Effective Date

Effective as of June 1, 2021

Scope of this Privacy Policy

This Privacy Policy is designed to inform users of the Moving Analytics Inc. ("Moving Analytics") websites, mobile application, and services (collectively, the "Service") about how we gather and use Personal Information collected by us in connection with your use of the Service. This Privacy Policy covers how Moving Analytics treats your Personally Identifiable Information ("PII") and Protected Health Information ("PHI") (PII and PHI, collectively hereafter "Personal Information") that Moving Analytics collects, receives, maintains, stores, or transmits, including information you transmit or submit to our Service. Your Personal Information includes information that individually identifies you or is information about you that can be traced back to you or a device that you use to access or use the Service.

“Moving Analytics” or the terms “we” or “us”or similar terms refer to Moving Analytics, Inc. “You” or “your” or similar terms refer to you as a user of our Services.

Agreement to Terms

By using our Service, you consent to our Privacy Policy and Terms of Service and our collection, use, and sharing of your information, and other activities, as described below. If you do not agree to the terms of this Privacy Policy or our Terms of Service, then you should immediately discontinue use of the Service without providing us with any Personal Information.

By accepting our Privacy Policy during registration, or by visiting and/or using our Service, you (a) expressly consent to our collection, use, disclosure, and processing of your PersonalInformation in accordance with this Privacy Policy, and (b) expressly acknowledge that you have read and understood our HIPAA Notice, which describes how we may use and disclose PHI about you for treatment, payment or health care operations and for other purposes that are permitted or required by law, including the Health Insurance Portability and Accountability Act of 1996, as amended from time to time (“HIPAA”). Our HIPAA Notice is available at  www.movinganalytics.com/hipaa-notice. Any conflict between this Privacy Policy and the HIPAA Notice with respect to any PHI be governed by the HIPAA Notice.

Protected Health Information

We are dedicated to maintaining the privacy and integrity of PHI that we receive as part of your application for or participation in our Services. PHI is information about you that we receive aspart of your application for or participation in the Movn Program that may be used to identify you (such as your name, social security number, or address),and that relates to (a) your past, present, or future physical or mental health or condition, (b) the provision of health care to you, or (c) your past, present, or future payment for the provision of health care. This PrivacyPolicy describes how we protect your privacy as a visitor to, or general user of our Service. You may have additional rights under federal and state law with respect to the access to, use, and disclosure of PHI. For a more complete description of your rights with respect to PHI, please refer to our HIPAA Notice, which provides important information to you about how we may use and disclose your PHI.

Information Collection

Moving Analytics collects Personal Information(a) directly from you, such as when you register with Moving Analytics or respond to a survey or questionnaire from us, (b) from your healthcare and/or health plan provider in connection with your eligibility for or use of theService,(c) from fitness wearables and other biometric monitoring devices if you allow those devices to share information with our mobile application, (d) from the device and browser that you use to access the Service, and (e) cookies.Your information will be stored in our cloud hosting provider’s data centers within the United States.

Below is a list of the Personal Information Moving Analytics collects.

1. Identifiers. We may collect your name, email address, account username and password, postal address, phone number, and information about your household.
2. Health information. We may collect information regarding your medical history, mental or physical condition, medical treatment or diagnosis, behaviors related to your health and medical conditions, treatment or diagnosis, and biometric information. This information includes PHI that is protected under the HIPAA Privacy and Security Rules.
3. Insurance information. We may collect information relating to your health insurance, including your health insurance provider, plan name, policy number, and group number.
4. Demographic information. We may collect your age, birthdate, race, ethnicity, gender (including gender identity and gender expression), sex (including pregnancy and childbirth), and marital status.
5. Messages. We provide functionality to send messages through the Service between patients and their healthcare providers. If you use this functionality, we collect the messages you send through the Service.
6. Audio and Visual Information. We may record calls for quality control, training, and documentation purposes. If you upload a photograph to your profile, we collect the photograph.
7. Device Information. We may collect device information when you visit our websites or use our mobile application. Device information may include the device type, browser type, IP address, and geolocation information (limited to the state and country).
8. Internet Activity. We may collect information concerning your interaction with our websites and/or mobile application, including when you access our websites or mobile application, which pages or screens you viewed, and how long you stayed on each page or screen.

You are not required to provide all Personal Information identified in this Privacy Policy to use our Service or to interact with us. If you choose not to provide certain information you may not be able to use some of the features or functions of our Service.

Cookies

This section explains how Moving Analytics uses cookies and similar technologies (like web beacons) when you visit any of our websites. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional or analytical. Cookies on our websites are generally divided into the categories below.

·      Strictly Necessary Cookies. These cookies are required for the operation of our websites. They include, for example, cookies that enable you to log into password-protected portions of our websites.

·      Analytical/Performance Cookies. These cookies allow us to recognize and count the number of users on our websites and understand how such users navigate through our websites (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located). This helps improve how the websites work, for example, by ensuring that users can find what they are looking for easily.

We use Google Analytics for part of this process. For more information about Google Analytics, please visit http://www.google.com/policies/privacy/partners/ and http://www.google.com/analytics/learn/privacy.html. You can opt-out of Google Analytics’ collection and use of data generated by your use of our websites by going to https://tools.google.com/dlpage/gaoptout.

·      Functional Cookies. These cookies improve the functional performance of our websites and make them easier for you to use. For example, cookies are used to remember that you previously visited one of our websites and asked to remain logged into it (e.g., this saves you username).

You can prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help”or “Internet Options.” Each browser that you use will need to be set separately, and different browsers offer different functionality and options in this regard. If you disable or delete certain cookies in your Internet browser settings, you may still access our websites, however, you might not be able to access or use important functions or features of our websites and you may, for example, be required to re-enter your log-in details.

Web beacons (also referred to as clear gifs, pixel tax, and single-pixel gifs) are small electronic files contained on our website pages and electronic messages. Web beacons are used to count visitors to our websites and users on our mobile application, monitor how users navigate our websites and mobile application, count how many emails from us were opened, and count how many links or articles were viewed.

Do-Not-Track Signals

At this time, Moving Analytics does not recognize automated browser signals regarding tracking mechanisms, which may include “do-not-track” instructions.

Information Use

We collect and use Personal Information for the following purposes:

·      Providing the Service to you and providing goods and services requested by, or reasonably anticipated within the context of our relationship with, you;

·      Managing our relationship with you;

·      Communicating with you, including responding your inquiries or requests and requesting feedback;

·      Providing promotional material or other marketing material regarding new features, services, or products that we believe will be of interest to you;

·      Keeping track of your login information; and

·      Analyzing your use of our website and mobile application;

·      Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity or prosecuting those responsible; and

·      Complying with legal and regulatory obligations.

De-Identified Information

In addition to the uses of Personal Information above, we may remove the identifiable parts of your information to created e-identified forms (“De-identified Information”). De-identified Information may be compiled with other data in aggregated forms. We use this aggregated or non-aggregated data in the following ways:

1. Product Improvement. We may use De-identified Information for product improvement, including improving the Service, and sharing this information with health plans or healthcare providers to evaluate their products or services.
2. Research. We may use De-identified Information for research whether scientific, marketing, or business in nature. This research may be made public through publication such as within a scientific journal.

Information Sharing and Disclosure

Moving Analytics only discloses Personal Information(a) at your request (which may require written authorization from you), (b) for treatment and related services, (c) for healthcare operations, (d) for billing purposes, or (e) as otherwise permitted by law. We may share PersonalInformation with the following categories of third parties:

·      Our affiliate, Telehealth Medical Services, PLLC, if you engage or receive treatment from our affiliate.

·      Healthcare Providers and Health Plans. We may share Personal Information with your healthcare provider or health plan in connection with your use of the Service. We also provide functionality to permit you to send messages through theService to your healthcare provider. Please note that if you use such functionality your username and the content of the message will be visible to your healthcare provider.

·      Service Providers. Moving Analytics may hire other companies to perform certain business-related functions. Examples of such functions include hosting providers, and web analytics providers. We only share information with service providers that they need to perform their specific function.

·      Advisors and Financial Institutions. We may share Personal Information with our advisors and financial institutions. This includes auditors, notaries, business continuity support service providers, and legal, tax and risk and compliance advisors.

·      Third parties in connection with a corporate restructuring, sale, transfer or assignment of assets or business merger divestiture, or other changes to the control or financial status of the company.

·      Government bodies, dispute resolution organizations, law enforcement agencies or third parties in connection with (a) responding to a subpoena, search warrantor other lawful request for information we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.

Moving Analytics does not sell Personal Information.

Confidentiality and Security

We have taken reasonable steps to ensure thatPersonal Information collected is secure. We have put in place appropriate physical, electronic, and administrative procedures in an effort to safeguard and help prevent unauthorized access, maintain data security, and correctly use the Personal Information that we collect.

We employ industry standard administrative, physical, and technical measures designed to safeguard and protect information under our control from unauthorized access, use, and disclosure. In addition, when we collect, maintain, access, use, or disclose your Personal Information, we will do so using systems and processes consistent with information privacy and security requirements under applicable federal and state laws, including HIPAA.

Furthermore, your individual user account is protected by a password for your privacy and security. To ensure that there is no unauthorized access to your account and Personal Information, you should not share your password with anyone, and you should limit access to your computer and browser by signing off after you have finished accessing your account.

We exercise care to protect your Personal Information.However, we cannot ensure or warrant the security and confidentiality of any information that you transmit to us or receive from us via the Service, byInternet or wireless connection, including email, or the appropriateness of the measures we use to safeguard such information. Unauthorized entry, access, or use; loss; hardware or software failure; or other factors, may compromise the security of your information at any time. This is especially true for any information that you transmit to us via email or text message, since we have noway of protecting that information until it reaches us. E-mail and text message and the communication lines they travel over do not have the security features that are built into our website and mobile application and may not be secure.In addition, by downloading the mobile application from a digital distribution platform such as the Apple App Store or Google Play (a “Mobile App Provider”),the Mobile App Provider and its agents may be able to identify you as a user of our Service. If you have reason to believe that your data or your interactions with us are no longer secure, please contact us immediately at the email address or telephone number listed at the end of this Privacy Policy.

We typically retain Personal Information for six years from your last contact with us, however, this period may be longer or shorter based on our agreements with health plans and healthcare providers or our need to address tax, corporate, compliance, employment, litigation, and other legal rights and obligations.

Privacy Choices

In some circumstances, healthcare providers may receive marketing communications from us. If you no longer want to receive marketing communications from us, you may unsubscribe at any time by clicking “unsubscribe” in any Moving Analytics’ marketing email. Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account.

Subject to certain exceptions, you may request access, changes, or deletions to your Personal Information and request information about our collection, use and disclosure of such information by contacting us at support@movinganalytics.com. You can help us maintain the accuracy of your information by notifying us of any changes to your Personal Information as soon as possible. In some circumstances we may not be able to honor your request to access, change, or delete your information—for example, when we need to keep your information to protect the security or functionality of our operations, to service your account, to protect the Personal information of a third party, or to comply with legal obligations.

For additional information concerning your rights regarding your PHI, please see the HIPAA Notice.

Third-Party Links

For your convenience, we may link to third-party sites and services, or otherwise display third-party content through the Service to provide increased value to our visitors. We have no control over these linked sites, each of which has separate privacy and data collection policies and practices independent from us. As such, we have no responsibility or liability for these independent policies or actions and are not responsible for the privacy practices or the content of any such websites. Please note that these other sites may send their own cookies to users, collect data, or solicit Personal Information, and we encourage you to review their policies before engaging with these third-party sites.

Privacy with Respect to Children

Moving Analytics does not knowingly collect Personal Information from children under the age of 16, and our Service is not directed at users under the age of 16. If we find that Personal Information has inadvertently been collected for an individual under the age of 16, we will immediately delete it.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time by posting a new version online. If we make any material changes that affect you as determined by Moving Analytics we will notify you by posting the revised Privacy Policy on our websites. Changes will apply to current PersonalInformation as well as new Personal Information after the change occurs.

Termination

Moving Analytics reserves the right to decide, at its sole discretion, to no longer offer you the Service. If Moving Analytics decides to terminate your account, Moving Analytics will either return or permanently destroy any copies it maintains of your Personal Information in accordance with its obligations under applicable law.

Questions and Suggestions

If you have questions about this Privacy Policy or our Terms of Service, please email Moving Analytics at shuoqiao@movinganalytics.com, call (833) 726-0123, or write to us at:

ATTN: Privacy Officer
Moving Analytics Inc.
16969 Von Karman Avenue, STE 220,
Irvine, CA 92606
USA