Consumer Health Data Privacy Policy

Introduction

Oxford Marketing LLC, doing business as AvenirMD (“AvenirMD,” “we,” or “us”), owns and operates the marketing website at www.avenir-md.com. AvenirMD is a marketing company and does not provide medical consultations, diagnose or treat patients, prescribe or dispense medications, or fulfill orders. If you continue to a patient intake or purchasing flow, Rimo Health LLC (“Rimo”) coordinates the platform, provider network, payments, pharmacy, and fulfillment, and independent medical practices and providers make clinical decisions. This policy describes Consumer Health Data handled by AvenirMD through its website; information collected directly by Rimo or another party is governed by that party’s privacy notices.

This Consumer Health Data Privacy Policy applies to the extent required by applicable state consumer health privacy law. It does not apply to protected health information subject to HIPAA. Protected health information maintained by Rimo or an applicable medical practice is governed by that entity’s Notice of Privacy Practices. This policy supplements AvenirMD’s general Privacy Policy; if the policies conflict, this policy controls only to the extent required by applicable consumer health privacy law.

Collection of Consumer Health Data

The Consumer Health Data we collect depends on how you interact with us, the services you use, and the choices you make.

We collect Consumer Health Data about you from different sources and in various ways when you use our services, including Consumer Health Data you provide directly, Consumer Health Data collected automatically, Consumer Health Data we obtain from third-party data sources, and Consumer Health Data we infer or generate from other data.

Consumer Health Data you provide. We collect Consumer Health Data you may provide to us. For example:

Name and contact information, such as your name, email address, phone number, and billing and physical addresses.

Demographic information, such as your gender, racial or ethnic origin, date of birth, and zip code.

Payment information, such as your credit card number, financial account information, and other payment details.

Account profile information, such as a username or account number in combination with a password, security or access code, or other credential that allows access to an account; a redemption code; biographical details; links to your profiles on social networks; information about your interests and preferences; and any other information that you add to your account profile.

Marketing information, such as your preferences for receiving our marketing communications and details about your engagement with them.

Content, such as photographs, videos, documents, and other files you upload to our Service. This includes email messages and the content of other communications you send to us.

Government-issued identifiers, such as driver's license number, passport number, and social security number. We may collect images of such identification cards.

Biometric information, such as information that can identify you.

Health information, such as information concerning your physical and/or mental health status.

Sexual and reproductive health, such as information about your sex life, reproductive health, and/or sexual orientation.

Consumer Health Data we collect automatically. When you use our services, we collect some information through certain technical tracking technologies that may be considered Consumer Health Data. For example:

Identifiers and device information. When you visit our websites, our web servers automatically log your Internet Protocol (IP) address and information about your device, including device identifiers (such as MAC address); device type; and your device's operating system, browser, and other software including type, version, language, settings, and configuration.

Location data. We may collect general location data when you use our apps or online services.

Usage data. We automatically log your activity on our websites, apps, and connected products, including the URL of the website from which you came to our sites, pages you viewed, how long you spent on a page, access times, and other details about your use of and actions on our website.

Consumer Health Data we create, infer, or generate. We may create, infer, or generate Consumer Health Data from other data we collect, including using automated means to generate information about your likely preferences or other characteristics.

Consumer Health Data we obtain from third-party sources. We also obtain the types of Consumer Health Data described above from third parties. These third-party sources may include, for example:

Corporate affiliates. We may obtain your Consumer Health Data from our corporate affiliates.

Third-party partners. Third-party applications and services, including social networks you choose to connect with or interact with through our services.

Co-branding/marketing partners. Partners with which we offer co-branded services or engage in joint marketing activities.

Service providers. Third parties that collect or provide data in connection with work they do on our behalf.

Publicly available sources. Public sources of Consumer Health Data such as open government databases.

Use of Consumer Health Data

We use Consumer Health Data for purposes described in this Consumer Health Data Privacy Policy or as otherwise disclosed to you. For example, we use Consumer Health Data for the following purposes:

Product and service delivery. To provide and deliver our Service and operate our business, including analyzing Service use, troubleshooting, facilitating your movement through the Service, confirming your location, billing, processing your payments, accounting, administering your account, securing our systems, detecting fraudulent or illegal activity, providing customer support, communicating with you about the Service, personalizing the Service, verifying your identity, and complying with our legal obligations and enforcing our rights.

Product improvement, development, and research. To develop, test, or improve the Service and content, features, and/or products or services offered via the Service. Additionally, to identify or create new products or services. Lastly, to analyze traffic and user behavior or activity to and through the Service.

Aggregation, de-identification, and/or anonymization. We may create aggregated, de-identified, and/or anonymized data from your Consumer Health Data.

Marketing. To communicate with you about new services, offers, promotions, rewards, contests, upcoming events, and other information about our services and those of our selected partners.

Sharing Consumer Health Data

We may “share” (as applicable state law defines that term) Consumer Health Data with your consent or as we determine necessary to complete your transactions, provide the services you have requested or authorized, or as otherwise permitted or required by law. For example, we may share your Consumer Health Data to:

Affiliates. We enable access to Consumer Health Data across our subsidiaries, affiliates, and related companies, for example, where we share common data systems or where access helps us to provide our services and operate our business.

Legal and law enforcement. We will access, share, and preserve Consumer Health Data when we believe that doing so is necessary to comply with applicable law or respond to valid legal process, including from law enforcement or other government agencies.

Your Consumer Health Data Rights

You may have certain rights to your Consumer Health Data under applicable state law. These rights may vary depending on your state of residence. Any of the rights discussed below may be subject to certain limitations (for example, a monetary charge).

If you wish to exercise these rights, please contact us at hello@reply.avenir-md.com.

Withdraw consent. To the extent we rely upon your consent for either our collection or sharing of your Consumer Health Data, you have the right to withdraw such consent from any future collection or sharing.

Access and confirm. You have the right to ask us to confirm whether we have collected, shared, or sold your Consumer Health Data. Further, you have the right to access (in other words, request a copy of) the Consumer Health Data that we have collected, shared, or sold.

Correction. You have the right to ask us to correct inaccuracies in your Consumer Health Data.

Deletion. You have the right to ask us to delete your Consumer Health Data.

Appeal. You have the right to appeal our denying a right you have attempted to exercise. We will provide details on how to appeal our denial in connection with such action.

To exercise your rights above and make a Consumer Health Data rights request, please contact us at hello@reply.avenir-md.com. We may need to verify your identity in order to process your request. To confirm your identity, we may ask you to verify personal information we already have on file for you. If we cannot verify your identity based on the information we have on file, we may request additional information from you (such as government identification), which we will only use to verify your identity, and for security or fraud-prevention purposes.

We need to collect certain Consumer Health Data in order to provide the Service to you. If you request that any required Consumer Health Data be deleted or withdraw your consent for future collection or sharing of any required Consumer Health Data, we may not be able to provide the Service or certain features of the Service to you.

Changes to this Consumer Health Data Privacy Policy

We reserve the right to modify this Consumer Health Data Privacy Policy at any time. If we make material changes to this Consumer Health Data Privacy Policy, we will notify you by updating the date of this Consumer Health Data Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this Consumer Health Data Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your use of the Service after the effective date of any modified Consumer Health Data Privacy Policy indicates your acknowledging that the modified Consumer Health Data Privacy Policy applies to your interactions with the Service.

Contacting Us

If you have any questions about this Consumer Health Data Privacy Policy, please contact us by email at hello@reply.avenir-md.com, or by regular mail at:

Oxford Marketing LLC dba AvenirMD

228 Park Ave S, Num 742392

New York, NY 10003

Attn: Privacy Officer