Your privacy is important to us. This privacy policy (“Privacy Policy”) applies to your use of the Site (as defined in the Terms of Service) offered by Community Wellness Technology, Inc. and its affiliates, including MyCleo.com. Community Wellness Technology, Inc. and its affiliates are collectively referred to in this Privacy Policy as “CW,” “we,” “us,” or “our.”

This Privacy Policy applies to any information we collect or maintain about you, including (1) personal information that you provide to us on or through the Site and (2) information collected through your use of or interaction with the Site. This Privacy Policy also explains the use of cookies and similar technologies on the Site. Your access to and use of the Site constitutes acceptance of this Privacy Policy and consent to our collection and use of your information as outlined below.

Please note that the Site is directed towards users who reside in the United States. It is not our intent to gather personal information from individuals residing outside the United States. This Privacy Policy does not apply to instances where your information is collected under a different privacy policy or notice made available to you at the time your information is collected.

Capitalized terms not otherwise defined in this Privacy Policy have the same meaning as set forth in the Terms of Service.

  1. Minors

Our Site is not intended for or designed to attract children under the age of 13. Moreover, we do not knowingly collect any personal information from anyone under the age of 18 without the consent of a parent or guardian, and you must be 18 years of age or older to submit registration or survey information. Should you believe that a minor of whom you are a parent or guardian has registered, please contact us at Community Wellness Technology, Inc., 1821 South Bascom Avenue #383, Campbell, CA 95008, ATTN: Legal and we will make reasonable efforts to remove all personal information related to the minor.

  1. Privacy Policy Updates

From time to time, we may revise this Privacy Policy. Any such changes to this Privacy Policy will be promptly reflected on this page. We encourage you to review this Privacy Policy regularly for any changes. Your continued use of this Site will be subject to the then-current Privacy Policy. The effective date of this Privacy Policy is July 1, 2021.

  1. Personal Information We Collect

You can generally visit the Site without revealing any personal information about yourself. However, to access certain options and services, we may ask you to provide certain personal information and without providing such personal information, you may be unable to access certain options and services. The following is a list of information that we may collect from or about you:

  • Personal information: your name and contact information (including your address, email address, phone number, and electronic signature), demographic information (including your gender, date of birth, and zip code), billing information (billing address, payment information)
  • Account information: your username and password
  • Device and/or browser information: your IP address, operating system, connection speed, bandwidth, browser type, web page requests, cookie information, other hardware and software attributes
  • Location information
  • Usage activity and viewing preferences
  • Your content: information or content you post or submit on the Site
  • Transaction history
  • For Providers: your name, contact information, and medical specialty
  • Other: information we collect from or about you in other online or offline contexts, including information submitted during purchases of Services and Products and interactions with our employees

In addition, when you request treatment from a Provider through the Site, you may share:

  • Personal information: your name and contact information (including your address, email address, phone number, and electronic signature), demographic information (including your gender, date of birth, and zip code), and demographic information; and
  • Medical information submitted for diagnosis or treatment purposes (including information about your applicable medical history) and current complaint or other reason for visiting a Provider

The information you provide to a Provider through the Site may be protected under applicable federal and state laws applicable to health information, including but not limited to, the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its implementing regulations, as may be amended from time to time (collectively, “HIPAA”). The Providers will use and disclose information about you that is protected under such privacy laws only as permitted or required by such laws. The Providers have adopted a [LINK TO NOTICE OF PRIVACY PRACTICES] that describes how they use and disclose PHI (as defined below). By accessing or using any part of the Service, you are acknowledging receipt of the Notice of Privacy Practices from your Provider(s).

We will not use or disclose information about you that is protected under health information privacy laws except on behalf of the Providers, as permitted by such laws, but may combine the personal information you share with us through the Site with other information we collect from or about you, both online and offline. We may also combine personal information with records provided by third parties. We use this consolidated information to help us better design our Site, including the selection of Services and Products, to communicate information to you, to enhance our marketing and research activities, and to facilitate other business functions.

  1. How We Collect Personal Information

We may collect information directly from you when you visit; access or use the Site; or when you register an account with us. We may also collect information when you purchase a Service or any Products available on our Site, submit information to use through a survey, communicate with us, or post or submit content on or in the Site.

Some of the information we collect depends on the settings on your web browser or mobile device. Please check your web browser or mobile device if you want to learn what information your browser or mobile device sends or how to change your settings. In addition to the information sent by your web browser or mobile device, as you navigate through a website or mobile app, certain information can be passively collected (that is, gathered without you actively providing the information) using various technologies and means, such as navigational data collection.

Like most website operators, we use cookies and similar technologies, local shared objects (or any other successor tracker technology), Software Development Kits, and pixel tags that automatically receive and track certain data about how you and other visitors interact with our Site, preferences expressed and settings chosen. For example, we may collect information about the technology you use (such as your browser, type of computer, operating system, mobile device and network used, and Internet service providers) and server log data (such as access dates and times, online features or pages viewed, system activity, and the third-party site or service you were using before interacting with our Site). These technologies are described in more detail below.

“Cookies” are small text files that are stored on your browser or device by websites, mobile apps, online media, and advertisements. There are different types of cookies. Cookies served by the entity that operates the website or app you are visiting or using are called “first party cookies” (so cookies served by us while you are using our Site are first party cookies). Cookies served by companies that are not operating the website or app you are visiting or using are called “third party cookies” (so we may use a website analytics provider to set a cookie on your computer via our Site while you visit our Site and that would be a third party cookie). Cookies may also endure for different periods of time. “Session cookies” last only as long as your browser or app is open. These are deleted automatically once you close your browser or app. Other cookies are “persistent cookies,” meaning they survive after your browser or app is closed (for example, they may recognize your computer when you re-open our online services).

“Local shared objects” (also called “Flash cookies” or “HTML5 cookies”) and any other successor technology refers generally to the collection of cookie-like data stored on a browser or computer by websites, ads, or third parties.

“Pixel tags” (also called “beacons” or “pixels”) are small blocks of code installed on (or called by) a web page, app, or advertisement which can retrieve certain information about your device and browser, including device type, operating system, browser type and version, website visited, time of visit, referring website, IP address, and other similar information (including the small text file (the cookie) that uniquely identifies the device). Pixels provide the means by which third parties can set and read browser cookies from a domain that they do not themselves operate and collect information about visitors to that domain, typically with the permission of the domain owner.

“Software Development Kits” (also called “SDKs”) function like pixels and cookies but operate in the mobile app context where pixels and cookies cannot always function. The primary app developer can install pieces of code (the “SDK”) from partners in the app, thereby allowing such partners to collect certain information about user interaction with the app, information about the user device, and network information.

In this Privacy Policy, these and similar technologies are collectively referred to as “cookies and technologies.” The following table sets out the different categories of cookies and technologies that our Site may use and why we use them:

Cookie Types and Purpose

Authentication: These cookies and technologies tell us when you’re using our Site so we can show you the appropriate features and content, such as your account information, purchase history, and to edit your account settings.

Security and web site integrity: These cookies and technologies support or enable security features to help keep our Site safe and secure. For example, they enable us to remember when you are logged into a secure area of our Site and help protect your account from being accessed by anyone other than you.

Online service features: These cookies and technologies provide functionality that help us deliver products and services. For example, cookies help you log in by pre-filling fields. We may also use these cookies and similar technologies to help us provide you and others with social plugins and other customized content and experiences.

Analytics and research: These cookies and technologies are used to understand, improve, and research our Site and better understand the interests of people who interact with our Site. For example, we and our approved partners may use these cookies and technologies to understand how you are using Site features, and segmenting audiences for feature testing. We and our partners may use these technologies and the information we receive to improve and understand how you use and interact with our Site.

For example, our Site uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to analyze use patterns and may collect information about your use of our Site. More information on Google Analytics can be found at www.google.com/policies/privacy/partners. If you would like to opt-out of having your data used by these cookies, please use the Google Analytics opt-out available at https://tools.google.com/dlpage/gaoptout/.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across the networks of websites and online services in which we participate. If we do so in the future, we will describe how in this Privacy Policy.

  1. How We May Use Personal Information

We may use the personal information identified above to:

  • Verify your identity and your location;
  • Provide the Product and/or Services to you;
  • Provide information about our Services and Products to you;
  • Fulfill your requests;
  • Manage your account;
  • Process your payments;
  • Communicate with you;
  • Provide support and training;
  • Develop, test, or improve the Site, including its features and/or the Services and Products;
  • Facilitate marketing activities and/or promotions;
  • Analyze behaviors on the Site (e.g., evaluating site usage patterns, assessing throughput);
  • Protecting or enforcing our rights, title, and interest;
  • Other uses in order to comply with applicable law, regulation, legal process, or other government authority;
  • Investigate fraud; and
  • Any other such use that is otherwise necessary under applicable law
  1. With Whom We Share Personal Information

We may share the information we collect from you with the following third parties:

  • Providers
  • Pharmacies
  1. Social Media Plugins

The Site may use social media plugins (e.g., the Facebook “Like” button, “Share to Twitter” button) to enable you to easily share information with others. When you visit the Site, the operator of the social plugin can place a cookie on your computer, enabling that operator to recognize individuals who have previously visited the Site. If you are logged into the social media website (e.g., Facebook, Twitter) while browsing on our Site, the social plugins allow that social media website to receive information that you have visited our Site. The social plugins also allow the social media website to share information about your activities on our Site with other users of their social media website. For example, Facebook Social Plugins allows Facebook to show your Likes and comments on our pages to your Facebook friends. Facebook Social Plugins also allows you to see your friends’ Facebook activity on our Site. We do not control any of the content from the social media plugins. For more information about social plugins from other social media websites, you should refer to those sites’ privacy and data sharing statements.

  1. How Long We Retain Personal Information

We will only retain personal information for as long as it is necessary to fulfill the purposes for which it was collected or to satisfy a legal obligation imposed on us. Personal information that is no longer needed for the above purposes will be deleted or anonymized. In the event we retain and use personal information for purposes not covered by the original notice, we will provide you with additional notice.

  1. Applicability of HIPAA

Pursuant to the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191 and its implementing regulations (collectively, “HIPAA”), you understand that CW is not deemed a “covered entity” as defined by HIPAA, and CW may, in some cases, be a “business associate” of a Pharmacy or Provider. If CW is deemed a “business associate,” we will be subject to additional protections of your “protected health information,” as defined under HIPAA (“PHI”), or other state laws. Your PHI will be used and disclosed only in accordance with such applicable laws and regulations.

  1. Security

We may employ procedural and technological security measures, consistent with industry practice. Such measures are reasonably designed to protect your personal information from loss, unauthorized access, disclosure, alteration, or destruction. We may use encryption, password protection, secure socket layers, internal restrictions, and other security measures to help prevent unauthorized access to your personal information. However, you provide your information to us at your own risk. We cannot guarantee that your data will not be lost, accessed without authorization, disclosed, altered, or destroyed.

  1. Links to Third Party Sites

Our Site may contain links to other websites on the Internet that are not under the control of or maintained by us. Such links do not constitute an endorsement by us of those other websites, the content displayed therein, or the persons or entities associated therewith. You acknowledge that we are providing these links to you only as a convenience and you agree that we are not responsible for the content of such websites. Your use of these other linked websites is subject to the respective terms of use and privacy policies located on the linked websites.

  1. Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by email at help@mycleo.com or help@communitywellness.com. You may also send your questions to Community Wellness Technology, Inc., 1821 South Bascom Avenue #383, Campbell, CA 95008, ATTN: Legal.