Privacy Policy

Expressable, Inc.

Effective Date: June 23, 2020

Expressable, Inc. (“Expressable,” “us” or “we”) takes your privacy very seriously. We created this Privacy Policy to provide you with important information about the privacy practices applicable to the services provided by us through the Expressable Application or through a third-party platform (the “Application”) and our website at expressable.io (collectively, the “Services”). This Privacy Policy describes how we collect, protect, use, disclose and store the information collected through the Services.

BY ACCESSING, OR USING THE SERVICES, AND/OR BY REGISTERING WITH US OR PROVIDING INFORMATION TO US IN CONNECTION WITH THE APPLICATION, YOU ACCEPT THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY, AND YOU HEREBY CONSENT THAT WE WILL COLLECT, USE, AND SHARE YOUR INFORMATION AS SET FORTH IN THIS PRIVACY POLICY. IF YOU ARE REGISTERING AN ACCOUNT OR USING THE SERVICES ON BEHALF OF AN INDIVIDUAL OR ENTITY OTHER THAN YOURSELF, YOU REPRESENT THAT YOU ARE AUTHORIZED BY SUCH INDIVIDUAL OR ENTITY TO ACCEPT THIS PRIVACY POLICY ON SUCH INDIVIDUAL'S OR ENTITY'S BEHALF.

Your use of the Services is also subject to our Terms and Conditions, which are available here.

Collection, Use, and Disclosure of Information

Personal Information We May Collect

In order for you to use the Services, we may require you to provide us with information that identifies you as an individual (“Personal Information”). We and our service providers (“Providers”) may collect Personal Information from you that includes, but is not limited to: (1) your name and your contact data (such as your e-mail address, phone number, billing and physical addresses, and your Application login and password); (2) demographic data (such as your gender, your date of birth and your zip code); (3) payment information (such as your credit or debit card number); (4) confirmation that your Provider provided services to you; and (5) health and medical data, if necessary (such as the previous doctors, dentists, therapists, or speech-language pathologists you visited, your reason for visiting those providers, your date of visiting providers, your medical history and condition, and other medical and health information you choose to share with us) that you provide through the Application. If you communicate with us by, for example, e-mail or letter, any information provided in such communication may be collected as Personal Information.

How We May Collect Personal Information

In addition to the information that we collect directly from you, we may also collect certain Personal Information about you from or on behalf of your past, current, and future health care providers. We use and disclose this information only in accordance with your express authorization, which we request from you through a separate document when you sign up to use the Services.

When you use our Services, we may collect certain information about you and your device automatically through the use of cookies, web beacons, and similar technologies. A "cookie" is a small data file sent from a website and stored on your device to identify your device in the future and allow for an enhanced personalized user experience. A "session cookie" disappears after you close your web browser, or may expire after a fixed period of time. A "persistent cookie" remains after you close your web browser and may be accessed every time you use our Services. We may use both session and persistent cookies. You should consult your web browser to modify your cookie settings. We may also use Local Shared Objects (sometimes referred to as “Flash Cookies”), which are similar to standard cookies except that they can be larger and are downloaded to a computer or mobile device by the Adobe Flash media player. By using the Services, you consent to our use of cookies and similar technologies.

We may also receive information about you from other sources, including through third-party services and organizations. We may combine our first-party data, such as your email address or name, with third-party data from other sources and use this to contact you (e.g. through direct mail). For example, if you access third-party services, such as Facebook, Google, or Twitter, through the Services to login to the Services or to share information about your experience on the Services with others, we may collect information from these third-party services.

How We May Use Personal Information

We and our third-party service providers may use Personal Information to:

  • respond to your inquiries and fulfill your requests, such as to arrange for a telephone conference;
  • communicate with health care professionals who will help you identify the appropriate level of care and healthcare setting for the healthcare services you are requesting;
  • send to you administrative information, including information regarding the Application, and changes to our terms, conditions and policies;
  • schedule and provide services related to the scheduling of an appointment, for example; communicate with you and your Providers regarding your health status, appointments and related services provided by your Provider; obtain or facilitate payments for appointments and related services provided by your Provider and send you payment receipts; and provide you with related customer service;
  • confirm that services you request were provided to you by your Providers;
  • send to you marketing communications that we believe may be of interest to you;
  • personalize your experience on the Application by presenting products and offers tailored to you;
  • create diagnostic or therapeutic models intended for use by the Expressable community;
  • further our business purposes, such as quality assessment, data analysis, audits, developing new products, enhancing the Application, improving our services, identifying usage trends to inform members of the Expressable community which aspects of the Application might be useful to them, developing tools which help you assess the performance, competence and qualifications of healthcare professionals and conducting training programs for such professionals, and determining the effectiveness of our promotional campaigns; and
  • act as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public or government authorities; (d) to enforce our Terms of Service; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; (g) at our discretion under emergency circumstances, to notify emergency services or your family members, personal representative or other individuals involved in your care of your location and condition; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.

Our use of your Personal Information may also be subject to certain restrictions set forth in an agreement between us and your Provider.

How Personal Information May Be Disclosed

Your Personal Information may be disclosed to:

  • our third-party service providers that provide services such as hosting of the Application, data analysis, IT services and infrastructure, customer service, e-mail delivery, auditing and other similar services;
  • Providers, including your Providers, to schedule and fulfill appointments and provide healthcare services and confirm those services were delivered to you;
  • our affiliates, for the purposes described for Personal Information in this Privacy Policy, including marketing purposes relating to their products and services;
  • third parties, to permit them to send marketing communications to you regarding our products or services or the services of your Providers;
  • for other treatment, payment or health care purposes of your Provider;
  • a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, liquidation or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceeding); and
  • a third party as we believe to be necessary or appropriate: (a) under applicable law; (b) to comply with legal process; (c) to respond to requests from public or government authorities; (d) to enforce the Terms of Service; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, or that of our affiliates, you or others; (g) at our discretion under emergency circumstances, to notify emergency services or your family members, personal representative or other individuals involved in your care of your location and condition; or (h) to allow us to pursue available remedies or limit the damages that we may sustain.

Our disclosure of your Personal Information may also be subject to certain restrictions set forth in an agreement between us and your Provider.

Upon request, we can provide you with access to a description or summary of the information that we maintain about you. If you have any concerns or feel that the Services are not following our stated policies with respect to your Personal Information, you may contact us at info@expressable.io.

Non-Personal Information We May Collect

“Non-Personal Information” is any information that does not reveal your specific identity. We may collect Non-Personal Information in a variety of ways, including:

  • Through your device: Certain information is collected automatically through your device, such as your operating system name and version, device manufacturer and model, device identifier, language, the name and version of the software application you are using. We use this information to ensure that the Services function properly and to understand usage of the Services.
  • Through other devices: Certain information may also be collected automatically through devices that are linked or paired to our Services.
  • Through server log files: Your “IP Address” is a number that is automatically assigned to the device that you are using by your Internet Service Provider (ISP). An IP Address is identified and logged automatically in our server log files whenever a user uses the Application, along with the time of the use and the pages visited within the Application. We use IP Addresses for purposes such as helping to calculate Application usage levels, diagnose server problems and administer the Services.
  • Physical Location: If you give us your consent, we may collect information about the physical location of your device, for example, using your device’s GPS functionality. We may use such information to provide you with personalized location-based services and content (for example, information regarding local Providers). We may also share your device’s physical location, combined with information about what advertisements you viewed and other information we collect, with our marketing partners to enable them to provide you with more personalized content and to study the effectiveness of advertising campaigns. You will be permitted to allow or deny such uses and/or sharing of your device’s location, but if you choose to deny such uses and/or sharing, we and/or our marketing partners may not be able to provide you with the applicable personalized services and content.
  • From you: We may collect Non-Personal Information such as your general geographic location, as well as other information, such as your preferred means of communication, when you voluntarily provide such information to us. Unless combined with Personal Information, this information does not personally identify you or any other user of the Services.
  • By de-identifying information: Aggregated Personal Information is information that is derived from Personal Information that does not personally identify you or any other user of the Application. For example, we may aggregate Personal Information to calculate the percentage of our users who have a particular telephone area code or a particular medical condition.

How We Use and Disclose Non-Personal Information

Because Non-Personal Information does not personally identify you, we may use and disclose Non-Personal Information for any purpose. In some instances, we may combine Non-Personal Information with Personal Information (such as combining your zip code with your name, or with your name together with a medical condition). If we combine any Non-Personal Information with Personal Information, the combined information will be treated by us as Personal Information as long as it is so combined.

Third Parties

This Privacy Policy does not address, and we are not responsible for, the privacy, information or other practices of any third parties, including Providers, the manufacturer of your mobile device, and any other third party mobile application or website to which the Application may contain a link. We encourage you to review the Notice of Privacy Practices of each Provider who provides you with services and the privacy policies of each website and application you visit and use.

HIPAA

Your Provider may be regulated as a “covered entity” under the Health Insurance Portability and Accountability Act (“HIPAA”). Please be aware that this Privacy Policy is distinct from your Provider’s HIPAA Notice of Privacy Practices, which describes in detail overall how your Provider uses and discloses your individually identifiable health information. If you would like to review a copy of your Provider’s HIPAA Notice of Privacy Practices, please request a copy directly from your Provider. Our use and disclosure of your Personal Information, which we receive pursuant to your express authorization, is not restricted under HIPAA. We will use and disclose your Personal Information consistent with the terms of your authorization and this Privacy Policy.

Security

We seek to use reasonable physical, technical and administrative measures to protect Personal Information under our control. Unfortunately, no data transmission over the Internet or data storage system is 100% secure, and therefore we cannot guarantee against all potential security breaches. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contacting Us” section below.

International Users

We intend to provide our Services in the United States. Accordingly, this Policy, and our collection, use, and disclosure of your Personal Information (as defined below) is governed by U.S. law. We do not represent or warrant that the Application, or any functionality or feature thereof, is appropriate or available for use in any particular jurisdiction. If you choose to access or use the Application from outside the United States, you do so on your own initiative and at your own risk, and are responsible for complying with all local laws, rules and regulations. By using the Application and submitting any Personal Information from outside the United States, you acknowledge that the Application is subject to U.S. law and consent to the transfer of your Personal Information to the United States, which may provide a different level of data security than in your country of residence.

Updates to This Privacy Policy

We may occasionally update this Privacy Policy at any time. Any changes to this Privacy Policy will become effective when we make the revised Privacy Policy available through the Application. We will update the “Effective Date” date at the top of this Privacy Policy if we make any such changes to this Privacy Policy. Your use of the Application or the submission of any information in connection with the Application following any change means that you accept the revised Privacy Policy. We encourage you to periodically review this Privacy Policy to stay informed about how we collect, use, and disclose personally identifiable information

Contacting Us

If you have any questions or comments about this Privacy Policy, please contact us by e-mail at info@expressable.io. Please note that e-mail communications are not always secure; so please do not include health information, credit card information or other sensitive information in your e-mail messages to us.

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