Privacy Policy Agreement

Welcome to MediFi. The MediFi platform includes the websites, mobile applications, and other platforms that link to this privacy policy (collectively, the “Platform”). The Platform is owned and operated by MediFi LLC, 640 South Montford Avenue, Baltimore, Maryland 21224 (together with its affiliates, “MediFi”).

This Privacy Policy (this “Policy”) is between MediFi and you, the individual using the Platform. PLEASE READ THIS POLICY CAREFULLY BEFORE ACCESSING OR USING ANY ASPECT OF THE PLATFORM.

MediFi knows that you care about your privacy and the protection of your personal information. MediFi also knows it has a responsibility to be clear about how it uses, discloses, and protects your personal information. MediFi has established this Policy to do just that. This Policy explains the types of personal information MediFi collects, and how it collects, uses, maintains, protects, and shares that personal information. This Policy also tells you about the rights and choices you may have when it comes to your personal information.

Some of what MediFi says in this Policy is required by law, and may at times seem long and complicated, but MediFi has worked hard to try to make this Policy easy to understand and provide examples where possible. If you have questions about this Policy, please contact MediFi via email to privacy@medifibillpay.com.

1. 1. Platform OverviewThis Policy applies only to MediFi’s actions with respect to the personal information that MediFi collects directly from you or from health care providers or other third parties (“Providers”) that has issued a Provider Bill (as defined in the Assignment Agreement).

      MediFi stores personal information in the United States. You consent to MediFi transferring personal information from your country of residence to the United States, and acknowledge that by doing so personal information may become subject to United States law.

   2. Collection of Personal InformationMediFi collects Personal Information as detailed in this section. “Personal Information” means any information relating to or reasonably capable of being associated with an identified or identifiable natural person or household.
      
      1. What Personal Information MediFi Collects:
         
         1. Identification Information. Information used to identify you as a Platform user, such as your name or Platform username.
         2. Contact Information. Information used to communicate with you, such as your email address, telephone number, or mailing address.
         3. Payment and Transaction Information. Information used to send or receive a payment, such as bank account number or payment card number. This also includes information about the payment, such as the amount, timestamp, and description.
         4. Health Information. Information directly or indirectly related to the services or supplies for which the Provider Bills were issued, including “protected health information” as such term is defined under U.S. Health Insurance Portability and Accountability Act.
         5. Preferences Information. To make data entry easier, the Platform may enable You to save certain pieces of information for future use, such as a preferred shipping method and preferred shipping address.
         6. Location Information. The location from which you are accessing the Platform. This location may be inferred from your IP address or may be explicit from the GPS coordinates of a mobile device (subject to your location-sharing settings on such device).
         7. Activity Information. MediFi collects certain information automatically about your use of the Platform and the device used to use the Platform. This information includes: (A) your activity within the Platform, such as pages visited and features used; and (B) information about the device being used to access the Platform, such as its IP address, Web browser, and other device identifiers.
      2. How MediFi Collects Personal InformationMediFi collects Personal Information in several ways. MediFi collects information when you provide MediFi with the information, such as when you create a Platform account, upload Provider Bills or otherwise use the Platform. MediFi may also collect information about you from its affiliates or other third parties, including: (i) information that a Provider provides us about you; (ii) identity verification information from third-party verification services and publicly-available sources; (iii) credit investigation, credit eligibility, or account verification information from third-party fraud services; and (iv) government databases and related resources that are either mandatory or recommended from time to time in connection with various regulations. This includes, without limitation, the receipt and exchange of account or credit-related information with any credit reporting agency or credit bureau, where lawful, and any person or corporation with whom you have had, currently have, or may have a financial relationship, including without limitation past, present, and future places of employment, financial institutions, and personal reporting agencies. If you believe that any of the information that MediFi has collected about you is incorrect, please contact MediFi at privacy@medifibillpay.com.
   3. How and When MediFi Uses Personal Information
      
      1. To Provide the Platform to You. MediFi uses your Personal Information for its legitimate interests in providing you with the Platform. This includes: (i) creating and maintaining a Platform account for you; (ii) enabling you to send and receive electronic invoices and payments; (iii) communicating with Providers (including their agents and representatives) regarding the Provider Bills, such as in connection with MediFi performing its duties, or availing itself of its rights, pursuant to the Assignment Agreement, (iv) communicating with you, such as responding to your requests for support; (v) analyzing and improving the Platform, such as understanding which features of the Platform are most frequently used by you and other Platform users; (vi) investigating fraud and securing the Platform, such as detecting unauthorized use of the Platform or your Platform account; (vii) creating aggregate statistics regarding the Platform for marketing and promotional purposes; and (viii) sending you marketing about the Platform, which marketing might be personalized based on your Platform account.
      2. To Improve Our Products and Services. MedFi uses your Personal Information for its legitimate interests in improving its business. This includes: (i) analyzing its current products and services; (ii) developing new products and services; (iii) managing and evaluating the effectiveness of its communications; (iv) performing analytics, such as measuring, tracking, and evaluating trends and usage of MediFi’s different products and services; and (v) doing internal research.
      3. Protecting the Platform and Complying with Law. MediFi uses your Personal Information for its legitimate interests in securing the Platform and complying with law. This includes: (i) conducting investigations, complying with and enforcing applicable laws, regulations, legal requirements and industry standards, and responding to lawful requests for information from the government or to valid legal process; (ii) contacting you to resolve disputes with Clients; (iii) debugging to identify and repair errors that impair how the Platform functions; (iv) enforcing MediFi’s agreements, policies and terms; and (v) investigating, detecting, preventing, recovering from, or reporting fraud, misrepresentations, security breaches or incidents, or other potentially prohibited, malicious, or illegal activities.
      4. Otherwise with Your Approval. MediFi uses your Personal Information as otherwise approved by you from time-to-time, which approval may be through the Platform interface.
   4. When and With Whom MediFi Shares Personal InformationMediFi may share your Personal Information with the following categories of third parties:
      
      1. With Providers. When you use the Platform to upload Provider Bills, we share or receive your Personal Information with or from the Provider as part of the core Platform usage.
      2. With Affiliates. MediFi may share your Personal Information with any affiliated company (including any successor), for purposes of helping us exercise or rights or perform our obligations with respect to the Platform.
      3. With Service Providers. MediFi may share your Personal Information with any service provider that MediFi uses to help it exercise its rights and perform its obligations with respect to the Platform.
      4. With Advertising Companies. MediFi may share your Personal Information with advertising companies that run advertising campaigns, contests, special offers, or other events or activities on its behalf or in connection with the Platform.
      5. With an Acquirer. MediFi may share your Personal Information with a subsequent owner, co-owner, or operator of the Platform, or if MediFi does or tries to do a corporate merger, consolidation, or restructuring (including during due diligence and negotiation of these) or sell substantially all of its assets.
      6. As Required for Safety and Compliance with Law. MediFi may share your Personal Information if it believes that sharing is reasonably necessary: (i) to comply with any applicable law, regulation, legal process or governmental request (e.g., from creditors, tax authorities, law enforcement agencies, in response to a garnishment, levy, or lien notice, etc.); (ii) to establish, exercise or defend its legal rights; (iii) to enforce or comply with its agreements or policies; (iv) to protect its or its customers’ rights or property, or the security or integrity of the Platform; (v) for an investigation of suspected or actual illegal activity; or (vi) to protect MediFi, users of the Platform, or the public from harm, fraud, or potentially prohibited or illegal activities.
      7. Otherwise With Your Approval. MediFi may share your Personal Information as otherwise approved by you from time-to-time, which approval may be through the Platform interface.
   5. How MediFi Protects Personal InformationMediFi follows industry-standard practices to prevent the unauthorized access, use, or disclosure of any Personal Information it collects and maintains. These practices include technical, administrative, and physical safeguards, which may vary, depending on the type and sensitivity of the information. Although MediFi takes the responsibility of safeguarding your Personal Information seriously, no security measures are 100% effective and MediFi cannot guarantee that these practices will prevent every unauthorized attempt to access, use, or disclose your Personal Information.

      You are responsible for keeping your Platform username and password secret.

   6. For How Long MediFi Keeps Personal InformationMediFi keeps Personal Information for different lengths of time depending on the type of information and the business and legal requirements. For example, if you have an account for the Platform, then MediFi keeps your Personal Information for as long as that account exists. If you no longer have an account for the Platform, MediFi still may need that information for business and legal requirements, such as to protect against fraud, calculate taxes, respond to legal requests, or comply with a third- party requirement (e.g., NACHA). Other information is deleted automatically after a set period of time, often set by law, unless MediFi is legally required to hold it longer, such as for pending litigation. MediFi will destroy, de-identify, or anonymize Personal Information when it is no longer needed in identifiable form.
   7. Your Choices Regarding Personal Information
      
      1. Right to Access, Delete, Correct, Modify, Object, or Restrict. You may have the right to: (i) access, delete, correct, or modify your entire Platform account, or information contained therein; and (b) object to or restrict MediFi’s processing of your Personal Information.You may take many of these actions yourself through the features made available to you in the Platform, or you may have MediFi take any of these actions for you by contacting MediFi at privacy@medifibillpay.com or MediFi, LLC, Attention: Privacy Compliance, PO Box [ ], Alexandria, VA 22315- .

         MediFi may refuse a request if permitted by law, or if it would violate another person’s rights. If MediFi refuses your request, MediFi will tell you why the request was refused.

      2. Right to Know. You have the right to know whether MediFi has collected Personal Information from you. You may submit up to two access requests within a 12-month period asking MediFi to tell you:
         • the categories or specific pieces of Personal Information that MediFi has collected from you;
         • the categories of sources from which MediFi has collected your Personal Information;
         • the reasons why MediFi collects Personal Information; and
         • the categories of third parties with which MediFi shares Personal Information.
      3. MediFi’s Response. MediFi will respond to requests within a reasonable timeframe. If MediFi requires additional time, then MediFi will acknowledge receipt of your request within a reasonable timeframe and promptly supplement its response within the time period required by applicable law. While MediFi makes efforts to accommodate requests to restrict MediFi’s use of your Personal Information, MediFi reserves the right to delete all or any portion of your Personal Information if MediFi is not able to reasonably accommodate a requested restriction.
      4. Email Marketing. Each marketing email sent by MediFi will contain information on how to unsubscribe from MediFi’s marketing mailing list. You can also unsubscribe by sending an email with the subject line “Unsubscribe” to privacy@medibillpay.com.
      5. Interest-Based Advertising and Cookies. For choices regarding cookies and interest-based advertising, please see the relevant sections, below.
   8. Cookies

      MediFi and its partners use cookies to analyze trends, administer websites, track users’ movements around the Platform, and to gather demographic information about its user base as a whole. Cookies help personalize and maximize your use of the Platform, including storing user preferences, improving search results and ad selection, and tracking user trends. You can control your cookies, on a per- Web-browser basis, but if you disable cookies, it may limit your ability to use certain features or functions on the Platform. To learn more about cookies, please visit http://www.allaboutcookies.org.

      MediFi uses the following types of cookies:

      1. Security. These cookies allow MediFi to secure access to your Platform account.
      2. Preference. These cookies are used to store your Platform preferences, such as language choice and preferred mailing address
      3. Analytics. These cookies use a unique identifier so that MediFi can differentiate between your and other users’ interaction with the Platform. Specifically, MediFi uses the third-party analytics service Google Analytics. To learn more about Google Analytics and how to opt out, please visit https://marketingplatform.google.com/about/ or https://support.google.com/analytics/answer/181 881?hl=en.
      4. Advertising. These cookies are used to show you relevant marketing, advertising, and other content on the Platform and third-party sites.

         You can use the methods described below to manage cookies. You must take these steps on each browser or device that you use to access the Platform. If you replace, change, or upgrade your browser or device, or delete your cookies, then you may need to use these opt-out tools again.

      5. Browser Controls. You may be able to disable and manage some cookies through your browser settings. If you use multiple browsers on the same device, then you will need to manage your settings for each browser. Please click on any of the below browser links for instructions:

         Google Chrome

         Apple Safari

         Mozilla Firefox

         Microsoft Internet Explorer

         If the browser you use is not listed above, please refer to your browser’s help menu for information on how to manage cookies. Please be aware that disabling cookies will not disable other analytics tools MediFi may use to collect information about you or your use of the Platform.

      6. Flash Local Storage. Flash cookies (also known as “local shared objects”) need to be deleted in the storage section of your Flash Player Settings Manager.
      7. Targeted Advertising. Most third-party advertisers offer a way to opt out of their targeted advertising. For more information visit the section regarding “Interest-Based Advertising,” below. After you opt out, you will still see marketing, advertisements, and other content, but they may not be as relevant to You.
   9. Interest-Based Advertising and Ad Choices

      The Platform adheres to the Digital Advertising Alliance’s Self-Regulatory Principles. For more information or to opt out of receiving targeted advertising from participating third-party advertisers, please visit https://youradchoices.com.

      If you would like to opt out of browser-based cross-device tracking for advertising purposes, you may do so by opting out using the various methods described in the section regarding “Cookies.” You must opt out separately on each device and each browser that you use to access the Platform. For more information about cross-device matching, please visit the Network Advertising Initiative or the Digital Advertising Alliance. If you opt out of cross-device tracking for advertising purposes, MediFi may still conduct cross-device tracking for other purposes, such as analytics.

      After you opt out from interest-based advertising, you will still see marketing, advertisements, and other content, but they may not be as relevant to you.

   10. “Do Not Track” Signals

       The Platform does not respond to “Do Not Track” signals sent from Web browsers, because definitions and rules for a “Do Not Track” standard have not yet been established.

   11. Changes

       MediFi may change this Policy over time as regulations, its business needs and the needs of its users change. If MediFi makes material changes to this Policy that increase its rights to use or share Personal Information that it has previously collected about you, then MediFi will notify you through written, electronic, or other means so that you can make any necessary decisions about your ongoing use of the Platform.

   12. How to Contact MediFi

       MediFi is the legal entity determining the purposes and means of processing the information gathered on the Platform, and is the data controller of all data the Platform collects from you.

       If You have any questions regarding MediFi’s processing of Personal Information, please email privacy@medifibillpay.com or write to MediFi at the mailing address earlier in this section.