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Path Assist App Privacy Notice

Effective February 24, 2022

Nomi Health, Inc. (“Nomi Health”) is a health care services provider that has developed this application (the “Path Assist App”) to assist Activate Care in its provision of certain services to you more efficiently and effectively.  This privacy notice (“Notice”) describes the individually identifiable information (“Personal Information”) that Nomi Health collects in connection with this Path Assist App, how we use that information and how you may interact with us.

The Notice covers:

· Scope of the Notice

· Information We Collect

· How We Use the Information We Collect

· "Do Not Track" Requests

· How We Share Your Information with Third Parties

· Third-Party Websites

· Social Media Features

· Preferences and Opting-Out

· California Consumer Privacy

· No Use by Children

· Security

· Lawful Basis if Subject to GDPR

· Privacy Notice Changes

· How to Contact Us

 

Scope of the Notice

This Notice applies to all Personal Information provided to us in this Path Assist App and Personal Information you provide us about yourself and others, or when your Personal Information is provided to us by others on your behalf. We may use that information for marketing, sales, quality improvement, product development, fraud detection and data analytics.

For information regarding compliance with the California Consumer Privacy Act (“CCPA”), please refer to our CCPA Notice.

Information We Collect

We collect Personal Information from you in several ways in connection with your use of this Path Assist App.

You provide us with Personal Information directly, we collect Personal Information automatically and we may get Personal Information about you from other sources including Activate Care and your Medicaid provider. Information provided by third party sources may include any of the following: eligibility/enrollment information including but not limited to dates of enrollment and demographic information; medical claims data which may include procedures, diagnoses, units, cost and provider information; Prescription Claims data which may include but is not limited to drug names, National Drug Codes, Prescriptions, days supply, cost and pharmacy information.  If you do not want us to collect this Personal Information, please do not provide it and do not permit Activate Care and/or your Medicaid provider share this information with us.

We also may get Personal Information about you from our service providers, customers or relevant project teams.

Information You Provide to Us:

· User information such as name, user name, telephone number, date of birth, log in information, etc. or other similar Personal Information

Information from Interaction with the Path Assist App:

· We collect information related to your interaction and Activate Care’s interaction with the Path Assist App including things such as goals, referrals and events.

Information We Automatically Collect from You When You Use the Path Assist App:

· The information we collect automatically may include Personal Information, or we may maintain it or associate it with Personal Information we collect in other ways or receive from third parties such as Activate Care, your Medicaid provider, our service providers, customers or relevant project teams who provide your Personal Information for us to make the Path Assist App available to you in connection with providing our services.

Information collected through cookies, web beacons, and other tracking technologies:

· We, or service providers on our behalf, may use technologies such as “cookies,” “web beacons,” “tags,” “scripts,” and other tracking technologies to automatically collect Personal Information from you when you use the Path Assist App.  Cookies are small amounts of data that are stored within your Internet browser, which save and recognize your browsing habits. Nomi Health uses both session cookies (which track a user’s progression during one site visit) and persistent cookies (which track a user over time). Web beacons (also called pixel tags or clear GIFs) are web page elements that can help deliver cookies, count visits, track browser type, identify your internet protocol (“IP”) address, understand usage, recognize certain types of information on your computer, in your email or on your mobile device, such as the time and date you viewed a page, which emails are opened, which links are clicked and similar information.

· We use cookies to help provide you with a more personalized experience and to improve service. Users can control the use of cookies at the individual browser level. If you reject cookies, you may still use the Path Assist App, but your ability to use some features of the Path Assist App may be limited.

How We Use the Information We Collect

We may use Personal Information collected from or about you to verify users, respond to your requests or to tailor content, to provide services to you, to provide informational services, prevent improper or illegal activity, or for any other legal, business purposes that are not inconsistent with the terms of this Notice and applicable laws and regulations.  This information may also be used for prioritization of patient outreach, understanding underlying conditions, understanding your healthcare ecosystem, and for developing a baseline that can be re-evaluated after program completion. 

“Do Not Track” Requests

Your Internet browser and mobile device may allow you to adjust your browser settings so that “do not track” (“DNT”) requests are sent to the websites you visit. We do not process DNT signals. Our third-party service providers may also not respond to DNT signals.

How We Share Your Information with Third Parties

Nomi Health may disclose Personal Information in the following circumstances:

· Customers. Nomi Health will share details about a customer account with that customer, including without limitation all orders and deliveries with its customer and information about the details of the individuals receiving gifts from the customer.

· Business Partners and Subcontractors. Nomi Health shares Personal Information with business partners and subcontractors, including without limitation marketers, analytics companies, vendors, service providers, suppliers, transport companies and other businesses that support our services. These third parties assist us in our business.

· Third-Party Analytics Providers. Nomi Health shares Personal Information with third parties that conduct marketing studies and perform data analytics.

Third-Party Websites

We may link to third-party websites. We are not responsible for the data collection, use practices, policies or cookie use of the third-party sites that you access from our website.

Preferences and Opting-Out

You can opt-out of receiving specific types of communications from us and our partners where we request data about you. To opt-out, send us an email at questions@nomihealth.com or click the unsubscribe link on any email we send you. Please note that even though your request is implemented, there may be a delay in the effect. For example, any names currently in the queue for publishing and mailing of catalogs will still receive a catalog weeks after the request due to lead time.

Most Internet browsers allow you to block or delete cookies and other similar technologies from your browser. If you do not agree to the use of these cookies or similar technologies, please disable or delete them by following the instructions in the help section of your browser.

Privacy Notice Changes and How to Contact Us

We reserve the right to modify this Notice at any time. When we make only minor modifications which do not materially change the Notice, we may do so without notifying you. It is your responsibility to keep current the contact information we have on file for you.

How to Contact Us

If you have questions or concerns regarding this Notice, contact us by email at questions@nomihealth.com or write to us at:

Nomi Health
Attn: Privacy
898 N 1200 W, Suite 200
Orem, UT 84057