KADEN (vMAT) PRIVACY POLICY

Last Updated: March 2022

Kaden Health, Inc.’s (“Kaden”, “we” or “us”) virtual Medication Assisted Treatment Model also referred to as “vMAT” enables healthcare professionals (“Treatment Providers”) to see and treat their patients (“Patients”) via video. This Privacy Policy applies to information we collect about you, including when you use our websites, mobile applications, and other online products and services that link to this Privacy Policy (collectively, our “Services”), contact our customer service team, engage with us on social media, or otherwise interact with us. This Privacy Policy does not apply to aggregated or de-identified information that cannot reasonably be used to identify you.

This Privacy Policy does not apply to the storage, use, and collection of protected health information (“PHI”), which is governed by the Health Insurance Portability and Accountability Act (“HIPAA”) and therefore is covered by our HIPAA Notice of Privacy Practices (the “HIPAA Policy”). Any conflict between this Privacy Policy and the HIPAA Policy with respect to such PHI shall be resolved in favor of the HIPAA Policy. Also, please note that, unless we define a term in this Privacy Policy, all capitalized terms used in this Privacy Policy have the same meanings as in our Terms of Service. Therefore, please make sure that you have read and understand our Terms of Service.

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).  We encourage you to review this Privacy Policy regularly to stay informed about our information practices and the choices available to you.

COLLECTION OF INFORMATION

Information You Provide to Us

We collect information you provide directly to us.  For example, you share information directly with us when an account is created for you, fill out any forms, conduct appointments (“Appointments”), submit or post content through our Services, make a purchase, communicate with us via third-party platforms, request customer support, or otherwise communicate with us.  The types of personal information we may collect include your name, email address, country, profession, telephone number, payment information, and any other information you choose to provide.

The types of information we may collect include:

• Basic user information: If you are a Patient, we may collect your name and country information and your Treatment Provider may capture images necessary for the telehealth visit and for medical record keeping. If you are a Treatment Provider, we may collect information necessary to create your account and provide you the Services such as your name, email address, postal address, phone number, profile photo, profession, username and password.
• Financial information: We collect financial information to process your transactions through the Services such as your credit card information (although note that we do not store full credit card numbers as all payment transactions are processed by our third party payment processors).
• Notes Data: We collect information that Treatment Providers input into the notes functionality of the Services. 
• Background Check and License Information: If you are a Treatment Provider, we will collect background check information about you and information about your medical license, including your federal program exclusion data, malpractice information, and criminal history (as permitted by applicable law. This information may be collected by a third party vendor on our behalf as part of your credentialing review.
• Information You Provide to Us: We collect information that you provide to us about yourself and about others such as (a) if you are a Patient, location information, emergency and caregiver contact information including your emergency contact’s name, phone number and relationship to you, (b) healthcare information that you choose to provide to us, like medical history, patient profile, symptoms, (c) if you are a Treatment Provider, information about other Treatment Providers, (c) any feedback or suggestions you provide to us about our Services and (d) any other information you choose to provide to us.

Other Information We Collect When You Interact with Us

We use different technologies (including automated systems) to collect and process your information. When you access or use our Services or otherwise transact business with us, we automatically collect information about your activities, including:

• Activity Information: We collect information about your activity on our Services, such as the date and time you use our Services, number of times you use our Services, chats, and Appointment recordings. If you are a Patient and with your prior consent, your Treatment Provider may record your voice and/or image through video and voice recordings during Appointments.  Additionally, if you are a Patient, we may collect information about you from your Treatment Provider and if you are a Treatment Provider, we may collect information about you from your Patients.
• Transactional Information: When you conduct a transaction through the Services such as hosting or participating in an Appointment or paying for an Appointment, we collect information about the transaction, such as the amount paid or received and the date and time of the transaction.
• Device and Usage Information:  We collect information about how you access our Services, including data about the device and network you use, such as your hardware model, operating system version, mobile network, IP address, unique device identifiers, browser type, and app version. We also collect information about your activity on our Services, such as access times, webpages viewed, links clicked, and the page you visited before navigating to our Services.
• Information Collected by Cookies and Similar Tracking Technologies:  We (and our service providers) may use tracking technologies, such as cookies and web beacons, to collect information about you.  Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits.  Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Services or emails to help deliver cookies, count visits, and understand usage and campaign effectiveness.  For more information about cookies and how to disable them, see the Your Choices section below.

Information We Collect from Other Sources

We may also obtain information about you from other sources.  For example, we may collect information about you from internet service providers, government entities, operating systems and platforms, social networks, customer feedback, business partners through which customers access our Services, insurance providers, and marketing service providers.

Information We Derive

We may derive information or draw inferences about you based on the information we or our partners collect. For example, we may make inferences about your location based on your IP address.

USE OF INFORMATION

We use the information we collect to administer your account.  We also use the information we collect to:

• Provide, maintain and improve our Services;
• Process transactions and send you related information, including confirmations and customer experience surveys;
• Send you technical notices, security alerts, and support and administrative messages and to respond to your comments, questions, and to provide you customer service;
• Communicate with you about products, services, and events offered by Kaden and others, and provide news and information we think will interest you (see Your Choices below for information about how to opt out of these communications at any time);
• Monitor and analyze trends, usage, user behavior and activities in connection with our Services;
• For research and development purposes, we may use datasets such as those that contain images, voices or other data that could be associated with an identifiable person;
• Tailor your experience on our Services;
• Detect, investigate and prevent security incidents and other malicious, deceptive, fraudulent, or illegal activity, and protect the rights and property of Kaden and others;
• Debug to identify and repair errors in our Services;
• Comply with our legal and financial obligations, including as required in accordance with HIPAA or related applicable local, state or federal laws (please refer to the HIPAA Policy); and
• Carry out any other purpose described to you at the time the information was collected.

SHARING OF INFORMATION

We share personal information in the following circumstances or as otherwise described in this policy:

• With vendors, service providers, and consultants that need access to personal information in order to perform services for us, such as companies that assist us with web hosting, fraud prevention, customer service, payment processing, , and marketing and advertising (except we will not share your PHI for marketing and advertising purposes without your prior written authorization);
• With our partners to fill your prescriptions and analyze your lab results;
• Publicly on our Services if you submit a product review or post content in another public area of our Services, like our virtual waiting rooms;
• With other users of the Services if you are conducting or participating a group Appointment;
• With your Treatment Provider if you are a Patient and with your Patient if you are a Treatment Provider;
• If we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements;
• If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Kaden, our users, the public, or others;
• With our lawyers and other professional advisors where necessary to obtain advice or otherwise protect and manage our business interests;
• In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;
• [Between and among Kaden and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership]; and
• With your consent or at your direction.

Third Party Sites

The Services contain links to other sites that are owned or operated by third parties. We are not responsible for the content, privacy or security practices of any third parties. To protect your information, we encourage you to learn about the privacy policies of those third parties.

Analytics

We allow others to provide analytics services on our behalf across the web and in mobile apps. These entities may use cookies, web beacons, device identifiers, and other technologies to collect information about your use of our Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in mobile apps, links clicked, and conversion information. This information may be used by Kaden and others to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity.

We also work with third parties to serve ads to you as part of customized campaigns on third-party platforms (such as Facebook and Instagram). As part of these ad campaigns, we or the third-party platforms may convert information about you, such as your email address and phone number, into a unique value that can be matched with a user account on these platforms to allow us to learn about your interests and serve you advertising that is customized to your interests. Note that the third-party platforms may offer you choices about whether you see these types of customized ads.

TRANSFER OF INFORMATION TO THE UNITED STATES AND OTHER COUNTRIES

Kaden is headquartered in the United States and we have operations and service providers in the United States and other countries. Therefore, we and our service providers may transfer your personal information to, or store or access it in, jurisdictions that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it.

YOUR CHOICES

Account Information

You may update and correct certain account information you provide to us at any time by logging into your account or emailing us at [email protected]  If you wish to deactivate your account, please email us at [email protected], but note that we may retain certain information as required by law or for legitimate business purposes.  We may also retain cached or archived copies of information about you.

Cookies

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  Please note that removing or rejecting cookies could affect the availability and functionality of some of our Services. For more information about cookies and how to disable them, see the Your Choices section below.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at [email protected] or write to us at:  Kaden Health, Inc. located at 450 Lexington Avenue, 4th Floor, New York, NY 10017.