PRIVACY POLICY

Last Updated: November 1, 2024

• Please Read Carefully

This Privacy Policy describes the information that governs your access to and use of the websites, platform, and all other services provided by CareKash LLC dba HLTHCard, a California limited liability company (collectively referred to as “Company” or “HLTHCard”). Although HLTHCard does not collect information about you through our website (other than as  specifically noted below), you may elect to submit information that HLTHCard may collect and retain through the HLTHCard platform (“Platform”) and the services we provide (collectively, the “Services”). This policy describes how we use and share that information, who will have access to the information we collect, and the security measures Company offers to protect your information. This policy applies to information we collect or maintain when you access or use our website(s).

This Privacy Policy does not apply to the individual relationship between you and HLTHCard related to your use of the Platform, the Services, and such use and interaction. A separate agreement governs delivery, access, and use of the Services on the Platform (the “Services Agreement”), including the processing of data uploaded through our Platform (hereinafter, “Personal Information,” as described herein).

When you visit our website, you are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as the Site’s Terms and Conditions.

Similarly, by visiting, accessing, or using the Platform, you are automatically accepting and agreeing to the most-recent version of this Privacy Policy, as well as the Site’s Terms and Conditions, and your continuing visit, access or use of the Site reaffirms your acceptance and agreement in each instance.

• Changes to this Privacy Policy

We may change this Privacy Policy from time to time. If we make changes, we will notify you by posting the updated policy on our Platform and revising the “Last Updated” date above. We encourage you to review the Privacy Policy whenever you use our Services to stay informed about our information practices and about ways you can help protect your privacy.

• Use of Services

Your access to and use of our Services are subject to certain terms and conditions, which are set forth in our Terms of Use and Acceptable Use Policy.

• Collection of Information

                  4.1 When do we collect Personal Information?

    We collect Personal Information from you when you:

• register for an account on our Site;
• enter information on our Site;
• access or use our Site and/or HLTHCard;
• contact or correspond with us; or
• respond to a survey or marketing communication from us.

‍

                  4.2 Information We Collect from Your Use of the Services

Your access to and use of our Services are subject to certain terms and conditions, which are set forth in our Terms of Use and Acceptable Use Policy.

• Personal identifying data (first, middle and last name, job title, location of residence, time zone, photograph, geographic location, date of birth);
• Communication/contact Details (email address, telephone number, mailing address, phone number); and
• Payment and bank information.

Specifically, we collect information about you when you use our Platform, including, but not limited to the following:

• Account Information. When you register with us using the Platform to create an account and become a registered user, you will need to provide us with certain personally identifiable information to complete the registration, including information that can be used to contact or identify you and payment or other billing information in some cases.

• Device Information. We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as (a) IP addresses, geolocation information (as described in the next section below), unique device identifiers and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as: referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information. As described further below, we may use third-party analytics providers or service providers and technologies, including cookies and similar tools, to assist in collecting this information.

• Location Information. We may collect different types of information about your location, including general information (e.g., IP address, zip code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if your IP address indicates an origin in Los Angeles, California, the Services may be customized with Los Angeles-specific information and advertisements. In order to do this, your location information may be shared with our agents, third party vendors or third party advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

• ‍Cookies and Other Electronic Technologies. We may use the tools outlined below in order to better understand users. As we adopt additional technologies, we may also gather additional information through other methods.                                                                                                                                                                                           
  • Cookies: “Cookies” are small computer files transferred to your computing device that contain information such as user ID, user preferences, lists of pages visited and activities conducted while using the Services. We use Cookies to help us improve or tailor the Services by tracking your navigation habits, storing your authentication status so you do not have to re-enter your credentials each time you use the Services, customizing your experience with the Services, and for analytics and fraud prevention.                                                                                                                
  • You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. If you turn cookies off, some of the features that make your Site experience more efficient may not function properly and you may not be able to access all of the functionalities of the Site and Platform. You do this through your browser settings. Since each browser is a little different, look at your browser’s Help Menu to learn the correct way to modify your cookies. Below are the methods offered by the primary browsers which allow the users to express their options regarding the use of cookies:                                                                                       
    1. Internet Explorer
    2. Chrome
    3. Firefox
    4. Opera
  • Web Beacons: “Web Beacons” (a.k.a. clear GIFs or pixel tags) are tiny graphic image files imbedded in a web page or email that may be used to collect anonymous information about your use of our Services, the websites of selected advertisers, and the emails, special promotions or newsletters that we send you. The information collected by Web Beacons allows us to analyze how many people are using the Services, using the selected advertisers’ websites or opening our emails, and for what purpose, and also allows us to enhance our interest-based advertising.                                                                                                                                                         
  • Platform Analytics: We may use third-party analytics services in connection with the Platform, including, for example, to register mouse clicks, mouse movements, scrolling activity and text that you type into the Platform. These analytics services generally do not collect personal information unless you voluntarily provide it and generally do not track your browsing habits across sites which do not use their services. We use the information collected from these services to help make the Platform easier to use.

‍

Third-Party Behavioral Tracking

We do not allow third-party behavioral tracking.

‍
Uploaded Content

HLTHCard and/or the Services may allow you to upload certain data (“Customer Data”). You agree not to create Customer Data that contains or references, and you understand and agree that we have no obligations or liability with respect to: (i) information that can identify an individual in relation to any past, present, or future physical or mental health or condition, provision of health care, or payment for the provision of health care, including, but not limited to, diagnoses, treatment information, medical test results, and prescription information; and/or (ii) an individual’s race, ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data, sex life or sexual orientation. Without limiting the generality of the foregoing, you acknowledge in no event will the Company be liable to you or any third party for any direct, indirect, incidental, lost profits, remote, cover, exemplary, consequential, special, or punitive damages, regardless of the foreseeability of such damages resulting from your upload of Customer Data.

‍

                  4.3 Information from Third Parties

Although we may obtain additional information from third parties such as marketers, partners, researchers, and others, we do not request or retain specific information about you. Nor do we combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

                  4.4 Aggregate or De-identified Data

We may aggregate and/or de-identify information collected by the Services or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose, in accordance with applicable laws and regulations.

• Changes to this Privacy Policy

We use the information that we collect for the following purposes:

1. For the purposes for which you provided the information.
2. To contact you when necessary or requested.
3. To personalize your experience with the Services by informing you of products, programs, events, services, and promotions of Company, our affiliates, our partners and/or third parties that we believe may be of interest to you (see the “Opt-In Policy” below).
4. To send mobile notifications (you may opt-out of this service).
5. To provide, maintain, administer, improve, or expand the Services, perform business analyses, or for other internal purposes to support, improve or enhance our business, the Services, and other products and services we offer.
6. To respond to your customer service requests.
7. To compile data regarding Site traffic and Site interaction to better user experience.
8. To customize and tailor your experience of the Services.
9. To provide access to your account through the Site.
10. To send emails and other communications that display content that we think will interest you and according to your preferences.
11. To send you news and information about our Services.
12. To track and analyze trends and usage in connection with our Services.
13. To better understand who uses the Services and how we can deliver a better user experience.
14. To combine information received from third parties with the information that we have from or about you and use the combined information for any of the purposes described in this Privacy Policy.
15. To conduct research and measurement activities for purposes of product and service research and development, advertising claim substantiation, market research, and other activities related to Company, the Site and/or their respective products and/or services.
16. To use statistical information that we collect in any way permitted by law, including from third parties in connection with their commercial and marketing efforts.
17. To prevent, detect, and investigate security breaches, fraud, and other potentially illegal or prohibited activities.
18. To enforce the legal terms that govern your use of the Services.
19. To protect our rights or property.
20. To administer and troubleshoot the Services.
21. For any other purpose disclosed to you in connection with our Services.

We may use third-party service providers to process and store personal information in the United States and other countries.

• Third-Party Disclosure

We do not sell, trade, or otherwise transfer your Personal Information, or data that you provide to HLTHCard (including but not limited to the content you upload to our Site, including pre-recorded videos, video transcripts, any drafts or notes you upload to your account, and names of existing patients to whom the pre-recorded content will be transferred) to outside parties, except we may disclose such information to third parties under the following circumstances:

1. With third parties to provide, maintain, and improve our Services, including service providers who access information about you to perform services on our behalf;
2. If it is necessary to protect the safety of Company employees, agents, customers or any person;
3. In connection with, or during the negotiation of, any merger, sale of Company stock or assets, financing, acquisition, divestiture or dissolution of all or a portion of our business (but only under non-disclosure and confidentiality agreements and protections);
4. If we believe that disclosure is reasonably necessary to comply with any applicable law, regulation, legal process or governmental request; to enforce applicable user agreements or policies; to protect the security or integrity of our Services; and to protect us, our users or the public from harm or illegal activities;
5. To our service providers, business partners, suppliers, sub-contractors, or agents who perform services for us, as well as our professional advisers (including our lawyers, bankers, auditors and insurers), and analytics and search engine providers that assist us in the improvement and optimization of the Services.
6. With your consent

We may also share aggregated, non-personally identifiable information with third parties for any purpose because we have taken reasonable steps to carefully remove any identifiers that may personally identify you.

• Data Retention

Company will retain Customer Data in accordance with a customer’s instructions (including to perform any applicable terms in the Customer Agreement and through customer’s use of Services functionality) and as required by applicable law. Customer may customize its retention settings as it develops its Platform. The deletion of Customer Data and other use of the Services by the customer may result in the deletion and/or de-identification of certain associated Other Information.

Company may retain Other Information pertaining to you for as long as necessary for the purposes described in this Privacy Policy (such as to provide the Services, including any optional features you use, and to provide customer support). This may include keeping your Other Information after you have deactivated your account for the period of time needed for Company to pursue legitimate business interests, conduct audits, comply with (and demonstrate compliance with) legal obligations, resolve disputes, and enforce our agreements.

• Opt-In Policy

When you supply us with personally identifiable information in connection with your use of the Services, you may be asked to indicate whether you are interested in receiving information from us about our product and service offerings and if you would like us to share personally identifiable information about you with our affiliates, partners or other third parties for their marketing purposes. If you do choose to opt-in, you will receive such communications and/or we will share your information in accordance with your “opt-in” consent.

You may, of course, choose not to receive additional marketing information from us or choose not to allow our sharing of your personally identifiable information as follows:   at any time, you can follow a link provided in our marketing-related email messages (but excluding e-commerce confirmations and other administrative emails) to opt out from receiving such communications; or at any time, you can contact us in accordance with the “Contact Us” section below to opt out from receiving such communications.

If you decide to contact us to change your contact preferences to opt out of receiving communications from us, please specify clearly which of the following choices you are opting out of: (a) receiving marketing communications from us; (b) allowing us to share personally identifiable information about you with our affiliates and partners for their marketing purposes; and/or (c) allowing us to share personally identifiable information about you with other third parties for their marketing purposes.

We will endeavor to implement your requested change as soon as reasonably practicable after receiving your request. Please be aware that your requested change will not be effective until we implement such change. Please note that if you choose not to allow our sharing of your personally identifiable information, we are not responsible for removing your personally identifiable information from the databases of third parties with which we have already shared your personally identifiable information as of the date that we implement your request. If you wish to cease receiving marketing-related e-mails from these third parties, please contact them directly or utilize any opt-out mechanisms in their privacy policies or marketing-related e-mails.

Please note that if you do opt-out of receiving marketing-related messages from us, we may still send you important administrative messages. You cannot opt-out from receiving these administrative messages. We reserve the right, from time to time, to contact former customers or users of the Services for administrative purposes or in order to comply with applicable laws, rules or regulations

• Social Media and Third Party Platforms

Company Site does not currently allow you to engage with or share information on websites that are owned or operated by other companies, including third party social media sites or platforms such as Facebook, Instagram, LinkedIn, Twitter, or other similar sites (collectively, “Third-Party Websites”), directly from the Site or Platform.

• Security and Protection of Your Personal Information

Your Personal Information is contained behind secured networks and is only accessible by a limited number of Company personnel who have special access rights to such systems and are required to keep the Personal Information confidential. We implement a variety of security measures when a user places an order, submits, or accesses their Personal Information to maintain the safety of your Personal Information.

We take reasonable measures, including administrative, technical, and physical safeguards, to help protect personal information from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, while we strive to protect your Personal Information, Company cannot ensure or warrant the security of any information you transmit to us, or upload Customer Data to the Platform,, and you do so at your own risk. Please note that information you send to us electronically may not be secure when it is transmitted to us.  We recommend that you do not use unsecure channels to communicate sensitive or confidential information (such as your Social Security number) to us, or to upload Customer Data. To help maintain the security of your personal information, we ask that you please notify us immediately of any unauthorized visit, access or use of the Site, or the loss or unauthorized use of your user access information for the Site (e.g., username or password).

• Children

Company provides content on its Platform intended for use only by persons eighteen (18) years of age and older. Company does not allow use of our Services, websites, and Platform by anyone younger than 18 years old, to the extent prohibited by applicable law. Neither the Site(s) nor the Platform is designed or intended to attract and is not directed to, children under 18 years of age, let alone children under thirteen (13) years of age. Company does not knowingly collect or maintain personally identifiable information from persons under 18 years of age without verifiable parental consent.  If you learn that anyone younger than 18 has unlawfully provided us with personal data, please contact us and we will take steps to delete such information.

Your Privacy choices

• How You Can Access and Update Your Information

You may update or correct information about yourself at any time or by emailing us at hello@hlthcards.com.

• Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject cookies; however, our Services may not function properly if you do so.

• Options for Opting out of Cookies

If you are interested in more information about online behavioral advertising/interest-based advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s Consumer Opt-Out link or TRUSTe’s Advertising Choices Page to opt-out of receiving tailored advertising from companies that participate in those programs.

Please note that even after opting out of interest-based advertising, you may still see Company’s advertisements that are not interest-based (i.e., not targeted toward you). Also, opting out does not mean that Company is no longer using its tracking tools—Company still may collect information about your use of the Services even after you have opted out of interest-based advertisements and may still serve advertisements to you via the Services based on information it collects via the Services.

• How Company Responds to Browser “Do Not Track” Signals

We are committed to providing you with meaningful choices about the information collected on our Platform for third-party purposes, which is why we provide above the Network Advertising Initiative’s “Consumer Opt-out” link, Digital Advertising Alliance’s Consumer Opt-Out Link, and TRUSTe’s Advertising Choices page. However, we do not 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. For more information about DNT signals, visit http://allaboutdnt.com.

• Links to Other Websites

Our Services may contain links to other Third-Party Websites, and those websites may not follow the same privacy practices as Company. We are not responsible for the privacy practices of Third-Party Websites. We encourage you to read the privacy policies of such third parties to learn more about their privacy practices.

• No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties.

• How to Contact Us

Please also feel free to contact HLTHCard if you have any questions about this Privacy Policy or HLTHCard’s practices, or if you are seeking to exercise any of your statutory rights. HLTHCard will respond within a reasonable timeframe. You may contact us at hello@hlthcards.com or at our mailing address below: