Wildflower Health, Inc.

Privacy Policy

1. Introduction

Wildflower Health, Inc. (us, we, or “Wildflower Health”) is committed to protecting the private information of our customers, visitors, and other users of wildflowerhealth.com (the “Site”) and related websites, applications, services and mobile applications provided by Wildflower Health and on/in which this Privacy Policy is posted or referenced (collectively the “Application” or “Services”). Your use of the Services is governed by this Privacy Policy and by the Wildflower Health Mobile End User License Agreement, which is incorporated by reference into this Privacy Policy.

This Privacy Policy describes how we collect, use, and disclose your information as a part of providing our Services. We offer you choices about how we use certain types of information we collect and the ability to access and correct your information. We encourage you to review this Privacy Policy periodically so that you are up-to-date on our privacy practices.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY ACCESSING THE SITE, DOWNLOADING THE MOBILE APPLICATION AND/OR USING THE SERVICES, YOU AGREE TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND YOU HEREBY CONSENT TO THE COLLECTION, USE, AND SHARING OF YOUR INFORMATION AS DESCRIBED IN THIS PRIVACY POLICY.  IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, YOU CANNOT USE THE SERVICES. THIS POLICY MAY CHANGE FROM TIME TO TIME. YOUR CONTINUED USE OF THE SERVICES AFTER WE REVISE THIS POLICY MEANS YOU ACCEPT THOSE CHANGES, SO PLEASE CHECK THE POLICY PERIODICALLY FOR UPDATES.

This Privacy Policy does not apply to any other website or digital service that you may be able to access through the Services or any website or digital services of our business partners, each of which may have data collection, storage and use practices and policies that may differ from this Privacy Policy. We encourage you to review the privacy statements of websites or digital services you choose to access from the Services so that you can understand how those websites or digital services collect, use and share your information.

For any questions of if you believe that Wildflower Health has not adhered to this Privacy Policy, please contact Wildflower Health at support@wildflowerhealth.com.

2. Information We Collect and How We Collect It

We collect information from and about users of our Services:

• Directly from you when you provide it to us;
• Automatically when you use the Services; and
• From third parties who may share Personal Information with us to provide you with the Services.

3. Information You Provide To Us
   1. Information That Personally Identifies You. When you access and use any of our Services, we may ask you to provide us with certain information that personally identifies you, or the individual on whose behalf you are using the Services (including for example, your family members), or could be used to personally identify you or the individual on whose behalf you are using the Services, or that you provide to create profiles for additional users who you invite (“Authorized Users”) to use the Services in connection with your account (“Personal Information”). Personal Information about you, individuals on whose behalf you use the services or provide information or your Authorized Users may include: (i) contact data (such as name, e-mail address and phone number); (ii) demographic data (such as gender, date of birth and zip code); (iii) insurance data (such as insurance carrier, insurance plan, member ID, group ID and payer ID); (iv) medical data (including, without limitation, the doctors, dentists, pharmacies or other healthcare specialists, professionals, providers, or organizations (collectively, “Healthcare Providers”) visited, reasons for visit, medical history, and other medical and health information you choose to share with us); (v) medical data that may be collected from third-party devices that are compatible with, and linked to, the Services (including, without limitation, fitness trackers, blood pressure monitors, weight scales, fetal dopplers) (collectively, “Health Data”); and (vi) other identifying information that you choose to provide to us, including, without limitation unique identifiers such as passwords or any medical data you choose to provide while using the Services.  
   2. Information That Does Not Personally Identify You.  When you access and use any of our Services, we may also ask you to provide us with certain information that is about you but individually does not identify you, including, without limitation, information that you provide by filling in any forms (including information provided at the time of subscribing to our Services), registering to use or mobile applications, and/or requesting further services. We may also ask you for information when you report a problem with our Services.
   3. Publicly Posted Information.  You may also provide information for publication or display (“Posted”) on public areas of our website or mobile applications (collectively, “User Contributions”). Your User Contributions are Posted and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of third parties with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
   4. Decision Not to Provide Information to Us.  You may still access and use some of the Services if you choose not to provide us with any Personal Information, but features of the Services that require your and your Authorized Users’ Personal Information may not be accessible to you.
4. Automatic Information Collection
   1. Information Automatically Collected
      1. Traffic Data.  We may automatically collect certain data when you use the Services, such as (i) IP address; (ii) type of device(s) used to access the Services; (iii)  web browser(s) used to access the Services; and (iv) other statistics and information associated with the interaction between your browser or device and the Services (collectively “Traffic Data”).
      2. Location Information. We, and other third party providers or their partners may collect, maintain, process and use your location data, including the real-time geographic location of your mobile device as necessary to provide the Application’s full functionality. By using or activating any location-based services on your mobile device, you agree and consent to our and such third parties' collection, maintenance, publishing, processing and use of your location data to provide you with the Services. You may withdraw this consent at any time by turning off the location-based feature on your mobile device or by not using any location-based features of the Application. However, turning off or not using these features may impact the functionality of the Application. Location data provided by the Application is for basic navigational purposes only and neither we, nor such parties guarantee the availability, accuracy, completeness, reliability or timeliness of information or location displayed by the Application.   
      3. Tracking Tools. Wildflower Health will keep track of the screens, views, and actions that our users take when they use the Services ("Tracking Tools") in order to improve the effectiveness of the Services. This data is used to deliver customized content to users whose behavior indicates that they are interested in a particular subject area.
   2. Information Collection Technologies

The technologies we use for automatic information collection may include:

1. 1. 1. Cookies.  A cookie is a small file placed on your device. We use cookies to recognize you and authenticate your device when you access the Services. It may be possible to refuse to accept cookies by activating the appropriate setting on your web browser or device. However, if you select this setting you may be unable to access certain parts of our Services.

1. 1. 2. Web Beacons. Email communications sent to you may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have read those emails.

4. 1. 3. Do Not Track Signals. We do not currently respond to web browser “do not track” signals or other mechanisms that may allow you to opt out of the collection of information across networks of websites and online services as there is no standard for how online services should respond to such signals. As standards develop, we may develop policies for responding to do-not-track signals that we will describe in this Privacy Policy.
5. Information Collected by Third Parties
   1. Third Parties. When you use the Services, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

• Analytics companies, including AppsFlyer.
• Your mobile device manufacturer.
• Your mobile service provider.
  2. Information Collected. These third parties may use tracking technologies to collect information about you when you use this Application. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. 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.

6. Use of Personal Information

We use your information to deliver our Services, contact you periodically in connection with our Services, and to develop and improve our Services. We only use your information as described in this Privacy Policy or otherwise through your consent.

Your privacy is important to us, and we strictly limit access to your information to those employees who require this information to better serve you. Under no circumstances do our employees have access to your Health Data beyond what is needed to deliver the Services to you. Certain insurance carrier networks may be able to access your information through our Services, but only to the extent that you permit. We aim to be responsible with your information, and ensure that you know exactly how it will be used through our Services. You may correct your data according to the procedures set forth in this Privacy Policy.

Information from Tracking Tools may be shared with our third party partners who may also use screen views and actions users take when they use Services to connect them with health care benefits or resources they may be eligible for.

In addition, we also use information, including Personal Information, to provide and improve the Services. Such use may include:

• Providing you with the products, services and information you request;
• Contacting you when necessary or requested, including to (i) remind you of an upcoming appointment, (ii) assist with onboarding you to the Services as necessary, (iii) provide support for any monitoring devices provided by us, (iv) ensure you are able to receive and connect you’re your medical devices as intended, and (v) support care plan compliance, including sharing your information with care quality networks to coordinate your treatment plan;
• Combining information received from third parties with information that we have from or about you and use the combined information for any of the purposes described in this Privacy Policy;
• Fulfilling any other purpose for which you provide it;
• Notifying you when Application updates are available, and of changes to any products or services we offer or provide though it.
• Using statistical information that we may collect as permitted by law, including from third parties in connection with their commercial and marketing efforts; and
• Fulfilling our legally required obligations, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.

7. Disclosure of Personal Information

In certain circumstances, and in order to perform the Services, Wildflower Health may disclose certain information that it collects from you.

We may disclose information to the following:

• To  Healthcare Providers whom you identify as your treating provider and/or from whom you choose to receive the Services.
• To our partners who perform operational services (such as hosting, billing, fulfillment, data storage, security, insurance verification, or communication services) and/or who make certain services, features or functionality available to our users.  In every circumstance in which we share or disclose Personal Information to such partners, we will require each such partner to sign an agreement that limits their use of Personal Information to only those uses that enable us to provide the services to you as set forth in this Privacy Policy and in which they commit to protect the Personal Information in the same manner as we commit to protect it in this Privacy Policy.
• If you are accessing this Application or any specific part of this Application as a benefit provided by your Healthcare Provider, insurance provider and/or employer, to the insurance provider and/or the employer you identify to us (and via our partners) to determine eligibility and cost-sharing obligations, to monitor usage of the Application, and otherwise obtain benefit plan information on your behalf.
• To recipients in accordance with the Health Insurance Portability and Accountability Act of 1996 as amended from time to time including Sections 13400 through 13424 of the Health Information Technology for Economic Clinical Health Act and the corresponding Standards for Privacy of Individually Identifiable Health Information, Security Standards and Notification in Case of Breach of Unsecured Protected Health Information (collectively, (“HIPAA”).  HIPAA covers "protected health information" (“PHI”) held by health plans and providers. You can learn more about HIPAA at http://www.hhs.gov/ocr/privacy/. We will use and disclose such PHI only as permitted under HIPAA and as further described in our Privacy Policy.  When we create, collect, receive, maintain or transmit PHI, we do so under “business associate” agreements with our “covered entity” clients that require us to comply with HIPAA in doing so.
• To any Healthcare Provider or insurance carrier network that you opt to share your information with while using the Services. You may need to accept an additional authorization when sharing your information with your selected Healthcare Provider or insurance carrier network. Your chosen Healthcare Provider or insurance carrier network will have access to your Health Data through our Services and may apply their own information collection technologies to you. We do not control the Healthcare Provider’s or the insurance carrier network's use of shared data. For any questions about a respective Healthcare Provider or insurance carrier network's use of your Health Data, please contact them directly.
• To the extent necessary or appropriate, and in compliance with HIPAA, to government agencies, advisors and other third parties in order to comply with applicable laws, the service of legal process, or if we reasonably believe such action is necessary to: (i) respond to a court order or request from a federal or state regulatory authority or to comply with any law or regulation requiring such disclosure; (ii) protect and defend the rights or property of Wildflower Health; (iii) prevent or aid in the investigation of a crime or protect national security; or (iv) act under exigent circumstances to protect the personal safety of users of Wildflower Health, or the public.
• In connection with an audit of our books and records, a merger, reorganization, dissolution, liquidation, or sale of some or all of our assets, stock or business.

We do not sell, rent or lease our customer lists to third parties.

8. Your Choices About Our Collection, Use, and Disclosure of Your Information

We strive to provide you with choices regarding the personal information you provide to us and offer settings to control what types of messages and notifications you receive from us. This section describes mechanisms we provide for you to control certain uses and disclosures of your information.

• Tracking Technologies. You may be able to set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent.
• Location Information. You can choose whether or not to allow the Application to collect and use real-time information about your device's location through the device's privacy settings. If you block the use of location information, some parts of the Application may become inaccessible or not function properly.
• Communication Preferences. You can visit your communication preferences page to set your preferences for receiving calls, emails, texts, and push notifications. We may send you messages and notifications about how to use our Services and to provide, reminders, suggestions, and other educational content we believe may be of interest to you. You can change your communication preferences at any time. Please note that you cannot opt-out of service messages, such as security and legal notices. For all mobile text communications, U.S. mobile carrier data rates may apply.

9. Security of Information Collected

We safeguard the security of the information you provide to us with physical, electronic, and administrative procedures.

9. 1.   User level information sharing.  All information gathered in the Application is encrypted for secure storage and encrypted if and when transported over the network. We may share personally identifiable Personal Information, Traffic Data, usage information, or other information you provide while using the Services with third parties, including your Healthcare Provider or insurance provider, as listed in Section 3.1, but all sharing will be done in an encrypted and secure fashion.
   2. Data Security. Wildflower Health secures your Personal Information from unauthorized access, use or disclosure through physical, administrative and reasonable technological measures.  Although we will use reasonable efforts to safeguard the privacy of your Personal Information, transmissions over the Internet cannot be made absolutely secure. Wildflower Health assumes no responsibility or liability for disclosure of any of your Personal Information due to errors in transmission, unauthorized third-party access or other causes beyond our reasonable control. The Services rely on the Internet and mobile networks, which are not always secure. We work hard to protect Wildflower Health and our users from data breaches, but we cannot assure that the use of the Services is secure. Whenever we collect sensitive information (such as personal health data), that information is encrypted and transmitted to us in a secure way. We also protect your information offline. Only employees or contractors who need information to perform a specific task are granted access to Personal Information. The cloud in which we store Personal Information is maintained in a secure environment.  In the event we become aware of a security incident, we will notify you as required under applicable law. Wildflower Health will not, at any time, request credit card information, login information, or any identification numbers in a non-secure or unsolicited email or telephone communication. You can learn more about how to prevent identity theft at www.ftc.gov.
10. Accessing and Correcting Your Personal Information.

You have the right, at any time, to review and/or modify any of your personal information that you provided during registration or any other voluntarily provided information.

In any event, for legal compliance purposes, we may retain information about you in a legal archive until such time as we no longer have legal obligations for such information. Our back-up files will maintain copies of your personal information until we complete normal operational overwriting of such files, but no longer than ninety (90) days from the date your information was removed from our primary files pursuant to your request. We reserve the right to contact former users from time to time.

11. Children Under Thirteen

Wildflower Health does not knowingly collect Personal Information from children under the age of 13.

If you are under the age of 13, you must ask your parent or guardian for permission to use the Services. If we become aware that a user under the age of 13 has registered or is attempting to register, we will notify the user that the user is not eligible for registration. We will then expunge any related Personal Information from our records. If we learn we have collected or received Personal Information from a child under 13 without verification of parental consent, we will expunge that information. If you believe we might have any information from or about a child under 13, please contact us at support@wildflowerhealth.com.

If you are a parent or legal guardian of a minor child, you may use the Services on behalf of such minor child. Any information that you provide while using the Services on behalf of your minor child will be treated as Personal Information as described herein.

12. Changes to this Policy

Wildflower Health will occasionally update this Privacy Policy to reflect company, customer, and user feedback, changes in the law, or other updates. We encourage you to periodically review this Privacy Policy to be informed of how Wildflower Health is protecting your information. Your continued access of the Services constitutes your agreement to this Privacy Policy and any updates or revisions.

13. California Privacy Rights

As of the date of this Privacy Policy, Wildflower Health does not serve advertising on the Services and does not sell any personal information.  Due to the scope of our Services, Wildflower Health is not currently required to comply with the California Consumer Privacy Act or the California Privacy Rights Act ("California Privacy Laws").  If/when Wildflower Health is required to comply with the California Privacy Laws, we will update our Privacy Policy. 

14. Contact Information

Wildflower Health welcomes your questions or comments regarding this Privacy Policy.  If you believe that Wildflower Health has not adhered to this Privacy Policy, please contact Wildflower Health at support@wildflowerhealth.com.  We will use commercially reasonable efforts to promptly respond and resolve any issue or question.

This policy was last updated on November 2022.