MORE Health, Inc. (“MORE Health”), values and is committed to protecting patient and user privacy. This privacy statement applies to all the data collected by MORE Health through its websites, online medical platforms, and mobile applications (collectively the “Services”). It does not apply to any data we have collected in offline MORE Health Services or products or through any other means.

By using the MORE Health sites, the MORE Health Services, or interacting with us, you are agreeing to this Privacy Notice. Please read the following carefully to understand how we collect, use, and maintain your personal information. In addition, it describes your choices for use, access, and correction of your personal information.

1. What data do we collect?

   Personal Information you disclose to us

   We collect personal information that you voluntarily provide to us when you register on the Website, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Website or otherwise when you contact us.

   The personal information that we collect depends on the context of your interactions with us and the Website, the choices you make and the products and features you use. The personal information we collect may include the following:

   Personal Information provided by you

   The first time a user signs in to the Services, the Services require the user to create a MORE Health account. To create a MORE Health account, a user must eventually provide personal information such as name, date of birth, e-mail address, address, postal code, phone number, gender, and country/region. Depending on which features a user uses, she/he may be asked for additional information for that feature such as contact preferences, contact or authentication data, billing addresses, debit/credit card numbers, and other similar information.

   All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

   Protected Health Information

   A MORE Health account allows users to review health information about themselves and their patients, and to participate in second opinions and similar Services. Examples of the types of information collected and stored include but not limited to:

   • Medical history

   • Medications

   • Allergies

   • Health history

   • Prior surgeries

   • Current medical conditions

   • Medical images

   Information automatically collected

   Whenever you interact with our Services, we automatically receive and record information from your browser or device, this information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about who and when you use our Website and other technical information. This information is primarily needed to maintain the security and operation of our Website, and for our internal analytics and reporting purposes.

   We also collect information through cookies and similar technologies. “Cookies” are identifiers we transfer to your browser or device that allow us to recognize your browser or device and tell us how and when pages and features in our Services are visited and by how many people. A user has the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but users can usually modify their browser setting to decline some or all cookies if they prefer. If a user chooses to decline all cookies, they may not be able to use interactive features of this or other Websites that depend on cookies.

   One of the primary purposes of cookies is to provide a convenience feature to save users’ time. For example, if a user personalizes a Web page, or navigates within a site, a cookie helps the site to recall that user’s specific information on subsequent visits. Using cookies simplifies the process of delivering relevant content, eases site navigation, and so on. When a user returns to the Website, they can retrieve the information they previously provided, so they can easily use the site's features that they customized.

   MORE Health uses cookies with the Services to enable users to sign in and to help personalize the Services. We may use this data to customize content for your liking, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of the Services, and we can use that knowledge to make the Services interesting to our users.  

   The information we collect includes:

   • Log and Usage Data. Log and usage data is service-related, diagnostic usage and performance information our servers automatically collect when you access or use our Website and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports and hardware settings), Internet Service Provider “ISP”, Web Pages visited, and URL of the Web Page you visited before navigating to MORE Health

   • Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system configuration information.

   • Location Data. We collect information such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type of settings of the device you use to access the Website. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Locations settings on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

   • Crash or Error Information. We collect information such as data to determine the cause of the error using first or third party services. The crash or error information collected may include the following: Device Internet Protocol (“IP”) address, device name, operating system version, application configurations(s), the time and date, and other statistics.

   Information collected from other sources

   In order to enhance our ability to provide relevant marketing, offers and services to you and update our records, we may collect limited data from public databases, marketing partners, social media platforms, and other outside sources. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion. If you interact with us on a social media platform using your social media account (e.g. Facebook or Twitter), we receive personal information about you such as your name, email address, and gender. Any personal information that we collect from your social media account depends on your social media account's privacy settings

2. How do we use your information?

   We use personal information collected through the Services, including health information, in the Services, and for a variety of business purposes as described in this privacy statement. We do not use or disclose users information except as described in this privacy statement.

   • To facilitate account creation and logon process.

   • To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

   • To send administrative information to you. 

   • To provide users with important information about the Services, including critical updates and notifications. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

   • To protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).

   • To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

   • To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

   • To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

   • To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

   • To check eligibility for clinical trials..

   • To allow third party contractors to allow them to perform services for MORE Health directly related to the Services that an individual user requests.

   • To send you MORE Health email newsletter, if the user opts-in.

   • For marketing or promotional purposes. We will not disclose any information that could be used to personally identify a user.

   • Aggregated data for site usage statistics

   • As reasonably necessary and as directly related to providing the Services that an individual user requests, including coordination with insurance, enforcing users’ rights, protecting against fraud, resolving disputes etc.

   • Request feedback. We may use your information to request feedback and to contact you about your use of our Website.
     
     

   MORE Health will not share any of personal information in such a way that it can be used to personally identify a user unless the user has authorized us to provide their information to clinical trial providers. Decisions based on data are made by natural persons and are never automated.

   Personal information stored in the Service may be processed in the United States or any other country in which MORE Health or its affiliates, subsidiaries or service providers maintain facilities.

   We may process information relating to transactions, including purchase services, that you enter into our website. The transaction data may include your contact details, your card details and the transaction details. The transaction data may be processed for the purpose of keeping proper records of those transactions.

3. Will your information be shared with anyone?

   We are committed to maintaining your trust, and we want you to understand when and with whom we may share the information we collect. We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

   We may process or share your data that we hold based on the following legal basis:

   • Consent: We may process your data if you have given us specific consent to use your personal information in a specific purpose.

   • Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

   • Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

   • Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

   • Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.

   More specifically, we may need to process your data or share your personal information in the following situations:

   • Business Transfers: We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

   • Authorized Vendors, Service Providers and Other Third-Party Service Providers: We may share your information with third-party vendors and service providers that help us with specialized services, including billing, payment processing,data analysis, email delivery, providing medical advice for telemedicine services, medical image management services, management and hosting of telemedicine services. These third-party vendors and service providers may not use your information for purposes other than those related to the services they are providing to us.

   • Affiliates: We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners or other companies that we control or that are under common control with us.

   • Business Partners: We may share your information with our business partners to offer you certain products, services or promotions.

   • Protected Health Information: We may transfer your PHI as described in the HIPAA Notice and as permitted under HIPAA.

   This website may include links to social media on other third party sites. If you choose to engage in public activities on third party sites, you should be aware that any information you share there can be read, collected, or used by other users of these sites and forums. You should use caution in disclosing personal information while participating in these areas. We are not responsible for the information you choose to submit in public areas.

4. How Do We Keep Your Information Safe?

   Our Company securely stores all your data electronically with measures to protect your Protected Health Information from loss, theft, misuse, and unauthorized access, disclosure, alteration, and destruction in accordance with HIPAA and GDPR. And we have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website is at your own risk. You should only access the Website within a secure environment.

5. How Long Do We Keep Your Information?

   MORE Health will retain your Personal Data for the entire time that you keep your account open. After you close your account, we may retain your Personal Data:

   • For as long as necessary to comply with any legal requirement;

   • On our backup and disaster recovery systems in accordance with our backup and disaster recovery policies and procedures;

   • For as long as necessary to protect our legal interests or otherwise pursue our legal rights and remedies

   Users can close their MORE Health account at any time by signing into the Services and editing their account profile. MORE Health waits 180 days before permanently deleting Services account information in order to help avoid accidental or malicious removal of users’ information. A user should Contact Customer Service if they want to reopen an account. Users should consider deletion carefully, because MORE Health will not be able to reopen it. 

6.  What Are Your Rights?

   You have the right to review, change, or terminate your account at any time.

   If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. 

   You can find their contact details here:  http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

   If you have questions or comments about your privacy rights, you may email us at: security@morehealth.com.

   Account Information: If you would at any time like to review or change the information in your account or terminate your account, you can:

   • Log in to your account settings and update your user account.

   • Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, we may retain some information in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with applicable legal requirements.

   Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. 

   Opting out of email marketing: You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting us using the details provided below. You will then be removed from the marketing email list – however, we may still communicate with you, for example to send you service-related emails that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes. Contact us to opt-out.

   Rights regarding Protected Health Information (PHI)?

   • Right to Amend PHI: If a user feels that their PHI is incomplete or inaccurate, then they have the right to request that MORE Health amend that error.

   • Right to Access PHI: Users have the right to access their PHI and request copies of their PHI. All requests for copies must be made in writing. We may charge a reasonable fee for the costs of copying and mailing users’ requested information, and we will inform each user of the cost prior to incurring any costs.

   • Right to Accounting of Disclosures: Users have the right to request an accounting of to whom MORE Health has disclosed their PHI. This writing must be made in writing, and must specify the time period within which the user wants an accounting. The time period may not be more than 6 years. Each user is entitled to one free accounting per 12-month period, and each additional request for an accounting within that time period shall bear a reasonable cost, and we will inform each user of the cost prior to incurring any costs.

   • Right to Request Restrictions on Use and Disclosure of PHI: Users have the right to restrict or limit how MORE Health uses or discloses your PHI. A request must be made in writing, and must inform MORE Health which information is to be limited, whether use or disclosure or both should be limited, and to whom the restrictions apply.

   • Right to Receive Confidential Communications: Users have the right to request that MORE Health deliver communications in a certain way if MORE Health’s normal communications channels could endanger the user. This request must be made in writing and must state whether all or part of the communication could endanger the user.

   • Right to a Paper Copy of this Policy: Users have the right to request a paper copy of this privacy policy at any time. We may charge a reasonable fee for the costs of copying and mailing users’ requested information, and we will inform each user of the cost prior to incurring any costs.

   Rights under GDPR

   Under GDPR you have the right to request access and obtain information about your personal data; update, correct or delete your personal data; restrict or oppose (for legitimate reasons) the processing of your personal data by contacting the Data Protection Officer (DPO).

   California Residents Privacy Rights

   California Civil Code Section 1798.83, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

   If you are under 18 years of age, reside in California, and have a registered account with the Website, you have the right to request removal of unwanted data that you publicly post on the Website. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Website, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).  

   CCPA Privacy Notice

   The California Code of Regulations defines a "resident" as:

   (1) every individual who is in the State of California for other than a temporary or transitory purpose and

   (2) every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose

   All other individuals are defined as "non-residents." If this definition of "resident" applies to you, certain rights and obligations apply regarding your personal information.

   What categories of personal information do we collect?

   We have collected the following categories of personal information in the past twelve (12) months:

   Category	Examples	Collected
   A. Identifiers	Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name	YES
   B. Personal information categories listed in the California Customer Records statute	Name, contact information, education, employment, employment history and financial information	YES
   C. Protected classification characteristics under California or federal law	Gender and date of birth	YES
   D. Commercial information	Transaction information, purchase history, financial details and payment information	YES
   E. Biometric information	Fingerprints and voiceprints	YES
   F. Internet or other similar network activity	Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements	YES
   G. Geolocation data	Device location	YES
   H. Audio, electronic, visual, thermal, olfactory, or similar information	Images and audio, video or call recordings created in connection with our business activities	YES
   I. Professional or employment-related information	Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us	YES
   J. Education Information	Student records and directory information	YES
   K. Inferences drawn from other personal information	Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics	NO

   We may also collect other personal information outside of these categories in instances where you interact with us in-person, online, or by phone or mail in the context of:

   • Receiving help through our customer support channels

   • Participation in customer surveys or contests; and

   • Facilitation in the delivery of our Services and to respond to your inquiries

   How do we use and share your personal information?

   More information about our data collection and sharing practices can be found in this privacy notice.

   You may contact us by email at security@morehealth.com, or by referring to the contact details at the bottom of this document.

   If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

   Will your information be shared with anyone else?

   We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Each service provider is a for-profit entity that processes the information on our behalf.

   We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" your personal data. We may use your personal information to analyse your eligibility for clinical trials if authorized by you. With your consent we may share your personal information with third parties for clinical trials which may incur monetary benefits for MORE Health. 

   MORE Health Inc. has disclosed the following categories of personal information to third parties for a business or commercial purpose in the preceding twelve (12) months:

   • Category B: Personal information, as defined in the California Customer Records law, such as your name, contact information, education, employment, employment history and financial information.

   The categories of third parties to whom we disclosed personal information for a business or commercial purpose can be found under "Will your information be shared with anyone?".

   Your rights with respect to your personal data

   Right to request deletion of the data - Request to delete

   You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation or any processing that may be required to protect against illegal activities.

   Right to be informed - Request to know

   Depending on the circumstances, you have a right to know:

   • whether we collect and use your personal information;

   • the categories of personal information that we collect;

   • the purposes for which the collected personal information is used;

   • whether we sell your personal information to third parties;

   • the categories of personal information that we sold or disclosed for a business purpose;

   • the categories of third parties to whom the personal information was sold or disclosed for a business purpose; and

   • the business or commercial purpose for collecting or selling personal information.

   In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

   Right to Non-Discrimination for the Exercise of a Consumer's Privacy Rights

   We will not discriminate against you if you exercise your privacy rights.

   Verification process

   Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match it with the information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.

   We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.

   Other privacy rights

   • you may object to the processing of your personal data

   • you may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the data

   • you can designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with the CCPA.

   • you may request to opt-out from future selling of your personal information to third parties. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.

   To exercise these rights, you can contact us by email at security@morehealth.com, or by referring to the contact details at the bottom of this document. If you have a complaint about how we handle your data, we would like to hear from you.

   If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: security@morehealth.com

   Or write to us:

   MORE Health, Inc.
   999 Baker Way, 5th Floor, 
   San Mateo, CA 94404
   

7. Use by Children/Minors

   We do not knowingly allow individuals under the age of 18 to create accounts that allow access to our Services. If we become aware of individuals who have provided us with personal data and are under the age of 18, we will take steps to deactivate the account and delete the personal data. If you become aware of information from individuals under the age of 18 which has been provided to MORE Health, please contact us at security@morehealth.com.

8. Changes to our privacy policy

   We update this privacy statement annually. When we do, we will also revise the "last updated" date at the top of the privacy statement. For material changes to this privacy statement, we will notify users either by placing a prominent notice on the homepage of the MORE Health website or by sending users a notification directly. We encourage users to review this privacy statement periodically to stay informed about how we are helping to protect the personal information we collect. A user’s continued use of the Apps constitutes a user’s agreement to this privacy statement and any updates.

9. Enforcement of this Privacy Statement

   By choosing to visit this website and use the Services, a user agrees that any dispute over the terms of this Agreement is governed by California law, excluding California's choice-of-law rules, and the user agrees to abide by the limitation on damages contained in our terms of service or other agreements with MORE Health. THE EXCLUSIVE VENUE FOR ANY DISPUTE RELATING TO THIS AGREEMENT IS SAN MATEO COUNTY, CALIFORNIA. A USER AND US CONSENT TO THE PERSONAL JURISDICTION OF THESE COURTS. Nothing in this Agreement limits either party's ability to seek equitable relief.

10. How to contact us

    If you have any questions about Our Company’s privacy policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

    Email us at: security@morehealth.com

    Or write to us at:

    MORE Health, Inc.
    999 Baker Way, 5th Floor, 
    San Mateo, CA 94404