Privacy Notice

Effective Date: 06/01/2018

At MPOWERHealth, a Delaware limited liability company (“MPOWERHealth”, “we”, or “us”), we value the trust that our customers, business partners, and employees place in us to appropriately use and protect information shared with us. This Privacy Notice describes how MPOWERHealth collects and uses personal information about you when you visit our website as well as your choices about how personal information will be used. By using this website, you accept the privacy practices contained in this Privacy Notice. We encourage you to read this Privacy Notice in full to understand our privacy practices before using this website or submitting any personal information.

Scope

The MPOWERHealth Privacy Notice applies only to [www.mpowerhealth.com].  [MPOWERHealth affiliates and subsidiaries may have their own subdomains and websites that may not be subject to this Privacy Notice]. MPOWERHealth business partners, ad networks, and other third parties have their own websites and privacy practices. We encourage you to read the privacy notices of all websites you visit to understand their privacy practices and your options.

Personal Information We Collect

When you visit our website, we collect the following personal information about you:

• Contact information, such as your name, home or other physical address, email, telephone number, fax number, organization name, and/or job title when you submit a contact form.
• Unique identifiers and preference information such as your username, password, marketing preferences, internet protocol (IP) address, browser type, operating system, computer or mobile device, your navigation and clickstream behavior from actions that you take on our website.
• Information about you from affiliates, subsidiaries, business partners, ad networks, and other third parties and combine it with information we already have about you.
• Information about you that you share or make visible on the Internet. We may combine such information with information we already have about you.

Tracking Technologies We Use

We use various technologies to collect personal information about visitors to our website. These technologies include the following:

Web logging

• As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp and/or clickstream data.

Cookies and other tracking technologies

• We and our subsidiaries, business partners, marketing partners, affiliates, or other service providers use technologies such as: cookies, beacons, tags and scripts. These technologies are used in analyzing trends, remembering users’ settings, administering the site, tracking users’ movements around the site and to gather demographic information about our user base as a whole. [We may receive reports based on the use of these technologies by companies such as Google Analytics on an individual as well as aggregated basis]. To learn more about Google Analytics’ privacy practices and opt-out, click here. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use our site, but your ability to use some features or areas of our site may be limited.
• We also use local storage [such as HTML5] to store content information and preferences. Third parties with whom we partner to provide certain features on our site or to display advertising based upon your Web browsing activity use local storage such as HTML5 to collect and store information. Various browsers may offer their own management tools for removing local storage.

Advertising

• We partner with third parties, including Google, to manage our advertising on other external websites. Our third party partners may use cookies and other technologies to gather information about your activities on this website and other websites in order to provide you advertising based upon your browsing activities and interests.  [Please note this does not opt you out of being served ads. You will continue to receive generic ads. To opt out of Google’s use of cookies to serve you ads based on your visit to this website, click here].

Response to “Do Not Track” Signals

Some web browsers have a “Do Not Track” feature. This feature allows you to tell websites you visit that you do not want to have your online activity tracked over time and across websites. These features are not yet uniform across browsers. Our website does not respond to web browser “Do No Track” signals.

Use and/or Sharing of Collected Personal Information

Use:
We may use the information collected for the following purposes:

• Improve the content on our website.
• Provide personalized website content based on your preferences.
• Communicate with you and respond to your inquiries, requests and applications and/or send important notices.
• Market products and services.
• Conduct surveys and research.
• If you participate in surveys, we will request certain personal information from you. Participation in these surveys or contests is completely voluntary and you therefore have a choice whether or not to disclose this information. We may use a third party service provider to conduct these surveys or contests. We will not share the personal information you provide through a contest or survey with other third parties unless we give you prior notice and choice.
• Further develop our products and services to improve our business.

Sharing:  We [will] share personal information about visitors to our website with third parties only in the ways that are described in this Privacy Notice. [MPOWERHealth does not sell such personal information to third parties].

• We may provide your personal information to third parties that provide services to help us with our business activities such as marketing communications and web analytics. These companies are authorized to use personal information about you only as necessary to provide these services to us.
• Some of our pages use framing techniques to serve content to/from our partners while preserving the look and feel of our website. Please be aware that you are providing personal information to these third parties and not directly to MPOWERHealth.
• [Our website offers a publicly accessible blog]. You should be aware that any personal information you provide in these areas may be read, collected and used by others who access them. To request removal of personal information from our blog or community forum, contact us at info@mpowerhealth.com.

We may also disclose personal information about visitors to our website:

• As required by law, such as to comply with a subpoena or similar legal process.
• When we believe in good faith that disclosure is necessary to protect our rights or property, protect your health and safety or the health and safety of others, investigate fraud or respond to a government request.
• If MPOWERHealth is involved in a merger, acquisition or sale of all or a portion of its assets.
• To any other third party with your prior consent to do so.

Access to Personal Information

Some MPOWERHealth products and services allow you to directly view, edit or delete information about you online.  If this option is not available, you can update information about you by contacting your account representative or our [Privacy Office] at info@mpowerhealth.com or the address listed below. We will respond to your request within a reasonable timeframe.

We will retain your personal information for as long as your account is active or as reasonably useful for commercial purposes. We will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.

Choice

Where appropriate or legally required, we will describe how personal information about you that we collect on our website will be used and will provide choices about whether or not to allow us to engage in that use. To exercise your choice, you can contact us to correct, update, amend or request deletion of your personal information through your account representative or through the [Privacy Office] at info@mpowerhealth.com or the address listed below.  If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or contacting us using the contact information listed below in this Privacy Notice.

Health Insurance Portability and Accountability Act (“HIPAA”)

As a key provider of services and technology to the health care industry, MPOWERHealth has implemented programs to address the privacy and security HIPAA requirements. Under HIPAA, each covered entity (health care provider, health plan or health care clearinghouse) is required to provide or make available to you a Notice of Privacy Practices (NoPP), depending on your interaction with the covered entity. To the extent a MPOWERHealth affiliate and subsidiary is a covered entity, a NoPP will be provided to you or made available to you. The NoPP is not related to the practices described in this Privacy Notice.

Protecting Your Information

We use reasonable and appropriate physical, technical and administrative industry safeguards to protect information from unauthorized access, use, loss, misuse or unauthorized alteration. We will make reasonable efforts to protect personal information stored on the website’s servers from unauthorized access using commercially available computer security products (for example, firewalls), as well as carefully developed security procedures and practices. Notwithstanding our security safeguards, it is impossible to guarantee 100% security in all circumstances. If you have any questions about security on our website, you can contact our Privacy Office at privacy@Mpower.com or the address listed below.

Seals, Buttons and Content from Other Companies

Our website may include seals, buttons and content links to other companies (for example, Facebook, LinkedIn, Twitter, YouTube, and Instagram). These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the feature to function properly. When you use a link to go from [mpowerhealth.com] to another website, our Privacy Notice is no longer in effect. We encourage you to read the privacy notice of each website you visit.

Privacy Shield Framework  [Confirm Applicability]

MPOWERHealth adheres to the Privacy Shield Framework as set forth by the U.S. Department of Commerce, and publicly certifies that it complies with the Privacy Shield Principles. We are committed to subjecting all personal information received from European Economic Area (EEA), in reliance on the Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Framework, or to view our certification, please visit the U.S. Department of Commerce’s Privacy Shield website.

MPOWERHealth is responsible for the processing of personal information it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. We comply with the Privacy Shield Principles for all onward transfers of personal information from the EEA, including the onward transfer liability provisions.

With respect to personal information received or transferred pursuant to the Privacy Shield Framework, MPOWERHealth is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose personal information in response to lawful requests by public authorities, including for meeting national security or law enforcement requirements.

Under certain conditions, more fully described on the Privacy Shield website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

Children’s Privacy

This website is not directed to children under the age of 13, and we do not knowingly collect information from children under the age of 13.

Changes to this Privacy Notice

MPOWERHealth may periodically update this Privacy Notice to describe new website features, products or services we offer and how it may affect our use of information about you and your controls. We will not apply changes to this Privacy Notice retroactively to personal information we have previously collected. MPOWERHealth is under no affirmative obligation to notify you that it has changed this Privacy Notice.

Since we may change this Privacy Notice, we recommend that you check the current version available from time to time. If we make changes to this notice, we will update the “Effective Date” at the beginning of this notice.

Contact Information

If you have questions or concerns about this Privacy Notice, our information handling practices, or any other aspect of privacy and security of your personal information, please email us at [info@mpowerhealth.com].