ONLINE PRIVACY POLICY FOR THE HEALTHFIRST FOUNDATION, INC.

Effective Date: May 15, 2024 

Last Updated: May 15, 2024

This website is owned, operated, licensed, and controlled by the Healthfirst Foundation, Inc. (“Healthfirst Foundation,” “we,” “us,” or “our”), a Healthfirst, Inc. entity. This Privacy Policy (“Privacy Policy” or “Policy”) describes the types of information we collect from individuals (collectively, “you”) when they visit our website at https://healthfirstfoundation.org and all related websites and applications (collectively, the “HF Websites”), as well over the course of receiving other products and services from the Healthfirst Foundation, whether that personal information is collected online, via other electronic communications or telephone, in paper correspondence, or in person (collectively, the “Services”). This Policy also describes how we use your personal information, under what circumstances we may share it and with whom, and your rights and choices.

For the purposes of this Privacy Policy, “personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include publicly available information or information that has been de-identified or aggregated.

This Policy does not pertain to the collection of protected health information. Any coverage of protected health information in this Policy is incidental and provided merely to enhance your understanding of our data collection and use practices, and does not waive or override our obligations under other laws. To the extent your use of the HF Websites is subject to a separate agreement, in the event of a conflict between that agreement and this Policy, the agreement will govern.

This Policy also does not apply to third-party sites, products, or services, even if they link to our HF Websites or Services, and we encourage you to read the privacy policies of any third-party site with which you choose to interact. Where links to third-party sites are integrated in our HF Websites or Services, we will make every effort to clearly mark them as such.

Table of Contents

This Privacy Policy explains the following. Please click on each section for more detail.

1. Collection of Personal Information. We may collect personal information when you communicate with us, including data you provide, automatically collected data, and data from third party sources.
2. How We Use Your Personal Information. We use your personal information in many ways, including to provide the HF Websites and Services, communicate with you, maintain a safe and secure environment, and comply with legal obligations.
3. How We Share Your Personal Information. We may share your personal information for several reasons, including for our own internal purposes and to promote various products and services.
4. Cookie Policy. We may collect personal information from you automatically through the use of cookies and other tracking technologies.
5. Your Rights and Choices. You can change certain privacy and communications preferences at any time.
6. Data Security and Retention. We maintain technical, administrative, and physical safeguards to help protect the security of your personal information.
7. Confidentiality and Use of Email. You are solely responsible for the content of your email messages and can take precautions to prevent compromise.
8. International Data Transfers. Our HF Websites and Services are operated from within the United States and intended only for individuals located in the United States.
9. Use by Children. We do not knowingly collect personal data from individuals under the age of 13 years without parental consent.
10. Links to Other Sites. This Privacy Policy does not apply to third-party websites and applications.
11. Changes to This Privacy Policy. We may update this Privacy Policy from time to time.
12. Contact Information. You may contact us in several ways.

1. Collection of Personal Information

The types of personal information we collect will be apparent by the context of the page or your interactions with us, and generally includes personal information you choose to provide us and personal information we collect as you interact with our HF Websites and Services.

a. Personal Information You Provide To Us

We may collect the following categories of personal information about you that you choose to provide to us when you use the HF Websites and Services:

• Identifiers and contact information. If you express an interest in connecting with the Healthfirst Foundation, you will be given the opportunity to provide your contact information, which may include your first and last name, email address, company name, and job title.
• Communications information. When you communicate with us by submitting a “Contact Us” request or otherwise corresponding with us, we may collect information about the communication and any other information you choose to provide in the content of those communications. If you contact us by telephone, we will collect the phone number you use to call us and additional information in order to verify your identity and process your inquiry.

b. Personal Information We Automatically Collect

In addition to the personal information you choose to provide us, our HF Websites and Services use cookies and similar tracking technologies that automatically collect personal information about you, including:

• Browser and device data, such as your device identifier, Internet Protocol (“IP”) address, device type, operating system and browser type, screen resolution, operating system name and version, device manufacturer and model, language, plug-ins, add-ons, and the language version of the sites you are visiting.
• Usage data, such as geolocation data, browsing history, time, frequency and patterns of service use, pages visited, links clicked, language preferences, and the pages that led or referred you to the HF Websites.

This collection may involve the use third-party cookies on our HF Websites to help us analyze your use of our HF Websites and diagnose technical issues. In addition, we may share this tracking information with third parties for the limited purposes indicated herein. To learn more about our use of cookies and how you can opt-out of analytics tracking by third parties, please see our Cookie Policy.

c. Personal Information From Third-Party Sources

We may collect personal information about you from our parent and affiliate companies or other third-party data sources. Any personal information collected from a third-party is only done pursuant to their privacy policies and other contractual and legal obligations, as may be applicable. To control the information that we receive from a third-party, please update your privacy settings or preferences with that third-party or in your browser. We do not combine the personal information that we collect from the HF Websites with information that we obtain from third-party data sources, including both online and offline data providers.

2. How We Use Your Personal Information

We may use the personal information that we collect about you for the following purposes:

• Provide you with the Services, as well as any other products or information that you request;
• Provide you with information about our Services and other opportunities that we believe may be of interest to you;
• Conduct analytics for website visitors, and new products and services;
• Maintain and improve the quality of the HF Websites and Services;
• Protect ourselves, you, and others, prevent fraud, and create and maintain a trusted and secure online environment;
• Comply with our legal obligations, respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims;

3. How We Share Your Personal Information

We may share certain of your personal information with our partners and other entities, consistent with the circumstances in which we have collected the information as follows:

• Our vendors, as necessary to provide services on our behalf such as website hosting, analytics, site optimization, communications, marketing, technical support, and customer support.
• Our corporate parent and affiliates, such as Healthfirst, Inc., consistent with the provision of requested Services to you.
• For business transactions, subject to applicable law, in the event of a merger, acquisition, bankruptcy, or other sale or transfer of all or a portion of our assets. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy. If any such transaction occurs and the terms of this Privacy Policy are materially changed as a result, we will provide you with notice before personal information is transferred and becomes subject to a different privacy policy.
• For legal compliance and harm prevention, including to respond to legal process (such as subpoenas, court orders, or search warrants, etc.) or to establish or exercise our legal rights or defend against legal claims. We also may provide information in order to investigate, prevent, or take action regarding illegal activities or wrongdoing; to protect the rights, property, or safety of the Healthfirst Foundation and others; to enforce our agreements and policies; or as otherwise required by law.

We may create anonymous, de-identified, or aggregated data from personal information. We may analyze this data and share our analyses at our discretion. Our use of anonymized, de-identified, or aggregated data is not subject to this Privacy Policy.

4. Cookie Policy

The HF Websites may use cookies and similar technologies to improve user experience, for performance and analytics, and to customize and enhance our content, products, and services. A “cookie” is a small text file that a web server stores in browser software. A browser sends cookies to a server when the browser makes a connection to that server (for example, when requesting a web page from the same domain that created the cookie).

The general purpose of cookies is to remember a browser over time and distinguish one browser instance (or user) from all others. Some cookies and other technologies may track the personal information users provide when they interact with a site, and may store such personal information. We may use first-party and third-party cookies to ensure that our HF Websites and Services function properly, to understand how individuals use and engage with our HF Websites and Services and to analyze and improve HF Websites and Services.

We may use third-party vendors, including Google, who use first-party cookies and third-party cookies together to inform, optimize, and serve advertisements based on your past activity on the HF Websites. The information collected may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand online activity. We encourage you to review Google’s relevant privacy policies. If you do not want any information to be collected and used by Google Analytics, you may be able to install an opt-out in your web browser.

Most browsers are initially set up to accept cookies, but you can reset your browser to block or delete all cookies in your browser’s settings using the links provided below. Please note that if you block essential cookies, certain parts of the HF Websites may not function properly.

• Chrome
• Edge
  - Viewing Cookies
  - Deleting Cookies
• Safari
• Firefox
• Opera

5. Your Rights and Choices

a. Electronic Marketing Communications

To the extent applicable, if you would like to stop receiving our emailed newsletter or other electronic marketing or promotional messages and notifications, you may do so by following the unsubscribe instructions that appear in our email or text communications. You may also be able to manage your electronic communications preferences using the information in the Contact Us section. We will endeavor to comply with these requests as soon as reasonably practicable. Please be advised that you may not be able to opt-out of receiving certain service or transactional email messages from us that are required to provide you with our Services.

b. Accessing, Changing, or Deleting Your Personal Information

You have the right to access your personal information, as well to request to change or delete such information. For your own protection, we may require additional information or contact you to verify your identity before processing your request. We will not fulfill your request unless you have provided sufficient information that enables us to reasonably verify that you are the consumer about whom we collected the personal information on. We will endeavor to comply with your request as soon as reasonably practicable.

6. Data Security and Retention

The privacy and security of your personal information is deeply important to us. To that end, the Healthfirst Foundation maintains technical, administrative and physical safeguards to help protect the security of your personal information against unauthorized access, destruction, loss, alteration, misuse or disclosure. Within the Healthfirst Foundation, your personal information is accessible to only a limited number of personnel who need access to the information to perform their duties. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure.

7. Confidentiality and Use of Email

You are solely responsible for the content of your email messages and other web-based communications. It is important to use your best judgment when sending information to the Healthfirst Foundation via email and similar methods. These communications may pass through private and public networks with varying levels of security. Some, but not all, of these networks may have taken appropriate steps to secure the email transmissions. It is thus possible for the privacy and integrity of an email message to be compromised.

8. International Data Transfers

The HF Websites and Services are operated from within the United States and intended only for web visitors located in the United States. Any collection of personal information from individuals located outside the United States is unintentional and/or incidental.

That said, it is possible that your personal information is transferred outside of your state, country, or other governmental jurisdiction in order for the Healthfirst Foundation to render the collection, use, and sharing practices disclosed elsewhere in this Privacy Policy.

Those jurisdictions may have data protection rules that are different from those of your jurisdiction. If so, we will take measures to ensure that any such transfers comply with applicable data protection laws and that your personal information remains protected to the standards described in this Privacy Policy. Personal information transferred to another country may be subject to lawful access requests by courts, law enforcement agencies, or other government authorities in those other countries.

9. Use by Children

Our HF Websites and Services are not directed toward individuals under the age of 13 (“Children”). We do not knowingly collect personal information from Children, and no personal information should be submitted to our HF Websites by Children. If we learn we have collected or received personal information from a Child, we will delete that personal information as permitted by law. You must be old enough to consent to the processing of your personal information in your country, and you must be at least 18 years of age to use our Services. If you believe we may have any collected personal information from a child under the age of 13 without parental consent, please submit a written request via the email to HIPAAprivacy@healthfirst.org.

10. Links to Other Sites

Our HF Websites and Services may contain links or otherwise provide access to third-party sites, which may include websites or mobile applications. These links are maintained for your informational purposes only and to point you toward the products and services of third parties that we believe may be of interest to you.

Please note that we have no control over and are not responsible for third-party sites, their content, or any products or services available through the third-party sites. Our Privacy Policy does not apply to third-party sites. We encourage you to read the privacy policies of any third-party sites with which you choose to interact.

11. Changes to This Privacy Policy

Advancements in technology will continue to provide us with new and improved ways to collect and use information so that we may better serve your health care needs. We may update this Privacy Policy from time to time to reflect those advances, and we encourage you to regularly return to this page for any updates.

The date this Privacy Policy was last updated is identified at the top of this document. Any changes are effective when we post the revised Privacy Policy on the HF Websites. If we make material changes to this Privacy Policy that expand our rights to collect new personal information or to use differently any personal information that we have previously collected about you, we will use our available contact information about you – if you are an existing Participant – to reasonably notify you of such updates and provide you with the new disclosures by posting it on our HF Websites and/or via email.

12. Contact Information

If you have any questions or concerns about this Privacy Policy or our privacy practices, please do not hesitate to contact us. You can email us, write to us, or call us using the information below:

Healthfirst Foundation, Inc.
100 Church Street, 18th Floor
New York, NY 10007
Email: kerickson@healthfirst.org