Introduction

Halo-Rx Meds, LLC (the "Websites") located at www.halo-rxmeds.com (collectively, the "Platform"). Your access and use of the Platform, any part thereof, or anything associated therewith, including its content ("Content"), any products or services provided through the Platform or otherwise by Halo-Rx Meds, and any affiliated website, software or application owned or operated by Halo-Rx Meds (collectively, including the Platform and the Content, the "Service") are subject to this Privacy Policy unless specifically stated otherwise. Capitalized terms not otherwise defined in this Privacy Policy have the same meaning as set forth in the Halo-Rx Meds Terms and Conditions ("Terms and Conditions").

We are committed to respecting the privacy of users of the Service. We created this Privacy Policy ("Privacy Policy") to tell you how Halo-Rx Meds collects, uses and discloses information in order to provide you with the Service.

By creating, registering, or logging into an account through the Service, or otherwise accessing or using the Service, you are acknowledging the most recent version of this Privacy Policy. If we make any changes to our Privacy Policy, we will post the revised Privacy Policy and update the "Last updated" date of the Privacy Policy.

If you are using the Service on behalf of an individual other than yourself, you represent that you are authorized by such individual to act on such individual's behalf and that such individual acknowledges the practices and policies outlined in this Privacy Policy.

Limitations on Use by Minors

Our Service is generally intended for use by individuals who are at least eighteen (18) years of age or such older age as may be required by applicable state laws in the jurisdiction in which an individual utilizes the Service. The Service is not designed or intended to attract, and is not directed to, children under eighteen (18) years of age. If we obtain actual knowledge that we have collected personal information through the Platform from a person under eighteen (18) years of age, we will use reasonable efforts to refrain from further using such personal information or maintaining it in retrievable form.

Please note that we are not required to erase or otherwise eliminate, or enable erasure or elimination of such content or information in certain circumstances, such as, for example, when an international, federal, state, or local law, rule or regulation requires Halo-Rx Meds to maintain the content or information; when Halo-Rx Meds maintains the content or information on behalf of your Providers (as defined in our Terms and Conditions) as part of your electronic medical record; when the content or information is stored on or posted to the Site by a third party other than you (including any content or information posted by you that was stored, republished or reposted by the third party); when Halo-Rx Meds anonymizes the content or information, so that you cannot be individually identified; when you do not follow the aforementioned instructions for requesting the removal of the content or information; and when you have received compensation or other consideration for providing the content or information.

Protected Health Information

When you set up an account with Halo-Rx Meds, you are creating a direct customer relationship with Halo-Rx Meds that enables you to access and/or utilize the various functions of the Platform and the Service as a user. As part of that relationship, you provide information to Halo-Rx Meds, including but not limited to, your name, email address, shipping address, phone number and certain transactional information, that we do not consider to be "protected health information" or "medical information".

However, in using certain components of the Service, you may also provide certain health or medical information that may be protected under applicable laws. Halo-Rx Meds is not a "covered entity" under the Health Insurance Portability and Accountability Act of 1996, Public Law 104-191, and its related regulations and amendments from time to time (collectively, "HIPAA"). One or more of the Pharmacies or Medical Groups (as defined in our Terms and Conditions) may or may not be a "covered entity" or "business associate" under HIPAA, and Halo-Rx Meds may in some cases be a "business associate" of a Pharmacy or Medical Group. It is important to note that HIPAA does not necessarily apply to an entity or person simply because there is health information involved, and HIPAA may not apply to your transactions or communications with Halo-Rx Meds, the Medical Groups, the Providers, or the Pharmacies. To the extent Halo-Rx Meds is deemed a "business associate" however, and solely in its role as a business associate, Halo-Rx Meds, may be subject to certain provisions of HIPAA with respect to "protected health information," as defined under HIPAA, that you provide to Halo-Rx Meds, the Medical Group or the Providers ("PHI"). In addition, any medical or health information that you provide that is subject to specific protections under applicable state laws (collectively, with PHI, "Protected Information"), will be used and disclosed only in accordance with such applicable laws. However, any information that does not constitute Protected Information under applicable laws may be used or disclosed in any manner permitted under this Privacy Policy. Protected Information does not include information that has been de-identified in accordance with applicable laws.

Collection of Personal Information

The personal data we collect depends on how you interact with us, the services you use, and the choices you make.

We collect information about you from different sources and in various ways when you use our services, including information you provide directly, information collected automatically, information from third-party data sources, and data we infer or generate from other data.

Information you provide directly

We collect personal data you provide to us. For example:

• Name and contact information, such as your name, email address, phone number, and billing and physical addresses.
• Demographic data, such as your gender, date of birth, and zip code.
• Third-party website, network, platform, server and/or application information (e.g., Facebook, Twitter, Instagram)
• Payment information, such as your credit card number, financial account information, and other payment details.
• Content and files, such as photographs, videos, documents, and other files you upload to our Service. This includes email messages and other communications you send to us.
• Sensitive personal information

Sensitive Personal Information:

• Government ID. We may collect government-issued identifiers such as driver's license, passport number, and social security numbers.
• Photographic or video images submitted for identification or non-diagnosis or treatment purposes, including photographs of your driver's license or passport
• Account access information. We collect information such as a username or account number in combination with a password, security or access code, or other credential that allows access to an account.
• Contents of communications. We collect the contents of communications that you make via our Service.
• Health data. We collect and analyze information concerning your health.

Information we collect automatically

When you use our services, we collect some information automatically. For example:

• Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device's operating system, browser, and other software including type, version, language, settings, and configuration.
• Usage data. We automatically log your activity on our websites, apps and connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website.

Information we create or generate

We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics ("inferences"). For example, we infer your general geographic location (such as city, state, and country) based on your IP address.

Information we obtain from third-party sources

We also obtain the types of information described above from third parties. These third-party sources include, for example:

• Third-party partners. Third-party applications and services, including social networks you choose to connect with or interact with through our services.
• Co-branding/marketing partners. Partners with which we offer co-branded services or engage in joint marketing activities.
• Service providers. Third parties that collect or provide data in connection with work they do on our behalf, for example companies that determine your device's location based on its IP address.
• Publicly available sources. Public sources of information such as open government databases.

When you are asked to provide personal data, you may decline. And you may use web browser or operating system controls to prevent certain types of automatic data collection. But if you choose not to provide or allow information that is necessary for certain services or features, those services or features may not be available or fully functional.

Cookies, Mobile IDs, and Similar Technologies

We use cookies, web beacons, mobile analytics and advertising IDs, and similar technologies to operate our websites and online services and to help collect data, including usage data, identifiers, and device information.

What are cookies and similar technologies?

Cookies are small text files placed by a website and stored by your browser on your device. A cookie can later be read when your browser connects to a web server in the same domain that placed the cookie. The text in a cookie contains a string of numbers and letters that may uniquely identify your device and can contain other information as well. This allows the web server to recognize your browser over time, each time it connects to that web server.

Web beacons are electronic images (also called single-pixel or clear GIFs) that are contained within a website or email. When your browser opens a webpage or email that contains a web beacon, it automatically connects to the web server that hosts the image (typically operated by a third party). This allows that web server to log information about your device and to set and read its own cookies.

Mobile analytics and advertising IDs are generated by operating systems for mobile devices (iOS and Android) and can be accessed and used by apps in much the same way that websites access and use cookies. Our apps contain software that enables us and our third-party analytics and advertising partners to access these mobile IDs.

Use of Personal Information

We use the personal information we collect for purposes described in this Privacy Policy or as otherwise disclosed to you, subject to the limitations addressed in the "Protected Information" section above. For example, we use personal information for the following purposes:

We combine data we collect from different sources for these purposes, and to give you a more seamless, consistent, and personalized experience.

Disclosure of Information

We disclose personal data with your consent or as we determine necessary to complete your transactions or provide the services you have requested or authorized. Subject to the limitations described in the Protected Health Information section above, we may disclose your information to third parties in connection with the provision of our Service or as otherwise permitted or required by law. For example, we may disclose your information to:

• Service providers. We provide personal data to vendors or agents working on our behalf for the purposes described in this statement.
• Financial services & payment processing. When you provide payment data, we will disclose payment and transactional data to banks and other entities as necessary for payment processing, fraud prevention, credit risk reduction, analytics, or other related financial services.
• Marketing/Ad Partners. We may provide personal data to marketing and advertising partners.
• The Pharmacies, Medical Groups, or their Providers. We facilitate information sharing between you and the Medical Groups, Pharmacies, Providers, as applicable, to enable them to provide services to you via the Service.
• Legal and law enforcement. We will access, disclose, and preserve personal data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process.
• Security, safety, and protecting rights. We will disclose personal data if we believe it is necessary to protect our customers and others, operate and maintain the security of our services, or protect the rights or property of ourselves or others.

Choice and Control of Personal Data

We provide a variety of ways for you to control the personal data we hold about you, including choices about how we use that data. In some jurisdictions, these controls and choices may be enforceable as rights under applicable law.

You can choose whether to receive promotional communications from us by email or SMS. If you receive promotional email or SMS messages from us and would like to stop, you can do so by following the directions in that message or by contacting us as described in the "Contact Us" section below.

Browser or platform controls

Cookie controls. Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies.

Global Privacy Control. Some browsers and browser extensions support the "Global Privacy Control" (GPC) or similar controls that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing.

Mobile advertising ID controls. iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.

Data Retention

Halo-Rx Meds may retain your information for as long as it believes necessary; as long as necessary to comply with its legal obligations, resolve disputes, and/or enforce its agreements; and/or as long as needed to provide you with the products and/or services of the Service or Halo-Rx Meds. Halo-Rx Meds may dispose of or delete any such information at any time except as set forth in any other agreement or document executed by Halo-Rx Meds or as required by law.

California Residents

If you are a California resident and the processing of personal information about you is subject to the California Consumer Privacy Act (CCPA), you have certain rights with respect to that information.

HIPAA Privacy Statement

Notice of Privacy Practices for Protected Health Information (PHI)

This Notice of Privacy Practices ("Notice") describes how Halo-Rx Meds ("we", "us", or "our") may use and disclose your Protected Health Information (PHI) to carry out treatment, payment, or healthcare operations and for other purposes that are permitted or required by law. This Notice also describes your rights regarding your PHI.

Uses and Disclosures of PHI

We may use and disclose your PHI for the following purposes:

• Treatment: We may use and disclose your PHI to provide, coordinate, or manage your healthcare and related services.
• Payment: We may use and disclose your PHI to obtain payment for healthcare services provided to you.
• Healthcare Operations: We may use and disclose your PHI for healthcare operations, including quality assessment, improvement activities, case management, accreditation, licensing, and credentialing.
• As Required by Law: We may use and disclose your PHI when required to do so by federal, state, or local law.
• Public Health and Safety: We may use and disclose your PHI to prevent or control disease, injury, or disability.

Your Rights Regarding PHI

You have the following rights with respect to your PHI:

• Right to Inspect and Copy: You have the right to inspect and copy your PHI that we maintain, with certain exceptions.
• Right to Amend: You have the right to request an amendment to your PHI if you believe it is incorrect or incomplete.
• Right to an Accounting of Disclosures: You have the right to request an accounting of disclosures of your PHI made by us in the past six years.
• Right to Request Restrictions: You have the right to request a restriction on our use or disclosure of your PHI.
• Right to Request Confidential Communications: You have the right to request that we communicate with you about your PHI in a certain way or at a certain location.
• Right to be Notified of a Breach: You have the right to be notified in the event that we discover a breach of your PHI.

Contact Information

If you have any questions about this Privacy Policy, please contact us by email at privacy@halo-rxmeds.com

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