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Privacy Policy

Last Revised on October 9, 2021

Welcome to the Privacy Policy for Neolth Inc. (“Company,” “we" or “us"). This Privacy Policy describes how we collect, use and disclose information about you related to your use of and access to our website, https://www.neolth.com/ and related subdomains (collectively, the “Website”), the Neolth mobile application, together with any content, tools, features and functionality offered on or through our Website (the “Services”). 

For purposes of this Privacy Policy, “you” and “your” means you as the user of the Services. 

This Privacy Policy applies only to the information collected in connection with the Services. Please read this Privacy Policy carefully to understand our policies and practices regarding your information. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing and using the Services, you acknowledge this Privacy Policy.
 

1 TYPES OF INFORMATION WE COLLECT

Information we may collect about you through the Services:

 

  • Registration details you provide when you create an account, such as your name, email address, telephone number, birthdate, username and password.

  • Health-related information you provide when you use the Services, including information related to your stress and mental and physical health condition through our questionnaire or otherwise.

  • Information you provide when you access or use the Services and each time you interact with the Services or otherwise with us, for example, when you update information in your account or communicate with us by telephone or email. This includes your payment information.

  • Usage, viewing and technical information, including your IP address or device identifier when you use the Services. If you access your account from a mobile device, that mobile device may also provide us with details of your location. Most mobile devices allow you to disable this functionality.

  • Information we receive about you from third parties (e.g., if your physician sends you a referral code for access to the Services, we may receive your e-mail address which your physician shares with us).

2 HOW WE COLLECT YOUR INFORMATION

  • We collect information you provide to us when you: register with us; input information into the Services; create user generated content; request services or information from us; respond to customer surveys; or otherwise interact with us or the Services. 

  • We collect information through unique identifiers (such as IP address or your mobile device advertising identifier).

  • We use “cookies” and other technologies to collect data that enable us to better understand and improve the usability, performance and effectiveness of our Services. Cookies are files sent to your browser and stored on your computer. We use cookies to gather general information about your use of the Services, the files you have designated for backup, the configuration of your computer and your computer’s interaction with the Services, and stores this information in log files. We use this information to understand traffic on and downloads from our Services, enabling us to improve the Services, provide the best online experience possible, and improve our customer service. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Services.

  • For example, we use Google Analytics, which is a web analytics tool that helps us understand how users engage with the Services. Like many services, Google Analytics uses first-party cookies to track user interactions, as in our case, where they are used to collect information about how users use our site. This information is used to compile reports and to help us improve the Services. The reports disclose website trends without identifying individual visitors. You can opt out of Google Analytics without affecting how you visit our site – for more information on opting out of being tracked by Google Analytics across all websites you use, visit this Google page: https://tools.google.com/dlpage/gaoptout.

  • We and the third parties’ we work with use analytic and tracking tools to better understand to collect information about your use of the Services, such as your IP address, browser type, browser version, pages viewed, time spent on pages, links clicked, location and conversion information. This information may be used by us and others to, among other things, analyze and track data, determine the popularity of certain content, provide customer support, troubleshoot issues with and improve the operation of the Services, and better understand your online activity. We do not have access to, nor control over, third parties' use of cookies or other tracking technologies.

 

You may disable cookies by changing the settings on your browser. Check your browser for further information. Remember that if you disable cookies it is likely to affect how the Services work and you may not be able to access or use certain features of the Services. Unless you have adjusted your browser setting so that it will refuse cookies, our Services will place cookies when you log on to the Services. 

Online Tracking

  • Do Not Track (DNT) is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. The Company and the Services do not recognize DNT.

3 USE OF YOUR INFORMATION BY THE COMPANY

The ways in which we may use your information include the following:

  • To provide you with the Services and other services you request.

  • To administer your Neolth account.

  • To communicate with you about your account or transactions with us and send you details or updates about features of the Services or changes to our policies.

  • To process payments. 

  • To create anonymized and aggregated data sets that may be used for a variety of functions, including research, internal analysis, analytics, and other functions. 

  • To ensure consistency with local law and choices and controls that may be available to you. 

  • To personalize content and experiences.

  • To detect, investigate and prevent activities that may violate our policies or be illegal.

  • To optimize or improve the content, products, services, and features of the Services.

  • To personalize and improve the Services and user experiences, to increase the functionality and user friendliness of the Services, to deliver content or features that match user profiles or interests.

  • To monitor and analyze the Services usage and trends and otherwise measure the effectiveness of the services.
     

4 SHARING YOUR INFORMATION WITH OTHER COMPANIES

We will not share your information outside the Company except in the following limited circumstances which you consent to:

  • When you allow us to share your personal information with another company or individual, such as your physician or school counselor. 

  • If you use the Services’ sharing functionality with third-party sites or platforms made available through the Services (e.g., Facebook), those third parties will have access to your information to the extent that you have authorized their access. Please consult Section 7 below and the third party’s privacy policy for additional information.

  • When we contract or partner with a third party to provide services on our behalf, including Services development and maintenance. We require all third parties to process your data in accordance with this Privacy Policy and as permitted by applicable data protection laws.

  • In connection with the sale of a business (including merger, acquisition, or sale of all or a material portion of its assets, change in corporate control, or insolvency or bankruptcy proceedings).

  • To enforce our Terms of Service or rules, to ensure the safety and security of our users and third parties, to protect our rights and property and the rights and property of our users and third parties, to comply with legal process, including judicial warrant, rule, order or subpoena or requests from law enforcement, or in other cases if we believe in good faith that disclosure is required by law or regulation.

 

In addition, we may share anonymized and aggregated data sets with third parties, alone or in combination with anonymized information of other users. 
 

5 SEMI-PUBLIC VENUES OF THE SERVICES


To the extent you submit a comment, blog, video or other message, or use the Services’ sharing functionality with third party social media platforms or the public features of the Services, you will be identified on those venues by your name.
 

6 YOUR CONTROLS AND CHOICES

We provide you the ability to exercise certain controls and choices regarding our collection, use and sharing of your information. Your controls and choices may include:

  • You may correct, update and delete your registration account.

  • You may request access to the information we hold about you and that we amend or delete it.

 

You may exercise your controls and choices, or request access to your Personal Information, by modifying your profile or by contacting us at SUPPORT@NEOLTH.COM or following instructions provided in communications sent to you. Please be aware that, if you do not allow us to collect personal information from you, we may not be able to deliver certain products and services to you, and some of our services may not be able to take account of your interests and preferences. If you have questions regarding the specific personal information about you that we process or retain, please contact us at SUPPORT@NEOLTH.COM.

7 THIRD PARTY WEBSITES AND LINKS

Our Services may contain links to other online platforms operated by third parties. We do not control such other online platforms and are not responsible for their content, their privacy policies, or their use of your Personal Information. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators except as disclosed on the Services. 


Please keep in mind that information you post on public or semi-public venues, including information you share on third party social networking platforms (such as Facebook or Twitter) through the Services’ sharing functionality or otherwise may also be viewable by other users of the Services and/or users of those third-party online platforms without limitation as to its use by us or by a third party. When you provide information to a third-party online platform, the information you provide may be separately collected by that third-party. The information the third-party online platform collects is subject to the third-party online platform’s privacy practices. Privacy choices you make on the third-party online platform will not apply to our use of the information we collect directly through our Services. 


We expressly disclaims any and all liability for the actions of third parties, including but without limitation to actions relating to the use and/or disclosure of personal information by third parties. 

8 CHILDREN’S PRIVACY

We do not seek or knowingly collect any information from children under 13 years of age without obtaining consent from the child’s parent or guardian. Parents have the right to review their child’s information; to have their child’s information deleted; and to refuse further collection, use, and/or disclosure of their child’s information by notifying us. As a parent, you understand that Company has a legitimate interest in providing your child’s information collected via the Services to external providers for the sole purpose of administering or providing the Services. Anyone under the age of thirteen (13) must seek and obtain parent or guardian permission to use our Services.


To the extent you wish to enable your child to use the Services, you must create an account for the child in accordance with our Terms of Service and provide consent for us to collect such information from your child. If we become aware that we have unknowingly collected information from a child under 13 years of age without such consent, we will make commercially reasonable efforts to delete such information from our database.


If you are the parent or guardian of a child under 13 years of age who has provided us with information, you may contact us to request it be deleted.

9 DATA SECURITY, INTEGRITY AND RETENTION

  • Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information to us. From time to time, we review our security procedures to consider appropriate new technology and methods. Please be aware though that, despite our best efforts, no security measures are perfect or impenetrable. We will retain your personal information for the length of time needed to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required, or for the establishment, exercise or defense of legal claims, or for legitimate businesses purposes, or as provided by law.

  • To provide secure credit card processing when ordering from us, orders placed through our Services are processed through a payment gateway which operates under its own privacy policy. If you choose to pay for the Services online using a credit card, the credit card information is sent to the Company using SSL (Secure Socket Layer) encryption, an industry-standard method for protecting data as it travels over the Internet, or a similar encryption technology that may become accepted as an industry standard, or better encryption method, in the future. To learn more about our policies with respect to third parties, please see Section 6. To learn more about our credit card processing vendors and their respective privacy and other policies which apply when you make a payment through their services, please review the terms of those third parties’ privacy policies. 

10 UPDATING THIS PRIVACY POLICY

We may modify this Privacy Policy from time to time in which case we will update the “Last Revised” date at the top of this Privacy Policy. If we make changes that are material, we will use reasonable efforts to attempt to provide notice to you and, where required by applicable law, we will obtain your consent. Notice may be by email to you at the last email address you provided us, by posting notice of such changes on the Services, or by other means, consistent with applicable law. However, it is your sole responsibility to review the Privacy Policy from time to time to view any such changes. The updated Privacy Policy will be effective as of the time of posting, or such later date as may be specified in the updated Privacy Policy. IF YOU DO NOT ACCEPT AND AGREE TO THIS PRIVACY POLICY, INCLUDING ANY CHANGES, THEN YOU MUST NOT ACCESS OR USE THE SERVICES.

11 YOUR CALIFORNIA PRIVACY RIGHTS

This section applies only to California residents.


Any California residents under the age of eighteen (18) who have registered to use the Services, and who have posted information in the publically-viewable portion of the Services, can request that such information be removed from the Services by contacting us at  SUPPORT@NEOLTH.COM. We will make reasonable good faith efforts to remove the information from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third-parties may have republished the information and archived copies of it may be stored by search engines and others that we do not control.


We do not share personal information as defined by Cal. Civil Code § 1798.83 (“Shine The Light Law”) with third parties for their direct marketing purposes.


The California Consumer Privacy Act (“CCPA”) provides California residents with additional rights regarding our use of your personal information (as such term is defined in the CCPA), which we have described in more detail below. 
WE DO NOT, AND IN THE PAST TWELVE MONTHS DID NOT, “SELL” (AS THAT TERM IS DEFINED IN THE CCPA) YOUR PERSONAL INFORMATION TO THIRD PARTIES. 


In the chart below, we have described the categories of personal information that we have collected and disclosed over the past twelve (12) months, the purposes for such collection and the types of entities with whom we have disclosed such information. 

If you are a California resident, the processing of certain personal information about you may be subject to the CCPA. Where the CCPA applies, this section provides additional privacy disclosures and informs you of key additional rights as a California resident. 

  • Right to Know Request. Under the CCPA, California residents have a right to request information about our collection, use, and disclosure of your personal information over the prior twelve (12) months, and ask that we provide you free of charge with the following information: 

    • the categories of and specific pieces of personal information about you that we collected;

    • the categories of sources from which the personal information was collected;

    • the purpose for collecting personal information about you;

    • categories of third parties to whom the personal information was disclosed for a business purpose; and

    • categories of personal information disclosed about you for a business purpose.

  • Right to Delete Request

    • Under the CCPA, you also have a right to request that we delete personal information, subject to certain exceptions.

  • How to Exercise Your Rights

    • If you are a California resident to whom the CCPA applies, you may contact us to exercise your rights at SUPPORT@NEOLTH.COM. Once we receive your request, we will review it, determine whether we can verify your identity, and process the request accordingly. We may need to collect information from you to verify your identity, such as your email address, government issued ID or date of birth. You may make a verifiable consumer request to access your personal information twice per twelve (12) month period. We aim to fulfill all verified requests within 45 days pursuant to the CCPA. If necessary, extensions for an additional 45 days will be accompanied by an explanation for the delay.

    • You may designate, in writing or through a power of attorney document, an authorized agent to make requests on your behalf to exercise your rights. Before accepting such a request from an agent, we will require that the agent provide proof that you have authorized them to act on your behalf, and we may need you to verify your identity directly with us.

  • Non-Discrimination. We will not discriminate against you simply for your exercising any of your CCPA rights. Unless permitted by the CCPA, we will not: deny you goods or services; charge you different prices or rates for goods or services, including by refusing to grant discounts or other benefits, or imposing penalties; provide you a different level or quality of goods or services; or, suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

12 HOW TO CONTACT US

Any questions or concerns regarding the use or disclosure of information should be directed to the Company at SUPPORT@NEOLTH.COM.

 

You may contact us regarding the Services or this Privacy Policy at: 4774 Park Granada #8843, Calabasas, CA, 91372, by phone at +1 925 262 3695  or by e-mail at SUPPORT@NEOLTH.COM.

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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