Privacy Policy

This Privacy Policy describes the information collected through the Palana websites, software applications (including mobile apps), and online Platforms (together, the “Platforms”) and how that information is used and disclosed. The “Platforms,” as that term is used in this Privacy Policy, includes telehealth and related services provided by healthcare providers through or in connection with such websites, software applications, and online Platforms. Palana, Inc. (together with its affiliates, “Palana,” “we,” “us,” or “our”), and its suppliers may collect or receive the types of information described below in connection with your access to and use of the Platforms (together, “Collected Information”).

This Privacy Policy also explains your rights and choices regarding your personal information, how we communicate changes to this Privacy Policy, and how you may contact us regarding questions or issues with respect to anything contained in this Privacy Policy. This Privacy Policy is incorporated into and made a part of our Terms of Use and any other agreement that references this Privacy Policy or governs access to or use of the Platforms.

By accessing or using the Platforms or by accepting our Terms of Use or entering into any other agreement with Palana that references this Privacy Policy, you agree on behalf of yourself and any organization or company that you represent (together, “you”) that you have read and understand this Privacy Policy. If you do not agree with this Privacy Policy, do not access or use the Platforms.

We reserve the right to modify this Privacy Policy at any time. All changes will be effective immediately upon posting of the updated Privacy Policy on the Platforms and, by accessing or using the Platforms after changes are posted, you agree to those changes. Material changes will be clearly posted on the Platforms or otherwise communicated to you.

Overview

The information we collect generally falls into the following categories:

• Information that you voluntarily provide to us, for example, your contact information and information and materials submitted in the course of using the Platforms.
• Information collected through your use of the Platforms, for example, data collected by the servers used to operate the Platforms (e.g., IP addresses and device information), data collected by analytics Platforms, and data collected by cookies and tracking technologies.

Information You Submit

We will collect any and all information that you choose to submit to us through, using, or in connection with the Platforms, including, without limitation, the types of information described below.

Personal Information. For certain activities, such as when you register to use the Platforms, receive or use our telehealth services, subscribe to our alerts, or contact us directly, you may provide some or all of the following types of information to us:

• Contact information, such as your full name, email address, mobile phone number, and address;
• Username and password;
• Payment information, such as your credit card number, expiration date, and credit card security code;
• Insurance information;
• Your Health Information, including information about your diagnosis, previous treatments, general health, health insurance; and
• Any other information you provide to us.

You can visit our website without submitting your personal information to us but you will be required to provide your personal information in order to sign up for a Platform account, to request information from us, to access telehealth services through the Platforms, and to use certain other tools and features of our Platforms. We will collect any personal information from or about you that you choose to provide to us, which may include, without limitation, your name, email address, other contact information, and demographic information. We will use your personal information as described below in this Privacy Policy, including to provide the services, to set up and administer Platforms accounts, and to communicate with our users. We may combine such information with information we already have about you.

Protected Health Information. If you use the Platforms to book an appointment with a health care provider, we will provide certain of the information you have provided to Palana to the health care provider. To the extent that information collected through or received by the Platforms is Protected Health Information (“PHI”) as that term is defined under the Health Insurance Portability and Accountability Act of 1996 and any regulations promulgated thereunder (“HIPAA”), that information is governed by Palana’s Notice of Privacy Practices, and not by this Privacy Policy. Unless specifically stated otherwise, references to “Collected Information” in this Privacy Policy do not include PHI. We protect PHI and will only use or disclose it as required or permitted by applicable federal and state laws, including HIPAA, and in accordance with any contractual obligations that we may have with your healthcare provider.

Account and Profile Information. To sign up for a Platform account, you will be required to provide certain personal information as described above, including your name, email address, and address. You may have the option of populating your Platform account and profile with other types of information. Any such information that you choose to provide will be collected by Palana.

Messages and Other Information Resulting from Use of the Platforms. If you choose to use the Platforms, we will collect all data, information, and other content that you enter into, submit to, upload to, transmit, or otherwise provide using the Platforms or otherwise collected by the Platforms in the course of such use, including messages sent and received, performance statistics, and usage data.

Other Information Collected

As you navigate and use the Platforms, certain information can be passively collected—that is, gathered without the user actively providing the information or being concurrently made aware of the collection of information—using various technologies. We passively collect a variety of types of information in a variety of ways, including:

User Activity. We will collect information on how you use the Platforms, for example, the features you choose to use and how much time you spend using those features.

IP Addresses and Related Data. The servers used to operate and provide the services may collect data pertaining to you and the equipment, software, and communication methods you use to access the Internet and the Platforms, including Internet protocol (“IP”) addresses assigned to the computers and other devices from where you access the Internet, your Internet services provider (ISP), device ID numbers and unique identifiers, your media access control (“MAC”) address, your operating system, your device’s screen resolution, your web browser type, the pages you access on the Platforms, the websites you access before and after visiting the Platforms, the length of time you spend on the Platforms, date and time stamps, clickstream data, your approximate geographic location, performance statistics, and usage data. Palana may use this information to administer the Platforms and its servers, to generate statistical information, to monitor and analyze Platforms traffic and usage patterns, to monitor and help prevent fraud, to investigate complaints and violations of our policies, and to improve the Platforms' content.

Cookies and Tracking Technologies. The Platforms automatically use cookies to track your activity in order to facilitate and enhance the user experience on the Platforms and for other purposes as described below. Cookies are small pieces of information that are stored on your device’s hard drive by your web browser. We use cookies to learn and track how you access and use the Platforms, including when and how users visit the Platforms and how popular particular Platform pages are and aren’t. We also use cookies to recognize Platform users, to help display information on the Platforms, and to improve your enjoyment and the usefulness of the Platforms.

How We Use and Share Collected Information

In addition to the uses and sharing described above, Palana and its suppliers may use and disclose Collected Information as described below. We do not use, sell, rent, or otherwise disclose Collected Information except as stated in this Privacy Policy or as required or permitted by applicable law.

Purpose Collected and Communication with You. We will use and share your personal information and other Collected Information for the purpose for which it was collected, for example, to provide the Platforms to you and others, to administer accounts, to communicate with and provide support to Platform users, and to respond to user requests. We may also use Collected Information to notify you of changes made to the Platforms (e.g., changes to our Terms of Use or this Privacy Policy).

Data Aggregation and Analysis. We may anonymize and aggregate personal information, as well as gather, organize, and/or analyze other Collected Information, and use that information in any manner for our business purposes, in each case to the extent permitted by applicable law and subject to any applicable provisions of this Privacy Policy or our Terms of Use.

Your Choices and Access

We give you choices regarding our use and disclosure of your personal information. To access or update your personal information as it exists in our records, please contact us using the contact information below.

Information Security

Palana does not guarantee that loss, misuse, or alteration of Collected Information will not occur, but we have implemented appropriate technical and organizational security measures in place to help protect against the loss, misuse, and alteration of information under our control. The storage and communication of information can never be completely secure, so we do not guarantee that communications or other information that you submit or that are otherwise provided to us will be completely secure.

If you become aware of any breach of Platforms security or this Privacy Policy, please notify us at support@palanahealth.com immediately. If our security system is breached, we will notify you of the breach only if and to the extent required under applicable law.

Access by Children

The Platforms are not directed at children under 13 years of age. Palana does not knowingly collect or use information from children under 13, through the Platforms.

Third-Party Websites; Advertising and Services

The Platforms may link to, be linked to, or reference, websites, applications, or services not maintained or controlled by Palana. Palana is not responsible for the privacy policies or practices of any third parties or any third-party websites, applications, or services. This Privacy Policy does not apply to any third-party websites, applications, or services or to any personal or other information that you may provide to third parties. You should read the privacy policy for each website, application, and Platforms that you visit or use.

Cross-Border Transfer

Your personal information and other Collected Information may be stored and processed in any country where our or our suppliers’ servers, databases, or facilities are located or operated. By accessing, receiving, or using the Platforms or by providing consent to us (where consent is required by law), you specifically acknowledge and agree that information may be transferred outside of the country from which you access the Platforms (including to the United States) and that such countries' data protection and related laws, regulations, and rules may be different, and may require a lower standard of protection, than those of the jurisdiction from where you access the Platforms.

Contact Us

If you have any questions or concerns regarding this Privacy Policy, contact us by email at support@palanahealth.com.