This Privacy Policy (“Policy”) lets you know how Citus Health Inc. (“Citus”, “We, “Us”) collects and uses your Personal Information, how you can control its use, and describes our practices regarding information collected from our website, computer or software applications, and social media pages and HTML-formatted e-mail messages (collectively, the “Services”).

This policy applies to information we collect:

  • On this Website.
  • In e-mail, text and other electronic messages between you and this Website.
  • Through our SaaS Application.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by Us or any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

We do not participate in the E.U. – U.S. and Swiss – U.S. Privacy Shield Frameworks and do not comply with the Privacy Shield Principles.

We at Citus know you care about how your personal information is used and shared, and we take your privacy seriously. Please read the following to learn more about our Privacy Policy. By using or accessing the Services in any manner, you acknowledge that you accept the practices and policies outlined in this Privacy Policy, and you hereby authorize Citus to collect, use, and share your information for the purposes identified herein and on the Site.

Remember that your use of Citus’ Services is at all times subject to the Terms of Service, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Service.

The Services may provide links to or the ability to connect with non-Citus websites, services, social networks or applications. Clicking on those links or enabling those connections might allow the third party to collect or share information about you. Those third-party websites or services are beyond Citus’s control. Citus advises you to check the privacy policies and terms of use of any non-Citus websites or services before providing any of your Personal Information to them.

As noted in the Terms of Service, we do not knowingly collect or solicit personal information from anyone under the age of 18. If you are under 18, please do not attempt to register for the Services or send any personal information about yourself to us. If we learn that we have collected personal information from anyone under age 18, we will delete that information as quickly as possible. If you believe that anyone under the age of 18 may have provided us personal information, please contact us at: citushealth.com.

1. Will Citus ever change this Privacy Policy?

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time as well, but we will alert you to changes by placing a notice in the app, by sending you an email, and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

2. WHAT DOES CITUS DO WITH YOUR INFORMATION. We want to be very clear about the type of information we collect and how we use it to deliver our Services to you and operate our business. We do not sell or share your Personal Information with third parties for their own commercial uses without your consent.

a) Types of Information We Collect. In connection with accessing our Services, we may collect information from you which can be used to identify you (“Personal Information”), such as your name, postal address, email address, phone, username and password and ANY OTHER INFORMATION THE WEBSITE COLLECTS THAT IS DEFINED AS PERSONAL OR PERSONALLY IDENTIFIABLE INFORMATION UNDER AN APPLICABLE LAW (“personal information”). Our website might also collect personal information that is about you but individually does not identify you, and/or about your internet connection, the equipment you use to access our Website and usage details.

We may also collect information about you that may include name, email addresses, telephone numbers, information of any person related to logging in to the Services, birth dates, social security numbers, and personally identifiable information (PII) including financial information, and protected health information covered under HIPAA.

We collect information when you register or open an account, sign in, pay a bill, purchase a Service, call us for support, or give us any type of feedback. We may also get information from other companies or third parties, or when we may use service providers to supplement the Personal Information you give us such as validating your mailing address to help us maintain the accuracy of your data and provide you with better service. We might also collect content or other information that you may provide or create when you interact with our Services.

To create and open an account through the Services, We may require you to provide personal information to identify yourself such as name, email address, password, phone number, date of birth and social security number or federal EIN number.

When purchasing certain Services, you will also be required to provide a credit card number, billing address, phone number or other payment information. No information of this type will be collected unless you have registered for aspects of the Service that require it. Be advised that if we collect payment from you of any kind that we will utilize the services of a third party payment processor to facilitate your payment by credit card.

We may also automatically collect certain usage information when you access our Services (“Usage Data”), such as Internet Protocol address (“IP address”) and information derived from your IP address such as your geographic location, log files, unique device identifiers, pages viewed, browser type, any links you click on to leave or interact with our Services, and other usage information collected from cookies and other tracking technologies. We collect IP addresses to track and aggregate non-personal information, such as using IP addresses to monitor the regions from which users navigate to our Services. We also collect IP addresses from users when they log into the Services as part of our log-in and security features. We may also, when you enable location-based Services, collect Global Positioning System (GPS) location data and/or motion data. We may also collect Past transactional behavior conducted by You on the Services, Information about your company such as the name, size and location of your company and your role within the company, and Behavioral or demographic attributes, when tied to personal identifiers.

Citus may also collect additional information through your dealings with and use of the Services and non-Citus websites, which does not disclose your specific identity or does not directly relate to an individual. Additional information may include, but is not limited to:

  • Internet Protocol address (“IP address”) and information derived from your IP address such as your geographic location;
  • Geographic location showing where You are using the Services;
  • Information about your devices such as information contained in HTTP Headers (defined below) or other internet transfer protocol signals, browser or device type and version; operating system, user-agent strings and information about or from the presence or use of “apps” on your mobile devices, screen resolution, and your preferred language;
  • Unique IDs such as a cookie placed on your computer, mobile or device IDs;
  • Behavioral data and information about your usage of the Services, including webpages clicked, websites and content areas visited, date and time of activities;
  • The web search you undertook to locate and navigate to the Services.

We might also may put together additional information with Personal Information, such as gathering geographical location from your IP address and combining all of this with behavioral data about your usage of the Services with your name. If we combine additional information with personal Information, we will treat the combined information as Personal Information.

We might also collect personal information from you if you log into our Services using a Third Party Social Network such as Facebook, Instagram or Snapchat.

Our Services may change over time and we may introduce new features that may collect new or different types of information.

b) How Citus Uses Your Information. Citus may use your Personal Information it collects (unless otherwise prohibited by applicable law), for the following purposes:

(i) Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to use our paid services, posting material or requesting further services. We may also ask you for information when you report a problem with our Website.

(ii) Account Registration. We may use your name, address, phone number, and email address to register your Citus Account for certain Services we provide and to communicate important information to you. We may obtain additional Personal Information about you, such as address change information, from commercially available sources, to keep our records current. If you set up an administrator account that may be accessed by people other than you, please note that they may see and have the ability to change or delete your Personal Information.

(iii) Records and copies of your correspondence (including e-mail addresses), if you contact us.

(iv) Your responses to surveys that we might ask you to complete for research purposes.

(v) Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.

(vi) Your search queries on the Website

(vii) To bill and collect money owed to us by our Customers. This includes sending you emails, invoices, receipts, notices of delinquency, and alerting you if we need a different credit card number. We use third parties for secure credit card transaction processing, and we send billing information to those third parties to process your orders and credit card payments.

(viii) To send you System Alert messages. For example, we may inform you of temporary or permanent changes to our Services, such as scheduled outages, new features, version updates, releases, abuse warnings, and changes to our Privacy Policy.

(ix) To enforce compliance with our Terms and Conditions and applicable law. This may include developing tools and algorithms that help us prevent violations.

(x) To protect the rights and safety of our Employees, Customers and third parties, as well as our own.

(xi) To meet legal requirements, including complying with court orders, valid discovery requests, valid subpoenas, and other appropriate legal mechanisms which includes responding to lawful requests by public authorities, including to meet national security or law enforcement requirements.

(xii) To communicate with our Customers about their account and provide customer support.

(xiii) To Let You Know About Other Services. We may use your information to communicate with you about our Services and to give you offers for third party products and services that may be of use to you.

(xiv) To Improve Services and Develop New Services. We may use your information to personalize or customize your experience to develop new features or services, and to improve the overall quality of Citus’s Services.

(xv) Feedback. We may use any information you volunteer provide to us in surveys you answer and combine them with answers from other customers in order for us to better understand our Services and how we may improve them. Of course, answering any survey is optional.

(xvi) To Provide Our Services and Operate Our Business. We may use your information to operate our business, including providing any Services that you have requested, provide you with support related to our Services, and to help us protect our Services, which includes taking action against fraud and protect your information.

(xvii) Customer Service and Technical Support. We may use your name, address, phone number, email address, how you interact with our Services, and information about your computer configuration to deal with and resolve questions you may have about our Services and to follow up with you about your experience.

(xviii) Publishing or Sharing Combined Information from Many Users In a Manner that Would Not Allow You or Any Other Person to be Identified Personally. We may prepare and share information about our customers with third parties, such as advertisers or partners, for research, marketing and/or promotional purposes but only in a way that would not allow you or any other person to be identified. For example, we may share demographic data that describes the percentage of our customers who use one of our services or who use a specific operating system. We or our third party partners may publicly report the aggregated findings of the research or analysis, but only in a way that would not allow you or any other person to be identified.

(xix) To provide information to representatives and advisors, including attorneys and accountants, to help us comply with legal, accounting, or security requirements.

(xx) To prosecute and defend a court, arbitration, or similar legal proceeding.

(xxi) To provide suggestions to you. This includes adding features that compare Customers’ content or communications, using data to suggest products or services that you may be interested in or that may be relevant to you.

(xxii) To transfer your information in the case of a sale, merger, consolidation, liquidation, reorganization, or acquisition. In that event, any acquirer will be subject to our obligations under this Privacy Policy, including your rights to access and choice. We will notify you of the change either by sending you an email or posting a notice on our Website.

(xxiii) Customer Testimonials. We might at some point upload Customers testimonials on our Services that may contain Personal Information. Before doing so, we will obtain your consent to use your name and testimonial. If you ever desire to delete a testimonial, please contact us at: citushealth.com

(xxiv) Respond to Your Requests. Citus may also use Personal Information in order to respond directly to your information requests.

(xxv) Third Party Social Networks. Citus may use your Personal Information to connect with you on third party social networks. Citus’s interactions with you on any third party social network would be subject to that network’s privacy policies and terms of use.

(xxvi) We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Website, or transmitted to other users of the Website or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages/you may set certain privacy settings for such information by logging into your account profile, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

c) How Does Citus Share Your Personal Information. We may disclose aggregated information about our users, and information that does not identify any individual, without restriction. We do not sell your personal information to third parties.

We may disclose personal information that we collect or you provide as described in this privacy policy:

(i) Third Party Service Providers. We do not share your personal information with unaffiliated third parties except agents or companies acting on Citus’ behalf. This means we may share information about you with service providers or agents in order to have them perform on our behalf any of the activities we are permitted to conduct under this Privacy Policy and our Terms of Service including but not limited to website design, sending email communications, fraud detection and prevention, customer care, removing repetitive information from customer lists, analyzing data, providing marketing assistance, providing search results and links (including paid listings and links), processing credit card payments, providing customer service or performing analytics. These third parties are acting on our behalf so while they may have access to your information they’re required to follow our instructions and meet the standards explained in our Privacy Policy when handling information about you that we provide them.

(ii) To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by the Company about our Website users is among the assets transferred.

(iii) To third parties to market their products or services to you if you have consented to these disclosures.

(iv) For any other purpose disclosed by us when you provide the information.

(v) With your consent.

(vi) Response to Subpoenas and Other Legal Requests. We may share your information with courts, law enforcement agencies, or other government bodies when we have a good faith belief that we are required or permitted to do so by law, including to meet national security or law enforcement requirements, to protect our company, or to respond to a court order, subpoena, search warrant, or other law enforcement request.

(vii) Protection of Citus and Others. We may share account information, Personal Information and Usage Data when we believe it is appropriate to enforce or apply our products’ Terms of Service and other agreements; or protect the rights, property, or safety of Citus, our Services, our users, or others. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction. This does not include selling, renting, sharing, or otherwise disclosing Personal Information of our customers for commercial purposes in violation of the commitments set forth in this Privacy Statement.

(viii) Reporting to Credit Bureaus. We may share your information with credit bureaus, consumer reporting agencies, and card associations. Late payments, missed payments, or other defaults on your account may be reflected in your credit report and consumer report. We may also share your information with other companies, lawyers, credit bureaus, agents, government agencies, and card associations in connection with issues related to fraud, credit, or debt collection.

(ix) Sale of Our Business. If we sell, merge, or transfer any part of our business, we may be required to share your information. If so, you will be asked if you’d like to stop receiving promotional information following any change of control.

(x) We do not sell or rent Personal Information to unaffiliated third parties for their advertising or marketing lists.

(xi) With your Consent. Other than as set out above, we will provide you with notice and the opportunity to choose when your Personal Information may be shared with other third parties.

3. WHAT CHOICES DO I HAVE ABOUT MANAGING MY PRIVACY?

You can always opt not to disclose information to us, but keep in mind some information may be needed to register with us or to take advantage of some of our features.

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

  • Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.
  • We do not control third parties’ collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

If you have privacy concerns regarding access to or the correction of your Personal Information, please contact us at: citushealth.com

4. Public Information and Third Party Websites

(a) Blog. We may at some point have public blogs on our Websites. Any information you include in a comment on our blog may be read, collected, and used by anyone. If your Personal Information appears on our blogs and you want it removed, contact us. If we are unable to remove your information, we will tell you why.

(b) Social media platforms and widgets. Our Websites may include social media features, such as the Facebook Like button. These features may collect information about your IP address and which page you are visiting on our Website, and they may set a cookie to make sure the feature functions properly. Social media features and widgets are either hosted by a third party or hosted directly on our Website. We might also maintain presences on social media platforms including Facebook, Twitter, and Instagram. Any information, communications, or materials you submit to us via a social media platform is done at your own risk without any expectation of privacy. We cannot control the actions of other users of these platforms or the actions of the platforms themselves. Your interactions with those features and platforms are governed by the privacy policies of the companies that provide them and we encourage you to read them.

(c) Links to third-party websites. Our Websites may include links to other websites, whose privacy practices may be different from Citus. If you submit Personal Information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Website you visit.

(d) Cookies and Similar Tracking Technologies. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). The information we collect automatically is statistical data and does not include personal information, but 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 our Website 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 Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our the Website may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

(e) Third-party Use of Cookies and Other Tracking Technologies.

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

(f) Do Not Track Disclosure

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services (including behavioral advertising services) that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time.

5. We Operate in the US Only

Citus operates in the United States only.

6. Security of Your Information

The security of your Personal Information is extremely important to Citus. We use physical, electronic, and administrative safeguards that are designed to protect your Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

We provide reasonable and appropriate security measures in connection with securing Personal Information we collect. For example, we:

  • Constantly work to update our security practices to implement accepted best methods to protect your Personal Information, and review our security procedures carefully.
  • Comply with applicable laws and security standards.
  • Securely transmit your sensitive Personal Information.
  • Train our staff and require them to safeguard your data.
  • We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure.
  • The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
  • Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

7. Notice of Breach of Security

If a security breach causes an unauthorized intrusion into our system that materially affects you, then Citus will notify you as soon as possible and later report the action we took in response.

8. Safeguarding Your Information

We take reasonable and appropriate measures to protect Personal Information from loss, misuse and unauthorized access, disclosure, alteration and destruction, taking into account the risks involved in the processing and the nature of the Personal Information.

Citus accounts require a username and password to log in. You must keep your username and password secure, and never disclose it to a third party. Account passwords are encrypted, which means we cannot see your passwords. We cannot resend forgotten passwords either. We will only reset them.

9. DATA RETENTION AND YOUR ACCESS RIGHTS

a) Data Retention. In accordance with and as permitted by applicable laws and regulations, we will retain your information as long as necessary to provide our Services you, to maintain your account for as long as your account is active, or as otherwise needed to operate our business. When you close your account, we may continue to communicate with you about our Services, give you important business updates that may affect you, and let you know about products and services that may interest you, unless you have opted out of receiving marketing communications. We may also continue to use some of your information for business purposes and to improve our offerings or in some cases to develop new ones. We will retain and use your information as required by applicable regulations and Citus’s records and information management policies to comply with our legal and reporting obligations, resolve disputes, enforce our agreements, complete any outstanding transactions and for the detection and prevention of fraud.

Accessing and Correcting Your Information

You may send us an e-mail at: citushealth.com to request access to, correct or delete any personal information that you have provided to us. We cannot delete your personal information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from the Website, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other Website users. Proper access and use of information provided on the Website, including User Contributions, is governed by our terms of use.

10. California Privacy

Under California Law, California residents have the right to request in writing from businesses with whom they have an established business relationship, (a) a list of the categories of Personal Information, such as name, email and mailing address and the type of services provided to the customer, that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes and (b) the names and addresses of all such third parties. To request the above information, please contact us through our contact form or at the addresses above.

11. CAN SPAM Act

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.

We collect your email address in order to:

  • Send information, respond to inquiries, and/or other requests or questions.
  • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred

To be in compliance with CANSPAM we agree to the following:

  • NOT use false, or misleading subjects or email addresses
  • Identify the message as an advertisement in some reasonable way
  • Monitor third party email marketing services for compliance, if one is used.
  • Honor opt-out/unsubscribe requests quickly
  • Allow users to unsubscribe by using the link at the bottom of each email

If at any time you would like to unsubscribe from receiving future emails, you can Follow the instructions at the bottom of each email and we will promptly remove you from all correspondence.

12. What if I have questions about this policy?

If you have any questions or concerns regarding our privacy policies, please contact Us at: citushealth.com and we will try to resolve your concerns.

13. Special Rules For Children.

Because of federal law, we are not permitted to knowingly collect any personal information from a child under the age of thirteen without the consent of that child’s parent or guardian. The statements in this Privacy Policy about our collection and use of personal information also apply to our treatment of personal information from children under the age of thirteen. Some elements of our Services such as signing up for our Services require the submission of a payment card number along with personal information in connection with a purchase; other elements of our Services require the submission of personal information to access or use the Services. Except in certain cases where limited contact information may be collected and not retained, these elements of our Services are not available to children under the age of thirteen. If a child who we know to be under the age of thirteen and for whom we have not received parental consent attempts to utilize a service on our Services which is not available to children, he/she will not be able to access it and may receive a message which relays that he/she is not eligible for such feature.

14. Dispute Resolution

If you have any complaints regarding our compliance with this policy, you should first contact Citus. We will investigate and attempt to resolve complaints and disputes regarding use and disclosure of your personal information in accordance with this policy.

15. Corporate Headquarters

If you have any questions about this Privacy Policy please contact us at: Citus Health Inc. located 181 East 119th Street, 8C, New York, NY 10035.

Last Updated: December 1, 2018