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Circulate 

Terms of Use & Privacy Policy

Welcome, and thank you for your interest in Circulate Health (“Circulate Health,” “we,” or “us”) and our website at www.circulate.health. This page explains the terms by which you may use our website (the “Site”). By accessing or using the Site, you signify that you have read, understood, and agree to be bound by these Terms of Use (“Agreement”) and to the collection and use of your information as set forth in our Privacy Policy found on this page, below this Agreement. Circulate Health reserves the right to make unilateral modifications to these terms and will provide notice of these changes as described below. This Agreement applies to all visitors and others who access the Site (“Users”).

 

Circulate Health provides administrative and technology services to medical practices that it supports and does not provide any medical or other clinical services itself.  Clinical services are delivered by independent medical practices.

 

Without limiting the applicability hereof, this Arbitration section applies to your relationship with Circulate Health and Circulate PC, as defined in the Patient Consent between you and Circulate PC, and any other agreements between you and Circulate PC. Please read this Agreement carefully to ensure that you understand each provision. This agreement contains a mandatory individual arbitration and class action/jury trial waiver provision that requires the use of arbitration on an individual basis to resolve disputes, rather than jury trials or class actions.

 

Do Not Use in an Emergency. IF YOU HAVE A MEDICAL EMERGENCY, CALL 9-1-1 IMMEDIATELY. NEITHER CIRCULATE HEALTH NOR THE SERVICE ARE DESIGNED FOR OR INTENDED FOR EMERGENCY USE.

 

NO MEDICAL ADVICE. THE INFORMATION CONTAINED ON THE SITE IN THE SERVICE IS NOT MEDICAL ADVICE. YOU ACKNOWLEDGE THAT, THE INFORMATION MADE AVAILABLE THROUGH THE SITE AND THE SERVICES DO NOT CREATE A MEDICAL PROFESSIONAL OR PATIENT RELATIONSHIP BETWEEN CIRCULATE HEALTH AND YOU, AND SUCH INFORMATION DOES NOT CONSTITUTE ANY PROFESSIONAL OPINION, MEDICAL ADVICE, DIAGNOSIS OR TREATMENT BY CIRCULATE HEALTH. NONE OF THE SERVICES OR INFORMATION PROVIDED THROUGH THE SITE BY CIRCULATE HEALTH ARE INTENDED AS A SUBSTITUTE FOR, NOR DOES IT REPLACE, ANY PROFESSIONAL ADVICE, DIAGNOSIS, OR TREATMENT.

 

Use of Our Site

 

Eligibility

 

This is a contract between you and Circulate Health. You must read and agree to these terms before using the Site. If you do not agree, you may not use the Site. You may use the Site only if you can form a binding contract with Circulate Health, and only in compliance with this Agreement and all applicable local, state, national, and international laws, rules and regulations. Any use or access to the Site by anyone under 13 is strictly prohibited and in violation of this Agreement. The Site is not available to any Users previously removed from the Site by Circulate Health.

 

Access to the Site

 

You can use the Service to find out information about our products and services and, in some cases, at your discretion, receive information about our providers for the services we offer.

Subject to the terms and conditions of this Agreement, you are hereby granted a non-exclusive, limited, non-transferable, freely revocable license to use the Site for your personal, noncommercial use only and as permitted by the features of the Site. Circulate Health reserves all rights not expressly granted herein in the Site and the Circulate Health Content (as defined below). Circulate Health may terminate this license at any time for any reason or no reason.

 

Site Rules

 

You agree not to engage in any of the following prohibited activities: (i) copying, distributing, or disclosing any part of the Site in any medium, including without limitation by any automated or non-automated “scraping”; (ii) using any automated system, including without limitation “robots,” “spiders,” “offline readers,” etc., to access the Site in a manner that sends more request messages to the Circulate Health servers than a human can reasonably produce in the same period of time by using a conventional on-line web browser (except that Circulate Health grants the operators of public search engines revocable permission to use spiders to copy publicly available materials from Circulate Health.com for the sole purpose of and solely to the extent necessary for creating publicly available searchable indices of the materials, but not caches or archives of such materials); (iii) transmitting spam, chain letters, or other unsolicited email; (iv) attempting to interfere with, compromise the system integrity or security or decipher any transmissions to or from the servers running the Site; (v) taking any action that imposes, or may impose at our sole discretion an unreasonable or disproportionately large load on our infrastructure; (vi) uploading invalid data, viruses, worms, or other software agents through the Site; (vii) collecting or harvesting any personally identifiable information, including account names, from the Site; (viii) using the Site for any commercial solicitation purposes; (ix) impersonating another person or otherwise misrepresenting your affiliation with a person or entity, conducting fraud, hiding or attempting to hide your identity; (x) interfering with the proper working of the Site; (xi) accessing any content on the Site through any technology or means other than those provided or authorized by the Site; or (xii) bypassing the measures we may use to prevent or restrict access to the Site, including without limitation features that prevent or restrict use or copying of any content or enforce limitations on use of the Site or the content therein.

 

Accessing any audiovisual content that may be available on the Site for any purpose or in any manner other than Streaming (as defined below) is expressly prohibited unless explicitly permitted by the functionality of the Site. “Streaming” means a contemporaneous digital transmission of an audiovisual work via the Internet from the Site to a User’s device in such a manner that the data is intended for real-time viewing and not intended to be copied, stored, permanently downloaded, or redistributed by the User.

We may, without prior notice, change the Site; stop providing the Site or features of the Site, to you or to Users generally; or create usage limits for the Site. We may permanently or temporarily terminate or suspend your access to the Site without notice and liability for any reason, including if in our sole determination you violate any provision of this Agreement, or for no reason. Upon termination for any reason or no reason, you continue to be bound by this Agreement.

 

Our Proprietary Rights

 

The Site and all materials therein or transferred thereby, including, without limitation, software, images, text, graphics, illustrations, logos, patents, trademarks, service marks, copyrights, photographs, audio, videos, and music (the “Circulate Health Content”), and all intellectual property rights related thereto, are the exclusive property of Circulate Health and its licensors. Except as explicitly provided herein, nothing in this Agreement shall be deemed to create a license in or under any such intellectual property rights, and you agree not to sell, license, rent, modify, distribute, copy, reproduce, transmit, publicly display, publicly perform, publish, adapt, edit or create derivative works from any Circulate Health Content. Use of the Circulate Health Content for any purpose not expressly permitted by this Agreement is strictly prohibited.

 

You may choose to or we may invite you to submit comments or ideas about the Site, including without limitation about how to improve the Site or our products (“Ideas”). By submitting any Idea, you agree that your disclosure is gratuitous, unsolicited and without restriction and will not place Circulate Health under any fiduciary or other obligation, and that we are free to use the Idea without any additional compensation to you, and/or to disclose the Idea on a non-confidential basis or otherwise to anyone. You further acknowledge that, by acceptance of your submission, Circulate Health does not waive any rights to use similar or related ideas previously known to Circulate Health, or developed by its employees, or obtained from sources other than you.

 

Privacy

 

We care about the privacy of our Users. You understand that by using the Sites you consent to the collection, use and disclosure of your personally identifiable information and aggregate data as set forth in our Privacy Policy at [URL], and to have your personally identifiable information collected, used, transferred to and processed in the United States.

 

Security

 

Circulate Health cares about the integrity and security of your personal information. However, we cannot guarantee that unauthorized third parties will never be able to defeat our security measures or use your personal information for improper purposes. You acknowledge that you provide your personal information at your own risk.

 

Third-Party Links and Information

 

The Site may contain links to third-party materials that are not owned or controlled by Circulate Health. Circulate Health does not endorse or assume any responsibility for any such third-party sites, information, materials, products, or services. If you access a third-party website or service from the Site on or through any third-party website or service, you do so at your own risk, and you understand that this Agreement and Circulate Health’s Privacy Policy do not apply to your use of such sites. You expressly relieve Circulate Health from any and all liability arising from your use of any third-party website, service, or content. Additionally, your dealings with or participation in promotions of advertisers found on the Site, including payment and delivery of goods, and any other terms (such as warranties) are solely between you and such advertisers. You agree that Circulate Health shall not be responsible for any loss or damage of any sort relating to your dealings with such advertisers.

 

Indemnity

 

You agree to defend, indemnify and hold harmless Circulate Health and its subsidiaries, agents, licensors, managers, and other affiliated companies, and their employees, contractors, agents, officers and directors, from and against any and all claims, damages, obligations, losses, liabilities, costs or debt, and expenses (including but not limited to attorney’s fees) arising from: (i) your use of and access to the Site, including any data or content transmitted or received by you; (ii) your violation of any term of this Agreement, including without limitation your breach of any of the representations and warranties above; (iii) your violation of any third-party right, including without limitation any right of privacy or intellectual property rights; (iv) your violation of any applicable law, rule or regulation; or (v) your willful misconduct.

 

No Warranty

 

The Site is provided on an “as is” and “as available” basis. Use of the Site is at your own risk. To the maximum extent permitted by applicable law, the Site is provided without warranties of any kind, whether express or implied, including, but not limited to, implied warranties of merchantability, fitness for a particular purpose, or non-infringement. No advice or information, whether oral or written, obtained by you from Circulate Health or through the Site will create any warranty not expressly stated herein. Without limiting the foregoing, Circulate Health, its subsidiaries, its affiliates, and its licensors do not warrant that the content is accurate, reliable or correct; that the Site will meet your requirements; that the Site will be available at any particular time or location, uninterrupted or secure; that any defects or errors will be corrected; or that the Site is free of viruses or other harmful components. Any content downloaded or otherwise obtained through the use of the Site is downloaded at your own risk and you will be solely responsible for any damage to your computer system or loss of data that results from such download or your use of the Site.

 

Circulate Health does not warrant, endorse, guarantee, or assume responsibility for any product or site advertised or offered by a third party through the Site or any hyperlinked website or site, and Circulate Health will not be a party to or in any way monitor any transaction between you and third-party providers of products or services.

 

Federal law, some states, provinces and other jurisdictions do not allow the exclusion and limitations of certain implied warranties, so the above exclusions may not apply to you. This agreement gives you specific legal rights, and you may also have other rights which vary from state to state. The disclaimers and exclusions under this agreement will not apply to the extent prohibited by applicable law.

 

Limitation of Liability

 

To the maximum extent permitted by applicable law, in no event shall Circulate Health, its affiliates, agents, directors, employees, suppliers or licensors be liable for any indirect, punitive, incidental, special, consequential or exemplary damages, including without limitation damages for loss of profits, goodwill, use, data or other intangible losses, arising out of or relating to the use of, or inability to use, this Site. Under no circumstances will Circulate Health be responsible for any damage, loss or injury resulting from hacking, tampering or other unauthorized access or use of the Site or your account or the information contained therein.

 

To the maximum extent permitted by applicable law, Circulate Health assumes no liability or responsibility for any (i) errors, mistakes, or inaccuracies of content; (ii) personal injury or property damage, of any nature whatsoever, resulting from your access to or use of our site; (iii) any unauthorized access to or use of our secure servers and/or any and all personal information stored therein; (iv) any interruption or cessation of transmission to or from the Site; (v) any bugs, viruses, trojan horses, or the like that may be transmitted to or through our site by any third party; (vi) any errors or omissions in any content or for any loss or damage incurred as a result of the use of any content posted, emailed, transmitted, or otherwise made available through the Site; and/or (vii) the defamatory, offensive, or illegal conduct of any third party. In no event shall Circulate Health, its affiliates, agents, directors, employees, suppliers, or licensors be liable to you for any claims, proceedings, liabilities, obligations, damages, losses or costs in an amount exceeding the amount you paid to Circulate Health hereunder or $100.00, whichever is greater.

 

This limitation of liability section applies whether the alleged liability is based on contract, tort, negligence, strict liability, or any other basis, even if Circulate Health has been advised of the possibility of such damage. The foregoing limitation of liability shall apply to the fullest extent permitted by law in the applicable jurisdiction.

 

Some states do not allow the exclusion or limitation of incidental or consequential damages, so the above limitations or exclusions may not apply to you. This agreement gives you specific legal rights, and you may also have other rights which vary from state to state. The disclaimers, exclusions, and limitations of liability under this agreement will not apply to the extent prohibited by applicable law.

 

The Site is controlled and operated from facilities in the United States. Circulate Health makes no representations that the Site is appropriate or available for use in other locations. Those who access or use the Site from other jurisdictions do so at their own volition and are entirely responsible for compliance with all applicable United States and local laws and regulations, including but not limited to export and import regulations. You may not use the Site if you are a resident of a country embargoed by the United States, or are a foreign person or entity blocked or denied by the United States government. Unless otherwise explicitly stated, all materials found on the Site are solely directed to individuals, companies, or other entities located in the United States.

 

Governing Law, Arbitration, and Class Action/Jury Trial Waiver

Governing Law. You agree that: (i) the Site shall be deemed solely based in New York; and (ii) the Site shall be deemed a passive one that does not give rise to personal jurisdiction over us, either specific or general, in jurisdictions other than New York. This Agreement shall be governed by the internal substantive laws of the State of New York, without respect to its conflict of laws principles. The parties acknowledge that this Agreement evidences a transaction involving interstate commerce. Notwithstanding the preceding sentences with respect to the substantive law, any arbitration conducted pursuant to the terms of this Agreement shall be governed by the Federal Arbitration Act (9 U.S.C. §§ 1-16). The application of the United Nations Convention on Contracts for the International Sale of Goods is expressly excluded. You agree to submit to the personal jurisdiction of the federal and state courts located in New York, New York for any actions for which we retain the right to seek injunctive or other equitable relief in a court of competent jurisdiction to prevent the actual or threatened infringement, misappropriation or violation of a our copyrights, trademarks, trade secrets, patents, or other intellectual property or proprietary rights, as set forth in the Arbitration provision below, including any provisional relief required to prevent irreparable harm. You agree that New York, New York is the proper forum for any appeals of an arbitration award or for trial court proceedings in the event that the arbitration provision below is found to be unenforceable.

 

Arbitration. Read this section carefully because it requires the parties to arbitrate their disputes and limits the manner in which you can seek relief from Circulate Health. For any dispute with Circulate Health, you agree to first contact us at info@circulate.health and attempt to resolve the dispute with us informally. In the unlikely event that Circulate Health has not been able to resolve a dispute it has with you after sixty (60) days, we each agree to resolve any claim, dispute, or controversy (excluding any claims for injunctive or other equitable relief as provided below) arising out of or in connection with or relating to this Agreement, or the breach or alleged breach thereof (collectively, “Claims”), by binding arbitration by JAMS, under the Optional Expedited Arbitration Procedures then in effect for JAMS, except as provided herein. JAMS may be contacted at www.jamsadr.com. The arbitration will be conducted in New York, New York, unless you and Circulate Health agree otherwise. If you are using the Site for commercial purposes, each party will be responsible for paying any JAMS filing, administrative and arbitrator fees in accordance with JAMS rules, and the award rendered by the arbitrator shall include costs of arbitration, reasonable attorneys’ fees and reasonable costs for expert and other witnesses. If you are an individual using the Site for non-commercial purposes: (i) JAMS may require you to pay a fee for the initiation of your case, unless you apply for and successfully obtain a fee waiver from JAMS; (ii) the award rendered by the arbitrator may include your costs of arbitration, your reasonable attorney’s fees, and your reasonable costs for expert and other witnesses; and (iii) you may sue in a small claims court of competent jurisdiction without first engaging in arbitration, but this does not absolve you of your commitment to engage in the informal dispute resolution process. Any judgment on the award rendered by the arbitrator may be entered in any court of competent jurisdiction. Nothing in this Section shall be deemed as preventing Circulate Health from seeking injunctive or other equitable relief from the courts as necessary to prevent the actual or threatened infringement, misappropriation, or violation of our data security, intellectual property rights or other proprietary rights.

 

Class Action/Jury Trial Waiver. With respect to all persons and entities, regardless of whether they have obtained or used the site for personal, commercial or other purposes, all Claims must be brought in the parties’ individual capacity, and not as a plaintiff or class member in any purported class action, collective action, private attorney general action or other representative proceeding. This waiver applies to class arbitration, and, unless we agree otherwise, the arbitrator may not consolidate more than one person’s claims. You agree that, by entering into this agreement, you and Circulate Health are each waiving the right to a trial by jury or to participate in a class action, collective action, private attorney general action, or other representative proceeding of any kind. 

 

General

 

Assignment. This Agreement, and any rights and licenses granted hereunder, may not be transferred or assigned by you, but may be assigned by Circulate Health without restriction. Any attempted transfer or assignment in violation hereof shall be null and void.

 

Notification Procedures and Changes to the Agreement. Circulate Health may provide notifications, whether such notifications are required by law or are for marketing or other business related purposes, to you via email notice, written or hard copy notice, or through posting of such notice on our website, as determined by Circulate Health in our sole discretion. Circulate Health reserves the right to determine the form and means of providing notifications to our Users, provided that you may opt out of certain means of notification as described in this Agreement. Circulate Health is not responsible for any automatic filtering you or your network provider may apply to email notifications we send to the email address you provide us. Circulate Health may, in its sole discretion, modify or update this Agreement from time to time, and so you should review this page periodically. When we change the Agreement in a material manner, we will update the ‘last modified’ date at the top of this page and notify you that material changes have been made to the Agreement. Your continued use of the Site after any such change constitutes your acceptance of the new Terms of Use. If you do not agree to any of these terms or any future Terms of Use, do not use or access (or continue to access) the Site.

 

Entire Agreement/Severability. This Agreement, together with any amendments and any additional agreements you may enter into with Circulate Health in connection with the Site, shall constitute the entire agreement between you and Circulate Health concerning the Site. If any provision of this Agreement is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Agreement, which shall remain in full force and effect.

 

No Waiver. No waiver of any term of this Agreement shall be deemed a further or continuing waiver of such term or any other term, and Circulate Health’s failure to assert any right or provision under this Agreement shall not constitute a waiver of such right or provision.

 

California Residents. If you are a California resident, in accordance with Cal. Civ. Code §1789.3, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Sites of the California Department of Consumer Affairs by contacting them in writing at 1625 North Market Blvd., Suite N 112 Sacramento, CA 95834, or by telephone at (800) 952-5210 or (916) 445-1254.

 

 

 

 

CIRCULATE HEALTH PRIVACY NOTICE

 

Last Updated: [1/28/2025]

 

Welcome to Circulate Health. This Privacy Notice explains how Circulate Health, Inc. (“Circulate Health”, “we”, “us”, or “our”) collects, uses, discloses, and otherwise processes personal data in connection with Circulate Health, as well as any other specific product, service, or application that references or links to this Privacy Notice (the “Services”). 

 

This Privacy Notice does not address our privacy practices relating to Circulate Health job applicants, employees and other personnel, nor data that is not subject to applicable data protection laws (such as deidentified or publicly available information). This Privacy Notice is also not a contract and does not create any legal rights or obligations not otherwise provided by law. 

 

Our Collection and Use of Personal Data

 

The categories of personal data we collect depend on how you interact with us and our Services. For example, you may provide us your personal data directly when you request information from us or submit an online form. 

We also collect personal data automatically when you interact with our websites and other services and may also collect personal data from other sources and third parties. 

 

Personal Data Provided by Individuals

 

We collect the following categories of personal data individuals provide us: 

  • Contact Information, including first and last name, email address, and communication preferences. We use this information primarily to fulfill your request or transaction, and to communicate with you directly and to send you marketing communications in accordance with your preferences.

  • Account Information, including first and last name, email address, account credentials or one-time passcodes, and the products or services you are interested in, purchased, or have otherwise used. We use this information primarily to administer your account, provide you with our Services, communicate with you regarding your account and your use of our Services, and for user support purposes.

  • User Content, including any apps, containers, files, documents, audio, videos, images, data, or communications you choose to upload to our Services. We use this content primarily to provide you with our Services, to facilitate your requests, and to improve our Services. 

  • Feedback and Support Information, including the contents of custom messages sent through the forms, chat platforms, email addresses, or other contact information we make available to users (including through the use of automated tools provided by us or our third-party providers). We use this information primarily to investigate and respond to your inquiries, to communicate with you via online chat, email, phone or social media, and to improve our Services.

 

If you choose to contact us, we may need additional information to fulfill the request or respond to your inquiry. We may provide additional privacy disclosures where the scope of the request we receive or personal data we require fall outside the scope of this Privacy Notice. In that case, the additional privacy disclosures will govern how we may process the information you provide at that time. 

 

Personal Data Automatically Collected

We, and our third-party partners, automatically collect information you provide to us and information about how you access and use our Services when you engage with us. We typically collect this information through the use of a variety of our own and our third-party partners’ automatic data collection technologies, including (i) cookies or small data files that are stored on an individual’s computer and (ii) other, related technologies, such as web beacons, pixels, and embedded scripts. Information we collect automatically about you may be combined with other personal data we collect directly from you or receive from other sources. 

 

We, and our third-party partners, use automatic data collection technologies to automatically collect the following data when you use our Services or otherwise engage with us: 

  • Information About Your Device and Network, including the device type, manufacturer, and model, operating system, IP address, browser type, Internet service provider, and unique identifiers associated with you, your device, or your network (including, for example, a persistent device identifier or advertising ID). [We may employ third-party technologies designed to allow us to recognize when two or more devices are likely being used by the same individual and may leverage these technologies (where permitted) to link information collected from different devices.]

  • Information About the Way Individuals Use Our Services and Interact With Us, including how frequently you access our Services, whether you open emails or click the links contained in emails, whether you access our Services from multiple devices, and other browsing behavior and actions you take on our Services (such as the pages you visit, the content you view, videos you watch, the communications you have through our Services, and the content and links you interact with). 

 

All of the information collected automatically through these tools allows us to improve your user experience. For example, we may use this information to enhance and personalize your user experience, to monitor and improve our Services, to offer communications features, and to improve the effectiveness of our Services, offers, communications and user service.  We may also use this information to:  (a) remember information so that you will not have to re-enter it during your visit or the next time you visit the site; (b) provide custom, personalized content and information; (c) identify you across multiple devices; (d) provide and monitor the effectiveness of our Services; (e) monitor aggregate metrics such as total number of visitors, traffic, usage, and demographic patterns on our website; (f) diagnose or fix technology problems; and (g) otherwise to plan for and enhance our Services.

 

For information about the choices you may have in relation to our use of automatic data collection technologies, please refer to the Your Privacy Choices section below.

Personal Data from Other Sources and Third Parties

 

We may receive the same categories of personal data as described above from the following sources and other parties: 

  • Other Users: We may receive your personal data from our other users. For example, a user may provide us with your contact information as a part of a referral. 

  • Social Media: When you interact with our Services through other social media networks (such as Instagram), such as when you follow us or share our content on other social networks, we may receive some information that you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network, and may include profile information, profile picture, username, and any other information you permit the social network to share with third parties. You should always review and, if necessary, adjust your privacy settings on third-party websites and social media networks and services before sharing information and/or linking or connecting them to other services. We use this information primarily to operate, maintain, and provide to you the features and functionality of our Services, as well as to communicate directly with you, such as to send you messages about features that may be of interest to you.

  • Service Providers: Our service providers that perform services on our behalf, such as analytics providers, collect personal data and often share some or all of this information with us. 

  • Inferences: We may generate inferences or predictions about you and your interests and preferences based on the other personal data we collect and the interactions we have with you.

 

Additional Uses of Personal Data

 

In addition to the primary purposes for using personal data described above, we may also use personal data we collect to:

  • Fulfill or meet the reason the information was provided, such as to fulfill our contractual obligations or to deliver the services requested;

  • Manage our organization and its day-to-day operations; 

  • Communicate with you, including via email, chat, social media and/or telephone calls;

  • Facilitate the relationship we have with you and, where applicable, the company you represent; 

  • Request you provide us feedback about our product and service offerings; 

  • Address inquiries or complaints made by or about an individual in connection with our Services; 

  • Create and maintain accounts for our users;

  • Verify your identity;

  • Administer, improve, and personalize our Services, including by recognizing you and remembering your information when you return to our Services;

  • Develop, operate, improve, maintain, protect, and provide the features and functionality of our Services; 

  • Identify and analyze how you use our Services;

  • Infer additional information about you from your use of our Services, such as your interests;

  • Create aggregated or de-identified information that cannot reasonably be used to identify you, which information we may use for purposes outside the scope of this Privacy Notice; 

  • Conduct research and analytics on our user base and our Services, including to better understand the demographics of our users;  

  • Improve and customize our Services to address the needs and interests of our user base and other individuals we interact with;

  • Test, enhance, update, and monitor the Services, or diagnose or fix technology problems; 

  • Help maintain and enhance the safety, security, and integrity of our property, products, services, technology, assets, and business;

  • Defend, protect, or enforce our rights or applicable contracts and agreements (including our Terms of Service), as well as to resolve disputes, to carry out our obligations and enforce our rights, and to protect our business interests and the interests and rights of third parties;

  • Detect, prevent, investigate, or provide notice of security incidents or other malicious, deceptive, fraudulent, or illegal activity and protect the rights and property of Circulate Health and others; 

  • Facilitate business transactions and reorganizations impacting the structure of our business; 

  • Comply with contractual and legal obligations and requirements;

  • Fulfill any other purpose for which you provide your personal data, or for which you have otherwise consented.

 

Our Disclosure of Personal Data

 

We disclose or otherwise make available personal data in the following ways: 

  • To Other Users and the General Public: We make available personal data designed for sharing through our Services with certain or all other Circulate Health users, or the general public, based on the applicable privacy settings and intended recipients. 

  • To Service Providers: We engage other third parties to perform certain services on our behalf in connection with the uses of personal data described in the sections above. Depending on the applicable services, these service providers may process personal data on our behalf or have access to personal data while performing services on our behalf.

  • In Connection with a Business Transaction or Reorganization: We may take part in or be involved with a business transaction or reorganization, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose, transfer, or assign personal data to a third party during negotiation of, in connection with, or as an asset in such a business transaction or reorganization. Also, in the unlikely event of our bankruptcy, receivership, or insolvency, your personal data may be disclosed, transferred, or assigned to third parties in connection with the proceedings or disposition of our assets.

  • To Facilitate Legal Obligations and Rights: We may disclose personal data to third parties, such as legal advisors and law enforcement: 

    • in connection with the establishment, exercise, or defense of legal claims; 

    • to comply with laws or to respond to lawful requests and legal process; 

    • to protect our rights and property and the rights and property of our agents, customers, users, and others, including to enforce our agreements, policies, and terms of use;

    • to detect, suppress, or prevent fraud; 

    • to reduce credit risk and collect debts owed to us; 

    • to protect the health and safety of us, our users, or any person; or 

    • as otherwise required by applicable law.

  • With Your Consent or Direction: We may disclose your personal data to certain other third parties or publicly with your consent or direction. For example, with your permission, we may post your testimonial on our websites. 

 

Your Privacy Choices

 

The following privacy choices are made available to all individuals with whom we interact. 

 

Email Communication Preferences

You can stop receiving promotional email communications from us by clicking on the “unsubscribe” link provided in any of our email communications. Please note you cannot opt-out of service-related email communications (such as, account verification, transaction confirmation, or service update emails). 

 

Automatic Data Collection Preferences

 

Certain of our Services may provide you the ability to adjust your preferences regarding our use of automatic data collection technologies. [For example, there is a “Cookie Preferences” manager linked in the footer of our websites that allows you to adjust your preferences regarding certain automatic data collection technologies on the specific website you are visiting for the specific device and browser you are using at that time (which means you will need to change your preferences on each device and browser you use to interact with the specific website you are visiting).]

 

Where a Circulate Health-specific preference manager or privacy setting is not available, you may be able to utilize third-party tools and features to further restrict our use of automatic data collection technologies. For example, (i) most browsers allow you to change browser settings to limit automatic data collection technologies on websites, (ii) most email providers allow you to prevent the automatic downloading of images in emails that may contain automatic data collection technologies, and (iii) many devices allow you to change your device settings to limit automatic data collection technologies for device applications. Please note that blocking automatic data collection technologies through third-party tools and features may negatively impact your experience using our Services, as some features and offerings may not work properly or at all. Depending on the third-party tool or feature you use, you may not be able to block all automatic data collection technologies or you may need to update your preferences on multiple devices or browsers. We do not have any control over these third-party tools and features and are not responsible if they do not function as intended.  

 

Partner-Specific Preferences

Certain of our third-party providers and partners offer additional ways that you may exercise control over your personal data, or automatically impose limitations on the way we can use personal data in connection with the services they provide: 

  • Device-Specific / Platform-Specific Preferences: The device and/or platform you use to interact with us (such as your mobile device or browser), may provide you additional choices with regard to the data you choose to share with us. For example, many mobile devices allow you to change your device permissions to prevent our products and services from accessing certain types of information from your device (such as your contact lists), and many social media platforms allow you to change your platform permissions to prevent integrated products and services from accessing certain types of information connected with your profile. Please refer to your device or platform provider’s user guides for additional information about implementing any available platform-specific targeted advertising opt-outs. 

  • Google Analytics: Google Analytics allows us to better understand how our users interact with our Services.  For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's website here: www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Add-On here: https://tools.google.com/dlpage/gaoptout/. We may also utilize certain forms of display advertising and other advanced features through Google Analytics. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the DoubleClick advertising cookie) or other third-party cookies together to inform, optimize, and display ads based on your past visits to our Services.  You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://myadcenter.google.com/personalizationoff?sasb=true&ref=ad-settings. 

 

Children’s Personal Data

Our Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal data from children under the age of 13. If an individual is under the age of 13, they should not use our Services or otherwise provide us with any personal data either directly or by other means. If a child under the age of 13 has provided personal data to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal data from our systems. If we learn that any personal data we collect has been provided by a child under the age of 13, we will promptly delete that personal data.

 

Third-Party Websites and Services

Our Services may include links to third-party websites, plug-ins, applications and other services. Except where we post, link to or expressly adopt or refer to this Privacy Notice, this Privacy Notice does not apply to any personal data practices of third parties. To learn about the personal data practices of third parties, please visit their respective privacy notices. 

 

Updates to This Privacy Notice

We may update this Privacy Notice from time to time. When we make changes to this Privacy Notice, we will change the date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify individuals by email to their registered email address, by prominent posting on this website or our other platforms, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.

 

Contact Us

If you have any questions or requests in connection with this Privacy Notice or other privacy-related matters, please send an email to info@circulate.health.

 

Nevada Residents

If you are a resident of the state of Nevada in the United States, you have the right to opt out of the sale of your personal data. Although we do not currently sell personal data of Nevada residents (as defined under Nevada law), you may submit a request to opt-out of the sale of your personal data by emailing to info@circulate.health.

 

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