February 3, 2023

Evolve Health (Evolve Health) values its users’ privacy. This Privacy Policy (“Policy”) will help you understand how we collect and use personal information from those who visit our website websites, mobile applications, and other online programs (“Online Services”). By accessing or using any of the Online Services, you agree that you have read and agree to be bound by this Privacy Policy. If you don’t agree, please do not use any of the Online Services. When you use any of the Online Services, we may collect information about you, and we may share some or all of that information with third parties in certain circumstances. This Privacy Policy will give you more details and information about such collection, use and sharing. Our Policy has been designed and created to ensure those affiliated with Evolve Health of our commitment and realization of our obligation not only to meet but to exceed most existing privacy standards.

We reserve the right to make changes to this Policy at any given time. If you want to make sure that you are up to date with the latest changes, we advise you to frequently visit this page. If at any point in time Evolve Health decides to make use of any personally identifiable information on file, in a manner vastly different from that which was stated when this information was initially collected, the user or users shall be promptly notified by email. Users at that time shall have the option as to whether to permit the use of their information in this separate manner.

This Policy applies to Evolve Health, and it governs any and all data collection and usage by us. Through the use of the website http://0vr.45c.myftpupload.com, you are therefore consenting to the data collection procedures expressed in this Policy.

Please note that this Policy does not govern the collection and use of information by companies that Evolve Health does not control, nor by individuals not employed or managed by us. If you visit a website that we mention or link to, be sure to review its privacy policy before providing the site with information. It is highly recommended and suggested that you review the privacy policies and statements of any website you choose to use or frequent to better understand the way in which websites garner, make use of, and share the information collected.

Specifically, this Policy will inform you of the following:

1. What personally identifiable information is collected from you through our website.

2. Why we collect personally identifiable information and the legal basis for such collection.

3. How we use the collected information and with whom it may be shared.

4. What choices are available to you regarding the use of your data; and

5. The security procedures in place to protect against the misuse of your information.

Information We Collect

It is always up to you whether to disclose personally identifiable information to us, although if you elect not to do so, we reserve the right not to register you as a user or provide you with any products or services. This website collects various types of information, such as:

• Voluntarily provided information which may include your name, address, email address, etc. which may be used to deliver the services you have requested.

• Information automatically collected when visiting our website, which may include cookies, third-party tracking technologies and server logs.

In addition, Evolve Health may have the occasion to collect non-personal anonymous demographic information, such as age, gender, household income, political affiliation, race, and religion, as well as the type of browser you are using, IP address, or type of operating system, which will assist us in providing and maintaining superior quality service.

Evolve Health may also deem it necessary, from time to time, to follow websites that our users may frequent to gleam what types of services and products may be the most popular to customers or the general public.

Please rest assured that this site will only collect personal information that you knowingly and willingly provide to us by way of surveys, completed membership forms, and emails. It is the intent of this site to use personal information only for the purpose for which it was requested, and any additional uses specifically provided for on this Policy.

Why We Collect Information and For How Long

We are collecting your data for several reasons:

• To better understand your needs and provide you with the services you have requested;

• To fulfill our legitimate interest in improving our services and products;

• To send you promotional emails containing information we think you may like when we have your consent to do so;

• To contact you to fill out surveys or participate in other types of market research, when we have your consent to do so;

• To customize our website according to your online behavior and personal preferences.

The data we collect from you will be stored for no longer than necessary. The length of time we retain said information will be determined based on the following criteria: the length of time your personal information remains relevant; the length of time it is reasonable to keep records to demonstrate that we have fulfilled our duties and obligations; any limitation periods within which claims might be made; any retention periods prescribed by law or recommended by regulators, professional bodies or associations; the type of contract we have with you, the existence of your consent, and our legitimate interest in keeping such information as stated in this Policy.

Use of Information Collected

Evolve Health does not now, nor will it in the future, sell, rent or lease any of its customer lists and/or names to any third parties.

Evolve Health may collect and may make use of personal information to assist in the operation of our website and to ensure delivery of the services you need and request. At times, we may find it necessary to use personally identifiable information as a means to keep you informed of other possible services that may be available to you from http://0vr.45c.myftpupload.com

Evolve Health may also be in contact with you with regard to completing surveys and/or research questionnaires related to your opinion of current or potential future services that may be offered.

Evolve Health uses various third-party social media features including but not limited to https://www.facebook.com/evolvehealthcares and other interactive programs. These may collect your IP address and require cookies to work properly. These services are governed by the privacy policies of the providers and are not within Evolve Health’s control.

 

Disclosure of Information

Evolve Health may not use or disclose the information provided by you except under the following circumstances:

• As necessary to provide services or products you have ordered.

• In other ways described in this Policy or to which you have otherwise consented.

• In the aggregate with other information in such a way that your identity cannot reasonably be determined.

• As required by law, or in response to a subpoena or search warrant.

• To outside auditors who have agreed to keep the information confidential.

• As necessary to enforce the Terms of Service.

• As necessary to maintain, safeguard and preserve all the rights and property of Evolve Health.

Non-Marketing Purposes

Evolve Health greatly respects your privacy. We do maintain and reserve the right to contact you if needed for non-marketing purposes (such as bug alerts, security breaches, account issues, and/or changes in Evolve Health products and services). In certain circumstances, we may use our website, newspapers, or other public means to post a notice.

Children under the age of 18

Evolve Health’s website is not directed to, and does not knowingly collect personal identifiable information from, children under the age of eighteen (18). If it is determined that such information has been inadvertently collected on anyone under the age of eighteen (18), we shall immediately take the necessary steps to ensure that such information is deleted from our system’s database, or in the alternative, that verifiable parental consent is obtained for the use and storage of such information. Anyone under the age of eighteen (18) must seek and obtain parent or guardian permission to use this website.

Unsubscribe or Opt-Out

All users and visitors to our website have the option to discontinue receiving communications from us by way of email or newsletters. To discontinue or unsubscribe from our website please send an email that you wish to unsubscribe to [email protected]. If you wish to unsubscribe or opt-out from any third-party websites, you must go to that specific website to unsubscribe or opt-out. Evolve Health will continue to adhere to this Policy with respect to any personal information previously collected.

Links to Other Websites

Our website does contain links to affiliates and other websites. Evolve Health does not claim nor accept responsibility for any privacy policies, practices and/or procedures of other such websites. Therefore, we encourage all users and visitors to be aware when they leave our website and to read the privacy statements of every website that collects personally identifiable information. This Privacy Policy Agreement applies only and solely to the information collected by our website.

Notice to European Union Users

Evolve Health’s operations are located primarily in the United States. If you provide information to us, the information will be transferred out of the European Union (EU) and sent to the United States. (The adequacy decision on the EU-US Privacy became operational on August 1, 2016. This framework protects the fundamental rights of anyone in the EU whose personal data is transferred to the United States for commercial purposes. It allows the free transfer of data to companies that are certified in the US under the Privacy Shield.) By providing personal information to us, you are consenting to its storage and use as described in this Policy.

Cookies, Web Beacons and Online Advertising

What Are Cookies?

Evolve Health and its agents use small text files called cookies, (collectively, “Cookies”). Cookies are small pieces of data that we and our agents place in your computer’s browser to store your preferences. Cookies are not themselves personally identifiable, but may be linked to Personal Information that you provide to us through your online interaction with us. A Cookie will typically contain the name of the domain (internet location) from which the Cookie has come, the “lifetime” of the Cookie (i.e. when does it expire), and a value, usually a randomly generated unique number.

Types of Cookies

Each cookie performs one or more of the following functions:

(a) Essential Cookies: These first party cookies allow you to use a feature of the Online Services, such as to stay logged in or make purchase.

(b) Analytics Cookies: These can be first party or third-party cookies. Such cookies track information about how the Online Services are used so Evolve Health can make improvements and report on our performance. Evolve Health may also use such cookies to test new ads or features.

(c) Preference Cookies: These first party cookies store your Online Services preferences.

(d) Ad Targeting Cookies: These third-party cookies (also called “behavioral” or “targeted” advertising) are placed by advertising platforms or networks to deliver ads and track performance or to deliver ads based upon your activities.

How We Use Cookies

We use Cookies so that we can improve your online experience – for example, by remembering you when you come back to visit us, and making the content you see more relevant to you. Cookies also enable us to track online purchases made through the Online Services.

• Your Control of Cookies : Web browsers allow some control of most Cookies through the browser settings. To find out more about Cookies, including how to see what Cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org. Please understand, however, if you disable Cookies, some features of the Online Services may not work as well (or at all) for you.

• Online Advertising : We use Cookies and other technologies, such as pixel tags, web beacons, and clear GIF files, to help manage our online advertising program. These technologies may enable us (or third-party advertising services we work with) to learn which advertisements bring users to the Online Services. They also may enable us (or third-party advertising services we work with) to track the actions of users online over time and across different websites or platforms to measure statistics of our marketing efforts, and to deliver electronic advertisements that may be more relevant to individual consumers and that will improve the consumer experience. For information about how tracking works for online advertising purposes, and what happens when you elect a do-not-track option, visit http://www.aboutads.info/choices.  In addition, some third-party businesses may provide a mechanism to opt-out of their technology.  For more information about the opt-out process, visit the Network Advertising Initiative website, available at: http://www.networkadvertising.org/managing/opt_out.asp. At this time, the Online Services are not able to respond to do-not-track requests from browsers.

• Analytics :  We also use third-party analytics such as Google Analytics to gather and analyze anonymous user information. Google Analytics is a web analytics service provided by Google, Inc. (“Google”), to collect information about use of the Online Services. Google may use cookies to collect information about your purchase history, the content you view, what websites you visit immediately prior to and after visiting the Online Services, and your system information and geographic information. The information generated by the Google cookies about your use of the Online Services will be transmitted to and stored by Google. The information collected by Google allows us to analyze the use of the Online Services but does not identify you.

Social Networking and Third-Party Sites

When you sign in or link to the Online Services through any social networking service, any information you supply (or have supplied) to us becomes subject to the privacy policy of that social network/service. We do not control, and are not responsible for, the privacy practices of such networks or services. You should consult the privacy policy of such networks/services. If you post information in a public forum it becomes public information. In addition, we may disclose your Personal Information in order to identify you to anyone to whom you send communications through the Online Services. The Online Services may provide links to other sites or services. If you use such other sites or services, check their privacy policies. We are not responsible for the privacy practices of any other site or service.

THIRD-PARTY HEALTH app integration

You may elect to integrate Online Services with the Apple HealthKit™ database or the Google Fit database (collectively, “Third Party Health Apps”). The Online Services cannot read or write to the Third-Party Health Apps without your express permission. Information accessed from the Third-Party Health Apps will not be shared with third-party service providers without your express permission. Your Third-Party Health App sourced data or documents will only be used, with your permission, to improve health management, or for the purpose of health research, and will not be shared with advertisers or used for marketing purposes.

The information you provide directly from the Third-Party Health Apps (not through the Online Services) is governed by the Terms and Conditions and Privacy Policy of Apple or Google. If you use one of the Third-Party Health Apps, review the Terms and Conditions and Privacy Policy for such Third-Party Health App. Evolve Health is not responsible for the protection of data and information stored within the Third-Party Health Apps.

California Residents

This section only applies to individuals who are residents of California under the California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws (together “California Laws”).

a. Personal Information Collected

This section only applies to individuals who are residents of California under the California Consumer Privacy Act of 2018 (“California Law”) where the resident is acting in their own capacity and not acting on behalf of a company or organization in the context of business activities.

Evolve Health collects the following categories of Personal Information, as defined by California Laws:

• Inferences

• Identifiers

• Health Information

• Commercial Information

• Employment Information

We collect them for the purposes described above, and may share tlined in the section titled, “Use or Sharing of Personal Information” above.

b. California Residents Rights

Under California Laws, California residents have the following rights (“Rights”) listed below. Your Right to Access and Right to Deletion are not absolute and are subject to certain exceptions. For instance, we cannot disclose specific pieces of Personal Information if the disclosure would create a substantial, articulable, and unreasonable risk to the security of the Personal Information, your account with us or the security of the business’s systems of networks.

• Disclosure & Access Rights: California residents have the right to request in writing from a business, (i) a list of the categories of personal information, such as name, address, e–mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including Independent Affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties. In addition, California residents have the right to request that we disclose to them (i) the categories of personal information we have collected about them, (ii) the categories of sources from which personal information is collected, (iii) the business or commercial purpose for the information collection, (iv) the categories of third parties with whom we have shared personal information, and (v) the specific pieces of personal information we hold about an individual.

• Deletion Rights: California residents have the right to have their personal information deleted, unless the personal information is necessary for the business or service provider to:

• Complete a transaction for which the personal information was collected, provide a good or service requested by the consumer or otherwise perform a contract between the business and the consumer;

• Detect security incidents;

• Protect against malicious, deceptive, fraudulent or illegal activity (or prosecute those responsible);

• Debug to identify and repair functionality errors;

• Exercise or ensure the right of another to exercise free speech or another legal right;

• Comply with the California Electronic Communications Privacy Act, which compels the production of or access to electronic communication information or electronic device information with a search warrant;

• Engage in research in the public interest (if the consumer has provided informed consent);

• To enable solely internal uses aligned with the consumer’s expectations given their relationship with the business;

• Comply with a legal obligation;

• Otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided it.

• Do Not Sell: Californian residents have the right to opt-out of having their personal information sold. We do not sell personal information.

Californians can exercise their privacy rights by contacting us at [email protected]

Security

Evolve Health takes precautions to protect your information. When you submit sensitive information via the website, your information is protected both online and offline. Wherever we collect sensitive information (e.g. credit card information), that information is encrypted and transmitted to us in a secure way. You can verify this by looking for a lock icon in the address bar and looking for “https” at the beginning of the address of the webpage.

While we use encryption to protect sensitive information transmitted online, we also protect your information offline.  Only employees who need the information to perform a specific job (for example, providers, billing, or customer service) are granted access to personally identifiable information. The computers and servers in which we store personally identifiable information are kept in a secure environment. This is all done to prevent any loss, misuse, unauthorized access, disclosure, or modification of the user’s personal information under our control.

The company also uses Secure Socket Layer (SSL) for authentication and private communications to build users’ trust and confidence in the internet and website use by providing simple and secure access and communication of credit card and personal information.

Acceptance of Terms

By using this website, you are hereby accepting the terms and conditions stipulated within the Privacy Policy Agreement. If you are not in agreement with our terms and conditions, then you should refrain from further use of our sites. In addition, your continued use of our website following the posting of any updates or changes to our terms and conditions shall mean that you agree and acceptance of such changes.

How to Contact Us

If you have any questions or concerns regarding the Privacy Policy Agreement related to our website, please feel free to contact us at the following email, telephone number, or mailing address.

Web Address: http://0vr.45c.myftpupload.com

Email: [email protected]

Telephone Number: 971-358-9292

Mailing Address:

Evolve Health

6400 SE Lake Rd Suite 430

Portland, Oregon 97222