Privacy Policy

Last Update: July 4, 2022

The purpose of this Privacy Policy is to describe how Zocalo Health MSO, LLC and its affiliated medical practices, Zocalo Health, PLLC and Zocalo Medical Group CA, P.C. (collectively, “Zocalo Health”, “we”, “our” or “us”) collect, use and share information about you when you access and use our websites (“Sites”) and online services (collectively, the “Services”).

Please read this notice carefully to understand how we use, disclose and otherwise manage the personal information we collect about you. The personal information we receive or obtain through your use of the Services may be subject to different state and federal privacy laws governing the use and disclosure of health information. Zocalo Health complies with applicable state and federal privacy laws and descriptions in this Privacy Policy regarding our collection, use and disclosure of personal information may be subject to or further restricted by the requirements of these laws. If you do not understand any aspects of this Privacy Policy, please feel free to contact us (our contact information is at the end of this Privacy Policy). This Privacy Policy is not a contract and does not create any contractual rights or obligations.

We may need to update this Privacy Policy from time to time. Unless we say otherwise, changes will be effective upon the last updated date at the top of this Privacy Policy. Please check this Privacy Policy regularly to ensure that you are aware of any changes. If we make material changes to this Privacy Policy, we will make reasonable attempts to notify you of such changes. Your use of the Services after changes to this Privacy Policy means you have accepted the changes.

Information We Collect

Information You Provide to Us. We collect information you provide to us through the Services and offline, for example when you register to use our Services, receive healthcare services from us, request information from us, contact customer support, fill out any form on a Site, or otherwise communicate with us. This information may include:

Account Information

When you register to use the Services, you will need to provide us with certain personal information to complete the registration, including information that can be used to contact or identify you, which may include your name, email address, username, password, and phone number. We also collect other information you provide as part of registration process and the administration and personalization of your user experience, including demographic information such as your gender, age, and zip code. We may combine this information with the personal information we collect from you.

Health Information

We may collect health information provided by you or generated through your use of the Services. This includes information about your physical, mental and behavioral health conditions, diagnoses and treatment, family medical history, prescription information, details of your exchanges with participating healthcare providers and their responses, suggestions, and guidance related to your interactions through the use of our Services. We also collect information about non-medical factors that influence your health outcomes (also known as “social determinants of health”).

Transaction Information

We may collect and store information about the products you purchase and shipping, billing and payment card information.

Information We Collect Automatically. Whenever you interact with our Services, we automatically receive and record information from your browser or device using cookies or similar technologies. This information may include your IP address, geolocation data, device identification, the type of browser and/or device you’re using to access our Services, and the page or feature you requested. To learn more about the cookies and other technologies we use, please see our Statement on Cookies and Similar Technologies below.

The information we collect automatically may include personal information, or 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 the Services 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 Site according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Site.

We may use this data to customize content for you that we think you might like, based on your usage patterns. We may also use it to improve the Services – for example, this data can tell us how often users use a particular feature of a Service, and we can use that knowledge to make the Services more helpful to as many users as possible.

How We Use Your Information

We may use your information for various purposes related to our operations and your use of the Services. For example, First Opinion may use your information to:

•Provide, maintain and improve our Services and provide you with relevant information;

•Send you technical notices, updates, security alerts and support and administrative messages;

•Respond to your comments, questions and requests and provide customer service;

•Facilitate contests, sweepstakes and promotions and process and deliver entries and rewards;

•Monitor and analyze trends, usage and activities in connection with our Services;

•Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Zocalo Health and others;

•Communicate with you about products, services, offers, promotions, rewards and events offered by us and others, and provide news and information we think will be of interest to you;

•Maintain appropriate records for internal administrative purposes;

•Link or combine with information we get from others to help understand your needs and provide you with a better experience; and

•Carry out any other purpose described to you at the time the information was collected or pursuant to your consent.

How We Share Your Information

Zocalo Health. We may share your information with our affiliates, including Zocalo Health Medical Group, to provide you with the Services.

Vendors and Service Providers. We may provide information to third-party vendors and service providers that help us operate and manage our Services and deliver products and Services that you purchase through us. These vendors and service providers will have access to your personal information in order to provide these services, but when this occurs we implement reasonable contractual and technical protections to limit their use of that information to helping us provide the service.

Third-Party Analytics. We use selected third parties to collect data about how you interact with the Services. This information may be used to, among other things, improve the functionality of our Services.

With Your Consent. In addition to the sharing described elsewhere in this

Privacy Policy, we will share personal information with companies, organizations or individuals when we have your consent to do so.

Legal Proceedings. We will share personal information with third party companies, organizations or individuals if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:

•meet any applicable law, regulation, subpoena, legal process or enforceable governmental request;

•enforce applicable Terms, including investigation of potential violations;

•detect, prevent, or otherwise address fraud, security or technical issues; or

•protect against harm to the rights, property or safety of Zocalo Health, our users, customers or the public as required or permitted by law.

Transfer in the Event of Sale or Change of Control. If the ownership of all or substantially all of our business changes or we otherwise transfer assets relating to our business or the Site to a third party, such as by merger, acquisition, bankruptcy proceeding or otherwise, we may transfer or sell your personal information to the new owner. In such a case, unless permitted otherwise by applicable law, your information would remain subject to the promises made in the applicable privacy policy.

We also may share aggregated or de-identified information, which cannot reasonably be used to identify you.

Statement on Cookies and Similar Technologies

Our Services use cookies and other data collection technologies described in this section.

Cookies. A cookie is a small file placed on your computer’s hard drive that collects and stores information about your equipment, preferences and browsing patterns. We use cookies to analyze web page traffic, usage patterns, and to tailor our Services to your individual interests. For more information about cookies, visit allaboutcookies.org.

Web Beacons. A web beacon (also referred to as clear gif, pixel tag or single-pixel gif) is a transparent graphic image used in tandem with cookies that enables us to record a user’s actions. We use web beacons to count users who have visited those pages, verify system and server integrity and for similar statistical measures.

Google Analytics. We use Google Analytics to help us understand how users engage with our Services. Google Analytics uses cookies to track your interactions with our Services, then collects that information and reports it to us, without identifying individual users. This information helps us improve our Services so that we can better serve users like you. For more information on Google Analytics, visit support.google.com/analytics.

You can set your Internet browser settings to stop accepting new cookies, to receive notice when you receive a new cookie, to disable existing cookies, and to omit images (which will disable pixel tags). Note that the opt-out will apply only to the browser that you are using when you elect to opt out of advertising cookies. Please note, without cookies or pixel tags, you may not be able to take full advantage of all features of our Services.

Some web browsers incorporate a “Do Not Track” feature (“DNT”) that signals to the websites that you visit that you do not want to have your online activity tracked. Many websites and applications, including our Services, do not currently respond to web browser DNT signals because such signals are not yet uniform. For more information about DNT signals, please visit allaboutdnt.com.

Choices You Have Regarding Your Information

You may review and request certain changes to the information we have collected about you by contacting us (our contact information is at the end of this Privacy Policy).

Reviewing, Correcting, and Deleting Your Personal Information. You may access, correct, and/or request deletion of certain information that you have provided to us by emailing us at help@zocalo.health. If you email us, for your protection, we may only implement requests with respect to the information associated with the particular email address you use to send us your request, and we may need to verify your identity before implementing your request. We will attempt to comply with any reasonable requests for accessing, correcting, or deleting your information.

Text Messages and SMS. Zocalo Health and those acting on our behalf may send you text (SMS) messages at the phone number you provide us. These messages will include operational messages about your use of the Services. You understand that by providing your mobile phone number, you expressly consent to receive automated text messages from us to the mobile phone number you provide. Consent to receiving text messages is not required in order to be a user. Message and data rates may apply, and you should check the rates of your mobile carrier. You can opt out of receiving text messages by texting STOP in response to any text message. We share your mobile phone number with service providers with whom we contract in order to send you automated text messages, but we will not share your mobile phone number with third parties for their own marketing purposes without your express consent.

Marketing Communications. You may choose to stop receiving marketing, promotional, reminder, or notification emails from us. You can opt-out of these messages following the instruction contained in the email or by contacting us and requesting to opt-out. (Our contact information is at the end of this Privacy Policy.)

Retention of Your Information

As a general matter, we will keep your personal information for as long as necessary to fulfill the purpose for which it was collected. If a law requires us to retain your information for a longer period of time, we will comply with that law. We will also retain your personal information as necessary to protect our legal rights.

Security of Your Information

We maintain administrative, technical, and physical safeguards designed to protect against unauthorized access, use, modification, and disclosure of your information in our custody and control. No data, on the Internet or otherwise, can be guaranteed to be 100% secure. While we strive to protect your information from unauthorized access, use, or disclosure, we cannot and do not ensure or warrant the security of your information.

Children’s Privacy

We do not knowingly collect information, including personal information as defined by the Children’s Online Privacy Protection Act, from children under the age of 13 without parental consent. If you are a parent or guardian of a child under the age of 13 and believe he or she has disclosed personal information to us without your consent, you may contact us to request that we delete and stop use of that information (our contact information is at the end of this Privacy Policy). If we learn that we have received any information directly from a child under age 13 without first receiving his or her parent’s verified consent, we will use that information only to respond directly to that child (or his or her parent or legal guardian) to inform the child that he or she cannot use the Services. We will then subsequently delete that child’s information.

Information for Users from Outside of the United States

The Services are intended for use only in the United States. If you use the Services or contact us from outside of the United States, please be advised that (1) any information you provide to us or that we automatically collect will be transferred to the United States; and (2) by using the Services or submitting information, you explicitly authorize its transfer to and subsequent processing in the United States in accordance with this Privacy Policy.

Shine the Light

California residents may also request information from us once per calendar year about any personal information shared with third parties for their own direct marketing purposes, including the categories of information and the names and addresses of those businesses with which we have shared such information. To request this information, please contact us (our contact information is at the end of this Privacy Policy). Your inquiry must specify “California Privacy Rights Request” in the subject line of the email, and you must include your name, street address, city, state, and ZIP code.

Zocalo Health does not share your personal information with third parties for their own direct marketing purposes.

Contact Us

If you have any questions, comments or concerns regarding this Privacy Policy, please contact us by sending correspondence to 6133 NE 188th Place, Kenmore, WA 98028 or send us an email at help@zocalo.health.