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OPOS, Inc.

This OPOS, Inc. Privacy Policy (“Policy”) describes the practices OPOS, Inc. (“OPOS,” “Company,” “we,” or “us”) observes when collecting, using, and sharing data and other information (“Information”) we collect through our mobile applications and any other websites operated by OPOS (each, a “Site”) and through the services we provide through each Site (each Site and those services, our “Platform”). This Policy is incorporated herein by reference to OPOS, Inc.’s (“OPOS”) End User License Agreement, which together with said document and Exhibit A thereto (Terms and Conditions), comprise the entire agreement among the parties hereto (collectively, the “EUL Agreement”). By accessing or using any part of our Platform, you consent to the collection, use and sharing of your Information by the Company as described in this Policy.

 

If you have any questions or concerns regarding this Policy or our Information collection or usage practices, please contact us at info@telepain.md and/or https://opos.solutions.

If we need, or are required, to contact you concerning any event that involves this Policy or your Information we may do so using the email address, telephone number, or physical mail address we have on file for you. The parties understand and agree that OPOS has the right to amend, update and/or modify this Policy in accordance with the terms of the EUL Agreement.

Summary.

Although we encourage you to read the entire Policy, the following provides a summary of some of the important aspects of this Policy:

  • This Policy is applicable to Information we collect through our Platform.

  • We may collect both Non-Personal Information and Personal Information through our Platform.

  • We may also collect Sensitive Personal Information through the Platform.

  • We will not use or share Your Personal Information (including Sensitive Information) except as permitted by this Policy.

  • You are permitted to “opt out” of certain uses of your Personal Information.

  • We will take reasonable and appropriate measures to secure your Personal Information, but we make no promise that your Personal Information will remain secure in all circumstances.

  • Your data will never be provided to 3rd parties, other than your doctor.

 

Scope of this Policy.

While the Platform enables you to interact and communicate with third parties and to access and use services offered by those third parties, this Policy covers ONLY Information we collect through our Platform. THIS POLICY DOES NOT COVER THE COLLECTION, USE, OR SHARING OF ANY INFORMATION BY THIRD PARTIES WITH WHICH YOU MAY INTERACT OR COMMUNICATE IN CONNECTION WITH YOUR USE OF THE PLATFORM. For information about what policies may apply to the Information you may share with any third party, please contact the third party before sharing Your Information.

Information We Collect.

The Information we collect through the Platform may include both “non-personal” and “personal” Information. We may also obtain “sensitive” personal information about you or from you through the Platform. For purposes of this Policy:

“Non-Personal Information” refers to information that may not by itself be reasonably associated with, linked to, or used to individually identify you. For example, general, non-specific Information regarding your use of the Platform or derived from the Information that you provide to us through the Platform.

“Personal Information” refers to information that may be reasonably associated with, linked to, or used to individually identify an individual, a group of individuals, or your; or allow an individual, a group of individuals, or you to be personally identified or contacted. For example, Personal Information may include information such as your name, email address, telephone number, address, or credit card number, either alone or in combination with other information.

“Sensitive Personal Information” refers to Personal Information regarding more sensitive areas such as financial information, such as bank account or credit card numbers, medical or health conditions, precise geolocation information, or other sensitive topics.

Sources of Information.

We may collect Information through the Platform from a variety of sources, for example:

Directly from You. We may collect Information about you or from you directly from you when you provide Information to us through the Platform. For example, by visiting and using the Site, registering for the Platform, providing Information through the Platform, or otherwise communicating through the Platform. We may use any Information you provide to us through the Platform in accordance with this Policy.

From Third Parties. We may also obtain Information about you from third parties who have a right to provide us with that Information. For example, we may obtain Information about you from third parties that have the right to provide that Information to us. We may use any Information about you we receive from a third party in accordance with the terms we establish with that third party. Only if we combine that Information with Information we collect under this Policy will we be required to use that Information in accordance with this Policy.

Through the Operation of the Platform. We may collect Information about you or from you automatically when you interact with the Platform. For example, the Company and service providers may use “cookies,” “web beacons,” and other automated tracking technology to monitor and collect Information regarding how you access, use, and interact with the Platform. “Cookies” are commonly used small files that are stored on your computer or mobile device to help identify you as a unique user of the Platform. “Web beacons” (also known as “single–pixel” or “clear” GIFs) include electronic images imbedded in the Platform that allow us to recognize when you visit that area of the Platform.

The Company may use cookies, web beacons, and other tracking technology that expire once you close your browser or log out of the Platform. We may also use technologies that persist and stay on your mobile device or computer until you delete them. Most browsers will allow you to erase cookies from your computer or mobile device, block acceptance of cookies, or receive a warning before a cookie is stored. You may also be able to refuse certain web beacons by adjusting the settings on your browser or email software. Please refer to your browser or email software instructions or help screen to learn more about these functions.

The computers we use to provide the Platform may also automatically record Information about you or from you. For example, our web servers may record the Information you enter on the Platform, the areas of the Platform you visit, the services you use through the Platform, your IP address, or cookies that are set on your browser. We may use any Information we collect from you automatically through the Platform in accordance with this Policy.

How We Use Information.

Protected Health Information

While using our service we will collect information related to your chronic condition(s) or illnesses that are provided directly by you or provided to OPOS by your doctor, insurance company or other third party that you have expressly provided consent for us to receive the data. Protected health information may include, but is not limited to:

●    Names

●    All geographical identifiers smaller than a state, except for the initial three digits of a zip code if, according to the current publicly available data from the U.S. Bureau of the Census: the geographic unit formed by combining all zip codes with the same three initial digits contains more than 20,000 people; and the initial three digits of a zip code for all such geographic units containing 20,000 or fewer people is changed to 000

●    Dates (other than year) directly related to an individual

●    Phone Numbers

●    Fax numbers

●    Email addresses

●    Social Security numbers

●    Medical record numbers

●    Health insurance beneficiary numbers

●    Account numbers

●    ICD 9 and ICD 10 Diagnostic Codes

●    CPT Procedure Codes

●    Medications

●    Vitals and Lab tests

●    Sleep recording data

●    Medical Allergies

●    Activity Data including run, walk, step, rolling distance and other exercise data

●    Certificate/license numbers

●    Vehicle identifiers and serial numbers, including license plate numbers;

●    Device identifiers and serial numbers;

●    Web Uniform Resource Locators (URLs)

●    Internet Protocol (IP) address numbers

●    Biometric identifiers, including finger, retinal and voice prints

●    Full face photographic images and any comparable images

●    Any other unique identifying number, characteristic, or code except the unique code assigned by the investigator to code the data

Usage Data: When you access the Service with a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data ("Usage Data").

Location Data: We may use and store information about your location if you give us permission to do so ("Location Data"). We use this data to provide features of our Service, to improve and customize our Service.

You can enable or disable location services when you use our Service at any time by way of your device settings.

Tracking Cookies Data: We use cookies and similar tracking technologies to track the activity on our Service and we hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Other tracking technologies are also used such as beacons, tags and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service. Examples of Cookies we use:

●    Session Cookies. We use Session Cookies to operate our Service.

●    Preference Cookies. We use Preference Cookies to remember your preferences and various settings.

●    Security Cookies. We use Security Cookies for security purposes.

Use of Data

OPOS, Inc. and OPOS.AI use the collected data for various purposes:

●    To provide and maintain our Service

●    To notify you about changes to our Service

●    To allow you to participate in interactive features of our Service when you choose to do so

●    To provide customer support

●    To gather analysis or valuable information so that we can improve our Service

●    To monitor the usage of our Service

●    To detect, prevent and address technical issues

●    To monitor your health with respect to your chronic condition under the care of your physician or care provider 

●    To establish your functional goals

●    To monitor your progress towards your functional goals

●    To identify circumstances that may have a negative impact on your health so they may be communicated to your physician or care provider 

●    To notify your care physician or provider that you may need medical assistance

●    To determine the type of medical educational material you should receive

●    To provide you with general information about other goods, services and events which we are similar to those that you have already enquired about unless you have opted not to receive such information.

We will never sell, lease, loan, give or disclose your personal information or protected health information to any 3rd party for the purpose of sales or marketing. Your data will only be used by us and your doctor or care provider to better manage your chronic condition.

Retention of Data

OPOS, Inc. and OPOS.AI will retain your Personal Data and Protected Health Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data and Protected Health Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes and enforce our legal agreements and policies.

OPOS, Inc. and OPOS.AI will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

OPOS, Inc. and OPOS.AI will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information, in accordance with HIPAA 45 CFR Parts 160, 162 and 164, as well as, HITECH (the Health Information Technology for Economic and Clinical Health Act of 2009) and the regulations thereunder (including 45 C.F.R. Sections 164.308, 164.310, 164.312, and 164.316).

Disclosure of Data

Business Transaction

If OPOS, Inc. and OPOS.AI is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data and Protected Health Information is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, OPOS, Inc. and OPOS.AI may be required to disclose your Personal Data and/or Protected Health Information if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

OPOS, Inc. and OPOS.AI may disclose your Personal Data in the good faith belief that such action is necessary to:

·    To comply with a legal obligation

·    To protect and defend the rights or property of OPOS, Inc. and OPOS.AI

·    To prevent or investigate possible wrongdoing in connection with the Service

·    To protect the personal safety of users of the Service or the public

·    To protect against legal liability

We may combine and enhance the Personal Information we collect and obtain about you or from you with Information we receive from third parties, provided that we use the combined Information in accordance with this Policy.

We may also use the Personal Information we collect and obtain about you or from you to generate Non-Personal Information. When we do so, we will take reasonable measures to ensure that the Non-Personal Information is no longer personally identifiable and may not later be reasonably associated with, linked to, or used to identify you. This will include, by way of example, storing the Non-Personal Information separately from any Personal Information. Once we generate Non-Personal Information from any Personal Information, we will not later attempt to again make that information personally identifiable. However, we may combine and enhance that Non-Personal Information with other Non-Personal Information we receive or obtain third parties.

You should not provide any personal information to us, whether via the Platform or any Services, unless you agree to the use of that Information in accordance with this Policy.

Online Protection Act (CalOPPA)

We do not support Do Not Track ("DNT"). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.

You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites or services.

Children's Privacy

Our Service does not address anyone under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "effective date" at the top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Your California Privacy Rights. California law provides that California residents have a right to request that businesses tell them how their personal Information has been shared with third parties for use in direct marketing purposes. We will never use any of your data for any direct marketing purposes.

If you no longer wish to receive certain messages from us or to have your Personal Information shared in the manner otherwise permitted by this Policy, you may seek to opt- out of receiving those messages or having your Personal Information shared in that manner. In some cases, opting out of receiving messages or having your Personal Information shared will not affect your ability to use the Platform or the services we provide through the Platform. However, some messages are necessary to the use and operation of the Platform.

Likewise, some sharing of Personal Information is necessary to provide you with the services we offer through the Platform. If you wish to opt-out of receiving these messages or of sharing your Personal Information in this manner, we may be required to limit or cancel your access to the Platform or our services.

Notification of Changes. We may notify you of any changes to this Policy by way of an email, by posting on the Site or through the Platform. Changes to this Policy will be effective 30 days following such notice. Your continued use of the Site or other aspects of the Platform after any change has become effective will constitute your acceptance of that change. Unless we seek and receive consent from you, we will use the Personal Information we collect and obtain about you or from you in accordance with the version of this Policy effective when the Personal Information was last collected.

By using the Platform or any website located at https://telepain.md and/or https://opos.solutions/ (together with any other websites maintained by OPOS, Inc. that may be accessed through this website), you agree to the above privacy policy, and you agree to the End User License Agreement.

Contact Us

If you have any questions about this Privacy Policy, please contact us: By email: info@opos.solutions

By telephone: 650-694-9500

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