Care Convene™ Privacy Policy

Effective Date: January 20, 2021

Care Convene™ ("Website") and its related services and product ("Application") are owned and operated by Meta-PHR, LLC (DBA Care Convene™) ("Care Convene™" or "We"). Care Convene™ has adopted this Privacy Policy ("Privacy Policy") to inform you that it collects personal information ("Personal Information") when you use the Website and Application and to explain how this Personal Information is used. Care Convene™ has also adopted this Privacy Policy because it respects your privacy and makes a concerted effort to protect your identity and personal information. When using the Website and/or Application, you are obligated to inform Care Convene™ of any changes to your Personal Information, and protect the security of your username, password, and Personal Information.

CARE CONVENE™ RESERVES THE RIGHT TO MODIFY, LIMIT, DISCONTINUE, OR REPLACE THE WEBSITE AND APPLICATION AND THIS PRIVACY POLICY IN ITS SOLE AND ABSOLUTE DISCRETION. IT IS YOUR RESPONSIBILITY TO REVIEW THIS PRIVACY POLICY ON A REGULAR BASIS TO KEEP YOURSELF INFORMED OF ANY MODIFICATIONS. IN THE EVENT CARE CONVENE™ MODIFIES, LIMITS, CHANGES, OR REPLACES THE WEBSITE OR APPLICATION OR THIS PRIVACY POLICY, YOUR USE OF THE WEBSITE OR APPLICATION AFTER SAID MODIFICATION, LIMITATION, CHANGE, OR REPLACEMENT CONSTITUTES YOUR MANIFESTATION OF ASSENT TO THE MODIFICATION, LIMITATION, CHANGE, OR REPLACEMENT HERETO.

Care Convene™ may collect Personal Information

Care Convene™ may collect Personal Information from you through various channels, including, but not limited to, through your voluntary submission of information to the Website or Application, through requests initiated by you through the Website or Application, through communication with third parties, including but not limited to banks, through the collection and analysis of information concerning your computer and browsing activities, through the use of cookies, web beacons, pixel tags, Google Analytics™, and through other sources permitted by law.

Specifically, Care Convene™ may also collect the following Personal Information, including but not limited to:

• Any information that you or your electronic device or computer submits to the Website and/or Application.

• Any personal, medical, or health-related information that you voluntarily submit to the Website and/or Application, which may include, without limitation, protected health information ("PHI"), data files from institutions. such as hospitals and laboratories, third-party activity trackers, such as Fitbit™, Withings™ or Garmin™, data regarding insurance claims, prescription and other data from pharmacies, such as Rite Aid, CVS, or Walgreens, and third-party web applications, such as Apple™ HealthKit™, and Google Fit™;

• Any information that you make public through third-party social media accounts or similar third- party sites or applications to which you allow the Website and/or Application access;

• First and last name;

• Email address;

• Payment information;

• Your IP address;

• Your geolocation;

• Your behavior and use with regard to the Website and/or Application;

• Information stored in cookies, pixel tags, or web beacons;

• Analytics data from Google Analytics™; and

• Any other additional analytic data that you voluntarily submit to the Website and/or Application

Care Convene™ may use Personal Information

Care Convene™ may use Personal Information to provide you with the Website and/or Application, process requests made by you, process any payments to the Website and/or Application, identify and fix problems with the Website and/or Application, update you on changes to the Website and/or Application, communicate with you concerning your account, and to update you on services offered through the Website and/or Application or the services of third parties.

Except where otherwise prohibited by the Health Insurance Portability and Accountability Act of 1996 (HIPAA), Care Convene™ may share your Personal Information with third parties where it has obtained your consent, whether express or implied, with health care providers that you may designate in your Member Account and other third-party service providers to provide you with services initiated at your request, with parents, subsidiaries, successors, and assigns of Care Convene™, and with business associates who offer services through or in association with the Website and/or Application.

Care Convene™ may aggregate and de-identify any Personal Information that is not PHI, which you voluntarily submit to the Website and/or Application for any lawful purpose, including, without limitation, for research or reporting purposes. Care Convene™ may sell or otherwise share such de-identified Personal Information that is not PHI individually or in the aggregate to any third-party for any lawful purpose.

To the extent that PHI is used by Care Convene™, it will be used in a manner consistent with HIPAA and any applicable Business Associate Agreement to which Care Convene™ is bound.

Care Convene™ may use your Personal Information, including your email address, to communicate with you about the Website and/or Application, your use of services related to the Website and/or Application including but not limited to promotions, advertising placements, sponsored content and/or the purchase of goods or services.

Care Convene™ will allow you to opt out of email marketing. Each email sent contains a simple and automated way for you to stop receiving email messages from us in the future. If you have received unwanted or unsolicited email sent through the Care Convene system or purporting to be sent through the Care Convene™ system, please forward a copy of that email with your comments to info@careconvene.com for review. Care Convene™ will investigate the matter immediately.

Except where otherwise prohibited by HIPAA, Care Convene™ may display the information you provide on your personal Member Account page. You are solely responsible for the protection of any Personal Information that you submit to the Website and/or Application and you are advised to review that Personal Information before you submit it to the Website and/or Application.

You acknowledge and agree that Care Convene™ is not responsible for any third-party links, content, or communications sent to you from entities or individuals that Care Convene™ does not own or control. You are advised to review the privacy policies of such third-party websites prior to engaging with them for any reason.

Care Convene™ may store Personal Information

Your Personal Information is stored and processed on computers within the United States and, through your use of the Website and/or Application, you consent to the processing and storage of your personal and Personal Information within the United States. You understand and agree that Care Convene™ may continue to store your information after you cease use of the service or disable your Account.

Care Convene™ uses all reasonable and appropriate efforts and technology to store and help prevent against the unauthorized disclosure of your Personal Information. As required by HIPAA, Care Convene™ implements administrative, physical, and technical safeguards that reasonably and appropriately protect the confidentiality, integrity, and availability of the electronic PHI that we receive, maintain, store, and transmit. Care Convene™ has appropriate HIPAA policies and procedures in place to protect the privacy and security of PHI. These safeguards include measures required by HIPAA, including but not limited to:

• Use of a fully HIPAA-compliant cloud storage service, which encrypts all data in transit and while stored

• Regular risk assessments of systems to ensure that safeguards remain relevant and effective

• Assigned security team which is responsible for maintaining compliance with HIPAA security requirements

• Screening, authorization, and training of Care Convene™ staff who come into contact with PHI

• Data backup plans

• Disaster recovery plans

• Systems regularly monitored, updated, and patched

• Incident response plan that includes reporting of security incidents to affected covered entities

• All communications with servers used by Care Convene™ are encrypted with SSL protocols

Though Care Convene™ undertakes all reasonable and appropriate efforts to protect your Personal Information, no Website or Application is completely safe. Accordingly, you provide all such Personal Information and PHI at your own risk.

Care Convene may share Personal Information

You understand and agree that Care Convene™ may specifically share some of your information with, including but not limited to: mobile service providers, search engine providers, payment processors, web merchants, and online retailers in order to complete the services offered through the Website and/or Application. Care Convene™ may also share your Personal Information under the following circumstances including but not limited to:

• For any lawful purpose that is in compliance with the laws of HIPAA

• Where Care Convene™ is complying or in good faith attempting to comply with any law, regulation or law enforcement request

• Where Care Convene™ has obtained your express or implied consent (e.g., if you opt to use the functions in the Website and/or Application that require the transmission of your PHI to a third- party, such as a health care provider designated in your Member Account, or if you have appointed or enabled a patient authorized representative to use the Website and/or Application on your behalf, including but not limited to a caregiver, parent, guardian, or other individual).

• Where sharing or disclosure of your Personal Information is necessary to provide you with the Website and/or Application services associated therewith

• Where sharing or disclosure of your Personal Information is necessary to share with parents, subsidiaries, successors, assigns, licensees, affiliates, or business partners

• Where Care Convene™ has been purchased by a third-party

• Where sharing or disclosure of Personal Information is needed to protect the employees, independent contractors, officers, directors, members, users, or shareholders of Care Convene™

• Where sharing or disclosure of Personal Information is needed to help prevent against fraud or the violation of any applicable law, statute, regulation, ordinance, or treaty

Care Convene™ may purchase other businesses or sell components of its business, including, but not limited to, the Website. In the event Care Convene™ purchases another business or sells any component of

its business, your Personal Information will continue to be used consistent with the terms of this Privacy Policy.

Opt-Out Procedure

You may prevent Care Convene™ from collecting certain Personal Information and/or PHI by:

• Not using the Website and/or Application

• Adjusting your web browser settings

• Limiting cookies or other tracking techniques

• Deleting your Member Account

• Discontinuing your use of the Website and Application

You may contact Care Convene™ with any requests regarding your information, but Care Convene™ reserves the right to act or not act upon such requests.

California Residents

California residents have the right to receive information that identifies any third-party companies or individuals that Care Convene™ has shared your Personal Information within the previous calendar year, as well as a description of the categories of Personal Information disclosed to that third-party. You may obtain this information once a year and free of charge by contacting Care Convene™ at the address below, under "Notices".

Children’s Online Privacy Protection Policy

The Website is not intended for or directed to users under the age of 18, and Care Convene™ does not knowingly or intentionally collect Personal Information from children under the age of 13 or other minors. Where appropriate, Care Convene takes reasonable measures to determine that users are adults of legal age and to inform minors not to submit such information to the Website or in response to advertisements. If you are concerned that personal information may have been inadvertently provided to or collected by Care Convene™ please contact us immediately so appropriate steps may be taken to remove such information from Care Convene’s™ database.

Notices

All questions and concerns regarding this Privacy Policy may be submitted to Care Convene™, 6757 Cascade Rd SE #43 Grand Rapids MI, 49546, with a copy emailed to info@careconvene.com.