RevelAi – Privacy Policy

Effective Date: March 27, 2024

Contents

●      Introduction

●      How we collect information

●      How we use (process) your information

●      How we share your information

●      Use of the revelai.health website

●      Links to other sites

●      Sharing information with third parties

●      How we share information with third parties

●      Security

●      HIPAA, PIPEDA, GDPR, PHIPA, PIPA

●      Children’s Privacy

●      Your Choices

●      Changes to this Privacy Policy

●      Contact

Introduction

RevelAi is an equity-focused digital health platform that enables specialty providers to improve patient outcomes by integrating Value-Based Care (VBC) and population health models into systems while actively addressing healthcare disparities.

RevelAi, Inc (“RevelAi,” “we,” or “our”) respect your privacy and are committed to protecting it through our compliance with this policy. This Privacy Policy explains how RevelAi collects, uses, discloses, and secures information about you through www.revelai.health, our related websites, networks, applications, electronic communications, including text and email messages, and other services provided by us (collectively, the “Services”). We recognize that information privacy is an ongoing responsibility, and so we will from time to time update this Privacy Notice as we undertake new personal data practices or adopt new privacy policies. By using the Services, you consent to the processing of your information as set forth in this Privacy Policy, now and as amended by us.

In providing the Services, we collect and obtain information about individual consumers (“End Users”) to provide End Users access to artificial intelligence chatbots and care pathways that deliver health-related guidance, reminders, surveys, and related information through the delivery and receipt of health-related text messages. In providing the Services, we at times act as a service provider to health care providers (“Providers”) who use the Services to engage with End Users.

When you submit information to or through the Services, you consent to the collection, use, sharing and processing of your information as described in this Privacy Policy. By using the Services, you accept the terms of this Privacy Policy and our Terms of Service and consent to our collection, use, disclosure and retention of your information as described in this Privacy Policy. IF YOU DO NOT AGREE WITH ANY PART OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, THEN PLEASE DO NOT USE ANY OF THE SERVICES.

How we collect information

RevelAi collects information from and about users of the Services:

·      When Providers enroll you to our Services

·      Directly from you when you provide it to us

·      Automatically when you use the Services

Personal Information. We use information associated with End Users to identify a specific individual. Personal Information includes contact data (such as e-mail address and telephone number).

Provider Submitted Information about End Users. Providers may provide us information about End Users they enrolled or recommended to the Services such as the End User’s name, date of birth, gender, telephone number, address, medical history, scheduled procedure, and prescribed medications. If you do not authorize the Provider to enroll you in our Services, or if you withdraw your authorization, you may not be able to use the Services, but may continue to receive services from the Provider outside of the Services.

Information You Provide. We collect information you provide when you use the Services or otherwise communicate with us. If you request information or enroll in our Services, we will collect the information you provide, such as your name, email address, phone number, city and zip code. We will also collect any information you submit through your use of the Services. For example, if you are an End User, the information you provide can include your text messages, survey responses, and photos submitted to the Services. We may also collect information through your communications with our employees.

Device and Usage Information. Like most digital services, we automatically receive standard technical, information when you interact with our Services including browser and device information such as unique device identifiers, mobile phone carrier, internet protocol (IP) addresses (which may identify your general geographic location), browser types, and the date and time of your interactions. We also receive information about your interactions with our Services, such as which website pages you visited and how much time was spent on the page.

How we use (process) your information

We use information in a variety of ways to provide our Services and to operate our business, including the following:  

Services Related Usage. We use the information we collect about and from you for a number of purposes, including: providing and supporting the Services, analyzing how you use the Services, and better tailoring features. Example Services include responding to End Users’ health-related inquiries and delivering health-related suggestions, reminders, surveys, and related information through the delivery and receipt of text messages.

Improve our Services. We use the information that we collect (i) to understand and analyze usage trends and preferences; (ii) to monitor and analyze the effectiveness of our Services; and (iii) to improve our Services and develop new products, services, features, and functionality.

Anonymous Data. We may de-identify your information and process it in an anonymous form for other purposes than described above, such as research.

How we share your information

We may disclose aggregated information about our users, and information that does not identify any individual or device, without restriction.

In addition, we may disclose personal information that we collect or you provide:

·      To Providers and approved persons. If you are an End User that was enrolled by a Provider, we share information collected from you through the Services with your Provider. In addition, the Services may allow End Users to share information collected with explicitly designated third-parties.

·      To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.

·      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 RevelAi assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by RevelAi about our RevelAi platform End 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.

·      With your consent.

·      To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

·      If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of RevelAi, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Use of the RevelAi Website

As is true of most other websites, RevelAi’s website collects certain information automatically and stores it in log files. The information may include internet protocol (IP) addresses, the region or general location where your computer or device is accessing the internet, browser type, operating system and other usage information about the use of RevelAi’s website, including a history of the pages you view. We use this information to help us design our site to better suit our users’ needs. We may also use your IP address to help diagnose problems with our server and to administer our website, analyze trends, track visitor movements, and gather broad demographic information that assists us in identifying visitor preferences.

RevelAi has a legitimate interest in understanding how members, customers and potential customers use its website. This assists RevelAi with providing more relevant products and services, with communicating value to our sponsors and corporate members, and with providing appropriate staffing to meet customer and End User needs.

Links to Other Sites

Our Services may contain or provide End Users links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

Sharing information with third parties

The personal information RevelAi collects from you is stored in one or more databases hosted by third parties located in the United States. These third parties do not use or have access to your personal information for any purpose other than cloud storage and retrieval.

RevelAi uses certain sub-processors to assist it in providing the Services. Below the list of our third-party sub-processors:

·       Amazon Web Services

·       Microsoft Azure

·       Twilio

·       MongoDB

We do not otherwise reveal your personal data to non-RevelAi persons or businesses for their independent use unless: (1) you request or authorize it; (2) it’s in connection with RevelAi-hosted and RevelAi co-sponsored conferences as described above; (3) the information is provided to comply with the law (for example, compelled by law enforcement to comply with a search warrant, subpoena, or court order), enforce an agreement we have with you, or to protect our rights, property or safety, or the rights, property or safety of our employees or others; (4) the information is provided to our agents, vendors or service providers who perform functions on our behalf; (5) to address emergencies or acts of God; or (6) to address disputes, claims, or to persons demonstrating legal authority to act on your behalf. We may also gather aggregated data about our services and website visitors and disclose the results of such aggregated (but not personally identifiable) information to our partners, service providers, advertisers, and/or other third parties for marketing or promotional purposes.

Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Users of the Services are responsible for maintaining the security of any password, user ID or other form of authentication involved in obtaining access to password protected or secure areas of any of our Services. In order to protect you and your data, we may suspend your use of any of the Services, without notice, pending an investigation, if any breach of security is suspected. Access to and use of password protected and/or secure areas of any of the Services are restricted to authorized users only.

Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through our Services. Any transmission of personal information is at your own risk and we do not accept liability for unintentional disclosure (e.g. leaving your phone unlocked and unattended or giving your account credentials to an unauthorized user). We are not responsible for circumvention of any privacy settings or security measures we provide.

HIPAA, PIPEDA, GDPR, PHIPA, PIPA

Some of our Providers may be regulated as “covered entities” under the Health Insurance Portability and Accountability Act (“HIPAA”), Personal Information Protection and Electronic Documents Act (“PIPEDA”), General Data Protection Regulation 2016/679 (“GDPR”), Personal Health Information Protection Act (“PHIPA”), or Personal Information Protection Act (“PIPA”). Examples of this include healthcare providers (e.g. hospitals, clinics, healthcare systems) and health plans. Please be aware that this Privacy Policy is distinct from such Provider’s HIPAA Notice of Privacy Practices, which describes in detail how that Provider uses and discloses individually identifiable health information. If an End User would like to review a copy of their Provider’s relevant Notice of Privacy Practices, the End User should request a copy directly from their Provider.

Children’s Privacy

Our Services do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.

Your Choices

If you do not want the Services to collect information through the use of cookies, your browser may allow you to be notified when you receive certain types of cookies and restrict or disable certain cookies. Each browser is different, so you should check your browser’s “Help” menu to learn how to change your cookie preferences. Please be aware that if you disable or reject cookies, some features may not work properly.

You can opt-out of receiving further text messages from us by texting “STOP” to the number from which you are currently receiving messages and health information.

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.

Contact

If you have questions, concerns, complaints, or would like to exercise your rights, please contact us at: support@azra.health