Privacy Policy — Tulio Health

This Privacy Notice describes how CareCapture by Tulio Health Technologies, LLC and its affiliates and subsidiaries ("CareCapture", "we", "our", or "us") collects, uses, retains and shares personal information when you interact with us through: (a) our application, CareCapture (the "App"), (b) website, www.carecapture.ai (the "Website"), and (c) when you otherwise interact with us (collectively, the "Services"). When you use the Services, you accept and understand that we collect, process, use, and store your Personal Information as described in this policy.

PERSONAL INFORMATION WE COLLECT, HOW WE USE IT, HOW LONG WE KEEP IT, AND HOW WE SHARE IT

What is Personal Information?

When you interact with us through the App and Website, we collect your personal information. "Personal information" is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Personal information does not include aggregate or de-identified personal data.

We collect personal information when you:

Create an Account.

When you create an account, we collect from you your personal identifiers (name, email address, telephone number, and age), password, and audiovisual information (i.e., profile photo if you choose to use one). We use this information to register your account for our Services and to authenticate you when you are using the Services. We may also use this information to send you additional emails to provide you with additional promotions and offers for our products and Services. You may unsubscribe at any time by clicking the "unsubscribe" link included at the bottom of each email we send to you. Our communications may contain tracking technologies, to analyze whether a predefined action took place by a recipient, such as opening our communications and other engagement metrics such as timestamps, delivery status, clicks within an email, as well as sender and recipient addresses to better adapt and distribute our communications. When you opt in to our marketing communications, you will be automatically opted in to the use of these technologies. To reject these tracking technologies, you must unsubscribe from our marketing communications. CareCapture will continue to send you necessary communications related to your care.

Contact us.

When you email or call us, for example, to ask questions regarding our products and services, we collect from you, your personal identifiers (name, email address, or telephone number) and anything else you choose to include in your message. We use this information to respond to your questions or inquiries, troubleshoot where necessary, or address any issues you have with the Services. We may record and retain your phone calls and use them for quality assurance and training purposes.

Use the App.

When you use the App, we collect from you your sensitive geolocation information (your geolocation within 1,750 feet of where you are) and internet or other electronic network activity information (e.g., IP address, unique device ID, unique User ID, and network information). CareCapture uses this information to find nearby medical providers based on their name or specialty to help you locate new or existing providers. We may also use this data to provide you with information on nearby health initiatives and programs that may be relevant to you.

Record Your Medical Appointments.

When you use the App during your medical appointments, we collect your personal information. The information collected will change each time you use the app for an appointment but may include collecting from you your personal identifiers (name), audio and visual recordings (your voice and the voices of others around you), medical information and sensitive medical information (such as your doctor's name and specialty, treatments, diagnoses, and more), and internet or other electronic network activity information (e.g., IP address, unique device ID, unique User ID, and network information). We use this information to provide you with the recording and transcription services through the App by collecting your information, your medical professional's information, and the audio of the meeting with your medical professional to create your medical summary. CareCapture does not store the audio recordings and only processes them to create the after-visit summary. We use the internet or other electronic network activity information to ensure the proper functioning of the Services.

If you create an Audio Recording of your medical appointment, this may collect the communications and Personal Information of other individuals. Before starting a recording, make sure you disclose you will be recording your conversation and have their consent to record your interaction and their Personal Information.

Interact with us on social media.

When you interact with our web pages on social networking websites, such as Meta (Facebook and Instagram), X (formerly Twitter), and LinkedIn (each, a "Social Media Page") (collectively, "Social Media Pages"), we collect basic engagement metrics and use it to tailor content and marketing as set forth in this section. Please note that we do not control the use or storage of the information that you have posted to any Social Media Page. This information is collected and processed by the social networking websites for their own purposes, including marketing. For more information on how Meta, X, YouTube, and LinkedIn use your personal information, please see Meta's Privacy Policy, Instagram's Privacy Policy, X's Privacy Policy, and LinkedIn's Privacy Policy. We also use a social marketing tool to collect information about the activity on our Social Media Pages and identify the most active users in our community. We receive this information in aggregated form only.

Social Media Pages.

When interacting with our Social Media Pages, we may collect from you, your personal identifiers (first and last name, social media handle, and profile picture) as well as any information that you provide when interacting with our Social Media Pages (e.g. commenting, sharing and rating). We may use this information to communicate with users.

Because our Social Media Pages are publicly accessible, when you use them to interact with other users, for example by posting, leaving comments or liking or sharing posts, any personal information that you post in them or provide when registering can be viewed by others or used by them as they see fit.

The content posted on our Social Media Pages or other public areas of social networking websites can be deleted in the same way as other content that you have created.

Community Management.

With the help of a third party, we collect from you, your interactions, including "likes", shares, messages, and other interactions with the content, to analyze and evaluate how our content is perceived, to learn from it, and to improve our social media and marketing efforts.

Direct Messages.

When using direct message capabilities on Social Media Pages, the applicable Social Media Page collects from you, automatically, your internet or other electronic network activity information (IP address, date and time of the server request, time zone, specific browser or app function, access status, amount of data transferred, browser or app from which the Request comes, device type, operating system used, and its interface (e.g. Android or iOS), language, version of the operating system, and device identifiers). We do not use this information; its use is governed by the applicable Social Media Page's Privacy Policy, a hyperlink to which is available above.

Page Insights.

When you visit our Social Media Pages, those sites record your IP address and other information about your usage behavior on our Social Media Page. The pages collect, through trackers in the browser of your device or via the advertising ID (IDFA from Apple or GAID from Google), when you open their app through your mobile device (e.g. smartphone or tablet). Social Media Pages use this information to create statistical evaluations for us of the use of the Social Media Page. We receive this information, from Social Media Pages, in the form of aggregated data and anonymous statistics regarding things like: age, gender, city/country, device, inquiries from fans about other fan pages, region and language settings of the users, proportion of men and women, the number of people reached, clicks on posts, "Likes" and reactions, comments and shared content, and total video views. We do not collect or process any other personal information in connection with the page insights.

We do not retain this information independently. For information on data protection and the storage period on Social Media Pages in relation to the "Page Insights" function see their Privacy Policies. It has been contractually agreed with Social Media Pages that they are responsible for providing you with information about the processing for Page Insights.

Information Processed Solely by Social Media Pages.

We do not know how Social Media Pages use personal information for its own purposes, how long the personal information is stored on their sites or whether the Social Media Pages data is passed on to third parties.

For example, if you are currently logged in to Facebook as a user, Facebook automatically collects, through trackers on your device, your Facebook ID or a link between the Facebook ID and the advertising ID (IDFA from Apple or GAID from Google) when you open the Facebook app through your mobile device (e.g. smartphone or tablet). This enables Facebook to understand that you have visited our Facebook Fan Page along with other Facebook pages that you have clicked on, whether you clicked on Facebook buttons integrated into websites that partner with Facebook, and other online interactions that report user data to Facebook. Based on this data, content or advertising tailored to you can be offered.

You can find more information about the personal information collected by Facebook, how it is used and how long it is stored by visiting Facebook's Privacy Policy.

Interact with the Website and App.

In addition to the personal information you provide directly to us, we also collect information from you automatically as you use our Website and App via cookies, web beacons, and similar tracking technologies. This includes, but is not limited to, the following: internet or other electronic network activity information.

We use essential, performance, marketing, and analytics cookies to collect your usage, device, and location information when you interact with the Website and App. We use this information to: (i) track you within the Website and App; (ii) enhance user experience; (iii) conduct analytics to improve the Website and App; (iv) prevent fraudulent use of the Website and App; (v) diagnose and repair Website and App errors, and, in cases of abuse, track and mitigate the abuse; and (vi) capture and aggregate viewing and engagement metrics.

In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent. Please note, if you opt out of cookies, your opt-out will be specific to the web browser, app, or device from which you accessed the opt-out. If you use multiple devices or web browsers, you will need to opt out of each browser or device that you use.

Aggregate data.

We aggregate the data we collect for benchmarking purposes, advertising, and internal analytics. We maintain and use this data in deidentified form. We will not attempt to reidentify the data unless it is necessary to determine whether our deidentification processes satisfy applicable data protection laws.

How Long Personal Information is Retained

We use the following criteria to determine whether it remains reasonably necessary to retain your personal information for one or more disclosed operational purpose, or a service provider or contractor's operational purpose(s): (i) whether there is a retention period required by statute or regulations; (ii) the existence of actual or threatened litigation for which we are required to preserve the information; (iii) the statutes of limitations for potential legal claims; and (iv) generally accepted best practices in our industry, including those related to the safety and security of our properties and assets. When we determine that it is no longer reasonably necessary to retain your personal information for one or more disclosed operational purposes based on the above criteria, we will delete your personal information.

CareCapture will also use the personal information we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in HOW WE SHARE YOUR PERSONAL INFORMATION.

HOW WE SHARE YOUR PERSONAL INFORMATION

CareCapture shares personal information in the following instances:

Within CareCapture. We may share your personal information among our affiliated entities for the legitimate business purposes of efficiently and effectively providing the Services. Access to your personal information is limited to those on a need-to-know basis.
In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, including without limitation liquidation and/or bankruptcy, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We will also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings.
For legal purposes. We share personal information where we are legally required to do so, such as in response to court orders, subpoenas, governmental/regulatory bodies, law enforcement or legal process, including for national security purposes. We may share your information with our legal advisors or auditors to establish, protect, or exercise our legal rights or as required to enforce our terms of service or other contracts or to defend against legal claims or demands. We also share this information with third parties as necessary to: detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; to comply with the requirements of any applicable law; or to comply with our legal obligations.
With your consent. Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request your consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time and may do so by contacting us via email at support@tuliohealth.ai.
With service providers. We have disclosed your personal information to service providers that assist us in providing the Website and Services. These service providers assist us with the following: information technology ("IT") support; Artificial Intelligence platform support; website hosting; data analysis; customer service; customer relationship management; payment processors; email delivery; marketing; and similar services. We have disclosed your internet or other electronic network activity information collected by cookies to our IT support team to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, and to identify and repair the Website and App. We have disclosed your internet or other electronic network activity information collected by cookies to our IT support team to update, improve, and maintain the Website and App.

YOUR INFORMATION CHOICES

You have the following choices with respect to your personal information:

Correct or View Your Information.

You may access your account to correct or view certain personal information you have provided to us.

Opt Out of Google Analytics.

To prevent your personal information from being used by Google Analytics, you may opt out here.

Opt Out of Email Tracking and Marketing Communications.

You can disable tracking in emails by unsubscribing from our marketing emails. You may opt out of receiving marketing emails and text messages from us by clicking the "unsubscribe" link provided at the bottom of each email we send or by replying STOP to our SMS. Please note that we may continue to send you notifications related to your medical care.

Opt Out of Advertising Cookies.

You can opt out of certain cookies by declining non-essential cookies when visiting our Website or by visiting your Cookie Preferences. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser's directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer's website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an "opt-out cookie" on your device. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the "Opt-Out" links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.

Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp
Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info
European Union (EU) /European Economic Area (EEA) Opt-Out: http://www.youronlinechoices.eu
In general, you can also disable cookies by setting your browser to refuse cookies or indicate when a cookie is being sent.

If the browser or extension that you (or your authorized agent) are using supports Global Privacy Control (GPC) (see here for more information), you may utilize the GPC opt out preference signal to instruct us to not sell or share any of your personal information collected online. The GPC opt out preference signal will apply to the device, platform, or browser in which you utilize it. You can utilize the opt out preference signal by turning on the signal in your device, platform, or browser settings. Please note that you must opt out of each device and each browser.

You must provide us with sufficient information that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. We will verify your request by the matching information provided by you with the information we have in our records. If we are not able to verify your identity for access, correction, and deletion requests with the information provided, we may ask you for additional pieces of information.

Only you, or a person that you authorize to act on your behalf may make a request related to your personal information. If you are an authorized agent making a request on behalf of another individual, you must provide us with signed documentation that you are authorized to act on behalf of that individual.

DO NOT TRACK

We do not respond to Do Not Track requests. Do Not Track is a preference you can set in your web browser to inform websites and mobile applications that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

INFORMATION SECURITY

We implement and maintain appropriate technical and organizational security measures, such as software- and hardware-based monitoring and protection, access controls, firewalls, and encryption (i.e., SSL and HTTPS) to protect the personal information that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal information we have collected from you.

CHILDREN'S PRIVACY

The Website is not directed to or intended for individuals under the age of thirteen (13). We do not allow registration by, nor do we directly collect personal information from any person we know to be under the age of thirteen (13).

CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy in our sole discretion at any time. If we do, we will post the changes to this page and will indicate the date the changes go into effect. We encourage you to review our Privacy Policy to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on our Websites and/or via email, and obtain your consent, if required.

CONTACT US

If you have any questions or concerns regarding this Privacy Policy, please contact us at:

support@tuliohealth.ai