Privacy Policy

PRIVACY POLICY

Effective Date: May 18, 2023

This Privacy Policy (this “Privacy Policy”) describes how Affect Therapeutics, Inc. (“Affect” or “Affect Therapeutics”) collects, uses, and stores your information that we gather when you interact with us, including when you use the Services or the Affect App. By using the Services or the Affect App, you accept the terms of this Privacy Policy and consent to our collection, use, and sharing of your information as described in this Privacy Policy. 

In the course of your accessing or using the Services or the Affect App you may interact with healthcare providers (including a Provider) using Affect Therapeutics’ platform. Please note that this Privacy Policy describes how we protect your privacy as a general user of the Services (including the Affect App) and not any information collected from you on behalf of Providers that is protected health information (“PHI”) governed by the Health Insurance Portability and Accountability Act of 1996 (“HIPAA”). Where PHI is collected from you on behalf of your Providers, our HIPAA Notice of Privacy Practices will govern our collection and use of such protected health information, not this Privacy Policy.

1. General Provisions.
   1. Definitions. The following definitions apply to this Privacy Policy:
      1. “Affect App” means collectively (i) the Affect Therapeutics website located at https://www.affecttherapeutics.com/, (ii) any other website set up by Affect Therapeutics in connection with scheduling or delivering the Services, and (iii) the Affect Therapeutics mobile application (the “Affect App”);
      2. “Providers” mean the healthcare professionals and Affect Provider Group, P.S.C. or another professional corporation with which Affect contracts (each, a “Professional Corporation”)who offer or schedule their services through the Affect App. Providers contract with Affect Therapeutics to provide certain Services. Depending on the state that you are located in, Services may be provided to you by: (i) Affect or (ii) a Professional Corporation with certain management services being provided by Affect;
      3. “Services” mean the Affect App and the website, www.affecttherapeutics.com, and other products and services; and
      4. “User” or “you” means an individual user (such as you) who is using the Services. 
2. The Information We Collect. 
   1. Information you provide to us. We collect the information that you provide to Affect Therapeutics, such as when you fill out any information form, including for account creation, scheduling or otherwise in connection with the Services. The categories of personal information that we may collect include:
      1. Contact information and identifiers (such as name, email address, mailing address, phone number, electronic signature, federal or state-issued professional identification information, and emergency contact information);
      2. Biographical and demographic information (such as date of birth, age, gender, race, height, weight, ethnicity, marital status, and sexual orientation);
      3. Health and medical information (such as medical insurance details, information about physical and mental health conditions and diagnoses, treatments for medical conditions, genetic information, family medical history, healthcare provider information, disease state, activity metric – such as steps taken, exercise, calories burned, heart rate, eating and sleeping habits, etc – medications an individual may take, including the dosage, timing, and frequency, and adverse event information);      
      4. Payment-related information we need to complete a transaction (such as credit card number, billing address, and financial account information);
      5. Employment-related information, including job title, professional experience, education, performance history, and compensation;
      6. Username and password that you may select in connection with establishing an account on the Affect App;
      7. Your photograph, social media handle or digital or electronic signature; and
      8. Information that you post or provide through the Affect App or through social media.
   2. Information automatically collected through the Affect App or the Services. We may collect information such as your Internet Protocol (“IP”) address or location information (if available from your IP address or your service provider’s IP address), activity or usage information relating to your use of the Affect App or the Services, and device information, such as hardware, operating system, browser, and website preferences. We use cookies and other data collection technologies to gather such information. If you are accessing the Affect App on your mobile device or using the Affect App, you may also choose to provide us with geolocation data, e.g., your physical location or movements. For more information on our use of such technologies, please see Section 5 below. 
   3. Information from other sources. We may collect information from other sources, including public sources. This information includes demographic information.
3. Information Use. We may use information about you for various purposes, including to:
   1. Provide, maintain and improve our Services;
   2. Provide and deliver the Services you request, and send you related information,
   3. Send you technical notices, updates, security alerts and support and administrative messages;
   4. Respond to your comments, questions and requests and provide customer service;
   5. Communicate with you about products, Services, offers, promotions, rewards, and events offered by Affect Therapeutics and others, and provide information we think will be of interest to you;
   6. Monitor and analyze trends, usage and activities in connection with our Services;
   7. Conduct research and measurement activities;
   8. Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of Affect Therapeutics and others; and
   9. Carry out any other purpose to which you consent.

We also may use aggregated or de-identified information, which cannot reasonably be used to identify you. Once de-identified and aggregated so that data does not personally identify you, it is no longer personal information. Such de-identified or aggregated information which does not identify individuals is not subject to this Privacy Policy, and we may use or disclose it in our discretion.

1. Information Disclosure. 

We do not share your information with third parties, except as set forth below. All of the categories of information described in Section 2 above may be shared as described below. 

1. To our subsidiaries and affiliates.
2. With service providers. We may share your information with third-parties that provide services to us in connection with our business, including to maintain the Affect App and to provide Services. It is our policy to require our service providers to keep the information confidential and to not use the information outside of our business relationship. 
3. With business partners. We may share your information with our business partners, such as Providers and insurers, to enable them to provide services to us or to you. 
4. Sales and Acquisitions. We may disclose your information with a third-party in the event of our merger, acquisition, reorganization, sale of assets, or similar transaction, or in the event of bankruptcy.
5. As Required By Law or In Connection With Legal Rights. We may disclose your information if, in our sole discretion, we believe it reasonable or necessary (a) to comply with the law, (b) in cases of medical emergency, abuse, neglect, or a court order, (c) to prevent illicit or unethical activity, (d) to protect and defend our, your, or others’ rights, property, safety, or interests, or (e) to detect, prevent, or respond to fraud, misuse of the Affect App or the Services, or other violations of law.
6. With Your Consent. We may otherwise disclose your information if we have your consent.
7. For any other purpose disclosed by us when you provide the information.
8. Cookies and Other Data Collection Technologies. We use cookies and other data collection technologies. Cookies are files through which small amounts of data are sent to your computer from a web server and stored on your computer. The types of personal information that we may collect using these technologies are described in Section 2 above. We also use  Google Analytics (website analytics tool) to provide usage statistics and support your access to and use of the Affect App. Google Analytics uses cookies to collect information, such as the number of visitors to the website, the pages visited, and the length of time on the Affect  App. To learn more about how Google Analytics uses and shares your information and what choices you have, please visit https://www.google.com/policies/privacy/partners/ and https://www.google.com/analytics/terms/us.html.]  

If you do not want the Affect App or the Services to collect information through the use of cookies and similar data collection technologies, your browser may allow you to manage and reject the use of cookies. Each browser is different, so you should check your browser’s “Help” menu to learn more about changing cookie settings. If you reject or block cookies, you may lose some of the functionality or features of the Affect App or certain Services. Some web browsers have a “do-not-track” feature that informs websites with which the browser communicates to not track the user’s online activity. The Affect App does not currently respond to these “do-not-track” signals or similar mechanisms. 

1. Your Choices. 
   1. Opt-Out from Marketing Emails. If you no longer wish to receive marketing emails from us, you may unsubscribe by clicking the “unsubscribe” link in the emails or by contacting us using the information in the “Contact Us” section below. Please note that even if you opt-out of receiving marketing emails from us, you may continue to receive emails from us that are unrelated to marketing, such as administrative emails, emails concerning our legal rights and obligations, and other important communications.
   2. Updates to Your Information Through Your Account. If you have an account for the Affect App, you may review and make changes to your information through your account.
   3. Opt Out of Internet-Based Advertising. You may be able to opt out of the use of your information for tailored advertising. For more information about interest-based advertising, or to opt out of having your web browsing information used for targeted advertising purposes, please visit the Digital Advertising Alliance and the Network Advertising Initiative.
   4. You may request deletion of your personal information by making such request of us. However, please be aware that we may be required (by law or otherwise) to keep such data and not delete it (or to retain it for a certain period of time, in which case it will be deleted after the required retention period). By deleting your personal information, we will remove it from active databases, however, it may remain in archives and we also may continue to use de-identified information about your use of Services. If we have disclosed personal information to third parties as permitted under this Privacy Policy, we may no longer be able to access this data and be able to compel its deletion or modification by such party. After we delete personal information, we may retain de-identified information and will continue to use de-identified information as permitted under this Privacy Policy.
2. Security. Affect Therapeutics takes reasonable steps to protect your information. However, no information is 100% secure, and we cannot guarantee the security of your information.
3. Children’s Privacy. The Affect App and the Services are not directed to, nor do we knowingly collect or sell personal information (as such term is defined under the U.S. Children’s Online Privacy Protection Act) from, children under the age of 18 without the verifiable consent of the child’s parent or guardian. If you become aware of a child providing his or her personal information without parental or guardian consent, please contact us using the contact information listed in the “Contact Us” section below.
4. Third Party Websites. The Affect App and the Services may link to or reference third-party websites (“Linked Websites”). We do not control and are not responsible for any Linked Websites, and you use such websites and services at your own risk. We encourage you to read the privacy policies and other legal documents applicable to such Linked Websites prior to using them.
5. International Data Transfers. Affect Therapeutics is located in the United States and is subject to United States law. If you are accessing the Services or the Affect App from outside of the United States, please be aware that United States law may have different standards that apply to how personal information may be used than in your jurisdiction. By accessing and using the Services or the Affect App, you consent to the transfer to and processing of your personal information in the United States.
6. Changes To This Privacy Policy. Affect Therapeutics reserves the right to modify, amend, add to, replace or remove this Privacy Policy at any time. If we make changes to this Privacy Policy, we will notify you by posting a new Privacy Policy on this page, with an updated effective date.
7. Contact Us. If you have any questions, comments, or concerns about this Privacy Policy, you can contact Affect Therapeutics at: 

Affect Therapeutics, Inc.
1640 Boro Place, 4th Floor
McLean, VA 22102
(323) 522-2218

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