Privacy Policy

This Privacy Policy describes how Lyv Health, Inc. (DBA Altro Health) and its corporate (collectively, “Altro,” “we,” “us” or “our”) process personal information that we collect or otherwise generate through our digital or online properties or services that link to this Privacy Policy (including as applicable, our website, mobile applications, social media pages) as well as our marketing activities, live events and other activities described in this Privacy Policy (collectively, the “Service”).
Altro may process personal information that identifies your past, present, or future health or mental health status, or that otherwise constitutes “consumer health data” or equivalent terms as defined by applicable U.S. state laws (“Consumer Health Data”). To the extent such laws apply to your Consumer Health Data, please see our Consumer Health Data Privacy Policy, which supplements this Privacy Policy.
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This Privacy Policy does not apply to:
·       “protected health information” (“PHI”) that we receive from and process on behalf of “covered entities” (as the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”) defines such terms). Our use of this information is governed by our agreements with the applicable covered entities. If you have questions regarding personal information that we process on behalf of a covered entity, please direct your concerns to the relevant imaging center or covered entity. To the extent that you have signed a release or otherwise effectuated an authorization that allows the relevant covered entity to disclose your personal information to Altro, this Privacy Policy applies to that information.
·       personal information that we process on behalf of wellness providers or other third parties with which you engage via the Service and to which we provide services (collectively, “clients”), [2] but which is not governed by HIPAA as PHI. Our use of information that we process on behalf of our clients is governed by our agreements with each client. If you have concerns regarding your personal information that we process on behalf of our clients, please direct your concerns to the client with which you have a relationship.

Index
●   Personal information we collect
●   How we use your personal information
●   How we share your personal information
●   Your choices
●   Other sites and services
●   Security
●   International data transfers
●   Retention
●   Children
●   Changes to this Privacy Policy
●   How to contact us

Personal information we collect
Information you provide to us or that we generate about you. Depending on how you interact with the Service, the personal information you may provide to us through the Service or that we generate about you or otherwise may include:
●   Contact data, such as your first and last name, salutation, email address, billing and mailing addresses, and phone number.
●   Demographic data, such as your city, state, country of residence, postal code, age, date of birth, gender or gender identity, and assigned sex at birth[4] .
●   Account data, such as the username and password that you may set to establish an online account on the Service, biographical details, photograph or picture, profile alias, preferences, and any other information that you add to your account profile.
●   Health and wearable[5] [CA6] -related data, such as mental or physical history, lifestyle preferences and patterns, conditions and diagnoses, treatments, medications, medical images, lab results, clinical notes, medical or health analyses, scan or medical test, meal choices and dietary preferences, and other physical or mental health information. This may include personal information that you provide directly to us when you complete electronic forms designed for you to self-report your physical or mental health status (for example, questionnaires, surveys, information requests, interviews, results, or other documentary, text, video, or audio interactions related to the provision of our Services), upload medical records, or link a wearable or Internet of Things device to our Services.
●   Audiovisual recording and photographic data, such as video and audio recordings and photos of you.[7] [CA8]
●   Transactional data, such as information relating to or needed to complete your orders on or through the Service, including order numbers and transaction history.
●   Communications data based on our exchanges with you, including when you contact us through the Service, communicate with us via email, phone, chat features, social media, or otherwise.
●   Relationship data, such as familial or other relationship to third parties whose personal information you may provide to us.
●   Payment data needed to complete transactions, including payment card information or bank account number. We use a third-party payment processor to directly collect and process your payment card information, as described further below.
●   Marketing data, such as your preferences for receiving our marketing communications and details about your engagement with them.
●   User-generated content data, such as photos, images, music, videos, comments, reviews, questions, messages, and other content or information that you generate, transmit, or otherwise make available on the Service, as well as associated metadata. Metadata includes information on how, when, where and by whom a piece of content was collected and how that content has been formatted or edited. Metadata also includes information that users can add or can have added to their content, such as keywords, geographical or location information, and other similar data.
●   Derived data, such as inferences about you that we derive or otherwise infer from your personal information.
●   Other data not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.
Third-party sources. We may combine personal information we receive from you with personal information of the kinds identified above that we obtain from other sources, such as:
●   Public sources, such as government agencies, public records, social media platforms, and other publicly available sources.
●   Private sources, such as data providers and social media platforms.
●   Linked third-party services, such as Google or other third-party service that you use to log into, or otherwise link to, your Service account. This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service.[10] [CA11]
●   Linked third-party devices[12] , such as wearable or Internet of Things devices that you link to your Service account (e.g., FitBit, Garmin, Whoop, Oura). This data may include your username, profile picture and other information associated with your account on that third-party service that is made available to us based on your account settings on that service. This may include your device’s health app information and historical data related to your use of the wearable device.
●   Provider partners, including third party healthcare services providers, laboratory and imaging services providers, meal delivery and preparation providers, and other providers of medical and medical-adjacent services.
●   Marketing partners, such as joint marketing partners.
●   Service providers that provide services on our behalf or help us operate the Service or our business.
●   Third parties that you designate, such as medical or healthcare providers with whom we do not have a contractual relationship.
●   Business transaction partners. We may receive personal information in connection with an actual or prospective business transaction. For example, we may receive your personal information from an entity we acquire or are acquired by, a successor, or assignee or any party involved in a business transaction such as a merger, acquisition, sale of assets, or similar transaction, and/or in the context of an insolvency, bankruptcy, or receivership.
Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your interaction over time with the Service, our communications and other online services, such as:
●   Device data, such as your computer or mobile device’s operating system type and version, manufacturer and model, browser type, screen resolution, RAM and disk size, CPU usage, device type (e.g., phone, tablet), IP address, unique identifiers (including identifiers used for advertising purposes), language settings, mobile device carrier, radio/network information (e.g., Wi-Fi, LTE, 5G), and general location information such as city, state or geographic area.
●   Online activity data, such as pages or screens you viewed, search history, how long you spent on a page or screen, the website you visited before browsing to the Service, navigation paths between pages or screens, information about your activity on a page or screen, access times and duration of access, and whether you have opened our emails or clicked links within them.
●   Communication interaction data such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails enabling us to detect if you have opened or forwarded a message.
Tracking technologies. Some of the automatic collection described above is facilitated by the following technologies:
Cookies, which are small text files that websites store on user devices and that allow web servers to record users’ web browsing activities and remember their submissions, preferences, credentials, and login status as they navigate a site. Cookies used on our sites include both “session cookies” that are deleted when a web browser session ends, “persistent cookies” that remain longer, “first party” cookies that we place and “third party” cookies that our service providers and other third parties place.
Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data on your device outside of your browser in connection with specific applications.
Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed, clicked or forwarded.
Chat technologies, such as those provided by third parties that employ cookies and software code to operate the chat features that you can use to communicate with us through the Service. These third parties may access and use information about webpages visited on our website, your IP address, your general geographic information (e.g., city, state), and other personal information you share through online chats to respond to your questions and for the purposes described in this Privacy Policy.
Session-replay technologies, such as those provided by third parties that employ software code to record users’ interactions with the Services in a manner that allows us to watch video replays of those user sessions. The replays include users’ clicks, mobile app touches, mouse movements and scrolls during those sessions. These replays help us diagnose usability problems and identify areas for improvement.
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How we use your personal information
We may use your personal information for the following purposes or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
●   provide, operate and improve the Service and our business;
●   process your requests, orders and transactions;
●   personalize the service, including understanding your needs and interests, remembering the devices from which you have previously logged in and remembering your selections and preferences as you navigate the Service;
●   establish and maintain your user profile on the Service;
●   enable security features of the Service, such as by sending you security codes via email, and remembering devices from which you have previously logged in;
●   communicate with you about the Service, including by sending Service-related announcements, updates, security alerts, and support and administrative messages;
●   understand your needs and interests, and personalize your experience with the Service and our communications; and
●   provide support for the Service, and respond to your requests, questions and feedback.
Insights and development. We may use your personal information for:
insights (including research);
to analyze your usage of the Service, help us understand user activity on the Service, including which pages are most and least visited and how visitors move around the Service, as well as user interactions with our emails; and
development purposes, including to analyze and improve the Service and our business and to develop new products and services.
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Marketing and advertising. We, our service providers and our third-party advertising partners [13] may collect and use certain of your personal information for marketing and advertising purposes:
●   Direct marketing. We may send you direct marketing communications (including in relation to our products and those of others) and may personalize these messages based on your needs and interests. You may opt-out of our marketing communications as described in the Opt-out of marketing[14]  section below.
●   Interest-based advertising. Our third-party advertising partners may use cookies, pixels and other technologies to collect information about your interaction (including the data described in the automatic data collection section above) with the Service, our communications and other third-party online services over time, and use that information to serve online ads that they think will interest you. This is called interest-based advertising. We may also share information about our users with these companies to facilitate interest-based advertising to those or similar users on other online platforms. You can learn more about your choices for limiting interest-based advertising in the Your choices section below.
●   Testimonials. We may use your feedback to post comments about your experience with any Service on the website, in our marketing and promotional materials.
●   Events, promotions and contests. We may use your personal information to administer promotions and contests, communicate with you about events in which you participate, or contact or market to you after collecting your personal information at an event.
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Cookies and similar technologies. In addition to the other uses included in this section, we may use the tracking technologies described above for the following purposes:
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Technical operation. To allow the technical operation of the Service, such as remembering selections as you navigate the site and remembering whether you are logged in.
Functionality. To enhance the performance and functionality of our services.
Analytics. To help us understand user activity on the Service, including the volume and demographics of users, which pages are most and least visited and how users move around the Service or interact with our emails. For example, we use Google Analytics for this purpose. You can learn more about Google Analytics and how to prevent the use of Google Analytics relating to your use of our sites here: https://tools.google.com/dlpage/gaoptout.
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Compliance and protection. We may use your personal information to:
●   comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas, court orders, investigations or requests from government authorities;
●   protect our, your or others’ rights, privacy, health, safety or property (including by making and defending legal claims);
●   audit our internal processes for compliance with legal and contractual requirements or our internal policies;
●   enforce the terms and conditions that govern the Service; and
●   prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
Data sharing in the context of corporate events, we may share certain personal information in the context of actual or prospective corporate events with our advisors, the prospective or actual counterparties to the corporate event and their advisors.
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With your consent. In some cases, we may specifically ask for your consent to collect, use or share your personal information, such as when required by law.
To create aggregated, de-identified and/or anonymized data. We may create aggregated, deidentified and/or anonymized data from your personal information and other individuals whose personal information we collect. We make personal information into deidentified and/or anonymized data by removing information that makes the data identifiable to you. Except as required or permitted by applicable law, we will not attempt to reidentify any data that has been aggregated, deidentified and/or anonymized. We may use this aggregated, deidentified and/or anonymized data and share it with third parties for our lawful business purposes, including to analyze and improve the Service, fine tune or train AI, promote our business, and for research purposes.
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How we share your personal information
We may share your personal information with the following parties and as otherwise described in this Privacy Policy, in other applicable notices, or at the time of collection.
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Affiliates. Such as our corporate parent, subsidiaries and affiliates.
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Service providers. Third parties that provide services on our behalf or help us operate the Service or our business (such as online chat functionality providers, hosting, information technology, customer support, email delivery, marketing, consumer research and website analytics).
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Artificial intelligence providers. We may share personal information with artificial intelligence (“AI”) providers to provide personalized health insights, behavioral guidance, and wellness recommendations. Our AI providers may use your personal information to deliver personalized recommendations and insights, identify trends and generate predictive health signals, improve model performance and safety, and conduct internal research and quality control. We do not permit our third-party AI providers to train on your personal information.
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Payment processors. Any payment card information you- use to make a purchase on the Service is collected and processed directly by our payment processors, such as Stripe. Stripe may use your payment data in accordance with its privacy policy, https://stripe.com/privacy.
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Research partners. We may share personal information with research partners to conduct research.
Advertising partners and ad networks. Third-party advertising companies for the interest-based advertising purposes[18]  described above. We do not provide health and wearable-related information to such advertising partners.
Provider partners. We may share your personal information with healthcare services providers, laboratory and imaging services providers, meal delivery partners, and other providers of medical and medical-adjacent services.
Third parties designated by you. We may share your personal information with other third parties where you have instructed us or provided your consent to do so, including your wellness providers and [insert][20] .
Business and marketing partners. Third parties with whom we jointly offer products or services, or whose products or services may be of interest to you.
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Linked third-party services or devices. If you log into the Service with a third-party service, or choose to link a wearable or Internet of Things device to your Service account, we may share your personal information with that third-party service. The third party’s use of the shared information will be governed by its privacy policy or other relevant terms and the settings associated with your account with the third-party service.
Professional advisors. Professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.
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Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the Compliance and protection purposes described above.
Business transferees and their advisors. We may disclose personal information in the context of actual or prospective business transactions (e.g., investments in or financings of Altro, public stock offerings, or the sale, transfer or merger of all or part of our business, assets or shares, liquidation or reorganization), for example, we may need to share certain personal information with prospective counterparties and their advisers. We may also disclose your personal information to an acquirer, successor, or assignee of Altro or a portion of our business assets as part of any merger, acquisition, sale of assets, or similar transaction, and/or in the event of an insolvency, bankruptcy, or receivership in which personal information is transferred to one or more third parties as one of our business assets.
Other users and the public. Certain user-generated content, including your health and wearable-related data and other data you submit to us may be visible to other users and the public, such as when you post comments in publicly accessible parts of the Service or provide a testimonial that is intended to be public. This information can be seen, collected and used by others, including being cached, copied, screen captured or stored elsewhere by others (e.g., search engines), and we are not responsible for any such use of this information. Once you publish content, it may be copied and stored on third party systems where you might not have the ability to have it deleted.
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Your choices
You may have the following rights with respect to your personal information:
Access or update your information. If you have registered for an account with us through the Service, you may review and update certain account information by logging into the account and navigating to your account profile and settings.
Opt-out of communications. You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us . It may take time for your opt-out to be effective. Please note that if you choose to opt-out of marketing-related emails, you may continue to receive service-related and other non-marketing emails.
If you receive text messages from us, you may opt out of receiving further text messages from us by replying STOP to our message.
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Cookies. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. Please note that if you set your browser to disable cookies, the Service may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit http://www.allaboutcookies.org.
Blocking images/clear gifs. Most browsers and devices allow you to configure your device to prevent images from loading, so the business hosting the image will not detect that you have viewed a page. To do this, follow the instructions in your particular browser or device settings.
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Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
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Advertising choices. You may be able to limit use of your information for interest-based advertising through the following settings/options/tools:
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Browser settings. Changing your internet web browser settings to block third-party cookies.
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Privacy browsers/plug-ins. Using privacy browsers and/or ad-blocking browser plug-ins that let you block tracking technologies.
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Platform settings. Some platforms offer opt-out features that let you opt out of use of your information for interest-based advertising. You may be able to exercise that option for Google and Facebook at the following websites:
o Google: https://adssettings.google.com/
o Facebook: https://www.facebook.com/about/ads
Ad industry tools. Opting out of interest-based ads from companies that participate in the following industry opt-out programs:
o Network Advertising Initiative: http://www.networkadvertising.org/managing/opt_out.asp
o Digital Advertising Alliance: https://optout.aboutads.info
o AppChoices mobile app, available at https://www.youradchoices.com/appchoices, which will allow you to opt out of interest-based ads in mobile apps served by participating members of the Digital Advertising Alliance
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Mobile settings. Using your mobile device settings to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
You will need to apply these advertising-related opt-out
settings on each device and browser from which you wish to limit the use of your information for interest-based advertising purposes. We cannot offer any assurances as to whether the companies we work with participate in the opt-out programs described above.
Training data. As set out in the How We Use Personal Information section, we may use your personal information, provided it is aggregated, de-identified and/or anonymized,] to train our AI models and for other machine learning purposes. This helps improve the Service.
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Mobile location data. You can disable our access to your device’s precise geolocation in your mobile device settings.
Shine the Light law opt out. Under California’s Shine the Light law (California Civil Code Section 1798.83), we give you the right to opt out of our disclosure of your personal information (as defined by this law) to third parties for their direct marketing purposes. You may send us requests to hello@altrohealth.com In your request, you must include the statement “Shine the Light Request," and provide your first and last name and mailing address and certify that you are a California resident. We reserve the right to require additional information to confirm your identity and California residency.
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Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information we identify as required or mandatory, we may not be able to provide those services.
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Linked third-party platforms. If you log into the Service with a third-party service, or choose to link a wearable or Internet of Things device to your Service account, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from such third-party platform, that choice will not apply to information that we have already received from that third party.
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Other sites and services
This Privacy Policy does not apply to third-party websites, applications, products, services or other properties even if they may link to our Service or we may refer you to such third parties as part of our Service. In addition, our content may be integrated into web pages or other online services that are not associated with us. These links, relationships and other integrations are not an endorsement of, or representation that we are affiliated with, any third party. We do not control websites, mobile applications or services operated by third parties, and we are not responsible for their actions. We encourage you to read the privacy policies of the other websites, mobile applications and services you use.
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Security
We employ technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.
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International data transfer
We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Retention
We generally retain personal information to fulfill the purposes for which we collected it, including for the purposes of satisfying any legal, accounting, or reporting requirements, to establish or defend legal claims, or for fraud prevention purposes. To determine the appropriate retention period for personal information, we may consider factors such as length of time we have an ongoing relationship with you and provide services to you; the amount, nature, and sensitivity of the personal information; the potential risk of harm from unauthorized use or disclosure of your personal information; the purposes for which we process your personal information and whether we can achieve those purposes through other means; whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); whether retention is advisable in light of our legal position, such as in regard to applicable statutes of limitations, litigation or regulatory investigations; and applicable legal requirements. For example, we will retain your personal information for as long as you have an account with us or keep using our services, and the length of time thereafter during which we may have a legitimate need to reference your personal information to address issues that may arise.  
When we no longer require the personal information we have collected about you, we may either delete it, de-identify it, anonymize it, or isolate it from further processing.
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Children and Teens
The Service is not intended for use by anyone under 18 years of age. If you are a parent or guardian of a minor from whom you believe we have collected personal information in a manner prohibited by law, or if information was provided on your behalf when you were under 18, please contact us . If we learn that we have collected personal information through the Service from a child without the consent of the child’s parent or guardian as required by law, we will comply with applicable legal requirements to delete the information.
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Changes to this Privacy Policy
The date at the top of this Privacy Policy indicates when this Privacy Policy was last updated. We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service or other appropriate means. Any modifications to this 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 Privacy Policy indicates your acknowledging that the modified Privacy Policy applies to your interactions with the Service and our business.
How to contact us
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If you have questions about our personal information practices or if you would like to exercise any privacy-related right that may be available to you, please contact us via the method listed below.
Email: hello@altrohealth.com