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Privacy Policy

Effective February 24, 2022

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This Privacy Notice is incorporated into Our Terms of Service.

All terms defined in the Terms of Service shall have the same meaning when used herein unless otherwise noted.

Version: 1.0

Effective Date: February 24, 2022

Please read this Privacy Notice in its entirety. By visiting, accessing or using the Health Portal, or any component thereof, you are consenting to the practices described in this Privacy Notice and agree to be bound thereby. If you do not agree with the terms of the Privacy Policy, please do not visit, access or use the Health Portal.

1.NAVIERRE’S PRIVACY NOTICE

Navierre respects Your privacy. This Privacy Notice (“Privacy Notice”) describes what information We collect from or about You, how it is used, and what choices You may have regarding your information in connection with the Health Portal , including our website located at at https://navierre.com, our Navierre App, or any other Navierre related website, webpage, application, social media, or other internet, mobile, or wireless offerings no matter how accessed that provide a link to this Privacy Notice or Navierre’s Terms of Service. This Privacy Notice does not address the privacy practices of any third parties that we do not own, control, or have an affiliation with.

This Privacy Notice applies to any individual in the United States, regardless of the individual’s state of residency, who visits, accesses or uses the Health Portal or receives any related services or products.

The Health Portal may provide access to and use of personally identifiable health information (“PHI”) that You or someone You authorized has provided to Us and may be subject to additional terms under the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Please read our Notice of Privacy Practices Under HIPAA.

2.PERSONAL INFORMATION THAT WE COLLECT

  1. Types of Information:

Navierre may collect Your personal information in connection with Your access to, Your use of, or Your submissions to the Health Portal. For example, We may collect personal information about You, such as:

  • Your name, postal mailing address, email address, telephone number, and Your date of birth;

  • Your account information, including the information that You have provided to us when establishing Your User Account, such as the unique account password that you create, Your Role with the Health Portal, Your Care Team Members or other individuals that You have authorized or have authorized You to access and use the Health Portal on the other’s behalf;

  • Your history of transactions with Navierre, such as Your enrolment with the Health Portal, or Your payment information for fees, if any, paid by You to Navierre;

  • Your interactions with the Health Portal, such as Your history of uploads or downloads of medical records or other information on the Health Portal , Your preferred language for communicating with Us and/or our service providers, Your medical providers and pharmacies, individuals that You have designated Care Team Members, and the scope of each individual’s authority to access, view and receive Your medical records and information on Your behalf, or other information that we need to provide You with Access to the Health Portal or provide You with the Services that You have selected to receive;

  • Information that You share as a result of Your public participation in the Health Portal;

  • Your Health Portal access preferences, such as the device(s) that You have used to access the Health Portal. Your User Account information, or Your permissions and preferences;

  • Information about Your geolocation, such as when You sign in and use certain features and functions which require Your location;

  • Your IP address and information about Your browsing, search history and navigation on, to and from the Health Portal .

We may also obtain additional information about you that may or may not be directly linkable to you. Examples may include, but are not limited to, aggregate information, analytics information using cookie IDs, advertising segment information, advertising IDs/cookies, and device information.

  1. Sources of Information:

Navierre collects information about You from a variety of sources, including:

  • Directly from you, for example, when You create or access your User Account; subscribe for, enroll with or receive services in connection with the Health Portal; upload Your medical records or healthcare information into Your Health Wallet or other portions of the Health Portal; communicate with Us by email, phone or SMS text, such as in connection with Your enrollment or experiences with the Health Portal; when You complete webforms; when You participate in surveys, reviews, sweepstakes or contests that may be available by Navierre or its partners or affiliates from time to time; or when You submit content for publication on the Health Portal, such as for blogs, social media pages, product review pages, community events, etc.;

  • Indirectly from You, for example, by observing Your actions on the Health Portal, from the individuals or entities that You have authorized to act on Your behalf as Your Care Team Members, or through information we collect while providing related services;

  • Through Your Mobile Device, only when the Navierre App is running, and when authorized by You regarding Your “Geolocation Information”, to enable Us to provide certain features and functions of the Health Portal. You may decline to allow us to collect such Geolocational Information, in which case we will not be able to provide certain features or functionalities to you.

  • Directly and indirectly from your activity on the Health Portal, for example, through Health Portal usage details that are collected automatically, through Your inquiries or submissions, or when You use the Navierre App;

  • From third parties, for example, from individuals who You have designated as “Care Team members,” Providers that You authorize to provide medical records or other health information to the Health Portal or to use the Health Portal in their interactions with You or third parties that assist Navierre in providing customer service or maintaining the Health Portal.

3.HOW WE USE THE INFORMATION WE COLLECT

Navierre may use personal information for a variety of Navierre’s business purposes and to the extent and manner permitted by law:

  • To fulfill or meet the reason for which the information is provided. For example, to facilitate Your access and use of the Health Portal and to process Your payment, if any; to assist You to interact with and communicate with the Health Portal, or Your Care Team Members, or Providers related services, that You have designated; to respond to Your questions or communications regarding Navierre, Health Portal, and Your Navierre User Account (including any changes or corrections that You may request); and to otherwise process customer service functions;

  • To provide You with communications regarding any changes to Navierre policies or account management procedures, notices, or terms of services; information on new products or services or updates; promotions and special offers regarding Navierre, the Health Portal, programs, services, or Our partners’ or affiliates’ products, services or programs that may be of interest to you;

  • To carry out Our obligations and enforce Our rights arising from any contracts entered into between You and Us, including for billing and collections;

  • To publish content on the Health Portal, under some circumstances, such as when Navierre publishes testimonial comments or enables public participation forum by Users on portions of the Health Portal;

  • To personalize Your experience and to deliver content and service offerings relevant to Your interests, including targeted offers and ads through the Health Portal, or via email or text message (with your consent, where required by law);

  • To help maintain the safety, security, and integrity of the Health Portal, its databases and other technology assets, and business on behalf of Navierre and its Users;

  • To investigate or prevent a violation of any individual’s contractual or other relationship with Navierre, or where Navierre has a good-faith belief that access, preservation or disclosure of such information is reasonably necessary to protect the rights, property or safety of Navierre, its Users, service providers, or the public, or to prevent or respond to any illegal, fraudulent or harmful activity;

  • For testing, research, analysis, and product development, including to develop and improve the Health Portal, or other products and services, and Your experience with the Health Portal;

  • For marketing Navierre’s or Other’s Services and Products, including providing You (via alerts, banner ads, postal mail, event registration, SMS text, email and other notices) with information about offers, programs, products and services that Navierre believes may be of interest to You. You may opt-out of receiving some or all of these communications by following the directions below;

  • At the request of law enforcement or governmental agencies or in response to subpoenas, court orders or other legal process, or to establish, protect or exercise Navierre’s legal or other rights, to defend against a legal claim or as otherwise allowed by law or regulation;

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Us about Our Users is among the assets transferred.

4.HOW WE SHARE INFORMATION

Navierre does not sell Your personal information, personal health information or sensitive information to unaffiliated third parties for their business purposes, nor do we share information, except as permitted by law, as described in this Privacy Policy or otherwise without Your consent.

Navierre may share information about You to third parties for Navierre’s business purposes, such as with agents, contractors, service providers or affiliates of Ours, who help Us operate the Health Portal, provide the Services, assist with Navierre’s marketing, conduct business on Our behalf, or help Us complete a service you requested, such as processing your credit card payment or enabling Your access to and Use of Health Portal and related services that You selected. When we share information for a business purpose, we do so only to the extent required for Our business purpose and only as permitted by relevant law. We may also share personal information with third parties if you have directed and authorized Us to do so through the Health Portal.

Navierre may share personal information when required to do so by federal or state enforcement officials, when state or federal law requires Us to do so (such as to comply with an inquiry from law enforcement officials), when ordered by a court or by other compulsory legal process, or when We believe, in good faith, it is necessary for us to comply with its legal obligations or to investigate or prevent suspected illegal activities or fraud.

  1. Cookies, IP Addresses and Other Technology

“Cookies” are small pieces of information that are stored by Your browser on Your computer’s hard drive or on Your mobile device. By placing a “cookie,” Navierre and Our third-party service providers can remember and distinguish You over time. We use “cookies” for a variety of functions, such as authentication, other types of security, User logins, to enable collection of analytics information, to market the Health Portal, products and services to You, to optimize the Health Portal, and tp personalize and customize Your experience with it. As one example, cookies enable Us to remember information You gave to Us so that You don’t have to reenter it each time You visit, such as in regard to Your account information and preferences. We may use both session cookies, which expire once You exit the Navierre Website or close the Navierre App, and persistent cookies, which remain until you delete them.

If you do not wish to permit “cookies” to be placed by Us, you should turn off or disable “cookies” on your browser or device or set Your mobile device to reject cookies. You can still use the Health Portal, but disabling cookies will also prevent the Health Portal from being fully functional.

  1. IP Addresses

Navierre maintains internal logs for Internal Protocol (IP) addresses. An IP address is a number that is automatically assigned to Your computer each time You access the Internet. Your IP address does not contain personally identifiable information. Navierre or its third-party service providers may collect IP addresses in order to conduct system administration, report aggregate information, conduct site analysis, and to detect improper use of the site. We sometimes use IP addresses to identify the general location of Your computer based on publicly available and third-party information. We may use IP addresses to market to You through internet marketing, mail or call campaigns, or online targeted, interest-based advertising.

  1. Other Technical Information We Collect Through the Health Portal

In addition to using browser cookies, Navierre also may use other technologies such as pixels, local shared objects (such as “Flash cookies”), and HTML5 local storage to collect information and remember your device. For example, when using the Navierre Website, some of the technical information We collect is the type of browser You use (such as Google Chrome, Internet Edge, Safari or Firefox), Your Internet protocol (“IP”) address, the name of Your ISP, the version of Your operating system, the dimensions and resolution of your display, your referrer URL (which is the URL for the websites that you were viewing prior to visiting the Health Portal), how You were directed to the Health Portal, which specific pages You access on the Health Portal, how long You view each page, the time and date you access our Health Poral, and any other interaction You have with the Health Portal or Navierre. When You access the Health Portal using the Navierre App we may also collect information about Your mobile device, its Operating System (“OS”) and mobile service provider.

Some of this information is collected by third-party service providers who assist Navierre in the operation and maintenance of the Health Portal. Before accessing the information, he third-party service providers agree that they will not use the information for any purpose other than for the reason for which they received access to it.

Some of this information is collected by third-party service providers who assist Navierre in the operation and maintenance of the Health Portal. Before accessing the information, he third-party service providers agree that they will not use the information for any purpose other than for the reason for which they received access to it.

The Health Portal also uses various third-party services, such as Google Analytics. You can consult the Google Analytics Terms of Service and the Google Privacy Policy for more information on how Google Analytics uses the data it collects/ If You would like additional information regarding the security and privacy practices of Google Analytics, please review the materials provided by Google here.
  1. Your Options

Most popular Internet browser applications will allow You to configure the browser so as not to accept cookies. However, setting Your browser to reject cookies may, in certain instances, prevent You from taking full advantage of the Heath Portal or cause some features or functions of the Health Portal to function improperly, slowly, or not at all.

Apple and Android also provide users with the means to modify the settings on their individual mobile devices to reflect their individual choices about these technologies, including how to opt out of “interest-based advertising.” As all operating systems are different and are often updated, We recommend that You refer to the “Settings” in Your mobile device’s OS for further direction.

5.EMAILS, SMS TEXTS AND OUR COMMUNICATIONS

Navierre may use email. SMS texts, or other forms of communication within the Health Portal, to communicate with Users regarding a variety of topics, such as questions about Navierre, the Health Portal; Your Care Team Members; Your medical information and records, Providers, appointments, etc. We may also send promotions to You using email of SMS text. You may opt out of receiving future promotions by clicking on the link provided in the email for that purpose or texting “Stop” in response to the text at issue. For further information about how We use Email, SMS Texts and Your choices, please see Paragraph 10 of the Terms of Use

While we make reasonable efforts to protect the personal information that You share with us, it is important to note that email and SMS Text messages are unsecured. Please consider the information you chose to send to us and the method which You use to send it. Should you choose to send your information via email or SMS Text, You do so at your own risk. We recommend that if your communication is sensitive or contains personal information, you may want to send it another way.

If you choose to correspond to us via email or text, we reserve the right (but not the obligation) to retain the content of Your messages as well as your email address, phone number or other personal information, and our responses.

6.SMS Terms & Conditions

SMS Opt-In consent and the phone numbers we collect for the purpose of SMS will not be shared with third parties or affiliates in any circumstance.

As part of the TCR registration process, mobile carriers require that you provide SMS Terms & Conditions for your messaging campaigns. These Terms & Conditions should include the following information:

Terms and Conditions

By subscribing to our services, you agree to the following terms and conditions regarding messaging and communications:

Messaging Frequency

By opting in, you consent to receive recurring messages from us. The frequency of these messages may vary depending on the service you're subscribed to (e.g., weekly, monthly, or as events or promotions arise).

Potential Fees

Standard messaging and data rates may apply depending on your mobile carrier and plan. You are responsible for any charges incurred from receiving messages.

Opt-In Method

To opt-in to our messaging service, you must provide explicit consent by (enter consent method) through our website.

Opt-Out Method

You can opt out of receiving further messages at any time by replying with STOP. After opting out, you will no longer receive further messages unless you opt back in.

Consent for SMS Communication

Information obtained as part of the SMS consent process will not be shared with third parties. SMS Opt-In consent and the phone numbers we collect for the purpose of SMS will not be shared with third parties or affiliates in any circumstance.

Types of SMS Communications

If you have consented to receive text messages from Navierre, you may receive text messages related to appointments, orders, medications, and other Navierre feature notifications.

7.PERSONAL INFORMATION PROVIDED AS PART OF USER CONTENT

On occasion and under certain circumstances, Navierre may, in its sole discretion, offer Users the opportunity to submit content to the Health Portal, such as questions and endorsements regarding the Health Portal, general discussions of healthcare, well-being and other communications with the Navierre community. You should consider what information You chose to share in the content that You submit. If You include personal, health or sensitive information in the content that you provide to Navierre for public posting, such information may be made available to anyone using the Health Portal Your contact information (which may include, without limitation, Your Account Information such as Your email address) may be included with any content that you post. Navierre does not edit or otherwise remove such information from User content before it is posted on the Health Portal. If You do not wish to have Your information made available in this manner, You must remove any such information from the content before posting. Navierre is not liable for any damages caused or incurred due to information that You have made available in the foregoing manner.

8.LINKS TO OTHER PLATFORMS

The Health Portal may contain links to non-Navierre platforms. Links to other platforms are provided to You for information and convenience only and do not constitute an endorsement or recommendation by Navierre. We are not responsible for, and this Privacy Notice does not apply to, the privacy practices of those platforms or of any companies that We do not own or control. We make no representations or warranties regarding the correctness, accuracy, performance, security, privacy or quality of any content, software, service, or application found at any Linked Site. We encourage You to seek out and read the privacy policy and Terms of Service of each platform that you visit.

9.APP STORE

Your app store (e.g., iTunes or Google Play) may collect certain information in connection with your access and use of the Navierre App, such as Personal Information, Payment Information, Geolocational Information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies.

10.SECURITY

Navierre takes commercially reasonable precautions to protect the security of your personal information. However, no security measures are perfect or impenetrable, and Navierre cannot guarantee that the information submitted to, maintained on or transmitted from its systems will always be secure. Navierre is not responsible for the circumvention of any privacy settings or security measures contained on the Health Portal by any Users or third parties.

Remember that You are the first and best defense against unauthorized access to Your information. Please do not share your Navierre account Information or Password with others and take the necessary steps to assess whether Your personal information is being transmitted to its intended recipient in a reasonably secure manner.

11.YOUR CHOICES ABOUT YOUR PERSONAL INFORMATION

  1. Inquiries concerning the collection and deletion of Your personal information.

We understand that You may have certain questions about Navierre’s access and use of information that We have collected. Under some circumstances, You may be able to opt out of our continued collection or use of Your personal information, and/or seek access to or deletion of personal information that We have collected about You in the past.

There are circumstances when Navierre will not be able to comply with such requests. For example, We may deny a request if We determine, in good faith, that We should not comply because: to do so would violate or conflict with Navierre’s legal obligations, including, but not limited to, legal obligations as to the preservation and non-disclosure of financial, medical or personal health information; the information is the privileged, proprietary or confidential information of Navierre or someone other than the person making the request; the identity or authority of the person making the request cannot be confirmed; compliance with the request would compromise the privacy or legal rights of others; the burden or expense of responding would be disproportionate to the requesting individual’s privacy risk; the information is commercially necessary for Us to complete transactions or provide products or services that the User requested; or to do so would impede Navierre’s detection, correction or prevention of any security incident, intentional or non-intentional interference with the Health Portal, products or services.

Additionally, under some circumstances, even if You opt out, non-personal information regarding your activities on the Health Portal, and/or information from third-party platforms for non-interest-based advertising purposes, may be collected and used to determine the effectiveness of the advertisements.

If You have any questions or concerns about Navierre’s collection or use of Your personal information, wish to opt out of further collection of Your personal information or request deletion of personal information currently in Our possession, please contact Us using one of the methods set forth below. Upon receiving Your request, We will endeavor to respond to request in a commercially reasonable time.

Please contact us at privacy@navierre.com

To request deletion of your account, please contact our support team at info@navierre.com.

  1. Opt out of specific phone, email, text, or marketing offers.

In accordance with Your prior experience with Navierre, including, in some cases, the permission You have given Us, Navierre may use a variety of means, such as telephone, email, or text, to communicate with You regarding Navierre’s marketing offers and/or the marketing offers of Our partners or others that may be of interest to You.

If You do not wish to receive telephone, mail, SMS text, or email marketing offers, You may request that we remove your name from our internal email, direct mail, or internal telemarketing lists.

Please submit your opt-out request to us:

By Telephone at: (628) 400 1166

By Email at: options@navierre.com

If You no longer wish to receive via email special offer information or other promotional messages from Us, you may click the link at the bottom of any email You receive from Us and follow the instructions. Your email address will be removed from Our marketing list. However, Navierre may continue to communicate with you concerning your Navierre User Account, the Health Portal, products and services, delivery, billing, renewal and other matters.

Please allow us a commercially reasonable period of time in order to satisfy your request, as some promotions may already be in process.

12.CHILDREN’S ONLINE PRIVACY PROTECTION ACT OF 1998.

In accordance with the Children’s Online Privacy Protection Act of 1998, Navierre does not knowingly collect information regarding minors under the age of 13 except to the extent that the child’s parent or legal guardian, as the Primary Account Holder, has elected to use the Health Portal on the child’s behalf as the Healthcare Subject. If You believe that Navierre has obtained information about a minor under the age of 13 without the authority of the child’s parent or guardian, please notify us at privacy@navierre.com so that we can take appropriate action to terminate such account and delete associated information.

13.GOVERNING LAW

Except where otherwise noted, this Privacy Notice and the use of the Health Portal and any related products or services shall be governed by and construed in accordance with the laws of the State of New Jersey, United States of America. If any provision of this Privacy Notice shall be unlawful, void, or for any reason unenforceable, then that provision shall be deemed severable from the other provisions and shall not affect the validity of the other provisions.

14.HOW WE RESPOND TO “DO NOT TRACK” SIGNALS

Navierre is required by California and Delaware law to tell Users whether it honors “Do Not Track” settings in your browser concerning targeted advertising. Navierre does not monitor, recognize, or honor any opt-out or “Do Not Track” mechanisms, including general web browser “Do Not Track” settings and/or signals.

15.NOTICE TO CALIFORNIA RESIDENTS

If you are a California resident, You may be aware that under certain circumstance not applicable to the Health Portal or Navierre, You may have certain additional or different rights under California law. Please do not use the Health Portal if You do not agree to the terms of this Privacy Notice.

16.VISITING THE HEALTH PORTAL FROM OUTSIDE THE UNITED STATES

If You are visiting the Health Portal from outside of the United States, please be aware that your information may be transferred to, stored or processed in the United States. The data protection, privacy and other laws of the United States and other countries might not be as comprehensive as those in your country. By using any portion of the Health Portal, You understand and consent to the transfer of your information to our facilities in the United States and to those third parties with whom We share it as described in this Privacy Policy.

17.CHANGES TO OUR PRIVACY POLICY

We may update or change this Privacy Notice at any time and from time to time. The most recent version of the Privacy Notice and its effective date is reflected by the version and date located at the top of this Privacy Notice. Your continued use of the Health Portal, including Your receipt of related service or products, after the Privacy Notice is updated, will constitute Your consent and agreement to be bound by the updated terms. Please be aware that, to the extent permitted by applicable law, our use of information is governed by the Privacy Notice in effect at the time we collect the information.

We encourage you to consult this Privacy Notice on a regular basis for any updates or changes.

18.QUESTIONS OR COMMENTS

If You have any questions or concerns about this Privacy Notice, Our practices or your interactions with the Health Portal, please contact us:

By Telephone at: (628) 400 1166

By Email at: privacy@navierre.com

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