CCAW JV, LLC’s
Website Privacy Policy

Last Revised: 1.19.22

This Privacy Policy applies to the website or mobile application that is linked to this Privacy Policy (the “Services”) provided by CCAW JV, LLC dba The Clinic by Cleveland Clinic or its affiliates (“The Clinic,” “we,” “us,” or “our”).

For the international version, click here

1. General

We know that your privacy is important to you, and we work hard to earn and keep your trust. CCAW JV, LLC d/b/a The Clinic by Cleveland Clinic affiliates and related entities (“Company,” “the Company,” “we,” “us,” and “our,”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”), and any related data, accounts, profiles, forms, and all other content provided therein for the purposes of providing educational virtual second opinion services through the Website (the “Services”).

This Policy describes:

The types of information we collect from you or that you may provide when you visit our website available at:

• https://theclinic.io, https://virtual2ndopinionbycc.io/landing.htm as well as any websites directly owned by the Company (collectively, our “Website”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on this Website or in emails and other electronic messages between you, other users of the Services and the Company, and information gathered when you interact with the Website and Services as disclosed in this Policy. Please read this Policy carefully to understand our practices regarding your information and how we will treat it. If you do not agree with our policies and practices, then please do not use our Website or access the Services. By using our Website, you agree to the terms of this Policy. This Policy may change from time to time (see below, “Changes to this Policy”). Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

2. Website Terms of Use; Other Agreements and Requirements

This Policy should be read in conjunction with any applicable Website Terms of Use, into which this Policy is incorporated by reference.

The laws that protect privacy and the confidentiality of individually identifiable health information, such as the Health Insurance Portability and Accountability Act (“HIPAA”) may also apply to telemedicine and may apply to certain aspects of the Services. Should you engage the Services, you will receive and have the opportunity to review, and you must acknowledge the Company’s Notice of Privacy Practices (“NPP”) prior to participating in the Services. The NPP explains how the Company may use and disclose individually identifiable health information for treatment, payment, and healthcare operations.

However, please note that not all information you provide or use through engagement of the Website or Services is necessarily protected by HIPAA. Regardless, your Personal Information will always be processed in accordance with this Policy. Should there ever be a conflict between this Policy and the NPP with respect to any Personal Information, the NPP shall apply.

3. What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and share information about you in accordance with this Policy.

Information You Provide to Us

Personal information is any information that can be used to individually identify you from a larger group (“Personal Information”), such as data including, but not limited to, your:

• first and last name;
• email address;
• telephone number;
• mailing address;
• date of birth;
• gender;
• healthcare provider reviews;
• health insurance identification number or other health insurance information;
• member login credentials (i.e., usernames and passwords); and
• credit card and other financial account information.

You may provide us Personal Information when you:

• register yourself with the Website;
• schedule an appointment;
• confirm an appointment;
• review or comment on the Services; or
• communicate with us, such as to request information.

The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as when contacting the Company to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers or other sensitive personal or financial data unless required for delivery of the Services.

Additionally, we may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous. Moreover, we may receive information about you from other sources and add it to the information you have provided to us.

Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. Some of the tools we use to automatically collect information about you may include:

(a) Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:

1. session cookies, which do not stay on your device after you close your browser, and
2. persistent cookies, which remain on your device until you delete them or they expire.

We may use the following categories of cookies on our Website.

• Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items (e.g. a shopping cart), cannot be provided.
• Performance Cookies. These cookies collect anonymous information on how you use our Website to help us understand how you arrive at our Website, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
• Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.
• Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks.

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.

(b) Google Analytics. The Website sends aggregated, non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance. For more information on how Google Analytics supports the Website and uses information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.

(c) Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Website. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.

(d) Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

(e) Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.

4. How We Use Your Information

The information we gather and that you provide is collected to provide you with relevant information and the Services you request, in addition to various other purposes, including, but not limited to:

• Provide, analyze, and improve the Services;
• Contact you;
• Send you information about additional clinical services or general wellness from us or on behalf of our affiliates;
• Conduct research using your information, which may be subject to your separate written authorization;
• Prevent potentially prohibited or illegal activities and otherwise in accordance with our Website Terms of Use; and
• For any other purposes disclosed to you at the time we collect your information pursuant to your consent, subject to any applicable limitation set forth under HIPAA and the HIPAA NPP.

5. How We Share Your Information

We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to our trusted third-party business partners in accordance with this Policy. We work with a number of partners that help us process your requests, deliver customer service and support, send email marketing communications, and provide high-quality experiences that you have come to expect from us. We will share your Personal Information with these third parties in order to allow them to fulfill the service that they provide to us. These third-party partners are under contract to keep your Personal Information secure and not to use it for any reason other than to fulfill the service we have requested from them.

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:

• Responding to duly authorized information requests from law enforcement or other governmental authorities.
• Complying with any law, regulations, subpoena, or court order.
• Investigating and helping prevent security threats, fraud, or other malicious activity.
• Enforcing or protecting the rights and properties of the Company or its subsidiaries.
• Protecting the rights or personal safety of Company employees.

There are circumstances where the Company may decide to buy, sell, reorganize, or merge its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your Personal Information is used in accordance with this Policy.

6. Your Choices and Selecting Your Privacy Preferences

We want to provide you with the relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertain to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or Service-oriented messages, such as appointment confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide Services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

7. Text Messaging

You may have the opportunity to receive SMS or “text” messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested. In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number in accordance with the Company’s Website Terms of Use. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us. You further acknowledge that no purchase is required to opt into this service, and you may opt out of receiving such texts at any time by following the instructions from CCAW. Therefore care should always be taken to limit the Personal Information included in such messages, especially protected health information.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

8. Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage, or contact us directly for assistance.

9. Information of Minors

We do not knowingly allow individuals under the age of eighteen (18) to create accounts that allow access to our Services. We do not target the Website to minors, and would not expect them to be engaging with our Website or Services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

10. Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Website may link to third-party websites and services. For example, if you click on an advertisement on this Website, you may be taken to another website that we do not own or control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

11. Your California Rights

Pursuant to California Civil Code Section 1798.83, we will not disclose or share your Personal Information with third parties for the purposes of third-party marketing to you without your prior consent.

Do-Not-Track Signals and Similar Mechanisms. Some web browsers transmit “do-not-track” signals to websites. Because of differences in how web browsers incorporate and activate this feature, it is not always clear whether users intend for these signals to be transmitted, or whether they even are aware of them. We currently do not take action in response to these signals.

CCAW is not a “business” under California Civil Code 1798.140. However CCAW provides that if you are a California consumer, as defined by the California Consumer Privacy Act of 2018, you may be afforded additional rights with respect to your “Personal Information” as that term is explicitly defined under California law. Any Personal Information we collect is collected for the commercial purpose of effectively providing our Services to you, as well as enabling you to learn more about, and benefit from, our services. You may exercise each of your rights as identified below, subject to our verification of your identity.

Access. You may email us at vso@theclinic.io”>vso@theclinic.io to request a copy of your Personal Information our Website databases currently contain.

Prohibit Data Sharing. When applicable, you may prohibit the sharing of your Personal Information by submitting a request via email to vso@theclinic.io”>vso@theclinic.io. In your email, please explain how you wish us to prohibit the sharing of your Personal Information, and which categories of third parties you want to prohibit from receiving your Personal Information. When such prohibitions are not possible as they would impact our ability to provide our Services to you, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.

Portability. Upon request and when possible, we can provide you with copies of your Personal Information. You may submit a request via email to vso@theclinic.io”>vso@theclinic.io. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy.

Deletion. If you should wish to cease use of our Website and have your Personal Information deleted from our Website, then you may submit a request by emailing us at vso@theclinic.io”>vso@theclinic.io. Upon receipt of such a request for deletion, we will confirm receipt and will confirm once your Personal Information has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.

In addition to the email address provided above, you may also submit requests at the following toll-free telephone number: 1-844-295-5883.

We do not sell your Personal Information. If we ever decide to sell Personal Information, we will update you via this Policy and include a link entitled “Do Not Sell My Personal Information,” to provide you with an opportunity to opt out of sales of your Personal Information.

If a California data subject exercises their rights under California law, including the CCPA, we shall not discriminate against that California resident by denying our Services, charging different prices or rates to similarly situated consumers, providing a different level or quality of our Services, or taking any other adverse action.

12. For Website Users Outside of the United States

Our Website is designed for use by individuals in the United States only. We do not warrant or represent this Policy or the Website’s use of your Personal Information complies with the laws of any other jurisdiction. Furthermore, to provide you with our Services, we may store, process, and transmit information in the United States and other locations around the world, including countries that may not have the same privacy and security laws as yours. Regardless of the country in which such information is stored, we will process your Personal Information in accordance with this Policy.

13. Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information, including PHI, against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us immediately of any actual or suspected unauthorized use.

14. Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through this Website. We are continually improving and adding to the features and functionality of this Website along with the Services we offer. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

15. How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please email vso@theclinic.io”>vso@theclinic.io.

CCAW JV, LLC’s
Website Privacy Policy

Last Revised: 11.19.21

1. General

We know that your privacy is important to you, and we work hard to earn and keep your trust. CCAW JV, LLC d/b/a The Clinic by Cleveland Clinic affiliates and related entities (“Company,” “the Company,” “we,” “us,” and “our,”) respects your privacy and is committed to protecting your privacy through our compliance with this Privacy Policy (the “Policy”), and any related data, accounts, profiles, forms, and all other content provided therein for the purposes of providing educational virtual second opinion services through the Website (the “Services”).

This Policy describes:

The types of information we collect from you or that you may provide when you visit our website available at:

• https://theclinic.io, https://globalvso.io/landing?instance=MyConsult as well as any websites directly owned by the Company (collectively, our “Website”).
• Our practices for collecting, using, maintaining, protecting, and disclosing that information.

This Policy applies to information we collect on this Website or in emails and other electronic messages between you, other users of the Services and the Company, and information gathered when you interact with the Website and Services as disclosed in this Policy.

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

2. Website Terms of Use; Other Agreements and Requirements

This Policy should be read in conjunction with any applicable Website Terms of Use, into which this Policy is incorporated by reference.

The laws that protect privacy and the confidentiality of individually identifiable health information, such as the Health Insurance Portability and Accountability Act (“HIPAA”) may also apply to telemedicine and may apply to certain aspects of the Services. Should you engage the Services, you will receive and have the opportunity to review, and you must acknowledge the Company’s Notice of Privacy Practices (“NPP”) prior to participating in the Services. The NPP explains how the Company may use and disclose individually identifiable health information for treatment, payment, and healthcare operations.

However, please note that not all information you provide or use through engagement of the Website or Services is necessarily protected by HIPAA. Regardless, your Personal Information will always be processed in accordance with this Policy. Should there ever be a conflict between this Policy and the NPP with respect to any Personal Information, the NPP shall apply.

3. What We Collect and How We Collect It

To ensure that we provide you with the best possible experience, we will store, use, and share information about you in accordance with this Policy.

Information You Provide to Us

Personal information is any information that can be used to individually identify you from a larger group (“Personal Information”), such as data including, but not limited to, your:

• first and last name;
• email address;
• telephone number;
• mailing address;
• date of birth;
• gender;
• healthcare provider reviews;
• health insurance identification number or other health insurance information;
• member login credentials (i.e., usernames and passwords); and
• credit card and other financial account information.

You may provide us Personal Information when you:

• register yourself with the Website;
• schedule an appointment;
• confirm an appointment;
• review or comment on the Services; or
• communicate with us, such as to request information.

The information that you provide in each case will vary. In some cases, you may be able to provide Personal Information via email or free text boxes, such as when contacting the Company to request further information. When providing your Personal Information, please provide only relevant information and do not provide unnecessary sensitive information, such as Social Security numbers, or other sensitive personal or financial data unless required for delivery of the Services.

Additionally, we may ask you to create a username and password that should only be known to you. When you provide this information to us, you are no longer anonymous. Moreover, we may receive information about you from other sources and add it to the information you have provided to us.

Automated Information Collection

In addition to the information that you provide to us, we may also collect information about you during your visit to our Website. We collect this information using automated tools that are detailed below. These tools may collect information about your behavior and your computer system, such as your internet address (IP Address), the pages you have viewed, and the actions you have taken while using the Website. Some of the tools we use to automatically collect information about you may include:

(a) Cookies. A “cookie” is a small data file transmitted from a website to your device’s hard drive. Cookies are usually defined in one of two ways, and we may use either (or both) of them:

1. session cookies, which do not stay on your device after you close your browser, and
2. persistent cookies, which remain on your device until you delete them or they expire.

We may use the following categories of cookies on our Website.

• Strictly Necessary Cookies. These cookies are essential in order to enable you to move around the Website and use its features. Without these cookies, services you have requested, such as maintaining a record of your purchased items (e.g. a shopping cart), cannot be provided.
• Performance Cookies. These cookies collect anonymous information on how you use our Website to help us understand how you arrive at our Website, browse or use our Website and highlight areas where we can improve, such as navigation. The data stored by these cookies never shows personal details from which your individual identity can be established.
• Functionality Cookies. These cookies remember choices you make such as the country from which you visit our Website, your preferred language, and your search parameters. This information can then be used to provide you with an experience more appropriate to your selections and to make your visits to our Website more tailored to your preferences. The information in these cookies may be anonymized. These cookies cannot track your browsing activity on other websites.
• Targeting Cookies or Advertising Cookies. These cookies collect information about your browsing habits in order to make advertising more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of an advertising campaign. The cookies are usually placed by third-party advertising networks.

Of course, if you do not wish to have cookies on your devices, you may turn them off at any time by modifying your internet browser’s settings. However, by disabling cookies on your device, you may be prohibited from full use of the Website’s features or lose access to some functionality.

(b) Google Analytics. The Website sends aggregated, non-Personal Information to Google Analytics for the purpose of providing us with the ability to conduct technical and statistical analysis on the Website’s performance. For more information on how Google Analytics supports the Website and uses information sent from the Website, please review Google’s privacy policy available at https://policies.google.com/technologies/partner-sites.

(c) Web Beacons. A Web Beacon is an electronic image. Web Beacons can track certain things from your computer and can report activity back to a web server allowing us to understand some of your behavior. If you choose to receive emails from us, we may use Web Beacons to track your reaction to our emails. We may also use them to track if you click on the links and at what time and date you do so. Some of the third-party marketers we engage with may use Web Beacons to track your interaction with online advertising banners on our Website. This information is only collected in aggregate form and will not be linked to your Personal Information. Please note that any image file on a webpage can act as a Web Beacon.

(d) Embedded Web Links. Links provided in our emails and, in some cases, on third-party websites may include tracking technology embedded in the link. The tracking is accomplished through a redirection system. The redirection system allows us to understand how the link is being used by email recipients. Some of these links will enable us to identify that you have personally clicked on the link and this may be attached to the Personal Information that we hold about you. This data is used to improve our service to you and to help us understand the performance of our marketing campaigns.

(e) Third-party Websites and Services. We work with a number of service providers of marketing communications technology. These service providers may use various data collection methods to improve the performance of the marketing campaigns we are contracting them to provide. The information collected can be gathered on our Website and also on the websites where our marketing communications are appearing. For example, we may collect data where our banner advertisements are displayed on third-party websites.

4. How We Use Your Information

The information we gather and that you provide is collected to provide you with relevant information and the Services you request, in addition to various other purposes, including, but not limited to:

• Provide, analyze, and improve the Services;
• Contact you;
• Send you information about additional clinical services or general wellness from us or on behalf of our affiliates;
• Conduct research using your information, which may be subject to your separate written authorization;
• Prevent potentially prohibited or illegal activities and otherwise in accordance with our Website Terms of Use; and
• For any other purposes disclosed to you at the time we collect your information pursuant to your consent, subject to any applicable limitation set forth under HIPAA and the HIPAA NPP.

5. How We Share Your Information

We do not sell or lease your Personal Information to any third party. We may disclose your Personal Information to our trusted third-party business partners in accordance with this Policy. We work with a number of partners that help us process your requests, deliver customer service and support, send email marketing communications, and provide high-quality experiences that you have come to expect from us. We will share your Personal Information with these third parties in order to allow them to fulfill the service that they provide to us. These third-party partners are under contract to keep your Personal Information secure and not to use it for any reason other than to fulfill the service we have requested from them.

Except as described in this Policy, we will not share your information with third parties without your notice and consent, unless it is under one of the following circumstances:

• Responding to duly authorized information requests from law enforcement or other governmental authorities.
• Complying with any law, regulations, subpoena, or court order.
• Investigating and helping prevent security threats, fraud, or other malicious activity.
• Enforcing or protecting the rights and properties of the Company or its subsidiaries.
• Protecting the rights or personal safety of Company employees.

There are circumstances where the Company may decide to buy, sell, reorganize, or merge its business in selected countries. Under these circumstances, it may be necessary to share or receive Personal Information with prospective or actual partners or affiliates. In such circumstances, the Company will ensure your Personal Information is used in accordance with this Policy.

6. Your Choices and Selecting Your Privacy Preferences

We want to provide you with the relevant information that you have requested. When possible, we will always provide options as to what information we collect and how you can manage any preferences that pertain to such information.

If we provide subscription-based services, such as email newsletters, we will allow you to make choices about what information you provide at the point of information collection or at any time after you have received a communication from us while you are subscribed. Transactional or Service-oriented messages, such as appointment confirmation messages, are usually excluded from such preferences, as such messages are required to respond to your requests or to provide Services, and are not intended for the purposes of marketing.

We will not intentionally send you email newsletters and marketing emails unless you consent to receive such marketing information. After you request to receive these emails, you may opt out of them at any time by selecting the “unsubscribe” link at the bottom of each email. Please note that by opting out or unsubscribing you may affect other services you have requested we provide to you, in which email communication is a requirement of the service provided.

7. Text Messaging

You may have the opportunity to receive SMS or “text” messages, pre-recorded voice messages or auto-dialed phone calls from the Company, its affiliates and related entities as well as third parties. Such messaging may be used to authenticate your identity or mobile device, as well as provide you informational updates about services or products you may have requested. In providing your mobile device number or cell phone number to the Company, you knowingly consent to such communications from the Company or for the Company to use your cell phone number or mobile device number in accordance with the Company’s Website Terms of Use. In providing your number, you represent that you have the authority to agree to receive text messages at the telephone number that you provide to the Company, or from which you sent the text message request to us. You further acknowledge that no purchase is required to opt into this service, and you may opt out of receiving such texts at any time by following the instructions from CCAW. Therefore care should always be taken to limit the Personal Information included in such messages, especially protected health information.

Any such communications you receive from us will be administered in accordance with your preferences and this Policy.

8. Accuracy and Access to Your Personal Information

We strive to maintain and process your information accurately. We have processes in place to maintain all of our information in accordance with relevant data governance frameworks and legal requirements. We employ technologies designed to help us maintain information accuracy on input and processing.

Where we can provide you access to your Personal Information in our possession, we will always ask you for a username and password to help protect your privacy and security. We recommend that you keep your password safe, that you change it periodically, and that you do not disclose it to any other person or allow any other person to use it.

To view and change the Personal Information that you have provided to us, you can log in to your account and follow the instructions on that webpage or contact us directly for assistance.

9. Information of Minors

We do not knowingly allow individuals under the age of eighteen (18) to create accounts that allow access to our Services. We do not target the Website to minors, and would not expect them to be engaging with our Website or Services. We encourage parents and guardians to provide adequate protection measures to prevent minors from providing information unwillingly on the internet. If we are aware of any Personal Information that we have collected about minors, we will take steps to securely remove it from our systems.

10. Third-party Websites

This Policy does not apply to websites or other domains that are maintained or operated by third parties or our affiliates. Our Website may link to third-party websites and services. For example, if you click on an advertisement on this Website, you may be taken to another website that we do not own or control. These links are not endorsements of these websites, and this Policy does not extend to them. Because this Policy is not enforced on these third-party websites, we encourage you to read any posted privacy policy of the third-party website before using the service or website and providing any information.

11. For Users in the United States

This Policy and Website are intended for Users based outside of the United States (“International Website Users”) only. If you are NOT an International Website User, please access our domestic Website and Privacy Policy.

12. Data Controller Contact Information

Under the (i) General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, or “GDPR”), (ii) Data Protection Act 2018, (iii) the GDPR as it forms part of the law of England and Wales, Scotland and Northern Ireland (i.e., “UK GDPR”) as provided in the Data Protection Act 2018, and (iv) any other applicable data protection legislation of any country or other jurisdiction (collectively “International Data Protection Laws”) individuals have specific rights with respect to their Personal Information, or “personal data” as defined under the International Data Protection Laws. For the purposes of this Policy, the Company operates as a data controller. Any personal data we collect from you is processed in the United States and under the terms of this Policy.

Any personal data we collect from you is processed in the legitimate interest of our business and providing our services to you as the lawful means of such processing. You may always withdraw your consent to our use of your personal data as described below. We will only retain your personal data for the time necessary to provide you the information and services to which you have consented, to comply with the law and in accordance with your rights below.

The Data Controllers are:
NAME: CCAW JV, LLC d/b/a The Clinic by Cleveland Clinic
ADDRESS: 10000 Cedar Avenue, Cleveland, OH 44106
EMAIL ADDRESS: vso@theclinic.io

13. International Website User/Visitor Rights

As an international user, you can exercise any of the following rights, subject to verification of your identity, by notifying us as described below:

Access. You may email us at vso@theclinic.io to request a copy of the personal data our Website databases currently contain.

Automated Processing and Decision-Making. You may email us at vso@theclinic.io to request that we stop using your personal data for automated processing, such as profiling. In your email, please explain how you wish us to restrict automated processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data.

Correction or Rectification. You can correct what personal data our Website database currently contains by accessing your account directly, or by emailing us at vso@theclinic.io to request that we correct or rectify any personal data that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause information to be incorrect. Where applicable, we will ensure such changes are shared with trusted third parties.

Restrict Processing. When applicable, you may restrict the processing of your personal data by submitting a request via email to vso@theclinic.io. In your email, please explain how you wish us to restrict processing of your personal data. When such restrictions are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

Object to Processing. When applicable, you have the right to object to the processing of your personal data by submitting a request via email to vso@theclinic.io. When such objections are not possible, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent to the processing of your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

Portability. Upon request and when possible, we can provide you with copies of your personal data. You may submit a request via email to vso@theclinic.io. When such a request cannot be honored, we will advise you accordingly. You can then choose to exercise any other rights under this Policy, to include withdrawing your consent. Where applicable, we will ensure such changes are shared with any trusted third parties.

Withdraw Consent. At any time, you may withdraw your consent to our processing of your personal data through this Website by notifying us via email at vso@theclinic.io. Using the same email address associated with your Website account, simply type the words “WITHDRAW CONSENT” in the subject line of your email. Upon receipt of such a withdrawal of consent, we will confirm receipt and proceed to stop processing your personal data. Where applicable, we will ensure such changes are shared with trusted third parties.

Erasure. If you should wish to cease use of our Website and have your personal data deleted from our Website, then you may submit a request by emailing us at vso@theclinic.io. Upon receipt of such a request for erasure, we will confirm receipt and will confirm once your personal data has been deleted. Where applicable, we will ensure such changes are shared with trusted third parties.

Submit Complaints or Questions. If you wish to raise a complaint on how we have handled your personal data, you can contact us as described below. You may also lodge a complaint in accordance with applicable Data Protection Laws. For example, if you reside in a European Union member state, you may lodge a complaint with the supervisory authority in your country. If you reside in the United Kingdom you may lodge a complaint with the United Kingdom’s Information Commissioner’s Office (UK ICO).

14. Countries to Which Your Personal Data May be Sent.

There may be instances where it may be necessary for us to transfer your information outside the European Union, United Kingdom, or other country where your data is collected (e.g., to our headquarters and various subsidiaries, or if we use third-party service providers from another country). In these circumstances, we will put in place suitable safeguards, for example an intra-group data transfer agreement or standard contractual clauses to ensure that your information is processed securely and in accordance with this Policy and applicable regulations. If you require further information about the safeguards we put in place, you can request such information by contacting us by email at vso@theclinic.io.

15. Safeguarding the Information We Collect

We use reasonable technical, administrative, and physical safeguards in order to protect your Personal Information, including PHI, against accidental loss and from unauthorized access, use, alteration, and disclosure. However, we can never promise 100% security. You have a responsibility, as well, to safeguard your information through the proper use and security of any online credentials used to access your Personal Information, such as a username and password. If you believe your credentials have been compromised, please change your password. Please also notify us immediately of any actual or suspected unauthorized use.

16. Changes to this Policy

This Policy describes our current policies and practices with regard to the information we collect through this Website. We are continually improving and adding to the features and functionality of this Website along with the Services we offer. If we make any changes to this Policy, a revised Policy will be posted on this webpage and the date of the change will be reported in the “Last Revised” block above. You can get to this page from any of our webpages by clicking on the “Privacy Policy” link (usually at the bottom of the screen).

17. How to Contact Us

We value your opinions and welcome your feedback. To contact us about this Policy or your Personal Information, please email vso@theclinic.io.