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CERTILYTICS, INC. STATEMENT OF PRIVACY


INTRODUCTION

Certilytics, Inc. (“Company” or “We”) respects your privacy and is committed to
protecting it through our compliance with this policy.

This policy describes the types of information We may collect from you or that
you may provide when you visit the website www.certilytics.com or make use of
company products (collectively our “Products“), the types of information that We
may collect from our customers that you are affiliated with, your health plan or
provider; and our practices for collecting, using, maintaining, protecting, and
disclosing that information.

This policy applies to information We collect:

 * With our Products, or in email, text, and other electronic messages between
   you and any Products.
 * About you from our customers and affiliates.
 * When you interact with our advertising and applications on third-party
   websites and services, if those applications or advertising include links to
   this policy.

It does not apply to information collected by:

 * Us offline or through any other means, including on any other website
   operated by Company or any third party (including our affiliates and
   subsidiaries); or
 * Any third party (including our affiliates and subsidiaries), including
   through any application or content (including advertising) that may link to
   or be accessible from or on the Website

Please read this 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 Products. By accessing
or using this website or our Products, you agree to this privacy policy. This
policy may change from time to time (see Changes to Our Privacy Policy) Your
continued use of Company Products after we make changes is deemed to be
acceptance of those changes, so please check the policy periodically for
updates.


CHILDREN UNDER THE AGE OF 18

Our Products are not intended for children under 18 years of age. No one under
age 18 may provide any information to or on our Products. We do not knowingly
collect personal information from children under 18. If you are under 18, do not
use or provide any information on this Product or through any of its features,
register on the Products, or provide any information about yourself to us,
including your name, address, telephone number, email address, or any screen
name or user name you may use. If we learn we have collected or received
personal information 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:
contact@certilytics.com

Compliance Department
Certilytics, Inc.
9200 Shelbyville Road, Suite 700
Louisville, KY 40222
888-356-6934

California residents under 18 years of age may have additional rights regarding
the collection and sale of their personal information. Please see your
California Privacy Rights for more information.


INFORMATION WE COLLECT ABOUT YOU AND HOW WE COLLECT IT

We may collect several types of information from and about users of our
Products, including information:

 * By which you may be personally identified, such as name, postal address,
   e-mail address, telephone number, or any other identifier by which you may be
   contacted online or offline (“personal information“);
 * That is about you but individually does not identify you, such as company
   name, job title, and type of organization; and/or
 * About your internet connection, the equipment you use to access our Website,
   and usage details.

We collect this information:

 * Directly from you when you provide it to us.
 * Automatically as you navigate through the site. Information collected
   automatically may include usage details, IP addresses, and information
   collected through cookies, web beacons, and other tracking technologies.
 * From third parties, for example, our business partners.


INFORMATION YOU PROVIDE TO US

The information we collect on or through our Products may include:

 * Information that you provide by filling in forms within our Products. This
   includes information provided at the time of registering to use our Products,
   or requesting further information. We may also ask you for information when
   you report a problem with our Website.
 * Information provided by your employer if you are using our Products in the
   performance of your duties.
 * Records and copies of your correspondence (including email addresses), if you
   contact us.
 * Your responses to surveys that we might ask you to complete for research
   purposes.
 * Your search queries on the Products.


INFORMATION WE COLLECT THROUGH AUTOMATIC DATA COLLECTION TECHNOLOGIES

As you navigate through and interact with our Products, 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 Products, including traffic data, location
   data, logs, and other communication data and the resources that you access
   and use within the Products.
 * Information about your computer and internet connection, including your IP
   address, operating system, and browser type.

The information we collect automatically may include personal information, but
we may maintain it or associate it with personal information we collect in other
ways or receive from third parties. It helps us to improve our Website 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
   Products according to your individual interests.
 * Speed up your searches.
 * Recognize you when you return to our Products.

The technologies we use for this automatic data collection may include:

 * Cookies (or browser cookies). A cookie is a small file placed on the hard
   drive of your computer. You may refuse to accept browser cookies by
   activating the appropriate setting on your browser. However, if you select
   this setting you may be unable to access certain parts of our Website. Unless
   you have adjusted your browser setting so that it will refuse cookies, our
   system will issue cookies when you direct your browser to our Website.
 * Web Beacons. Pages of our the Website [and our e-mails] may contain small
   electronic files known as web beacons (also referred to as clear gifs, pixel
   tags, and single-pixel gifs) that permit the Company, for example, to count
   users who have visited those pages or [opened an email] and for other related
   website statistics (for example, recording the popularity of certain website
   content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this
information to personal information about you that we collect from other sources
or you provide to us.


THIRD-PARTY USE OF COOKIES AND OTHER TRACKING TECHNOLOGIES

Some content or applications, including advertisements, on the Products are
served by third-parties, including 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 Products. The information they collect
may be associated with your personal information or they may collect
information, including personal information, 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.


HOW WE USE YOUR INFORMATION

We use information that we collect about you or that you provide to us,
including any personal information:

 * To present our Products and their contents to you.
 * To provide you with information, products, or services that you request from
   us.
 * To fulfill any other purpose for which you provide it.
 * To carry out our obligations and enforce our rights arising from any
   contracts entered into between you and us.
 * To notify you about changes to our Products or services we offer or provide
   though it.
 * In any other way we may describe when you provide the information.
 * For any other purpose with your consent.

We may also use your information to contact you about goods and services that
may be of interest to you. If you do not want us to use your information in this
way, please check the relevant box located on the form on which we collect your
data.  For more information, see Choices about How We Use And Disclose Your
Information.


DISCLOSURE OF YOUR INFORMATION

We may disclose aggregated information about our users, and information that
does not identify any individual, without restriction.

We may disclose personal information 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 and who are bound by contractual obligations to keep personal
   information confidential and use it only for the purposes for which we
   disclose it to them.
 * 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 Company’s assets, whether as a going concern or as part of
   bankruptcy, liquidation, or similar proceeding, in which personal information
   held by the Company about our Product’s users is among the assets
   transferred.
 * To fulfill the purpose for which you provide it.
 * For any other purpose disclosed by us when you provide the information.
 * With your consent.

We may also disclose your personal information:

 * 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 and other agreements.
 * If we believe disclosure is necessary or appropriate to protect the rights,
   property, or safety of Certilytics, our customers, or others.


CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION

We strive to provide you with choices regarding the personal information 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 to refuse all
   or some browser cookies, or to alert you when cookies are being sent. If you
   disable or refuse cookies, please note that some parts of this site may then
   be inaccessible or not function properly.
 * Promotional Offers from the Company. If you do not wish to have your contact
   information used by the Company to promote our own or third parties’ products
   or services, you can opt-out by checking the relevant box located on the form
   on which we collect your data or sending us an email stating your request to
   contact@certilytics.com. If we have sent you a promotional email, you may
   send us a return email asking to be omitted from future email distributions.
 * Targeted Advertising. If you do not want us to use information that we
   collect or that you provide to us to deliver advertisements according to our
   advertisers’ target-audience preferences, you can opt-out by having your
   browser set to accept all browser cookies.

We do not control third parties’ collection or use of your information 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 opt out of receiving targeted ads from members of the Network Advertising
Initiative (“NAI“) on the NAI’s website.

California residents may have additional personal information rights and
choices. Please see your California Privacy Rights for more information.

Nevada residents who wish to exercise their sale opt-out rights under Nevada
Revised Statutes Chapter 603A may submit a request to this designated address:
contact@certilytics.com

Compliance Department
Certilytics, Inc.
9200 Shelbyville Road, Suite 700
Louisville, KY 40222
888-356-6934

However, please know we do not currently sell data triggering that statute’s
opt-out requirements.


YOUR CALIFORNIA PRIVACY RIGHTS

If you are a California resident, California law may provide you with additional
rights regarding our use of your personal information. To learn more about your
California privacy rights, visit https://oag.ca.gov/privacy/ccpa.

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users
of our Products that are California residents to request certain information
regarding our disclosure of personal information to third parties for their
direct marketing purposes. To make such a request, please send an email to
contact@certilytics.com or write us at:

Compliance Department
Certilytics, Inc.
9200 Shelbyville Road, Suite 700
Louisville, KY 40222


DATA SECURITY

We have implemented measures designed to secure your personal information from
accidental loss and from unauthorized access, use, alteration, and disclosure.
All information you provide to us is stored on our secure servers behind
firewalls and data transmissions are encrypted using SSL technology.

The safety and security of your information also depends on you. Where we have
given you (or where you have chosen) a password for access to certain parts of
our Website, you are responsible for keeping this password confidential. We ask
you not to share your password with anyone.


COMPANY WEBSITE DATA SECURITY

Unfortunately, the transmission of information via the internet is not
completely secure. Although we do our best to protect your personal information,
we cannot guarantee the security of your personal information transmitted to our
Company Website. Any transmission of personal information is at your own risk.
We are not responsible for circumvention of any privacy settings or security
measures contained on the Company Website.


YOUR HEALTH INFORMATION RIGHTS REGARDING HIPAA IDENTIFIABLE COVERED INFORMATION

HIPAA Privacy Rule restrictions only cover identifiable protected health
information, whereas We are provided identifiable data in only some cases by our
customers. When the Company holds your identified HIPAA Covered Information, you
may have certain rights to access, amend, and request an accounting of certain
disclosures of the PHI that the Company handles on behalf of your plan. These
rights are described in more detail in the separate Notice of Privacy Practice
provided by your health plan or provider.

You have the right to:

 * Request a restriction on certain uses and disclosures of your information
   through the covered entity as provided by 45 C.F.R. §164.522; however, the
   covered entity is not required to agree to a requested restriction if it is
   an emergency treatment situation or the individual terminates the
   restriction.
 * Receive confidential communications of protected health information;
 * Obtain a copy of the notice of privacy practices upon request (this
   document);
 * Inspect and obtain a copy of your health information as contained within the
   Company health record as provided for in 45 C.F.R. §164.524;
 * Request that your health record be amended as provided in 45 C.F.R. §164.526;
 * Request communications of your health information by alternative means or at
   alternative locations; and
 * Receive an accounting of inappropriate disclosures made of your health
   information as provided by 45 C.F.R. §164.528.


HOW THE COMPANY MAY USE OR DISCLOSE YOUR HIPAA COVERED HEALTH INFORMATION

This section generally describes how the Company uses and discloses health
information to administer benefits under your health plan. Please note that this
Statement does not list every use or disclosure, instead it gives examples of
the most common uses and disclosures.

We may use and disclose PHI about you for additional related health care
operations necessary to operate your health plan. For example, your health
information may be received or created by members of the staff through business
operations. We also may use your PHI for administrative activities such as
business planning and development, cost management, business management and
conducting quality assessment, and improvement activities.

Required by law. We may use and disclose information about you as required by
law. For example, We may disclose information for the following purposes:

 * For judicial and administrative proceedings pursuant to legal authority;
 * To report information related to victims of abuse, neglect or domestic
   violence;
 * To assist law enforcement officials in their law enforcement duties;
 * To assist with health oversight activities as required by law; and
 * To report information related to decedents that will assist coroners, medical
   examiners, and funeral directors.

Public Health. Your health information may be used or disclosed for public
health activities such as assisting public health authorities or other legal
authorities to prevent or control disease, injury, or disability, or for other
health oversight activities.

Health and Safety. Your health information may be disclosed to avert a serious
threat to the health or safety of you or any other person pursuant to applicable
law.

Government Functions. Your health information may be disclosed for specialized
government functions such as protection of public officials or reporting to
various branches of the armed services that may require use or disclosure of
your health information.

Workers Compensation. Your health information may be used or disclosed in order
to comply with laws and regulations related to Workers Compensation.

Other uses. Other uses and disclosures will be made only with your written
authorization, and you may revoke the authorization except to the extent We have
taken action in reliance on such.

Material Limitations: State laws may be more stringent. Material limitations
such as records surrounding mental health / HIV, that are imposed by state or
other applicable law on permitted uses and disclosures will be applied.


YOUR HEALTH INFORMATION RIGHTS REGARDING HIPAA IDENTIFIABLE COVERED INFORMATION

When we do not hold your identified HIPAA Covered Information and your
information is anonymized, we are unable to associate your identity to your
health information. As such, to exercise your rights under HIPAA, you must
contact the entity holding your identifiable covered information, your
healthcare plan or provider.


OBLIGATIONS OF THE COMPANY

We are committed to:

 * Maintaining the privacy of personally identifying information and protected
   health information;
 * Providing you, upon request, this statement of its legal duties and privacy
   practices with respect to your health information;
 * Abiding by the terms of this statement; notifying you if we are unable to
   agree to a requested restriction on how your information is used or
   disclosed; and
 * Accommodating reasonable requests you may make to communicate health
   information by alternative means or at alternative locations; and We reserve
   the right to change our information practices and to make the new provisions
   effective for all protected health information We maintain.


CHANGES TO OUR PRIVACY POLICY

It is our policy to post any changes we make to our privacy policy on this page.
If we make material changes to how we treat our users’ personal information, we
will notify you through a notice on the Website (www.certilytics.com) or Product
home page. The date the privacy policy was last revised is identified at the top
of the page. You are responsible for ensuring we have an up-to-date active and
deliverable email address for you, and for periodically visiting our Website and
this privacy policy to check for any changes.


CONTACT INFORMATION

To ask questions or comment about this privacy policy and our privacy practices
or register a compliant or concern, please contact us at:

Compliance Department
Certilytics, Inc.
9200 Shelbyville Road, Suite 700
Louisville, KY 40222
contact@certilytics.com

or via our toll-free number: 888-356-6934

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