Privacy Policy

RVO Health, LLC (“RVO Health,” "Company," “us,” “our” or "we") respects your privacy and are committed to protecting it through our compliance with this policy.

This Website Privacy Policy (the “Policy”) describes the types of information we may collect from you or that you may provide when you visit the website www.rvohealth.com (our "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect:

• On this Website.

• In email and other electronic messages between you and this Website.

• Through mobile and desktop applications you download from this Website, which provide dedicated non-browser-based interaction between you and this Website.

• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by Company or any third party (including our affiliates and subsidiaries); or

• Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through the Website.

Please read this Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Policy. This Policy may change from time to time. (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Children Under the Age of 18

Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on this Website or through any of its features, register on the Website or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information as required under applicable law.

Information We Collect About You and How We Collect It

We collect information about you (“Information”) in a variety of ways, including directly from you, through automatic means, or from third parties. The information that is collected depends on how you use the Website.

Information You Provide to Us:

When you use the Website, you may provide information to use directly, such as name and email address, for example, when you use our Contact Us feature.

Information that is Automatically Collected:

We and third parties may use automated means to collect information about you, your computer or other device that you used to access the Website, and your use of the Website. These automated means include common technologies such as cookies, tokens, tags, web logs, web beacons, or similar technologies. These technologies help us analyze trends, administer the Website, track users’ movements around the Website, gather demographic information about our user base as a whole, and otherwise provide you with relevant content (e.g., by gathering your zip or postal code). We may receive reports on an individual as well as aggregated basis based on the use of these technologies by RVO Health, and any third party vendors acting on RVO Health's behalf.

· Cookies and Tracking

Cookies are small files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Our Website may use HTTP cookies, HTML5 cookies, and other types of local storage. Cookies may include “single-session cookies” that generally record information during only a single visit to a website and then are erased, and “persistent” cookies that are generally stored on a computer unless or until they are deleted or are set to expire. You may disable cookies by adjusting your browser preferences at any time. Please note, however, that without cookies you may not be able to use all of the features of our Website.

Our cookies, tokens and similar technologies (collectively, "Tracking Technologies") also are used for to improve our internal operations, the content of our Website and our services. Users may be able to control the use of, or reject or disable, some Tracking Technologies at the individual browser level. If you reject or disable Tracking Technologies, you may still use our Website, but your ability to use some features or areas of our Website may be limited. We use Tracking Technologies to identify your device and keep track of your Internet session.

· Web Logs

In conjunction with the gathering of data through cookies, Web servers may log records such as your device type, operating system type, device advertising identifier, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The Web server logs also may record the address of the Web page that referred you to our Services, the IP address (and associated city and state or province for the IP address) of the device you use to connect to the Internet, and data about your interaction with our Services, such as which pages you visit.

· Pixels/Web Beacons

To control which Web servers collect information by automated means, we may place tags on our Web pages called "Web beacons" (or “pixels”), which are files that link Web pages to particular Web servers and their cookies. We may use pixels for security and fraud-prevention purposes. We also may include Web beacons in e-mail messages to record whether an email has been opened or whether certain links in such email have been clicked. We or third parties also may send instructions to your device using JavaScript or other computer languages to store or gather the sorts of data described above and other details about your interactions with the Website. We may also use these pixels to deliver notices about new and existing features on our Website. These reminders and notices may appear on other websites, and third parties who provide the pixels may use the information obtained from pixels for their business purposes. To opt out of such use of third party pixels for advertising, please visit http://www.aboutads.info/choices.

· Online Analytics

We may use third-party web analytics services on our Services, such as Google Analytics. These service providers use the technology described in this “Information that is Automatically Collected” section to help us analyze use the Services, including by noting the third-party Web site from which Website visitors arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here.

HOW WE USE INFORMATION COLLECTED

We and third-party vendors acting on our behalf, may use the information that we collect through our Website for a variety of purposes, including to:

• Fulfill any request you make;

• Communicate with you, including, without limitation, via email;

• Connect you with and provide you with information about RVO Health or RVO Health’s services or providers of services:

• Provide you with content, including, without limitation, generating recommendations and processing your preferences and requests;

• Analyze, customize, and personalize the Website, including through the delivery of tailored content and communications;

• Verify your compliance with your obligations in our Terms of Use or other RVO Health policies;

• Process any job applications or inquiries about jobs with us, including assessing your qualifications for a particular opening you’ve applied for or any other opportunities at RVO Health;

• Improve the quality of the Website;

• Comply with laws, regulations, and other legal process and procedures;

• Establish, exercise, or defend our legal rights;

• Take steps that we reasonably believe to be necessary to protect the safety, security, and rights of RVO Health, its employees, service providers, and others; and

• Provide services as directed by you or provided for herein.

Except where prohibited by law, and only to the extent permitted by RVO Health’s agreements with applicable partners, we may also use your Information in connection with any other services we make available to you.

CREATION AND USE OF COMBINED DATA, DE-IDENTIFIED DATA, AND AGGREGATED DATA

As permitted by law and by RVO Health’s agreements with applicable RVO Health Partners, RVO Health, and any third party vendors acting on RVO Health’s behalf, may aggregate and/or de-identify your Information and/or combine your Information with other information maintained or available to RVO Health and may also use and disclose de-identified data, de-identified aggregated data, and/or de-identified combined data for any purpose, including improving our products and services, conducting analytics such as evaluating our Website and disclosing to RVO Health Partners for analytics purposes.

HOW WE PROTECT YOUR INFORMATION

The security of your Information is important to us. We follow security standards to protect the Information submitted to us from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

HOW WE SHARE INFORMATION

We may disclose your Information in the following circumstances.

DISCLOSURES TO SERVICE PROVIDERS AND RVO HEALTH PARTNERS

RVO Health, and third-party vendors acting on our behalf, may disclose your Information to RVO Health Partners, third party service providers, or vendors acting on our behalf for the purpose of providing the Website and related services to you or other users, including, without limitation providing you with information you have requested through the Website or related services.

SAFETY, SECURITY AND COMPLIANCE WITH LAW

Your Information and the contents of your communications through the Website may be disclosed to third parties as required by law, such as to comply with a subpoena or similar legal process, or when we reasonably believe disclosure is necessary to protect our rights (including to enforce our Terms of Use), protect your safety or the safety of others, investigate fraud, report improper or unlawful activity, or respond to a government request.

SUBSIDIARIES AND AFFILIATED COMPANIES

Except where prohibited by law or precluded by contract, we may share your Information with any subsidiaries or other affiliated companies under common control with RVO Health for the purposes set out in this Policy.

SALE, MERGER OR SIMILAR TRANSACTION

We may share your Information in connection with any proposed or actual merger, reorganization, a sale of some or all our assets, a financing or acquisition of all or a portion of our business by another company, or to a receiver, trustee or successor in interest in bankruptcy, in which case such company may continue to process your Information as set forth in this Policy (except where prohibited by law) or otherwise with your consent.

AT YOUR DIRECTION/CONSENT

We may share information about you with third parties whenever you consent to or direct such sharing.

AGGREGATE/DE-IDENTIFIED INFORMATION

We may create and share aggregate/de-identified information about use of the Website, such as by creating reports on usage trends.

THIRD PARTY WEBSITES AND SERVICES

Our Services may contain links that enable you to visit or use other third party websites, resources or programs. However, we do not have control over the other websites, resources, or programs that you choose to visit, so this Policy does not apply to information collected or that you provide while visiting such other websites, resources, or programs. You should refer to the privacy policies, if any, applicable to the other websites, resources, or programs.

OUR DATA RETENTION PRACTICES

Personal data will be retained for so long as reasonably necessary for the purposes set out above, considering criteria such as applicable rules on statute of limitations and at least the duration of your use of our Website. Information may persist in copies made for backup and business continuity purposes for additional time.

OUR LEGAL BASES FOR PROCESSING OF YOUR INFORMATION

The laws of some jurisdictions such as the laws of the European Union and United Kingdom require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your Information. To the extent those laws apply, our legal grounds are as follows:

·      Contractual Commitments: We may use, share, or disclose your Information to honor our contractual commitments to you. For example, to comply with our Terms of Use, which you accept by browsing or otherwise accessing the Website.

·      With Your Consent: Where required by law, and in some other cases, we use, share, or disclose your Information on the basis of your consent.

·      Legitimate Interests: In many cases, we use, share, or disclose your Information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as user support, analyzing and improving our business, providing security for the Website, preventing fraud, and managing legal issues.

·      Legal Compliance: We need to use, share, and disclose your Information in certain ways to comply with our legal obligations.

YOUR CHOICES

CHOICES REGARDING ACCESSING, UPDATING, AND DELETING INFORMATION

You may update and/or delete certain Information by contacting us at contact@rvohealth.com. We will respond to your request within a reasonable and lawful timeframe under the circumstances of your request. We may request you provide us with information necessary to confirm your identity before responding to your request.

Please note that even though you may request the deletion of your Information, we may be required or authorized (by law or otherwise, such as to prevent fraud, resolve disputes, or troubleshoot problems) to retain certain information. We may also keep a copy of your Information to protect our legal rights, such as in connection with your use of the Website or your agreement to our Terms of Use, as permitted or required by applicable law.

CHOICES REGARDING COMMUNICATIONS FROM RVO HEALTH

You can decline promotional communications at the point information is requested or, by following the unsubscribe instructions on communications sent to you. You can also contact us as described in the “How to Contact Us” section below.

Please also note that you, not RVO Health, have control over certain settings for how communications such as emails are displayed on your devices, and the settings you select will affect how RVO Health’s communications are displayed (e.g., whether they are visible on a locked screen and whether a preview of message content is displayed).

You may initiate communications with us via email, or you may request that we communicate with you via email. By doing so, you are acknowledging and accepting the risks associated with using unencrypted email to communicate with us, particularly where you request communications that may include health information about you or others. If you do not agree, please do not request sensitive information via emails.

HOW TO CONTACT US

To contact us, please email us at contact@rvohealth.com.

YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, you may have certain rights. For more information, please see the Supplemental Privacy Notice for California Residents below.

CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to this Policy on this page with a notice that the Policy has been updated on the Website home page. If we make material changes to how we treat our users' personal information, we will notify you, such as through a notice on the Website home page. The date the Policy was last revised is identified at the top of the page.

SUPPLEMENTAL PRIVACY NOTICE FOR CALIFORNIA RESIDENTS

If you are a California resident, you may have certain rights. These rights apply to personal information we collect on or through the Website and through other means (such as information collected offline, in person, and over the telephone). It does not apply to personal information not subject to the California Consumer Privacy Act, such as personal information subject to HIPAA.

SUMMARY OF INFORMATION WE COLLECT

California law requires us to disclose information regarding the categories of personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as those terms are defined by applicable law) for which the information was collected, and the categories of parties with whom we disclose personal information.

Except for the information not subject to the California Consumer Privacy Act, in the preceding twelve months, we or our service providers may collect the below categories of information for business or commercial purposes (as those terms are defined in applicable law):

• Identifiers (such as account information, name, email address, mailing address, or phone number);

• Commercial information (such as transaction data);

• Internet or other network or device activity (such as IP address, unique device, advertising, and app identifiers, browsing history or other usage data);

• Location information (such as general location, and, if you provide permission, precise GPS location);

• Sensory information (such as audio recordings if you call our customer service);

• Inference data about you; and

• Other information that identifies or can be reasonably associated with you (such as user generated content).

We collect the categories of personal information identified above from the following sources: (1) directly from you; (2) through your use of the Website; (3) affiliates; and (4) third parties such as information received from our vendors and other users who, for example, may refer you to use the Website.

We collect the categories of personal information identified above for the following business and commercial purposes:

• Providing the Website (e.g., maintenance, analytics, and communication about the Website);

• Our or our service provider’s operational purposes;

• Auditing consumer interactions on our site;

• Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity;

• Bug detection and error reporting;

• Customizing content that we or our service providers display on the Website;

• Improving our existing Website and developing new services (e.g., by conducting research to develop new products or features);

• Other uses about which we notify you.

We may also use the categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

We describe our information sharing practices in the Policy above. In the previous twelve months, we may have shared certain categories of personal information with other parties, as such as vendors that provide services to us.

YOUR RIGHTS

If you are a California resident, California law may permit you to request that we:

• Provide you the categories of personal information we have collected or disclosed about you in the last twelve months; the categories of sources of such information; the business or commercial purpose for collecting or selling your personal information; and the categories of third parties with whom we shared personal information.

• Provide access to and/or a copy of certain information we hold about you.

• Delete certain information we have about you.

You may have the right to receive information about the financial incentives that we offer to you (if any). You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law. We may need certain types of information so that we can provide certain Services to you. If you ask us to delete it, you may no longer be able to access or use the Website.

You also have the right to not be discriminated against (as provided for in applicable law) for exercising certain of your rights. Certain information may be exempt from such requests under applicable law.

If you would like to exercise any of these rights, please submit a request contact@rvohealth.com. You may be required to verify your identity before we fulfill your request. You can also designate an authorized agent to make a request on your behalf. To do so, you must provide us with written authorization or a power of attorney, signed by you, for the agent to act on your behalf. You will still need to verify your identity directly with us.

The California Consumer Privacy Act (CCPA) sets forth certain obligations for businesses that “sell” personal information. Based on the definition of “sell” under the CCPA and under current regulatory guidance, we do not believe we engage in such activity and have not engaged in such activity in the past twelve months.

RVO Health does not currently recognize or respond to browser-initiated Do-Not-Track signals, as the Internet industry is currently still working on Do-Not-Track standards, implementations and solutions.