Website Privacy Policy

Effective Date: January 25, 2023

1. Introduction

This Privacy Policy (this “Privacy Policy”) describes the personal information that HealthDrive Corporation and its affiliates (collectively, “HealthDrive,” “we,” “us,” or “our”) may collect, and how HealthDrive collects, uses and discloses such personal information when you access or use our website made available at (the “Website”), as well as your choices related to your personal information. By accessing or using the Website, you acknowledge and consent to the practices described in this Privacy Policy regarding our collection, use and disclosure of your personal information.

Patient health information and any other information that is Protected Health Information (as defined by the Health Insurance Portability and Accountability Act of 1996 and its implementing regulations) is governed by, and will be used and disclosed solely as permitted by our Notice of Privacy Practices. For more information about the privacy of Protected Health Information, please refer to our Notice of Privacy Practices.

Employees and job applicants may receive a supplemental privacy notice that applies to their relationship with HealthDrive in the context of their employment or job application. In the event of any conflict with this Privacy Policy, the supplementary employee notice will control.

If you do not consent to the terms of this Privacy Policy, you may not use the Website. Please note that some privacy rights and obligations may differ in certain locations based on local law, in which case HealthDrive will comply with local legal requirements. If you reside in California, Colorado, Connecticut, Utah or Virginia, Section 7 may apply to you.

2. The Personal Information We Collect

The categories of information we have collected about you in the last 12 months include the following:

• “Personal information” is 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. Personal information can include identifiers such as your name, email address, physical address and telephone number or other information, commercial information, and inferences from any of the above. HealthDrive will only collect this information if you provide it to us on the “Contact Us” page and is limited to the information you provide.

• “Usage Data” is information that we automatically collect about your Internet or other electronic network activity, including your use of the Website and the sort that Web browsers and servers typically make available, through Web server logs, Web beacons, cookies and other similar tracking technologies, about the devices you use to access our Website, as well as information on how you interact with our Website. Usage Data may include the IP address of a device or internet service used to connect your device to the Internet and may provide information about your location; computer and connection information such as your browser type and version; operating system and platform; and the URLs which lead you to and around the Website including the date and time of access. Usage Data generally does not directly identify an individual, but may constitute Personal Information in some instances.

3. How We Collect Your Personal Information

When you access or use the Website, HealthDrive may collect personal information in the following ways:

• Information You Provide to HealthDrive: HealthDrive collects personal information when you use and interact with the Website, such as when you complete and submit forms to us on our Website, or when you communicate with HealthDrive about our Website whether by letter, e-mail, online chat window, or telephone.

• Information that HealthDrive Collects Automatically: When you use the Website, HealthDrive may automatically collect Usage Data subject to the settings of your device that you use to access the Website. HealthDrive may use this data to analyze trends and statistics to improve your online experience or our customer service.

4. Use of Information Collected by HealthDrive

HealthDrive may use the personal information you provide us for various purposes, including to:

• Respond to your comments, questions and requests and provide customer service;

5. Data Collection Technologies

We and our service providers may use various tracking technologies, including cookies and web beacons, to collect information about you when you interact with our Website. Cookies are small data files stored on your hard drive or in device memory that help us improve the Website and your experience, see which areas and features of the Website are popular, and count visits. Web beacons are electronic images that may be used on the Website or emails and help deliver cookies, count visits and understand usage and campaign effectiveness. For more information about cookies, and how to disable them, please see “Your Choices” below.

Notice concerning Do Not Track. Do Not Track is a privacy preference that users can set in certain web browsers. We are committed to providing you with meaningful choices about the information collected on our websites for third-party purposes, and that is why we provide the variety of opt-out mechanisms listed above. Some web browsers offer users a “Do Not Track” privacy preference setting in the web browser. We do not currently recognize or respond to browser-initiated Do Not Track signals. Please note that “Do Not Track” is a distinct privacy mechanism from the browser-based opt out signals referenced above, which HealthDrive does honor in accordance with applicable law.

6. Disclosing Your Information

We may share information about you, including personal information, as follows, or as otherwise described in this Privacy Policy:

• With vendors, consultants and other service providers who need access to such information to carry out work or perform services on our behalf;

• In response to requests from local, state, provincial or federal law enforcement officials, any judicial, administrative or similar proceeding or order, such as a subpoena if we believe disclosure is in accordance with, or required by any applicable law;

• If we believe your actions are inconsistent with our user agreements or policies, or to protect the rights, property and safety of HealthDrive and others;

• To investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, the Website’s

rules or policies, or the rights of third parties or to investigate any suspected conduct which we deem improper;

• 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 HealthDrive and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership;

• With your consent or at your direction;

• To comply with transparency or other public reporting obligations; and

• As otherwise permitted or required by law.

7. Your Privacy Rights

If you reside in California, Colorado, Connecticut, Utah or Virginia, you may have legal rights with respect to your personal information. You may have the right to: (i) request additional disclosures about the personal information we collect, use, and share;

(ii) request access to and deletion of your personal information, subject to certain exceptions; (iii) opt out of the sale and sharing of your personal information; (iv) correct inaccurate personal information that we maintain about you; (v) limit the use and disclosure of sensitive personal information; and (vi) obtain a copy of your personal information. We will not discriminate against you for exercising any of these rights.

Methods for submitting requests. If you wish to exercise any of these rights, please email with the phrase “Privacy Rights” in the subject line. You may also send a request to us via mail at HealthDrive, 100 Crossing Blvd., Suite 300, Framingham, MA 01702 (please mark the envelope ‘Data Protection Officer’), or call us toll-free at (800) 964-6681. We will process your request within the timeframe provided by applicable law. The rights described herein are not absolute and we reserve all of our rights available to us at law in this regard. You may have the right to appeal our decision with respect to a request you have submitted by emailing us at Additionally, if we retain your personal information only in de-identified form, we will not attempt to re-identify your data in response to a privacy rights request.

If you make a request related to personal information about you, you will be required to supply a valid means of identification as a security precaution. We will verify your identity with a reasonably high degree of certainty using the following procedure where feasible: we will match identifying information you provide when making the request to the personal information maintained by us, or use a third-party identity verification service. If it is necessary to collect additional information, we will use the information only for verification purposes and will delete it as soon as practicable after complying with your request. For requests related to particularly sensitive information, we may require additional proof of your identity.

Authorized Agents. You may use an authorized agent to submit a right to know or right to deletion request. 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 for you. To protect your personal information, we reserve the right to deny a request from an agent that does not submit adequate proof that you authorized them to act for you.

Sales and Sharing of Personal Information. Under the CCPA, a ‘sale’ is defined broadly to include disclosing or making available personal information to a third-party in exchange for monetary compensation or other benefits or value, and ‘share’ broadly includes disclosing or making available personal information to a third party for purposes of cross-context behavioral advertising. As such, while we do not disclose personal information to third parties in exchange for monetary compensation, we may, pursuant to the CCPA or other applicable law, sell or share personal information with advertising networks and third party ad companies and data analytics providers in order to analyze use of the Website, optimize and develop our products and services, improve and measure our ad campaigns, and reach users with more relevant ads and content. However, we do not knowingly sell or share personal information about individuals who are younger than 16.

Verification. When you exercise your right to know or right to delete, we will take steps to verify your identity with a reasonably high degree of certainty before processing your request. We may ask for additional information so that we can verify your identity. If it is necessary to collect additional information, we will use the information only for verification purposes and will delete it as soon as practicable after complying with your request. We will only use the personal information you provide to us in response to this request to verify your identity and to process your request, unless you initially provided the information for another purpose. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Shine the Light: Individuals who are California residents may request (i) a list of categories of personal information disclosed to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes; and (ii) a list of the categories of third parties to whom we disclosed such information. To exercise a request, please send us an email or a letter to the addresses in the section entitled “Contact Us” below and specify you are making a “California Shine the Light” request. We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

8. Security of Personal Information

HealthDrive has reasonable and appropriate safeguards in place to help protect the personal information HealthDrive collects from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Although HealthDrive attempts to protect the personal information in our possession, no security system is perfect, and HealthDrive cannot promise that your personal information will remain absolutely secure in all circumstances.

9. Retention of Personal Information

HealthDrive will retain your personal information as needed to fulfill the purposes for which it was collected. HealthDrive will retain and use your personal information as necessary to comply with HealthDrive’s business requirements, legal obligations, resolve disputes, protect our assets, and enforce our agreements, but for no longer than six months

10. Links to Third Party Websites

Our Website may contain certain links to third party websites. HealthDrive is not responsible or liable for the privacy practices or content found on these websites. You should check the privacy notice and policies of each website you visit. Links to third party websites are provided solely for your convenience and any use or submission of data to such websites shall be at your sole risk.

11. United States Only

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

12. Changes to the Privacy Policy

HealthDrive may change this Privacy Policy at any 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. We may try to notify you of material changes to this Privacy Policy, which if we do so may be by means such as by posting a notice directly on the Website, by sending an e-mail notification (if you have provided your e-mail address to us), or by other reasonable methods. In any

event, if you use the Website after changes to this Privacy Policy, you have accepted the changes. If you do not agree with the changes, please stop using the Website.

13. Contact Us

If you have any questions or concerns related to this Privacy Policy, please contact us at: (800) 964-6681

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