same way we do. Example: We may use a contractor to help us make a doctor’s appointment for you. They are required to protect any information they receive about you

Other Ways We Can Use or Share Your Health Information

In certain other circumstances, we are allowed, and sometimes are required, to share your health information without your written permission. We have to meet many conditions in the law before we can share your information for these purposes. Comply with the law: We will share health information about you if state or federal laws require it, including with the Department of Health and Human Services if it wants to see that we’re complying with federal privacy law. Respond to lawsuits and legal actions: We can share health information about you in response to a court or administrative order, or in response to a subpoena. For law enforcement purposes: We can share health information about you for law enforcement purposes or with law enforcement officials. Health oversight activities: We can share your health information with health oversight agencies for activities authorized by law. Research: We can share your health information for research purposes when approved by a privacy board.

Permitted Use and Disclosures that We Don’t Generally Engage In.

We are allowed under federal law to use or disclose your information without your permission for the following purposes, however, we generally don’t do so: Help with public health and safety issues We are permitted to share health information about you for certain public health situations such as: Preventing disease Helping with product recalls Reporting adverse reactions to medications Reporting suspected abuse, neglect, or domestic violence Preventing or reducing a serious threat to anyone’s health or safety Responding to organ and tissue donation requests We are permitted to share health information about you with organ procurement organizations. Work with a medical examiner or funeral director We are permitted to share health information with a coroner, medical examiner, or funeral director when an individual dies. Address workers’ compensation and other government requests We are permitted to use or share health information about you: For workers’ compensation claims For special government functions such as military, national security, and presidential protective services

Your Choices

There are times when we are allowed to conclude by your actions that you have given us permission to share your health information with others. At other times, we need to get your written permission to share your information. Your family, close friends, or others involved in your care: We highly recommend that you do not share your password or other sign –in information with others, like your family and friends. When you share your sign-in information with others, we will assume that you have given us permission to share your health information with them. Any uses and disclosures of your health information not described elsewhere in this Notice will be made only with your prior written authorization. In particular, we never share your health information in the following cases unless you give us clear written permission: Employers: Some employers sponsor Pearl Plus Accounts to help their employees make good healthcare decisions. Even if your employer sponsors your Pearl Plus Account, we will never share your protected health information with any employer without clearly asking you first. Marketing purposes Selling of your health information

Your rights

When it comes to your health information, you have certain rights. This section explains your rights and some of our responsibilities to help you. You have the right to: Get an electronic copy of your health information You can see an electronic copy of health information we have about you on your user account. If you would like a paper copy you can print your account page through your browser. Ask us to correct your health information If you believe the health information that we maintain about you is inaccurate or incomplete, you can take the following actions. You can make your own corrections to some of the health information (e.g., name and age) through your online account. You can ask us to correct other health information about you that you think is incorrect or incomplete by sending an email to [email protected]. We may say “no” to your request, but we’ll tell you why in writing within 60 days. Request confidential communications You can ask us to contact you in a specific way (for example, home or office phone) or to send email to a different address. We will say “yes” to all reasonable requests. Ask us to limit what we use or share You can ask us not to use or share certain health information for treatment, payment, or our operations. We are not required to agree to your request, and we may say “no”. Under HIPAA, you may request us not to share health information for which you have paid out-of-pocket with your health insurer. So long as it is not prohibited by other law, we will honor such requests. Get a list of those with whom we’ve shared information You can ask for a list (accounting) of the times we’ve shared your health information for up to six years prior to the date you ask, who we shared it with, and why. We will include all the disclosures except for those about treatment, payment, and healthcare operations, and certain other disclosures (such as any you asked us to make). We’ll provide one accounting a year for free but will charge a reasonable, cost-based fee if you ask for another one within 12 months. Get a copy of this privacy notice You can ask for a paper copy of this notice at any time, even if you have agreed to receive the notice electronically. We will provide you with a paper copy promptly. File a complaint If you believe your privacy rights have been violated you can file a complaint: With us by contacting us at [email protected] and include “Complaint” in the subject line With the US Department of Health & Human Services We will not retaliate against you for filing a complaint.

Our Responsibilities

We are required by law to maintain the privacy and security of your protected health information. We must follow the duties and privacy practices described in this notice. You can print a copy of this notice or send an email to [email protected] to request a paper copy. We will not use or share your protected health information other than as described here unless you tell us we can. If you tell us we can, you may change your mind at any time. Let us know by email through [email protected] if you change your mind. We will let you know promptly if a breach occurs that may have compromised the privacy or security of your information. For more information see: www.hhs.gov/ocr/privacy/hipaa/understanding/consumers/noticepp.html. Changes to the terms of this notice. We can change the terms of this notice, and the changes will apply to all information we have about you. The new notice will be on our web site.