Accuhealth Privacy Policy
Effective Date: August 18, 2022
Last Updated: August 07, 2023

Introduction
Accuhealth Global Inc, a Delaware corporation (“Accuhealth”)
owns and operates the Service or has affiliates through which the Service is owned
and operated. We value Your privacy and we are committed to keeping your Personal
Data confidential. We use your data solely in the context of helping you improve your
health by offering a convenient and secure software solution with tools that allow
users to monitor and remotely transmit patient-generated health data and
communicate for telehealth visits. Terms not defined in this Privacy Policy are defined
in our Terms of Use.

This Privacy Policy applies to information that Accuhealth collects from users of the
Service, including Personal Data. “Personal Data” includes any information that can be
used on its own or in combination with other information to identify or contact an
individual and may include health data. In this Privacy Policy (the “Policy”), we provide
you detailed information about our collection, use, maintenance, and disclosure of your
Personal Data. The policy explains what kind of information we collect, when and how
we might use that information, how we protect the information, and your rights
regarding your Personal Data.

Please read the following carefully to understand our views and practices regarding
your Personal Data and how we will treat it. 

BY SUBMITTING YOUR PERSONAL DATA THROUGH THIS APP, YOU ARE
ACKNOWLEDGING THAT YOU HAVE READ AND AGREE TO THE TERMS OF THIS
POLICY. IF YOU DO NOT AGREE, PLEASE DO NOT LOG INTO OR ACCESS THE APP
AND PLEASE DO NOT SUBMIT ANY PERSONAL DATA TO US.
PLEASE NOTE THAT WE OCCASIONALLY UPDATE THIS PRIVACY POLICY AND THAT
IT IS YOUR RESPONSIBILITY TO STAY UP TO DATE WITH ANY AMENDED VERSIONS.
IF WE MODIFY THE POLICY, YOU WILL FIND THE UPDATED PRIVACY POLICY ON OUR
WEBSITE AT accuhealth.tech/privacy-policy. YOU MAY STORE THIS POLICY AND/OR
ANY AMENDED VERSION(S) DIGITALLY, PRINT THE POLICY, OR SAVE IT. ANY
CHANGES TO THIS PRIVACY POLICY WILL BE EFFECTIVE IMMEDIATELY UPON
PROVIDING NOTICE, AND SHALL APPLY PROSPECTIVELY TO ALL INFORMATION WE
MAINTAIN, USE, AND DISCLOSE. IF YOU CONTINUE TO USE THE APP FOLLOWING
SUCH NOTICE, YOU ARE AGREEING TO THOSE CHANGES.

If have any questions or concerns after reading this Privacy Policy, please do not
hesitate to contact us at info@accuhealth.tech. We appreciate your feedback.

Responsible Entity/Controller
Accuhealth is the Controller of your Personal Data and we may process this data in
accordance with this Privacy Policy. If we are processing Personal Data on behalf of a
healthcare provider or other third-party that is not Our agent or affiliate, the terms of
this Privacy Policy do not apply—instead, the terms of that third-party’s privacy policy
will apply. You can contact Us with any questions about our Privacy Policy at
info@accuhealth.tech. You can reach our data protection officer at 1-888-407-4108 x2

Links to Other Sites 
Our App may contain links to websites and services that are owned or operated by
third parties (each, a “Third-party Service”). Any information that you provide on or to a
Third-party Service or that is collected by a Third-party Service is provided directly to
the owner or operator of the Third-party Service and is subject to the owner’s or
operator’s privacy policy. We are not responsible for the content, privacy or security
practices and policies of any Third-party Service. To protect your information, we
recommend that you carefully review the privacy policies of all Third-party Services
that you access.

What Personal Data do we collect?
We collect “Personal Data”, which includes any information that can be used on its own
or with other information in combination to identify or contact an individual. In some
cases, this Personal Data may be or may include healthcare information or “Protected
Health Information.” The types of Personal Data we collect are described below. 

Demographic Data
We collect demographic information such as your name, email address, age, gender,
phone number, postal address, and personal health information such as your
diagnosed condition(s). Primarily, the collection of your Personal Data assists us in
creating your User Account, which you can use to securely track, manage, and transmit
your Personal Data to your healthcare provider. We also use your demographic data for
the purposes of research and analysis; however when we do so any personal health
information is “de-identified”, meaning it has been stripped of certain identifiable
elements that would contain the data to a particular individual.

Payment Data
If you make purchases via our Website, we may require that you provide to us your
financial and billing information, such as billing name and address, credit card number
or bank account information.

Support Data
If you contact Accuhealth for support or to lodge a complaint, we may collect technical
or other information from you through log files and other technologies, some of which
may qualify as Personal Data (e.g., IP address). Such information will be used for the
purposes of troubleshooting, customer support, software updates, and improvement of
the Service and related services in accordance with this Privacy Policy. Calls with
Accuhealth may be recorded or monitored for training, quality assurance, customer
service, and reference purposes.

Device, Telephone, and ISP Data
We use common information-gathering tools, such as log files, web beacons, and
similar technologies to automatically collect information, which may contain Personal
Data, from Your computer or mobile device as you navigate our App. The information
we collect may include your Internet Protocol (IP) address (or proxy server), device and
App identification numbers, location, browser type, Internet service provider and/or
mobile carrier, the pages and files you viewed, your searches, your operating system
and system configuration information, and date/time stamps associated with your
usage. This information is used to analyze overall trends, to help us provide and
improve our App and to guarantee their security and continued proper functioning. 
Health Data (Patient Users Only)

In addition to demographic information, we may collect information regarding your
health conditions, medications, medical appointments, insurance provider, healthcare
facility information, medical biometric data. We collect this information to help your
healthcare provider(s) track and manage your health. We will have an agreement, such
as a BAA, with your healthcare provider(s) limiting our use of such data, which controls
over this policy.

Third-party Data Sources
We may collect information about you from other sources, including third parties from
whom we have purchased Personal Data, and combine this information with Personal
Data provided by you. In particular, we collect Personal Data from the following
sources:

Third-party providers of business contact information, including mailing addresses, job
titles, email addresses, phone numbers, intent data (or user behavior data), IP
addresses, social media profiles, LinkedIn URLs and custom profiles, for purposes of
targeted advertising, delivering relevant email content, event promotion and profiling;
and

How Will We use Your Personal Data?
We process Your Personal Data for purposes based on legitimate business interests,
meeting our contractual obligations to you, complying with our legal obligations,
and/or your consent. We only use or disclose your Personal Data when it is legally
mandated or where it is necessary to fulfill the purposes described herein. Where
required by law, we will ask for your prior consent before doing so.

Specifically, we process Your Personal Data for the following legitimate business
purposes:

1. To fulfill our obligations to You under the Terms of Use or another applicable
services agreement, which includes providing Your information, if You are a
patient, to Your healthcare provider.
2. To communicate with You about and manage Your User Account 
3. To properly store and track Your data within our system
4. To respond to lawful requests from public and government authorities, and to
comply with applicable state/federal law, including cooperation with judicial
proceedings or court orders. 
5. To protect our rights, privacy, safety or property, and/or that of you or others by
providing proper notices, pursuing available legal remedies, and acting to limit
Our damages  
6. To handle technical support and other requests from You
7. To enforce and ensure your compliance with our Terms of Use or the terms of
any other applicable services agreement We have with You
8. To manage and improve our operations and the Service, including the
development of additional functionality
9. To manage payment processing
10. To evaluate the quality of service You receive, identify usage trends, and
thereby improve Your user experience
11. To keep our App safe and secure for You and for Us
12. To send You product, service and new feature information and/or
information about changes to our terms, conditions, and policies (with your
consent)
13. To allow us to pursue available remedies or limit the damages that we may
sustain
14. To provide access to a third-party user (with your consent), to enable that
individual to monitor your progress and overall condition and to follow up with
you, as they deem appropriate (e.g., you can give access to your caregiver,
parent, child, or spouse).
15. To send you marketing communications, including newsletters, new
product offerings, SMS messages, and push notifications about Accuhealth and
its affiliates and partners (with your consent). 
16. To aggregate and anonymize Your data for research analysis and possible
resale
You can opt-out of receiving promotional emails by changing the notification
preferences in your account settings or by unsubscribing via the “Unsubscribe” link in
any Accuhealth email. Opting-out of these emails will not end transmission of
important service-related emails that are necessary to your use of the Service. 

Where is your Personal Data
processed?
Personal Data Accuhealth collects through the Service will be stored on secure US
servers through Amazon Web Services, GSUITE, Google Compute, DROPBOX even if
you are accessing the Service from outside the United States. Your country’s data
protection laws may not apply and may be more stringent than those to which
Accuhealth is legally subject. Personal Data may be transmitted to third parties, which
parties may store or maintain the data on their secure servers. Any data that may be
stored out of the United States will be encrypted in transit and at rest. 

Will we share your Personal Data with anyone else?
Yes, with Our legal affiliates We may share your Personal Data with the following
companies to which we are legally related (companies that we own or which own Us)
and who have agreed to the same Privacy obligations laid out herein, but only for the
purposes described herein: ASC HEALTHCARE INC., TELLIHEALTH LLC, ACCUHEALTH TECHNOLOGIES LLC

Yes, with Your healthcare provider (if You are a patient)

Yes, with any third-party with whom you choose to connect via the Service (“Third-party
User”).

We will share information you enter into the Service, as well as any reports generated
by the Service based on the information you enter, with the Third-Party User with whom
you choose to share data via the Service. If you permit Third-party User access to your
account, that user will also have access to your activity within the platform (e.g., view
your biometric readings]). If, at any point, you want to deny access to one or more
Third-Party Users, you can do so by sending an email to support@accuhealth.tech

Yes, with third parties that help us power our App
Accuhealth has a limited number of service providers and other third parties
(“Business Partners”) that help us run various aspects of our business. These Business
Partners are contractually bound to protect Your Personal Data and to use it only for
the limited purpose(s) for which it is shared. Business Partners’ use of Personal Data
may include, but is not limited to, the provision of services such as data hosting,
information security, IT services, customer service, and billing management. 
Yes, with third parties and the government when legal or enforcement issues arise

We may share your Personal Data, if reasonable and necessary, to (i) comply with legal
processes or enforceable governmental requests, or as otherwise required by law; (ii)
cooperate with third parties in
investigating acts in violation of this Agreement; or (iii) bring legal action against
someone who may be violating the Terms of Use or who may be causing intentional or
unintentional injury or interference to the rights or property of Accuhealth or any third-
party, including other users.

Yes, with third parties that provide advisory services

We may share Your Personal Data with Our lawyers, auditors, accountants, or banks,
when We have a legitimate business interest in doing so. 

Yes, with third parties in the event of a reorganization, merger, sale, joint venture,
assignment, transfer, or other disposition of all or any portion of Accuhealth’s
corporate entity, assets, or stock (including in connection with any bankruptcy or
similar proceedings)

If We share Your Personal Data with a third-party other than as provided above, You will
be notified at the time of data collection or transfer, and You will have the option of not
permitting the transfer.

What is “anonymized data” and what will We do with it?
We may, from time to time, rent or sell aggregated data and/or other information that
does not contain any personal identifiers (i.e., the information has been anonymized by
stripping out identifiers such as name, address, phone number, etc. such that no
person or entity can be re-identified using such information). The purpose of this type
of disclosure is to describe the Service to current and prospective business partners
and other third parties. The anonymized data may also be shared or published through
academic journals or media platforms for lawful purposes. Once your data is
anonymized, it is no longer Personal Data, and we are not restricted in our use of that
data for any purpose. 

What is our Cookie Policy?
In operating the Service, we may use cookies, web beacons and similar technologies. A
cookie is a piece of information that the Service stores on your device when you
access the Service. Our cookies help provide additional functionality to the Service and
help us analyze usage more accurately for research and marketing purposes. In all
cases in which we use cookies, we will not collect Personal Data except with your
permission. We recommend that you leave cookies turned on because they allow you
to take advantage of some of the Service’s features. In addition to cookies, we may use
web beacons (also known as “clear GIFs”) to measure traffic to or from the Service and
related browsing behavior and to improve your experience when using the Service.
We use two types of cookies: essential and non-essential cookies. Essential cookies
are those necessary for us to provide the Service to you. All other cookies are non-
essential. We use two types of non-essential cookies: (1) cookies used to analyze your
behavior on a website (“Analytics Cookies”); and (2) cookies used to provide you
enhanced functionality (“Functional cookies”). We have provided, below, a full list of
our cookies, categorized as described above. We have described the purpose of each,
whether they are Accuhealth or third-party cookies, and how to withdraw consent to
their use. We have also indicated which cookies are “session cookies” (which last for
as long as you keep your browser open) and “persistent cookies” (which remain on
your hard drive until you delete them or they expire).
Essential Cookies:
1. Cookie Name, Who Controls It, and Duration
2. Purpose
3. Information Collected
4. How to Withdraw Consent
5. auth-tokens-token
6. Stel
7. 30 Days 
8. To authenticate you when you sign into the service.
9. A generated token that allows the server to identify you.
10. Do not use our Service if you do not want to receive this cookie.

Analytics Cookies:
1. Cookie Name, Who Controls It, and Duration
2. Purpose
3. Information Collected
4. How to Withdraw Consent
5. Website Cookies
6. Website Analysis
7. Browser information and IP address
This Privacy Policy covers the use of cookies, web beacons and similar technologies
by Accuhealth only. Uses of these technologies by third-party websites are governed by
each such website’s privacy policy. For example, we use 

How long do We retain Personal Data?
We will retain your Personal Data for as long as you maintain a User Account. The
exact period of retention will depend on the type of Personal Data, our contractual
obligation to you, and applicable law. We keep your Personal Data for as long as
necessary to fulfill the purpose for which it was collected, unless otherwise required or
necessary pursuant to a legitimate business purpose outlined herein. At the end of the
applicable retention period, we will remove your Personal Data from our databases and
will request that our Business Partners remove your Personal Data from their
databases. If there is any data that we are unable, for technical reasons, to delete
entirely from our systems, we will put in place appropriate measures to prevent any
further processing of such data. We retain anonymized data indefinitely. Contact Us at
info@accuhealth.tech regarding the applicable data retention period for your Personal
Data. 

NOTE: Once we disclose your Personal Data to third parties, we may not be able to
access that Personal Data any longer and cannot force the deletion or modification of
any such information by the parties to whom we have made those disclosures. Written
requests for deletion of Personal Data other than as described should be directed to
info@accuhealth.tech.

How do we protect your Personal Data?
Accuhealth is committed to protecting the security and confidentiality of your Personal
Data. We use a combination of reasonable physical, technical, and administrative
security controls to maintain the security and integrity of your Personal Data, to protect
against any anticipated threats or hazards to the security or integrity of such
information, and to protect against unauthorized access to or use of such information
in our possession or control that could result in substantial harm or inconvenience to
you. However, Internet data transmissions, whether wired or wireless, cannot be
guaranteed to be 100% secure. As a result, we cannot absolutely ensure the security of
the information you transmit to us. By using the Service, you are assuming this risk.

Safeguards
The information collected by Accuhealth and stored on secure servers is protected by
a combination of technical, administrative, and physical security safeguards, such as
authentication, encryption, backups, and access controls. If Accuhealth learns of a
security concern, we may attempt to notify you and provide information on protective
steps, if available, through the email address that you have provided to us or by an
in-app notification. Depending on where you live, you may have a legal right to receive
such notices in writing.

You are solely responsible for protecting information entered or generated via the
Service that is stored on your personal device (such as your cell phone or tablet)
and/or removable device storage. Accuhealth has no access to or control over your
personal device’s security settings, and it is up to you to implement any device level
security features and protections you feel are appropriate (e.g., password protection,
encryption, remote wipe capability, etc.). We recommend that you take any and all
appropriate steps to secure any device that you use to access our App.

NOTWITHSTANDING ANY STEPS THAT WE TAKE, IT IS NOT POSSIBLE TO
GUARANTEE THE SECURITY OR INTEGRITY OF DATA TRANSMITTED OVER THE
INTERNET. THERE IS NO GUARANTEE THAT YOUR PERSONAL DATA WILL NOT BE
ACCESSED, DISCLOSED, ALTERED, OR DESTROYED BY BREACH OF ANY OF OUR
PHYSICAL, TECHNICAL, OR ADMINISTRATIVE SAFEGUARDS. THEREFORE, WE DO
NOT AND CANNOT ENSURE OR WARRANT THE SECURITY OR INTEGRITY OF ANY
PERSONAL DATA YOU TRANSMIT TO US, AND YOU TRANSMIT SUCH PERSONAL
DATA AT YOUR OWN RISK.

How can You protect Your Personal Data?
Please be advised that we will NEVER send you an email requesting confidential
information such as account numbers, usernames, passwords, or social security
numbers, and you should NEVER respond to any email requesting such information. If
you receive such an email purportedly from Accuhealth, DO NOT RESPOND to the
email, DO NOT CLICK ON ANY LINKS AND/OR OPEN ANY ATTACHMENTS in the email,
and NOTIFY Accuhealth SUPPORT at info@accuhealth.tech immediately.
You are responsible for taking reasonable precautions to protect your user ID,
password, and other User Account information from disclosure to third parties, and
You are not permitted to circumvent the use of required encryption technologies. You
should immediately notify Accuhealth at info@accuhealth.tech if you know of or
suspect any unauthorized use or disclosure of your user ID, password, and/or other
User Account information, or any other security concern.

What are Your Rights?
You have certain rights relating to Your Personal Data, subject to local data protection
laws. These rights may include the right to:
1. access your Personal Data held by us 
2. erase/delete your Personal Data, to the extent permitted by applicable data
protection laws 
3. receive communications related to the processing of your personal data that are
concise, transparent, intelligible and easily accessible;
4. restrict the processing of your Personal Data to the extent permitted by law
(while we verify or investigate your concerns with this information, for example);
5. object to the further processing of your Personal Data, including the right to
object to marketing;
6. request that your Personal Data be transferred to a third-party, if possible;
7. receive your Personal Data in a structured, commonly used and machine-
readable format
8. lodge a complaint with a supervisory authority
9. rectify inaccurate Personal Data and, taking into account the purpose of
processing the Personal Data, ensure it is complete
10. not be subject to a decision based solely on automated processing,
including profiling, which produces legal effects ("Automated Decision-Making");
and
11. withdraw your consent at any time (to the extent we base the collection,
processing and sharing of your Personal Data on your consent) without affecting
the lawfulness of the processing based on such consent before its withdrawal.
You can exercise the rights listed above at any time by contacting us at
info@accuhealth.tech.

California Residents
California residents may request and obtain from us, once a year, free of charge, a list
of third parties, if any, to which we disclosed their Personal Data for direct marketing
purposes during the preceding calendar year and the categories of Personal Data
shared with those third parties. If you are a California resident and wish to obtain that
information, please submit your request by sending us an email at
info@accuhealth.tech with “California Privacy Rights” in the subject line.

How do You update, correct, or delete Personal Data?
You may change your email address and other contact information by sending an
email to support@accuhealth.tech. If you need to make changes or corrections to
other information, you may send an email to support@accuhealth.tech. Please note
that in order to comply with certain requests to limit use of your Personal Data, we may
need to terminate your account and your ability to access and use the Services, and
you agree that we will not be liable to you for such termination or for any refunds of
prepaid fees paid by you. You may deactivate your account by sending an email to
support@accuhealth.tech.

Although we will use reasonable efforts to do so, you understand that it may not be
technologically possible to remove from our systems every record of your Personal
Data. The need to back up our systems to protect information from inadvertent loss
means a copy of your Personal Data may exist in a nonerasable form that will be
difficult or impossible for us to locate or remove. 

How do You “OPTOUT” of receiving communications from Us?
We will not market third-party services to you without your consent. We will only send
emails to you regarding your Accuhealth account and services unless we have your
express consent to do otherwise. You can choose to filter these emails using your
email client settings, but we do not provide an option for you to opt out of these
emails. You can opt out of non-essential emails by sending an email to
support@accuhealth.tech.

Information submission by minors
We do not knowingly collect Personal Data from individuals under the age of 18 and
the Service is not directed to individuals under the age of 13. We request that these
individuals not provide Personal Data to Us. If we learn that Personal Data from users
less than 18 years of age has been collected, we will deactivate the account and take
reasonable measures to promptly delete such data from our records. If you are aware
of a user under the age of 13 using the Service, please contact us at
info@accuhealth.tech.

If you are a resident of California under the age of 18 and have registered for an
account with us, you may ask us to remove content or information that you have
posted to our websites. 

Accuhealth SMS
1.This program will send messages to users who opt-in to our services for
appointments reminders and medical adherence reminders. Users can expect to
receive telemedicine visit invitations from their Physicians, and medical adherence
reminders. Users of this system will have the ability to order consumables and have
support tickets raised - this is a non-emergency form of communications.  Please see
provisions above concerning marketing and advertising.
2. You can cancel the SMS service at any time. Just text "STOP" to the short code.
After you send the SMS message "STOP" to us, we will send you an SMS message to
confirm that you have been unsubscribed. After this, you will no longer receive SMS
messages from us. If you want to join again, just sign up as you did the first time and
we will start sending SMS messages to you again.
3. If you are experiencing issues with the messaging program you can reply with the
keyword HELP for more assistance, or you can get help directly
at support@accuhealth.tech, 1-888-407-4108
4. Carriers are not liable for delayed or undelivered messages
5. As always, message and data rates may apply for any messages sent to you from us
and to us from you. SMS messages frequency varies  on average 1-3 messages per
week. If you have any questions about your text plan or data plan, it is best to contact
your wireless provider.
6. If you have any questions regarding privacy, please read our privacy
policy:https://www.accuhealth.tech/privacy-policy

Contact Us
If you have any questions about this Privacy Policy, please contact us by email at
info@accuhealth.tech.
Please note that email communications are not always secure; so please do not
include sensitive information in your emails to us.