Last modified: 01 August, 2024

 

Introduction

MedLink Global, Inc. ("MedLink" or "We") respect your privacy and are committed to protecting it through our compliance with this policy.

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This policy describes the types of information we may collect from you or that you may provide when you visit our website [www.medlink.global] (the "Website") and related websites, applications, and services owned and operated by MedLink and that link to this Privacy Policy (collectively, the “Services”).

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This policy applies to information we collect:

• On this Website.

• In email, text, and other electronic messages between you and this Website.

• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
   

It does not apply to information collected by:

• Us offline or through any other means, including on any other unrelated website operated by MedLink or any third party; or 

• Any third party, including through any application or content (including advertising) that may link to or be accessible from or through the Website.
   

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using this Website, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates. 

 

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website (collectively, “Personal Information” or “Personal Data”, as defined under applicable state law), including information:

• By which you may be personally identified, such as name, address, email address, telephone number, date of birth, credit or debit card number (for payment purposes only), gender, medical history and health information;

• About your internet connection, the equipment you use to access our Services, and usage details.
   

We collect this information:

• Directly from you when you provide it to us;

• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies; and

• From third parties, for example, our business partners.
   

Information You Provide to Us  

The information we collect on or through our Website may include:

• Information that you provide by filling in forms or questionnaires on our Website. This includes information provided at the time of registering to use our Website, or during the evaluation and treatment recommendation process. We may also ask you for information when you report a problem with our Website.

• Records and copies of your correspondence (including email addresses), if you contact us.

• Details of transactions you carry out through our Website and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our Website.
   

Information We Collect Through Automatic Data Collection Technologies  

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website.

• Information about your computer and internet connection, including your IP address, operating system, and browser type.
   

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 our Website and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.

• forecast future needs, functions, and uses of our Website and related applications.

• Store information about your preferences, allowing us to customize our Website according to your individual interests.

• Speed up your searches.

• Recognize you when you return to our Website.
   

The technologies we use for this automatic data collection may include:

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website. For information about managing your privacy and security settings for cookies, see Choices About How We Use and Disclose Your Information.

• Web Beacons. Pages of our Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit MedLink, for example, to count users who have visited those pages and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity). 
   

We do not collect personal information automatically, but we may tie non-personal information collected automatically to personal information about you that we collect from other sources or that you provide to us.

 

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on the Website are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content. 
 

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see Choices About How We Use and Disclose Your Information.

 

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our Website and its contents to you.

• To provide you with services such as matching you with an evaluation psychologist or a psychiatrist based on a proprietary artificial intelligence (AI)-augmented algorithm.

• To respond to your inquiries, fulfill your requests, and send you communications that you ‎request.

• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.

• To send administrative ‎information to you, for example, information regarding the Website and related applications as well as changes to our terms, ‎conditions and policies.

• As we believe to be necessary or appropriate, and only as permitted under applicable law: (a) to ‎comply with legal process; (b) to respond to requests from public and government authorities, ‎including public and government authorities outside your country of residence; (c) to protect our ‎operations or those of any of our affiliates, including in connection with investigating security ‎incidents; or (d) to protect our rights, privacy, safety or property, or that of our affiliates, you ‎or others.‎

• For any other purpose as you may consent or as may be authorized or required by applicable law.
   

We may also use your information to contact you about services that may be of interest to you, including through newsletters. If you wish to opt-out of receiving such communications, you may do so at any time by clicking unsubscribe at the bottom of these communications. For more information, see Choices About How We Use and Disclose Your Information.
 

We may use the information we have collected from you to enable us to display advertisements to our advertisers' target audiences. Even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

 

Health Information

Some information MedLink collects constitutes protected health information (“PHI”) under the U.S. Health Insurance Portability and Accountability Act (“HIPAA”). The HIPAA Notice, which is available on your profile page after you log in, describes how we can use and share your PHI and also describes your rights with respect to your PHI. To the extent that there is a conflict between this Privacy Policy and the HIPAA Notice with respect to PHI, the HIPAA Notice will prevail.

 

Disclosure of Your Information

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our affiliates and third party service providers that we use to support our business. The services provided by these organizations include providing IT and infrastructure support services, and payment processing services.

• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by MedLink about our Website users are among the assets transferred;

• To fulfill the purpose for which you provide it. For example, we may disclose your Personal Information to an evaluation psychologist or a matched psychiatrist.

• For any other purpose disclosed by us when you provide the information.

• With your consent.
   

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.

• To enforce or apply our terms of use and other agreements, including for billing and collection purposes.

• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of MedLink, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

 

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information: 

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this site may then be inaccessible or not function properly.

• Promotional Offers from MedLink. If you do not wish to have your email address used by MedLink to promote our own or third parties' products or services, you can opt-out by clicking the unsubscribe link at the bottom of any promotional emails or other marketing communications you receive from us. This opt out does not apply to information provided to MedLink as a result of your use of our services. 

• Targeted Advertising. We do not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

 

Accessing and Correcting Your Information

You can review and change your Personal Information by logging into the Website and visiting your account profile page.
 

You may also send us an email at info@medlink.global to request access to, correct, or delete any Personal Information that you have provided to us. We cannot delete your Personal Information except by also deleting your user account. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.

California and Colorado residents have additional rights with respect to accessing and Correcting Personal Information, as described in the Privacy Rights for California and Colorado Residents, below.

 

Data Security

We seek to use administrative, physical, and technical safeguards that are reasonable ‎and appropriate for the protection of the Personal Information in our custody or control. We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. We use application timeouts and encryption technology for information sent and received by us.

The safety and security of your information also depends on you. Where you have chosen a password for the use of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
 

‎Unfortunately, no data transmission or storage system can be guaranteed to be 100% ‎secure. Although we work diligently to try and protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Website. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained in your browser or operating system.

 

Your State Privacy Rights

The California Consumer Privacy Act (“CCPA”) and the Colorado Privacy Act (“CPA”) provide residents of those states with certain additional privacy rights as described below.
 

These California and Colorado Privacy Rights supplement the other information contained in our Privacy Policy and apply solely to visitors, users, and others who reside in the State of California or the State of Colorado (“consumers” or “you,” when either term is used in the applicable section).
 

Please note that these laws expressly exclude information regulated as protected health information (PHI) collected by a “covered entity” (e.g., a health care provider or insurance plan) or “business associate” (e.g., MDLIVE) that provides services to covered entities subject to HIPAA. In addition, the CCPA also excludes information regulated under the California Confidentiality of Medical Information Act (CMIA).

 

California Privacy Rights

To the extent you are a California resident, you may have the following rights regarding your Personal Information:

• Right to Access: After we have held your Personal Information for 12 months, you have the right to request from us (up to twice per year and subject to certain exemptions), regarding the Personal Information we collected in the prior 12 months: (i) categories of Personal Information about you we have collected; (ii) the sources from which we have collected that Personal Information; (iii) our business or commercial purposes for collecting, selling, or disclosing that Personal Information; (iv) the categories of third parties to whom we have disclosed that Personal Information; and (v) a copy of the specific pieces of your Personal Information we have collected.

• Right to Correct: You have the right to request that we correct inaccuracies in your Personal Information.

• Right to Delete: Subject to certain conditions and exceptions, you may have the right to request deletion of Personal Information that we have collected about you.

• Right to Opt-Out of Sale/Sharing: The categories of sources that we collect Personal Information and Sensitive Personal Information and our business and commercial purposes for using this information are set forth above. We do not "sell" or "share" your Personal Information. You may remove or adjust your cookie preferences on your device or browser as they permit, and you may contact us to exercise your rights at any time.

• Right to Non-Discrimination: We will not discriminate against you for exercising any of the rights described in this section.

• Authorized Agent: You may designate someone as an authorized agent to submit requests and act on your behalf. To do so, you must provide us with written permission to allow the authorized agent to act on your behalf.
   

To make a request for the rights described above, please contact us at info@medlink.global. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access twice within a 12-month period.
 

Please note that the verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative. We specifically request that you provide us with the following information: (1) first and last name; (2) email address; (3) date of birth; and (4) address. We will take steps to verify your request by matching the information provided by you with the information we have in our records. In some cases, we may request additional information in order to verify your request or, where necessary, to process your request.
 

Your request must also include sufficient detail to allow us to properly understand, evaluate, and respond to it.

 

Colorado Privacy Rights

Under the CPA, Colorado residents have the right to receive certain disclosures regarding a business’ processing of “Personal Data,” as defined under the CPA, as well as certain rights with respect to our processing of such Personal Data. To the extent you are a resident of Colorado, and we collect Personal Data subject to applicable Colorado law, the following applies.

• Right to Access: You have the right to confirm whether or not we are processing your Personal Data and to access such Personal Data.

• Right to Correction: You have the right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of your Personal Data.

• Right to Deletion: You have the right to delete the Personal Data provided to us by you.

• Right to Data Portability: You have the right to obtain a copy of the Personal Data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit your Personal Data to another controller without hindrance, where the processing is carried out by automated means.

• Right to Opt-Out of Sale, Targeted Advertising, and Profiling: For purposes of the CPA, a “sale” includes disclosing Personal Data to a third party in exchange for monetary compensation or other valuable consideration. We do not “sell” Personal Information under this definition. You may remove or adjust your cookie preferences on your device or browser as they permit, and you may contact us to exercise your rights at any time.

• Right to Appeal: If we decline to take action regarding your request, you have the right to appeal. We will notify you providing our reasons and instructions for how you can appeal the decision. You have the right to contact the Colorado Attorney General if you have concerns about the result of the appeal.
   

If any of the rights described in the sections above apply to you, you may make a request by contacting us at info@medlink.global. Please indicate that you are making a request pursuant to your “Colorado Privacy Rights” and provide us with the following information: (1) first and last name; (2) email address; (3) physical address; and (4) date of birth. We will take steps to verify your request by matching the information provided by you with the information we have in our records.

 

Children’s Privacy

The Services are not directed to or intended for use by children under 13 years of age. If you are a child under the age of 13, please do not attempt to register for or otherwise use the Services or send us any Personal Information. By accessing, using, and/or submitting information to or through the Services, you represent that you are over the age of 13. As noted in the Terms of Use, we do not knowingly collect or solicit Personal Information from children under the age of 13. If we learn that we have received any Personal Information directly from a child under age 13 without first receiving their parent’s verified consent, we will use that Personal Information only to respond directly to that child (or their parent or legal guardian) to inform the child that they cannot use the Services. We will then subsequently delete that child’s Personal Information. If you believe that a child under 13 may have provided us with Personal Information, please contact us at info@medlink.global.
 

If you are between the age 13 and the age of majority in your place of residence, you may use the Services only with the consent of or under the supervision of your parent or legal guardian. If you are a parent or legal guardian of a minor child, you may, in compliance with the Agreement, use the Services on behalf of such minor child. Any information that you provide us while using the Services on behalf of your minor child will be treated as Personal Information as otherwise provided herein.
 

If you use the Services on behalf of another person, regardless of age, you agree that MedLink may contact you for any communication made in connection with providing the Services or any legally required communications. You further agree to forward or share any such communication with any person for whom you are using the Services on behalf.

 

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users' personal information, we may notify you of such changes through your contact information and invite you to review (and accept, if necessary) the changes. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

 

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at info@medlink.global.