Effective Date: 4/11/22
INTRODUCTION Necto Health Tech, Inc. (“Necto Health,” “we,” “our,” or “us”) is committed to respecting your privacy. This Privacy Policy (the “Privacy Policy” or “Policy”) describes how we collect, process, and share your Personal Data (as defined below) while operating our business and explains your rights and choices with respect to such information. This Policy applies to information we collect: · on or through our websites, https://app.remoteptnetwork.com/ and http://remoteptnetwork.com (the “Websites”); · on or through the RPTNetwork Mobile App (the “Mobile App”); · when you contact us or submit information to us; · when you interact with our advertising and applications on third party websites and services, if those applications or advertising include links to this Privacy Policy; and · from third parties, such as our business partners and service providers. Except as described above, this Privacy Policy does not apply to information collected by: · us offline or through any other means, including on any other website operated by Necto Health or any third party; or · any third party, including through any application or content (including advertising) that may link to or be accessible from our Websites or Mobile App. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Websites or Mobile App (collectively referred to in this Privacy Policy as the “Platform”). By accessing or using our Platform, you agree to the terms of this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of the Platform after we make changes is deemed to be acceptance of those changes, so please check this Privacy Policy periodically for updates.
INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT
Generally
We collect several types of information from and about users of our Platform, including information:
· by which you may be personally identified, such as name, username or alias, e-mail address, telephone number, date of birth, licensure information, social media handle, name of college or university graduated from, graduation date, place of employment, hobbies, areas of clinical interest or expertise, and other similar identifiers (“Personal Data”);
· that is about you but individually does not identify you, such as traffic data, location data, logs, referring/exit pages, date and time of your use of the Platform, error information, information associated with your Apple iTunes or Google Play accounts or any other account used to download or access our Mobile App, and other communication data and the resources that you access and use in our Platform; and
· about your internet connection, the type and location of mobile device and operating system you use to access our Mobile App, the equipment you use to access our Websites, browser type, and usage details.
We collect this information:
· directly from you when you provide it to us;
· automatically as you navigate through the Platform. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and
· from third parties, for example, our business partners and service providers.
Information You Provide to Us
The information we collect from or about you includes:
· information that you provide to us directly on or through our Platform or on other forms, applications, or surveys you complete, whether in writing, by phone, electronically, or by other means. This includes information provided at the time of registering to use our Platform, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our Platform; and
· records and copies of your correspondence (including email addresses), if you contact us; and
· details of transactions you carry out through our Platform and of the fulfillment of your orders.
You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of the Platform, or transmitted to other users of the Platform or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to other members who are in the same group(s) as you, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of the Platform with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.
Information We Collect Through Automatic Data Collection Technologies
As you navigate through and interact with our Platform, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:
· details of your visits to our Platform, including usage details, traffic data, location data, logs, and other communication data and the resources that you access and use on the Platform; and
· information about your computer, mobile device, and internet connection, including your IP address, operating system, browser type, Mobile App version information, and information associated with your Apple iTunes or Google Play account(s) or any other account used to download or access our Mobile App.
We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (behavioral tracking). Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Platform is not currently set up to respond to those signals.
The information we collect automatically may include Personal Data, or we may maintain it or associate it with Personal Data we collect in other ways or receive from third parties. It helps us to improve our Platform and to deliver a better and more personalized service, including by enabling us to:
· estimate our audience size and usage patterns;
· store information about your preferences, allowing us to customize our Platform according to your individual interests; and
· recognize you when you return to our Platform.
Cookies. We may use cookies and other technologies to receive and store certain types of information whenever you interact with our Platform through your computer or mobile device. A cookie is a small file or piece of data sent from a website and stored on the hard drive of your computer or mobile device. On your computer, you may refuse to accept browser cookies by activating the appropriate setting on your browser, and you may have similar capabilities on your mobile device in the preferences for your operating system or browser. However, if you select this setting you may be unable to access certain parts of our Platform. Unless you have adjusted your browser or operating system setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Platform.
Third Party Use of Cookies and Other Tracking Technologies. Some content or applications, including advertisements, on the Platform are served by third-parties, including sponsors, advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our Platform. The information they collect may be associated with your Personal Data or they may collect information, including Personal Data, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.
We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.
Google Analytics. We use Google Analytics, a web analytics service provided by Google, Inc. (“Google”) to collect certain information relating to your use of our Platform. Google Analytics uses cookies, to help our Platform analyze how users use our Websites. You can find out more about how Google uses data when you visit our Platform by visiting “How Google uses data when you use our partners' sites or apps”, (located at www.google.com/policies/privacy/partners/). For more information, please visit Google and pages that describe Google Analytics, such as www.google.com/analytics/learn/privacy.html.
Information We Collect From Third Parties
The information we collect from third parties includes your name, e-mail address, telephone number, date of birth, licensure information, name of college or university graduated from and graduation date, place of employment, areas of clinical interest or expertise, and other similar identifiers.
HOW WE USE YOUR INFORMATION
We use information that we collect about you or that you provide to us, including any Personal Data:
· to fulfill or meet the reason you provide the information;
· to provide, support, personalize, or develop the services provided on or through our Platform;
· to maintain, customize, and secure your account with us (including to provide you with notices about your subscriptions, including expiration and renewal notices);
· to personalize your Platform experience and to deliver content and product and service offerings relevant to your interests, including targeted offers and ads through our Platform and/or third-party sites (with your consent, where required by law);
· to process your requests, purchases, and transactions, and/or to prevent transactional fraud;
· to administer surveys, sweepstakes, promotions, and other contests;
· to send you newsletters and other similar communications not specifically advertising our own goods and services;
· to allow you to participate in the interactive features on our Platform;
· to provide you with support and to respond to your inquiries (including to investigate and address concerns as well as monitor/improve responses);
· to help maintain the safety, security, and/or integrity of our business, Platform, products, services, databases, and other technology assets;
· for internal testing, research, analysis, and product development, including to develop and improve our Platform, and to develop, improve, or demonstrate our products and services;
· to perform services on behalf of a third party, such as employers;
· to notify you about changes to our Platform or any products or services we offer or provide though it;
· to respond to law enforcement requests and as required by applicable law, court order, or governmental regulations;
· to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Necto Health’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Necto Health about our Platform users is among the assets transferred;
· if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Necto Health, our users, or others;
· to enforce or apply our Terms of Use, carry out our obligations, and enforce our rights arising from any contracts entered into between you and us; and
· for any other purpose with your consent or as otherwise permitted by law.
We may also use your information to contact you about our own and third-parties’ goods and services that may be of interest to you. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications or modifying your notification settings within the Platform. For more information, see Choices About How We Use and Disclose Your Information.
We may use the information we have collected from you to enable us to display advertisements to our advertisers’ target audiences. Even though we do not disclose your Personal Data for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.
DISCLOSURE OF YOUR INFORMATION We do not share, sell, or otherwise disclose your Personal Data for purposes other than those outlined in this Privacy Policy. However, we may disclose aggregated information about our users without restriction. We may disclose Personal Data that we collect or you provide as described in this Privacy Policy: · to our subsidiaries and affiliates; · to contractors, service providers, and other third parties we use to support our business, including social media companies and internet cookie recipients, such as analytics and/or behavioral advertising service providers; · to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Necto Health’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Data held by Necto Health about our Platform users is among the assets transferred; and · to third parties to market their products or services to you if you have not opted out of these disclosures (for more information, see Choices About How We Use and Disclose Your Information). We may also disclose your Personal Data: · to comply with any court order, law, or legal process, including to respond to any government or regulatory request; · to enforce or apply our Terms of Use, carry out our obligations, or enforce our rights arising from any contracts entered into between you and us; and · if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Necto Health, our users, or others.
CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION We strive to provide you with choices regarding the Personal Data you provide to us. We have created mechanisms to provide you with the following control over your information: · Tracking Technologies and Advertising. You can set your browser or operating to refuse all or some cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of our Platform may then be inaccessible or not function properly. We do not control third parties’ collection or use of your information through cookies and other tracking technologies to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can learn more about interest-based advertisements and your opt-out rights and options from third party platforms for marketing purposes from the following resources: o Network Advertising Initiative (www.networkadvertising.org); and o Digital Advertising Alliance (www.aboutads.info). · Disclosure of Your Information for Third-Party Advertising. If you do not want us to share your Personal Data with unaffiliated or non-agent third parties for promotional purposes, you can opt-out by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or emailing support@remoteptnetwork.com. · Promotional Offers from Necto Health. If you do not wish to have your e-mail address used by us to promote our own or third parties’ products or services, you can opt-out at any time by clicking the unsubscribe link at the bottom of any email or other marketing communications you receive from us or emailing support@remoteptnetwork.com. If we have sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to Necto Health as a result of a product purchase, product service experience or other transactions.
YOUR RIGHTS REGARDING YOUR PERSONAL DATA Generally You can review and change your Personal Data by logging into our Platform and visiting your account profile page. You may also send us an email at support@remoteptnetwork.com to request access to, correct, or delete any Personal Data that you have provided to us. We may not be able to accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect. If you delete your User Contributions from the Platform, we will maintain and use your User Contributions in accordance with the Terms of Use. In addition, copies of your User Contributions may remain viewable in cached and archived pages, or may have been previously copied or stored by other Platform users before deleted by you. Proper access and use of information provided on the Platform, including User Contributions, is governed by our Terms of Use. State Specific Rights The law in some states may provide you with additional rights regarding our use of Personal Data. To learn more about any additional rights that may be applicable to you as a resident of one of these states, please see below. Your California Rights • Do Not Track. California law requires us to let you know how we respond to web browser Do Not Track (“DNT”) signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about your online activities over time. Because there is not yet a common understanding of how to interpret the DNT signal, we do not currently respond to the browser DNT signals when you use our services and products or interact with our Platform. • Deleting User Contributions Posted by Minors Upon Request. California law permits minors under the age of 18 to request the removal of their User Contributions, subject to certain exceptions. As noted in Section 9, below, we do not knowingly collect Personal Data from children under 18. If you are under the age of 18 in California, you may contact us using the Contact Information below (if you contact us via email, please use the subject “California Eraser Law Request”). We may not remove your User Contributions that we are required to retain under any federal or state law, or that have been provided to a third party. While we will do our best to remove a minor’s information upon a valid request, we cannot ensure the complete or comprehensive removal of your User Contributions from our Platform or any information that has been republished, copied, downloaded, or reposted by any third party, and we cannot guarantee that any such information may not be accessible to users of the internet in the future. We do not advertise or market any of the products or services identified in California Business and Professionals Code Section 22580(i) to users who we have actual knowledge are under 18 years of age. • “Shine the Light” Law. California Civil Code Section 1798.83 (California’s “Shine the Light” law) permits users of our Platform that are California residents and who provide Personal Data in obtaining products and services for personal, family, or household use to request certain information regarding our disclosure of Personal Data to third parties for their own direct marketing purposes. If applicable, this information would include the categories of Personal Data and the names and addresses of those businesses with which we shared your Personal Data with for the immediately prior calendar year (e.g., requests made in 2021 will receive information regarding such activities in 2020). You may request this information once per calendar year. To make such a request, please send an email to support@remoteptnetwork.com.
DATA SECURITY We have implemented measures designed to secure your Personal Data from accidental loss and from unauthorized access, use, alteration, and disclosure. The safety and security of your information also depends on you. Where you have chosen a password for the use of our Platform, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Data, we cannot guarantee the security of your Personal Data transmitted to our Platform. Any transmission of Personal Data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Platform or in your operating system.
THIRD PARTY SITES Our Platform may contain links to third party websites or services that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other websites or services. The privacy practices of these third parties, including details on the information they may collect about you, are subject to the privacy policies of these parties, which we suggest you review.
CHILDREN UNDER THE AGE OF 18 Our Platform is not intended for or directed to children under 18 years of age. We do not knowingly collect Personal Data from children under 18. If you are under 18, do not use or provide any information on or through our Platform. If we learn we have collected or received Personal Data from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at the Contact Information below.
CHANGES TO OUR PRIVACY POLICY We may change this Privacy Policy at any time. It is our policy to notify you of any changes we make to our Privacy Policy by e-mail to the e-mail address specified in your account. If we make material changes to how we treat our users’ Personal Data, we will notify you by e-mail to the e-mail address specified in your account and through a conspicuous banner or posting on the home page our Websites and Mobile App. The date this Privacy Policy was last updated is identified at the top of the page. You are responsible for ensuring we have an up-to-date, active, and deliverable e-mail address for you, and for periodically visiting our Platform and reviewing this Privacy Policy to check for any changes.
CONTACT INFORMATION If you have any questions, concerns, complaints, or suggestions regarding our Privacy Policy or otherwise need to contact us, you may contact us at the contact information below:
Necto Health Tech, Inc. 22 Boston Wharf Rd, 7th Floor Boston, MA 02210 Phone: (978) 296-8460 E-mail: support@remoteptnetwork.com