Privacy Policy

Last Updated:

November 01, 2023

This Privacy Policy applies to Qi Healing, Inc., products and services, including www.qihealth.io and any other websites, pages, features or content we own or operate, or that links to this Privacy Policy (collectively, the “Services”). When you use these Services, this Privacy Policy applies to your use.

If you have questions about our Privacy Policy, please contact us at privacy@qihealth.io. You should read our entire Privacy Policy to understand how we use your data, but if you only have a few minutes you can take a look at the summary below.

PRIVACY HIGHLIGHTS

Information We Collect. We generally collect the following information:

• Account Information: information we collect at registration, including your name, phone number, address and email address.
• Self-Reported Information: information you provide to us, such as ratings, survey answers, or preferences.
• Health Information: information you provide to us or our Traditional Chinese Medicine Doctor Team, related to your physical, mental or other health conditions.
• Device Information: information about the computer or device that you use to access our Services. This could include device attributes like the IP address, operating system, browser type, or app version, device IDs, and other identifiers associated with your device.
• Log Information: information related to the ways in which you interact with the Services, such as referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information.
• Location-Related Information: information about your location, such as your IP address.
• Cookie Information: information on how you use the Services, or how your devices access the Services is collected via the use of cookies, web beacons, mobile device identifiers, and other technologies.

How We Collect Your Information

• From You
• Through Your Use of the Services
• From Third Parties

Your Choices. It’s your data, you’re in control.

• Communications. We provide you with choices about communications you receive from us.
• Access and Correction: You can request access and correct information via your account settings, or by contacting us.

Deletion: You can delete your Qi Health account and data at any time by contacting us, at privacy@qihealth.io.

FULL PRIVACY POLICY

1. Information We Collect

When we say “Personal Information” we mean information that identifies you personally, and use this as a general term to refer to the different categories we describe in this section.

We may collect the following types of Personal Information:

• Account Information. Information such as your name, user ID, password, date of birth, billing address, payment information, or other contact information (e.g., email or phone number).
• Self-Reported Information. Information you choose to provide, such as ratings, survey answers, or preferences, to us.
• Health Information. Information you provide to us or our Medical Team, related to your physical, mental or other health conditions.
• Device Information. Information about the computer or device that you use to access our Services. This could include device attributes like the IP address, operating system, browser type, or app version, device IDs, and other identifiers associated with your device.
• Log Information. Information related to the ways in which you interact with the Services, such as referring and exit pages and URLs, platform type, the number of clicks, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information.
• Location-Related Information. Information about your location, such as your IP address or zip code.
• Cookie Information. Information on how you use the Services, or how your devices access the Services is collected via the use of cookies, web beacons, mobile device identifiers, and other technologies. We do not support the Do Not Track browser option.

Aggregate Information. Aggregate Information is information that is stripped of identifying information, like your name or email, and is combined with that of other individuals, and analyzed as a whole, so no single individual can be identified. Aggregate Information is considered non-personal information for purposes of this Privacy Policy, and we may disclose it to others without limitation for any purpose, in accordance with applicable laws and regulations.

2. How We Collect Information

• From You: We collect information from you when you provide it to us directly, such as information provided during account registration or during a telehealth visit, through the messages you send us, or information you directly authorize to share with us from another entity, like lab test results.
• Through Your Use of The Services. We may collect information about you through your use of the Services, such as through service providers who use a variety of technologies and tools to collect such information, such as cookies, web beacons, and other technologies when you visit or interact with our Services. For more detail on how we use Cookie Information, please see our Cookie Policy.
• From Third Parties. We may obtain additional information about you from third parties, such as marketers, partners, researchers, and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any Services we provide. We may use third-party website analytics services in connection with the Services, including, for example, to note mouse clicks, mouse movements, scrolling activity and text that you type into the Website or App.

3. How We Use Information

We use your information to:

• Provide, develop, maintain, operate, improve, enhance, administer, protect, and troubleshoot our Services and your experience with them;
• Track and analyze trends and usage of the Services;
• Communicate with you, including customer support, reminders about your telehealth appointment, herbal medicine prescription-related notifications, to inform you of our Services, and other offers and information that we believe may be of interest to you;
• Customize and tailor your experience of the Services;
• Secure our systems, prevent fraud and protect the security of Qi Health systems;
• Enhance the security and safety of our Services;
• Verify your identity and prevent, detect, and investigate fraud and other potentially illegal or prohibited activities;
• Enforce, investigate, and report conduct violating our Terms of Service and other policies that govern your use of the Services; and
• Comply with our licensing, legal, and regulatory obligations.

4. How We Share Information

Rest assured, Qi Health does not sell, rent, license, or trade your Personal Information. We may share your Personal Information as follows:

• As Directed by You. When you direct us to share Personal Information, we will do so on your behalf.
• Service Providers. Qi Health may share your Personal Information with other companies that work with, or on behalf of, Qi Health to provide products and services. For example, some of the types of service providers include: payment processors, order fulfillment, marketing and analytics, cloud storage, IT and security vendors.
• Traditional Chinese Medicine Providers and Herbal Pharmacies. Qi Health may share your Personal Information to provide the Services to you, such as treatment, running our alternative healthcare operations, processing payments, herbal pharmacy fulfillment services, and quality assurance reviews.
• As Required by Law, To Prevent Harm and/or in the Public Interest. We may provide Personal Information about you to respond to subpoenas, court orders, legal process or governmental regulations, or to establish or exercise our legal rights or defend against legal claims. Where necessary, we will share information in order to investigate, prevent or take action regarding illegal activities, suspected fraud, safety or security concerns, or as otherwise required by law.
• Business Transfers. We may share your Personal Information with other business entities in connection with the sale, assignment, merger or other transfer of all or a portion of Qi Health’s business to such business entities. This Privacy Policy will apply to your Personal Information as transferred to the new entity.‍
• Affiliates. We may share information with entities within the Qi Healing Inc. family of companies.

5. Your Privacy Choices

We believe you should be in control of your Personal Information. You can make the following choices by contacting the Patient Support Team at privacy@qihealth.io or by sending us a secure message through the Services:

• Communications: You can choose whether we may contact you (such as through email, in-product notifications, push notifications, or text messages) for product or promotional purposes, or certain transactional messages, such as appointment or prescription notifications. Except as required to provide you the Services you requested, you can also ask that we stop sending SMS/text messages by replying “STOP.”. You can also click “unsubscribe” at the bottom of promotional email communications.
• Access: You can access and download your Personal Information processed by Qi Health.
• Correction: You can correct certain account information, such as email address or phone number associated with your account. You can also make these changes in your account settings.‍
• Deletion: You can delete your Qi Health account at any time. Please keep in mind we are required to retain certain limited information for legal and regulatory purposes, such as information that is part of your medical record.

6. Your Rights With Respect to Health Information

You have certain rights with respect to your Health Information, in accordance with applicable state and federal medical privacy laws. All rights and authorized uses of your health information may be found in Qi Health’s Notice Regarding Information in Your Medical Record.

7. Children’s Privacy

Qi Health is not intended for, or directed toward, individuals under the age of 18. We do not knowingly collect any Personal Information from anyone under 18.

8. How We Use Your Personal Information

Qi Health may share Personal Information listed above for operational business purposes or at your direction. Such business purposes include:

• Providing Services: To provide our Services to you, including maintaining or servicing your account, providing customer service, processing or fulfilling orders and transactions, and more.
• Audit: Auditing related to a current interaction and concurrent transactions.
• Security: Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity.
• Debugging: Debugging to identify and repair errors that impair existing intended functionality.
• Transient Use: Short-term, transient use, where personal information is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer’s experience outside the current interaction.
• Product Research and Development: Research that Qi Health performs to improve and develop its products and services.
• Quality Assurance and Product Improvement: Activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by Qi Health, and otherwise to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by Qi Health.

If you have given your explicit consent, for example via a data transfer authorization or other consent document, we may share your Personal Information for commercial purposes. The purpose may vary and will be described in the consent.

Complaints or Questions: If you believe that we have infringed your rights, we encourage you to contact us so that we can try to address your concerns or dispute informally. Our contact information is:

Qi Healing, Inc.

℅ CSL

69 Charlton Street

New York, NY 10014

privacy@qihealth.io

9. User-Generated Content and Image Uploads

When you choose to upload pictures or any other form of user-generated content (collectively referred to as "Content") to our platform, you acknowledge and agree to the terms outlined in this section. By submitting Content, you grant Qi Healing Inc a non-exclusive, transferable, sub-licensable, royalty-free, worldwide license to use, reproduce, distribute, prepare derivative works of, display, and perform the Content in connection with the services provided by Qi Healing Inc, including but not limited to marketing, promotional activities, and educational initiatives.

Ownership and Control

You retain ownership of the Content you upload to our platform. However, by submitting Content, you grant Qi Healing Inc the right to use, modify, adapt, and reproduce it for the purposes stated herein. Qi Healing Inc will not sell or transfer your Content to third parties for direct monetary gain without your explicit consent.

Marketing and Promotional Activities

Your uploaded Content may be used by Qi Healing Inc for marketing and promotional activities, both online and offline. This includes but is not limited to featuring your Content on our website, social media channels, advertising materials, and other promotional mediums. We may also use your Content to showcase the capabilities and features of our platform.

Educational Initiatives

In addition to marketing and promotional activities, Qi Healing Inc may use your Content for educational purposes, such as tutorials, case studies, or other informative materials. This may involve sharing your Content with our user community to demonstrate the diverse ways in which our platform can be utilized.

User Visibility and Settings

We respect your privacy, and Qi Healing Inc understands the sensitivity of certain Content. Therefore, we provide users with controls and settings to manage the visibility and accessibility of their uploaded Content. You can adjust your privacy settings to limit the usage and visibility of your Content as per your preferences.

Termination of License

You can revoke the license granted to Qi Healing Inc at any time by deleting your Content from our platform. However, please note that content shared publicly before such deletion may continue to be used by Qi Healing Inc in accordance with the terms of this policy.

10. Changes to this Privacy Policy

We may revise this Privacy Policy from time to time. We’ll let you know about those changes here, or by contacting you, such as via email to the email address associated with your account. We display the "Last Updated" date on the policy in the upper left corner of this Privacy Policy so that it will be easier for you to know when there has been a change. We may also provide additional notice, such as an in-app notification, or on another website page or feature. Small changes or changes that do not significantly affect individual privacy interests may be made at any time and without prior notice.

11. How to Contact Us

If you have questions about this Privacy Policy, or have a complaint or inquiry, please email us at compliance@qihealth.io, or send a letter to:

Qi Healing, Inc.

Attn: Privacy Officer

℅ CSL

69 Charlton Street

New York, NY 10014

NOTICE REGARDING INFORMATION IN YOUR MEDICAL RECORD

Summary:

This Notice Regarding Information in Your Medical Record Notice (“Notice”) applies to Qi Health and details how Qi Health uses, protects, and discloses information contained in the record that we maintain regarding the health care that we provide to you (your “Medical Record”). Please note, your Medical Record contains only a limited set of Personal Information. For example, it may include demographic information (e.g., your name, address, gender, or age), diagnosis, or communications with a provider. It applies to all Medical Records created, controlled, or otherwise maintained by Qi Health. To keep things simple, all capitalized terms have the same meaning as our Privacy Policy and Terms of Use.

We encourage you to read the entire Notice, but here are the key highlights:

How We Use or Share Your Medical Record:

• To provide treatment
• To provide Services
• To comply with your instructions
• As required by law
• To disclose threats to health or safety
• To comply with public health reporting requirements

You Can:

• Get a copy of your Medical Records
• Request corrections to your Medical Record if it is inaccurate or incomplete
• Request to limit sharing or use of your Medical Record
• Tell us how you want us to share information with family or others involved in your care
• Delete your Account

Full Notice Regarding Information in Your Medical Record

Our Pledge Regarding Your Medical Record

Your health care treatment is personal to you and we understand the importance of protecting your Medical Record. This Notice applies to all Medical Records we create, control, or maintain, and outlines the ways your information in those records are used or shared, and what your choices are.

What is a Medical Record

Please note, your Medical Record contains only a limited set of Personal Information that relates to the health care we provide to you. For example, it may include demographic information, diagnosis, or communications with a provider.

To understand how all your Personal Information is handled by Qi Health, please review our Privacy Policy. To the extent there are any conflicts between the Privacy Policy and this Notice related to your Medical Record, this Notice will govern.

In some circumstances, your Medical Record could have additional information about your health that we give special consideration to protecting. Examples of this information include, but are not limited to, psychotherapy or mental health notes, results related to sexually transmitted infection(s) (“STI”), or genetic information. We require additional authorization from you before we use or share that information.

How We Use and Share Your Medical Record

The following categories describe ways that we may use or share your Medical Record.

• For Treatment. We share your Medical Record in the course of providing Traditional Chinese Medicine medical treatment or consultation or in coordinating or managing any Services you’ve received or requested. For example, we may share your Medical Record with members of our Medical Team involved in your care to provide an additional consult or to fill a herbal medicine prescription.
• For Providing Services. We may use and share your Traditional Chinese Medicine Medical Record to carry out our business operations and be able to provide the Services to you. These uses or disclosures are related to things like billing or fulfilling herbal medicine prescriptions, quality of care, compliance activities, administrative purposes, contractual obligations, grievances, or legal obligations. For example, we may use information in your Traditional Chinese Medicine Medical Record to review the treatment and services provided or to evaluate the performance of the staff and contractors caring for you.
• To Comply with Your Instructions. We will share your Traditional Chinese Medicine Medical Record as directed by you. For example, if you choose to share your Traditional Chinese Medicine Medical Records with a third party available on the Services, we will do so with your consent.
• As Required by Law. We will share your Traditional Chinese Medicine Medical Record when required to do so by federal, state, or local law. In certain circumstances, Qi Health may be required by law to comply with a valid court order, subpoena, or search warrant for a Traditional Chinese Medicine Medical Record. As permitted under applicable law, we will provide notice to you prior to sharing your Traditional Chinese Medicine Medical Record.
• Disclosure for Threats to Health and Safety. In certain circumstances, we are required to share your Traditional Chinese Medicine Medical Record to help protect you or someone else’s health and/or safety. For example, we may ask local law enforcement to perform a health and welfare check if, in our provider’s professional judgment, a welfare check is necessary.

Special Considerations

In certain situations, some sensitive information in your Medical Record will not be used or shared without your written authorization, unless required by law. One example of types of information that need specific authorization:

• Genetic Information. This is any information about your individual genotype, including results of any genetic test.
• Psychotherapy Notes. We do not create psychotherapy notes in your Medical Record since mental health counseling is not a part of our Traditional Chinese Medicine medical team’s care.
• STI Test Results. This is information related to any sexually transmitted infection(s) you experience.
• HIV/AIDS Results. This is information related to any HIV or AIDS test results.

Control of Your Medical Record You have control over your Medical Record. You can request the following by contacting the Health Care Compliance Team at the address below.

• Copy of your Medical Record. With certain exceptions, you may receive copies of your Medical Record, which may include information such as your diagnosis, provider notes, and treatment plan.
• Correction. If you believe that information in your Medical Record is incorrect or incomplete, you may ask us to correct the information.
• List of Disclosures. You may request a list of certain third parties we have shared your Medical Record with in the past 12 months.
• Request Us to Limit How We Use or Share Your Medical Record. You can request that we limit how we share your Medical Record with your family members or others involved in your care. If you provide any written authorization to disclose your Medical Record, you are free to revoke your authorization at any time in writing. After receiving the request, we will stop any further use or sharing of your Medical Record, except in cases where we have already acted based on your previous permission. We are unable to undo any disclosure already made with your permission.
• Request Confidential Communications. You can request that we communicate with you about your appointments or other health care matters in a specific way. We’ll do our best to accommodate your reasonable request but may be unable to if it causes significant operational or administrative burdens.
• Account Deletion: As mentioned in our Privacy Policy, you are free to delete your account at any time. We may retain all or part of your Medical Record after you close your account for a limited period of time as required by law, contractual obligations, as necessary for the establishment, exercise or defense of legal claims, audit and/or compliance purposes.

In some circumstances, we may not be able to accommodate your request if it conflicts with our legal obligations, the request is manifestly unfounded or excessive, or it affects our ability to provide the Services.

Contact Us

If you have any questions about how we use or share your Medical Records, please contact us at:

Qi Healing, Inc.

℅ CSL

Attn: Compliance Team

69 Charlton Street

New York, NY 10014

Email: privacy@qihealth.io

Changes to this Notice

We reserve the right to change and make updates to this Notice from time to time. These changes will be effective for all Medical Records that we maintain and control. We will post our most current version of this document on our website. Whenever material changes to this Notice are made, we will provide you with notice before the modifications are effective, such as by posting a notice on our website or sending a message to the email address associated with your account.

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