Easy Healthcare U.S. State Privacy Supplement

Last revised: December 26, 2023

This Easy Healthcare U.S. State Privacy Supplement (“U.S. State Privacy Supplement”) is only applicable to Colorado, Connecticut, Utah and Virginia residents (“you”). It supplements the information contained in our Easy Healthcare Privacy Policy. It is delivered on behalf of Easy Healthcare Corporation and our relevant affiliates (collectively, “Easy Healthcare,” “we,” “us,” and “our”) and governs certain personal data we collect from or about you.

We have adopted this U.S. State Privacy Supplement to comply with the Colorado Privacy Act (“CPA”), Connecticut Data Privacy Act (“CTDPA”), Utah Consumer Privacy Act (“UCPA”) and Virginia Consumer Data Protection Act (“VCDPA” and together with the CPA, CTDPA, and UCPA the “Relevant State Privacy Laws”).

Scope

This U.S. State Privacy Supplement covers personal data collected from or processed about you when you use our websites, www.premom.com and healthcare-manager.com (“Sites”) and the Premom mobile application (“App”) (the Sites and App together are called the “Services”).

Some personal data we collect from you may not be covered by this U.S. State Privacy Supplement. The Relevant State Privacy Laws include certain exemptions that may apply to our collection and processing of your personal data. Therefore, this U.S. State Privacy Supplement and the privacy rights set forth herein may not apply to you or to all of your personal data. For example, personal data we may have collected from individuals in their capacity as Colorado, Connecticut, Utah or Virginia current or former Easy Healthcare employees or job applicants is not covered by this U.S. State Privacy Supplement.

Collection, Processing and Disclosure of Personal Data

The Relevant State Privacy Laws require us to give you information about the categories of personal data we process, our purpose for processing it, the categories of entities with whom we share personal data, and the categories of personal data we share with such entities. This table sets out our relevant practices.  Our collection, use and disclosure of personal data depends on your relationship with us and your interaction with us.

 

Category of Data

Categories of Sources From Which We May Collect Personal Data

Purpose for Processing

Categories of Entities To Whom We May Disclose

Identifiers, such as name, unique personal identifier, online identifier, IP address, email address

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Automatically, such as via cookies and other tracking technologies that may be used to collect information about your device and activities while using the Services

· Via companies we engage to act on our behalf

· Integrated sign-in partners, such as Google Sign-In

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· To engage in marketing and advertising

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To vendors who help us promote our business, including for marketing and advertising purposes and to conduct audience engagement and analytics related to the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

Commercial information, such as records of products or services purchased, obtained or considered, or other purchasing or consuming histories of tendencies

 

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Automatically, such as via cookies and other tracking technologies that may be used to collect information about your device and activities while using the Services

· Via companies we engage to act on our behalf

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· To engage in marketing and advertising

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To vendors who help us promote our business, including for marketing and advertising purposes and to conduct audience engagement and analytics related to the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

Internet or other electronic network activity information, such as browsing history, search history or information regarding interaction with our website, app or services

 

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Automatically, such as via cookies and other tracking technologies that may be used to collect information about your device and activities while using the Services

· Via companies we engage to act on our behalf

· Integrated sign-in partners, such as Google Sign-In

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· To engage in marketing and advertising

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To vendors who help us promote our business, including for marketing and advertising purposes and to conduct audience engagement and analytics related to the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

Geolocation data, such as the state or country associated with your IP address

 

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Automatically, such as via cookies and other tracking technologies that may be used to collect information about your device and activities while using the Services

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· To engage in marketing and advertising

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To vendors who help us promote our business, including for marketing and advertising purposes and to conduct audience engagement and analytics related to the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

Audio, electronic, visual, thermal, olfactory or similar information, such as a photo associated with your account

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Integrated sign-in partners, such as Google Sign-In

 

· To provide you with the Services

· To communicate with you

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

Inferences

· Directly from you or automatically when you Use the App  

· Automatically, such as via cookies and other tracking technologies that may be used to collect information about your device and activities while using the Services

· Via companies we engage to act on our behalf

 

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· To engage in marketing and advertising

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To vendors who help us promote our business, including for marketing and advertising purposes and to conduct audience engagement and analytics related to the Services

· To monitor for fraud

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

Information that may be sensitive personal data, such as information about your health and well-being

· Directly from you or otherwise at your direction, such as when you use the Services, register to create an account, become a subscriber, communicate with us, or purchase products

· Via companies we engage to act on our behalf

 

 

· To provide you with the Services

· To communicate with you

· For analytics purposes

· For compliance with law, to enforce our rights and manage our business

· To prevent activity we determine to be potentially illegal or contrary to our terms of service, or as permitted or required by law, including for auditing, fraud and security monitoring purposes

· Other uses about which we notify you

· Our affiliates

· To our vendors, such as those who help us perform tasks on our behalf, process orders and payments, respond to your technical support questions, provide customer support or otherwise help us provide the Services

· To comply with legal requirements and enable protection of rights, such as at the request of law enforcement or government agencies, or as otherwise required by law

· As otherwise described to you or with your consent

· In connection with a business transaction, such as the sale of all or part of our business

 

Sales of Personal Data

We do not sell your personal data.

Targeted Advertising

We do not process your personal data for purposes of targeted advertising.

Your Privacy Rights

You may have certain rights in relation to your personal data.

Right to Know

You may have the right to confirm whether we process your personal data and to access such personal data.

Right to Make a Deletion Request

You may have the right to request that we delete your personal data that we have collected or received about you. Subject to certain exceptions, we must delete your personal data.

Right to Correct Inaccurate Personal Data

You may have the right to request that we correct inaccurate personal data about you, taking into account the nature of the personal data and the purposes of the processing of your personal data.

Right to Opt-Out of Sales of Personal Data

You may have the right to opt-out of the sale of your personal data.

Right to Opt-Out of Processing of Personal Data for Targeted Advertising

You may have the right to opt-out of the processing of your personal data for purposes of targeted advertising.

Right to Opt-Out of Profiling

You may have the right to opt-out of the processing of your personal data for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.

Right to Obtain a Copy of Your Personal Data

You may have the right to obtain a copy of your personal data that you previously provided to us.

Right to Non-Discrimination

You have the right not to be discriminated against by us for choosing to exercise your rights.

How to Exercise Your Privacy Rights

If you wish to exercise your right to know or confirm, delete, correct inaccuracies, opt-out of profiling (where relevant) or obtain a copy of your personal data, please submit a request to us by, clicking here or contacting us at support@premom.com or service@healthcare-manager.com.

Authorized Agents

To submit a request to Easy Healthcare on behalf of another person as an Authorized Agent, please submit a request to us by clicking here  or contacting us at support@premom.com or service@healthcare-manager.com.

Authenticating Your Requests

We only comply with requests when we can authenticate that you are a resident of Colorado, Connecticut, Utah or Virginia exercising your rights regarding your personal data.

We may need to ask you for personal data to authenticate your request so we can match it to the personal data we already have about you in order to authenticate your request. We will let you know via email if we need more information from you to authenticate your request. Please reply to our requests promptly.

We will communicate with you about your requests via email. We will use the email address you provided when submitting your request.

If we cannot verify your identity, we will let you know.

Responding To Your Requests

We aim to promptly authenticate and respond to your requests within 45 days of receipt but may require a total of up to 90 days to respond to your requests. If we require additional time beyond the initial 45 days after we receive your request, we will let you know within the first 45 days.

We do not ordinarily charge a fee for our response to your requests. However, we may do so to the extent your request(s) are excessive, repetitive, or manifestly unfounded. If we determine that charging a fee is warranted, we will let you know and will provide you with an estimate of the associated costs of responding to your request(s).

If we determine that we cannot or will not take the action that you requested, we will let you know. We will inform you of our reasons for not taking action and any rights you may have to appeal the decision.

We will respond to your requests via email. We will contact you at the email address you provided when submitting your request(s). If you would like to receive responses to a request to know or access personal data via postal mail rather than email, please let us know when submitting your request(s).

Limitations

The Relevant State Privacy Laws do not apply in full to all personal data we collect from residents of Colorado, Connecticut, Utah and Virginia. As set out in “Scope” above, the Relevant State Privacy Laws are not fully applicable to some personal data collected from Colorado, Connecticut, Utah and Virginia residents. Therefore, even if you are a Colorado, Connecticut, Utah or Virginia resident and submit an authenticated request, we may not be required to comply with your request.

Information provided in response to a consumer request shall be provided free of charge, up to twice annually per consumer. If requests are manifestly unfounded, excessive, or repetitive, we may charge a reasonable fee to cover the administrative costs of complying with the request or decline to act on the request.

Changes to Our U.S. State Privacy Supplement

From time to time, Easy Healthcare may update or revise this U.S. State Privacy Supplement. If there are changes to the terms of this U.S. State Privacy Supplement, documents containing the revised policy on the relevant webpage and/or or application page will be updated.

How to Contact Us

If you have any questions or concerns about this U.S. State Privacy Supplement, please contact us at support@premom.com or service@healthcare-manager.com.

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