Introduction

‍Welcome to Primum, a digital platform empowering licensed medical professionals facing increasing patient complexity to engage with each other to share general, practical medical insights and knowledge, to deliver better care, closer to home.

This Privacy Policy (our “Privacy Policy”) describes how Primum Health, Inc. (“we,” “our,” or “us”) collects personal information about you through the use of primum.co and its subpages (collectively our “Website”) and through other electronic communications between you and Primum Health, Inc. This Privacy Policy also describes our practices for collecting, using, maintaining, protecting, and disclosing that information. We respect your privacy and are committed to protecting it through our compliance with this policy.

This Privacy Policy applies to information we collect:


- on our Website;
- in email, text, and other electronic messages between you and our Website;
- 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;
- any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

This Privacy Policy also does not apply to protected health information covered by the Health Insurance Portability and Accountability Act (“HIPAA”). Privacy practices of such information are governed by the HIPAA rules.

Please read this policy 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 our Website, you agree to this Privacy Policy. This Privacy Policy may change from time to time (see below under “Changes to Our Privacy Policy”). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.

Information We Collect About You

‍We collect, or may collect, several types of information from and about users of our Website, specifically information:

- by which you may be personally identified, such as your name, postal address, billing address, work address, e-mail address, telephone numbers (home, work, and mobile), government identification numbers, date of birth,), gender, race, photos of you, and other personal information;
- that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your visit to our Website, error information, clickstream data, de-identified data created from conversations that take place on the Sites, and other communication data and the resources that you access and use on the Website;
-about your internet connection, the equipment you use to access our Website and usage details.

We refer to this information collectively as “Personal Data” in this Privacy Policy.

‍How We Collect Information About You

We collect Personal Data directly from you when you provide it to us, automatically as you navigate through the Website and from third parties, for example, our business partners.

The information we collect on or through our Website provided by you may include:

- information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, completing a questionnaire or form, or requesting further services. We may also ask you for information when you report a problem with our Website;
- records and copies of your correspondence (including email addresses), if you contact us;
- your responses to surveys that we might ask you to complete; and
- details of transactions that may be tracked through our Website and of initiation of services. You may be required to provide financial information as part of initiation of services through our Website.

We may also collect information about you, including Personal Data, automatically. The information we collect automatically may include personally identifiable information or we may maintain it or associate it with personally identifiable 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 by enabling us to:

- estimate our audience size and usage patterns;
- verify your location to ensure we can provide you with our services;
- store information about your preferences, allowing us to customize our Website according to your individual interests;
- 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 or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
- Web Beacons. Pages of our Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit us, for example, to count users who have visited those pages, used those screens, 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).
- Analytics Services. We may use analytics services to collect certain information relating to your use of the Website. Analytics services use “cookies”, which are text files placed on your computer, to help the Website analyze how users use the site.
- Advertising Networks. We may use advertising networks to provide you with interest-based advertising based on your online activity.

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

- to provide our Website and its contents to you;
- to communicate with you about our products and services;
- to send newsletters, advertisements, or other promotional materials to you regarding our products and services;
- to develop services for you;
- to provide you with information, products or services you request from us;
- to register and service your account;
- to provide you with notices about your account;
- to track administration of care coordination transactions and initiation of services you request;
- to contact you in response to a request;
- to carry out our obligations and enforce our rights arising from any contracts entered into between you and us;
- to enforce our rights arising from contracts or our intellectual property rights;
- to notify you about changes to our Website or any of our products and services;
- in any other way we may describe when you provide the information;
- to fulfill any other purpose for which you provide it;
- for any other purpose with your consent.

Sharing Your Information

‍Our Website may provide you with the opportunity to create individual pages that enable you to share information about your patient’s de-identified health information or general medical questions. If you choose to share information via our Website, information provided may be indexed by public search engines.

Our Website may also provide you with the opportunity to share information about your de-identified patient information or case on social media. Our Website may include certain social media buttons or widgets which allow you to share, retweet or otherwise easily transfer content from our Website to social media platforms (“Social Media Features”). These Social Media Features may collect your IP address, which page you are visiting on our Website, and may set a cookie to enable the Social Media Feature to function properly. Social Media Features are either hosted by a third party or hosted directly on our Website. Your interactions with these Social Media Features are governed by the privacy policy of the company providing it and the privacy settings you have selected on the social media platform.

When using our Website, you may share sensitive personal information with us or with others. Sensitive personal data is a subset of Personal Data which includes, but is not limited to, information revealing health and medical history, race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, or information that concerns sexual orientation, genetic, biometric data or criminal allegations (convictions or otherwise). In general, we do not collect sensitive personal data from you unless you voluntarily provide such information as part of your use of the Services. Providing sensitive personal data is entirely optional. By providing your sensitive personal data, you consent to our collection of such data. Our lawful basis for collection of this data is with your consent. If you provide this information, it may be difficult, if not impossible, to delete this information if you later desire to remove the data. By providing this information in any form, you consent that this information loses its right for future deletion.

Disclosure of Your Information

We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. We may share, sell or disclose your Personal Data:

- to our contractors and third-party service providers that we use to support our business;
- to a company we merge with, acquire, or that buys us, or in the event of change in structure of our company of any form, such as a sale or transfer of some of all of our assets, or a bankruptcy, liquidation or similar proceeding;
- to affiliates and third parties for their commercial purposes;
- to enforce or apply our and other agreements, including for billing and collection purposes;
- to affiliates and third parties to market their products or services to you if you have not opted out of these disclosures;
- to comply with our legal obligations;
- if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of us, our customers, or others (including without limitation exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction);
- to enforce our rights;
- to resolve any potential fraud or perceived irregularity in any audits of the accuracy of any documentation or information submitted to us by you or on your behalf, as deemed appropriate by us;
- to comply with any court order, law, or legal process, including to respond to any government or regulatory request;
- to fulfill the purposes for which you provide it;
- for any purpose disclosed by us when you provide the information; and
- with your consent.

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

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 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. These third parties may, however, aggregate the information they collect with information from their other customers for their own purposes.

In addition, we strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with control over your Personal Data:

- Tracking Technologies and Advertising. You can set your browser or operating system to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Website may then be inaccessible or not function properly.
-Promotional Offers from Us. If you do not wish to have us use your email address to promote our products and services, you can opt-out at any time by emailing us at the contact info below. This opt out does not apply to information provided to us as a result of your purchase or use of our products and services.
- Disclosure of Your Information to Affiliates and Third Parties. By using our Website, you consent to our sharing of your Personal Data with our affiliates and third parties for their promotional purposes. If you wish to unsubscribe from such affiliate and third parties’ promotions, you can do so by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from them.
- Targeted Advertising. We belong to ad networks that may use your browsing activity across participating websites to show you interest-based advertisements on those websites. To learn more about interest-based advertisements and your opt-out rights and options, visit the Digital Advertising Alliance and the Network Advertising Initiative websites (www.aboutads.info and www.networkadvertising.org). Please note that if you choose to opt out, you will continue to see ads, but they will not be based on your online activity. 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 also opt out of receiving targeted ads from members of the NAI on its website.

Promotions for Our Products and Services

‍We may use your Personal Data to contact you about products and services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by contacting us at the email below. For more information, see Choices About How We Use and Disclose Your Information.

Advertising Partners

‍We may use how you browse in order to show you ads for our advertising partners that are more relevant to your interests. We may use cookies and other information to provide relevant interest-based advertising to you. Interest-based ads are ads presented to you based on your browsing behavior in order to provide you with ads more tailored to your interests. These interest-based ads may be presented to you while you are browsing our Website or third party sites we do not own.

‍Links To Other Websites

‍Our Website contains links to other websites that have information we believe may be of interest. We do not endorse these sites. While we try to link only to websites that share our high standards and respect for privacy, we are not responsible for the content of the sites or privacy practices employed by other sites. We encourage you to read the privacy policy of each site you visit that may collect information or ask you to disclose Personal Data. This Privacy Policy does not apply to information collected on external websites that may be linked to or through the Site.     

‍Testimonials

‍We may display personal testimonials of satisfied customers on our Site in addition to other endorsements. With your consent we may post your testimonial along with your name. If you wish to update or deactivate your testimonial, you can contact us at the contact information listed below.

‍SMS/MMS Mobile Messaging Marketing Program

‍We may use your telephone number for the purpose of sending you SMS messaging related to the services we provide, marketing messages, order and shipping confirmations, and other purposes if you have opted in to receive such messaging. You may opt-out from receiving SMS messaging from us, at any time, by emailing info@primum.co notifying us of the change.

Messaging will be sent by an automated system initiated by our third party messaging provider. We do not share your telephone number with third parties for the purposes of receiving third party marketing messages. We also will not send messages to you promoting the goods or services of third parties. For additional information regarding our SMS messaging program, please read our Terms of Service or reach out to us at the contact information below.

Your Rights Regarding Your Information and Accessing and Correcting Your Information

‍You may review and change your Personal Data settings by emailing us at the contact information below. You may also notify us through the contact information below of any changes or errors in any Personal Data we have about you to ensure that it is complete, accurate, and as current as possible or to delete your Personal Data.  We may also not be able to accommodate your request if we believe it would violate any law or legal requirement or cause the information to be incorrect.

‍Data Retention

‍We will retain your information for as long as your account is active or as needed to provide you services. If you wish to deactivate or delete your account or request that we no longer use your information to provide you services, contact us at the contact information listed below. If you provide, enter, upload, or create any information on our Site, it may be difficult if not impossible, to deactivate or delete this information if you later desire to remove the data. By providing this information in any form, you consent that this information loses its right for future deletion. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

‍Do Not Track Signals

‍We also may use automated data collection technologies to collect information about your online activities over time and across third party websites or other online services (behavioral tracking). 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 signal is broadcast or received.

‍Data Security

‍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 you have chosen a password for the use 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 contained on the Website or in your operating system.

‍Your California Privacy Rights

‍Under some circumstances, California law may provide you with the right to obtain a list of third parties (if any) to whom we provide your Personal Data for their own direct marketing purposes.

California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Website that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the preceding calendar year (e.g., requests made in 2020 will receive information regarding such activities in 2019). You may request this information once per calendar year. To make such a request, please send an email by using the Contact Information below.

Children Under the Age of 18

‍Our Website is not intended for children under 18 years of age. No one under age 18 may provide any information to or through the Website. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on our Website or on or through any of their 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 18, we will delete that information. If you believe we might have any information from a child under 18, please contact us using the contact information listed below.

‍Storage of Personal Data in the United States

‍All of the information that you provide to us will be stored and processed in the United States. While you may access our Website from a location outside of the United States, you agree not to transfer any of your information to us from outside the United States. The laws in the United States may not offer the same degree of privacy protection as the laws in your jurisdiction.

‍Changes to Our Privacy Policy

‍We may change this Privacy Policy at any time. It is our policy to post any changes we make to our Privacy Policy on this page with a notice that the Privacy Policy 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 by email to the email address you have provided to us and/or through a notice on the Website’s home page. The date this Privacy Policy was last revised is identified at the bottom 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 reviewing this Privacy Policy to check for any changes.

Contact Information

‍You may contact us through the contact information below.

If you have any questions, concerns, complaints or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below or through the “Contact” page on our Website.

How to Contact Us:

Name: Support Services
Address: 85 5th Ave., 8th Floor, New York, New York, 10003
Email: info@primum.co