Privacy Policy

UCM Privacy Policy

Last updated: September 23rd, 2022

This Privacy Policy describes how UCM Digital Health, Inc., together with its subsidiaries and affiliates, (collectively, “UCM,” “we,” “us,” or “our”) collects, uses, maintains, discloses, and protects your information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.

Please review this Privacy Policy carefully to learn more about our privacy practices.

WHAT DOES THIS PRIVACY POLICY COVER?

This Privacy Policy applies to information collected when you access or use our websites and mobile apps, audio and/or video teleconferencing services, and/or any other online applications or services that display this Privacy Policy (collectively, the “Services”), contact us, engage with us on social media, or otherwise interact with us.

Please note, some of the information we collect through the Services includes patient information that is protected under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). This Privacy Policy does not apply to such information. If you are a patient, please see our Notice of Privacy Practices for information regarding how we process your protected health information as well as your rights concerning your protected health information.

We may provide additional “just-in-time” disclosures or information about our privacy practices. These notices may supplement or clarify our privacy practices or may provide you with additional choices about how we process your personal information.

WHAT INFORMATION DO WE COLLECT AND HOW DO WE COLLECT IT?

We collect information through a variety of means and sources, including:

INFORMATION YOU PROVIDE TO US

When you complete and submit a form through the Services, such as to register for an account, request a consult, or contact us for an appointment or general inquiry, we collect your name, date of birth, telephone number, email address, and information relevant to your request, including any pictures or videos you choose to provide. We will also collect information as part of the Services or information provided during the audio and/or video teleconference consultation itself, and, to the extent applicable, through other telephonic communications. You are responsible for ensuring the accuracy of the information that you submit to us. Inaccurate information will affect your experience when using the Services and our ability to contact you as described in this Privacy Policy.
If you contact us, we collect your name, contact information (such as your telephone number and/or email address) and the content of your correspondence.
If you sign up to receive promotional materials, we collect your email address and/or postal address.
If you participate in a survey, we collect any responses you choose to provide.
We may also collect other types of information, such as gender, age, personal interest and medical or health-related information.
If you apply to our job postings, we may collect your name, contact information (such as your telephone number and/or email address), professional experience, and visa status. It is voluntary to provide your race or ethnicity, gender, veteran status, and Self-Identification of disability.

INFORMATION COLLECTED THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

We may use automatic data collection technologies (or “tracking technologies”) to collect certain information when you visit or interact with our Services and email communications. The information we collect may include:

Usage Details. When you access and use the Services, we may automatically collect certain details of your access to and use of the Services, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through the Services.
Device Information. We may collect information about your computer and/or mobile device and internet connection, including the device’s unique device identifier, IP address, operating system, browser type, mobile network information, and the device’s telephone number.
Stored Information and Files. Certain mobile applications may access metadata and other information associated with other files stored on your device. This may include, for example, photographs and audio and video clips.

The tracking technologies we use for automatic data collection may include:

Cookies. We may use “cookies,” which are pieces of information a website or mobile application sends to your computer or mobile device while you are viewing the website or mobile application, for a variety of purposes. For example, when you return to our websites and mobile applications after logging in, cookies may provide information to the site so that the site will remember who you are. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies or block the use of other tracking technologies, some parts of the Services may then be inaccessible or not function properly.
Web Beacons. We may also use information collected through web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs), which are small pieces of data that are embedded in images on the pages of websites and mobile applications, to analyze the traffic patterns on our websites and mobile applications, such as the frequency with which our users visit various parts or pages of our websites and mobile applications. We may also use these technical methods in HTML e-mails that we send to our users to determine whether our users have opened those e-mails and/or clicked on links in those e-mails.

We use the information collected through tracking technologies for several reasons, including:

To ensure our Services operate properly and efficiently.
To improve our Services and deliver a more personalized experience.
To understand and save your preferences for future visits.
To help us analyze the use and performance of our Services, including site traffic and site interaction so that we can offer better experiences and tools in the future.
To monitor our networks and the visitors to our Services for security purposes, including detecting and preventing fraud.
For advertising purposes.

Third-Party Advertising and Analytics

Some content or applications, including advertisements, on the Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Services. They may collect information about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

We may also use third parties to help manage and optimize our Internet business and communications. Website and mobile app tracking services help websites and mobile apps to measure the effectiveness of advertising and how visitors use websites and mobile apps through the use of web beacons and cookies provided by such company. The type of information we may collect includes, but is not limited to, the pages visited, and links clicked by users. By supplementing our records, this information would help us to learn things such as what pages are most useful and attractive to our visitors and which of our tools and information most interest our visitors.

For example, we use Google Analytics to help us analyze your use of the Services. To learn more about how Google collects and processes data, please visit https://policies.google.com/technologies/partner-sites. For more information about how to opt out of having your information used by Google Analytics, visit https://tools.google.com/dlpage/gaoptout/.

INFORMATION THAT WE COLLECT FROM OTHERS

We may supplement information that we have collected directly from our users with other information that we obtain from third parties. For example, we may receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.

HOW DO WE USE YOUR INFORMATION?

In addition to the purposes and uses described elsewhere in this Privacy Policy, we collect and use information for the following purposes:

To administer, maintain, evaluate, and improve our Services.
To deliver products or services that you request from us.
To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues or feedback.
To deliver targeted advertising.
To conduct analytics and develop new features and offerings on the Services.
To send you promotional materials.
To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property or safety of UCM and our users, employees or others.
To debug, identify and repair errors that impair existing intended functionality of the Services.
To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
To operate and improve upon our business and lawful business activities, such as to maintain our accounts and records, to conduct research and perform analytics, to manage our relationships, and for any other business purpose that is permitted by law.
For such other purposes as you may consent (from time to time).

We may also combine information to create “aggregate data” or create and use de-identified data.

WHEN DO WE SHARE YOUR INFORMATION?

In addition to the specific situations discussed elsewhere in this policy, we disclose information in the following situations:

Affiliates. We may share information with our corporate affiliates (g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control).
Service Providers. We share information with contractors, service providers, and other third parties that perform services to support our business and internal operations. Among other things service providers may help us to deliver products or services that you have requested, operate and manage the Services, provide technical support, send communications, or assist with the other activities described in this Privacy Policy.
Other Third Parties. We may disclose your information in response to subpoenas, warrants, court orders, government inquiries or investigations, or in connection with any other legal process, or to comply with relevant laws and regulations. We may also disclose your information to establish, exercise, or protect the rights of our company, employees, agents, and affiliates; to defend against a legal claim; to protect the safety and security of our visitors; to detect and protect against fraud; and to take action regarding possible illegal activities or violations of our policies.
Business Transactions. If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
Other Disclosures with Your Consent. We may ask if you would like us to share your information with other third parties who are not described elsewhere in this policy.

WHAT CHOICES DO YOU HAVE?

With regard to personal information that you have provided under this Privacy Policy, you may exercise your opt-out choices available to you (if any and where applicable) by contacting us directly as described below.

Accessing and Correcting Your Personal Information. We rely on you to update and correct your personal information. You can review and change your personal information by logging into your account. If our website does not permit you to update or correct certain information, you can contact us at the address described below in order to request that your information by modified. Note that we may keep historical information in our backup files as permitted by law.]
Deleting Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this policy, unless a longer retention period is required or permitted by law. You may request that we delete your personal information by contacting us at the address described below. If required by law we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send promotional materials to you. You can stop receiving promotional emails by following the unsubscribe instructions in e-mails that you receive. If you decide not to receive promotional emails, we may still send you service-related communications.
Do Not Track Disclosure. Some Internet browsers have a “do not track” feature that lets you tell websites that you do not want to have your online activities tracked. Because these features are not yet uniform, our Services do not currently process or respond to “Do Not Track” signals.

HOW DO WE SAFEGUARD YOUR INFORMATION?

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our Services permit you to create an account. When you do, you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

CHILDREN

The Services are not intended for or directed to children under the age of 13 and we do not knowingly collect personal information from children under the age of 13.

HOW CAN YOU ASK QUESTIONS OR SEND COMMENTS TO US ABOUT THIS PRIVACY POLICY?

If you have any questions or comments about this Privacy Policy, you can e-mail us directly at legalandcompliance@ucmdigitalhealth.com. You can also write to us at the following address:

Attn: Compliance
Department
UCM Digital Health
216 River Street, 3rd floor

Troy, NY 12180

HOW WILL YOU KNOW IF WE AMEND THIS PRIVACY POLICY?

We may update our Privacy Policy from time to time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our Privacy Policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

ADDITIONAL INFORMATION FOR CALIFORNIA RESIDENTS

California residents have the right to request in writing from businesses with whom they have an established business relationship (1) a list of the categories of personal information that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (2) the names and addresses of all such third parties. Though we do not share information with third parties for their direct marketing purposes unless you first affirmatively agree to such disclosure, you can request information by writing to us at:

Attn: Compliance Department
UCM Digital Health, Inc.
216 River Street, 3rd floor
Troy, NY 12180

SPECIAL NOTE TO INTERNATIONAL USERS

The Services are hosted in the United States and are intended for and directed to users in the United States. If you are a user accessing the Services from outside of the United States, please be advised that through your continued use of the Services, you agree to the transfer, storage and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States.

Effective Date: September 23rd, 2022

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