Orchestra Healthcare, Inc. Privacy Notice

 Orchestra Healthcare, Inc. (“Orchestra Health” or “we” or “us”) respects your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Notice (our “Privacy Notice”) describes the types of information we may collect, use, maintain, protect, disclose, or otherwise process about you when you visit the website tryorchestra.com (the “Website”) and our practices for collecting, using, maintaining, protecting, disclosing, or otherwise processing that information. 

This policy applies to information we collect:

• on our Website; and
• in email, text, and other electronic messages between you and our Website.

It does not apply to information collected by:

• us through any other means, including on any other website operated by Orchestra Health or any third-party (including our affiliates and subsidiaries); 
• us or any of our affiliates or subsidiaries related to your or any other individual’s employment or potential employment with us; 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 the Website.

Please read this Privacy Notice carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Website. By accessing or using this Website, you agree to this Privacy Notice. This Privacy Notice may change from time to time (see Changes to Our Privacy Notice). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Notice periodically for updates. 

Children Under the Age of 13

Our Website is not intended for children under the age of 13 and children under the age of 13 are not permitted to use our Website. We will remove any information about a child under the age of 13 if we become aware of it.

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to the Website. We do not knowingly collect Personal Data from children under 13. If you are under 13, do not use or provide any information on our Website or on or through any of its features, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information directly from a child under 13, please contact us at hello@tryorchestra.com. 

Information We Collect About You and How We Collect It

We collect different types of information about you, including information that may directly identify you, information that is about you but individually does not personally identify you, and information that we combine with our other users. This includes information that we collect directly from you or through automated collection technologies. 

Throughout this Privacy Notice, the term “Personal Data” means any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or device. However, Personal Data does not include any deidentified or aggregated information. 

Generally

We collect Personal Data from various sources, including:

• directly from you when you provide it to us; and
• From third parties, for example, our business partners.

Information You Provide to Us

We collect the following types of Personal Data directly from you when you access or use our Website: real name, postal address, unique personal identifier, email address, telephone number, social security number, drivers’ license number, employment history, medical information, age, birthdate, color, marital status, medical conditions, physical or mental disability, gender, gender identity, gender expression, sexual orientation, pregnancy status, veteran or military status, genetic information, health data, and exercise data. In addition, we also collect other types of information that you may provide when you fill out a form or through your correspondence with us. 

The Personal Data we collect on or through our Website through:

• information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, or requesting further services. We may also ask you for information when you report a problem with our Website;
• if you contact us, records and copies of your correspondence (including email addresses); and
• your responses to surveys that we might ask you to complete for research purposes;

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain Personal Data about your interaction with our Website, including information about your equipment, browsing actions, and patterns:

• details of your visits to our Website. This includes communication data and the resources that you access, use, or otherwise interact with on the Website; 
• Information about your computer and internet connection, i.e., your IP address, operating system, and browser type.

The information we collect automatically is statistical data and does not include Personal Data, we may maintain it or associate it with Personal Data 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 by enabling us to:

• estimate our audience size and usage patterns;
• store information about your preferences;
• customize our Website according to your individual interests;
• speed up your searches; and
• 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. Our Website may use both session cookies (which expire once you close your browser) and persistent cookies (which stay on your computer until you delete them) to provide you with a more personal and interactive experience on 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. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. However, if you do not consent to our use of cookies or select this setting you may be unable to access certain parts of our Website. You can find more information about cookies at http://www.allaboutcookies.org and http://youronlinechoices.eu. 
• 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. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.
• Session Cookies. Our use of cookies also includes “session cookies.” Each time you access the Website, a session cookie containing an encrypted, unique identifier is placed on your browser. These session cookies allow us to uniquely identify you when you use the Website and track which pages of the Website you access. Session cookies are required to use the Website.
• Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Orchestra Health, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 

Information We Collect from Third Parties

We may collect Personal Data from third parties. When we associate this information with other Personal Data about you, we consider this information to be Personal Data. This information includes: real name, postal address, unique personal identifier, email address, telephone number, social security number, drivers’ license or other state-issued ID number, insurance information, employment history, medical information, age, birthdate, color, marital status, medical conditions, physical or mental disability, gender, gender identity, gender expression, sexual orientation, pregnancy status, veteran or military status, and genetic information.  

How We Use Your Information

We use your Personal Data for various purposes described below, including to:

• provide our Website to you;
• provide you with information you request from us;
• enforce our rights arising from contracts;
• notify you about changes; and
• provide you with notices about your account

We use information that we collect about you or that you provide to us, including any Personal Data:

• to provide and personalize our Website and its content to you;
• to provide you with information, products, or services that you request from us;
• to support, develop, troubleshoot, and debug our Website, products, and services;
• to create, maintain, customize, and secure your account with us;
• to process your requests, purchases, transactions, and payments and prevent transactional fraud;
• to provide you with notices about your account;
• to provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses;
• for internal testing, research, analysis, and product development, including to develop and improve our Website, and to develop, improve, or demonstrate our products and services;
• to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection;
• to notify you about changes to our Website or any products or services we offer or provide though them;
• to allow you to participate in interactive features on our Website;
• in any other way we may describe when you provide the information; 
• to fulfill any other purpose for which you provide it; and
• for any other purpose with your consent.

For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. We disclose your Personal Data to a few third parties, including:

• our subsidiaries and our affiliates;
• our third-party service providers that we use to support our business;
• to a company we merge, acquire, or that buys us, or in the event of change in structure of our company of any form; 
• to comply with our legal obligations;
• to enforce our rights; and
• with your consent.

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Notice. However, we may disclose aggregated information about our users, and information that does not identify any individual, without restriction. 

We may disclose Personal Data that we collect or you provide as described in this Privacy Notice:

• to our subsidiaries and affiliates;
• to contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep Personal Data confidential and use it only for the purposes for which we disclose it to them. These entities provide IT and infrastructure support services, and payment processing services and Our payment processors’ privacy policies may be found at http://stripe.com/us/privacy.
• to a potential or actual buyer or other successor in the event of a planned or actual merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Orchestra Health’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Orchestra Health about our Website’s users is among the assets transferred;
• to fulfill the purpose for which you provide it;
• for any other purpose disclosed by us when you provide the information; and
• with your consent.

We may also disclose your Personal Data:

• to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
• to enforce or apply our terms of use and other agreements, including for billing and collection purposes; and
• if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Orchestra Health, our customers, or others. 

Choices About How We Use and Disclose Your Information

We offer you choices on how you can opt out of our use of tracking technology, disclosure of your Personal Data for third-parties to advertise to you, our advertising to you, and other targeted advertising. 

We do not control the collection and use of your information collected by third parties described above in Disclosure of Your Information. When possible, these organizations are under contractual obligations to use this data only for providing the services to us and to maintain this information strictly confidential. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes. 

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 learn more about interest-based advertisements and your opt-out rights and options from members of the Network Advertising Initiative (“NAI”) on its website (www.networkadvertising.org) and from members of the Digital Advertising Alliance on its website (www.aboutads.info). 

Accessing, Correcting, and Deleting Your Personal Data

We may use automated data collection technologies to track you across websites. We currently do not honor do-not-track signals that may be sent by some browsers. 

You can review and change your Personal Data by logging into the Website and submitting a request. You may also call us at 210.549.6581 to request access to, correct or delete any Personal Data that you have provided to us. We cannot delete your Personal Data except by also deleting your user account. We may not accommodate a request to change or delete your Personal Data if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.

Do Not Track Signals

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential. 

We do not track you over time and across third-party websites or other online services for any purpose. Some web browsers permit you to broadcast a signal to websites and online services indicating a preference that they “do not track” your online activities. At this time, we do not honor such signals and we do not modify what information we collect or how we use that information based upon whether such a signal is broadcast or received by us.

Data Security

Information transmitted over the Internet is not completely secure, but we do our best to protect your Personal Data. You can help protect your Personal Data and other information by keeping your password to our Websites confidential. 

We have implemented measures designed to secure your Personal Data 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 Data, we cannot guarantee the security of your Personal Data transmitted to our Website. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures deployed on the Website. 

Changes to Our Privacy Notice

We will post any changes to our Privacy Notice on our Website. If we make material changes to our Privacy Notice, we may notify you through a notice on the Website’s home page.

We may change this Privacy Notice at any time. It is our policy to post any changes we make to our Privacy Notice on this page with a notice that the Privacy Notice has been updated on the Website’s home page. If we make material changes to how we treat our users’ Personal Data, we will notify you through a notice on the Website’s home page. The date this Privacy Notice was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this Privacy Notice to check for any changes.

YOUR CONTINUED USE OF OUR WEBSITE FOLLOWING THE POSTING OF CHANGES CONSTITUTES YOUR ACCEPTANCE TO SUCH CHANGES.

Contact Information

If you have any questions, concerns, complaints, or suggestions regarding our Privacy Notice or the ways in which we collect and use your Personal Data described in this Privacy Notice, have any requests related to your Personal Data pursuant to applicable laws, or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Website. 

Orchestra Healthcare, Inc.

3331 General Hudnell Drive

San Antonio, Texas 78226

United States

210.549.6581

hello@tryorchestra.com

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