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Privacy Policy

Last updated: June 7, 2023

The purpose of this Privacy Policy is to describe how Carte Clinics and its affiliated medical practitioners (collectively, “Carte Clinics”, “we”, “our” or “us”) collect, use and share information about you through our websites (“Sites”) and any other online services that link to this Privacy Policy, through email, text, and other electronic messages between you and the Services and through written documents, phone calls and other offline activities between you and Carte Clinics (collectively, the “Services”).

Please read this notice carefully to understand how we use, disclose and otherwise manage the personal information we collect about you. If you do not understand any aspects of this Privacy Policy, please feel free to contact us (our contact information is at the end of this Privacy Policy). This Privacy Policy is not a contract and does not create any contractual rights or obligations.

We are constantly trying to improve our Services, and we may need to update this Privacy Policy from time to time. Unless we say otherwise, changes will be effective upon the last updated date at the top of this Privacy Policy. Please check this Privacy Policy regularly to ensure that you are aware of any changes. If we make material changes to this Privacy Policy, we will make reasonable attempts to notify you of such changes. Your use of the Services after changes to this Privacy Policy means you have accepted the changes.

Information We Collect
Information You Provide to Us. We collect information you provide to us through the Services and offline, for example when you create or modify your account, register to use our Services, purchase products or services from us, request information from us, contact customer support, fill out any form on a Site, or otherwise communicate with us. This information may include:
- Name
- Email address
- Telephone number
- Addresses (home, work, or any other address you provide as an anchor point near which you are seeking care)
- Payment information (credit card or debit card number, expiration date and credit card security code)
- Date of birth
- Username and password
- Information about your medical conditions, treatment options, physician referrals, prescriptions, and lab results or other related health information, such as your physical and emotional characteristics
- Professional information, such as your title/role, business name, business address, tax identification number, national provider identifier number and other professional information requested or provided through a contact form or registration form
- Any other information requested or provided through a contact form, registration form, email, text or other message with the Site.

Information We Collect Automatically. Whenever you interact with our Services, we automatically receive and record information from your browser or device using cookies or similar technologies. This information may include your IP address, geolocation data, device identification, the type of browser and/or device you are using to access our Services, and the page or feature you requested. To learn more about the cookies and other technologies we use, please see our Statement on Cookies and Similar Technologies below.

The information we collect automatically may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve the Services and to deliver a better and more personalized service, including by enabling us to:Estimate our audience size and usage patterns.Store information about your preferences, allowing us to customize our Site according to your individual interests.Speed up your searches.Recognize you when you return to our Site.We may use this data to customize content for you that we think you might like, 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 a Service, and we can use that knowledge to make the Services more helpful to as many users as possible. 

How We Use and Share Your InformationTo Provide Services and Information. We use your information to:
- present our Services, Sites and their contents to you
- provide you with information, products, or services that you request from us, including, if applicable, facilitate the provision of health care services to you licensed providers affiliated with us and ensure that our affiliated licensed providers have the services and support necessary for health care operations.
- fulfill any other purpose for which you provide it
- register and service your online account
- process credit card and debit card transactions
- send you promotional materials or advertisements about our products and services, as well as new features and offerings
- enforce our Terms or other legal rights and remedies
- provide interest-based targeted advertising to you
- notify you about changes to our Services or any products we offer or provide
- fulfill any other purposes disclosed to you at the time we collect your information or pursuant to your consent.

Vendors and Service Providers. We may provide information to third-party vendors and service providers that help us operate and manage our Services and deliver products and Services that you purchase through us. These vendors and service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to help us provide the service.

Third-Party Analytics. We use selected third parties to collect data about how you interact with the Services. This information may be used to, among other things, improve the functionality of our Services.

With Your Consent. In addition to the sharing described elsewhere in this Privacy Policy, we will share personal information with companies, organizations or individuals when we have your consent to do so.

Legal Proceedings. We will share personal information with third party companies, organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, subpoena, legal process or enforceable governmental request;
- enforce applicable Terms, including investigation of potential violations;
- detect, prevent, or otherwise address fraud, security or technical issues; or
- protect against harm to the rights, property or safety of Carte Clinics, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy.

Statement on Cookies and Similar Technologies
Our Services use cookies and other data collection technologies described in this section. 

Cookies. A cookie is a small file placed on your computer’s hard drive that collects and stores information about your equipment, preferences and browsing patterns. We use cookies to analyze web page traffic, usage patterns, and to tailor our Services to your individual interests. For more information about cookies, visit allaboutcookies.org.

Web Beacons. A web beacon (also referred to as clear gif, pixel tag or single-pixel gif) is a transparent graphic image used in tandem with cookies that enables us to record a user’s actions. We use web beacons to count users who have visited those pages, verify system and server integrity and for similar statistical measures.

Google Analytics. We use Google Analytics to help us understand how users engage with our Services. Google Analytics uses cookies to track your interactions with our Services, then collects that information and reports it to us, without identifying individual users. This information helps us improve our Services so that we can better serve users like you. For more information on Google Analytics, visit support.google.com/analytics.

You can set your Internet browser settings to stop accepting new cookies, to receive notice when you receive a new cookie, to disable existing cookies, and to omit images (which will disable pixel tags). Note that the opt-out will apply only to the browser that you are using when you elect to opt out of advertising cookies. Please note, without cookies or pixel tags, you may not be able to take full advantage of all features of our Services.

Some web browsers incorporate a “Do Not Track” feature (“DNT”) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit allaboutdnt.com.

Choices You Have Regarding Your Information
You may review and request certain changes to the information we have collected about you by contacting us (our contact information is at the end of this Privacy Policy). 

Reviewing, Correcting, and Deleting Your Personal Information. You may access, correct, and/or request deletion of certain information that you have provided to us by emailing us at support@carteclinics.com. If you email us, for your protection, we may only implement requests with respect to the information associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request. We will attempt to comply with any reasonable requests for accessing, correcting, or deleting your information.

Text Messages and SMS. Carte Clinics and those acting on our behalf may send you text (SMS) messages at the phone number you provide us. These messages may include operational messages about your use of the Services, as well as marketing messages. You understand that by providing your mobile phone number, you expressly consent to receive automated text messages from us to the mobile phone number you provide. Consent to receiving text messages is not required in order to be a user. Message and data rates may apply, and you should check the rates of your mobile carrier.  You can opt out of receiving text messages by texting STOP in response to any text message. We share your mobile phone number with service providers with whom we contract in order to send you automated text messages, but we will not share your mobile phone number with third parties for their own marketing purposes without your express consent.

Marketing Communications. You may choose to stop receiving marketing, promotional, reminder, or notification emails, direct mail, phone and mobile marketing communications from us. You can opt-out of these messages following the instruction contained in the message or by contacting us and requesting to opt-out (our contact information is at the end of this Privacy Policy).

Retention of Your Information
As a general matter, we will keep your personal information for as long as necessary to fulfill the purpose for which it was collected. If a law requires us to retain your information for a longer period of time, we will comply with that law. We will also retain your personal information as necessary to protect our legal rights. 

Security of Your Information
We maintain administrative, technical, and physical safeguards designed to protect against unauthorized access, use, modification, and disclosure of your information in our custody and control. No data, on the Internet or otherwise, can be guaranteed to be 100% secure. While we strive to protect your information from unauthorized access, use, or disclosure, we cannot and do not ensure or warrant the security of your information.

Children’s Privacy
We do not knowingly collect information, including personal information as defined by the Children’s Online Privacy Protection Act, from children under the age of 13. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us, you may contact us to request that we delete and stop use of that information (our contact information is at the end of this Privacy Policy). If we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. We will then subsequently delete that child’s information.

Information for Users from Outside of the United States
The Services are intended for use only in the United States. If you use the Services or contact us from outside of the United States, please be advised that (1) any information you provide to us or that we automatically collect will be transferred to the United States; and (2) by using the Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States in accordance with this Privacy Policy.

Contact Us
If you have any questions, comments or concerns regarding this Privacy Policy, please contact us by sending correspondence to support@carteclinics.com.

Notice to California Residents (“CA Privacy Notice”)
Last Updated: August 12, 2023
This CA Privacy Notice describes how Carte Clinics handles your Personal Information as required under applicable law as well certain rights afforded to California residents. For purposes of this CA Privacy Notice, “Personal Information” may be broader than Personally Identifiable Information and means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

Disclosures: In general, in the preceding 12 months:
- We have collected the Personally Identifiable Information described in our Privacy Policy, including the following categories of Personal Information, directly from you, when you use our Service and from third parties:
      - Identifiers / contact information, such as your name, email address, phone number, IP address, account login information
      - Protected class and demographic information, such as age, date of birth, sex, gender, national origin, citizenship, race, marital status, sexual orientation, medical condition, genetic information, and information about your health and/or disability status, including pregnancy information.
      - Professional or employer-related information, such as your business name, job title, office location and other information related to your business
      - Commercial information, such as information about Services purchased or obtained, and considered and Service history and tendencies.
      - Device information, consisting of information from devices you use to connect to the Services, including your mobile device. The information we receive from these devices may include browsing IP address, unique device identifiers such as MAC address, usage information, crash data, device performance characteristics and hardware information, battery status, and WiFi network information.
      - Geolocation data such as physical location or device location, including zip code and Global Position System (“GPS”) data. 
      - Internet or other electronic network activity information, such as interactions regarding your interaction with our Service
      - Biometric information, such as physiological, biological, and behavioral characteristics, and genetic and health information. 
      - Audio, electronic, visual, or other sensory information, such as audio records, videos, images, and photographs.
      - Inferences drawn from the information we collect about you to create a profile about you reflecting your preferences, behaviors, and characteristics. 

Some of the data we collect may be considered sensitive personal information, including your log-in name and password that you use to access your user account on the Services, precise geolocation, racial or ethnic origin, and health and genetic data.

- We have used your Personal Information for the following purposes described in our Privacy Policy, including for the following purposes:
      - To provide you with our Service
      - To maintain and provide support for your Carte Clinics account, if you choose to create one
      - To communicate with you
      - To send you marketing and promotional materials, if you have signed up for such materials
      - To conduct business analytics in order to improve our business functionality and Service to you
      - To detect security incidents, to protect against malicious, deceptive, fraudulent, or illegal activity, and to comply with our policies and procedures
      - To comply with our legal, regulatory, and risk management obligations, including establishing, exercising and/or defending legal claims

- We have shared and disclosed your Personal Information in the following circumstances:
      - We may share any category of your Personal Information to any other third party for whom you have given your consent for us to share your Personal Information
      - We share your identifiers, contact information, and commercial information to healthcare providers to book appointments and facilitate our Service to you
      - To our Service Providers: We may share all categories of your Personal Information with companies that provide services to us, such as for hosting, marketing and communication services, and payment processing (“Service Providers”). Our policy is to authorize these Service Providers to use your Personal Information only as necessary to provide services for us, and require that they not use or disclose your Personal Information for any other purpose.
      - We may have and may potentially share your Personal Information as described in our Privacy Policy and to other third parties outside of Carte Clinics in the following circumstances:
      - We may share any or all categories of your Personal Information with our parent and affiliate companies in order for them to provide analytics across the entire corporate family and for other internal business purposes.
      - From time to time, we may be required to provide any or all categories of your Personal Information to a third party in order to comply with a subpoena, court order, government investigation, or similar legal process.
      - We may also share any or all categories of your Personal Information to third parties, such as law enforcement agencies, when we, in good faith, believe that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

As a California resident, you are entitled to the following disclosures:
- Categories of Personal Information. We have collected in the preceding 12 months the categories of Personal Information detailed in the Disclosures section above.
- Sources of Personal Information. We have collected Personal Information from the sources detailed above.
Use and Disclosure of Personal Information. We have used and disclosed Personal Information for the business and commercial purposes detailed, respectively, in the sections above. We only use and disclose your sensitive personal information for the following purposes: (i) performing services or providing goods reasonably expected by an average consumer; (ii) detecting security incidents; (iii) resisting malicious, deceptive, or illegal actions; (iv) ensuring the physical safety of individuals; (v) for short-term, transient use, including non-personalized advertising; (vi) performing or providing internal business services; or (vii) verifying or maintaining the quality or safety of a service or device. We do not disclose sensitive information for any other purpose.
- Sales and Sharing of Personal Information. We do not sell Personal Information, including the Personal Information of minors under age 16.  When interacting with our Site as a general user (e.g., not when you are logged in), we may share Personal Information with third parties for targeted advertising purposes. 
- Financial Incentives. From time to time, we may offer a financial incentive when you complete onboarding assessments, surveys, tracks, or other programs that ask you to share your feedback or other Personal Information with us. The specific instructions for how to participate in these programs and related incentives may vary and will be set out within each program. Our good-faith estimate of the value of your Personal Information is the value of the benefit we offer to you. We have calculated that value by weighing our expense of operating the program against the benefit. Participation in these incentive programs is always optional, and you can terminate program participation at any time as explained in the applicable program terms. You can also contact us by using the contact information provided below to unsubscribe or cancel your program participation.

Your Rights and Choices: The CCPA provides certain California residents with privacy rights. This section describes how to exercise these rights.
- Right to Know: You have the right to request to know (i) the specific pieces of Personal Information we have about you; (ii) the categories of Personal Information we have collected about you in the last 12 months; (iii) the categories of sources from which that Personal Information was collected; (iv) the categories of your Personal Information that we shared, sold, or disclosed in the last 12 months; (v) the categories of third parties to whom your Personal Information was shared, sold, or disclosed in the last 12 months; and (vi) the purpose for collecting and selling your Personal Information.
- Right to Delete: You have the right to request that we delete the Personal Information that we have collected or maintain about you. We may deny your request under certain circumstances, such as if we need to comply with our legal obligations or complete a transaction for which your Personal Information was collected. If we deny your request for deletion, we will let you know the reason why.
- Right to Correct: You have the right to request that we correct inaccurate Personal Information that we maintain about you.
- Right to Opt Out of Sale or Sharing: You have the right to opt out of the sale or Sharing of your Personal Information. However, we do not sell or share your Personal Information.
- Right to Non-Discrimination: If you choose to exercise any of these rights, we will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our Service.

You may exercise your right to know , right to correct, and your right to delete twice a year free of charge. To exercise your right to know, right to correct, and right to delete, please submit a request  to support@carteclinics.com. You may also submit an opt-out request using a preference signal that is sent in a commonly used and recognized format, such as the Global Privacy Control.

We will take steps to verify your identity before processing your request to know or request to delete. We will not fulfill your request unless you have provided sufficient information for us to verify you are the individual about whom we collected Personal Information. If you have a Carte Clinics account with us, we may use our existing account authentication practices to verify your identity. If you do not have an account with us, we may request additional information about you to verify your identity. We will only use the Personal Information provided in the verification process to verify your identity or authority to make a request and to track and document request responses, unless you initially provided the information for another purpose.

You may use an authorized agent to submit a request to know or a request to delete. When we verify your agent’s request, we may verify both your and your agent’s identity and request a signed document from you that authorizes your agent to make the request on your behalf. To protect your Personal Information, we reserve the right to deny a request from an agent that does not submit proof that they have been authorized by you to act on their behalf.

In addition, residents of California also have the right to request once per calendar year certain information with respect to the types of personal information (as defined by California law) we share with third parties for those third parties' direct marketing purposes, and the identities of the third parties with whom we have shared such information during the immediately preceding calendar year.

Shine the Light: California residents are also entitled to request and obtain from Carte Clinics once per calendar year informational about any of your Personal Information shared with third parties for their own direct marketing purposes. To request this information, please submit a request to support@carteclinics.com.

Additional Notices for Certain Other U.S. Residents
Last Updated: May 25, 2023 

Certain other U.S. residents may be granted the following rights under the laws of your state of residence:
- To access your Personal Information.
- To correct inaccuracies in your Personal Information.
- To delete your Personal Information that we have obtained.
- To receive a copy of your Personal Information in a portable and readily usable format.
- To opt in or opt out of certain types of sensitive Personal Information processing
- To opt out of the processing of your Personal Information for purposes of (i) targeted advertising or (ii) automated decision-making or profiling in furtherance of decisions that produce a legal or similarly significant effect on you. 

If you choose to exercise any of these rights, Carte Clinics will not discriminate against you in any way. If you exercise certain rights, understand that you may be unable to use or access certain features of our website or our products or services. You may have the right to appeal our decision if we deny your rights request. To submit an appeal, contact us at: support@carteclinics.com. 


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